Before The White House Office of Science and Technology Policy (OSTP)
Regarding the development of policies to deliver public access to published results of taxpayer-funded research
[DOCID:fr31de09-73]
COMMENTS BY KNOWLEDGE ECOLOGY INTERNATIONAL
Knowledge Ecology International appreciates the opportunity to submit the following reply comments in connection with the Notice of Inquiry regarding enhancing public access to archived publications resulting from research funded by Federal science and technology agencies published in the Federal Register on December 31, 2009.
Knowledge Ecology International is an international organization that searches for better outcomes, including new solutions, to the management of knowledge resources. KEI undertakes and publishes research and new ideas, engages in global public interest advocacy, provides technical advice to governments, NGOs and firms, enhances transparency of policy making, monitors actions of key actors, and provides forums for interested persons to discuss and debate knowledge ecology topics.
We would like to thank the OSTP for its serious interest on this issue and for giving all stakeholders the opportunities to contribute to this debate.
To reply to specific questions from the OSTP, we offer the following comments in response to the nine questions:
Q1. How do authors, primary and secondary publishers, libraries, universities, and the federal government contribute to the development and dissemination of peer reviewed papers arising from federal funds now, and how might this change under a public access policy?
A1. Today there is little coordinated effort to support the funding of open access journals, and considerable resources being spent to support the costs of subscriptions to proprietary journals. If one would total the costs of subscriptions to biomedical journals, for example, and compare this to the support for open access journals, there would be a huge disparity, in favor of the subscription access journals. The challenge is to change this.
Q2. What characteristics of a public access policy would best accommodate the needs and interests of authors, primary and secondary publishers, libraries, universities, the federal government, users of scientific literature, and the public?
A2. Aside from eliminating subscription fees for access, there has to be an increase in the resources available to edit and manage open access journals. Something has to replace subscription fees in providing a decentralized system of support for quality journals.
Q3. Who are the users of peer-reviewed publications arising from federal research? How do they access and use these papers now, and how might they if these papers were more accessible? Would others use these papers if they were more accessible, and for what purpose?
A3. One benefit of open access journals is an increase in cross-disciplinary use of journals. Today it is unfortunately the case that persons in some fields fail to read journals outside of their core specialization. But often important ideas and data can be found in the scholarly work from a different discipline. This is also a major issue for policy relevant work. With lower barriers to access, not only will journals be read by persons outside of the core specialization, but by a much wider audience, including younger students considering a field of study, and policy makers, businesses, consumers and other elements of civil society that are trying to glean practical knowledge from scholarly research.
Q4. How best could Federal agencies enhance public access to the peer-reviewed papers that arise from their research funds? What measures could agencies use to gauge whether there is increased return on federal investment gained by expanded access?
A4. We are skeptical of a particular metric being useful to drive a centralized funding mechanism. What we think is more promising are new mechanisms to resource research institutions to support open access journals in a decentralized way, using their own criteria to select journals they find worthy of financial support. This decentralized approach to valuation is what currently drives the subscription funding model. But rather than have institutions paying for subscriptions to support the access to their own staff or students, the research institutes would support access to everyone. Several different mechanisms should be evaluated, with input from research institutions and publishers of open journals. One would be to require a certain fraction of research grants to any institution be spent to resource open journals, chosen by the research institution, or by consortia of research institutions that the institution voluntarily joined. This is one way to create a system of competitive intermediaries to fund on a decentralized basis the work of open journals.
In such a system of competitive funding consortia, research institutions would be required to allocate a portion of their research budgets to one of the open access funding consortia, but they could choose which one. The competing funding consortia would have different tastes and strategies for funding open journals, including preferences for particular journals and topics. The research institution would resource the consortium that it believed was best supporting its research needs.
We also recommend consideration of the open source dividend approach, to reward and stimulate open access publishing. This innovative policy has been described in academic papers and in recent proposals to the World Health Organization by Bangladesh, Barbados, Bolivia and Suriname, and in a proposal for TB prize for diagnostics that has been supported by many public health groups. See James Love and Tim Hubbard, “Prizes for Innovation of New Medicines and Vaccines,” Annals of Health Law, Vol. 18, No 2, pages 155-186, Summer 2009. /wp-content/uploads/prizes_new_medicines_annals_healthlaw.pdf
Q5. What features does a public access policy need to have to ensure compliance?
A5. A system of mandated funding of open access journals, as a condition of funding research, would require a workable definition of a qualifying project. Given the fact that funding was involved, there would be no need to delay open access. Requirements for archiving copies of articles, and making them available in open document formats would be important.
Q6. What version of the paper should be made public under a public access policy (e.g., the author’s peer reviewed manuscript or the final published version)? What are the relative advantages and disadvantages to different versions of a scientific paper?
A6. In the long run, you want to support, financially, true open access journals. Even in the short run, a reader should have access to the actual text of the published article, with interior citations (such as page numbers of paragraph numbers).
Q7. At what point in time should peer-reviewed papers be made public via a public access policy relative to the date a publisher releases the final version? Are there empirical data to support an optimal length of time? Should the delay period be the same or vary for levels of access (e.g., final peer reviewed manuscript or final published article, access under fair use versus alternative license), for federal agencies and scientific disciplines?
A7. If there is no system of mandated funding of open access journals, it may be necessary to accept a delay in open access, such as 6 months after first publication.
Q8. How should peer-reviewed papers arising from federal investment be made publicly available? In what format should the data be submitted in order to make it easy to search, find, and retrieve 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?
A8. It should be manageable to identify a list of formats for the text or graphics of articles that would be acceptable for open access journals. What will be more difficult are the formats for data and databases that are referenced or part of the research paper. The development of multiple standards of presenting different types of data will be important to address the special requirements of different types of data. For example, some economic time series data may have one solution, while certain geographic data systems have another, or medical research data yet another. Even if it is not yet possible to have overarching solutions that cover all data, it should be possible to develop more common approaches to storing and sharing data of particular types, when the use of such standards will facilitate the aggregation or use of the data with other relevant datasets to provide additional analysis, or to lower the overall costs of data collection.
Q9. Access demands not only availability, but also meaningful usability. How can the Federal government make its collections of peer-reviewed papers more useful to the American public? By what metrics (e.g., number of articles or visitors) should the Federal government measure success of its public access collections? What are the best examples of usability in the private sector (both domestic and international)? And, what makes them exceptional? Should those who access papers be given the opportunity to comment or provide feedback?
A9. Text should be digital, searchable, and indexed by search engines. The development of better standards for database data formats would make data more useful, as will a wider use of systems of annotation and comment by readers. It may be useful to have better disclosures of conflicts of interest. Better implementation of technologies to track and report links to an article would be useful.
We would like to thank the OSTP for facilitating discussions on policies regarding the expansion of the NIH public access policy to cover all federal agencies.
Respectfully submitted,
Manon Ress and James Love
Knowledge Ecology International