EBLIDA, the European Bureau of Library, Information and Documentation Associations, is an independent, non-profit umbrella organisation of national library, information, documentation and archive associations in Europe. Subjects on which EBLIDA concentrates are European information society issues, including copyright & licensing, culture & education and EU enlargement. We promote access to information in the digital age and the role of archives and libraries in achieving this goal. We represent the interests of our members to the European institutions, such as the European Commission, European Parliament and the Council of Europe. 

EBLIDA welcomes the Study on the economic and technical evolution of the scientific publication markets in Europe (see also IP/06/414 of 31 March 2006).  The study deals briefly but generally thoroughly with a very complex situation, providing evidence that in many areas has hitherto been lacking.  For EBLIDA the key success of the study lies in the way in which it sets the markets firmly within the broad context of scientific information, which has immense importance to the economies of the European Union.  EBLIDA agrees with the study that ‘dissemination and access to research results is a pillar in the development of the European Research Area’.  We could go further and emphasise the benefits to society generally – in innovation, in education and in healthcare – of optimal dissemination of research results. 

We strongly support recommendation A1 (‘guarantee public access to publicly-funded research results shortly after publication’), except that we are unconvinced by the argument that immediate public access on publication [in a traditional journal] might undermine sales. Section 7.2.3 offers little support for this supposition: rather, the contrary.  Section 7.5 envisages possible undermining of the current system only ‘in the short run’.  We therefore believe that public access should be guaranteed immediately on publication – or, at worst, if a delay is to be insisted upon, it should be a short-term public policy measure for one or two years only, after which all delays and embargoes  would cease with respect to the immediate publication of publicly-funded research results.

We also strongly support recommendation A2 which recognises the responsibility of public funding authorities to facilitate experimentation in business models.  With the current barriers to entry in to the system (identified in the study), it is clear that the playing-field is far from level at present.  We are surprised, incidentally, that the study makes so little mention of the important hidden subsidy enjoyed by traditional publishers through the free delivery to them of their raw material, the research papers.  The value of this subsidy, coupled with the sub-optimal performance of the system at present, justify public policy decisions to investigate alternative methods.

However, we would recommend that more investigation is done in regard to the “author pay” business model. It is unclear whether this will, in fact, lead to improvements in the scientific publication process. The economic burden of publication may well remain within the confines of publicly funded research institutions and have neither economic or qualitative advantages for the market as a whole.

In principle we agree with recommendation A3 (extended quality rankings of scientific journals) though we recognise that work would be required to achieve appropriate measures.

We also believe that recommendation A4 is important (guarantee perennial access to scholarly journal digital archives).  As the study suggests, a variety of solutions need to be explored, but is should be underlined that publishers initiatives for making available and preserving journal articles are supplemented by provisions on legal deposit in all Member States.

We support recommendation A5 (foster interoperable tools to improve knowledge visibility, accessibility and dissemination) and the use of open standards and metadata to ensure interoperability.

We are also in favour of pro-competitive pricing strategies (recommendation B1) and we support trials of price based on usage.  Like the authors of the report we are wary of library tariffs that charge pro-rata for ever-increasing use, since it is unlikely that costs will increase pro-rata.

Recommendation B2 (scrutinise future significant merges) also meets with our approval, though it represents a traditional approach to competition policy and tends to overlook the significance of copyright material as a monopoly product in itself.

We are wholly in favour of recommendation B3 (promote the development of electronic publications).  In particular the VAT levied on electronic publications is a massive and perverse disincentive to innovate and to optimise the benefits of technology.

We support recommendation C1 (setting up an advisory committee) to foster and support cooperation and dialogue between stakeholders.

We support the remaining recommendations.  We hope very much that where the desirability of further study has been identified, it will not be regarded as a reason to delay implementing the main recommendations.

The Hague, May 2006