Open Access, Research and Government Policy

Open Access storefrontBack in November last year I attended a couple of useful and interesting events on open access policy which involved a mix of publishers, academics and HE managers, and government representatives. I’ve been meaning to blog my notes for a while but the small matter of the REF intervened…

I haven’t edited these much so they are more or less my thoughts and snippets that I thought would be useful to others. I’m putting them up here to share and hopefully contribute to the ongoing debate on open access in HE. It’s a little long for a blog post, but I’ve summarised the key messages at the start of each section.

Westminster HE Forum on Open Access:

[important]Summary of event: This event was definitely the most diverse of the two in terms of participants as it involved a mix of HE, funders, publishing industry and policymakers on the panels and in the audience. This made for some lively debate particularly as the question of what value publishers actually add to the academic publication process came up frequently.

Key messages: Most funders already mandate OA, if not they are moving in that direction, but concerns surround how this is to be paid for – not all allow Gold OA costs as part of the grant. There was an interesting discussion of the OA landscape around Europe which showed a very mixed picture in the details, but a general trend towards OA as a requirement for publicly funded research. There was fierce debate about whether Gold is necessary, with OA advocates such as Harnad arguing strongly that increasing adoption of Green OA will eventually lead to worldwide adoption of OA without excessive costs. Publishers – needless to say – argued that Gold is a necessary part of the transition to sustainable OA.[/important]

