February 11, 2019
AAP Submits Comments to cOAlition S on Plan S Implementation Guidance
Washington, DC; Feb. 11, 2019 – On February 6, 2019, the Association of American Publishers (AAP) filed comments with cOAlition S expressing serious concerns with the coalition’s “Guidance on the Implementation of Plan S” (the “Guidance”).
AAP’s full comments are available here.
AAP has long supported public policy frameworks that enable a mix of business models to achieve and continuously improve upon the objective of making important works of authorship readily available to those who want to read and/or share them. Many of our members are strong advocates of open science and offer researchers an increasing array of publishing options and tools to enhance the dissemination and impact of research publications. AAP believes that a robust and innovative licensing landscape is an important part of this objective, and that licensing options should continue to include models for open access where they are sustainable. AAP is committed to working together with research funders, scholarly authors, and other stakeholders to develop appropriately balanced frameworks in this regard.
Unfortunately, there is little such balance in the pending Plan S proposal. Having studied the Guidance, AAP is deeply troubled by the plan’s failure to recognize the value of publishers and the services that publishers provide to support scholarly authors in creating and disseminating journal articles, as well as the wide variety of business models that publishers employ in order to provide these important services. Instead, the Guidance mandates a one-size-fits-all approach to access and licensing that would (1) pose a significant threat to scholarly societies and the researchers they support, (2) restrict the foundational freedoms to write and publish, and (3) ultimately reduce investment in scholarly publishing by undermining copyright law.
Plan S was developed and announced without input or buy-in from key stakeholders in the scholarly publishing community, and without following basic principles of sound regulatory process. Among other things, cOAlition S did not offer stakeholders a notice-and-comment opportunity before announcing the foundational regulatory principles of Plan S, and likewise did not offer a notice-and-comment opportunity before crafting the Guidance. cOAlition S also failed to conduct formal impact assessments before developing Plan S and the Guidance, and the Guidance itself fails to even acknowledge, let alone resolve, significant stakeholder concerns raised throughout the process. Furthermore, elements of Plan S—such as undermining copyright law, picking winners and losers between business models, and proposing price controls—would undercut sound economic principles that have enabled innovation, diversity, and growth in scholarly publishing for decades.
AAP urges cOAlition S and the Plan S signatories to consider fostering open access through an inclusive, stakeholder-driven, and evidence-based process that considers the wide diversity of researchers, scholarly disciplines, reading audiences, and publishers that contribute to and benefit from scholarly publishing. This process would involve consulting with a broad range of stakeholders and receiving input and buy-in before crafting foundational principles. This process would also involve undertaking empirical analysis to identify and understand the important differences in scholarly disciplines, research communities, and reading audiences that have led to the wide diversity of publishing business models we see today.
Open access policies should be sustainable and should be designed to promote innovation and diversity in scholarly publishing. Furthermore, open access policies should be carefully crafted to avoid unintended consequences that would harm the dissemination of knowledge by reducing the quality and distribution of scholarly articles.
It is the strong view of the American publishing industry that Plan S, as outlined in the Guidance, is not a sustainable policy model for scholarly publishing, and AAP has serious concerns that Plan S will do considerably more harm than good. We have further explained this view in our comments.