Re: Please Comment on Pres. Obama's OSTP Mandate Proposal

From: Stevan Harnad <>
Date: Wed, 16 Dec 2009 06:30:39 -0500

On 12-Dec-09, at 7:01 AM, wrote:

> Dear Stevan,
> I fully endorse your comments. My only concern regards the WHO
> DEPOSITS section: to ensure a primary deposit one needs servers,
> personnel and some infrastructure, which, in a situation as presently
> witnessed in the Italian public research institutions, may no longer be
> warranted due to drastic shortage of public funding. This means that,
> paradoxically, publicly funded (italian and european tax payers) research
> results might be obscured thru the obsessive policy of our Ministry. On
> the
> other hand, many publishers (unfortunatly not the dominating ones) are
> private but +- non-profit organizations. Allowing for the option that such
> publishers were in charge of the deposit might be the solution to a
> problem
> more than a risk to lose positions in open access.

Dear Miguel,

I understand and lament the public funding situation in Italy today -- but
the conclusion that therefor Italian funders should adopt mandates for which
compliance can be in the form of publishers doing the depositing in place
of fundees in no way follows from that unfortunate state of affairs!

-- (1) Less public funding does not mean that fundees cannot do the
keystrokes to deposit their own final drafts.

-- (2) If a fundee's institution does not yet have an institutional
repository, the fundee can deposit in DEPOT (it has
plenty of room! ). DEPOT
was created specifically for that purposes and is now open to deposits from
researchers the world over whose institutions do not yet have repositories
of their own.
-- (3) Publishers are free to make their articles OA too, if they wish,
either on their own websites or by depositing them in an OA repository, but
that again does not mean that the author cannot or need not deposit in the
author's own institutional repository in such a case: on the contrary, it
facilitates author deposit.

A funder's OA mandate has to be systematic, scaling up to cover every case,
if it is to be successful. Exceptions, loopholes, and unconfirmable
compliance mean that mandates are not really mandates. And without mandates,
deposits do not take place beyond the 15% global baseline for spontaneous,
unmandated self-archiving:

Mandating immediate deposit by the fundee covers every case. Instead
allowing or encouraging the option of deposit by some party other than the
fundee, at some other time, does not cover every case, delays deposit, and
makes it very difficult if not impossible to monitor whether and when there
has been compliance with the mandate (since the "compliance" might not be on
the part of the mandated fundee but an unmandated, unfunded 3rd party, and
at an indeterminate time).

And the locus-of-deposit is just as important, not only for monitoring
compliance with the funder mandate, but to facilitate and reinforce the
adoption of -- and compliance with -- the all-important complementary
mandates by institutions, the universal providers of research output, for
the deposit of the rest of their institutional research output, in all
disciplines, funded and unfunded.

Again, if funders allow institution-external (i.e., central repository)
deposit, this competes with, instead of converging with, institutional
mandates, by necessitating multiple deposits of the same paper
(institution-internally and institution-externally) for funded papers.
Authors rightly resist having to deposit a paper more than once. Relying on
publishers to do the deposit -- institution-externally or
institution-internally -- again simply increases the uncertainty about
whether, when and where a deposit mandate has been complied with.

As ever, DEPOT is available to serve as an interim repository for
institutions that do not yet have a repository. (But even with Italy's hard
times in public funding, it is difficult to image that an institution cannot
afford a 2000 euro server and the few hours sysad time it takes to set up
and maintain the repository. The software, after all, is free -- and Italy already has 28 institutional
repositories 15 EPrints and 11 DSpace, out of its
total of 50 registered repositories: 26 Eprints and 15

Stevan Harnad

> On 10 Dec 2009 at 9:26, Stevan Harnad wrote:
> > Today (Dec 10 2009) begins the comment period for President Obama's
> > OSTP Public Forum on How Best to Make Federally Funded Research
> > Results Available For Free.
> >
> > to-make-federally-funded-research-available-for-free/
> >
> > 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 evaluations.
> >
> > 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 content).
> >
> > 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
> >
> >
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> >
> --
> Miguel Gregorkiewitz
> Dip Scienze della Terra, UniversitÓ
> via Laterina 8, I-53100 Siena, Europe
> fon +39'0577'233810 fax 233938
> email
> -- To unsubscribe from the BOAI Forum, use the form on this page:
Received on Wed Dec 16 2009 - 11:52:34 GMT

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