Wellcome Trust

  • Policy is OA as soon as possible
  • Supports green and gold with strong preference for gold, but gold funding is eligible grant cost
  • Compliance is 65% general upward trend
  • CC BY requirement from April 2013
  • Currently spend £4m per year to support OA
  • If Wellcome funded everything through OA it would cost £9m, but that would only be 1-2% of total spend
  • Market may be dysfunctional, so double-dipping etc happens
  • Have commissioned research into Gold OA with RCUK RLUK etc
Springer
  • Discussing Green vs Gold is not helpful any more
  • Was part of Finch review
  • UK is not alone in this process of transitioning to OA
  • Horizon 2020 APCs are in the grant
  • Lots of US funding agencies accept APCs as eligible cost in grant
  • (… But RCUK does not!)
Questions
  • What about people not funded through grants?
  • What about humanities and social sciences? How might research funders cope with this?
  • Has there been any progress on OA for books and monographs?
  • How does the argument for Green > Gold work? How will the market suddenly flip from Green to Gold?
    • Springer not sure. But whole Springer portfolio allows Green.
  • What about books/monographs?
    • Springer: Books, totally agree no progress. Question of time.
    • Wellcome: requires monographs and book chapters to be available.
    • Wellcome: we all want to be at the place where publications are freely available.
  • How much is too much?
    • Imperial: need an evidence base to determine how much it’s worth paying.
    • Harnad: goal is not Gold, it’s open access. Only the UK mandates Gold. As we approach 100% OA, institutions will cancel journal subscriptions.
    • Association of Learned and Professional Society Publishers: if all we want is accepted version, then we go Green, but if we want the ‘value add’ that publishers provide in terms of the ‘version of record’ then we need to go Gold.
British Embassy Prague, Science attaché – A European perspective on OA
  • 50% of scientific papers published between 2008-2011 are now available for free
  • It’s already happening
  • Spain is only EU country with clear OA legislation at national level
  • Denmark: prefers Green. Funder mandates. Should be OA providing it’s accepted by the journal in question
  • France: mix of Green and Gold = Platinum, no details of what this means or how to bring it about
  • Germany: prefers Green. 6 months for STEM subjects. Gold is considered a ‘parallel route’
  • Netherlands: no official policy but all universities have signed Berlin declaration since 2005. Dutch association of universities have reached agreement with Springer such that all publications by Dutch authors will be freely available next year.
  • Similar concerns and questions across Europe as in the UK: e.g. licensing, CC BY, if gold where do we get the funds?, if green how do we set optimum embargo periods?
Martin Hall, VC Salford – New colonialism in the knowledge economy: Opportunities in the ruins of book publishing
  • Changing nature of research by allowing publication to make reference to data source through hyperlinks etc
  • The power of the hashtag, allows aggregation of massive amounts of information
  • The importance of the copy of record, vital importance of the research repository
  • Repositories will serve as archives for data sets as well as publications
  • OAPEN offers shared open access platform to get material out there
  • Opportunity for social sciences and humanities to learn from previous discussion in science publishing
  • Social media: MOOCs closely connected to publication and OA publication. Coursera likely to be commercialised. Used to outsource 101 teaching courses in US. Implies loss of jobs among junior staff. MOOCs used publications in OA repositories, dependent on OA model.
  • Books: strange that there’s so little movement on this. Is it so different to the journal area? Driver for Finch came from BIS, which was about driving business-oriented innovation. OA publishing may have greater impact in humanities and social sciences than on sciences. Format of papers haven’t changed in transition to OA. But book format constrained very much by format. Might this change? Used correctly digital publishing may have transformative effect on the way arts and socsci publish.
  • Are repositories publishers? No reason why they can’t become primary place for publication. Would be better to develop sensible consortia to do this together. Gets away from ridiculous competitiveness between universities.
  • Is difference between author accepted version and publisher version different enough to pay Gold for? It’s an open question for debate. Need cost-benefit analysis.
Wolfram Horstmann: maximising potential of OA 
  • Commercialisation of results, text mining
  • Government needs to support universities to optimise exposure of research through OA in institutional repositories
  • Pre-publications could be used for text mining etc, so there is an advantage of Green
  • Trend is that there is a growth in journal titles, but also a rise in mega-journals
Mark Ware Consulting
  • How will it benefit SMEs? Large range of SMEs, covers everything from window cleaners to biotech consultants
  • Difference between access to knowledge and tech transfer
  • Main barriers to research for SMEs are paywalls and discoverability
  • Deepdyve and Proquest Udini provide discovery portals, as well as new business models
Nicholas Canny, ERC chair on OA policies
  • Recommending to deposit in institutional repository and discipline repositories because this is the best way to reach the widest possible expert audience – though Harnad disagreed.
  • OA can be paid for through grant if cost is incurred during grant
  • Embargoes: 12 months for HSS and 6 months for STEM
  • OA on its own is not sufficient to draw attention of industry, which is why ERC have developed Proof of Concept grant to work with business/industry
Phill Jones, Macmillan Science and Education
  • Discoverability problem of Green OA
  • Institutional repositories are difficult to find and navigate (disputed point!)
  • Readcube trying to create a single portal for access – publishers well placed to solve this problem
  • Green OA model enables you to be much more agile and innovative
  • Knock on effect to ECRs. Presumption that publishing in high impact journals is the only way to get research out there. Lowered barrier to publication, eg data sets.
  • Economic shift away from library and publisher towards author
  • Incentivises publishers to make it easier to publish, broaden types of publication
Questions
  • Discoverability is key for Green
  • Funding is key for Gold – awareness raising
  • Ensure there is an appropriate IR compliant with Openaire EU standard
  • No clear understanding of what a publication is, introduce quality controls?!
  • Upload author manuscript on OA IR
  • Ensure there’s a DOI
  • Increasing amount of “born digital” publications, need to urgently give higher recognition to these journals
  • “Quality”: not talking about removing peer review, but shifting away from impact citation/view potential determined by editors, towards research quality determined by academic peer review
  • Can language used be changed in the paper? A lay abstract? Nothing to do with OA. Kudos providing services to authors to make papers more discoverable, eg lay summaries, using social media
BIS select committee
  • Select committee rejected Govt report recommendations on the basis that not enough evidence had been presented. Saw it as propping up a dysfunctional market.
  • Does Green maintain status quo? Or does Gold?
  • Where is the funding coming from for humanities and social sciences?
  • Govt needs to do more to come up with a model which will deliver open access

Open Access: Measuring the costs to universities of implementing RCUK policy

[important]Summary of event: This event was co-organised by ARMA and London Higher (a consortium of London universities) so it was very much populated by HE policy and research manager types (like me). However, it was useful to get a sense check of what other institutions are doing around OA and how the sector is preparing to implement RCUK and HEFCE policy in the run up to the next REF.

