Open response of publishers on the proposed mandatory criteria for transformative journals

In addition to concerns expressed in the HSS open letter, we believe the proposed framework would remove the ability of most HSS publishers to facilitate Plan S funded authors potentially creating research silos, with unfunded and funded research operating in a two-tiered closed versus OA system. This hampers interdisciplinarity and potential for global collaboration which should be amongst the key objectives for OA and open science. The proposed framework may have the unintended consequence of further consolidating the publishing landscape around the largest global publishers, instead of facilitating a wider diversity of outlets, formats and discussions to the benefit of open science and society. Whilst we support the objective to accelerate OA, the proposed framework would create a barrier to publishing for our communities at the same time as expanding access. We suggest the proposed framework could be adapted for the benefit of HSS communities, as follows:

• A transformative journal is transparent in the transition from subscription based to OA, in line with support from relevant subject communities, noting ability to pay APCs and prevailing research culture.
• A transformative journal contributes to changing research culture towards transparency and openness in research, which would do more to improve societal outcomes from research. We also propose a transformative journal would mandate a data availability statement for all research articles.
• A transformative journal has signed DORA, to support research culture change away from legacy metrics (high impact journals) towards a more balanced approach to research evaluation. 
• We note the framework does not explicitly allow for journals with zero embargo green routes to be publicly acknowledged as Plan S-compliant. The models currently considered Plan S compliant are not suitable for HSS fields, however this change would allow our author communities to publish both sustainably and compliant to Plan S.

At present, 0.75% of the subscription journal content we publish has been funded by Plan S signatories. Whilst we are in a privileged position to be able to negotiate transformative agreements with some library consortia, there is no global consensus on a sustainable route to OA and its growth rate remains difficult to predict. In the meantime, global research output continues to grow, including in subscription journals. We are committed to transition our journals towards being fully OA at the rate our communities are supported to do so. We have plans to pilot mechanisms to make this transition more transparent. However, we see mixed support for APCs among our library customers, including within Europe, with many preferring our zero embargo Green OA route alongside subscription access, or to channel their APC funding towards STEM subjects rather than the largely HSS programme published by Emerald. We therefore cannot commit to a specific OA % growth within individual journals, when we haven’t previously seen this percentage growth across our whole programme to date.

We are not able to commit to flipping our subscription journals to be fully OA once they reach 50% and do not agree that there is a need to have an arbitrary threshold when it is possible that important research and formats may never have APC funding. In humanities and social sciences (HSS), so little research is in receipt of funding that waivers and discounts for unfunded authors would not be sustainable. In addition, research outputs in SSH are varied and not always in the form of a journal article. Emerald currently publishes 38 different content types, many of which would not be supported by journal transformative arrangements proposed by Plan S. We are concerned that the current criteria for a transformative journal strongly favours STEM publication in the journals of a small number of global publishers who already have the existing infrastructure to support OA workflows. The framework lacks any mandate concerning open data practices, and does not address the need to move research culture away from practices which contribute to the current citation-focused models.