Australian University Heads of English (AUHE)

Name (Individual/Organisation)

Australian University Heads of English (AUHE)

Responses

Q1. How could the purpose in the ARC Act be revised to reflect the current and future role of the ARC?

For example, should the ARC Act be amended to specify in legislation:
(a) the scope of research funding supported by the ARC
(b) the balance of Discovery and Linkage research programs
(c) the role of the ARC in actively shaping the research landscape in Australia
(d) any other functions?

If so, what scope, functions and role?

If not, please suggest alternative ways to clarify and define these functions.

The Australian University Heads of English (hereafter AUHE) does not have specific recommendations about the purpose of the ARC Act.
We support the purpose of the ARC as stipulated in Section 3(a) of the ARC Act, that is:
the making of high-quality recommendations to the Minister in relation to which research programs should receive financial assistance;
the administration of the regimes of financial assistance; and
the provision of high-quality advice to the Minister about matters related to research.

We are strongly of the view that the ARC Act should be amended to remove the capacity for the Minister to reject recommended grants which has led to political interventions that have had a detrimental impact on literary studies research funding. The independence of the ARC is crucial to maintain the global standing of Australia’s research culture. The recent ministerial vetoes have damaged the reputation of the ARC, both within Australia and globally, and it is crucial that the ARC is, and perceived to be, independent and committed to excellence.
As an organisation that advocates on behalf of the discipline of English, we do not have a view in relation to exclusions including health and medical research and experimental development. We support the ARC strategy “to help shape the Australian research system for the benefit of the nation by enabling world-leading research, fostering research quality, translation and impact, and safeguarding research integrity.” In particular, we endorse the broad purview of the ARC in defining the scope of the ARC, which ensures it can be responsive to the changing nature of the global research environment. We therefore do not support the codification of ratios of Discovery to Linkage research programs and endorse the maintenance of the ARC’s support for fundamental research.
While it is crucial for Australian universities to attract and retain excellent researchers, we are wary of the ARC taking a lead in this space beyond current funding arrangements, that is, through DECRAs, Future Fellowships and Laureates.
We endorse the amending of legislation to recognise and support the research of Aboriginal and Torres Strait Islander peoples and the expansion of research according to Indigenous knowledge systems.
The ARC already recognises the effects of disruption to research careers through its commitment to Research Relative to Opportunity.

Q2. Do you consider the current ARC governance model is adequate for the ARC to perform its functions?

If not, how could governance of the ARC be improved? For example, should the ARC Act be amended to incorporate a new governance model that establishes a Board on the model outlined in the consultation paper, or another model.

Please expand on your reasoning and/or provide alternative suggestions to enhance the governance, if you consider this to be important.

The AUHE supports the suggestion made in the consultation paper that the ARC re-establish a Board rather than just relying on a CEO. We agree that the said Board needs to bring a wide range of research expertise and be appointed by the research community. The Board should then appoint the CEO. This would avoid political appointments and the politicisation of research. Board expertise needs to include a broad representation from academic disciplines, with one or more humanities representatives appointed that have an understanding of the range of and value of research methodologies used in the humanities disciplines. The representative would be able to advocate for the value and importance of humanities research and seek to ensure it is more conspicuously included in policy positions and understandings of national priorities and national interest statements. At present the humanities is often marginal to these kinds of statements.

Q3. How could the Act be improved to ensure academic and research expertise is obtained and maintained to support the ARC?

How could this be done without the Act becoming overly prescriptive?

The AUHE supports the appointment process of the College of Experts in which appointees are recognised for their research excellence and scholarly expertise. The AUHE believes that the most urgent priority is for the ARC Act to enshrine the principles of academic freedom, academic autonomy, and academic expertise at the centre of all the Council’s activities. Most immediately, this entails i) reforming the Act so that the Minister for Education does not have the discretion to overrule grants recommended by the ARC, and ii) abolishing the National Interest Test.

End Ministerial Interference

For research in English and Literary Studies more broadly, ending ministerial interference in grants has become an existential matter. Grants in literary studies have most frequently been targeted on occasions when a Minister has exercised the right to reject grants. In the most recent instance of Ministerial overrule (DP22 round), only 70% of recommended grants in literary studies were approved (9 out of 13) as against 98.9% of projects overall. On this basis, it is nearly thirty times more likely that a grant in literary studies will be refused than for other fields of research. In 2018, three of the eleven grants refused by the former Education Minister Simon Birmingham were in literary studies.