Key messages: Green tends to be preferred route for most HEIs unless Gold is necessary to meet a funder mandate. Having said that, even institutions which had a significant RCUK block grant to fund Article Processing Charges haven’t seen a major draw on those funds. OA to research data is a big unknown and lots of uncertainty exists around this. At the end of this event there was a useful final discussion session which acts as a good summary of the current state of OA in the HE sector.[/important]

Geoff Rogers – PVC Brunel, Chair of London Higher Research Excellence Group: Introduction

  • Context of RCUK policy, concern around emphasis on Gold, embargo periods etc.
  • Wrote to RCUK and BIS in early 2013 expressing concerns
  • Evolving picture, still trying to understand what’s happening and share experiences
David Price – UCL, Setting the Scene
  • OA is a solution to the problem of inaccessible research, paywalls
  • OA right in principle and a key way to disseminate research, yet it’s difficult to implement
  • Finch report contentious because strong recommendation for Gold OA and no one picked up need for extra money
  • RCUK first policy in July 2012 was too hasty, back-pedalled and we have latest iteration of OA policy
  • Publishing community is now alert to ‘threat’ of Green OA and are policing it
  • Sept 2013 BIS select committee report criticised Finch for Gold emphasis, prefers Green
  • HEFCE policy for OA in REF 2020 sets 2016 as start date for eligibility
  • Problems… Policing of embargoes more prevalent, lack of APC controls, double-dipping, rest of world swinging to Green over Gold
  • Price wanted a national subscription service (!?) for all institutions and SMEs – concern that current situation helps international industry more than UK industry and costs UK more to do this
  • UCL context: 9000 research outputs per year, publication ‘core to business’
  • Researchers select ‘most effective dissemination channels’ so OA no threat to academic freedom at UCL
  • 275,000 items on repository, 20,000 OA full text, 1,000,000 downloads on those items
  • Big challenge is compliance
  • No discrimination against younger, ECRs, etc, it’s UCLs responsibility to make it OA if it’s been funded by RCUK. Short by 2000 RCUK publications given RCUK OA fund (£2M). UCL put aside money to develop approach to OA.
  • Considering going directly to publishers every year and asking who’s published from UCL over last year and then making them Gold
  • UCL press, ‘overlay’ journals, and OA monograph publishing service

The following speakers then responded to the context talk and gave different views…

Cathy Urquhart – Manchester Metropolitan

  • Embargo periods for OA getting longer
  • Finch report best estimate was that it would cost sector £50-60M
  • Different environment at MMU, 300 publications per year, less resource
  • Green is preferred route for MMU, but they are going to set up APC fund (but not much money), Library will manage this fund, negotiating with publishers where necessary
  • MMU got £11K from RCUK for 2013/14 (similar ballpark to Northumbria)
  • Making REF 2014 outputs OA to see where costs lie in advance of 2020
  • Monitoring equal access to APCs
  • Will support Gold if funding is available from funder.
Trevor McMillan – Lancaster University
  • Divide figures from UCL by 5 to reach Lancaster’s figures
  • 30-35% science so big concerns about AHSS side of debate
  • 10 years ago debate was whether money should be put into repository – eprints vs DSpace
  • Lots of promotion around ePrints and resource in terms of Library staffing
  • 10-15% of total repository deposits have/had? full text
  • Only publisher PDFs were put into repository, but concerns from maths etc where working papers were more common – still policy, but fraying at edges
  • Using PURE which allows integration into University web pages of repository content
  • OA policy effectively says Green as standard, unless money exists to go Gold from elsewhere
  • Got £160,000 from RCUK and only spent 20% of this (similar to St Andrews experience)
  • But £25K made available for non RCUK funded research and this has all gone
  • Not expecting reduction in journal subscriptions, so OA is additional money (double dipping)
  • Publishers are starting to come out with deals, eg IEEE deal. Social Sciences directory institutional rate for OA journals. Will they create reputation and get traction with academic colleagues?
  • Worry about % compliance rates for HEFCE. Imagine having to say to people they can’t be included in REF because they have to hit OA compliance rate. Targets are a serious worry.
  • OA to research data is a major issue, even RCs are starting to worry about this.
Oriana Baddeley – University of the Arts
  • Small in some interpretations of a University, but large in terms of a monotechnic – only returning to one UoA!
  • UAL research online – 4000 live records, 37% have downloadable content, developed as part of KULTUR project funded by JISC customised for non text outputs
  • 15% of text based return is journal articles, lots is books etc
  • Firmly committed to Green
  • Lots of investment in staff because IR cannot easily automate non journal, non-standard content
  • Invest money on picture reproduction rights charged by journals to authors
  • Lots of QR income is to pay publishers for reproduction rights
  • APCs will be in addition to above costs. Will end up spending more
  • Self-archiving
Questions
  • How can universities collaborate with each other to solve some of these issues?
    • Collaborations around arts and humanities are important
    • Need to have debate
    • Is the future about disciplinary responses to OA rather than institutional response?
  • How much have universities been setting the agenda, and how much have we been responding?
    • Good in setting up IRs, but since then on the back foot
    • Sector didn’t see it coming, a bit naive. Need to start thinking now about open data question because that’s the next tsunami
  • How many universities thinking about retaining copyright as in Harvard’s case?
    • Not an option for those lower down the tree
  • Say more about national subscription model
    • Finland have an agreement with publishers that entire population has access to publications. Current UK subscription bill is £120M and some publishers have indicated this would rise by 20%
    • Netherlands tried this and got less than 200 applications for access. What problem are we really trying to solve here? Is there really a lack of access, do people want access? Do people know that this is available?
  • MOOCs
    • Real issue about OA is about timing. MOOCs may not rely on information produced in embargo periods.
    • Issue about copyright of images which MOOCs material may rely on.
  • Culture change and ensuring compliance?
    • Both carrots and stick required
    • Effective research is not just disseminated but engaging from the start
    • “Hitting people with bigger carrots”. Tie to HR processes, eg promotions and appraisals. Make process of uploading as painless as possible.

