Many of my readers may recall that back in October I published a post announcing the Draft Open Access Policy consultation process launched by the Canadian Tri-Councils -- Social Sciences & Humanities Research Council, Natural Sciences & Engineering Research Council and Canadian Institutes of Health Research. The deadline for submissions was December 13th. Since the deadline was just before the holidays I thought it best to wait awhile before compiling all the publicly posted responses. And that was probably a good idea, as many of the responses were published in the new year. I imagine that a few more may trickle in, but I'll add those to the list.
As you can see from the list below, there are a wide range of responses, from people, from societies, from institutions and even from a publisher.
My institution also gave a response which is included below. I was on the working group that consulted the campus community and composed the response. I also sent the Tri-Agencies my own personal response, which is immediately below.
What do I think of the responses themselves? Mostly they are all very positive and supportive. There are some misconceptions, there is a bit of perhaps misplaced caution and a tiny hint of fear, uncertainty and doubt but overall I am quite pleased by the responses. I think the Tri-Agencies have a lot of digest and I definitely look forward to seeing what they have to offer. The challenge will be to move the conversation beyond a certain deference for the cadre of entrenched incumbents that are leery of any change.
The best way for the Tri-Agencies to do that is to make sure that legitimate concerns are addressed and to make available the resources that are needed to ease the transition of all those entrenched interests to a more open world. In other words, have a plan, lay it out clearly with precise expectations for all involved and put the systems and resources in place to make it happen without anyone feeling they've been voted off the island.
Here is my response:
To the Tri-Agency (Canadian Institutes of Health Research, Natural Sciences and Engineering Research Council and Social Sciences and Humanities Research Council),
I am glad to see the Tri-Agency views research as a conversation among scholars, one that the Canadian public supports and advances through the Tri-Agency’s funding programs. It is clear to me that the Tri-Agency has decided that if the Canadian people are going to fund scholarly conversations, then those conversions should happen where the Canadian people can see and participate, as openly and as publicly as possible. This is accomplished by requiring that Tri-Agency funded scholars ensure that their relevant research outputs are made open access.
I would recommend two recent blog posts by Barbara Fister which deal with research as a conversation.
From Things to Conversations
From Conversations to Things
Some suggestions for the final version of your Draft Policy:
- You mention that the publication-related research data responsibilities that CIHR has in its policy will not be extended to SSHRC and NSERC. I would hope that you would change your mind and extend similar responsibilities to all the agencies. The rationale for making appropriate data available is the same, so the responsibilities for all researchers should be the same.
- Your requirement for research outputs to be open access within 12 months is fairly standard in among similar policies. Notwithstanding that, I would like to see the time frame be 6 months which is much better for time-sensitive scientific and health-related research.
- You mention that the policy will only apply to peer-reviewed journal articles. Given that the importance of journal articles can vary by discipline, I would hope that you will extend the requirement to all peer-reviewed research outputs. I understand that monographs are an issue here for many scholars, so at very least conference papers and book chapters should be included in your policy.
- Your requirement for authors to self-archive non-open access articles is very important. However, the requirement to post the final peer-reviewed full text version of the article may unnecessarily restrict the non-open access publishers that researchers will be able to publish in. I hope that you will consider clarifying this requirement.
- One new thing I would like to see included is explicit grant support for open access author processing charges. These should be awarded completely separate from the rest of the grant so that in cases where a researcher includes the fees in their initial grant but the actual amount awarded is lower than requested, the researcher will not feel squeezed to both pay the charges and continue to properly fund their core research activities. Perhaps this is an opportunity to collaborate with the library community to manage these funds.
- The Tri-Agencies should be sensitive to disciplinary differences around scholarly communications while still firmly and unwaveringly requiring open access to as broad a range of the research outputs they fund as possible.
Thank you very much for this Draft Policy; it is a major step forward for scholarship in Canada. I very much look forward to the final version. I hope that the implementation of the final policy will encourage collaboration among all the relevant stakeholders, including government, libraries, colleges and universities, publishers, scholarly societies and others.
Thank you for your time and attention,
Personally gratifying was that the Tri-Agencies chose to include my own Resources on Open Access in Canada in their FAQ. York's Open Access Publishing Toolkit was also included. Both are nice nods to the commitment to open access and scholarly publishing reform from librarians and administrators here at York.
In no particular order, here are all the publicly posted responses I have been able to find. If you know of others I've missed, please let me know either at jdupuis at yorku dot ca or in the comments. Thanks to my colleague Barbara McDonald for suggesting I collect these in the comments to my initial post.
- Canadian Association of Physicists
- A Submission on the Proposed Tri-Council Open Access Policy by Rowland Lorimer, Professor of Publishing, Simon Fraser University
- Dan Morgan, Senior Manager – Global Academic Relations (North America), Elsevier
- Federation for the Humanities and Social Sciences
- Centre for Mathematical Biology, University of Alberta
- York University
- Canadian Association for Graduate Studies
- Granting councils consider mandatory open-access policies: Move by NSERC, SSHRC would align them with CIHR and funding councils in other countries by Rosanna Tamburri
- Canadian Psychological Association
- Tri-Councils to require open access publishing by Jeremy Richards
- Canadian Historical Association / Dominique Marshall, President
- Open Letter to SSHRC on Open Access by Hendrik Kraay
- Open access threatens journals by Heather Sparling
- Advocates for Canadian Open Access (ACOA): Draft response to Draft Tri-Agency Open Access Policy
- Draft Tri-Agency Open Access policy: my response by Gavin Simpson
- Canadian Association of Research Libraries (CARL)
- Canadian Research Knowledge Network (CRKN)
- Canadian Library Association (CLA)
- Canadian Association of University Teachers (CAUT) (press release)
- Submission on Tri-Agency Open Access Policy by Samuel Trosow
- Harnad Comments on CANADA'S NSERC/SSHRC/CIHR DRAFT TRI-AGENCY OPEN ACCESS POLICY PROPOSAL by Stevan Harnad
- Draft Tri-Agency Open Access Policy by N. Lemay
- Canada's tricouncil draft open access policy: my comments by Heather Morrison
- Open Access by Christine Jewell
- Saskatchewan Library Association
- Brock University
- Federally-funded research may become free by Yuko Inoue
- Athabasca University Faculty Association
As usual, I welcome any feedback or suggestions for items I have have missed. And please feel free to add your own thoughts about the Draft OA policy in the comments.