The high proportion of literary projects denied funding points to a significant decline in research investment and yet international ranking systems (QS and THE) continue to number Australian English departments amongst the best in the world. In the Federal Government’s 2018 ERA ratings, 17 Australian universities achieved “at world standard”, “above world standard” and “well above world standard” outcomes in the Literary Studies code (2005).

It is not sufficient for individual ministers to pledge not to overrule recommended grants. Without legislation to prevent political interference and the overrule of rigorous processes of peer-review, researchers in English will continue to work in fear of having their projects struck down by politicians. This is anti-intellectual and anti-liberal. As the ANU Vice Chancellor Brian Schmidt tweeted in response to the most recent vetos: “To all politicians. In a liberal democracy, You make the grant rules. The independent research agency uses peer review to determine funding. It is completely inappropriate for grants to be removed by politicians, unless the grant rules were not followed.”

In the United Kingdom this is known as the “Haldane Principle,” which Professor Andrew Francis succinctly summarised in his submission to the 2022 inquiry into Australian Research Council Amendment Bill: “The principle is that Ministers should set the parameters for funding, and approve processes and rules for funding allocation, but leave decisions about individual projects to the research agencies to determine with the advice of researchers.” The AUHE recommends that words to this effect be included in an amended ARC Act.

Abolish the National Interest Test

When the former Education Minister Dan Tehan introduced the National Interest Test for ARC grants in the wake of the outcry following former Minister Birmingham’s refusal of grants, it provided the Minister another lever with which to overrule academic expertise. Australian academics conduct research in a multitude of fields that thrive within a global ecology of ideas and debates. There are many urgent research projects whose rationale derives from the intellectual possibilities within particular fields, and their points of focus are not always immediately justifiable in the terms of national interest. It is always in Australia’s national interest to have qualified academics participating actively in their fields alongside international peers, with research priorities determined by the state of knowledge and the procedures of open-ended and free inquiry. Public benefits accrue when projects of national benefit draw on this knowledge, including those that reap the economic benefits of innovation as well as the enhancement to democracy when critical and analytical rigour are brought to bear in all areas of public life. One of the more invidious aspects of the NIT is the ease with which it is deployed as a national security cover for what are in fact ideological differences and hostilities deeply embedded in public discourse; the habitual recourse to the fiction of a ‘pub test’ merely confirms this inbuilt duplicity. The NIT has also increased the amount of administrative churn at the ARC and led to delays in the announcement of grants. The AUHE recommends that all clauses relating to the NIT be struck from the ARC Act.

Q4. Should the ARC Act be amended to consolidate the pre-eminence or importance of peer review?

Please provide any specific suggestions you may have for amendment of the Act, and/or for non-legislative measures.

The AUHE supports consolidating the pre-eminence of the peer review process and the principles that underpin it, particularly for for assessing grant outcomes; namely, academic autonomy, freedom of inquiry, and academic expertise. The Act should make clear that the use of expert peer review when assessing grants is just one key way in which these principles are realised through concrete processes. Peer review is certainly a key means for ensuring autonomy, free inquiry, and importance of expertise for research. The AUHE notes that there are numerous other factors, including:

- secure ongoing employment (‘tenure’);
- institutional autonomy through self-governance, democracy, and internal critique;
- institutional and legislative guarantees for free speech and free inquiry;
- institutional and legislative guarantees that research priorities be determined by the necessities of free inquiry and the pursuit of truth;
- the dynamic interrelation between teaching and research that ensures that the teaching is continually infused with new knowledge and that researchers teach the next generation of critical thinkers who in turn challenge existing paradigms;
- equal access to universities so that knowledge does not serve sectional interests of particular genders, classes, religions, or ethnic groups.

