Please Comment on Mandate Proposal by President Obama's Office of Science and Technology Policy (OSTP)

Today (Dec 10 2009) begins the comment period for President Obama's OSTP Public Forum on How Best to Make Federally Funded Research Results Available For Free. Comments will be in three phases:

Implementation (Dec. 10 to 20): Which Federal agencies are good candidates to adopt Public Access policies? What variables (field of science, proportion of research funded by public or private entities, etc.) should affect how public access is implemented at various agencies, including the maximum length of time between publication and public release?

Features and Technology (Dec. 21 to Dec 31): In what format should the data be submitted in order to make it easy to search and retrieve information, and to make it easy for others to link to it? Are there existing digital standards for archiving and interoperability to maximize public benefit? How are these anticipated to change.

Management (Jan. 1 to Jan. 7): What are the best mechanisms to ensure compliance? What would be the best metrics of success? What are the best examples of usability in the private sector (both domestic and international)? Should those who access papers be given the opportunity to comment or provide feedback?

Please do comment at the OSTP site (you'll need to register first).

My own comments follow:

It would be a great benefit to research progress in the US as well as worldwide if the US were to require not only NIH-funded research journal articles to be made freely accessible to all users online, but all federally funded research journal articles.

BENEFITS: The benefits of making all US publicly funded research publicly accessible online would not only be in the fact that all tax-payers (and not just those who can afford to subscribe to the journal in which it was published) will be able to read and use the research their taxes paid for, but, even more important, it will allow all researchers (and not just those whose institutions can afford to subscribe to the journal in which it was published) to read, use, apply and build upon all those research findings, again to the benefit of the public that funded them, and for the future research advances for the sake of which research is funded, conducted and published.

WHICH RESEARCH? Which federally funded research should be made publicly accessible online? Start with all research that is fully funded federally, in all scientific, technical and scholarly fields, and then work out agreements in the case of joint private funding. Most private funders will likewise want to ensure maximal usage and impact for the research they have funded. If they want it published at all, they will also want access to it to be maximized.

TIMING OF DEPOSIT: Allowable embargo time should be minimal, but, far more important, the requirement should be to deposit the final, peer-reviewed draft, immediately upon acceptance for publication, in the author's institutional repository, without exception. 63% of journals already endorse making the deposit Open Access immediately. For the remaining 37%, the deposit can be made Closed Access, with only its metadata (authors, date, title, journal, abstract) accessible publicly during the allowable embargo. That way researchers can send the author a semi-automatic email eprint request for an individual copy to be used for research purposes. This will tide over research needs during any embargo.

LOCUS OF DEPOSIT: It is extremely important to require institutional instead of central deposit (which is what several funders require now, e.g., NIH requires central deposit in PubMedCentral, PMC). Institutional deposits can be easily and automatically harvested or imported into central collections and services like PMC (or Scirus or OAIster or Citeseer, or, for that matter, Google Scholar and Google).

The NIH requirement to deposit in PubMedCentral (PMC) is an extremely counterproductive handicap, needlessly slowing down the growth of public access for no good reason at all. Institutions (universities and research institutes) are the universal providers of all research output, funded and unfunded, across all fields. If funders mandate institutional deposit, they encourage and reinforce universalizing the adoption of institutional public access mandates across all their fundees' institutions (and they gain a powerful ally in monitoring and ensuring compliance with the funder mandates).

But if funders instead require central deposit, they discourage and compete with universalizing the adoption and implementation of institutional public-access requirements. Nor is there any advantage whatsoever -- functional, technical or practical -- to requiring central rather than institutional deposit; it only creates needless obstacles to the universal adoption of public access and public access mandates for all research output. (It's rather like web hosts depositing their web pages directly in google, instead of hosting them locally and just letting google harvest them.)

WHO DEPOSITS? The current NIH public access policy allows the option of publishers doing the PMC deposits in place of NIH's fundees. This not only makes fundee compliance vaguer and compliance-monitoring more difficult, but it further locks in publisher embargoes (with less scope for authors providing individual access to researchers during the embargo) and it further discourages convergent institutional mandates (with the prospect of researchers having to do multiple deposit for the same paper, institution-internal and institution-external). The ones responsible for ensuring that the deposit is made, immediately upon acceptance for publication, are the fundee and the fundee's institution, by monitoring the deposits in their own institutional repository. Publishers should be out of the loop.

DEPOSIT WHAT? There is no need at all to be draconian about the format of the deposit. The important thing is that the full, peer-reviewed final draft should be deposited in the fundee's (OAI-compliant) institutional repository immediately upon acceptance for publication. A preference can be expressed for XML format, but any format will do for now, until the practice of immediate Open Access deposit approaches global universality (at which time it will all converge on XML as a natural matter of course anyway).

