Australian Association of von Humboldt Fellows and the Australian Association of University Professors

Name (Individual/Organisation)

Australian Association of von Humboldt Fellows and the Australian Association of University Professors

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.

In his letter of expectation to the former CEO of the ARC, Professor Sue Thomas, the former acting minister for Education, the Hon. Stuart Robert MP, stated that a minimum of 40 per cent by value of all grant funding decisions were to be for approval under the Linkage Program, and, furthermore, that 70 per cent of recommended Linkage Program grants were to be aligned with the Government’s National Manufacturing Priorities.
We do not support these changes to the ARC proposed by the Hon. Stuart Robert MP. University researchers are not unpaid employees of the Australian Manufacturing Industry. The AAvHF and AAUP do not support the introduction of quotas for particular research areas in any of the ARC’s funding programs. Selection should be based on the quality of the proposed project and the quality of the researchers alone.
Furthermore, the AAvHF and AAUP stress the importance of fundamental research, funded under the Discovery Program, whose long-term benefits are often not immediately evident, but can have far greater societal impacts than short-term applied research. Therefore, the AAvHF and AAUP are against any erosion of the Discovery Program in favour of the Linkage Program.
The AAvHF and AAUP would also like to point out inconsistencies in the ARC Medical Research Policy (v 2018.1) which must be rectified. Point 2a of this document states that research eligible for ARC support includes “research where the aim is the fundamental understanding of biological processes not directly related to human medical and/or health interventions and outcomes (e.g., human biology not related to health)”. This final statement contradicts itself, because all human biology must be related to health. Any malfunction in human biology must automatically lead to a pathological condition or disease. Therefore, it is illogical to exclude ARC funding to research projects leading to an improved understanding of human health. Point 3a then states that research ineligible for ARC support includes “research …of physical or mental disease or other medical and/or human health condition”. As stated above, all research into human biology is related to health, and consequently also to disease. Understanding of disease is enhanced dramatically if the fundamental biological processes operating in a healthy state are understood. This indicates that the ARC medical research policy as it stands is impossible to effectively implement, leading to valuable projects being arbitrarily excluded based on opinions on what constitutes medical research and what doesn't.

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.

No. The AAvHF and AAUP support the re-establishment of an ARC Board, which would make recommendations to the Minister for the appointment of a CEO who has extensive experience as a researcher and is held in high regard by the academic research community. The AAvHF and AAUP believes that this is preferable by far to the current system where the CEO is appointed solely by the Minister. The ARC Board itself should be democratically elected by those eligible to apply for ARC funding.

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?

To avoid continual erosion of funding levels, the AAvHF and the AAUP believe that the act needs to include a minimum level of funding relative to GDP or some other agreed measure that indicates a serious national commitment to research.
The AAvHF and AAUP also believe that the current panels are too broad in the subject areas that they encompass and do not reflect modern research trends. In particular, modern interdisciplinary areas which fall between the current panels are not being adequately funded. For example, the fields of biophysics and biophysical chemistry fall between the panel Mathematics, Physics, Chemistry and Earth Sciences (MPCE) and the panel Biological Sciences and Biotechnology (BSB). Another example is fundamental AI research with benefits for biomedicine which cannot be funded currently although too basic for any NHMRC program. To ensure that research grants are assessed by qualified assessors, the panels should be replaced with a greater number of subject-specific review boards. These could be modelled on the Fachkollegien of the German Research Council (Deutsche Forschungsgemeinschaft, DFG), of which there are 49, in comparison with the 5 panels of the ARC. A further advantage of the DFG system, which encourages the quality of assessments, is that members of the Fachkollegien are voted into office by their peers. Selection by one’s peers as a DFG Reviewer is, thus, a recognition not only of academic achievement, but also academic integrity, honesty, and reliability. This method would achieve a higher quality of reviewers than the ARC’s current system where members of the Colleges of Experts are nominated by their institutions with no input from researchers at other institutions in the same field.

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.

