COAPI Response for OSTP Memorandum Data  

The Coalition of Open Access Policy Institutions (COAPI) welcomes the February 22, 2013, White House Memorandum on “Increasing Access to the Results of Federally Funded Scientific Research.”  COAPI includes 56 institutional members that represent universities that have or are developing open access policies[1].  As such, COAPI members are actively managing the implementation of these policies as well as open access repositories, fully accessible to the public. We fully support the primary objective of the Memorandum, which is to ensure that the direct results of federally funded research be made available to and useful for the public, industry and the scientific community.

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 data. Universities have already made significant investments in infrastructure to support the storage and use of data sets for our researchers who require these services to conduct their research.   Multiple libraries have partnered to develop the Data Management Plan Tool[2], which is widely used to assist researchers meet the NSF, IMLS, NEH and NIH requirements for data management plans.  Our experience and expertise with digital preservation enables us to provide long-term stewardship and access to data sets that result from federally funded research.

We believe universities and their libraries can serve to facilitate open access to the data sets that result from federally funded research to fulfill the objectives of the Memorandum.  Although not every university has an openly accessible data repository, there are several university collaborative initiatives by discipline that originated as academic collaborations (e.g. Dryad, ICPSR, Dataverse Network).  Universities and libraries have learned from our researchers, the creators and users of data sets, that there are differences in the data needs of each discipline, and that storing discipline  data sets together greatly facilitates their utility for that discipline.  As a result of this experience, we strongly encourage the agencies to look at norms and infrastructures that already exist in specific disciplines.

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

1. Each researcher funded totally or in part by a federal agency should be required to submit their data sets to a suitable repository upon completion of the grant in order to help ensure consistency in compliance.
2. While we would prefer that data sets arising from federally funded research be made available to the public immediately upon grant completion to fully leverage their value, we support the inclusion of an embargo period that is as short as practicable, but no longer than six months after grant completion.
3. A suitable repository should be defined as one that meets all requirements for ensuring full public accessibility, productive reuse (including downloading, machine analysis, and computation), interoperability with other repositories housing federally funded scientific data sets and publications, metadata based on open standards, long-term stewardship and preservation, and appropriate confidentiality safeguards, without charge to the author 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, and the complementary resources for sequence, microarray and bioassay data as a potential repository solution.
5. We also believe that some existing university repositories can meet the above criteria.  Allowing researchers to deposit data in the repository of their institution or a collaborative university-sponsored data repository, 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. Agencies should require the use of persistent, unique identifiers for data sets in order to facilitate reuse of data, development of new services, and demonstrating the impact of sharing data in ways that align with existing discipline norms, which would encourage compliance.  In addition, agencies should support the development of and require the use of data citation standards to appropriately cite data sources in scholarly publications, which will improve metrics for use of data sets.
7. Final peer-reviewed scholarly publications should be linked openly and consistently 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 the availability of data sets resulting from federal research.  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 data sets 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.

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.  We strongly believe that just as U.S. Copyright Law does not protect data sets of facts, which facilitates re-use of data, implementation of this policy must ensure that no one single entity or group has exclusive rights to the use or re-use of federally funded data.  Public access policies can stimulate the development of new tools and services that generate opportunities for the public, industry, and the scientific community.  We thank you for the opportunity to give input as stakeholders.

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