Reform to the ARC Act thus needs to ensure that the allocation of grant funding is determined principally by peer-review and cannot be interfered with politically. These changes need to take place in tandem with other legislative and non-legislative measures that secure the principles that we have named. (This includes overhauling the funding model to universities to minimise casual and fixed-term labour in teaching and research, reforming governance models to be more democratic and self-governing, ensuring that the bulk of grant funding is for basic research, and producing legislative guarantees for universal access to universities and the knowledge they produce.)

Q5. Please provide suggestions on how the ARC, researchers and universities can better preserve and strengthen the social licence for public funding of research?

The AUHE understands the importance of preserving and strengthening the social licence for the public funding of research.

The AUHE stands firm on the principle that the preservation and strengthening of the social licence for public funded research is best served with the end of Ministerial interference in grant funding decisions. In his State of the University address in February 2022, the Nobel Laureate and ANU Vice Chancellor Brian Schmidt characterised the capacity for Ministers directly to interfere in research funding as “an existential threat to Australian universities”. Researchers across all disciplines understand that Ministerial interference undermines the core purpose of universities as autonomous institutions dedicated to the pursuit of truth and new knowledge. AUHE stresses that this autonomy is crucial to the capacity for universities to serve the public good. When researchers can freely apply themselves to the most challenging problems without fear of censorship or interference, it yields the ideas and solutions that allow society to meet challenges of the scale of climate change and spiralling global inequality.

The ARC has a rigorous grant funding process, which includes the expertise of peer assessors and members of the College of Experts. The AUHE supports this process. The rejection of recommended projects through ministerial veto undermines public confidence in the ARC processes, including peer review, and undermines support for the ARC amongst the national and international research community. Peer assessors need to know that the time they dedicate to peer assessment will not be wasted.

The most recent exercise of ministerial veto in 2021 was based on their failure to meet, in the minister’s opinion, the national interest test (NIT). However, as the Senate Estimates of 17 February 2022 made clear, the Acting Minister did not have access to full applications, nor is it clear what criteria were used to determine how or why these projects did not meet the requirements of the NIT. This arbitrary refusal of grants points to the need for fundamental reform of the ARC act and comprehensive legal protections for academic freedom and expertise. One aspect of legislative reform required would be to develop an Australian version of what is referred to as the ‘Haldane’ principle in the United Kingdom: a mechanism for ensuring that the government’s provision of funds for research is kept entirely separate from decisions about how those funds are spent.

In comparable higher education systems in the USA, United Kingdom, and Canada, it is recognised by all sides of politics that the public benefits, including economic, of scholarly research are compromised when politicians make decisions about funding with disregard to independent peer-review processes. In the United Kingdom, the Haldane Principle was enshrined by the Conservative government in UK law in the Higher Education and Research Act 2017. The rationale for this amendment to the Act was to protect basic scientific research in the context of an ambitious industrial strategy that aimed to increase productivity by raising the UK’s investment in R&D to 2.7 per cent of GDP by 2027. The law stipulated that the Government can give UK Research and Innovation larger scale strategic directions about the allocation or expenditure of grants received, but decisions at the level of individual research proposals should be left to expert peer review.

Australia finds itself at a similar point in research funding strategy that requires a robust protection of peer review processes that are fundamental to the international standing of the ARC.

Q6. What elements of ARC processes or practices create administrative burdens and/or duplication of effort for researchers, research offices and research partners?

The AUHE’s is grateful that this review is concerned with questions of administrative burden and duplication. One aspect of the existing ARC practices and processes that we find unnecessarily burdensome is the presumed dedifferentiation for all grant proposals between applied and pure or ‘blue-sky’ research projects. The AUHE, representing the discipline of English literary studies nationally, is inherently predisposed (as several but not all humanities disciplines are) towards pure or blue-sky research, as applications of literary research are less immediately tangible than research in other disciplines (Education, Business, Architecture, etc.). And yet the existing framework for all grant applications is identical: all proposals must make a case for socio-economic and national benefit, construed increasingly in terms of quantifiable social and economic outcomes. This presumption strikes at the heart of what we believe to be the constant and inestimable benefit of the advancement of learning per se: the idea that knowledge begets knowledge, understanding leads to further understanding, and the development of analytical, critical, and evaluative tools for the comprehension of human culture is a good in and of itself (just as in mathematics there is a clear and necessary distinction between pure and applied research; and the advancement of learning in this field is obviously a good in itself). For research that identifies itself as ‘pure’ or unapplied to any particular social or economic problem, it is an unnecessary and unwanted diversion to then account in advance for outcomes that speak to specific governmental priorities or goals, commercial applications, or industrial advantages.

