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[BOAI] Re: HEFCE's Open Access consultation announced

From: Stevan Harnad <amsciforum AT gmail.com>
Date: Wed, 24 Jul 2013 20:43:19 -0400


Threading: [BOAI] Re: Research Community Interests and the Publishing Lobby's Latest Trojan Horse (CHORUS) from amsciforum AT gmail.com
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On Wed, Jul 24, 2013 at 9:15 AM, Alma Swan <a.swan AT talk21.com> wrote:

>  The UK=92s Higher Education Funding Council for England has announced it=
s
> consultation on Open Access in the post-2014 Research Excellence Framewor=
k.
> Details can be downloaded from
> http://www.hefce.ac.uk/pubs/year/2013/201316/#d.en.82765
>
> Responses should be made online by 1700 GMT on 30 October 2013.
>
> Alma Swan
> SPARC Europe
>

HARNAD Replies to HEFCE REF OA Policy Consultation questions


Question 1

*Do you agree that the criteria for open access are appropriate (subject to
clarification on whether accessibility should follow immediately on
acceptance or on publication)?*

*Yes. *

1.1 The HEFCE REF OA Policy should apply to the refereed, accepted version
of peer-reviewed research articles or refereed conference articles.

1.2 It should be deposited in the author=92s HEI repository, immediately up=
on
acceptance for publication.

1.3 Access to the deposit should be immediately Open Access where possible,
or, where deemed necessary, it can be made Closed Access if the publisher
requires an OA embargo.

1.4 The crucial thing is that the deposit should be made *at time of
acceptance, time-stamped as such, with a copy of the acceptance letter to
serve as the date marker.*

*Comments:*

The proposal is excellent. And if adopted and effectively implemented, it
will serve as a model for OA policies worldwide.


Question 2

*Do you agree with the role outlined for institutional repositories,
subject to further work on technical feasibility?*

*Yes.*

Fortunately, most UK HEI institutions already have institutional
repositories (IRs) that are already configured, or readily configurable, to
be compliant with HEFCE=92s proposed policy for REF. They also already have=
 a
date of deposit tag. The dated acceptance letter can be uploaded as a
supplementary document. The full text can be uploaded with access set as
either Open Access or Closed Access (during an embargo, in which case the
repositories also have a facilitated *eprint request Button* that can tide
over the usage needs of UK and worldwide researchers for the deposited
research during the allowable embargo).

Many HEIs are already use their IRs for submission to REF. The only change
required by the HEFCE policy will be to require the deposit to be made
immediately upon acceptance, rather than in batch, at the end of the year,
or the end of the REF cycle. But this is the crucial core of the policy
(and what will also make it an effective compliance mechanism for the RCUK
Mandate as well).

The IR software is also easily configurable so researchers can keep
updating their REF choices as they publish further articles, substituting a
later one for an earlier one, if they judge it more suitable for REF. What
is brilliant about the HEFCE proposal is that it ensures that all
potentially suitable articles are deposited immediately, in order to ensure
that they are eligible, even if they might later be superseded by a more
suitable article.

*Should the criteria require outputs to be made accessible through
institutional repositories at the point of acceptance or the point of
publication?*

*Deposit should definitely be required at point of acceptance rather than
at point of publication*, for the following reasons:

1.     The point of acceptance has a definite date, with the editor=92s dat=
ed
letter of acceptance serving as the time marker.

2.     The point of acceptance is also the natural point in the author=92s
workflow to do the deposit, again marked by a clear, unambiguous, dated
event: the letter of acceptance for publication.

3.     The date of publication is extremely vague and uncertain for
journals.

4.     The author does not know, at point of acceptance, when the article
will be published.

5.     The publication date of the article often has no calendar date.

6.     The publication date usually does not correspond to the date at
which an article actually appears: the article may appear earlier than the
publication date, but more often it appears later, sometime very much
later.

7.     The author often only finds out the date of publication after the
fact =96 sometimes long after the fact.

8.     All these possibilities are vague and uncertain, and the span of
uncertainty can be from several months to two years or even more, which is
even longer than most publishers=92 OA embargo length.