It would be a needless handicap and deterrent to insist on any particular format today. (Doc or Docx will do, so will HTML or PDF or any of the open formats.) Don't complicate or discourage compliance by gratuitously insisting on more than necessary at the outset, and trust that as the practice of public access provision and usage grows, researchers will converge quite naturally on the optimal format. And remember that in the meanwhile the official published version will continue to be generated by publishers, purchased and stored by subscribing institutions, and preserved in deposit library archives. The public-access drafts are just supplements for the time being, not substitutes, deposited so that it is not only paying subscribers who can access and use federally funded research.)

MONITORING COMPLIANCE: What are the best mechanisms to ensure compliance? To require deposit in the fundee's institutional repository immediately upon acceptance for publication. Fundees' institutions are already co-responsible for compliance with funders' application and fulfillment conditions, and already only too eager to help. They should be made responsible for ensuring timely compliance with the funder's deposit requirement. It can also be made part of the grant requirement that the funder must be notified immediately upon deposit by being sent the deposit's URL, so it can be linked or imported for the funder's records and/or harvested by the funder's designated central repository (e.g. PMC).

METRICS OF SUCCESS: Institutions already have an interest in monitoring the usage and impact of their research output, and their institutional repositories already have means for generating usage metrics and statistics (e.g., IRStats). In addition there are now central means of measuring usage and impact (free services such as Citeseer, Citebase, Publish-or-Perish, Google Scholar and Google Books, as well as fee-based ones such as SCOPUS and Thompson-Reuters Web of Science). These and other rich new metrics will be available to measure success once the deposit requirements are adopted, growing, and supplying the content from which these rich new online metrics are extracted. Which of the new metrics proves to be the "best" remains to be tested by systematically assessing their predictive power and their correlation with peer evaluations.

COMMENT AND FEEDBACK: Once the research content is openly accessible online, many rich new tagging, commenting and feedback mechanisms will grow quite naturally on top of them (and can also be provided by central harvesters and services commissioned by the funders themselves, if they wish, or the metrics can simply be harvested from other services for the funder's subset of their content).

PRIVATE SECTOR USABILITY: Metrics will not only make it possible for deposit rates, downloads, citations, and newer metrics and their growth to be measured and monitored, but it will also be possible to sort uptake metrics into those based on public access and usage, researcher access and usage, and industrial R&D and applications access and usage. But the urgent priority is first to provide the publicly accessible research content on which all these uptake measures will be based. The measures will evolve quite naturally once the content is globally available.

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For more detailed guidelines on optimizing OA mandates (what to mandate depositing, where and when to mandate deposit, and how to integrate institutional and funder mandates), see 1, 2 & 3).

All federal agencies that fund scientific, technical and scholarly research should require fundees to make the resulting peer-reviewed articles to be made freely accessible online (”Open Access”).

There is no objective reason why any publicly funded research that is published in peer-revewed journals should be accessible only to subscribers.

The costs of providing free online access are minimal. Fundees should be required to make their articles publicly accessible by depositing them in their own institutions’ OAI-compliant Open Access Repository.

The deposit should be made immediately upon acceptance for publication. For the minority of publishers who do not yet endorse making the deposit Open Access immediately, an embargo of 6 months can be allowed during which only the deposit’s metadata are openly accessible but the author can provide individual eprints for researcher purposes in response to individual user email requests mediated by the institutional repository software.

All empirical data indicate that the optimal embargo is no embargo. If there is any access embargo at all, the result is needlessly lost research usage and impact. There is no field of science or scholarship, fast or slow, that benefits — or fails to lose — from denying access to peer-reviewed, published results once they have been accepted for publication.

The only version of a paper that needs to be made freely accessible to all users online is the author’s peer-reviewed final draft, immediately upon acceptance for publication. There are no advantages at all to later versions of the paper, only disadvantages, because fewer publishers endorse making their proprietary PDF freely accessible. Eventually the author’s final draft can be in XML format, but for now any format (doc, docx, html, pdf, etc.) will do.

Only mandatory deposit is successful and effective. All other alternatives fail to generate deposits above the spontaneous unmandated level of about 15%. See Arthur Sale’s studies.

The only relevant structural characteristics of a public access policy are the ones already mentioned: mandate deposit of the fundee’s peer-reviewed final draft in the fundee’s institutional repository immediately upon acceptance for publication. (Preferable format, but not obligatory: XML.) Compliance should be monitored by the fundee’s institution, as part of the grant’s fulfillment condition. Maximum permissible embargo before making the deposit Open Access: 6 months (but preferably no embargo). Deposits can be harvested to central collections and services like PubMed Central, but deposit should be institutional and not central, in order to reinforce and facilitate complementary institutional mandates to deposit unfunded research.

Stevan Harnad
American Scientist Open Access Forum