We therefore recommend that the ARC introduce a two-tier system, funded at equal levels: an applied research stream, which would maintain the emphasis on practicable outcomes and social desiderata; and a pure or blue-sky stream which endorsed in advance the notion that the advancement of learning is a social and cultural benefit in itself without the need for clear ties to any further outcomes in the framing of specific projects. This would free a good percentage of grant applications from the contortions that inevitably beset their framing when going through the sections tethered to socio-economic and national benefits. We also recommend that the detailed assessors’ scores be given greater weighting than those of the general assessors for pure or blue-sky applications.

We believe that the currently mandated provision of hand-crafted endorsements by DVCs-Research for each specific researcher’s application places an enormous burden on research offices and stretches resources very thin at the relevant crunch times of every cycle for each grant scheme. A proforma endorsement would make much more sense and reduce the pressures placed on these critical bottlenecks.

As well, we would wish to amplify the bullet-point noted as already received in the review of the consultation paper: impediments to international research collaboration; onerous requirements made of partners (including industry and international) at the time of submission in cases where these partners do not receive any direct funding from the ARC. These are ongoing stresses that actively reduce the amount of international research collaboration fostered by the ARC.

Q7. What improvements could be made:

(a) to ARC processes to promote excellence, improve agility, and better facilitate globally collaborative research and partnerships while maintaining rigour, excellence and peer review at an international standard?

(b) to the ARC Act to give effect to these process improvements, or do you suggest other means?

Please include examples of success or best practice from other countries or communities if you have direct experience of these.

Some research projects in literary studies do not require the minimum $30,000 per year stipulated by current ARC guidelines, and are not being adequately funded through internal institutional grants. In effect they are not being advanced at the rate they ought. The AUHE believes that any effort to increase agility and outcomes, and improve the cost benefit per grant for the ARC, should include a discipline-specific grouping around agreed FOR codes which would allow for smaller grants (say, from $5,000 to $15,000 per year for 2-3 years). Other disciplines might include Classics, Philosophy, Film Studies, and Religious Studies. Such a move would lead to more, and more targeted, research projects being funded annually and increase the yield of top-quality research outcomes nationally without any additional expenditure. Successful small grants schemes are already in place through Canada’s SSHRC, New Zealand’s Marsden Fund and the European Research Council.


We believe that an agreed list of top-tier international partner institutions ought to be identified with streamlined and less onerous rules around including PIs from those institutions in any grant application.

Q8. With respect to ERA and EI:

(a) Do you believe there is a need for a highly rigorous, retrospective excellence and impact assessment exercise, particularly in the absence of a link to funding?

(b) What other evaluation measures or approaches (e.g. data driven approaches) could be deployed to inform research standards and future academic capability that are relevant to all disciplines, without increasing the administrative burden?

(c) Should the ARC Act be amended to reference a research quality, engagement and impact assessment function, however conducted?

(d) If so, should that reference include the function of developing new methods in research assessment and keeping up with best practice and global insights?

A. Do you believe there is a need for a highly rigorous, retrospective excellence and impact assessment exercise, particularly in the absence of a link to funding?

Yes. Entirely removing the ERA and decoupling it from any relation to funding will have potential negative effects on research in disciplines in the humanities which do not receive the same levels of research funding as STEM disciplines. Should no accounting for the quality and level of research publications take place, research in these disciplines might become invisible to university administrators who might then simply discount this research and its impact on Australian society and culture. This might then affect the research careers of staff and staff workloads and the potential for promotions since their research might effectively be decoupled from their perceived roles in the university system.
As the sole remaining instrument through which to measure and evaluate actual research outcomes (as opposed to research income or HDR completions—the means of determining research block funding), it is crucial to protect and enhance the significance of the ERA (or equivalent) in a context of increasingly arbitrary institutional and governmental priorities in research. Internationally, the ERA is a crucial visible sign of the scope and significance of research excellence in Australia and cannot be removed without a serious diminishment of the regard in which Australian researchers are held.