9.     Hence publication date is no basis for reliably and systematically
complying with a HEFCE immediate-deposit requirement by the author, nor for
monitoring and ensuring fulfilment by the author=92s HEI or by HEFCE.

10.  A further advantage of the acceptance date is that it is earlier, and
hence allows more and earlier access and usage of the funded research.

*Do you have any comments on these proposals?*

IR deposit, at point of acceptance, is a simple, clear, natural, readily
implementable and verifiable procedure for the author, the HEI and HEFCE,
as well as an excellent compliance verification mechanism for the RCUK OA
mandate. It is also an optimal model for the rest of the research world to
adopt globally. With it, HEFCE will be performing a great service not only
for UK and worldwide access to UK research output, but also for UK access
to the rest of the world=92s research output, with an exemplary policy,
suited for use by all.


Question 3

*Do you agree that the proposed embargo periods should apply by REF main
panel, as outlined above?*

*Yes.*

The length of the embargo is far less important than the requirement to
deposit in the author=92s institutional repository, and to deposit
immediately upon acceptance.

Embargoes should be as short as possible, but they can, if desired, be
allowed to vary by discipline. The IRs have the facilitated *eprint request
Button* to help tide over the usage needs of UK and worldwide researchers
for the deposited research during the allowable embargo.

*Do you agree with the proposed requirements for appropriate licences?*

It is not clear from the documentation what these license/re-use
requirements will be. I strongly urge not get bogged down in them. We are
talking here about UK research output. Once it is deposited and any embargo
elapses, deposits will be OA and hence can be searched, linked, downloaded,
printed, stored and text-mined by individual researchers and research
groups. They will also be harvested and full-text inverted for Boolean
search by Google and other harvesters. *All of this comes with the
territory in making them Open Access, and does not require any further
license.*

What would require further license permissions would be the right for
databases to harvest, data-mine and republish the texts. Do not get bogged
down in this now, if it creates any obstacles. We are only talking about UK
research output: 6% of worldwide research output. If the rest of the world
adopts the HEFCE immediate-deposit requirement too, OA will become 100%
globally, and all re-use rights authors wish to provide and users need will
follow soon after. But it would be a needless risk to let licensing
requirements hold back adoption or compliance of the HEFCE OA policy at
this point. And there are discipline differences here too, potentially even
bigger ones than differences in embargo length.

Go easy on licensing: It will all come after the HEFCE policy succeeds and
is adopted worldwide. Don=92t let licenses and re-use rights become a
sticking point even before the HEFCE mandate is adopted. Access is
infinitely more urgent than re-use/license needs; access needs are
universal across disciplines; re-use/license needs are not. And access is a
prerequisite for re-use rights, not vice versa. First things first.

*Do you have any comments on these proposals?*

Be flexible and pragmatic on licensing. Immediate IR deposit is the crucial
thing.


Question 4

*Do you agree that the criteria for open access should apply only to
journal articles and conference proceedings for the post-2014 REF?*

*Yes.*

Refereed journal articles and refereed conference articles have from its
inception been the primary targets of the worldwide Open Access movement,
because they are the only form of research output that is, without
exception, author giveaway content, written only for research uptake and
impact, not for royalty revenue.

It is for this reason that all authors of articles will readily comply with
an OA mandate: They all want their findings to be accessible to all their
potential users worldwide, not just to those at institutions that can
afford subscription access to the journal in which it happens to be
published.

For researchers, loss of access to their work means loss of uptake, usage,
applications and impact for their work. And the progress and funding of
their research, as well as their careers, depend on the uptake, usage,
applications and impact of their work.

*Books**.* But all of this becomes much more complicated and
exception-ridden when we move to monographs and books. Some books may fall
in the same motivational framework, but many are written in hope of royalty
income, so authors are not eager to give them away free for all. Also the
economics of book publication entail a much bigger investment in each book
by the publisher, who would likewise be reluctant to make the investment if
the book was made available as an online give-away.

