Self-Archiving Mandates

The Humanities and Social Sciences branch of France's Agence Nationale de la recherche has just announced its Green OA self-archiving mandate -- France's first funder mandate (France' second mandate overall, and the world's 50th). See ROARMAP

Note that the situation in France with central repositories is very different from the case of NIH's PMC repository: France's HAL is a national central repository where (in principle) (1) all French research output --from every field, and every institution-- can be deposited and (again, in principle) (2) every French institution (or department or funder) can have its own interface and "look" in HAL, a "virtual" Institutional Repository (IR), saving it the necessity of creating an IR of its own if it does not feel it needs to.

The crucial underlying question -- and several OA advocates in France are raising the question, notably, Hélène Bosc, in a forthcoming article (meanwhile, see this) -- is whether the probability of adopting institutional OA mandates in France is increased or decreased by the HAL option: Are universities more inclined to adopt a window on HAL, and to mandate central deposit of all their institutional research output, or would they be more inclined to mandate deposit in their own autonomous university IRs, which they manage and control?

Again, the SWORD protocol for automatic import and export between IRs and CRs is pertinent, because then it doesn't matter which way institutions prefer to do it.

---

Agence Nationale de la recherche (ANR) (Humanities and Social Sciences Branch) (FRANCE*
funder-mandate)

Institution's/Department's OA Eprint Archives

Institution's/Department's OA Self-Archiving Policy

[Paraphrase by T. Chanier]

"The Humanities and Social Sciences branch of the French National Research Agency (ANR) mandates [requires] researchers involved in projects that it funds to deposit their scienfically validated (refereed postprint) publications in the HAL-SHS open archive, without any delay.

"HAL is a nation-wide open archive supported by all public French Research Insitutions. Hal-SHS is a sub-part dedicated to Humanities and Social Sciences

"In November 2007, the general ANR agency had merely invited its researchers to deposit in HAL

"This time (July 2008), the ANR's SHS branch mandates that its researchers deposit (and requests project leaders to confirm that the deposit is done by everyone)."

** text extracted (July 2008) from the ANR SHS text **

"Par un communiqué :en date du 14 novembre 2007, l’ANR incite les chercheurs, porteurs ou partenaires de projets financés par elle, à intégrer leurs publications dans le système d’archives ouvertes HAL avec lequel elle collabore.

"Le Département SHS de l’ANR et la cellule-support de l’ENS LSH souhaitent donner un écho particulier à cette directive qu’ils jugent essentielle pour une visibilité accrue de la recherche française en SHS.

"La communauté des porteurs et partenaires de projets ANR en SHS doit ainsi se mobiliser autour d’un objectif commun qui est celui d’un dépôt systématique de leurs productions scientifiques dans HAL- SHS, interface SHS de l’archive HAL.

"Il est demandé aux porteurs et responsables de projets ANR de s’assurer, au sein de leurs équipes (chercheurs, universitaires, post-doc, doctorants, qu’ils soient français et étrangers), de l’intégration dans HAL de l’ensemble des publications (articles, communications, contributions à ouvrages collectifs, ou autres productions éligibles) réalisées dans le cadre du projet, et ce, au fur et à mesure de leur élaboration (par exemple dès la soumission à une revue puis à nouveau au moment de la publication effective)."

Registered by: Thierry Chanier (Professor, leader of ANR SHS-funded project) on 29 Jul 2008

      [see also PART I and PART 0]

SUMMARY: The concept underlying the OAI metadata harvesting protocol is that local, distributed, content-provider sites each provide their own content and global service-provider sites harvest that content and provide global services over it, such as indexing, search, and other added values. (This is not a symmetric process. It does not make sense to think of the individual content-providers as "harvesting" their own content (back) from global service-providers.)
    The question is accordingly whether OA deposit mandates should be (1) convergent, with both institutional and funder mandates requiring deposit in the author's own OA Institutional Repository (IR), for harvesting by global overlay OA services and collections (such as PubMed Central, PMC) or (2) divergent, requiring authors to deposit all over the map, locally or distally, possibly multiple times, depending on field and funding. It seems obvious that coordinated, convergent IR deposit mandates from both institutions and funders will bring universal OA far more surely and swiftly than needless and counterproductive divergence.
    In the interests of a swift, seamless, systematic, global transition to universal OA, NIH should accordingly make one tiny change (entailing no loss at all in content or functionality) in its otherwise invaluable, historic, and much-imitated mandate: NIH should mandate IR deposit and harvest to PMC from there.
    The spirit of the Congressional directive that publicly funded research should be made publicly accessible online, free for all, is fully met once everyone, webwide, can click on the link to an item whose metadata they have found in PMC, and the article instantly appears, just as if they had retrieved it via Google, regardless of whether the item's URL happens to be in an IR or in PMC itself.
    A possible reason the NIH mandate took the divergent form it did may have been a conflation of access archiving with preservation archiving: But the version that NIH has (rightly) stipulated for OA deposit (each "investigator's... electronic version of their final, peer-reviewed manuscripts upon acceptance for publication") is not even the draft that is in the real need of preservation; it is just a supplementary copy, provided for access purposes: The definitive version, the one that really stands in need of preservation, is not this author-copy but the publisher's official proprietary version of record.
    For preservation, the definitive document needs to be deposited in an archival depository (preferably several, for safe-keeping, updating and migration as technology evolves), not an OA collection like PMC. But that essential archival deposit/preservation function has absolutely nothing to do with either the author or with OA.