Yes. No one person has sufficient knowledge across all disciplines to be able to judge the quality of all grant applications and whether they should be funded or not. The veto of approved projects by the Minister makes a mockery of the review process and damages the international reputation of Australia as a research collaborator. The Minister’s sole discretion to approve or reject a research proposal recommended by the ARC must be removed.
However, it is important to remember that there are three stakeholders in the awarding of any grant. Firstly, there is the researcher concerned, who rightly expects an assessment of their proposal by qualified experts in the research area of the project without any political interference. Secondly, there is the Minister or the Government, who are elected representatives of the public and who have a duty to spend public money wisely. Thirdly, there is the public, who have the expectation of their elected representatives that they use their taxes wisely. Each of these stakeholders needs to be satisfied in the approval of grants. For this to occur, political involvement in grant approval cannot be totally removed. However, the political involvement should not be focussed on the Minister alone. Therefore, the AAvHF and AAUP recommend that the approval of proposals recommended by the ARC be carried out by a committee which includes both academic and Government representatives. Here, again, the German Research Council (DFG) provides a good model.
In the case of the DFG, projects recommended for funding are approved by a Central Committee (Hauptausschuss), which has both academic and Governmental representation. The Committee consists of 70 members, of which 37 are academics, 24 are Government representatives (both federal and state), 3 are members due to held office, 5 are guests (presumably without voting rights), and 1 is a representative of a research sponsors’ association. From these numbers one can see that the academics are in the majority. This ensures that projects are not rejected for purely party-political reasons. However, Governmental representation on the committee ensures that the Governmental and public stakeholders are satisfied by having some influence over the spending of public money. Furthermore, if there are any situations where for reasons of national security it is in the best interests of the public for a recommended grant not to be approved, then the Governmental representatives have an opportunity to make this case. The current national interest statement should be removed (also see below). In general, political influence on funding decisions should be much reduced at all levels of the application handling process in favour of merit-based criteria.

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

As stated on page 6 of the Consultation Paper, the Discovery scheme is for fundamental research. Fundamental research has appeared in the past under the name “Breakthrough Science”, for example as a National Research Priority. However, it has been absent for many years, and fundamental research is not currently supported by the National Research Priorities. We strongly recommend reviewing the National Research Priorities with a view to including one or more new priorities that focus on fundamental research.
The national benefit of fundamental research cannot be foreseen and must not be underestimated. In his opinion piece published in the Australian Financial Review on the 7th of February 2022, Dr Enno Aufderheide, Secretary-General of the Alexander von Humboldt Foundation, provided a prime example. In 1920, in the course of curiosity-driven fundamental research, Otto Stern and Walther Gerlach unexpectedly discovered the spin quantisation of atomic nuclei. This discovery forms the basis for medical MRI (magnetic resonance imaging) scans, which are now performed in hospitals the world over. But at the time no-one could have envisaged the medical application that this discovery would have. Stern and Gerlach would definitely not have written in a national interest statement that their research would lead to the development of MRI fifty years later, i.e., in the 1970s.
We mention one more example of fundamental research having tremendous long-range unforeseeable impact: pure mathematics and cryptography. In our modern society not much happens on the internet without leveraging work of Gauss, Abel, Euler and Riemann from two hundred to three hundred years ago. Until the mid 20th century, no practical application of their work in number theory was known. Nevertheless, public investment of research effort into number theory was defended famously by British number theoriest G. H. Hardy in “A Mathematician’s Apology”. Hardy’s argument was not predicated on any eventual application, and used number theory as something “almost wholly useless”. Only a few years later the first computers would be constructed.
Stern and Gerlach would have needed fifty years of foresight to use the eventual incredible application of their work to justify its funding, and for the mathematics of number theory, more than two hundred years of foresight would have been needed. However in both cases we could not have the world we enjoy today without that fundamental research.
Therefore, because of the unforeseeable applications of fundamental research, the AAvHF and AAUP recommend that the National Interest Test be dropped from the Discovery Program. Instead of trying to justify the funding of fundamental research to the public in terms of short-term applications, the Government should invest more effort in educating the public as to the long-term benefits of fundamental research. The example of spin quantisation is one example that the Government could use, but there are many others.

