Plan S: A Mandate for Gold OA with Lots of Strings Attached - The Scholarly Kitchen (original) (raw)

Over the past several weeks, many in the scholarly publishing world have been reacting to the open access (OA) 10 principles outlined by cOAlition S — a plan now referred to as “Plan S”. The principles laid out were interesting but lacked significant detail leading to loads of conversations trying to imagine what an implementation might look like.

Last week the “implementation plan” for Plan S compliance was posted. The biggest questions going in were whether they would really disallow hybrid models and what the proposed the APC cap would look like.

While at first, the introduction to the implementation plan sounded like a compromise (hybrid okay for now, no cap yet on Article Processing Charges), the devil is in the details. The technical details make clear that the only acceptable solution is author-pays, APC Gold or Platinum OA. This has been mandated by making all other options nearly impossible. Let me explain.

Strings attached.

Publishing Compliance

The implementation plan describes what kind of OA journal and/or platform would be considered compliant to host papers based on Plan S-funded research. For starters, the journal/platform must be included in DOAJ or be in the process of evaluation and there must be a peer review process that roughly follows COPE guidelines.

Compliant journals must “enable authors to publish under a CC BY 4.0 license (alternatively CC BY-SA 4.0 or CC0).” The word enable seems important. It would appear that an OA journal that gives authors a choice of licenses will still be considered compliant, but that cOAlition S-funded authors will be required to select the abovementioned licenses.

The implementation plan seems to throw a nod in the direction of those who fairly believe that the APC model of OA disadvantages researchers who are underfunded:

“The journal/platform must provide automatic APC waivers for authors from low-income countries and discounts for authors in middle-income countries.”

How this is to be determined is not at all explained. Currently, some journals use the World Bank designations, others use HINARI which is based on World Bank data, and still others make up their own maps. Waivers for APCs is a controversial topic with many complaining that they are unevenly applied. The lack of detail here does not adequately address concerns nor explain exactly what is required.

Presumably, requiring those same “automatic” APC waivers will extend to the hybrid journals ruled to be compliant because they are under what are called, “transformative agreements” (more on this below). While free or heavily discounted access is often provided to the subscription part of the journal, waivers for APCs in hybrid journals are less common given that OA publication in those journals, and hence the charge, is entirely optional.

Reporting Compliance

In order to be a compliant journal/platform, “transparent costing and pricing” is required. Specifically,

“information on the publishing costs and on any other factors impacting the publication fees (for example cross-subsidising) must be openly available on the journal website/publishing platform. This must include details on direct costs, indirect costs, and potential surplus.”

So let’s start with the fact that pricing from vendors is proprietary and often not legally disclosable. Next, we can consider that APCs are not, in fact, what it costs to publish a paper. APCs also cover the costs for:

1. Rejected articles (those cost money too)
2. Published papers with waivers (see above regarding mandatory waiver requirements)
3. Subsidizing other journals

Hold on, why should Author A pay extra so Author B can publish in a different journal? Well, some communities are small. A journal has an expense even before it has papers and some cost more than others. Look at PLOS as an example. Their APC-funded OA, high-end journals that cover specific fields are not financially sustainable on their own. They continue to exist because they are supported largely by surplus generated from APCs paid by authors publishing in PLOS ONE. This is often the truth for any publisher with a suite of journals — some make money, and some don’t even cover their expenses. Those that don’t cover their expenses are still important to the community they serve.

The Plan S implementation document makes mention of commissioning a study to look at costs before it decides on an appropriate cap. Seeing as publishers of different sizes, with different levels of scale, offering different services, in different parts of the world, serving different audiences all have different costs, this should be interesting.

In addition to costs, “potential surpluses” must also be disclosed. That is privileged business information and I question the usefulness of this requirement. Is there an acceptable level of surplus, and if so, who makes that determination? Are the activities of one organization seen as more valiant than the others, allowing for more surplus to be acceptable from publisher A but not from publisher B?

Technical Compliance

Technical requirements on content output are likely to cause problems for some OA journals. Compliant journals are required to have full-text XML of article content set in the JATS DTD. It is important to state that creating properly tagged XML to the JATS DTD is not a simple conversion. Doing this competently can be one of the largest expenses incurred by a publisher. Many newer platforms built for OA journals are not set in JATS.

Citations must be parsed and tagged in the metadata and made available for free in a “standard operable format” (not defined). This would be achieved by signing on to the Initiative for Open Citations and depositing the tagged citations with Crossref to make them available. Reference editing and tagging is often the most grueling part of the composition process. In order to have full reference sections that meet the stated requirements, investment needs to be made for editing, clean-up software, tagging, author querying, and quality control. This is a big ask for smaller operations, particularly those running lean operations in order to keep APC levels down.

Additionally, all funder information must be included in the metadata. Again, some publishers have done this via the Crossref Funder Registry, but many others, including smaller OA journals, have not incurred this expense. Installing this functionality into one’s article submission system can be an expensive and time-consuming task.

A significant number of OA journals do not have archiving set up via partners such as CLOCKSS or Portico. This too is a requirement of compliant journals. Journal must also provide “linking to underlying data, code, and so on available in external repositories.” In order for a journal article to have linking to this information, the author must provide it. It appears that compliant journals must REQUIRE that authors make the “data, code, and so on” available and cite it in the paper. This means additional editorial overhead as each article must be checked for inclusion of this type of content, authors must be chased to provide those links, and those links must be checked to ensure their validity. Again, article submission systems will need to be customized to include these sorts of questions for authors.