---

Peter Suber: "At the moment, I see two conflicting APA statements and no evidence that either statement [2002 or 2008] took the other into account. So I'm still waiting for a definitive clarification from the APA. But as I say, if the APA reaffirms the 2002 policy to allow no-fee, no-embargo self-archiving to IRs, then I will applaud it."

That will shortly sort itself out.

---

[See APA update, which appeared after this posting. Peter has since responded to that update too. The only point to add is that Stuart Shieber's concern about a remaining ambiguity in yet another APA document will no doubt likewise be resolved in the same way. (Stuart was the architect of Harvard FAS's institutional OA mandate and has since been appointed director of Harvard's newly formed Office for Scholarly Communication.)]

---

It seems obvious to me that the only coherent resolution is that APA's 2002 Green OA policy takes precedence over the contradictory passages in APA's 2008 PMC addendum. It would be arbitrary bordering on dementia to declare that:

"Our policy is that any APA author may self-archive their own refereed final draft in their own IR for free as long they are not mandated to do so by NIH; but if they are mandated to do so by NIH, then they must pay us $2500 to do it!"

I predict that the proposed APA policy will first be:

"All we meant was that, as before, any APA author may self-archive their own refereed final draft in their own IR for free, but depositing APA's proprietary published version in PMC will cost $2500."

And then they will back down from the surcharge altogether. (I do have a bit of a track-record for correctly second-guessing APA policy!)

Peter Suber: "However, if the APA retains the "deposit fee" for NIH-funded authors, then I will continue to criticize it. The APA will still be charging for green OA, which is utterly unnecessary."

Do continue to criticize it, Peter, but please make sure the criticism is on target: As long as APA authors are free to provide green OA by depositing in their own IRs, APA can definitely not be said to be "charging for green OA" if APA charges authors for depositing in PMC (any more than I can be said to be charging for water if I say "water is free but bring your own container" and you insist on water in a container).

The $2500 fee is indeed absurd, but that absurdity (and a many other counterproductive consquences) would be completely remedied by NIH's simply dropping its supererogatory requirement to deposit directly in PMC, and harvesting the metadata from the IRs instead. A central collection like PMC is just that: a collection. It is sufficient for such collections to harvest the metadata (as Google does) and to link to the full-text where it is actually deposited, i.e., the IR of the institution it came from.

Peter Suber: "[APA] will still fail to deliver immediate OA, or OA to the published edition, which fee-based [Gold or optional-Gold] OA journals always deliver in exchange for their fees."

You mean the publisher's proprietary version? But even the NIH mandate is only requiring deposit of the author's final refereed draft, not the publisher's proprietary version:

The NIH Public Access Policy implements Division G, Title II, Section 218 of PL 110-161 (Consolidated Appropriations Act,2008).  The law states:

The Director of the National Institutes of Health shall require that all investigators funded by the NIH submit or have submitted for them to the National Library of Medicine’s PubMed Central an electronic version of their final, peer-reviewed manuscripts upon acceptance for publication, to be made publicly available no later than 12 months after the official date of publication: Provided, That the NIH shall implement the public access policy in a manner consistent with copyright law.

I also think you may be equating the $2500 fee with a (hybrid) optional-Gold OA fee (from a non-Green publisher such as ACS). But it is not that. APA's is a PMC deposit fee, from a Green publisher. (There is no relevant category for a requirement to deposit in a 3rd-party CR, because it is arbitrary to have to do so, and has nothing to do with OA itself, which APA authors can already provide via Green OA in their own IRs.)

Moreover, to heap absurdity upon absurdity, we both know, Peter, that (1) not only does it not matter one bit, for OA accessibility to one and all, webwide, whether a document's locus is an IR or a CR, but (2) if and when all of OA's target content is made OA, one way or the other, then the distinction between 1st-party (author-institution), 2nd-party (publisher) and 3rd party (PMC, UKPMC, EuroPMC, Google, or any other CR) archiving becomes irrelevant, the game is over, universal OA has at last arrived, and all these trivial locus and party details as well as this absurd talk of deposit surcharges becomes moot.

The problem is with first reaching that universal OA, which is already long, long overdue (after many, many false starts, including a prior one by NIH itself, 3 years ago, which elicited a compliance rate below 4%, less than a third of the global average for spontaneous -- i.e., unmandated -- self-archiving.)

And coordinated, convergent IR deposit mandates -- funder mandates complementing institutional mandates -- will get us there far more surely and swiftly than the needless and counterproductive divergence we have imposed on ourselves by not thinking the PMC locus stipulation through in advance (or fixing it as it becomes more and more apparent that it creates unanticipated and unnecessary problems).

Peter Suber: "If the APA reaffirms its 2002 green policy, then NIH-funded authors could bypass the deposit fee when self-archiving to their IRs. But they couldn't bypass the fee when self-archiving to PMC, and they are bound by the NIH policy to deposit in PMC (or have their journal do so for them)."

Correct, but isn't this reasoning a bit circular, if not fatalistic? Which one is cluttering the path to universal OA (now that we have the invaluable NIH mandate)? APA, which blesses OA self-archiving in the author's own OA IR, for free, or NIH, which (unnecessarily) insists on mandating more than "merely" OA?

Would it not be better for NIH to think it through, and then -- patiently, in the interests of a swift, seamless, systematic, global progression to universal OA -- make in its otherwise invaluable, historic, and much-imitated mandate the one tiny change that (with no loss at all in content or functionality) will create the optimal conditions for a full-scale transition to universal OA, rather than only (the NIH/PMC) part of it?