Afternoon session

Alma Swan – assessing costs and benefits to UK HEIs

  • ARMA issues:
    • Lack of author engagement
    • Disciplinary concern, eg arts and humanities
    • No system for monitoring publication practices
    • Impact factor still critical which makes advocacy difficult
    • How to spend RCUK funds?
    • Lack of ownership of OA agenda within institutions
    • What about other types of output?
  • SCONUL briefing:
    • Lots of helpful contextual information, based on case studies done at 8 institutions
    • Looked at advocacy, staffing, institutional position on OA, management of APC funds
  • RIN study:
    • Policy making practices
    • Focused heavily on research intensives
    • Looked at how 2012 pump priming money had been used
  • None of existing studies have looked at costs. London Higher report will focus on this aspect
  • Sample representative of UK HE sector
  • Questions:
    • Implementation and planning
    • Support for Gold and Green OA
    • Costs £££ how have you spent money from RCUK?
  • Alma Swan: a.swan@talk21.com if you want to be involved in this
Final discussion
  • Strong preference for Green among research intensives and research led institutions
  • Some institutions using RCUK block grant on a first-come first-served basis, and therefore concern about what will happen when this fund runs out (though Kent, St Andrews, Lancaster reported low demand for this)
  • Some are spending RCUK money on Green OA implementation – no one using this money for repositories
  • Some institutions had APC fund before RCUK block grant (Nottingham), many didn’t – often run by the Library
  • Having fund taken over by a third party does not necessarily reflect a cost saving
  • Final action plans not yet developed (many still evolving), but interim plans are in place in many cases
  • No rigorous compliance activity going on – this is seen as the major issue
  • Lead responsibility generally lies with Library, but research offices often involved in compliance activity/reporting to funders – often APC funds administered by Library
  • Some institutions getting involved in setting up OA journals, will self-publishing become increasingly important?
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Commission launches pilot to open up publicly funded research data

I heart Open AccessInformation produced by researchers in many EU-funded projects will be shared freely as a result of a Pilot on Open Research Data in Horizon 2020. Researchers in projects participating in the pilot are asked to make the underlying data needed to validate the results presented in scientific publications and other scientific information available for use by other researchers, innovative industries and citizens. This will lead to better and more efficient science and improved transparency for citizens and society. It will also contribute to economic growth through open innovation.

For 2014-2015, topic areas participating in the Open Research Data Pilot will receive funding of around €3 billion. The Pilot involves key areas of Horizon 2020:

  • Future and Emerging Technologies
  • Research infrastructures – part e-Infrastructures
  • Leadership in enabling and industrial technologies – Information and Communication Technologies
  • Societal Challenge: Secure, Clean and Efficient Energy – part Smart cities and communities
  • Societal Challenge: Climate Action, Environment, Resource Efficiency and Raw materials – with the exception of topics in the area of raw materials
  • Societal Challenge: Europe in a changing world – inclusive, innovative and reflective Societies
  • Science with and for Society

The Commission has produced a Fact Sheet on Open Access in Horizon 2020.