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

In 2021 grant outcomes of the Discovery Program were announced by the Minister on Christmas Eve. Approved grants are often scheduled to start at the beginning of January. It is important to remember that many postdoctoral researchers rely on ARC funding for their salaries. An announcement on Christmas Eve of grants that were not approved, gave many young postdoctoral researchers only a handful of days’ notice that they were out of a job. It is highly likely that many of them couldn’t wait until Christmas Eve to find out whether they still had employment, and instead started looking for a job overseas. This represents a tragic loss of valuable expertise for Australia. This situation was unacceptable and cannot be allowed to occur again. Funding announcements must be made by the end of November at the very latest.
A further problem with a delayed funding announcement is that it causes a delay in the release of forms for the subsequent ARC Discovery funding round. In 2022 the forms for funding in 2023 were not released until well into first semester of the new academic year. This is a time when academic staff are meant to be focussing on teaching undergraduate students. The late release of the forms, thus, potentially impacted on the quality of undergraduate teaching. The new forms need to be released on-line in December, as they were for the current round, so that grant applications can be prepared when undergraduate students are on their long summer break and the teaching of students is not adversely affected.
Every year it seems that the ARC changes aspects of the application. The order of different sections of the project description change, or the information requested in the application changes. These may seem like small changes to the bureaucrat in Canberra who introduced them, but they create unnecessary work for researchers and administrators across the country, wasting time which could be more fruitfully employed in actually doing research. The ARC should decide on one basic format and avoid changes as much as possible to save everyone involved time.

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.

The overall success rate for the latest ARC Discovery round was 18.5%. This is simply not good enough. Many excellent research projects are not receiving any funding at all year on year, and researchers are wasting months of their time preparing grant applications for no reward, when they could be spending their time much more constructively in actually carrying out research. Particularly in scientific and arts disciplines, e.g., biology and chemistry, visual art, film studies, funding is required for consumables such as chemicals, film and recording equipment. If zero funding is received from the ARC and the research is not in a medical area, so that NHMRC funding isn’t a possibility, then experimental or artistic research no longer becomes possible. In the case of many university academics’ contracts, which stipulate that 40% of their time is meant to be devoted to research, this would mean that they’re no longer able to meet the terms of their employment. In addition, if zero funding is awarded, then any academic who does experimental or artistic research would no longer be able to take on honours, masters or PhD students, because they wouldn’t have the funds to support their project. For fields in which intense face-to-face collaboration of international experts is required, lack of grant funding effectively blocks that research from happening. Therefore, the low level of grant success means that many Australian students are unable to complete their studies and researchers without access to other sources of funding face significant obstacles.
Most university funding is currently tied to teaching and in many universities some of this money is used to subsidise research and scholarly work of academics. This impacts on teaching quality. To address this, an additional component of university funding should be provided in recognition that on-going scholarly and research work is an essential component of the academic role. Often many large project applications emerge from several years of pilot studies, small collaborations, interactions at conferences and other scholarly activities. If some research funding was provided to universities specifically to support this level of scholarly work, it would enable researchers working on nascent ideas in a range of disciplines, and the more than 80% of unsuccessful applicants for ARC and NHMRC and other grants, to continue to develop their ideas while they seek funding. However, the internal process by which universities allocate this funding would need to be strictly transparent, criteria driven and carefully monitored by a representative professorial committee.
Alternatively, some mechanism for awarding small grants of, for example, up to $50,000 would need to be introduced. This would at least provide enough support that some research could continue, even if a member of academic staff were not able to win a Discovery grant. Such small grants were a feature of the ARC system in the past, and would be a valuable contribution to improve the quality of scientific outputs. Another mechanism of providing necessary additional support would be to introduce an ARC-administered near-miss scheme. A number of universities have in the past run near-miss schemes in which grant applications which were not approved for funding by the ARC because of the ARC’s limited budget, but were still deemed fundable, received funding for one year, so that valuable projects could still proceed to some degree, even if not to the extent possible if they were fully funded. A potential advantage of such a scheme over a separated small grants scheme would be that no separate evaluation of grant applications would be required. For equity across all Australian universities, it would be better if such as scheme was administered by the ARC, rather than being left to individual universities to implement.
The ARC Research Networks scheme also previously provided a mechanism for providing small amounts of funding to foster innovation and the development of new projects. Some networks (the Fluorescence Applications in Biotechnology and the Life Sciences, FABLS, network is a good example) allowed applications direct to the network executive for small amounts of funding for the initiation of new projects. These applications had a very high success rate and allowed projects to be developed to a stage where application for a large grant such as ARC Discovery became feasible. AAvHF and AAUP encourage the restoration of the ARC Research Networks scheme.
ARC grant applications are large undertakings and cost significant amounts of time and energy. For the majority of applicants who are not close to being funded, a full application should not be needed. We recommend that the ARC consider a two-stage process, with the first stage a much shorter application that costs little time and focuses on the quality of the investigative team. Applicants that make it through this first stage, by placing in the top 30% of applications for example, are invited to submit full applications. This structure has two benefits: (1) full applications are required from only 30% of applicants, saving significant time and energy; (2) the focus in the first round is on the quality of the researcher and their team. The second point is a cornerstone of the Humboldt Foundation’s funding philosophy, focusing on the development of the long-term potential of researchers internationally, and not only on short-term projects.
It would also be useful if applications would be possible all year round. One year is too long for “hot” research areas.
We also encourage the Review Board to consider the effectiveness of the DECRA, Future, and Laureate Fellowships. Instead of establishing fellowships, this money could be added to the Discovery scheme. Postdoctoral fellowships can already be created by the chief investigators of an awarded Discovery project. Such fellowships allow young scientists to work within an established research group and gain mentoring from more senior investigators. Furthermore, the young scientists’ careers would benefit by networking with the contacts of their more senior collaborators. We fear that many young scientists who are awarded DECRAs may end up leaving academia at the completion of their fellowship, because they’ve effectively been isolated from more established research groups and haven’t had sufficient time to develop their own networks. An alternative way to support early career researchers could be to allocate a certain percentage of Discovery funds to early career researchers, and to review the applications of early career researchers separately from other applications. The same applies to Future Fellowships. The ability to network and establish collaborations is crucial to a successful scientific career. This is borne out by the worldwide success of the fellowships of the Alexander von Humboldt Foundation, where fellowships are awarded to individuals, but always to work together with a host professor in Germany. The relationships which are established in this way are encouraged by the Foundation, who provide continued support of fellows far beyond the term of their fellowship. The benefits of this model are validated by the large number of Humboldtians who have won Nobel Prizes in their fields.
Laureate fellowships are generally awarded to researchers who already have extensive resources for their research. We believe that providing funds for a broader base of research and the development of a multitude of worthwhile ideas should be preferred over the concentration of funds in a relatively small number of researchers. This approach starves many good researchers of funds and leads to many looking to other countries to pursue their ideas.