Let NIH mandate IR deposit and harvest from there.

Peter Suber: "Stevan hopes that policies like the APA's will pressure the NIH to drop this requirement and allow deposits in an IR to suffice. But even if that ought to happen, it won't happen soon and very likely won't happen at all. One reason is simply that the requirement to deposit in PMC was mandated by Congress. The NIH undoubtedly supports the Congressional directive, but it's not an in-house policy decision that the agency is free to reverse at will."

Deposits in IRs can be harvested into PMC. The issue here is merely the locus of the point of direct deposit.

Does anyone imagine that the spirit of the Congressional directive -- to the effect that publicly funded research should be made publicly accessible online, free for all -- would not be fully met once everyone, webwide, can click on the link to an item whose metadata they have retrieved from PMC, and the article instantly appears, just as if they had retrieved it via Google, but the item's URL happens to be in an IR rather than in PMC!

Or are OA self-archiving issues being conflated with preservation archiving issues here (yet again, as so often happens, and inevitably at OA's expense)? If so, the preservation of what: "final, peer-reviewed manuscripts"?

---

Access Archiving or Preservation Archiving? One discerns the dead hand of digital preservationists here, pushing their worthy but distinct agenda, oblivious to the fact that the content they seek to preserve is mostly not even OA yet, and that the version that NIH has (rightly) stipulated for OA deposit (each "investigator's... electronic version of their final, peer-reviewed manuscripts upon acceptance for publication") is not even the draft that is in the real need of preservation, but just a supplementary copy, provided for access purposes: The definitive version, the one that really stands in need of preservation, is not this author-copy but the original itself: the publisher's official proprietary version of record. But is it not crucial, here especially, to raise the fundamental question: Is the NIH mandate an access mandate or is it a preservation mandate? For preservation, one needs to deposit a (digital and analog) original in an archival depository (preferably several, for safe-keeping, updating and migration as technology evolves), not an OA collection like PMC. That essential archival deposit/preservation function has absolutely nothing to do with either the author or with OA, and APA would certainly have no problem with a digital deposit requirement like that...

---

Peter Suber: "But should Congress and the NIH prefer PMCs to IRs? Maybe, maybe not. I see good arguments on both sides."

For OA functionality, the locus of deposit makes zero difference. For preservation, OA is beside the point and unnecessary. But for OA content-provision itself -- and not just for NIH-funded content, but for all of OA's target content, across all disciplines, institutions and nations -- locus of deposit matters enormously. There's no functionality without content. And I know of no good argument at all in favor of institution-external direct deposit, insofar as OA content-provision is concerned; only a lot of good arguments against it.

Peter Suber: "But they are irrelevant here because (1) the APA deposit fee would still [be] unnecessary"

Why is it just APA's absurd $2500 fee for PMC deposit that is singled out as being unnecessary (given that the APA is Green on free OA IR deposit): Is NIH's gratuitous stipulation of PMC deposit not likewise unnecessary (for OA)?

(This question is all the more germane given that the global transition to universal OA stands to benefit a lot more from NIH's dropping its gratuitous (and alas much imitated) deposit-locus stipulation than from APA's dropping its absurd bid for a PMC deposit fee.)

Peter Suber: "(2) there's no evidence that the APA was motivated, as Stevan is, to protest the preference for PMC --as opposed to (say) mandatory OA."

But I never said the APA was motivated to protest the preference for PMC! That really would be absurd. I am certain that APA (and every other non-OA publisher) is none too thrilled about either author self-archiving or mandatory OA, anywhere, in any form!

But APA nevertheless did the responsible thing, and bit the bullet on formally endorsing institutional self-archiving. There's no (OA) reason they should have to bite it on institution-external, 3rd-party archiving in PMC too (even though the distinction will eventually be mooted by universal OA) -- though the response of the OA community, if directed, myopically, at APA alone, and not NIH, will no doubt see to it that they will.

Frankly, I think APA just saw an opportunity to try to make a buck, and maybe also to put the brakes on an overall process that they saw as threatening to their current revenue streams. Can't blame them for thinking that; it may turn out to be true. But as long as they're Green, they're "gold," as far as OA is concerned (though, to avoid conflicting terminology, let us just say they are "on the side of the angels").

Peter Suber: "(For the record, my position is close to Stevan's: institutional and disciplinary repositories should harvest from one another; that would greatly lower the stakes in the question where an OA mandate should require initial deposit; if we got that far, I'd be happy to see a policy require deposit in IRs.)"

I'm afraid I can't quite follow Peter's reasoning here:

The issue is whether deposit mandates should be convergent -- requiring all authors to deposit in their own OA IRs, for harvesting by global overlay OA services and collections therefrom -- or divergent, requiring authors to deposit all over the map, possibly multiply, depending on field and funding, possibly necessitating "reverse-harvesting," with each institution's software having to trawl the web, looking to retrieve its own institutional output, alas deposited institution-externally.

(That last is not really "harvesting" at all; rather, it involves a functional misunderstanding of the very concept of harvesting: The OAI concept is that there are local content-providers and global service-providers. Content-providers are local and distributed, each providing its own content -- in this case, institutional IRs. Then there are service-providers, who harvest that content [or just the content's metadata and URL] from the distributed, interoperable content-providers, and provide global services on it, such as indexing, search, and other added values. This is not a symmetric process. It does not make sense to think of the content-providers as "harvesting" their own content (back) from the service-providers! Another way to put this is that -- although it was not evident at the time -- OAI-interoperability really meant the end of the need for "central repositories" (CRs) for direct deposit. Now there would just be central collections (services), harvested from distributed local content-providers. No need to deposit distally. And certainly no sense in depositing distally only to "harvest" it back home again! Institutional content-provision begins and ends with the institution's own local IR; the rest is just global, webwide harvesting and service-provision.)

