[A2k] KEI comments in OSTP review of policies to deliver public access to results of taxpayer-funded research

[Manon Ress]

The Office of Science and Technology Policy in the Executive Office of
the President and the White House Open Government Initiative launched
the =93Public Access Policy Forum=94 to invite public participation in
thinking through what the Federal government=92s policy should be with
regard to public access to published federally-funded research
results. To that end, OSTP is currently conducting an interactive,
online discussion that began Thursday, December 10, 2009.  More here: http:=
//www.ostp.gov/cs/public_access/public_access_forum

Here are KEI comments for OSTP review of policies to deliver public
access to results of taxpayer-funded research
http://www.keionline.org/node/764

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. http://keionline.=
org/sites/default/files/prizes_new_medicines_annals_hea
...

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


***************************************************************************
Manon Ress
manon.ress@keionline.org
Knowledge Ecology International
1621 Connecticut Ave, NW, Washington, DC 20009 USA
Tel.:  +1.202.332.2670, Fax: +1.202.332.2673

Il vaut mieux remuer une question, sans la d=E9cider, que la d=E9cider,
sans la remuer. (Pens=E9es, essais, maximes et correspondance de J.
Joubert  p.249)
Translation: It is better to debate a question without settling it
than to settle a question without debating it