Academic Publishing

Updated: Frontiers helped Robert-Jan Smits design Plan S

I obtained from the EU commission evidence that Smits was at least strongly influenced by Frontiers while designing Plan S. There were meetings with Kamila Markram and other Frontiers representatives, most notably on 25 April 2018, and a string of emails, where Smits requested and received "Frontiers feedback on the transition to OA and APCs". Updates at the end of this article supply evidence that not only Frontiers did advise Smits on Plan S from spring 2018 on, they were the only stakeholder to do so.

Robert-Jan Smits, EU Commission’s special envoy for Open Access (OA), is the mastermind behind Plan S. A bold plan to transform scholarly publishing to OA, which impending arrival Smits announced on 11 July 2018 during a panel discussion where also Kamila Markram, CEO of the for-profit OA publisher Frontiers was present, advertising for her business. On 4 September 2018, Plan S was revealed to the masses in Frontiers (but also in PLOS). Scientists were to be virtually banned (and punished for even trying) from publishing in subscription journals, due to restrictive licensing and archiving mandate which forbids any embargoes. It was rather obvious who would profit most financially from Plan S: vast commercial megajournal publishers like Frontiers. Scholarly societies whose academic activities depend on the income from their subscription journals were told by Smits “to bite the bullet”, face the OA competition and try to survive in the free market.

I obtained from the EU commission documents which suggest that Smits was at least strongly influenced by Frontiers while designing Plan S. There were other meetings with Kamila Markram aside of that panel session at ESOF 2018 in July, most notably one on 25 April 2018, and a string of emails, where Smits requested and received “Frontiers feedback on the transition to OA and APCs“. Smits attested Frontiers an “Impressive OA publishing model” and recently accepted the invitation as speaker next to Kamila, at the upcoming Open Science Policy Symposium in Brussels on 29 November 2018. The event is organised by Frontiers.

Updates at the end of this article supply evidence (provided by EU Commission) that not only Frontiers did advise Smits on Plan S from spring 2018 on, they were the only stakeholder to do so.

All this confirms the suspicion that Plan S was designed with Frontiers in mind. How much actual active input Markram had, except of providing Smits with pitches and brochures, we don’t know. But it looks like it was more than enough.

(For background on Plan S, read here, here and here)

Screenshot_2018-11-12 ESOF 2018 - Opening Up Open Science Innovations, Ideas and Possibilities - YouTube
Kamila Markram, speaking at ESOF 2018. Smits spoke next, here sitting, second from right.

It is not normal that Smits, an EU Commission official decides the future of all European scientists based on advice from the main commerical profiteer of Plan S, Frontiers, while basically declaring a war on scholarly societies. This man who was recorded as impressed by “the success of Frontiers’ journals – citations / impact factor” has now the gall to constantly accuse critics of his Plan S of obsession with the journal impact factor:

“One thing I was quite disappointed by – although these scientists are extending the frontiers of knowledge, when it comes to publishing, they still embrace the traditional subscription based model and, with this, the journal impact factor instead of going for full open access and developing new metrics. […] It’s not just what Plan-S can do for you, but what you can do for Plan-S.”

Ironically, right when Smits was preparing his Plan S while exchanging emails with Kamila Markram for feedback, her DORA signatory Frontiers were celebrating new impact factor.

Finally, elsewhere Smits was heard saying recently that he only ever met Kamila Markram once, at the ESOF panel on 11 July 2018 in Toulouse. That statement of his is now proven as a false.

The documents provided by the EU Commission are now publicly available here. I did not receive the contents of the emails, but the subject lines are already quite revealing.