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?

No. It’s just a “navel gazing” exercise that is at risk of being abused by individual universities to paint themselves in the best light. Any ERA system would need to be carried out objectively, not by the people who are doing the research, because this makes it open to abuse. However, since the researchers are the only people capable of judging research excellence, such assessment exercises should be abolished. It is just of waste of researchers’ time and consumes university resources which could be better used to actually do research.

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?

The demonstration of the on-going value and excellence of Australian research is best left in the hands of the individual universities, who are better placed to communicate directly with the relevant researchers. The Government could facilitate this by providing funds to the universities for the purpose of public outreach and international publicity.

Q10. Having regard to the Review’s Terms of Reference, the ARC Act itself, the function, structure and operation of the ARC, and the current and potential role of the ARC in fostering excellent Australian research of global significance, do you have any other comments or suggestions?

To obtain the greatest global significance of Australian research, the Government should not attempt to prescribe the direction of research. The greatest global impact and long-term benefits of Australian research will be achieved by supporting curiosity-driven fundamental research. In chemistry, Australia has only had a single Nobel Prize Winner, Sir John Cornforth, a graduate of the University of Sydney, who in 1975 won the prize for “work on the stereochemistry of enzyme-catalysed reactions”, although it is worth noting that he carried out all the work for which he won the prize in the UK, not Australia. In their press release announcing the prize, the Nobel Foundation stated that “This subject is difficult to explain to the layman.” The understanding of the mechanisms of enzyme-catalysed reactions, however, has been crucial to the development of modern drugs, for example, the statins, which inhibit the enzyme HMG-CoA reductase in the cholesterol biosynthetic pathway, are the most-commonly-used drugs for the prevention of cardiovascular disease. In economic terms, the statins generate multi-billion-dollar sales each year for the pharmaceutical industry. By politically interfering in the grant approval process and attempting to direct research towards short-term gain, perhaps for political purposes, it’s hard to judge what scientific advances and economic benefits might be lost to Australia.
We have one additional comment that is specific to the AAvHF. In 2004, the AAvHF was successful in establishing an MoU with the Australian Research Council to support a Baron Ferdinand von Mueller Fellowship. The arrangement was intended to provide support for German researchers to come to Australia in a way that reciprocated, in a small way, the enormous support provided by the German von Humboldt Foundation. The Fellowship operated as part of the ARC’s Linkage programme, but unfortunately ceased in 2009. The AAvHF would urge that consideration be given to re-establishing some similar arrangement as part of the ARC’s future programme.

Submission received

13 December 2022

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