Following the 2012 round of the Performance-Based Research Fund (PBRF), the Ministry of Education, alongside the Ministry of Business, Innovation and Employment and the Tertiary Education Commission, decided to review the PBRF, to see whether the fund is achieving its aims.
Part of this review was a process of public consultation, including a general call for feedback, which closed on 4 October. As part of our work supporting open access and open licensing for scholarly research, Creative Commons Aotearoa New Zealand decided to submit.
The submission below is based on a series of questions posed by the review panel, in relation to a consultation document, which you can read at the PBRF Review page. Some of the questions are rather specific, so if you’re only interested in CCANZ’s general position, focus on the first and last question.
1. Do the proposed objectives provide a clear statement of the Government’s expectations for the PBRF? What are the key advantages or disadvantages of the proposed objectives?
Creative Commons Aotearoa New Zealand welcomes the Government’s recognition of the wider public benefits of excellence in research, including “provid[ing] economic, social, cultural, and environmental benefits to New Zealand” and “support[ing] commercialisation of research and technology transfer to New Zealand businesses and organisations.”
On their own, however, these objectives do not specifically incentivise the free transfer of knowledge from the research sector to other individuals and organisations — whether across or beyond the research sector itself.
The need for such incentives is clear. At present, most publicly funded research is not freely available for reuse by the organisations and individuals that need it. In fact, most publicly funded research — including journal articles and research data — is made available under prohibitively expensive pay-walls; even if organisations pay to access the research, it is usually restricted by all rights reserved copyright, which means that it cannot be freely reused.
The net result of the closure of academic research outputs is that the potential benefits cited above, which constitute the underlying purpose of public investment in funding research, will not be realised, regardless of whether the quality of New Zealand research outputs continues to increase.
The closure of academic research produces inefficiencies across the economy, as research is either unnecessarily duplicated or its social and economic potential is not fully realised. The inaccessibility of New Zealand research also restricts the reputational benefits of increased citations and visibility to the wider public.
We recommend that the PBRF objectives encourage the broad and free dissemination of openly licensed research to the individuals and organisations that can more effectively exploit its findings.
5. In your view, would redefining PBRF-eligible External Research Income to include commercialisation income earned from research outputs encourage individual researchers and tertiary education organisations to seek more commercialisation income?
We recommend that the Government defines commercialisation in the broadest possible sense. While there has been an international trend towards direct commercialisation by researchers and research institutions — with the attendant commercial income — the potential commercial benefits of New Zealand’s publicly funded research are much broader than commercialisation income on its own would suggest.
If commercialisation is to be recognised in the PBRF, Creative Commons Aotearoa New Zealand recommends that commercialisation that does not provide direct income to the university or researcher be included. As the New Zealand Government’s Open Access and Licensing framework already recognises, and as the rise of local businesses built on openly licensed government data and information proves, there is enormous potential for individuals and organisations in New Zealand to make efficiencies and innovate on publicly funded copyright material, if that material is made freely accessible.
If the intention of the PBRF is to increase activity across the economy, then we recommend that it incentivise the open dissemination of research, to give all New Zealand individuals and companies the ability to innovate from it.
6. What are the benefits and risks for tertiary education organisations, teaching and research staff, and research end users of redefining PBRF-eligible External Research Income to include commercialisation income earned from research outputs?
There is a risk that, unless the PBRF include a provision incentivising the free dissemination of openly licensed research outputs, the redefinition of eligible research outputs to include commercialisation income — and not commercialisation by New Zealand companies that do not provide a direct payment to the researcher or institution — will have the perverse effect of closing off New Zealand research to the companies that helped to pay for its production. We would also recommend that the PBRF include examples of reuse by non-profit organisations, as the activities of these organisations may also lead to downstream increases in productivity.
7. In your view, would placing a weighting on External Research Income received from non-government sources encourage researchers and tertiary education organisations to seek out research funding from industry, iwi and other community sources?
8. What are the benefits and risks for tertiary education organisations and teaching and research staff of requiring reporting of PBRF-eligible External Research Income by source and placing a weighting on External Research Income received from non-government sources?
While it is important that researchers seek external funding, it is essential that research outputs remain accessible to the wider New Zealand public, including commercial organisations that are better suited to benefit from those research outputs. While Creative Commons Aotearoa New Zealand accepts that some commercial arrangements will require restrictive IP arrangements, we wish to emphasise that public funding remains a core part of most New Zealand research outputs, even when it is partially sourced from elsewhere.
We believe that incentives for open access and open licensing are necessary to ensure that the Government’s current recommendations do not incentivise more restrictions being placed on New Zealand’s publicly funded research, which would in turn only serve to restrict full exploitation of the research outputs in the private sector. This would, as stated above, have the perverse effect of reducing the capacity of New Zealand organisations to realise the economic, social, cultural and environmental benefits of high quality New Zealand research.
11. In your view, would reducing the number of examples of Peer Esteem and Contribution to the Research Environment significantly reduce the amount of time spent by teaching and research staff and tertiary education organisations preparing Evidence Portfolios, while still providing sufficient information to allow for robust assessment?
12. In your view, would the introduction of a single Research Contribution component, together with more explicit guidelines, improve recognition of research contribution outside of academia within the Quality Evaluation?
While we accept the need to reduce the burden PBRF places on researchers and institutions, we wish to emphasise the need for the PBRF to prioritise the wider economic, social, cultural and environmental benefits of high quality research. Any proposed changes to the reporting structure should also include incentives for researchers to show the realisation of these wider benefits — including the innovative reuse of research by individuals and organisations outside of the academy.
For this reason, we recommend that the PBRF include specific guidelines for researchers to actively and openly disseminate their research to the public, including individuals, companies, community groups and other non-government organisations.
13. What are the benefits and risks for tertiary education organisations and teaching and research staff of removing the special circumstances provisions from the Quality Evaluation?
The removal of the special circumstances provision may discourage researchers from engaging in public outreach activities that help realise economic, social, cultural and environmental outcomes. For this reason, we recommend that the current provision be kept.
20. Is there any other feedback you would like to provide on the consultation document?
Creative Commons Aotearoa New Zealand welcomes the Government’s efforts to improve the efficacy of the PBRF. As the PBRF’s proposed objectives suggest, excellence in research is essential to New Zealand’s cultural, social, economic and environmental future, and it is appropriate that Government research funding bodies provide incentives to ensure that the benefits of funded research are realised.
We believe that these benefits can only be realised when New Zealand’s publicly funded research — including journals articles, research data and research tools — is freely accessible to the organisations and individuals that fund it. Specifically, we recommend that the PBRF incentivise the publication of research in open access journals and repositories, under an open licence that allows for broad dissemination and commercial and non-commercial reuse, following the precedents set by the NZGOAL framework for government data and information and many other funding bodies overseas, such as the National Institute of Health in the USA and the Wellcome Trust in the UK.
In closing, CCANZ also notes that New Zealand is a signatory to the OECD Declaration on Access to Research Data from Public Funding, which recognises “an optimum international exchange of data, information and knowledge contributes decisively to the advancement of scientific research and innovation.” Other relevant international agreements include the UNESCO Paris Open Educational Resources Declaration, which recommends that States “encourage the open licensing of educational materials produced with public funds.”