--- title: The British Academy response misrepresents Plan S and OA layout: post image: feature: oa.png --- The [British Academy has responded](https://www.thebritishacademy.ac.uk/sites/default/files/A_commentary_by_the_British_Academy_on_final_Plan_S-July_2019.pdf) to the revised Plan S consultation. It's nice of them to grudgingly accept there have been some improvements but I remain dismayed by the continued misrepresentation of Plan S within their documents. I will here quote some of the elements of their response that I believe misread or misrepresent Plan S. This post is strictly my personal opinion based on my academic expertise. > "It may be assumed that future rules for the REF may be different again, especially given that a very large part of UK-published research (and the vast majority of HSS research) is not funded by grants" QR, awarded by REF, is a grant. It is given to institutions by Research England and the devolved funding councils. Research England are a council of UKRI and therefore, one might suppose, can and will attach Plan S conditions to their future grants. If institutions do not want QR for the humanities and since the Academy believes that humanities work isn't funded by this stream it seems, then we can do away with REF and QR and OA and Plan S and all will be fine. I would suggest, though, that this is a misguided view and that without QR, humanities research would be significantly impoverished. Humanities research _is_ therefore funded in the UK and it is disingenuous and even dangerous to claim otherwise. This type of special pleading spectacularly damages our own cause in defending humanities funding. > In particular, we thought, and think, that it is generally recognised that in HSS OA journals and platforms are few in number, and have little profile. For these to be got ready – capable of maintaining high standards, with proper peer review – in a short period of time, across the whole of Europe with some thirty academic languages and numerous disciplinary fields, seems highly unlikely. Perhaps a prestigious Learned Society could do something to change which titles have "profile"? Can you think of such an organization? Further, the whole implication behind this type of logic is: "we hire based on where you publish and we value the 'profile' of journals above reading the work itself". So, rather than blaming Plan S for stopping ECRs from publishing in the venues that are supposedly valued, why doesn't the Academy invest substantially in revising and reforming hiring practices so that they are fit for purpose in the twenty-first century? (This is a "stated goal" of Plan S.) I also object to the Academy claiming that they have had a "short period of time" to adapt to an open digital publication environment. The declarations on OA were first signed in 2002, almost twenty years ago. The Finch Report is almost a decade old. So answer us this: how long do you actually want/need? What is a reasonable timescale? > But publishing with a proper sense of responsibility to the needs of science (including peer review, datachecking, and clarity in layout as well as editing) is not, and cannot be, free. A nice straw man argument. If Plan S thought that publishing was free, it would not even mention business models and costs. I also assume then that the BA pays all of its peer reviewers? > If cOAlition S is successful in its stated aim, to create an environment in which all research is entirely open from the start, in non-hybrid and APC-funded journals, where will ECRs, who in many cases do not have a permanent position, frequently move employment, and will not have easy access to funds unless they are established members of grant-funded research teams, be able to publish? This is flat out incorrect. The Academy claims that the "stated aim" of cOAlition S is "to create an environment in which all research is entirely open from the start, in non-hybrid and APC-funded journals". This is simply untrue. The actual guidance says: "cOAlition S acknowledges the existing range of high-quality Open Access journals and platforms and the importance of a diversity of business models". APCs, in other words, are not the only business model. You could look at consortial funding, or society-membership funding. Zero-embargo green is also allowed in subscription or even in hybrid titles. This was wrong even when it referred to the first version. If this is the kind of accurate, responsible publishing to which the Academy refers -- in which there are blatant misrepresentations -- then this is not a good demonstration of that value. Further, as above, QR could be used to pay such fees, where they exist. > The ‘misrepresentation of contentious work’, as the new guidelines put it, is not something that is going to go away Indeed. Such misrepresentation has existed for decades. Does the Academy believe that those who would misrepresent such work will be stopped by restrictive licensing? Our current generation of politicians and media spinners seem to have no ethical principles at all and will not be stopped by an -ND license. [I have written more extensively on this elsewhere](/2019/01/24/a-little-more-on-defamation-and-cc-by/), though. I would claim that the BA has misrepresented the Plan S declaration without any violation of the open license. > ‘hybrid’ journals, as the coalition still describes them Yes, funnily enough, this is how the coalition still describes them, as this is the term used for at least the past decade to describe journals that publish OA material while maintaining a subscription model. It's kind of how language works that we describe things using the accepted terminology. This type of "as the coalition calls it", "as the new guidelines put it", and "as the coalition still describes them" is a patronizing way to refer to a document that is simply using widely accepted designations and is an attempt to somehow discredit through linguistics, as though these people are on another planet and "don't speak the same language as us". > We remain entirely unpersuaded that such journals represent a threat to further progress towards OA The [recent report from Jisc](https://scholarlycommunications.jiscinvolve.org/wp/2018/10/22/open-access-briefing-paper-considering-the-implications-of-the-finch-report/) noted that while hybrid contributed to the growth of OA, it did not result in effective offsetting of subscription costs. It is, therefore, an unsustainable transition. So I would like to know on what persuasive basis the academy grounded its logic. A gut feel or a report from the central body for publisher negotiations? > It is possible that few HSS journals will actually make this change. It must always be remembered that articles published in most HSS disciplines overwhelmingly (that is, between 80 and 90%) do not arise from the sort of grant funding that includes an allowance for APCs. As a direct result, in HSS disciplines, we have found very few journals which could under any circumstances ‘flip’ to Gold-only OA without failing financially The Academy seems, again and as above, to make a good case for removing QR funding from the humanities and social sciences. This seems like a bad idea to me. It also seems to imply that QR can't be spent on APCs whereas, in actual fact, institutions can spend this grant howsoever they choose. It is precisely the "sort of grant funding" that can accommodate APCs, although, again, I note that it's not APCs or green; but a diversity of models. > for authors funded by grants will find themselves at a considerable disadvantage when seeking to publish the results of their research Really? This is just a simply incredible statement. The work funded by such grants is surely of enormous profile in its own right. The prestige of the current "top" journals will go down the pan if all funded research is routed into pure-gold OA titles. This is just an attempt to preserve the status quo and prestige hierarchy of titles, which is a deeply flawed model. > Some are prepared to publish with a 12-month embargo, but they are concerned that a shorter embargo will undermine their business model too considerably for it to be sustainable Did you know that Cambridge University Press already allows zero-embargo green OA of journal articles in the HSS disciplines? I believe Emerald and SAGE also have similar policies. This has not resulted in the collapse of their journals but has allowed more people to read the underlying work. See also: [Open access: ‘no evidence’ that zero embargo periods harm publishers ](https://www.timeshighereducation.com/news/open-access-no-evidence-zero-embargo-periods-harm-publishers). > The HSS academics with whom we have been in contact see no reason or need to have embargoes shorter than 12 months Haven't been in contact with me, that's for sure. Clearly not people working on any matter of contemporary relevance? I work on _contemporary_ fiction. It's quite useful not to have to wait until the fiction isn't contemporary to read the secondary material on it. I find this whole charade quite wearisome. Why can't the British Academy accurately represent a single document? You might disagree with some of my interpretations here, but there is at least that one part on non-hybrid APCs that is just simply wrong. This is not good enough.