Peter Suber: "Stevan does call the deposit fee absurd. So we agree on that as well. But he adds that the NIH preference for PMC over IRs "reduced us to this absurdity". I'm afraid that's absurd too. If the NIH preference for PMC somehow compelled publishers to respond with deposit fees, then we'd see many of them. But in fact we see almost none."

(1) Of course APA's $2500 deposit fee is absurd. But -- given that APA is Green on OA, and given the many reasons why convergent IR deposit, mandated by institutions as well as funders, not only makes more sense but is far more likely to scale up, coherently and systematically, to universal OA across disciplines, institutions and nations than divergent willy-nilly deposit of institutional content here, there and everywhere -- I welcome this absurd outcome (the $2500 PMC deposit fee) and hope the reductio ad absurdum it reveals helps pinpoint (and fix) the real source of the absurdity, which is not APA's wistful surcharge, but NIH's needless insistence on direct deposit institution-externally in PMC.

(2) I have no idea whether the OA community's hew and cry about the $2500 APA surcharge for PMC deposit will be targeted exclusively at APA (and any other publishers that get the same bright idea), forcing them to withdraw it, while leaving the dysfunctional NIH constraint on locus of deposit in place.

(3) I hope, instead, that the OA community will have the insight to target NIH's constraint on deposit locus as well, so as to persuade NIH to optimize its widely-imitated policy in the interests of its broader implications for the prospects of global OA -- one small step for NIH but a giant leap for mankind -- by fixing the one small bug in an otherwise brilliant policy.

Peter Suber: "Even if the NIH preference for PMC were a choice the agency could reverse at will, the APA deposit fee is another choice, not necessitated by the NIH policy and not justified by it."

Where there's a will, there's a way, and here it's an extremely simple way, a mere implementational detail: Instead of depositing directly in PMC, authors deposit in their IRs and send PMC the URL. If NIH adopted that, the APA's PMC deposit surcharge bid would instantly become moot.

If the furor evoked by the APA $2500 surcharge proved to be the factor that managed to inspire NIH to take the rational step that rational argument alone has so far been powerless to inspire, then that will be a second (unintentional) green feather in APA's cap, and another of the ironies and absurdities of our long, somnambulistic trek toward the optimal and inevitable outcome for scientific and scholarly research.

A Simple Way to Optimize the NIH Public Access Policy (Oct 2004)

Please Don't Copy-Cat Clone NIH-12 Non-OA Policy! (Jan 2005)

National Institutes of Health: Report on the NIH Public Access Policy. In: Department of Health and Human Services (Jan 2006, reporting 3.8% compliance rate after 8 months for its first, non-mandatory deposit policy)

Central versus institutional self-archiving (Sep 2006)

Optimizing OA Self-Archiving Mandates: What? Where? When? Why? How? (Sep 2006)

THE FEEDER AND THE DRIVER: Deposit Institutionally, Harvest Centrally (Jan 2008)

Optimize the NIH Mandate Now: Deposit Institutionally, Harvest Centrally (Jan 2008)

Yet Another Reason for Institutional OA Mandates: To Reinforce and Monitor Compliance With Funder OA Mandates (Feb 2008)

How To Integrate University and Funder Open Access Mandates (Mar 2008)

One Small Step for NIH, One Giant Leap for Mankind (Mar 2008)

NIH Invites Recommendations on How to Implement and Monitor Compliance with Its OA Self-Archiving Mandate (Apr 2008)

Institutional Repositories vs Subject/Central Repositories (Jun 2008)

Stevan Harnad
American Scientist Open Access Forum

With today's Green OA Self-Archiving Mandate announcement from Canada's National Research Council, that makes 49 mandates adopted worldwide, and 12 more proposed. See ROARMAP (Registry of Open Access Repository Material Archiving Policies). (Thanks to Peter Suber and Richard Ackerman for the notice.)

Let us hope that NRC will sensibly require that authors deposit directly in their own Institutional Repositories, from which NRC's planned central repository, NPArC, can then harvest the deposit, rather than needlessly (and counterproductively) requiring -- as NIH currently does -- direct institution-external deposit. The optimal mandate is of course ID/OA (immediate deposit/optional access) rather than delayed or optional deposit.

A Simple Way to Optimize the NIH Public Access Policy (Oct 2004)

Central versus institutional self-archiving (Sep 2006)

Optimizing OA Self-Archiving Mandates: What? Where? When? Why? How? (Sep 2006)

THE FEEDER AND THE DRIVER: Deposit Institutionally, Harvest Centrally (Jan 2008)

Optimize the NIH Mandate Now: Deposit Institutionally, Harvest Centrally (Jan 2008)

How To Integrate University and Funder Open Access Mandates (Mar 2008)

One Small Step for NIH, One Giant Leap for Mankind

NIH Invites Recommendations on How to Implement and Monitor Compliance with Its OA Self-Archiving Mandate (Apr 2008)

Institutional Repositories vs Subject/Central Repositories (Jun 2008)

Stevan Harnad
American Scientist Open Access Forum

In Open Access News, my comrade-at-arms, Peter Suber commented on my essay "In Defense of the American Psychological Association's Green OA Policy," which defended the APA from criticism for levying a $2500 fee on authors for compliance with the NIH mandate to deposit in PubMed Central (PMC). I had said the problem was with NIH's stipulation that the deposit had to be in PMC rather than in the author's own Institutional Repository (IR): Though initially opposed in 1996, APA has since 2002 been solidly among the majority of publishers that are Green on OA self-archiving, meaning they explicitly endorse deposit in the author's own institutional IR immediately upon acceptance for publication, with no fee (exactly as all publishers ought to be doing). Moreover, APA has now re-confirmed (see below) that it has no intention of back-sliding on that 6-year-old green policy (as Nature Publishing Group did 3 years ago, immediately upon the impending announcement of the NIH policy).