In 2017, there were two conferences in Brussels where both Smits and Kamila Markram were speakers, on 27 June 2017  and 3 July 2017. The latter was an EU Commission organised event. If you are so inclined you can believe that the EU Special Envoy for OA and the CEO of Frontiers never spoke to each other at those conferences. Maybe at those two conferences Smits was hiding from Markram in the gents’, while she was pushing Frontiers brochures under the door. This was the statement from the EU Commission to me:

“We have been informed that no exchanges (emails or meetings) took place between Mr 
Smits and representatives of Frontiers Media S.A. during 2017. 
Mr Smits met three times with Frontiers representatives during 2018: 
On 25 April with Dr Kamila Markram and two other representatives and during a follow-
up meeting on 11 June with one Frontiers representative; 
Mr Smits and Dr Markram were speakers on the same panel (Opening Up Open Science:
Innovations, Ideas and Possibilities) at ESO
F 2018 on 11 July. “

The emails with the subject line “Quick catch-up discussion in Vienna on Tuesday?” however indicate there was yet another, unofficial meeting between the two, after Plan S was announced. It seems to have taken place on Tuesday, 18 September 2018, at the COASP 2018 OA publisher conference in Vienna. Smits was speaker there, but neither Markram nor any other Frontiers execs are listed in the programme. They apparently stayed in the shadows.

On 26 March 2018, Frontiers EU Office (yes, they do have a secret unlisted one) sent an email to Smits and other EU officials titled “Request for a meeting with Dr. Kamila Markram, Frontiers CEO and co-founder (April 25th, Brussels)“. The email likely was sent by Laure Sonnier of Interel, which apparently serves as a covert Frontiers Brussels lobbyist (here, Sonnier was attributed in June 2018 as member of “The Frontiers Team” to “EU Liaison Office” of Frontiers). Sonnier now organises the 29 November 2018 Symposium in Brussels on behalf of Frontiers, where Smits and Markram will speak. And now another unexpected connection: Sonnier previously worked as Senior Scientific Officer for Science Europe, the funder lobby organisation which co-authored Plan S together with Smits and which represents the cOAlition S of Plan S-willing European funders. Stephan Kuster, secretary general of Research Europe, is apparently a regular face at Frontiers events, while as reminder, Plan S was announced on 4 September 2018 in Frontiers, by Science Europe president Marc Schiltz.

Screenshot_2018-11-13 (8) Laure Sonnier LinkedIn
From Laure Sonnier’s LinkedIn profile. Note that her actual association with Frontiers is nowhere mentioned. It was however evidenced here.

But back to the Frontiers meeting with Smits. Incidentally, April 2018 was exactly the time when Smits said to Plan S critics in a video conference to have begun working on Plan S. He said he was working on it alone, assisted only by Anne Mallaband. Pity that the EU envoy forgot to mention that on April 25th he met Kamila Markram and other Frontiers execs to help him design that Plan S.

These are the records provided by EU Commission, for some reason they chose to hide the identities of other Frontiers execs except of Kamila Markram.

“Report of meeting with Frontiers on Open Access to scientific publications 
EC offices, 25 April 2018 

Participants:  Dr.  Kamila  Markram,  CEO  and  co-founder  of  Frontiers,  Dr. XXXX
at Frontiers; Dr. XXXX  and XXXX, EPSC, EC.

XXXX gave a short introduction to the assignment.

K. Markram gave a short presentation on Frontiers’ innovative business model, including the current state of play regarding services offered and ways that Frontiers can contribute to realising the transition to immediate open access in Europe – see slides and brochure 1 .

The following issues were raised:
– the Frontiers’ publishing process (submission, peer review, editorial boards etc.);
– the range of APCs charged – depending on different status, discipline, maturity of journals and waivers;
– transparency of costs;
– the success of Frontiers’ journals – citations / impact factor;
– building the brand;
– reinvestment in the company;
– AI and technology key elements as well as personnel;

Conclusion
Impressive OA publishing model;
Frontiers agreed to prepare a paper with more detail on the OA business model and pricing policies.”

Slides and brochure were provided also, but I didn’t get those.

Right after the meeting more emails were exchanged between Frontiers Brussels mole Sonnier, Kamila Markram and Smits with the subject line “Meeting Frontiers and Mr. R-J Smits – Thank you note and next steps“. Meanwhile, Plan S was being prepared by Smits, who soon received help from Science Europe, where Sonnier used to work before she switched to Frontiers.

