To the SSHRC Consultation committee,
I am writing on behalf of the Research Development Committee of the Faculty of Arts and Social Sciences at Dalhousie University to express our concerns about the proposed open-access policy or, perhaps more accurately, the digital-access policy on SSHRC-funded research.  SSH research has been “open access” for a century through public libraries, a group that includes most university libraries (very few, like the Robarts in Toronto, require library cards to access the stacks).

We of course admire the aim of making SSH research even more easy to access. But we have a number of concerns about the impacts of this policy. Many of these concerns arise from a simple problem:  free digital access to peer-reviewed journals is, as the open-access consultation document and proposed policy indicate, growing, but it is still very far from universal and it is not evenly growing across fields. Arguably, SSH fields are further behind on this than NSERC and CIHR fields:  lots of new, open-access journals are springing up, but relatively few established journals are making the transition because of the economics of SSH publishing (see below).  Requiring open-access publication (or open-access through a repository) will be, in fact, a closing of access—an imposition of a glass ceiling on SSHRC-funded research that will prevent much of it from appearing in the top peer-reviewed journals.  We are especially concerned about the impact of that glass ceiling on junior researchers.

This policy as a whole will impact the Canadian academy and research on a number of fronts:

Tenure and Promotion.  At least two of the four jurisdictions noted in the consultation document for their advances in open access do not have academic systems that use tenure (Australia and the UK). Tenure is, however, a key aspect of university culture in Canada, as a protection of academic freedom, as a means of ensuring high-quality faculty, and as a term of employment defined through collective agreements and similar documents.

It is a normal part of tenure and promotion processes for candidates and referees to address the quality of publication venues: acceptance rates, reputation in the field, and so on.  SSHRC researchers in fields where the top journals are not yet open access will be required, under the proposed policy, to publish in a less-prominent forum (say, a collection of essays, or a new online journal that does not yet have a strong reputation for quality). Their reasons for doing so will not be transparent to international referees, and will create, internally, conflict with established tenure-and-promotion standards.

For instance, if a SSHRC-funded candidate publishes in a journal with a 50% acceptance rate because it is the best available open-access option, and not a first-tier journal with a 15% acceptance rate that retains copyright, referees and tenure-and-promotion committees will have this question left unanswered: is the work significant enough to have been published in the first-tier journal, or does the candidate not produce work of that quality?  How can committees and referees fairly compare—for tenure and/or promotion, for a tenure-track hiring, for an award—two candidates, one of whom is in a field where the top journals are open access and one of whom is in a field where the top journals are not yet open access?

This will be a particularly difficult problem at research universities such as ours with PhD programs, where first-tier publications are expected, and we should all expect to see grievances and/or a relaxing of standards if the open-access policy is approved without, for instance, exemptions for untenured scholars.

Academic Freedom.  Choices about publication are not just made on the basis of a general desire to communicate research results.  Such decisions also involve, for instance, consideration of which audience a researcher wishes to engage and to which debate or line of discussion an article is meant to contribute.  SSH journals often publish articles that are a “Reply to” a previous article in the same publication; a researcher might decide that British scholars are well aware of the research s/he is doing, and so should publish the next article in a US journal; and so on.  These choices, and hence academic freedom as the informed exercise of academic judgment, would be arbitrarily curtailed by an open-access requirement that is significantly ahead of the current state of SSH journal publishing.

Copyright.  We appreciate the recognition of the issue of copyright over articles by SSHRC-holders (esp. in the FAQ), but consideration also needs to be given to the SSH-specific requirement of getting copyright permissions for material included in those articles. Many SSH researchers require copyright permissions for images and quotations over a certain length from recent authors, for instance.  This is relatively straightforward for an academic journal with limited access—through either print or a pay-wall—because that limited access assures the copyright owners of limited distribution and so the protection of their copyright. But full open access will compromise their copyright and so may make copyright permissions prohibitively expensive and even unattainable for SSHRC researchers.

Economics of SSH journals. In many NSERC and CIHR fields, it is not unusual to charge fees to submit and/or publish articles; in open-access cases, this has now been extended to fees (typically about $3,000) to publish an article in an open-access journal.  SSH journals almost never do this. The disreputable character of “vanity publishing” and the low-cost economics of most SSH research forbids it. Our journals therefore require subscription fees and pay-walls to finance quality control (refereeing, copyediting, and so on), especially in the US and UK where most of our top-tier journals are located:  in the US, journals are often in private or university hands (and are excluded from federal funding); in the UK, a number are with private corporations (e.g., Taylor and Francis) or, like many Canadian journals, with struggling university presses.  Again, open access may become standard in the future, but we are not there yet and these economic pressures will keep many top journals from switching to open-access protocols—and so prolong the impact of that glass ceiling.

SSHRC’s reputation.  SSHRC researchers for decades have contributed to SSHRC’s international reputation as a rigorous granting body by including “I would like to thank the Social Sciences and Humanities Research Council…” in top-tier publications.  In fields where top-tier journals are not open access, SSHRC will drop off the map.  Senior researchers who only need small grants may also elect not to apply to SSHRC rather than sacrifice their academic freedom on publishing choices, and junior scholars may not apply because it compromises their ability to put forward the best possible application for promotion and tenure.  All of this will lessen SSHRC’s impact and international visibility, as well as those of Canadian research in SSH areas.

We would also appreciate some clarifications on key aspects of this policy:

Students.  There’s a general slippage in the language of the proposed policy between “Agency-funded” (#5, also #2; and “Agency-supported research” in #3) and “Grant recipients” (#3 and #6).  MA, doctoral, and postdoctoral SSHRC-holders are agency-funded but are not typically characterized as grant recipients.  Will they be bound by this policy?  The FAQ suggests not (#6), at least for now, but the policy itself is ambiguous at best. Moreover, what about graduate students who build on their work as research assistants for “Agency-supported research” in producing their own research? We would appreciate it if the final draft of the policy, if this does proceed to approval, made it explicit that graduate and postdoctoral research is fully exempt from the requirements of this policy to ensure that our students remain viable candidates in a highly competitive North American academic job market.

Multiple-grant research.  Research often benefits from support from various sources:  e.g., a collaborative project with a US scholar might have support from both the American NEH as well as SSHRC, and perhaps some university funding as well.  If 30% of the funding comes from SSHRC, do 100% of the peer-reviewed journal articles have to comply with these open-access requirements? Or just 30%?

Multiple-author research.  If a faculty member with SSHRC support co-writes an article with someone who does not have SSHRC support (say, a former PhD student), does the open-access policy apply? If the collaborator without SSHRC funding is applying for jobs or tenure and/or promotion in a field where top-tier journals are not open access, SSHRC’s policy could threaten a non-SSHRC-holder’s career.

We of course recognize the importance of public accountability for the use of public funds and do laud efforts to make Canadian SSH research easier to access online. But we would respectfully suggest that a key part of the value of SSHRC funding is its contribution to Canada’s international reputation in SSH research, to high-quality research from the graduate levels up, and to research dissemination in the most impactful and well-regarded research forums.  This contribution has various indirect benefits, including furthering international recruitment (from graduate programs to new faculty), and it advances Canada’s credibility in the knowledge economy.  We are deeply concerned that this policy, for the reasons noted above, will significantly undermine this contribution as well as compromise academic freedom and tenure-and-promotion processes at Canadian institutions.

Sincerely,

Julia M. Wright

Professor of English and Associate Dean Research (FASS)
Dalhousie University