Peter Suber: "Stevan is mixing up unrelated issues.  The APA "deposit fee" had nothing to do with the distinction between disciplinary repositories (like PMC) and institutional repositories.  If the NIH mandated deposit in IRs instead of PMC, then the APA would demand a $2,500 fee for deposit in IRs, and the fee would be equally noxious and indefensible.  Even if the NIH's preference for PMC were as foolish as Stevan says it is (a criticism I do not share), it would not justify the APA fee."

Peter seems to be replying with a hypothetical conditional, regarding what the APA would have done. But the APA has already been formally endorsing immediate Open Access self-archiving in the author's own IR for six years now. Moreover (see below), the publisher, Gary Vandenbos, has confirmed that APA has not changed that policy, nor are there plans to change it.

What needs to be changed is just one small implementational detail of NIH's Public Access Policy: the requirement to deposit directly in PMC. The locus of deposit should be the author's own IR. PMC can harvest the metadata and link to the full-text in the IR. This will cost NIH authors nothing. APA itself has no plans to repeal its commendable 6-year-old Green OA self-archiving policy. (It would certainly have put APA in a very bad light if, having given its authors the green light to self-archive in their own IRs, APA then decided to slap a $2500 traffic ticket on them for going ahead and doing so!)

---

Date: 15 Jul 2008 23:28:40 -0400
To: Gary Vandenbos (Publisher, American Psychological Association Journals)
Cc: Alan Kazdin (President, American Psychological Association)
Subject: In Defense of the American Psychological Association's Green OA Policy

Hi Gary (and Alan),

As long as APA does not dream of back-sliding on its 6-year green OA policy on institutional self-archiving, you can count on my firm support in the forthcoming onslaught from OA advocates worldwide, and you will weather the storm and come out looking good.

But please do reply to reassure me that back-sliding is not an option!

Best wishes, Stevan

Date: 16 Jul 2008 2:05:49 AM EDT (CA),
From: Gary VandenBos

Steven, I expect no change in the existing policy. Have not ever heard anyone suggest it.
Gary

Date: 16 Jul 2008 13:22:08 +0100 (BST)
To: Gary VandenBos

Splendid. Expect a spirited (and successful) defense that will leave APA looking benign and responsible (as it indeed is). The problem is in the well-meaning juggernauts (in this case, NIH OA policy-makers) that simply do not think things through.

Best wishes, Stevan

---

Peter Suber: "Stevan points to a 2002 APA policy statement, still online, which allows self-archiving in IRs.  But he doesn't point out that the APA's newer policy statement describing the "deposit fee" effectively negates the older green policy, at least for NIH-funded authors.  The new policy prohibits NIH-funded authors from depositing their postprints in any OA repository, disciplinary or institutional."

The 2002 APA policy statement is not only still online and still in effect, but we have the publisher's word that there is to be no change in that policy. The proposed fee only pertains to deposit in PMC.

APA Policy on Posting Articles on the Internet ...Update effective June 1, 2002...Authors of articles published in APA journals may post a copy of the final manuscript... on their Web site or their employer's server after it is accepted for publication... APA does not permit archiving with any other non-APA repositories...

Peter Suber: "The title of Stevan's post suggests that he's defending the APA's 2002 self-archiving policy.  I join him in that.  But the body of his post attempts to defend the 2008 deposit fee as well:  "Although it looks bad on the face of it...things are not always as they seem."  Not always, but this time."

Not this time, and never for a publisher that is Green on OA. Once a publisher is Green on OA, there is nothing more that can or should be demanded of them, by the research community. The ball is now in the research community's court. It is up to research institutions and research funders to design sensible policies that will ensure that the researchers they employ and fund actually provide Green OA for their joint research output.

Not all research is funded (and certainly not all by NIH), but (virtually) all researchers have institutions. And all institutions are just a piece of free software, some server-space, and a few hours of sysad set-up and maintenance time away from having an IR, if they do not already have one.

The sensible OA mandate, from both institutions and funders (like NIH) is to require deposit in the researcher's own IR, immediately upon acceptance for publication. If there is an embargo, access to the deposit can be set as Closed Access during the embargo. The IR's "email eprint request" button will provide almost-immediate, almost-OA for all user needs during any embargo.

If funders or others want to create institution-external, central collections of already-OA content, based on subject matter, funding source, nationality, or whatever, then they can harvest the metadata and link to the full-text in the IR in which it was deposited. But there is certainly no reason to insist that it be deposited directly in their collections. Google, for example, quietly harvests everything: no need to deposit things directly in Google or Google Scholar. And no charge.

Peter Suber: "Both arguments are moot for a while, now that the APA has taken down the new policy statement for "re-examination".  (See the 7/16/08 update to my blog post on the policy.)"

