[BOAI] Some Nudge! Some Notion!

[Stevan Harnad]

*Critique of excerpts from UK Government
<http://www.publications.parliament.uk/pa/cm201314/cmselect/cmbis/833/83304.htm>
Response
to BIS Committee
<http://openaccess.eprints.org/index.php?/archives/1040-.html> *




*Joint "Re-Engineering" Plan of UK Government and UK Publisher Lobby for
"Nudging" UK Researchers Toward Gold Open Access*

*UKGOV: "...in the long term the most effective form of OA will be Gold
OA…. there is no distinction to be made between the Government's and
BISCOM's direction of travel for OA. The envisaged final destination is
likely to be what the Finch Group termed a 'mixed economy' of Gold and
Green OA, the proportions of which the decisions of researchers and
behaviour in the market will decide…"*

Throughout its response, it is evident that the UK Government is not
perceiving OA primarily as a means of maximizing UK research uptake and
impact -- for the benefit of the UK tax-payers that fund the research, and
for the progress and productivity of research, in the UK and world-wide --
but as a means of sustaining the current revenue streams of peer-reviewed
journal publishers, come what may.

That is why the Government's "travel" plans tend to be framed far less in
terms of the real needs of UK research and researchers and far more in
terms of "business models," "market," a "mixed economy," and how these can
be "re-engineered" to keep them congruent with publishers' terms and
timetable.

There seems to be little room in the UK Government's vision for even
considering the following contingencies:

-- that 100% OA is not only already fully feasible today, thanks to the
online medium, but also urgent for research and researchers, indeed already
overdue;

-- that the online era has already made a lot of the traditional products
and services of journal publishers (and their costs) obsolete;

-- that publishers' current revenue streams are greatly and needlessly
inflated;

-- and that the embargoes and other retardants that publishers are
themselves placing in the path of OA are not, in reality, necessities, to
sustain the essential functions of peer-reviewed journal publishing, as
publishers claimù; they are merely contrived to prop up the expensive and
obsolescent functions of publishers *in order to sustain publishers'
current highly inflated levels of income* at all costs, come what may.

What is keeping the economy "mixed" and slow to provide OA, in other words,
is that *publishers are holding OA hostage to their current revenue streams*,
by embargoing Green, and transitioning to Gold only on terms and on a
timetable that guarantee those revenue streams.

The UK Government's "re-engineering" plans are designed to make sure any
transition stays on that track.

*UKGOV: "...Government's approach, therefore, amounts to a subtle
re-engineering of the present market. By 'nudging' the flow of revenue for
the publishing industry towards it becoming income from Article Publication
Charges (APCs) for Gold OA…"*

This "subtle re-engineering of the present market" consists of sustaining
current publisher income streams (and *modera operandi*) by only providing
OA on condition that current subscription revenue levels per article are
sustained, and continue to be collectable in the form of Gold APCs in place
of subscriptions.

The is no thought given to the distinct
possibility<http://www.dlib.org/dlib/july10/harnad/07harnad.html>
 that *with all peer-reviewed final drafts deposited in institutional Green
OA repositories, there will no longer be any need or demand for a print
edition, online edition, access-provision or archiving (and their
associated costs)*from the peer-reviewed journal publisher: only the need
for peer review (which is only a fraction of the cost of subscription
publishing today).

And no thought of the real "market" that could indeed decide whether in a
100% Green OA world there will be any real demand left for anything else
that peer-reviewed journal publishers offer, forcibly co-bundled with the
peer review.

UK publicly funded research is being conceived by the UK Government as if
it were primarily an investment in the journal publishing industry rather
in research productivity, applications and progress.

Some "nudge"! Some notion!

*UKGOV: "...96% of journals have an embargo period of 24 months or less;
64% of journals have an embargo period of 12 months or less… This
illustrates the extent to which the Government's policy already is being
complied with…"*

Hardly. The effect of the UK policy has been precisely the opposite. More
and longer embargoes have been adopted by publishers since the new UK
policy was announced and began to be implemented.

Yet despite this perverse effect, the percentage of publishers that endorse
immediate, unembargoed Green OA remains over
60%<http://www.sherpa.ac.uk/romeo/statistics.php?la=en&fIDnum=|&mode=simple>according
to SHERPA Romeo data (much as it was before the Finch/RCUK policy). (This
figure is camouflaged in the Government's composite category of 64% with
"an embargo period of 12 months *or less *.")

