Feedback from Karolinska Institutet on the implementation guide for Plan S

Plan S is a European initiative to further increase open access to research results. The purpose of the plan is that all research funded by the participating funders will be published open access immediately, as of 1 January 2020.

When the opportunity arose to give feedback on the implementation guide for Plan S, the following points were conveyed to the Swedish research funders FORTE and Formas (signatories of Plan S that have asked for feedback). The feedback has been collected through a consultation process at KI, including the opportunity for KI researchers to answer a survey, and through discussion with the university management and the university library. KI provides the following feedback:

Uncertainties in the implementation guide need clarification

  • The economic consequences of Plan S are not described clearly enough, for us to be able to arrive at a considered opinion on the plan as a whole. Considering that the main routes to ‘compliant’ open access suggested in Plan S involve article processing charges, a more clear description of how funding will work is needed. Without more detail on, for example, the suggested cap on article processing charges covered by funders, it is difficult to take a stand on Plan S as a whole.    
  • We deem the suggested timeframe to be too tight, given the many uncertain factors that need to be resolved, for the goal of immediate open access to be achieved under sustainable conditions.

Further questions or problems that need to be addressed

  • It is of great importance that the academic freedom—that researchers can choose where and how research is published—is maintained. As Plan S is now formulated, we can see a hollowing out of that freedom. 
  • We see a risk that Plan S inhibits the possibility for Swedish researchers to initiate collaborations in a global context given the differences in how research is financed, published and assessed. The same risk exists regarding the possibility for researchers to merit themselves and compete in a global context. Either a broader global support for Plan S is needed, or a harmonization with policy with the rest of the world.
  • It would be unfortunate if researchers cannot publish their results in internationally recognized quality journals that do not meet the specific demands from cOAlition S funders.
  • We are hesitant to why article processing charges have such a prominent place in Plan S, rather than ‘green’ open access through self-archiving, or ‘diamond’ open access. We see a risk in that shifting the costs from subscriptions to an exaggerated focus on publication charges will bring about new barriers for resource weak countries, institutions and researchers. It also risks introducing incentives that do not benefit the quality of research.

Other comments

  • Open access to research results are unambiguously of gain for both the global research community and for society at large. Access to information globally is to a large extent a question of empowerment. However, we see that an unreflective and uncritical implementation of Plan S may undermine the support of the research community for open access, and paradoxically inhibit the development towards open access.  
  • It is of utmost importance that researchers and research organizations all over the world will be part of the continued process to design policies and guidelines that affects their possibilities to publish their results and how these will be assessed. If free research is not to be overly compromised, funders and policy makers must realize that their potential for affecting peer review is limited. We consider the representation of the research community has been too weak in the work leading up to Plan S and its implementation guide.  
  • The widened opportunities for green open access, and the usage of the infrastructure for self-archiving in repositories, for example presented by the libraries at Harvard University and MIT, is something that needs to be explored in a greater extent.
  • KI supports the statements made by the Swedish Research Council to not formally join cOAlition S with regard to the tight schedule suggested by Plan S.

For more information on the KI view on Plan S, please read the blog post (in Swedish) by KI President Ole Petter Ottersen.

If you have any questions, please contact the University Library.