Plan S: What's the point of policy consultations? - Samuel Moore
peter.suber's bookmarks 2019-02-14
"At first glance, consultations are an opportunity for organisations and individuals to shape a particular policy intervention through their responses. The architects of Plan S have granted the public an opportunity to voice their concerns with the expectation that these concerns are both heard and taken onboard in the resulting policy. This reading appeals to liberal-democratic notions of governance that assume the correct way to proceed will prevail, or that a compromise can be reached, if people can air their grievances through open and frank exchange of ideas.
The problem with such a conception of policy consultations is that it isn’t in clear how they should work: Whose comments should be taken into account (and are they weighted somehow)? Who gets to speak for whom? How do the Plan S architects incorporate such divergent and often oppositional feedback? Put simply, it is unclear how such feedback could ever result in a representative and fair process if all responses have to be accounted for somehow. Policy consultations are thus not an exercise in radical democracy....
In my PhD thesis, I looked at the creation of the HEFCE policy for open access for the next Research Excellence Framework. From reading a number of the consultation responses, and interviewing one of the policymakers at HEFCE, it became clear to me that the consultation was used to position actors in blocs so as to justify certain elements of the policy. For example, HEFCE were able to point to the consultation responses from learned societies and commercial publishers in order to make the case for a longer embargo length, even though many responses from different actors argued that embargos should be shorter. Learned societies and publishers were positioned by HEFCE as two different kinds of actors (the voices of academics and publishers) even though they both have a financial interest in the profits of the academic publishing industry. The consultation was thus used to justify (rather than reform) certain elements of the policy in accordance with the wishes of certain actors. The divergent responses to the consultation are helpful because they allow policymakers to cherrypick evidence that can make the policy more acceptable and seem more thought through...."