In early May 2018, Smits was organising his participation at the ESOF 2018 panel event in Toulouse, as his emails to Kamila Markram and other undisclosed recipients indicate. In late May, Smits apparently wrote to his Frontiers muse asking for “Frontiers feedback on the transition to OA and APCs”. That email EU Commission omitted, but there is a reply from Kamila Markram on May 31, and Smits’s follow up on June 1st, and Markram’s next email, and Smits’ reply, with same subject chain on June 8th and 18th, respectively. As EU Commission revealed, on June 11th, an unnamed Frontiers representative came to Brussels to provide more feedback to Smits, that agenda of that meeting was not recorded.

Basically, from April 2018 on when Smits started working on his Plan S up until at least June 2018 Kamila Markram was advising him on OA transition and appropriate article processing charges to be paid by public funders.

Smit’s brainchild Plan S was taking it baby steps, led on the hand by auntie Kamila.

Then the ESOF 2018 panel arrived on 11 July 2018, here is the video if you interested.

On 31 August 2018 Smits proudly informed Markram in an email addressed just to her about “Plan S – Release on 4 September 2018“. Some more emails were exchanged. On September 14th, Smits replied to Markram’s invitation of a  “Quick catch-up discussion in Vienna on Tuesday?” at the COASP 2018. That meeting was unofficial, hence unrecorded by EU Commission, one wonders if there were more.

And on 19 October 2018, immediately right after he finished his videoconference with Plan S critics, Smits wrote to Kamila Markram to organise the “Invitation to participate as speaker – Open Science Policy Symposium – 29 November 2018, Brussels“, where he will speak at a Frontiers-organised conference. Other notable participants there will be Stephan Kuster of Science Europe, Gareth O’Neill, Plan S-disciple and President of Eurodoc whose somewhat obscure EU-funded organisation has actually only 36 natural person members but insists on speaking for every single one of the tens of  thousands of early career researchers in Europe, and Jean-Claude Burgelman, Head of Open Science policies at EU Commission. Burgelman recently spoke at a private Frontiers event celebrating this publisher’s 10 years of commercial success on 21 June 2018.

The Open Letter against Plan S drew now over 1000 signatories, of real people in academia. There is a lot of backlash of course, much of it goes against its main author, the Swedish chemistry professor Lynn Kamerin (she also coauthored the original Appeal on my site and was one of the Plan S critics at the videoconference with Smits). On of such ad hominem attacks is this protest letter against the protest letter, written by the Dutch chemist Gerard Meijer (now Max Planck Institute director in Berlin) and published on Science Guide website, in Dutch. Meijer accuses the Open Letter authors of lies, calls upon the signatories to retract their support, all because Plan S is good, and everyone paying more than €2000 for publishing a paper is enriching greedy publisher CEOs. Thing is, just in 2018 Meijer published 5 papers, of which one appeared in the for-profit OA journal Nature Communications where Meijer and his coauthors paid $5200 APC. His other remaining 4 papers from this year were all published in subscription journals of ACS (American Chemical Society) and are all paywalled. Yes, you read it right, paywalled.

Plan S is becoming more and more of a crooked farce. And Smits’ continuous close involvement with Frontiers while designing and implementing that Plan S, from the very beginning to right now, makes it all problematic on wholly new level.


Update 29.11.2018. Some Twitter impressions from the above mentioned Frontiers conference in Brussels, as tweeted by Daniel Spichinger, former “senior policy officer for open access and open data in the European Commission”.

It started with Kamila Markram giving instruction on publisher-funder deals:

She then demanded total financial transparency of every single Platinum OA publisher. Meanwhile, her own Frontiers refuses to reveal where their start-up funding in 2007 came from and who exactly owns how much of Frontiers now. Never mind the money flows at Frontiers.