AUHE also believe that any impact and assessment excellence exercise needs to include mechanisms for supporting research at smaller, often vulnerable, institutions which might include only a few researchers in a given FoR code. These researchers, often at regional institutions, often undertake research that is of high significance and speak to the diversity of Australia’s regions.

B. What other evaluation measures or approaches (e.g. data driven approaches) could be deployed to inform research standards and future academic capability that are relevant to all disciplines, without increasing the administrative burden?

The ARC must take fully into consideration the scholarship that confirms that major providers of research citations, such as Scopus/Scimago and Clarivate/WoS, simply do not count the majority of citations from books, book chapters and journals in humanities disciplines.

Research indicates only between 20-27% of humanities journals are covered by these commercial databases so that, according to the 2017 KPMG report to FASS UNSW, p 22, ‘Any research evaluation using citation data supplied by Scopus or WoS would be based on very small samples of an academic’s work, and it is unlikely that this would provide for robust and verifiable assessment of their portfolio’ (see also Aksnes and Sivertsen; Mongeon et. al; Martín-Martín et.al).

Google Scholar potentially provides a more robust measure of research citations in the humanities and can be applied to all disciplines, and its application should be examined (Martín-Martín et.al). It is certainly superior to other available citation counting systems for the humanities.

However, we question any data driven approach that insists on being equally applicable to ‘all disciplines’. This does not recognise or value publishing and research traditions that are specific to different fields. ‘The Norwegian Model’ which runs successfully in many European countries is designed to account for such field specific differences and we encourage the ARC to examine this model (Aksnes and Sivertsen). For example, humanities book publishing traditions involve research undertaken over many years that is then relevant within its field for many years, even decades for strong work.

So too, commercial databases that attempt to rank journals in a field (such as Scimago’s ranking of ‘Literature and Literary Theory’) are highly problematic. They include many journals that do not sit predominantly within ‘Literature and Literary Theory’ for example but rather come from high citations disciplines (such as the top ranked journal ‘Criminology and Public Policy’). Including a high number of such journals distorts the rankings and citation expectations of those journals that primarily or exclusively relate to the discipline of Literary Studies and thereby radically pollute the data related to ‘journal quality’. Rankings lists of this kind are problematic in a discipline such as ‘Literary Studies’ (FoR 4705) which is divided into numerous sub-fields (something 6 digit FoR codes attempt to partially capture) since these sub-fields will each have their own journals of record, so that rather than a simple hierarchy of acknowledged quality, quality is dispersed into branches in the field. Again we recommend the ARC/ERA look to the methods adopted by the Norwegian Method, which factors in ‘field specific publishing traditions’ into its ranking methodology, and requires input from peak bodies in disciplines (Aksnes and Sivertsen, 3-5; Siversten, 79-90).

We strongly contend that in the absence of genuine peer review the ARC/ERA must develop field-specific modes of analysis and evaluation. We strongly contend that disciplinary peak bodies be allowed some time (at least 3 but ideally 6 months) to consult with their fields to respond to problems posed by the ARC/ERA and attempt to provide advice specific to their own fields.

We also recommend that some form of peer review be maintained. For example, discipline leads could be identified at all institutions that qualify under a given four digit FoR code. These experts could be asked to make use of a rubric to evaluate short summary applications listing chosen data summaries and statements of attainment and impact from all eligible institutions. This limited peer review could be added to the overall process. Since discipline leads will likely only be involved in evaluating one or two 4 digit FoR codes the burden of peer-review work will be spread across institutions and become less onerous.

The data assessed could include items such as HDR completions. They could include citations taken from Google Scholar and possibly include all citations that accrue over a given period (for, say, a given number of researchers who represent a field), including for publications that where published before the given period began (so as to capture data related to the long term impact of research in our fields). Data could include reference to World Cat, which indicates how many books are held in world libraries. These kinds of suggestions could be examined and explored, for example, through round table discussions with peak bodies and the ARC.


