Response to the Research Excellence Framework (REF) 2029 Open Access Consultation
The four UK higher education funding bodies (Department for the Economy Northern Ireland, Higher Education Funding Council for Wales, Research England and Scottish Funding Council) opened a consultation in March of 2024 on their proposed guidelines and requirements on Open Access for REF 2029. The Association for Art History submitted a response to the consultation in June 2024 which focused on the concerns and particular areas of interest of those in our field.
The consultation comprised questions in three sections concerning: OA developments in the higher education sector, journal articles and conference proceedings, and the proposed expansion of an OA requirement for long-form publications. Limits of 3,000 characters were imposed for question 4, and 1,500 for all other questions. Information on the consultation, administered by Research England, can be found here.
SECTION A: Open access developments in the sector
4. What are the most important changes in the open access landscape since the development of the REF 2021 open access policy? 1) How do these differ across disciplinary areas? 2) What are the implications of these changes for the REF 2029 open access policy?
The changes in the open access landscape since the 2021 REF policy have included the increased number of journal articles in the arts and humanities being published under OA licences and the concomitant lessening of publishing revenues realised by subject associations/learned societies which publish scholarly journals.
A very significant change to the broader higher education landscape since the previous REF policy is the worsening financial health of HEIs who regularly refer to the “unsustainable financial model” they are operating under which has led to over 70 HEIs reducing or eliminating arts and humanities provisions since 2020, with 25 doing so in the last several months, and to the reduction and elimination of research funds for individual researchers. This situation is very likely to pertain through the 2029 REF cycle regardless of which party wins the upcoming election.
It is apparent that the proposed extension of OA requirements to long form publications would increase costs significantly, with the burden, in humanities disciplines, usually falling on universities and individual researchers to find sources of funding for OA publications and licences for third party held material. These increased costs are not cited in the consultancy documentation, and therefore, we assume that research has not been undertaken to determine the level of funding which would be necessary to extend OA requirements to long form publications.
Even if there were not a funding crisis in the HE sector, it seems clear that the extra costs for universities and researchers to bear in publishing more in OA would be a challenge and would take away from QR funding. However, with the financial straits in which UK universities find themselves, it seems an inopportune time, to say the least, to extend OA requirements which will place another untenable burden on HEIs and researchers. At the same time, the ability of subject associations to help fund research/OA costs has been severely hampered by the onset of OA publishing. This is the case with the Association for Art History which has seen income from its journal, which is used, among other things, to fund the research grants we give, reduced by 55% in the last several years.
The reduced funding available in the HE sector and the increased demand for it with expanded OA requirements will lead to an inequitable distribution of support of OA publications which favour those in larger/wealthier HEI’s; increased difficulty in publishing in OA for those without affiliation (including ECRs) and the deleterious effect this has on EDI efforts; and less scholarship published in the UK of researchers from regions where funding or an infrastructure of support does not exist (e.g. they are not part of institutional or country-wide ‘read and publish’ deals).
Given the above, we are not favour of extending the OA requirement for REF credit to long-form publications.
Section B: Journal Articles and Conference Proceedings
5. Should deposit requirements post-acceptance be maintained where publication is not immediately open access?
No. We welcome the move from acceptance to publication as starting point for repository deposit or the tolling of embargo periods.
6. Do you agree with alignment to the UKRI open access policy in respect of licensing for journal publications by requiring licensing terms equivalent to CC-BY or CC-BY-ND licensing for journal publications? What, if any, negative or positive impacts might there be from this change?
No. We welcome that fact that a CC-BY-ND licence for journal articles is accepted. However, we would encourage the four funding bodies to also accept a CC-BY-NC-ND licence—i.e. adding a non-commercial restriction as is proposed for long-form publications.
We believe that the concerns that the four funding bodies have around the commercial use of research in those publications also pertain to journal articles. We do not think that allowing for the commercial re-use of scholarly material furthers the REF goals of making the results of research freely available to all potential users. Rather, it simply encourages other entities to profit from the labour of researchers and editors without recompense, and would not a commercial use, which would involve some payment to access the material, be against the very proposition of OA? Those commercial entities include other publishers and, worryingly, AI creators who, without an NC licence in place, will be able to re-use material from journal articles with impunity and for their own financial gain.
7. Do you agree with recognition of alternative platforms as meeting open access requirements as primary platform for publications?