Falk Reckling, head of strategy of the Austrian national funder ORF was worried (at a Frontiers invitation-only conference!) that the friendship between funders like his own and publishers like Frontiers is not friendly enough. In December 2017, FWF signed an OA publishing agreement with Frontiers.

I challenged Spichinger and FWF on Twitter, asking how public servants can so openly display their loyalty to Frontiers. This was his reply, to my criticism of Reckling’s attitude and Smits’ Frontiers proximity (the latter Spichinger previously insinuated was a Trumpian-style propaganda):

The EU Commission official Jean Burgelman called to design punishments for Plan S-noncompliant researchers and apparently explained that regardless of what DORA Assessment means, there will be “next generation metrics”.


Update 18.02.2019

My request for full uncensored emails was rejected today by EU Commission on the grounds that… Kamila Markram is against it. Seriously, read the decision letter here. The EU Commission now openly admits that Smits was indeed advised by Frontiers on OA transformation, but says it was “part of a broad engagement with key stakeholders over the spring 2018”.

The history of this request goes like this. On 13. November 2018 I updated my earlier request and requested access to full and uncensored emails. The request was rejected one month later, on the grounds that I did not ask for full access before. On 11 December 2018 I placed a new FOIA inquiry, requesting “Full and uncensored access to emails between Robert-Jan Smits and Frontiers“. On 9. January 2019, instead of a reply, I was asked to provide once again my postal address, otherwise the application will be rejected. I immediately provided my postal address (delivery was confirmed), again, only to be told on 14 January 2019 that neither my request nor my complaints about its rejection will be processed because I failed to provide my postal address.

I complained to the European Ombudsman, who on 28.01.2019 returned the matter back to EU Commission. On 1 February 2019, European Political Strategy Centre wrote to me, promising a reply no later than 18. February 2019. Just when the workday ended in Brussels today, after more than 3 months, I finally received this letter. The kicker quote is this, highlight mine:

“The authors of the documents have objected to disclosure of the documents that they sent to the Commission. The exceptions laid down in Article 4(2) of Regulation 1049/2001 apply unless there is an overriding public interest in disclosure of the documents. We consider it is not the case: the email exchange was part of a broad engagement with key stakeholders over the spring 2018.”

Because Kamila Markram was against it, all her communications with Robert-Jan Smits about OA transformation policies are secret. But who were those key stakeholders, aside of Frontiers?

On 17 January 2019, Smits publicly accused me of harassment and lies, and said I would spread “below the belt accusations” about him and Kamila Markram.

Update 13.03.2019.

The EU commission admitted that there never was any “broad engagement with key stakeholders over the spring 2018“. On 18.20.2019, I requested the list of these stakeholders, and EU Commission today declared that they basically made that up. I n fact, they claim I made it up:

“We regret to inform you that the Commission does not hold any documents that would correspond to the description given in your application.”

There were no stakeholder consultations. Just Frontiers advising Smits on Plan S, unofficially.


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22 comments on “Updated: Frontiers helped Robert-Jan Smits design Plan S

  1. Rix Rictor

    Its unclear why the content of the mails should not be disclosed. What do they have to hide. Frontiers should themselves put these mails forward as they could otherwise be accused of potential illegal lobbying.

    Like

  2. Interesting article. There is a typo in “This are the records provided by EU Commission,…”. Looking forward for more!

    Like

  3. Myself I will be attending a frontiers meeting next year in New York hopefully
    As I suggested to RJ Smits the bet would be in public peer-review and and making available
    to public as well the original data
    Looking forward to hearing from RJ Smits about my suggestions and I challenge frontiers to publish my work in the terms mentioned above

    Like

  4. FAIR OPEN ACCESS

    FOR-PROFIT OPEN ACCESS FRONTIERS MEDIA LOBBYING AT EU LEVEL IS WORRISOME NOT ONLY BECAUSE OF INFLUENCE ON OPEN ACCESS POLITICS BUT ALSO BECAUSE OF FINANCIAL EU PUBLIC INTEREST THAT MAY BE QUESTIONABLE