*UKGOV: "...The Government, through HEFCE and the Research Councils, will
continue to encourage Jisc, the Open Access Implementation Group (OAIG) and
others to promote standardisation and compliance across subject and
institutional repositories…"*

Far more important for the UK Government to promote would be the
institutional adoption of a mechanism for verifying compliance with its OA
policy<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=mechanism+compliance++blogurl:http://openaccess.eprints.org/&safe=active&tbas=0&tbm=blg>
--
in particular, its Green option (rather than just focusing on how the Gold
is spent). HEFCE<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=hefce+immediate+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
has
provided a potential mechanism, in requiring immediate
deposit<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=%22immediate+deposit%22+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
(whether
or not OA to the deposit is embargoed) for REF eligibility. Institutions
(ever eager to ensure compliance with funders' conditions) will thereby be
recruited and strongly motivated to monitor and ensure timely compliance.
(Funding that would be a constructive use for unspent RCUK Gold OA funding.)

*UKGOV: "...RCUK have balanced the objective of timely OA to all users with
the need to respect, through a mutually acceptable embargo period,
sustainable business models…"*

Translation: RCUK has collaborated with publishers in embargoing OA to make
sure that OA is only provided on publishers' terms and timetable. (This is
the UK/publishing-industry "re-engineering" plan.)

Fortunately, there is a remedy for this, and that is the HEFCE
immediate-deposit
mandate<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=%22immediate+deposit%22+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>,
plus the institutional repositories' automatedrequest-a-copy
Button<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=button+blogurl:http://openaccess.eprints.org/&safe=active&tbas=0&tbm=blg>,
which allows users to request and authors to provide (with one click each)
a copy for research or educational purposes during any embargo (i.e.,
the Liege-model
mandate <http://orbi.ulg.ac.be/handle/2268/102031>, which is the one the UK
should adopt.)

*UKGOV: "...A re-engineering of the research publications market entails a
journey not an event. Necessarily it requires a period of transition for
the process of change. Longer embargo periods, as illustrated below, play
an important part under some circumstances during the transition process…"*

Translation: RCUK has collaborated with publishers in embargoing OA to make
sure that OA is only provided on publishers' terms and timetable.

This "journey" to "re-engineer the research publications market" is
actually a government-funded business trip to guarantee publishers' current
income at UK tax-payers' expense (and at the cost of lost research usage
and impact). Not a happy "event" for UK research and researchers -- or for
global OA.

*UKGOV: "...Government believes that the first signs of the impact of its
OA policy on embargo periods have been beneficial…"*

Beneficial for publishers, perhaps, but certainly not for researchers, nor
for OA, since the policy's perverse effect has been to encourage publishers
to adopt and extend embargoes, not to shorten or drop them. (Nevertheless,
over 60% of journal still do not embargo Green OA, despite the UK OA
policy.)

*UKGOV: "...as stated in David Willetts' letter of 20 June 2013, UK policy
already is leading to shorter embargo periods for Green OA…"*

It is very hard to imagine what David Willetts is imagining here: The
adoption of a Green OA embargo that is within Finch/RCUK's current
allowable limits is hardly a triumph for OA if the publisher formerly did
not embargo Green OA at all (or had not yet formulated a policy).

Moreover, an embargo of a year or longer is no boon at all for OA. It is
unspoken, but I think it's fairly clear that *most publishers are by now
resigned to one-year embargoes on Green*, along with a mandated push toward
hybrid Gold. They know that most of the revenue in question comes from that
first year.

So a "deal" to let publishers hold OA hostage to that one-year embargo (or
else pay Gold) is not good news for research and research progress in an
era where immediate 100% Green OA is fully within reach, technically and
practically speaking, and where the costs of peer-reviewed journal
publishing could be radically reduced if freed from the grip of publisher
Green OA embargoes.