But there is a simple solution for books: *Don=92t require them to be
deposited, just recommend it.* And authors have the option of depositing
books as Closed Access rather than Open Access, with no limit on how long
they can embargo OA. (Meanwhile, if they wish, they can provide individual
copies via the Button as and when they choose.)

*Data**.* Data are complicated in another way. The problem is not potential
royalties but *first-exploitation* rights. Researchers are not just
data-gatherers. They gather data because they want to do something with it.
To analyze and process it. They must be given a fair allotment of time to
do this. Otherwise, if they must make their data open to all immediately,
so anyone can analyze it, then they may as well not bother gathering it at
all, and simply wait to analyze the data that *others* have taken the time
and trouble to gather =96 and were then obliged to make open immediately.

The moral is that if article embargo lengths and licensing needs vary from
discipline to discipline, then the fair length of the period of exclusive
first-exploitation rights for data varies even more, not just from
discipline to discipline, but from research project to research project.

And again the solution is to encourage (but not require) depositing the
data and making it open as soon as possible. But no fixed embargo lengths.

*Comments:*

A successful HEFCE immediate-deposit policy for refereed journal and
conference articles will be an enormous positive contribution, and more
than enough as a first step. All the rest (re-use rights, the gradual
disappearance of article OA embargoes, and the extension of OA to other
kinds of content) will follow as a natural matter of course. It should not
be allowed to complicate what is otherwise an extremely timely and powerful
means of making UK research articles OA.


Question 5

*Do you agree that a notice period of two years from the date of the policy
announcement is appropriate to allow for the publication cycle of journal
articles and conference proceedings?*

            *No.*

I think two years is needlessly and unjustifiably long.

We are still now in the phase of REF 2014. As soon as that ends,
researchers and HEIs begin to prepare for REF 2020.

There is no reason at all why immediate-deposit upon acceptance for
articles accepted for publication starting 2014 should not begin in 2014
rather than in 2016, as a condition for REF 2020 eligibility.

Not even those HEIs that don=92t yet have IRs should be exceptions: Their
authors can start depositing at once in OpenDepot, the UK back-up
repository designed for that purpose.

*Comments:*

That said, there is no reason why HEFCE cannot show some flexibility in the
first two years, for inadvertent failures to comply immediately. But this
potential flexibility should not be publicized, for it will only encourage
lax compliance during the two designated years.


Question 6

*Do you agree that criteria for open access should apply only to those
outputs listing a UK HEI in the output=92s =91address=92 field for the post=
-2014
REF?*

*No.*

Every UK researcher who is submitting an article for REF should have to
deposit it in their IR immediately upon acceptance (except if they came to
the institution after the acceptance date).

*Comments:*

Better to be as inclusive as possible and handle would-be exceptions on a
case by case basis rather than declare explicit exceptions.


Question 7

*Which approach to allowing exceptions is preferable? *

I support *Option a**:* Full compliance; exceptions considered on case by
case basis, first by the HEI, and if not resolved, by the REF panel.

*There will be no basis for objections by publishers to immediate-deposit
in Closed Access.* The embargo length for Open Access is less important
(because of the Button) and will not (and should not) constrain authors=92
choice of journals).

External collaborators will certainly not object to Closed Access
immediate-deposit, and are very unlikely to object to OA either =96 and
certainly not post-embargo OA.

*Do you have any comments on these proposals?*

Percentage compliance criteria would be a very bad idea, and would
virtually be inviting institutions not to strive for 100%. Case-by-case
handling is an infinitely better way to exercise flexibility.

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On Wed, Jul 24, 2013 at 9:15 AM, Alma Swan <span 
dir=3D"ltr">&lt;<a href=3D=
"mailto:a.swan AT talk21.com" target=3D"_blank">a.swan 
AT talk21.com</a>&gt;</spa=
n> wrote:<br><div class=3D"gmail_quote"><blockquote 
class=3D"gmail_quote" s=
tyle=3D"margin:0 0 0 .8ex;border-left:1px #ccc 
solid;padding-left:1ex">





