SCONUL feedback on Plan S guidance has been submitted today.

SCONUL has reinforced its strong support for the Plan S vision of immediate open access to all scholarly publications funded by cOAlition S members, and to its broader aim of accelerating the transition to a scholarly publishing system that is characterised by immediate, free online access to, and largely use and re-use of scholarly publications. 

The submission highlights where changes to the proposed implementation guidelines might foster these two aims. This includes:

- the need for a pluralistic approach to open access under the guidance, including pay to publish but also green routes

- further work on transformative agreements

- a more lengthy and staged transition period

- including rights retention mechanisms such as the UK SCL

- price caps on APCs while DORA principles are fully implemented

- an approach to specifying infrastructure requirements which focuses on outcomes and principle rather than precise delivery mechanisms.

The submission is available here.