On March 6, 2023, The Journal of Science Policy & Governance (JSPG) and the National Science Policy Network (NSPN) released Volume 22, Issue 01, the 2022 Standard Winter Issue of the journal.

The 2022 standard winter issue addressed topics that included open science, climate literacy, workforce development for careers in STEM, data transparency, knowledge infrastructure, space policy, social media, and governmental programs to better evaluate research funding outcomes. 

The Op-Ed, "Publish, Don't Perish: Recommendations for Mitigating Impacts of the New Federal Open Access Policy," authored by Alexander B. Belles, Karen E. Beatty, Claire H. Rodman, and Charles J. Connolly, included recommendations for stakeholders to address that provides both short-term and long-term solutions to address open access policies. ​

​In response, readers committed to open science submitted a letter to the editor. The response to the published Op-Ed is provided in full below. 

To the editor,
​
While it calls welcome attention to an important new policy development in access to publicly-funded research, the March 6 article by Rodman et al. leaves a few false impressions about the 2022 Nelson memo from the White House Office of Science and Technology Policy (OSTP). 

The authors support open access (OA) and want to facilitate grantee compliance with the forthcoming federal OA policies. So do we. But their analysis is undermined by two false assumptions. First, they assume that the only way for grantee-authors to comply with the new policies is to publish in OA journals. Second, they assume that all or most OA journals levy article processing charges (APCs). Building on these two assumptions, they focus their recommendations on ways to raise money to pay APCs. 

However, the Nelson memo is explicit in §3.a that agency policies should ensure “that all peer-reviewed scholarly publications authored or coauthored by individuals or institutions resulting from federally funded research are made freely available and publicly accessible by default in agency-designated repositories.” 

Grantees can fully comply with the policies by depositing the right version of their work in the right repository. That is entirely compatible with publishing in OA journals. But depositing in the right repository is necessary, and publishing in an OA journal is not.  

It’s possible that some agencies will create a second compliance channel for those who do publish in OA journals. But it’s too early to say. In any case, depositing in the right repository will suffice, and as far as we know today publishing in OA journals will not suffice. And even if some agencies will count publishing in OA journals as compliance, grantee-authors may still comply by depositing in a repository without paying an APC. 

The authors are right to point out that researchers, especially those early in their careers, are in a difficult position given the pressure to “publish or perish” in certain journals. The Nelson Memo provides universities with a new opportunity to re-think those pressures, focusing more on the research itself, and its quality and impact, than on the journal in which it was published.

Apart from charging no APCs, the repository method of compliance has other advantages for authors and addresses this concern. It preserves author freedom to submit new work to the journals of their choice, for example OA or non-OA journals. This is especially important for early-career researchers, who often face pressure to publish in non-OA journals. The repository method of compliance allows them to satisfy their funder and their promotion-and-tenure committee at the same time.

It has been well-known for more than 15 years that the majority of peer-reviewed OA journals do not charge APCs, even if the majority of articles in OA journals are currently published in the APC-based variety. Using data from today (March 28, 2023), the Directory of Open Access Journals lists 19,150 peer-reviewed OA journals, 68% of which charge no APCs. There is a wide variety of models in use to support OA journal publishing that do not require author-side fees, but rather draw on individual and collective funding from libraries, research institutions, and funders and which provide more equitable and sustainable operating models. 

The most important message for grantee-authors is that paying an APC is not necessary to comply with the new federal OA policies. If a particular journal charges an APC to publish an author’s federally funded research, authors should not draw the wrong conclusion. The fee is not to comply with the federal funder policy; it is to publish in that particular journal. There is no charge for compliance with the federal funder policies.

Signed,
Peter Suber, Senior Advisor on Open Access, Harvard Library
Heather Joseph, Executive Director, SPARC