<div>
<font face=3D"Calibri, Verdana, Helvetica, Arial"><span 
style=3D"font-size:=
12pt">The UK=92s Higher Education Funding Council for England has 
announced=
 its consultation on Open Access in the post-2014 Research Excellence Frame=
work. Details can be downloaded from <a 
href=3D"http://www.hefce.ac.uk/pubs=
/year/2013/201316/#d.en.82765" 
target=3D"_blank">http://www.hefce.ac.uk/pub=
s/year/2013/201316/#d.en.82765</a><br>


<br>
Responses should be made online by 1700 GMT on 30 October 
2013.<span><font =
color=3D"#888888"><br>
<br>
Alma Swan<br>
SPARC 
Europe</font></span></span></font></div></blockquote><div><br></div><=
div>














<h2><span lang=3D"EN-GB"><font>HARNAD Replies to 
HEFCE REF OA Policy Consul=
tation
questions</font></span></h2>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><span 
lang=3D"EN-GB">=
=A0</span></p>

<h3><span lang=3D"EN-GB">Question 
1</span></h3>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Do you agree that the criteria for open access are
appropriate (subject to clarification on whether accessibility should follo=
w
immediately on acceptance or on publication)?</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><i><u><span 
lang=3D"EN-GB">Yes.
</span></u></i></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">1.1 
The HEFCE REF OA Poli=
cy should apply
to the refereed, accepted version of peer-reviewed research articles or
refereed conference articles. </span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">1.2 
It should be deposite=
d in the author=92s
HEI repository, immediately upon acceptance for publication. 
</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">1.3 
Access to the deposit=
 should be
immediately Open Access where possible, or, where deemed necessary, it can =
be
made Closed Access if the publisher requires an OA embargo. 
</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">1.4 
The crucial thing is =
that the deposit
should be made <i>at time of acceptance,
time-stamped as such, with a copy of the acceptance letter to serve as the =
date
marker.</i></span></p>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Comments:</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">The 
proposal is excellent=
. And if adopted
and effectively implemented, it will serve as a model for OA policies
worldwide.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><span 
lang=3D"EN-GB">=
=A0</span></p>