I don't doubt that well-meaning OA supporters who have not thought it through are now railing at APA instead of resolutely requesting that NIH make the minor modification in its otherwise admirable, timely, and welcome policy that would put an end to this nonsense and let researchers get on with the urgent task of providing OA by depositing their own research in their own OA IRs, free for all, webwide.

Epilogue and Homily:

The influence of the pro-OA lobby has become gratifyingly strong and swift:

A new policy is in the works. In an e-mail from Alan Kazdin, APA president:

“A new document deposit policy of the American Psychological Association (APA) requiring a publication fee to deposit manuscripts in PubMed Central based on research funded by the National Institutes of Health (NIH) is currently being re-examined and will not be implemented at this time. This policy had recently been announced on APA’s Web site. APA will soon be releasing more detailed information about the complex issues involved in the implementation of the new NIH Public Access Policy.

APA will continue to deposit NIH-funded manuscripts on behalf of authors in compliance with the NIH Public Access Policy.

Gary R. VandenBos, PhD
APA Publisher”

but it would be useful if the heads of OA advocates worldwide were focused, commensurately strongly, on using their growing influence to promote what will actually generate universal OA, swiftly and surely, rather than dissipating it on the short-sighted distractions -- such as Gold Fever, Preservation Panic, Copyright Compulsion, and, here, Supererogatory Centralism -- which are only delaying rather than facilitating OA:

(For the record, and the too literal-minded: Of course a $2500 fee for depositing in PMS is absurd, but what reduced us to this absurdity was needlessly mandating direct deposit in PMS in the first place. Time to remedy the absurdity and let researchers' fingers do the walking so we can all reach 100% OA at long last.)

A Simple Way to Optimize the NIH Public Access Policy (Oct 2004)

Please Don't Copy-Cat Clone NIH-12 Non-OA Policy! (Jan 2005)

National Institutes of Health: Report on the NIH Public Access Policy. In: Department of Health and Human Services (Jan 2006, reporting 3.8% compliance rate after 8 months for its first, non-mandatory deposit policy)

Central versus institutional self-archiving (Sep 2006)

Optimizing OA Self-Archiving Mandates: What? Where? When? Why? How? (Sep 2006)

THE FEEDER AND THE DRIVER: Deposit Institutionally, Harvest Centrally (Jan 2008)

Optimize the NIH Mandate Now: Deposit Institutionally, Harvest Centrally (Jan 2008)

Yet Another Reason for Institutional OA Mandates: To Reinforce and Monitor Compliance With Funder OA Mandates (Feb 2008)

How To Integrate University and Funder Open Access Mandates (Mar 2008)

One Small Step for NIH, One Giant Leap for Mankind (Mar 2008)

NIH Invites Recommendations on How to Implement and Monitor Compliance with Its OA Self-Archiving Mandate (Apr 2008)

Institutional Repositories vs Subject/Central Repositories (Jun 2008)

Stevan Harnad
American Scientist Open Access Forum

---

SUMMARY: So the American Psychological Association (APA) is trying to charge $2500 per article to fulfill NIH's Green OA mandate by proxy-depositing in PubMed Central on the author's behalf? So maybe if NIH had sensibly mandated depositing in the author's own Institutional Repository (IR), this awkward problem wouldn't have come up? Like the majority of journals, APA journals -- unlike ACS journals -- are Green on authors self-archiving in their own IRs. There's still time to fix the NIH mandate so good sense can prevail...

---

Although it looks bad on the face of it -- the American Psychological Association (APA) charging the author's institution and/or research grant $2500, not even for Gold OA publishing, but just for depositing the author's refereed final draft in PubMed Central (PMC) on the author's behalf ("proxy self-archiving"), in order to fulfill the NIH mandate -- things are not always as they seem.

There is no culprit in this nonsense, but if I had to pinpoint its provenance, it would be the foolish form in which the NIH -- despite relentlessly repeated advice and reasons to the contrary -- insisted on drafting its policy:

To cut to the quick, there is no earthly reason NIH should insist on direct deposit in PMC. The mandate should be (and should all along have been) to deposit in the author's own Institutional Repository (IR). PMC can then harvest the metadata and link to the IR-deposited full-text itself from there.

Unlike the American Chemical Society journals (which have unswervingly opposed Green OA), the American Psychological Association journals (after initial opposition, and eventually the majority of other journals) -- for reasons they would have found it very hard to justify flouting -- have long given their green light to immediate deposit (no delay, no embargo, and of course no fee) in the author's own IR:

---

APA Policy on Posting Articles on the Internet

Update effective June 1, 2002

Authors of articles published in APA journals may post a copy of the final manuscript, as a word processing, PDF, or other type file, on their Web site or their employer's server after it is accepted for publication. The following conditions would prevail:

• The posted article must carry an APA copyright notice and include a link to the APA journal home page.
• Further, the posted article must include the following statement: "This article may not exactly replicate the final version published in the APA journal. It is not the copy of record."
• APA does not permit archiving with any other non-APA repositories.
• APA does not provide electronic copies of the APA published version for this purpose, and authors are not permitted to scan in the APA published version.

---

To repeat, a publisher that is Green on immediate OA self-archiving in the author's own IR is squarely on the side of the angels. (If that publisher seeks to profit from NIH's gratuitous insistence on institution-external deposit, by treating PMC as a 3rd-party free-loader or rival publisher, hence legally requiring permission or payment to re-publish, I would say that NIH drew that upon itself. As noted many times, that technicality does not work with an author's own institution.)

And it is remediable: Simply revise the NIH mandate to require institutional IR deposit of the accepted final draft, immediately upon acceptance (with a cap on the permissible embargo length, if any). That is the sensible policy -- and nature will take care of the rest, with universal OA just around the corner.

