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Date of publication, which is relative to date of acceptance, is extremely variable, can only be estimated on average, and is highly arbitrary.
This is another reason (if yet another reason was needed) to peg deposit date requirements to acceptance date and not to publication date:
The earlier the deposit date — as well as the OA date — the better (for research, researchers, their institutions, their funders, the tax-payers that fund the funders, and for the “public good”). The purpose of OA is to eliminate research access and impact loss in the online era because of needless access denial.
Another reason is that the Copy Request Button can start to provide “Almost-OA” as of the date of deposit, not before.
Yet another reason is that — whether they like it or not, and whether they admit it of not — virtually all journal publishers have by now conceded on “OA” after a one-year embargo (from publication date!):
Hence the needless access/impact-loss figure to beat is P + 12.
It stands to reason that if P = A + 3, 6, 12 or more then the needless access/impact-loss becomes not just 12 months, but (unpredictably) 12, 15, 21, 33 months or more.
OA means immediate OA (or at least immediate OA + Almost-OA) to refereed research -- not embargoed access.
“OA” after 12, 15, 21, 33 months or more, on the other hand, is a not OA but a grotesque and cynical caricature of OA.
Hence HEFCE have adopted exactly the right mandate:
1. Deposit immediately upon acceptance for publication (with 3 month grace period) plus
2. OA as soon as possible thereafter. (Meanwhile, at least almost-OA immediately.)