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6 Open Access Myths Busted

Open Access Week 2013 by slubdresden CC BY 2.0

Peter Suber, author of an introductory text on Open Access (MIT Press, 2012) sets out six commonly held views about open access research in this Guardian article and explains why they are either outdated or untrue. For example: the only way to provide OA to peer reviewed articles is to publish in (gold) OA journals…

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HEFCE Consultation on Open Access post-REF

Open Access promomaterial by biblioteekje CC BY-NC-SA 2.0Both myself and Ruth Hattam recently attended events organised by HEFCE focussing on the recent consultation paper around Open Access (OA) in the post-2014 REF.  The principle behind the proposals is that outputs submitted for the next REF submission (likely to be around 2020) should be open access.

Definitions first

For a publication to be classed as OA according to the criteria proposed by HEFCE, it must:

  • be accessible through an institutional repository immediately upon either acceptance or publication (to be decided as part of the consultation);
  • be the final peer-reviewed text (though not necessarily identical to the publisher’s edited and formatted version); and
  • be presented in a form allowing the reader to search for and re-use content subject to proper attribution.

HEFCE acknowledges the challenges around these proposals, and the system is designed to move towards the principle of full OA. As such, the proposal is that only journal articles and conference proceedings will be expected to comply with OA for the next REF, and that the OA criteria will only apply two years after the date of the policy announcement (i.e. from 2016).

The proposals as they stand mean that outputs which are retrospectively made to comply with the above definition of OA would not be eligible for submission to the REF. There were various issues raised at the consultation events about how this principle might work in cases where staff move institutions, bringing outputs with them. Delegates noted that this would effectively demand an extra administrative step on recruitment to check that outputs published while at the previous institution complied with REF OA guidelines.

Targets and exceptions

HEFCE propose that exceptions to the policy will be permitted, and one of the consultation questions is whether this should be on a case-by-case basis, a set percentage (70% is the suggestion) across an institutional submission, or whether targets are varied on a panel basis to take account of subject differences.

The audience from a variety of HEIs was broadly in favour of the open access proposal, in fact, some felt the proposal did not go far enough in progressing an open access approach.  One view was that tolerating up to 30% non-compliance could be seen as a way for institutions/academics to circumvent the OA principle.

The case-by-case approach was seen as potentially bureaucratic, however, and there was some difficulty in establishing the sort of circumstances that would qualify as an ‘exception’.  At this stage, HEFCE felt unable to expect 100% compliance without raising serious questions about academic freedom.

Publish or perish?

Publishers (and their ever-changing policies on OA) came in for some criticism, but the HEFCE panel was keen to stress that they see the publishing industry as part of the solution rather than the problem. One suggestion was that HEFCE and other funders invest in the SHERPA RoMEO/FACT service to ensure a robust and accurate information service which has capacity to keep track of the shifting publisher OA policies. It was further noted in this context that the issues around monographs were currently too complex to try and tackle in a meaningful way for the post-2014 REF.

Concerns were raised about the additional costs of supporting OA. The HEFCE panel view was that costs did not have to be a major issue if institutions developed policies that allowed for both green and gold OA. The suggestion was that the HEFCE REF guidelines should be viewed as a minimum standard.

Resource requests

The use of institutional repositories would clearly be key in the proposed changes, but the additional resources required to ensure that repositories were used most effectively was seen as an issue.  For instance, the implications of embargoes on outputs was seen as something that would be difficult to monitor, particularly as there was no standard approach among publishers and the parameters were constantly changing.  If publishers extended their embargoes beyond the RCUK recommendations (which were likely to be adopted by HEFCE) then it would be up to an institution whether to choose to pay gold OA fees in order to have outputs available to the REF submission.

Other discussion covered the potential for OA to form part of the REF5 narrative, and it was noted that further consideration needed to be given to the penalties if institutions missed OA targets. HEFCE commented that it was unlikely that OA constraints would be placed on research that supported impact.  There was a strong argument for consistency as far as possible between and across panels.

Comments please!

Anyone who wishes to read the full consultation document from HEFCE can access it at the following link:

http://www.hefce.ac.uk/pubs/year/2013/201316/#d.en.82765

If any member of Northumbria staff wishes to comment on any of the seven questions (in Appendix A of the document) please send views to me (email: david.g.young@northumbria.ac.uk) by 18th October 2013.