But again, there is a remedy for this, and that remedy is the
HEFCE<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=hefce+immediate+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
 immediate-deposit
mandate<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=%22immediate+deposit%22+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>,
plus the institutional repositories' automated request-a-copy
Button<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=button+blogurl:http://openaccess.eprints.org/&safe=active&tbas=0&tbm=blg>,
which allows users to request and authors to provide (with one click each)
a copy for research or educational purposes during any embargo. (This is
again the Liege-model mandate <http://orbi.ulg.ac.be/handle/2268/102031>,
which is the one the UK should adopt.)

*UKGOV: "...Publication of the results of publicly funded research is an
integral part of the research process…"*

This re-statement of the Wellcome Trust
mantra<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=wellcome+publication+research+costs+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
continues
to ignore the fact that *the UK (but not Wellcome) also has to pay the
costs of journal subscriptions*. Hence the Gold APC costs are over and
above subscription costs (which are likewise "a legitimate part of the cost
of undertaking research").

That means Gold OA APCs today are needless double-payments, over and above
uncancellable subscriptions: "Fool's
Gold<https://www.google.ca/?gws_rd=cr&ei=b-CUUuTZNM-3kQeAj4CACA#q=harnad+(fools+OR+fool's)+gold>."
The only way they can turn into "Fair
Gold<https://www.google.ca/?gws_rd=cr&ei=b-CUUuTZNM-3kQeAj4CACA#q=harnad+%22fair+gold%22>"
is if mandatory Green OA first prevails, eventually allowing subscriptions
to be cancelled<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=transition+green+gold+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
(and
driving down publication costs by offloading access-provision and archiving
onto Green OA repositories).

Then the price of Gold will drop to a fair, affordable, sustainable level,
single-paid out of the institutional subscription cancellation savings,
instead of double-paid, needlessly, as now, out of scarce UK research
funds. -- Needless, because while subscriptions are still being paid (fully
and fulsomely), Green OA can provide the OA.

*UKGOV: "...HEFCE and other Funding Councils have agreed that QR funding
may be used [to pay for Gold] at the discretion of the HEIs. Hence, HEIs
have access to the necessary public funds to cover the cost of implementing
the Government's and RCUK's OA policy…"*

For UK researchers and institutions who deplore wasting research funds to
pay publishers even more money, it is hardly solace to tell them that if
their UK Gold allotment runs out, they can squander their research money
from other sources too.

(But fortunately, be the Government ever so grudging about it, freedom of
author choice between Green and Gold is now restored by RCUK, so the best
protection against wasting UK research funds on Gold is to provide Green
instead, via immediate-deposit<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=%22immediate+deposit%22+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>,
irrespective of embargo-length.)

*UKGOV: "...The Government is aware of the reluctance of some HEIs to
promote the Government's preference for Gold OA, on the grounds that it
represents a reduction in funding available for research, but the cost of
the Government's funded OA policy is estimated to be… approximately one per
cent of the science budget… This is a marginal cost expected to be
outweighed by the benefits to the economy arising from direct innovation
and spill over benefits…"*

(1) As noted, the UK's designated funding for outgoing UK Gold is far from
being the whole of the UK's publication funding: The UK continues to pay
for essential incoming journal subscriptions. And it is that level of
spending that the UK is collaborating with publishers to "re-engineer" so
as to sustain it whether it's paid in the form of subscriptions or in the
form of Gold APCs.

(2) So the extra marginal costs of the UK Gold subsidy (a further 1% of the
UK's research spend) are over and above the existing UK publication spend.

(3) Researchers cannot be expected to welcome the loss of yet another 1% of
their already sparse research funding -- and especially not when it is lost
just for the purpose of propping up publishers' already inflated revenue
levels, come what may, in exchange for an OA that researchers could have at
no further expense (beyond the existing UK subscription spend) via Green OA
-- *if it were not for the publisher embargo on it* -- an embargo that the
UK government is reinforcing, with its joint "re-engineering" plans to
"nudge" researchers toward Gold OA.

Fortunately, there is a remedy for this, and that is the
HEFCE<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=hefce+immediate+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
 immediate-deposit
mandate<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=%22immediate+deposit%22+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
--
plus the institutional repositories' automatedrequest-a-copy
Button<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=button+blogurl:http://openaccess.eprints.org/&safe=active&tbas=0&tbm=blg>,
which allows users to request and authors to provide (with one click each)
a copy for research or educational purposes during any publisher embargo
(i.e., the Liege-model mandate <http://orbi.ulg.ac.be/handle/2268/102031>,
which is the one the UK should adopt.)