    FRONTIERS MEDIA: ELEMENTS OF FISCAL OPTIMIZATION SCHEME

    Frontiers Media contact webpage (https://www.frontiersin.org/about/contact) does not mention active American corporates that could be used for fiscal optimization, but OpenCorporates database shows (https://opencorporates.com/companies?jurisdiction_code=&q=frontiers+media&utf8=%E2%9C%93) :

    Frontiers Media Inc, a branch of Frontiers Media Inc located in Olympia state of Washington.
    Frontiers Media Inc, in the corporation trust company located at Corporation Trust Center, 1209 Orange Street, St Wilmington, New Castle state of Delaware.

    Wikipedia (!) explains what kind of typical activities of Corporation Trust Center at the above address in Delaware…
    (https://en.wikipedia.org/wiki/Corporation_Trust_Center_(CT_Corporation):

    ” The Corporation Trust Center, 1209 North Orange Street, is a single-story building located in the Brandywine neighborhood of Wilmington, Delaware, USA, operated by CT Corporation. This is CT Corporation’s location in the state of Delaware for providing “registered agent services.”In 2012 it was the registered agent address of no fewer than 285,000 separate businesses. Companies have offices in Delaware due to its desirable corporate taxes and law, and it is estimated that 9 billion dollars of potential taxes were not levied over the past decade, due to the Delaware loophole”.

    Fiscal optimization scheme may also involve British and Swiss Frontiers Media corporations, two countries known as tax heaven by ONGs Tax Justice Network, as is Delaware in USA (https://www.financialsecrecyindex.com/).
    In Mr Leonid Schneider blog post about Frontiers Media lobbying with Mr Smits EU Commission’s special envoy for Open Access (OA) and main author of PlanS, EU documents reveal that Mr Smits expressed a positive opinion about continual reinvestment of Frontiers Media.
    Mr Christian Gutknecht at Swiss OA Lausanne conference 2018 reported in his blogpost a sentence by Mrs Kamila Markram sentence, Frontiers Media CEO (https://wisspub.net/2018/10/31/open-access-konferenz-schweiz-2018/)

    ” Auf die Kritik von Aguzzi, dass dadurch doch eine Erwartung auf Gewinn vorhanden sei, antwortete Markram, dass seit 10 Jahren bei Frontiers bislang noch keine Dividenden ausbezahlt wurden”.

    -> So why does have Frontiers Media a trust in Delaware if all benefits are reinvested in the corporation and not used at least partly as dividends? How could this question be better reformulated to be more relevant to understand financial fluxes within Frontiers Media? Is the financial flux scheme also include the non-profit Frontiers Research Foundation (https://www.zefix.ch/de/search/entity/list/firm/847516?name=Frontiers%2520Research%2520Foundation&searchType=exact)

    DIGITAL INDUSTRY FISCAL TAXES IS A PROBLEM IN EU

    EU and the European Competition Commission are working on rules in order to obtain fair taxes from digital industry in general (Fair Taxation of Digital Economy https://ec.europa.eu/taxation_customs/business/company-tax/fair-taxation-digital-economy_en).This latter pays in average about 9% taxes on benefits instead of 15 to 25% in nations with ‘physical’ companies. If all digital industry would pay an average of 9% or lower taxes through EU, then this industry may participate to lower public income that is necessary for sustainability of schools and … research. Moreover, ‘physical’ companies involved with real goods would not pay same amount of taxes as digital industry, meaning fiscal unfairness.
    Unfair fiscal situation also for other new OA players lacking resources to build such complex scheme to decrease taxes.

    PARADOX: WHAT IS PUBLIC INTEREST?

    Because OA is claimed to be of public interest, each EU OA partner industry should be totally transparent and prove how much taxes were paid on benefits in each EU countries where business occurred. If this condition is full-filled, then EU may consider to work with corresponding new OA for profit players?!