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10,000th Item Deposited in Northumbria Open Access Repository

My 10000th public image on Flickr by Leo Reynolds CC BY-NC-SA 2.0

Northumbria Research Link (NRL), the University’s Open Access Repository for research outputs and publications, has recently passed a milestone of 10,000 items. As reported in the University’s Insight magazine:

“The landmark 10,000th publication was a paper by Anniversary Research Fellow, Dr Frank Lewis, from the Department of Applied Sciences, on processes which attempt to reduce the radioactive lifetime of used nuclear fuels by separating out the hazardous radioactive elements.

In the last year almost 150,000 items were downloaded from the repository by more than 100,000 visitors to its website, with significant numbers based in the USA, India and China.

Almost 30,000 downloads originated in the United States, with 8,000 from India and 7,000 from China. These three countries alone account for approximately 30% of downloads from the repository.

Professor Peter Golding, Pro Vice-Chancellor for Research and Innovation, said: “These impressive figures confirm the continuous growth in the scale of research activity at Northumbria University and the interest shown in it from all over the world.

“In the past twelve months alone, more than 4,000 new research outputs have been placed in Northumbria Research Link. The sheer volume increase in deposits shows that growth in the quality and quantity of research undertaken by our staff is creating international interest in what we do.””

If you’re a researcher at Northumbria and you’d like to find out more about the repository, why you should use it, and how to upload your research to it, Library staff run periodic training via the HR People Development programme. Alternatively, you can contact the NRL Site Administrator.

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Check Your Open Access Compliance With SHERPA/FACT

Following the recent RCUK announcements on their open access policy, it’s becoming increasingly important for academic authors to ensure that the places they publish comply with funder OA policies.

RCUK and Wellcome Trust have jointly sponsored SHERPA/FACT (Funders’ and Authors’ Compliance Tool) which can help you to check whether the journal you want to publish in complies with the Open Access policies of the funder of your research. The tool itself is a simple text field where you identify the journal you want to publish in. You also need to select the relevant funder using a check box and the article status (i.e. whether it has been submitted for publication or not).

For example, say you’ve been funded by the Wellcome Trust and want to publish an article in the Journal of Clinical Microbiology, you’d simply fill in the details and you’d get the results page below which clearly shows that you are able to comply with the funder’s open access policy because the funder will deposit your article in the Europe PMC open access repository either at the time of publication (paid option) or six months following publication:

SHERPA FACT 1

 

Another example: an ESRC-funded publication in the Journal of Social Policy would not be able to comply with the funder OA policy unless they paid for the open access publication option:

SHERPA FACT 2

 

This is a recently released Beta version of the tool and SHERPA encourage feedback to: fact@sherpa.ac.uk.

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HEFCE Seeks Advice on Post-2014 REF Open Access Proposals

Open Access by AJ Cann CC BY-NC-SA 2.0HEFCE (alongside the other three UK HE funding bodies) is inviting responses and advice on its proposals for open-access publication in the next research assessment cycle (i.e. after the 2014 REF – this consultation will have no bearing on the current REF).

HEFCE: Open Access and submissions to the REF post-2014 [PDF]

The proposals re-state the importance of open access publication in the future higher education policy landscape, however they do not express any preference for gold vs. green OA and essentially propose to leave it up to individual institutions to decide which of these routes is preferable.

The three key criteria for open access are:

  1. deposited in the author’s own institutional repository immediately upon publication, although the repository may provide access in a way that respects agreed embargos;
  2. made available as the final peer reviewed text, though not necessarily identical to the publisher’s edited and formatted version; and
  3. presented in a form allowing the reader to search for and re-use content (including by download and for text-mining) both manually and using automated tools, provided such re-use is subject to proper attribution under appropriate licensing

They are looking for advice and comments specifically on the following issues:

  • The expectations for open access publication, as set out in the three criteria above
  • Repository use and techniques for institutional repositories to cross-refer to subject and other repositories
  • Embargoes and licensing as these issues relate to open access publication
  • Exceptions to the above principles, and how to handle them
  • The issue of monographs and whether these should be exempt from OA requirements
  • The issue of open data, which is not expected to be made a requirement for the next REF

The deadline for responding to this consultation is 25th March 2013. The details of how to respond are given in the open letter.

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