<h3><span lang=3D"EN-GB">Question 
2</span></h3>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:0cm"><b><span 
lang=3D"EN-GB">Do you agree with =
the role outlined for
institutional repositories, subject to further work on technical feasibilit=
y?</span></b></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><i><u><span lan=
g=3D"EN-GB">Yes.</span></u></i></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">Fortunately, most UK HEI institutions already
have institutional repositories (IRs) that are already configured, or readi=
ly
configurable, to be compliant with HEFCE=92s proposed policy for REF. They =
also
already have a date of deposit tag. The dated acceptance letter can be uplo=
aded
as a supplementary document. The full text can be uploaded with access set =
as
either Open Access or Closed Access (during an embargo, in which case the
repositories also have a facilitated <i>eprint
request Button</i> that can tide over the usage needs of UK and worldwide 
r=
esearchers
for the deposited research during the allowable 
embargo).</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">Many HEIs are already use their IRs for
submission to REF. The only change required by the HEFCE policy will be to
require the deposit to be made immediately upon acceptance, rather than in
batch, at the end of the year, or the end of the REF cycle. But this is the
crucial core of the policy (and what will also make it an effective complia=
nce
mechanism for the RCUK Mandate as well).</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">The IR software is also easily configurable
so researchers can keep updating their REF choices as they publish further
articles, substituting a later one for an earlier one, if they judge it mor=
e
suitable for REF. What is brilliant about the HEFCE proposal is that it ens=
ures
that all potentially suitable articles are deposited immediately, in order =
to
ensure that they are eligible, even if they might later be superseded by a =
more
suitable article.</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:0cm"><b><span 
lang=3D"EN-GB">Should the criteri=
a require outputs to be
made accessible through institutional repositories at the point of acceptan=
ce
or the point of publication?</span></b></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><i><span lang=
=3D"EN-GB">Deposit should definitely
be required at point of acceptance rather than at point of publication</spa=
n></i><span lang=3D"EN-GB">, for the following 
reasons:</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">1.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">The point of acceptance has a
definite date, with the editor=92s dated letter of acceptance serving as th=
e time
marker.</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">2.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">The point of acceptance is also
the natural point in the author=92s workflow to do the deposit, again marke=
d by a
clear, unambiguous, dated event: the letter of acceptance for publication.<=
/span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">3.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">The date of publication is
extremely vague and uncertain for journals. </span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">4.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">The author does not know, at point
of acceptance, when the article will be published.</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">5.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">The publication date of the
article often has no calendar date.</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">6.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">The publication date usually does
not correspond to the date at which an article actually appears: the articl=
e
may appear earlier than the publication date, but more often it appears lat=
er,
sometime very much later. </span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">7.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">The author often only finds out
the date of publication after the fact =96 sometimes long after the fact.</=
span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">8.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">All these possibilities are vague
and uncertain, and the span of uncertainty can be from several months to tw=
o
years or even more, which is even longer than most publishers=92 OA embargo
length. </span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">9.<span style=3D"f=
ont-size:7pt;font-family:&#39;Times New 
Roman&#39;">=A0=A0=A0=A0 </span></s=
pan><span lang=3D"EN-GB">Hence publication date is no basis
for reliably and systematically complying with a HEFCE immediate-deposit
requirement by the author, nor for monitoring and ensuring fulfilment by th=
e
author=92s HEI or by HEFCE.</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:54.0pt"><span 
lang=3D"EN-GB">10.<span style=3D"=
font-size:7pt;font-family:&#39;Times New Roman&#39;">=A0 
</span></span><spa=
n lang=3D"EN-GB">A further advantage of the
acceptance date is that it is earlier, and hence allows more and earlier ac=
cess
and usage of the funded research.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Do you have any
comments on these proposals?</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">IR
deposit, at point of acceptance, is a simple, clear, natural, readily
implementable and verifiable procedure for the author, the HEI and HEFCE, a=
s
well as an excellent compliance verification mechanism for the RCUK OA mand=
ate.
It is also an optimal model for the rest of the research world to adopt
globally. With it, HEFCE will be performing a great service not only for UK=
 and
worldwide access to UK research output, but also for UK access to the rest =
of
the world=92s research output, with an exemplary policy, suited for use by =
all.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><span 
lang=3D"EN-GB">=
=A0</span></p>

<h3><span lang=3D"EN-GB">Question 
3</span></h3>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:0cm"><b><span 
lang=3D"EN-GB">Do you agree that =
the proposed embargo
periods should apply by REF main panel, as outlined 
above?</span></b></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><u><span lang=
=3D"EN-GB">Yes.</span></u></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">The length of the embargo is far less
important than the requirement to deposit in the author=92s institutional
repository, and to deposit immediately upon acceptance.=A0 
</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">Embargoes should be as short as possible, but
they can, if desired, be allowed to vary by discipline. The IRs have the
facilitated <i>eprint request Button</i> to
help tide over the usage needs of UK and worldwide researchers for the
deposited research during the allowable embargo.</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:0cm"><b><span 
lang=3D"EN-GB">Do you agree with =
the proposed requirements
for appropriate licences?</span></b></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">It is not clear from the documentation what
these license/re-use requirements will be. I strongly urge not get bogged d=
own
in them. We are talking here about UK research output. Once it is deposited=
 and
any embargo elapses, deposits will be OA and hence can be searched, linked,
downloaded, printed, stored and text-mined by individual researchers and
research groups. They will also be harvested and full-text inverted for Boo=
lean
search by Google and other harvesters. <i>All
of this comes with the territory in making them Open Access, and does not
require any further license.</i></span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">What would require further license
permissions would be the right for databases to harvest, data-mine and
republish the texts. Do not get bogged down in this now, if it creates any
obstacles. We are only talking about UK research output: 6% of worldwide
research output. If the rest of the world adopts the HEFCE immediate-deposi=
t
requirement too, OA will become 100% globally, and all re-use rights author=
s
wish to provide and users need will follow soon after. But it would be a
needless risk to let licensing requirements hold back adoption or complianc=
e of
the HEFCE OA policy at this point. And there are discipline differences her=
e
too, potentially even bigger ones than differences in embargo length.</span=
></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">Go easy on licensing: It will all come after
the HEFCE policy succeeds and is adopted worldwide. Don=92t let licenses an=
d
re-use rights become a sticking point even before the HEFCE mandate is adop=
ted.
Access is infinitely more urgent than re-use/license needs; access needs ar=
e
universal across disciplines; re-use/license needs are not. And access is a
prerequisite for re-use rights, not vice versa. First things 
first.</span><=
/p>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Do you have any
comments on these proposals?</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">Be
flexible and pragmatic on licensing. Immediate IR deposit is the crucial th=
ing.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span 
lang=3D"EN-GB">=A0</span></p>

