Dear cOAlition S,

This is an open letter to the funders, government bodies and institutions that support Plan S and will be submitted to the open consultation of cOAlition S draft framework for transformative journals.

We thank you for the provision of a draft framework for transformative journals and appreciate the opportunity to consult on the guidance. We are responding from the perspective of publishers working across the humanities and social sciences (HSS) who typically publish a large proportion of unfunded authors, be that by region, discipline or organisational setting.

We remain committed to realising the benefits of full and immediate open access for our authors and their stakeholders and we appreciate the efforts of cOAlition S to date to engage with the wider discussion and assist smaller publishers to transition to open publishing models. Given that scholarship remains a global and collaborative endeavour, we urge cOAlition S to continue to be mindful of the unintended consequences for academic colleagues and disciplines that do not have the luxury of direct funding, or access to money for APCs from their organisation or institution.

The issues as previously stated in our open letter of 8^th February 2019 remain a reality. Transformative agreements – and thus funding for APCs – are not available to all of the many varied publishers within the ecosystem. Globally there remain mixed approaches to achieving open access with many customers, including within Europe, preferring non-APC routes to open publishing. This includes green open access. Other models, such as subscribe-to-open, remain interesting but un-tested with respect to long-term sustainability.

For those publishers that are in position to even contemplate transformative agreements these new mandated criteria are far too prescriptive, and do not allow for experimentation of models that may be more appropriate for unfunded disciplines.

We welcome the criteria for journal owners to be more transparent about their transition to open and think this is an important step towards fully realising open for our communities. The reality remains that for small and medium sized HSS publishers:

• Cost neutrality effectively asks smaller publishers who have traditionally been relatively low cost with high outputs to subsidise the deals of larger publishers who are able to lock in revenues for historical read-and-publish deals.
• Mandating specific growth targets does not allow for the fact that within HSS, growth rates of 8% per annum are impossible to achieve across entire portfolios, let alone within given journals. In addition, many journals remain financially unsustainable under an APC model, given their relative small size and without the economies of scale enjoyed by larger publishers.
• As we publish research in a variety of formats and from a variety of researchers including those not based at higher education institutions, a commitment to flip journals that reach 50% open is a threshold that is not financially sustainable and would see important and varied voices excluded from academic discourse. There are simply too many unfunded authors in HSS for all of them to publish openly via waivers or discounts.
• Although we understand the positive drivers for a number of the mandated criteria, many of them require investments in systems, reporting and processes without acknowledging the varied resources in both revenue and staff that exist outside of the largest publishers. Mandating these requirements means that smaller publishers would need to divert scarce resources to enable the tiny proportion of funded authors in HSS to continue to publish in their preferred outlets to meet requirements that the majority of our authors are not asking for nor bound by.

We conclude by reiterating our previous assertion that the transition away from the current model must be based on fairness, broad equality of outcome, and – of course – openness. We ask that cOAlition S continues to seek transparent dialogue between all parties – funders, associations, libraries, journal editors, individual researchers, publishers – and for a firm commitment by all, including those now forcing the pace of change, to develop community-appropriate solutions that deliver sustainable, open outcomes for all researchers, whatever their chosen field of enquiry.

We remain ready to support the process, in collaboration with the communities we serve.

1. Amsterdam University Press, The Netherlands
   2. Berghahn Books, USA
   3. Boom Uitgevers, The Netherlands
   4. Böhlau Verlag, Germany
   5. Brepols, Belgium
   6. Brill, The Netherlands
   7. Bristol University Press, UK
   8. Budrich Unipress, Germany
   9. Campus, Germany
   10. De Gruyter, Germany
   11. Edinburgh University Press, UK
   12. Éditions La Découverte, France
   13. Edward Elgar, UK
   14. Eleven International Publishing, The Netherlands
   15. Emerald Publishing, UK
   16. Equinox Publishing, UK
   17. Facultas, Austria
   18. Ferdinand Schöningh / Wihelm Fink / mentis, Germany
   19. Georg Olms Verlag, Germany
   20. Hogrefe, Germany
   21. Intellect, UK
   22. Intersentia, Belgium
   23. John Benjamins, The Netherlands
   24. Juventa, Germany
   25. Klostermann, Germany
   26. Liverpool University Press, UK
   27. Manchester University Press, UK
   28. Mohr Siebeck, Germany
   29. Multilingual Matters, UK
   30. Nomos, Germany
   31. Pluto Journals, UK
   32. SAGE Publishing, USA
   33. Transcript, Germany
   34. University of Toronto Press, Canada
   35. University of Wales Press, UK
   36. UTB, Germany
   37. Vandenhoeck & Ruprecht, Germany
   38. Verlag Barbara Budrich, Germany
   39. Verlag Julius Kinkhardt, Germany
   40. Verlagsgruppe Beltz, Germany
   41. V&R Unipress, Germany
   42. Waxmann Verlag, Germany
   43. wbv Media, Germany
   44. Cairn.info, France
   45. Knowledge Unlatched, Germany