    MR SMITS AND EU COMPETITION COMMISSION SHOULD QUESTION FRONTIERS MEDIA FISCAL PRACTICE

    How can Mr Smits be sure that reinvestment of benefits really occurs, and after which benefit taxes paid in each EU country? What is the American trust in Delaware for?
    Could EU Competition Commission help Mr Smits to analyze and understand the legal or abuse of fiscal optimization?

    FRONTIERS MEDIA SHOULD PUBLISH AT MINIMUM ITS PRINCIPLES ON TAX AFFAIRS

    Could Frontiers Media consider to do a statement and prove how much was paid in each country where business occurred, like RELX Tax Principles (https://www.relx.com/investors/corporate-governance/tax-principles)?

    “3. Relationships with tax authorities
    We maintain professional working relationships with taxing authorities around the world:
    We are open and transparent about our tax affairs and significant transactions.
    We work co-operatively to resolve issues in a positive and professional manner”.

    CONCLUSION

    Frontiers Media could explain the financial fluxes between the trust in Delaware and previous holdings in California, the role of different corporates in Switzerland, UK, Spain, USA, and the Research Foundation. It could provide publicaly or to Mr Smits proofs about fair fiscal paid tax through the world. That would show all new for-profit OA corporations a principle of Fair OA thanks to transparency that EU citizen and economy needs for the future.

    Like

  5. Very unfortunate. Openness is paramount and must be given by the EU system.

    Like

  6. Dr. Teofilo Folengo

    This is fundamentally corrupt, and yet another demonstration that “Open Access” (which should be called “Author pays”) is a scam driven by publishers. I stood on a podium with Kamila Markram recently, and I was shocked by how she invoked her autistic child as a motivation for her to run Frontiers. I am sympathetic with her plight, but please don’t abuse your child to justify your parasitic business. All the millions that Frontiers is siphoning off, are millions that are missing from research – including autism research. You cannot go more hypocritical than that.

    Like

    • Interesting point of view. I would say taxpayers paying for research, without having access to the results is a scam. In my opinion, publishing in non-open and/or for-profit journals should be forbidden because it leads to massive revenues for private companies, while draining the library budget of universities, let academics work for them for free during their work-time (=peer-review process), and do not promote the one thing science should stand for: Open for everyone!

      However, if people are so keen on “academic freedom” to publish wherever they want, they can still share their manuscripts on Facebook, or GoogleDocs, or print them out and nail them to random trees in the forrest, nobody stops them. But same as you cannot take public/university money to pay for your private television, you can also not take it for a private publisher of your choice that does not follow EU regulations.

      Why not use the money that is pumped into the private industry at the moment and build up a publicly funded academic publishing service by the EU?

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      • You will quickly find out that non-profit publishing societies cannot afford open access under current conditions! So nailing papers to trees it will have to be!

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  7. Smut Clyde

    Edward Tufte’s aphorism seems appropriate here: “products under development are in one of two states – either too early to tell, or too late to change.”
    When it appeared, Plan S was already in the “Too late to change” state. That didn’t matter, we were told; wait for the details of the implementation. The implementation is currently in the “too early for consultation” state and at some point will switch over to “too late for consultation”.

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  8. Smut Clyde

    Imagining, arguendo, that Frontiers had designed a new framework that would ensure a reliable full-throttle flow of money directly from research funders to pay-to-print publishers (removing competition from subscription journals and removing the gatekeeper role of librarians), and given it to Smits to present it as a fait accompli to the EU Commission…
    How would it differ from the actual Plan S?

    Like

  9. anoneditor

    BTW, thousands of jobs are at stake here. Did anyone think what would happen if we were to lose them? Will the universities then employ these publishing and production professionals? It will pose a welfare-burden on the same taxpayer.

    Like

    • FAIR OPEN ACCESS

      ‘ Today’s international corporate tax rules are not fit for the realities of the modern global economy and do not capture business models that can make profit from digital services in a country without being physically present.

      Current tax rules also fail to recognise the new ways in which profits are created in the digital world, in particular the role that users play in generating value for digital companies.