<h3><span lang=3D"EN-GB">Question 
4</span></h3>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Do you agree that
the criteria for open access should apply only to journal articles and conf=
erence
proceedings for the post-2014 REF?</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><u><span 
lang=3D"EN-GB">Yes.</span></u></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span 
lang=3D"EN-GB">Refereed
journal articles and refereed conference articles have from its inception b=
een
the primary targets of the worldwide Open Access movement, because they are=
 the
only form of research output that is, without exception, author giveaway
content, written only for research uptake and impact, not for royalty reven=
ue.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">It is
for this reason that all authors of articles will readily comply with an OA
mandate: They all want their findings to be accessible to all their potenti=
al
users worldwide, not just to those at institutions that can afford subscrip=
tion
access to the journal in which it happens to be 
published.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">For
researchers, loss of access to their work means loss of uptake, usage,
applications and impact for their work. And the progress and funding of the=
ir
research, as well as their careers, depend on the uptake, usage, applicatio=
ns
and impact of their work.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><b><i><span 
lang=3D"EN-GB">Books</span></i></b=
><b><span 
lang=3D"EN-GB">.</span></b><span 
lang=3D"EN-GB"> But all
of this becomes much more complicated and exception-ridden when we move to
monographs and books. Some books may fall in the same motivational framewor=
k,
but many are written in hope of royalty income, so authors are not eager to
give them away free for all. Also the economics of book publication entail =
a
much bigger investment in each book by the publisher, who would likewise be
reluctant to make the investment if the book was made available as an onlin=
e
give-away.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">But
there is a simple solution for books: <i>Don=92t
require them to be deposited, just recommend it.</i> And authors have the
option of depositing books as Closed Access rather than Open Access, with n=
o
limit on how long they can embargo OA. (Meanwhile, if they wish, they can
provide individual copies via the Button as and when they 
choose.)</span></=
p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><b><i><span 
lang=3D"EN-GB">Data</span></i></b>=
<b><span lang=3D"EN-GB">.</span></b><span 
lang=3D"EN-GB"> Data
are complicated in another way. The problem is not potential royalties but =
<i>first-exploitation</i> rights. Researchers
are not just data-gatherers. They gather data because they want to do somet=
hing
with it. To analyze and process it. They must be given a fair allotment of =
time
to do this. Otherwise, if they must make their data open to all immediately=
, so
anyone can analyze it, then they may as well not bother gathering it at all=
,
and simply wait to analyze the data that <i>others</i>
have taken the time and trouble to gather =96 and were then obliged to make=
 open
immediately.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">The
moral is that if article embargo lengths and licensing needs vary from
discipline to discipline, then the fair length of the period of exclusive
first-exploitation rights for data varies even more, not just from discipli=
ne
to discipline, but from research project to research 
project.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">And
again the solution is to encourage (but not require) depositing the data an=
d
making it open as soon as possible. But no fixed embargo 
lengths.</span></p=
>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Comments:</span><span 
lang=3D"EN-GB"></span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">A 
successful HEFCE immedi=
ate-deposit
policy for refereed journal and conference articles will be an enormous
positive contribution, and more than enough as a first step. All the rest
(re-use rights, the gradual disappearance of article OA embargoes, and the
extension of OA to other kinds of content) will follow as a natural matter =
of
course. It should not be allowed to complicate what is otherwise an extreme=
ly
timely and powerful means of making UK research articles 
OA.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span 
lang=3D"EN-GB">=A0</span></p>