No. For the most part, pre-prints of journal articles are not published/distributed in our discipline. Researchers appreciate the value of, and rely upon, the version of record for journal articles. To be of use in our discipline, content on alternative platforms would have to have gone through the editing process.
8. Do you agree with the proposed changes to embargo periods for journal publications for main panels A and B (12 months reduced to 6 months) and main panels C and D (24 months reduced to 12 months), in light of changing standards and practice? What, if any, negative or positive impacts might there be from this change?
No. For humanities journals that cannot viably flip to OA, reducing the embargo period from 24 to 12 months would make academic publishing an even more tenuous a proposition than it already is. With a shorter embargo period, subject associations, and publishers, will be less able to recoup the investment they make into producing journal articles.
Libraries will be less likely to purchase journals and subject associations will be less likely to recoup the significant investment they make in soliciting, securing, peer-reviewing, editing and publishing high-quality scholarly content. This would, in turn, further limit the ability of the associations to provide support for researchers.
For these reasons we recommend that the embargo period remain at 24 months.
9. Do you agree that changes to the open access policy for journal-based publications should be implemented from 1 January 2025?
No. An implementation date of 1 January 2025 is too soon given that the REF policy will not be announced until autumn of 2024. The short window will result in the policy being applied to articles that are already in production under the previous guidelines though will be published under the new guidelines. For that reason, we recommend that the new policy be implemented on 1 January 2026. This will give researchers and subject associations ample time to ensure that journal articles will be compliant from the inception of the publishing process.
10. Do you consider that tolerance limit for articles and conference proceedings should be retained at 5% of any submission?
No. We are encouraged by the high compliance level in REF 2021, and that tolerance levels do not include submissions which fall under an exception to the REF policy. However, as HEIs are struggling more recently than they were during the last REF and, as such, will be able to offer less support for OA publications, we would like to see the tolerance limits increase to 10%. This will help to accommodate for decreased funding for APC’s, particularly at smaller institutions and those, such as ECRs, with less ability to sustain their research support through these very lean years for HEIs.
11. Do you agree with the proposed exceptions for journal publications?
Yes, none should be removed. We welcome the exceptions for journal publications. They are reasonable and accommodate some of the challenges faced by researchers in satisfying the OA policy.
We suggest an expansion to the first exception to include instances where third party material is prohibitively expensive to obtain. Researchers have found that the cost of obtaining traditional licences/permissions for image use can be prohibitive in its own right. Researchers usually need to apply for grants specifically to help with image costs (The AAH offers small grants in this area with the revenues from its publication, which, as noted are significantly lower than in recent years). Rights for OA licences are, by definition, more expensive to secure as costs for images are based on distribution runs and can be time limited—a licence for unlimited access in perpetuity will invariably increase the already substantial financial burden on researchers.
In administering this exception, we advocate for a process that is streamlined and easy to apply for, rather than, for example, requiring authors to provide comparative data for traditional and OA licences for each image used.
We would also advocate for an exception for researchers whose articles were largely researched and written while they were unaffiliated and which are subsequently included in a REF submission. These researchers are much more likely to have difficulty securing funding for their research and the costs of publishing in OA.
Section C: Longform Outputs (monographs, book chapters, and edited collections)
12. Do you agree that there should be no deposit requirement for longform publications, but that they should be made immediately available as open access upon publication (or no later than 24 months following publication if subject to an embargo)?
Not sure. As stated in the answer to question 4, we do not think that OA requirements should be extended to long-form publications. However, we will provide answers to questions 12 to 19 should the OA requirements be put in place. We agree that a deposit requirement should not be applied to long-form publications. If an embargo period is put in place, it should be longer than 24 months (see answer to Qs 8 & 13).
13. Do you agree with the proposal of a maximum embargo period of 24 months for longform publications?
No. We are concerned that publishers will be less interested in publishing long-form publications and libraries will be less likely to purchase them when they know they will be freely available after two years. We recommend that, if imposed, an embargo period be at least 36 months and optimally 60 to help ensure continued investment in and purchase of long-form publications. While the funding bodies assert that most of the revenue from such publications is realised within the first two years after publication, we do not know the impact on the market if the rest of the revenues over the lifetime of a publication can never be realised. Will this mean, for example, that publishers will become more risk averse and agree to publish more frequently from established authors and less from ECRs whose publications are often needed to secure academic posts? Will important, but less saleable publications be passed on by publishers? We appreciate that these concerns have to be balanced by the funding bodies’ desire to make scholarship freely available, but if the publishing ecosystem is further tested, scholarship may be less available than it currently is in the long run.