A Simple Way to Optimize the NIH Public Access Policy (Oct 2004)

Please Don't Copy-Cat Clone NIH-12 Non-OA Policy! (Jan 2005)

National Institutes of Health: Report on the NIH Public Access Policy. In: Department of Health and Human Services (Jan 2006, reporting 3.8% compliance rate after 8 months for its first, non-mandatory deposit policy)

Central versus institutional self-archiving (Sep 2006)

Optimizing OA Self-Archiving Mandates: What? Where? When? Why? How? (Sep 2006)

THE FEEDER AND THE DRIVER: Deposit Institutionally, Harvest Centrally (Jan 2008)

Optimize the NIH Mandate Now: Deposit Institutionally, Harvest Centrally (Jan 2008)

Yet Another Reason for Institutional OA Mandates: To Reinforce and Monitor Compliance With Funder OA Mandates (Feb 2008)

How To Integrate University and Funder Open Access Mandates (Mar 2008)

One Small Step for NIH, One Giant Leap for Mankind (Mar 2008)

NIH Invites Recommendations on How to Implement and Monitor Compliance with Its OA Self-Archiving Mandate (Apr 2008)

Institutional Repositories vs Subject/Central Repositories (Jun 2008)

Stevan Harnad
American Scientist Open Access Forum

NOTE: Since this posting, Peter Suber has informed me [and since then announced] that Nature had informed him that they were willing to do proxy deposit not just in Central Repositories like PubMed Central, but in Institutional Repositories too, immediately upon acceptance (if it can be done in batch -- and it can: see this link).
     If that is the case, then I withdraw all but one of my criticisms below, with apologies for having impugned Nature's motives. However, the one remaining criticism stands: Nature would do open access a lot more good by dropping its access embargo than by offering to save Nature authors a few minutes worth of keystrokes.
     There is still great and widespread confusion among still mostly passive authors about WHO should deposit WHAT, WHERE, WHEN, WHY and HOW. Publishers doing proxy deposits in diverse repositories at diverse times is not conducive to grasping the home truth that the most natural, reliable and direct way for all authors to self-archive all their articles, simply, systematically, and convergently, is to deposit their own articles in their own institutional repositories, immediately upon acceptance for publication (and leave any further collecting to automatic batch harvesting).
     We are talking about a few keystrokes. Any arbitrary scrambling or complexification of this simple home truth is simply compounding confusion and inaction. (Before you ask: There are also provisional DEPOTs for authors whose institution does not yet have its own repository.)

---

SUMMARY: Nature Publishing Group has offered its authors a (free) proxy archiving service that would:
     (1) help lock in embargoed deposit instead of immediate deposit
     (2) help lock in central deposit (which does not scale) instead of institutional deposit (which does).
     (3) help lock out IDOA/DDR mandates and the embargo tide-over Button (again, to Nature's advantage, not OA's)
     (4) help keep deposit in publisher hands instead of author/institution hands, encouraging authors to remain passive instead of proactive about OA
     (5) give the misleading impression that Nature (and other publishers that make such offers) are acting in OA's interests rather than their own.

If Nature really wants to help OA, then dropping its access embargo would be a lot more helpful than saving authors from having to do a few keystrokes.

---

Nature has circulated the following Press Release:

NATURE PUBLISHING GROUP TO ARCHIVE ON BEHALF OF AUTHORS

Nature Publishing Group (NPG) is pleased to announce the initiation of a free service, launching in 2008, to help authors fulfill funder and institutional mandates.

NPG has encouraged self-archiving, including in PubMed Central, since 2005.

No, as of 2003, Nature had given its green light to immediate author self-archiving of the author's final refereed draft, but in January 2005 Nature abruptly withdrew its green light and instead imposed a 6-month embargo on self-archiving in anticipation of NIH's announcement in February 2005 that it would allow an embargo of 6-12 months on its OA self-archiving recommendation. The NIH recommendation became a mandate 3 years later, but Nature continues to impose a 6-month embargo. I would not call that "encouraging self-archiving." I would call that Nature trying to make the best of what it considers a bad but now inescapable bargain.

Later in 2008, NPG will begin depositing authors' accepted manuscripts with PubMed Central (PMC) and UK PubMed Central (UKPMC), meeting the requirements for authors funded by the Howard Hughes Medical Institute (HHMI), the National Institutes of Health (NIH), The Wellcome Trust, the Medical Research Council and a number of other major funders in the US, the UK and Canada who mandate deposition in either PMC or UKPMC. NPG hopes to extend the service to other archives and repositories in future.

In other words, now that there is no choice but to comply with these biomedical funder mandates (all clones of one another, and all pertaining only to biomedical research, all stipulating PubMed Central as the direct locus of the deposit and all allowing an access embargo of 6-12 months), Nature is trying to retain maximal control over the remaining degrees of freedom, by "relieving" authors of the burden of doing the deposit (i.e., taking deposit out of the author's hands), by ensuring that the deposit does not occur before the embargo occurs, and by ensuring that the locus of deposit is PubMed Central rather than the author's Institutional Repository (IR) [this last plaint is mooted if Nature is indeed willing and able to do immediate proxy deposits in authors' IRs too].

The result of this co-opting of self-archiving is:

(1) The self-archiving practice is made less likely to generalize beyond non-NIH/biomedical research.