Because RCUK has restored authors' freedom of choice of journal, and
because HEFCE<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=hefce+immediate+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
proposes
requiring immediate-deposit<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=%22immediate+deposit%22+blogurl:http%3A%2F%2Fopenaccess.eprints.org%2F&safe=active&tbm=blg>
for
REF eligibility, UK researchers can choose to publish in any journal and
can fulfill the RCUK mandate through immediate deposit in their
institutional repository, whether or not OA to the deposit is embargoed. It
is this immediate deposit that can -- with the help of the repository's
automated request-a-copy
Button<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=button+blogurl:http://openaccess.eprints.org/&safe=active&tbas=0&tbm=blg>
during
any embargo period -- "re-engineer" publishing to Fair
Gold<https://www.google.ca/?gws_rd=cr&ei=b-CUUuTZNM-3kQeAj4CACA#q=harnad+%22fair+gold%22>
(after
100% Green OA has prevailed, and made it possible for publishers to
downsize to an affordable, sustainable price for peer review alone) instead
of theFool's Gold<https://www.google.ca/?gws_rd=cr&ei=b-CUUuTZNM-3kQeAj4CACA#q=harnad+(fools+OR+fool's)+gold>
toward
which the UK government has set the "direction" for the UK's "journey"
toward OA.

*BISCOM:* "The Government and RCUK should clarify that Gold open access is
the ultimate goal of, rather than the primary route to, their open access
policies. We recommend that the Government and RCUK reconsider their
preference for Gold open access during the five year transition period, and
give due regard to the evidence of the vital role that Green open access
and repositories have to play as the UK moves towards full open access.
(Paragraph 70)"

*UKGOV: "...Gold OA, at 12 per cent, is now proving to be the dominant form
of OA.*

Gold OA the dominant form of OA? Far from the truth.

Spontaneous, unmandated Green OA is already twice that figure, and if
effectively mandated (on the
HEFCE<https://www.google.ca/search?hl=en&lr=&q=harnad%20OR%20Harnad%20OR%20archivangelism+blogurl:http://openaccess.eprints.org/&ie=UTF-8&tbm=blg&tbs=qdr:m&num=100&c2coff=1&safe=active#c2coff=1&hl=en&lr=&q=harnad+hefce+blogurl:http://openaccess.eprints.org/&safe=active&tbas=0&tbm=blg>
/Liege <http://orbi.ulg.ac.be/handle/2268/102031> model) Green OA is over 10
times that figure <http://eprints.soton.ac.uk/358882/>, with the majority
of deposits being done even before the date of publication.

*UKGOV: "...the Government and RCUK would maintain that the merits of Gold
OA (immediate, final published version, compatibility with data mining,
unrestricted access and re-use, with attribution) mean that it is preferred
to Green OA.*

Preferred by whom? Finch/RCUK or UK researchers (and the rest of the world)?

(1) Much of today's Green OA is immediate; some of today's Gold OA is
delayed. The embargoes are a result of publisher preference to sustain
their current revenue levels come what may.

(2) To researchers who are denied access to unaffordable publishers'
versions, toll-free online access to the author's Green OA final draft is
the difference between night and day, insofar as research applications and
progress are concerned.

(3) While access itself is restricted (both by publishers' subscription
access tolls and by publishers' OA embargoes) freeing access is
incomparably more important and urgent than paying publishers still more
for further re-use rights.

(4) The fastest, fairest and surest way to reach Fair Gold OA and all the
re-use rights users need and authors want to provide is to first mandate
that authors provide Green OA -- rather than to require pre-emptive
double-payment, over and above uncancellable subscriptions, out of scarce
research funds, for Fool's Gold OA, at arbitrarily inflated prices, on the
pretext of needing to sustain publishers' current revenue streams
(otherwise peer-reviewed publishing will perish).

*UKGOV: "...The use of repositories is a feature of both Gold and Green OA.
In terms of the sustainability of long term access to published research
and data…"*

Before institutional repositories can *preserve* access they must first
*provide* it.

(There are no publisher embargoes holding up data-archiving, so it is a red
herring to mention data in this context.)