In addition to encouraging the funding bodies to undertake research on the costs of the proposed new requirements for long-form publications, we also ask them to consider direct consultation with publishers, beyond this exercise with its attendant character limits, on the viability of some of the requirements.
14. Is licensing for third party materials not being granted a reasonable ground for exemption from open access requirements?
Yes. This is an eminently reasonable ground for an exemption from OA requirements, and we are heartened that it is based on the recognition of the fundamental importance of third-party material in research outputs. As with the answer to question 11, we recommend that the exception extend to third-party material that is prohibitively expensive to procure in OA. And, as in that answer, we advocate for the award of the exemption through a simple, user-friendly process which may rely on, for instance, the representations of the author.
15. Is sharing of a version of an output without third-party materials if licensing can’t be obtained, mirroring the UKRI open access policy for longform outputs, appropriate to meet the open access requirements for REF 2029 policy? Does this present issues for output submission and assessment?
No. We consider the use of third-party material to be integral and foundational to scholarship in our field. Sharing text without these images can, therefore, undermine or make incomprehensible arguments in a long-form publication.
We strongly disagree with the approach taken by UKRI to allow for sharing text without third-party material or doing so by providing a link to an online copy of the material (UKRI acknowledges that permissions may be required for such linking), or, as UKRI puts it, ‘tombstoning’ the third-party material for the open access version of the publication and providing a citation for the material.
Millions of images throughout the world have not been digitally photographed and uploaded to the web (therefore a URL doesn’t exist). Even where the full view of a work of art may be on the web, there are other views that will exist in museum collections but are not typically uploaded to their websites and/or they have not been published elsewhere where a reader can be directed; these include photographs of material or markings on the backs of works of art, technical studies (eg. x-rays), or details of works. Where images are available digitally and in OA, clicking on a link to another publication (where further searching may be necessary) or being referred to a source in print would make for a disruptive and impractical experience while trying to digest arguments in a text.
16. Do you agree with the principle of a tolerance level for non-compliant longform outputs?
Yes. We appreciate the funding bodies’ recognition that reasonable tolerance levels are needed for long-form publications which are being subjected to OA requirements for the first time.
17. Do you agree with the proposed tolerance level of 10% for longform outputs?
No. With the challenges inherent in the transition to OA long-form publications for REF credit, we think that tolerance levels should be more generous than proposed. With HEIs experiencing significant financial pressure and with research funds reduced, we expect that funds for OA publications will be more difficult to secure from HEIs, and this will lead to an increase in non-compliant publications. We therefore suggest a higher tolerance level of at least 33%, though, ideally, we would suggest aspirational, non-binding goals for REF 2029 which can inform realistic goals for the next REF.
18. Do you agree with the proposed date for implementation of an open access policy for longform outputs in REF 2029 being for all longform publications for which contracts are agreed from 1 January 2026?
No. Given the funding crisis in the UK HE sector and its impact on research funding, and with a first-time application of OA requirements for long-form publications, we suggest that the start date of 1 January 2026 should be made later, commencing with the next REF cycle on 1 January 2029. We are concerned that the application of the new policy will lead to fewer long-form publications being eligible for REF credit by the end of 2028; this could be from publishers taking more time to assess the impact and risks of the new policy, and ultimately to contract with authors and, conversely, it may encourage some publishers to rush to publish books prior to the deadline date (thereby reducing the number that could have been published in OA).
19. Do you agree with the proposed exceptions for longform publications? Are there other exceptions you think are necessary for longform outputs? Please provide evidence in support.
Yes. We welcome the exceptions proffered by the funding bodies.
Other exceptions: We recommend that the following long-form publications be considered out of scope of OA requirements: exhibitions catalogues, scholarly editions and scholarly illustrated catalogues (in art history these can take the form of catalogues raisonné, publishing a single artists’ complete output); these publications often have multiple authors and are also, by their nature, densely illustrated, making the securing of rights an obstacle for publishing in OA. Exhibition catalogues, in particular, are good examples of what some may call ‘cross-over’ books: those which rely on scholarly research and are intended for use (and are used) by researchers, curators and the public.
The types of publications noted above are considered out of scope of the UKRI OA policy, and we recommend that the two policies be made consistent in this regard.