<h3><span lang=3D"EN-GB">Question 
5</span></h3>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:0cm"><b><span 
lang=3D"EN-GB">Do you agree that =
a notice period of two
years from the date of the policy announcement is appropriate to allow for =
the
publication cycle of journal articles and conference 
proceedings?</span></b=
></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-top:0cm;margin-right:0cm;marg=
in-bottom:6.0pt;margin-left:0cm"><span 
lang=3D"EN-GB">=A0=A0=A0=A0=A0=A0=A0=
=A0=A0=A0=A0 <u>No.</u></span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">I think two years is needlessly and
unjustifiably long.</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">We are still now in the phase of REF 2014. As
soon as that ends, researchers and HEIs begin to prepare for REF 2020.</spa=
n></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">There is no reason at all why
immediate-deposit upon acceptance for articles accepted for publication
starting 2014 should not begin in 2014 rather than in 2016, as a condition =
for
REF 2020 eligibility.</span></p>

<p class=3D"MsoListParagraph" 
style=3D"margin-bottom:6.0pt"><span lang=3D"E=
N-GB">Not even those HEIs that don=92t yet have IRs
should be exceptions: Their authors can start depositing at once in OpenDep=
ot,
the UK back-up repository designed for that purpose.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Comments:</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">That
said, there is no reason why HEFCE cannot show some flexibility in the firs=
t
two years, for inadvertent failures to comply immediately. But this potenti=
al
flexibility should not be publicized, for it will only encourage lax compli=
ance
during the two designated years.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><span 
lang=3D"EN-GB">=
=A0</span></p>

<h3><span lang=3D"EN-GB">Question 
6</span></h3>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Do you agree that
criteria for open access should apply only to those outputs listing a UK HE=
I in
the output=92s =91address=92 field for the post-2014 
REF?</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><u><span 
lang=3D"EN-GB">No.</span></u></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">Every 
UK
researcher who is submitting an article for REF should have to deposit it i=
n their
IR immediately upon acceptance (except if they came to the institution afte=
r
the acceptance date).</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Comments:</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span 
lang=3D"EN-GB">Better
to be as inclusive as possible and handle would-be exceptions on a case by =
case
basis rather than declare explicit exceptions.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span 
lang=3D"EN-GB">=A0</span></p>

<h3><span lang=3D"EN-GB">Question 
7</span></h3>

<p class=3D"MsoNormal" 
style=3D"margin-bottom:6.0pt"><b><span 
lang=3D"EN-GB=
">Which approach to
allowing exceptions is preferable? </span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span lang=3D"EN-GB">I
support <u>Option a</u><b>:</b> Full
compliance; exceptions considered on case by case basis, first by the HEI, =
and
if not resolved, by the REF panel.</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><i><span 
lang=3D"EN-GB">There will be no basis=
 for objections by
publishers to immediate-deposit in Closed 
Access.</span></i><span lang=3D"E=
N-GB"> The embargo length for Open Access is less
important (because of the Button) and will not (and should not) constrain
authors=92 choice of journals).</span></p>

<p class=3D"MsoNormal" 
style=3D"margin-top:0cm;margin-right:0cm;margin-bott=
om:6.0pt;margin-left:36.0pt"><span 
lang=3D"EN-GB">External
collaborators will certainly not object to Closed Access immediate-deposit,=
 and
are very unlikely to object to OA either =96 and certainly not post-embargo=
 OA.</span></p>

<p class=3D"MsoNormal"><b><span 
lang=3D"EN-GB">Do you have any comments on =
these proposals?</span></b></p>

<p class=3D"MsoNormal" 
style=3D"margin-left:36.0pt"><span 
lang=3D"EN-GB">Pe=
rcentage compliance criteria would be a
very bad idea, and would virtually be inviting institutions not to strive f=
or
100%. Case-by-case handling is an infinitely better way to exercise
flexibility.</span></p>

</div></div>

--047d7b6042be010e8b04e24b5028--

        
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