The remedy is again obvious (to all but the UK Government: the publishing
lobby is certainly fully aware of it, because it is fighting it tooth and
nail):

Mandate immediate-deposit of all articles, whether published in a
subscription journal or a Gold OA journal, whether OA is embargoed or
immediate, whether the OA is Gratis (toll-free online access) or Libre
(toll-free online access plus various re-use rights such as text-mining,
re-mixing and re-publication).

That, with the help of the Button, will ensure that 100% Green Gratis OA --
and eventually Fair Libre Gold OA -- will come to pass as quickly as
possible: affordably, scalably and sustainably.

*UKGOV: "...the UK OA Decision Tree sets out clearly the direction of
travel. This is not incompatible with researchers having a free choice as
to whether or not to follow the preferred path. Government and RCUK hope
they will choose to do so. Government welcomes RCUK retaining this decision
tree. It has been agreed by all affected parties, and does not simply
reflect the publishers' position, but the consensus position arrived at by
members of the Finch Group…"*

I suppose it's enough that the Government agrees that UK researchers and
institutions are free not to follow the preferred path, hence can ignore
the decision tree.

But it would have been more forthright and sensible to abandon the decision
tree altogether, rather than leave it as a misleading sign-post.

It is indeed true that the UK-Government/Publishing-Lobby joint
"re-engineering" plan for "nudging" UK researchers toward (Fool's) Gold
Open Access "does not simply reflect the publishers' position, but the
consensus position arrived at by members of the Finch Group."

But what is patently false is that it has "been agreed by all affected
parties."

*UKGOV: "...Government believes that by [funding hybrid Gold] the rate of
adoption of Gold OA by publishers and researchers alike will accelerate…"*

No doubt it will. But the goal of UK research, researchers, their
institutions and the UK tax-payers who are funding the research is not to
accelerate the UK rate of adoption of Gold OA but to accelerate the
worldwide rate of provision of OA.

*UKGOV: "...Evidence quoted above from the Publishers Association suggests
that this is already proving to be the case. Researchers would be
disappointed to have publication in their favoured journals denied to them
if they opt for Gold OA and publishers would not want the inefficiencies,
or brand dilution effects, of always putting publication of Gold OA
material in to a new and separate journal…"*

This ludicrous and embarassing piece self-promotional spin is so obviously
a page borrowed from the publishers' agenda that it does not deserve a
reply. It is shameful that the Government of the United Kingdom is echoing
this tendentious sales pitch as its own.

*UKGOV: "...Government does not consider it appropriate for publishers to
rely on retrospectively amortising their APC revenue to discount global
subscription rates, as some now do. This may address 'double-dipping' in
one sense, (no increase in total revenue to the publisher) but it does
nothing to address the concerns of research intensive individual
institutions, wherever they are located around the world. Such institutions
paying APCs for Gold OA publication in particular journals should see some
related and proportional discount in their total subscription fees, with
the same publisher, to avoid them disproportionately funding the
translation to Gold OA…"*

This pious homily is actually masking a piece of uncritical, unreflective
and unrealistic nonsense:

If the Government agrees that a UK subscription rebate of only 6% of a UK
Gold OA 6% overspend (i.e., 6% of 6%), over and above the UK's 100%
subscription spend, is not an "appropriate" way to abstain from
double-dipping, what on earth does the UK imagine publishers will do
instead? Because if publishers simply deduct the fee for UK hybrid Gold OA
from UK subscription fees, that's just tantamount to say the UK can have
hybrid Gold OA for free.

That would be just fine (since subscription fees are already paying the
costs of publication in full): UK authors would automatically be free of
embargoes and would automatically retain all desired re-use rights for the
hybrid Gold journals in question.

But that's not at all what publishers have in mind (so I suggest that the
UK re-discuss their joint "re-engineering" plans in this regard).

Here's a hint: *Publishers are only interested in a transition scenario
that guarantees sustaining their current revenue levels*. They are just as
averse to immediate-Gold OA as to immediate-Green OA, because it is the
sustainability of their current revenue levels that is at risk. So unless
the hybrid Gold fees are real and sustainable -- which they are not, if
they are merely funny-money available to every subscribing institution as a
free bonus -- publishers will not budge on the UK Government's plaintive
nudge for "proportional discount in their total subscription fees."

*Stevan Harnad*
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