COAPI Response for OSTP Memorandum Articles

We appreciate that the Memorandum calls for agency plans to be developed in consultation with stakeholders, which include universities and their libraries, who share common interests with the federal government in promoting broad public access and productive reuse of scientific publications. Universities have already made significant investments in infrastructure to support the development of institutional repositories.  Unlike commercial interests, the enduring mission of universities is to generate new knowledge, and the mission of their libraries is to preserve and make accessible that knowledge for future generations.  Our experience and expertise with digital preservation enables us to provide long-term stewardship and access to final peer-reviewed scholarly publications. In fact, some COAPI member universities have been in existence longer than the Federal Government.  We believe universities and their libraries can serve to facilitate open access to the results of federally funded research to fulfill the objectives of the Memorandum, and that university libraries should be considered candidates for hosting suitable repositories.

COAPI, as administrators of open access policies and repositories, and as stakeholders, respectfully offer the following recommendations:

1. Each researcher funded totally or in part by a federal agency should be required to submit the author’s final manuscript to a suitable repository upon acceptance for publication in a peer-reviewed journal in order to help ensure consistency in compliance.  Immediate submission of author’s final manuscript is also an element of our institutional open access policies, and the largest percentage of scientific journals already allow author’s to use this version in institutional repositories, increasing compliance.
2. While we would prefer that articles arising from federally funded research be made available to the public immediately upon publication to fully leverage their value, we support the inclusion of an embargo period that is as short as practicable, but no longer than six monthsafter publication in a peer-reviewed journal.
3. A suitable repository should be defined as one that meets all requirements for ensuring full public accessibility, productive reuse (including downloading, text mining, machine analysis, and computation), interoperability with other repositories housing federally funded scientific publications, metadata based on open standards, and long-term stewardship and preservation, without charge to authors or the public for any of the above.
4. We strongly encourage agencies to consider leveraging the public investment in the NIH’s repository, PubMed Central, as a potential repository solution.
5. We also believe that many existing university repositories can meet the above criteria.  Allowing researchers to deposit articles in the repository of their institution, when an appropriate existing federal agency repository is not available, and providing a durable link in reports to the federal agency providing funding, will increase compliance.
6. In order to facilitate reuse of content and development of new services, agencies should require the use of persistent, unique identifiers for publications, data, authors, and other elements of research output.
7. Final peer-reviewed scholarly publications should be linked openly to their source data to allow for reuse and replication of results.
8. To track the effectiveness of agency policies, a variety of metrics and identifiers should be supported to provide information on access, use, and impact of final peer-reviewed scholarly publications.  Various metrics have been implemented in university repositories.  Agencies should also develop plans to assess the broader economic and societal impact of their policies.

We believe that the development of consistent federal agency policies to ensure access to this information will benefit our nation, our economy, and our future, and that it will accelerate scientific discovery, improve education, and empower entrepreneurs to translate research into commercial ventures and jobs.  To realize this potential, we strongly encourage agencies to be as consistent as possible in their policies and compliance requirements to minimize the cost and complexity of compliance with grant requirements for both principal investigators and research administration.

Also, we strongly recommend that agencies draft their policies in accordance with the FASTR guidelines, where those guidelines are stronger than the OSTP guidelines.  The FASTR guidelines are stronger on embargoes and reuse, and more beneficial to research and researchers. On embargoes, for example, the FASTR guidelines cover our recommendation in #2 above. On reuse, the FASTR guidelines require reuse rights and the OSTP guidelines merely encourage them. The FASTR guidelines specifically require rights for computational analysis by state-of-the-art technologies, while the OSTP guidelines merely encourage rights for search, retrieval, and analysis. If agencies write policies at the weak end of what OSTP allows, and if FASTR passes, then agencies will have to revise and strengthen their policies, regardless of the time and effort put into harmonizing with other agencies and consulting with stakeholders. Agencies could save time, reduce friction in the long run, and support research more effectively, by creating policies that comply with FASTR in the first place.

Finally, we strongly believe that appropriate copyright and other intellectual property rights should be assigned to scientific publications in a non-exclusive manner to ensure discovery, sharing, and text mining.  Public access policies can stimulate the development of new tools and services that generate opportunities for the public, industry, and the scientific community. Licensing arrangements must ensure that no one single entity or group secures exclusive rights, or the objectives of the Memorandum will not be met.  We thank you for the opportunity to give input as stakeholders.

Respectfully submitted by Lisa A. Macklin, on behalf of COAPI.