Recommendations of the European Commission
on Open Access : GFII’s first comments
11 January 2013

On  July 17, 2012,  the European Commission issued a recommendation encouraging 
the Member States to make necessary arrangements to disseminate publicly funded 
research through open access publication, as soon as possible, preferably 
immediately and in any case within  6 or 12 months after the date of 
publication, depending on the discipline.
The French government should soon take a stand on this issue. In this context, 
the professional Group GFII, bringing together public and private stakeholders 
involved in the information and knowledge industry, would like to inform the 
government on the preliminary findings of its Working Group on Open Access. The 
text below has been discussed by the GFII Board of Directors and was approved 
with just one vote against (CNRS).
The GFII shares the conviction that publications, which are researchers output, 
must be disseminated as open as possible and as soon as possible to the benefit 
of their authors, their institutions, readers and the whole of society. But the 
Group recalls that editing scientific texts, either in the Humanities and 
Social Sciences (HSS) or in the Scientific, Technical and Medical (STM) 
publishing, is not only publishing it, particularly in the digital environment. 
Indeed, editing scientific texts involves different stages including selecting, 
enhancing and validating information through exchanges with authors on a 
regular basis, correcting proofs, formatting it, printing these manuscripts or 
posting it online and ensuring sustainable indexing on valuable platforms, 
enhancing it by adding metadata, developing tools to facilitate information 
retrieval through databases, communicating/promoting authors and their 
research, etc. So many activities and services are needed to the scientific 
community and they have a cost that requires to be paid. Open Access needs 
therefore to find a balance between ensuring the widest dissemination of 
research publications and business models allowing a real editorial and 
promotional work of scientific texts for their potential readers. In absence of 
balance between these different objectives, the scientific information sector 
will be deeply destabilized.

The balance is even more difficult to find since the situation is actually 
different depending on the discipline, the linguistic area or the type of works 
published. There are differences, for example, in scholarly publishing in the 
STM compared with the HSS, as the former is largely globalized whereas the 
latter is highly dependent on specificities of each linguistic area. And within 
these fields of disciplines, there are major differences of communication 
practices between each discipline. For the GFII, it is only through 
consultation between the scientific communities, publishers and distributors of 
scientific publications that such complex issues can be really addressed and 
that a balanced outcome can be achieved. It is convinced that this consultation 
is an essential step before any decision is made on the subject.

To avoid counterproductive effects, particularly in areas where public and 
private national publishing houses or publishing structures are involved, the 
GFII strongly recommends an independent impact study seeking to address the 
following questions :

-        What is, for each discipline, the adequate embargo period needed for 
rewarding fairly scholarly publishing actors ?

-        If adequate embargo periods for each discipline were not obtained, 
which other business models could be implemented to ensure quality, diversity, 
sustainability and independence of scientific publications (“Author pays” 
model, freemium model, etc.) ? What would be the cost of it ? How to bear this 
cost ?

-        In accordance to the measures currently specified by the European 
Commission for the Horizon 2020 program, what should the French government do 
to provide a mechanism for an immediate posting of scholarly articles through 
pre-financing of publication costs ? What would be the case for the Humanities 
and Social Sciences in particular ?

-        What would be the impact of science dissemination using open access on 
other publishing sectors such as the professional publishing and/or other 
knowledge publishing sectors ?

We believe also that the Government should take account of the following points 
:

-        Which type of publications should not be subject to the regulatory 
measures being considered ? Regarding self-archiving, should recommendations 
only be applied on journal articles or also on collective books and even 
research monographs ?

-        How should a “publicly funded” research be clearly defined ? For 
example, should we consider that all the writings of an author that has been 
paid from public funds, in some way, must be made freely available (after the 
embargo period) ? Should knowledge transfer publications and scientific 
publications be concerned by the proposed measures once their authors are “paid 
from public funds” through their salaries for example ?

The Commission Communication was also on other subjects which are the main 
focus of GFII’s work, including Open research data. The Working group on Open 
Access will shortly prepare an analytical and conceptual paper and what 
appeared to constitute the strengths and weaknesses of the scientific and 
technical information ecosystem in France will be discussed.
GFII stands ready to provide any clarification or assistance on these issues to 
the French government and in case it would consider that such a study is 
required before making any decisions on the transposition of the European 
Recommendation.

About the GFII
The GFII (Groupement Français de l’Industrie de l’Information) includes 
representatives from the information and knowledge market : information 
producers, publishers, servers, intermediaries, information providers, service 
providers, software developers, libraries and subscription agencies.
The GFII hosts working groups allowing members of the information industry to 
meet, discuss and exchange points of view on the legal, technical and economic 
aspects of the sector. With a membership from the private and public sectors, 
the GFII is a valuable forum for helping stakeholders to get to know one 
another and to exchange about their jobs, their goals and their constraints. 
The GFII has been assisting all the stakeholders in the development of the 
digital information market and is running an  e-books working group.
About GFII’s Working Group on Open Access
Created in September 2007 and including representatives from the main economic 
stakeholders involved in Open Access: research institutes, publishers, 
aggregators, internet services, subscription agents, academic libraries, the 
GFII’s Working Group on Open Access aims to analyze this movement and its 
demands and also to advance it at the national level through a constructive and 
reasonable approach. As a result of the Group’s work, a series of 
recommendations has been published in June 2010 and is available online at  
http://www.gfii.fr/fr/groupe/open-access. One of these recommendations was on 
setting up and operating “a shared, standardized and transparent information 
site to display each publisher’s policy with regard to Open Access 
repositories”. To this end, publishers within the SNE (Syndicat National de 
l’Edition) and the SPCS (Syndicat de la Presse Culturelle et Scientifique) have 
been meeting the CNRS in order to collaborate in the creation of the Héloise 
platform developed by the CCSD-CNRS. The platform is today online and hosted by 
the publishers (http://heloise.ccsd.cnrs.fr/).
The working group which has been relaunched in early 2012 is chaired by 
Ghislaine Chartron who is professor of Information and Communication Sciences 
and Chair of Document Engineering in the CNAM (Conservatoire National des Arts 
et Métiers).

Contact :
Ruth Martinez, General Delegate, GFII
ruth.marti...@gfii.fr<mailto:ruth.marti...@gfii.fr>
tel 00 33 1 43 72 96 52


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