Today I have submitted my comments on the RCUK proposed policy on access to research outputs. Here I am posting these comments publicly.

Summary

I am very happy to see these proposed changes in the RCUK’s open access policy. Especially so concerning your policy on text- and datamining described as:

Specifically stating that Open Access includes unrestricted use of manual and automated text and data mining tools; and unrestricted reuse of content with proper attribution

I do have strong objections to the acceptance of delayed open access as a valid form of open access. This may be a compromise so that (certain) publishers will accept the policy, however there are enough open access publishers that do not impose an embargo and I don’t see why we (scientists) should give in to the wishes of a specific group of publishers. For me any embargo is obstructing the advancement of science and the timely sharing of knowledge and should thus not be part of open access. I personally would also welcome it when you would refer in your open access definition to the Budapest or to the BBB definition, as we do on the website of the @ccess Initiative where I am an member. Finally, I would like to see more collaboration and cooperation with the EU digital agenda which in my view runs a same course as RCUK.

A few more comments and suggestions for some of the proposed changes are listed here below.

(2) What do the Research Councils mean by Open Access?

Search for and re-use the content of published papers both manually and using automated tools (such as those for text and data mining) without putting restrictions on the amount of data , provided that any such reuse is subject to proper attribution.

(3) How is a Scholarly Research Paper made Open Access?

but in practice the Research Councils will accept that access may be restricted to comply with an embargo period imposed by the publisher

 embargo period is not acceptable

(4) What do journals need to do to be compliant with Research Council policy on Open Access?

a) This may require payment of an ‘Article Processing Charge’ to the publisher

I recommend adding a note on what is an acceptable charge because this should not be left open

(5) What Research Outputs will be covered by Research Council Policy on Access to Research Outputs and where should they be published?

No comment

(6) When should a paper become Open Access?

In future, Research Councils will no longer be willing to support publisher embargoes of longer than six or twelve months from the date of publication, depending on the Research Council

Delayed open access not acceptable (see summary above)

(7) How is Open Access paid for?

Research Council grant funding may be used to support payment of Article Processing Charges to publishers

I think that the policy to have open access papers paid from grants is a good one. I would however impose limits to an acceptable APS see comment under (4)

(8) Acknowledgement of funding sources and access to the underlying research materials

The underlying research materials do not necessarily have to be made Open Access, however details of relevant access policies must be included

In my opinion that the underlying research materials can not be seen as separate from the results of research, they should fall under the same rules and should be open access. In fact the underlying data are vital to be able to judge the quality of research. However, I do recognize the need for exceptions for some datasets like patient medical data, but for these cases a list of exceptions would be sufficient.

(9) Implementation and compliance

No comments except for agreement

Dr. Tom Olijhoek
Independent researcher
Consultant Dutch Malaria Foundation
Ass. Editor MalariaWorld Journal
Group Coordinator @ccess Initiative
1336GB Almere
The Netherlands
tomolijhoek@malariastichting.nl
@greboun