University response to HEFCE consultation on open access and the REF post 2014
The university has responded to HEFCE’s first consultation on open access and research assessment post 2014.
In support of their objective of increasing the proportion of research outputs that are made available in open access form, HEFCE’s proposals centred on the requirement that all research outputs submitted to future assessment exercises should be made open access as soon as possible after publication:
“To support and encourage the further implementation of open access we intend to introduce a requirement that all outputs submitted to the post-2014 Research Excellence Framework (REF) exercise are published on an open-access basis, where this is reasonably achievable and where, given the medium in which the output is presented, the concept of ‘open access’ applies.” (HEFCE, 2013, para 8)
HEFCE requested responses focused on several key issues, as follows:
(Paragraph numbers refer to those in this letter)
HEFCE: We welcome advice on our expectations for open-access publications, as set out at paragraph 11.
University: The University of Northampton welcomes the strong support for open access to research outputs shown in this document and the willingness of HEFCE to accept deposit in an institutional repository as a mechanism for achieving this. We have outstanding concerns about the role that copyright might play in achieving compliance with the mandate. Specifically, we are concerned that some publishers will be unwilling to give permission for deposit and as a result researchers’ free choice in publication route may be compromised.
HEFCE: We welcome further advice on repository use and on techniques for institutional repositories to cross-refer to subject and other repositories.
University: The flexibility of gold or green route to open access is welcomed. However, we are aware that both routes potentially carry high cost to the institution. The University of Northampton does not expect to be awarded significant funding by the Research Councils to support open access and will therefore have to find other monies to ensure compliance (i.e. to fund an open access publication fund and additional staffing to manage significantly higher full content deposits in the repository). Will HEFCE provide funds to subsidise these costs?
HEFCE: While we expect that sufficient clarity and reassurance on embargoes and licences will be achieved through the Research Council discussions, we welcome responses which address these issues.
University: Clarity and equitable treatment are essential.With respect to licensing, we would like assurance that the IP in research outputs with commercial potential should remain with the originator (and originating institution) of the work and that re-use by others should not be allowed without permission.
HEFCE: We welcome advice on the best approach to exceptions and on an appropriate notice period. Any cases made for exceptions should be underpinned by clear evidence.
University: We agree that a clear process for handling exceptions should be defined. Of the three options given in paragraph 11, we favour option b: to allow individual outputs to be exempt on a case-by-case basis. Assuming that clear, pertinent and preferably brief guidelines are provided, we believe that this option will offer the greatest flexibility and transparency. The guidelines should give examples of acceptable types of evidence (for exception) and should explicitly address licensing arrangements.
HEFCE: We seek comment on when it may be thought inappropriate to expect repository deposit of monograph text. Alternatively, given the percentage of submitted material which is in monograph form, we ask for advice on whether an expectation of a given percentage of compliance as described above (paragraph 18c) would eliminate the need for a special-case exception for monographs.
University: We agree that it is early days for a general approach to the deposit of monograph text in repositories and look to the sector to suggest best practice in this.
HEFCE: We invite comment on whether respondents feel this is the appropriate approach or whether they feel that sufficient progress has in fact been made to implement a requirement for open data as well. We will consider any representations that such a requirement may reasonably now be developed but would also need advice on how this might be achieved.
University: We recognise that the Research Councils are taking the lead in requiring access to research data and believe they are best placed to mandate this for funded researchers. Does HEFCE have plans to accept submission of research datasets to post 2014 REFs as outputs in their own right? If so, early advice on open access requirements for these would be welcomed.