Works Cited
Aksnes, Dag W., Gunnar Sivertsen, ‘A Criteria-based Assessment of the Coverage of Scopus and Web of Science’, Journal of Data and Information Science, Vol 4, No. 1, 2019, pp. 1-21.
KPMG Australia, ‘Identifying Research Performance Measures and Performance Management Mechanisms for the Faculty of Arts and Social Sciences’, Final Report for UNSW, 2017.
Martín-Martín, Alberto, Enrique Orduna-Malea, Mike Thelwall, Emilio Delgado López-Cózar, ‘Google Scholar, Web of Science, and Scopus: A systematic comparison of citations in 252 subject categories’, Journal of Informetrics, 12, (2018), 1160-1177.
Mongeon, Philippe and Adele Paul-Hus, The journal coverage of Web of Science and Scopus: a comparative analysis, Scientometrics (2016) 106:213–228.
Sivertsen, Gunnar, ‘Publication-Based Funding: The Norwegian Model’, in Michael Ochsner, Sven E. Hug, Hans-Dieter Daniel (Editors) Research Assessment in the Humanities: Towards Criteria and Procedures, Springer Open, 2016, pp. 79-90.


C. Should the ARC Act be amended to reference a research quality, engagement and impact assessment function, however conducted?

Yes. The ARC should be careful to accurately assess the value of the disciplines of the humanities which often contribute to Australian society and its place in the world through providing social and cultural benefits and developing new knowledge within particular disciplines. Such knowledge is and has always been applied either to teaching students and to the communication of results both to specialists and to the general public. Such knowledge is and always has been applied to deeper understandings of particular times, places, problems, and cultural practices, including the most pressing contemporary social and cultural problems. As such humanities research is essential to the thriving of Australian society. The impact of humanities research and its value needs to be much better recognised.

D. If so, should that reference include the function of developing new methods in research assessment and keeping up with best practice and global insights?

Yes. As set out above there is currently no ‘off the shelf’ bibliometric system that can adequately assess all disciplines in the Australian university system. Any attempt to impose an existing system of this kind will have the effect of deeply harming other disciplines and driving them to the margins of Australian public life. Much work and thinking needs to be done to find systems (plural, since we do not agree that one system can account for the disciplinary differences inherent to the university, which, by its very definition, must take account of multiple views and approaches) that can do justice to the complexities involved. AUHE and I am sure other peak bodies in the humanities are very willing to engage with a process that offers sufficient time and clear direction on developing systems that might better account for these disciplines.

Q9. With respect to the ARC’s capability to evaluate research excellence and impact:

(a) How can the ARC best use its expertise and capability in evaluating the outcomes and benefits of research to demonstrate the ongoing value and excellence of Australian research in different disciplines and/or in response to perceived problems?

(b) What elements would be important so that such a capability could inform potential collaborators and end-users, share best practice, and identify national gaps and opportunities?

(c) Would a data-driven methodology assist in fulfilling this purpose?

A. The AUHE strongly believe the ARC must clearly recognise the differences in research methodologies in play across different disciplines and clearly communicate to government, the university sector, and the general public the nature of these differences. In doing this, the ARC must look to world best practice in identifying the best methods for evaluating different disciplines in ways which do not distort or devalue the research work done within disciplines in the humanities and other disciplines that are poorly represented by bibliometric methods of accounting that may work well in other areas. We have outlined above some suggestions for doing this in the previous question, and pointed to research that has been done internationally to attempt to address some of these short-falls and problems. We believe the ARC should convene round tables that openly address, rather than hide, these issues, and seek some measure of consensus in how to deal with them in ways that are not corrosive to important research being done, whether it is done in well resourced institutions or by one or two researchers in isolated departments. These round tables should invite peak bodies that represent disciplines in the humanities as we believe that many of the key problems with data based systems of accounting relate to how research in the humanities is valued and counted.

B. An open debate that is structured and focused on outcomes would itself inform collaborators and end-users and provide an opportunity for fields to better explain the value of the research they produce.

C. Data driven methodologies are, no doubt, unavoidable. However, as we point out above they can be highly inaccurate, and if inaccurate they can be corrosive of genuine research, undermining it rather than helping it to thrive. Data driven approaches, then, need to be properly adapted to the disciplines they seek to describe and assist. We set out above some suggestions as to how to begin to deal with these concerns.

Submission received

14 December 2022

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