(2) The self-archiving practice is less likely to be done in the author's institutional repository. [possibly moot]

(3) The self-archiving is less likely to be immediate (rather than after an embargo). [possibly moot if Nature is willing and able to proxy-deposit in the author's IR immediately upon acceptance for publication]

(4) It is less likely that the institutional repository's "Request a Copy" Button will be able to tide over research usage needs during any embargo. [possibly moot]

(5) In general, this proxy-archiving in an external repository makes it less likely that institutions and funders worldwide will converge on institutional self-archiving mandates -- like Southampton's, Liège's, Harvard's and Stanford's -- that will systematically cover all of OA space.

In other words, while appearing to be doing OA a service, this Nature policy is actually doing Nature a service and only giving OA the minimal due that is already inherent in the NIH and kindred mandates.

"We are announcing our intention early in the process to solicit feedback from the community and to reassure authors that we will be providing this service," said Steven Inchcoombe, Managing Director of NPG. "We invite authors, funding bodies, institutions, archives and repositories to work with us as we move forward."

Translation: "We are offering to take over the burden of doing the few extra keystrokes that self-archiving mandates entail in exchange for retaining control over self-archiving and its likelihood of scaling up to universality and immediacy across disciplines and institutions. Let's now hope that the appetite for OA stops there: embargoed, journal-mediated central access to NIH-funded biomedical research in PubMed Central and the like..."

"Optimize the NIH Mandate Now: Deposit Institutionally, Harvest Centrally"

As a researcher, my response would be: "Thank you, but I'll still go ahead and do the keystrokes myself, depositing my own final refereed draft in my own institutional repository, immediately upon acceptance for publication. That way I can provide immediate OA to those of my deposits that are published in the 63% of journals that, unlike Nature, are already fully green. And for the rest, my IR's Request a Copy Button will help me provide almost-instant, almost-OA to fulfill the immediate-usage needs of researchers webwide who cannot afford access to (say) Nature's paid version and cannot afford to wait until Nature's embargo expires. Then, at the end of the Nature embargo, my deposits can also be exported to PubMed Central or harvested by any other central collections that may also want to host them -- but they will already be OA in my IR in any case."

Initially, the service will be open to authors publishing original research articles in Nature, the Nature research titles and the clinical research section of Nature Clinical Practice Cardiovascular Medicine. NPG will then extend the service to society and academic journals in its portfolio that wish to participate.

Let's hope that authors and their institutions will be wise enough not to once again leave their research output entirely in the hands of publishers. In the online age, journal publishers render their essential service in managing peer review and certifying its outcome with their journal-name and its track-record, but there is no longer any earthly reason why they should continue to retain exclusive control over the access-provision process, particularly in order to embargo it!

For eligible authors who opt-in during the submission process, NPG will deposit the accepted version of the author's manuscript on acceptance, setting a public release date of 6-months post-publication. There will be no charge to authors or funders for the service.

Deposit is only a few keystrokes, and the only place it makes sense to deposit upon acceptance is the author's own institutional repository, which hosts all the institution's research output (not just biomedical research funded by NIH and held and embargoed by Nature) and makes it possible for the author to provide immediate almost-OA during any embargo period (thanks to the Button).

"NPG is committed to serving as a partner to the scientific and medical communities," continued Steven Inchcoombe. "We believe this is a valuable service to authors, reducing their workload and making it simple and free to comply with mandates from their institution or funder. We recognise that publishing in an NPG title can be a career high-point for researchers, and want to ensure that our authors enjoy the best possible service from their publisher of choice."

Minus the hype, this is an offer to spare you a few keystrokes in exchange for retaining control over access provision to your work, blocking access for 6 months, and reducing the probability and speed with which self-archiving and self-archiving mandates will scale across all disciplines and all institutions worldwide.

NPG has been an early mover amongst subscription publishers in encouraging self-archiving. In 2002, the publisher moved from requesting copyright transfer for original research articles to requesting an exclusive license to publish. In 2005, NPG announced a self-archiving policy that encourages authors of research articles to self-archive the accepted version of their manuscript to PubMed Central or other appropriate funding body's archive, their institution's repositories and, if they wish, on their personal websites.

After a six-month embargo, rescinding (in 2005) Nature's previous (2003) green light to provide immediate Green OA upon acceptance for publication.

In all cases, the manuscript can be made publicly accessible six months after publication...

And retaining control over that is the real motivation behind this generous offer, along with the brakes it puts on scaling beyond NIH (and kindred) funded biomedical research, destined for PubMed Central, to all research, from all institutions, across all scientific and scholarly disciplines. [possibly moot]

NPG's policies are explained in detail at this web page.

And their consequences are explained above.

Advice to Nature authors: Accept the offer, but deposit your final refereed draft in your IR immediately upon acceptance anyway, allowing you and your institution to retain control of it, as well as to provide almost-OA to it immediately. Once all researchers do this, all access-embargos will die their well-deserved deaths of natural causes soon thereafter.

(Could Nature's announcement be an attempt at damage control after its recent ill-received attack on its competitor, Gold OA publisher PLoS? If so, then some more critical reflection is needed on Nature's part as to why it continues to embargo access to the refereed final draft while its other competitor, Science, is already fully Green. [Science, in turn, might ponder why, unlike Nature, which has abandoned it, Science continues to cling to the obsolescent "Ingelfinger Rule," ruling out the self-archiving of the pre-refereeing preprint before publication: This self-serving edict is neither a legal matter nor an OA matter, but it too is inimical to research progress, and a distinct anachronism.])

Stevan Harnad
American Scientist Open Access Forum