      As a result, there is a disconnect – or ‘mismatch’ – between where value is created and where taxes are paid’

      Says European Commission for Fair Taxation of the Digital Economy in https://ec.europa.eu/taxation_customs/business/company-tax/fair-taxation-digital-economy_en#heading_0.

      Only revenue with taxes on employees does not ensure public sustainability in the future.

      So all scientific publication digital industry should pay fair taxes on benefits, to finance roads, schools and…. research!

      Like

    • True question here which have been pondering up in my mind for several years: what about an open access system where the authors don’t pay and the research including original data is open access? Something like these examples:

      https://theconversation.com/humanity-under-threat-from-antibiotic-resistant-infections-106682

      and

      https://theconversation.com/nonprofit-drugmaker-civica-rx-aims-to-cure-a-health-care-system-ailment-104744

      And finally, one that I use at the moments for some of my website and email systems:

      https://letsencrypt.org/

      Technologically, it is entirely possible to build the technology need but where the rubber need to meet the road is in funding (Let’s encrypt have their own), accounting (Frontier and its for-profit status is the elephant in the room here) and marketing, to scientists that is, which is of utmost importance.

      Alain (who, happen to have a 3rd author cite in one of the frontiers journal…)

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  10. Click to access smits-robert-jan-cv_en.pdf

    The areas of Robert-Jan Smits degrees are not obvious. Does he hold a science degree?

    Like

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  12. The most important statement is the first: “I obtained from the EU commission evidence that Smits was at least strongly influenced by Frontiers while designing Plan S”. This is the conflict of interests initiated by Frontiers. The only, ethically recognized requestor toward any OA plans including Plan S could be scholars as authors and readers. Do we have such a strong request from scholars now? Not, we do not have. Scholars need to have a free access only to high quality papers. Can Frontiers declare that plan S will increase the quality of publisher papers? I did not hear any statement like this. You are right – Fronties and other active promoters, for profit OA publishers as Hindawi, MDPI and others, coming first of all from a list of OASPA members, expect to gain profit to speed up the process of establishing new OA journals. I see that commercial OA publisher exploit e specific concept of OA – the more paper will be OA, the better for science. The more papers to be published, more profit will be gained by publishers. Scholars do not like this idea. What about quality of the papers, more reliable reviewing, etc? In this context plan S does not influence the quality of papers at all. It is a pity to see.

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  13. There are many certain items of Plan S. I see that one of the most important for its promoters is an attempt to make DOAJ a widely and officially recognized list of journals. One of items of Plan S declares about a leading role of DOAJ and only journals listed in DOAJ will be acceptable to have an access to funding APC. It means that DOAJ intends to play the role of widely (WOS, SCOPUS) and nationally (ABDC, ABS, QUALIS, AIDEA, ANVUR, NSD, etc) journal lists. Yes, WOS and SCOPUS are commercial products but it was established in expenses and under initative of a sole institution. ABDC, ABS, QUALIS, AIDEA, ANVUR, NSD are not commercial and this is a request of scholars. DOAJ declared at its web-site that DOAJ does not recognize and journal impact factor (which are residuals from journal lists). Does it mean that DOAJ will get rid of its statement about the role of journal impact factor with regard to the wish of DOAJ to be recognized officially as a sole accptable journal list under Plan S? Does it mean that plan S ignores other national journal lists like ABDC, ABS, QUALIS, AIDEA, ANVUR, NSD? If we compare the procedure of revision the journal lists above, so in major cases the journals list are set up for 3-5 years. DOAJ addes and removes journals daily. This does not go in the line with the practices of other journal lists. If the open access journals are in ABDC, ABS, QUALIS, AIDEA, ANVUR, NSD why plan S disregard these national journal lists and address a respect just to DOAJ? If DOAJ excludes each year about 400-500 journals we expect that the procedures of evaluation of new journals by DOAJ are not so effective and should be improved remarkably before pretending for a sole journal list under plan S.

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