All in all, the requirements for Plan S-compliant OA are easily performed by journals owned by commercial publishers and large OA-only publishers. This is not a friendly policy for lower-cost or “community-founded” initiatives or for societies that self-publish and are interested in starting OA journals.

Hybrid Compliance

The Principles released last month included a prohibition on publishing in hybrid journals. This requirement is where a lot of concern about Plan S originated. Hybrid OA allows researchers mandated to publish OA, or those preferring to publish OA, to publish in their journal of choice. Plan S makes this choice more complicated.

Plan S allows for publication in a hybrid journal as long as that journal has a transformative agreement to flip to full OA within three years of the agreement. These agreements need to be signed no later than December 31, 2021. These transformative agreements are essentially the “Read and Publish” agreements with guarantees about flipping to OA in a certain time period.

The implementation plan is, once again, light on details. Read and Publish deals are usually made with a library or a library consortia. These are not the same entities as the funding bodies behind Plan S. If a journal has one such deal with one library, is that sufficient for compliance? How many such deals would be needed? Does the journal need to seek approval from cOAlition S (or from every separate member of cOAlition S) for every deal that is undertaken to determine compliance? Having to run all such deals past multiple bureaucracies would essentially make them impossible to accomplish.

It would be very difficult for a hybrid journal that today only has <10% of its articles OA to make a promise to flip at some specific time in the future. The requirements for APC waivers and discounts may also skew the data. Having a consistent and significant amount of OA articles is only going to precipitate a flip to OA if those papers are collecting the full APC.

Even if a journal has a Plan S-compliant transformative agreement, the funders participating in Plan S can still choose to not pay the APC. This would be similar to the Wellcome Trust model where grantees aren’t prohibited from publishing in hybrid journals, but Wellcome won’t foot the bill.

The implementation plan takes exception to the Mirror Journal concept. The guidelines state that mirror/sister journals (OA version of subscription journals with overlapping editorial boards) will be considered the same as hybrid and therefore, not be compliant. How this is to be determined and monitored (what level of overlap is acceptable?) has not been disclosed.

There is a lifeline thrown to hybrid journals later in the post.

Green OA Compliance

At this point, you may be thinking that Plan S-funded authors should just archive accepted papers in an OA repository and be done with it. Not so fast…this is also about to get a lot harder for Plan S-funded authors.

The implementation plan does allow for authors to post papers on an OA Repository. However, there are lots of strings attached.

First, there can be no embargo and the posted content (either the publisher created version of record of the author accepted manuscript) must by under a CC BY license. For the most part, this can only happen if an author has paid an APC. Journals will not typically facilitate peer review and produce a paper without being able to cover those expenses either through an APC or by selling the content.

To be considered compliant, repositories must meet some difficult technical requirements, including automated manuscript ingest. This requirement moves away from systems where authors have to upload files one at a time. But where might they be ingesting these manuscripts from? The publishers, of course. cOAlition S is requesting that publishers facilitate deposit while declining to pay for it. And looking at the requirements, this may be the only way. Full-text XML in the JATS DTD, tagged metadata “of the same quality criteria of open access journals,” an API, and a “QA process to integrate full-text with core abstract and indexing services.” Finally, it must cost the author nothing to deposit in such a repository.

A question was asked on Twitter…are there any institutional repositories that meet this requirement. The answer, so far, has been no. However, EuropePMC meets the technical requirements, but only for a subset of content.

figshare eagerly jumped in to the conversation to say that they were putting full text XML conversion on their roadmap and bioRxiv is having all their papers converted to XML thanks to funding from CZI.

bioRxiv has a different problem though, it currently only allows an actual preprint—unpublished manuscript, not peer reviewed by a journal — which disqualifies them as a compliant Plan S repository. In fact, while the implementation plan encourages authors to post preprints, what they want to make free is the peer-reviewed version.

And that is where we have a problem. The members of cOAlition S don’t want to facilitate the peer review process for their funded authors. They don’t want to start their own journals like the Gates Foundation or Wellcome Trust have tried. Their stated goal is to eliminate subscription journals and by making the lower-cost OA options onerous to implement, they have devised a plan that calls for author-pays APC-supported Gold OA.

The Loop-hole: Hybrid + Self-Archiving

A cOAlition S-funded author could publish in a hybrid or mirror journal where the publisher offers CC BY as the licensing option. The author can then archive the paper in a compliant repository and meet all of their funder requirements. The only problem is that the funder will not be paying the APC. For wealthier authors with diverse funding sources, those from well-funded institutions, or those with collaborators with access to APC money, this would not be a problem.

Ongoing Expenses

What I find particularly difficult about Plan S is that it does not embrace an OA mechanism that currently exists. It bolts on new requirements to current OA processes, which could be problematic, at least until everyone gets up to speed. The new requirements come at significant expense and it’s not a one-time expense, it’s an ongoing expense. That said, reducing the cost of publishing is not a stated goal of the plan.

What cOAlition S does state is that they want to work toward, “new models of academic publishing,” and mentions that incentives and support will be made by the cOAlition S participants to “open access infrastructure, where necessary.”

While I hope that support will including funding for whatever is envisioned, I can’t help but wonder why a system was not put in place to make the plan successful from the start. The implementation plan, with its expensive and not-really-there-yet requirements, seems to assume that others — publishers, institutions, third parties — will start building this infrastructure at their own expense. Larger publishers are likely to get out of the gate first for compliance, and smaller, independent, and society publishers may never be able to catch up.