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Today (Dec 10 2009) begins the comment period for President Obama's
OSTP=A0Public Forum on How Best to Make Federally Funded Research Results
Available For Free. http://blog.ostp.gov/2009/12/09/ostp-to-launch-public-forum-on-how-best-to-=

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
sake of 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.

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 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

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

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.

Stevan Harnad
American Scientist Open Access Forum