In his "Analysis of Comments and Implementation of the NIH Public Access Policy <http://edocket.access.gpo.gov/2009/E9-3442.htm>," Dr. Raynard Kington <http://www.nih.gov/about/director/index.htm>, Acting Director, National Institutes of Health (NIH), writes that *"direct feeds from [institutional repositories (IRs) are]... worthwhile... but... raise important technical and logistical challenges regarding author approval, copyright permissions, quality control, and formats for electronic transfer. The NIH remains open to closer collaboration with institutional [repositories] and will consider this issue as the Policy matures."* It is virtually certain that all technical and logistical challenges to designating Institutional Repositories (IRs)<http://roar.eprints.org/?action=home&q=&country=&version=&type=institutional&order=name&submit=Filter> as NIH's preferred locus of direct deposit (followed by "direct feed" to PubMed Central (PMC) <http://www.pubmedcentral.nih.gov/>) can be successfully met (and most already have been: see below). The benefits of NIH/institutional collaboration<http://blogsearch.google.ca/blogsearch?hl=en&num=100&c2coff=1&safe=active&oi=spell&ie=UTF-8&q=%28mandate+OR+mandates%29+%28%28integrate+OR+integration%29+OR+convergence%29++OR+NIH+blogurl%3Ahttp%3A%2F%2Fopenaccess.eprints.org%2F&btnG=Search+Blogs> on direct feeds will be enormous, and will far exceed the current reach of the NIH mandate<http://www.eprints.org/openaccess/policysignup/fullinfo.php?inst=National%20Institutes%20of%20Health%20%28NIH%29> (which is now restricted to the 80,000 articles a year resulting from NIH funding, no more, no less). The NIH mandate touches the institutions of every one of NIH's fundees. If the NIH mandate preferentially encourages its fundees to deposit their NIH-funded output in their own respective IRs (with direct feed to to PMC therefrom, instead of direct deposit in PMC, as now), it will also motivate their fundees to deposit -- and motivate their fundees' institutions to mandate the deposit of -- the *rest of their institutional output* in their IR too, not just the NIH-funded fraction of it. Not so if the 80,000 NIH articles must be directly deposited institution-externally (in PMC): That has the exact opposite effect, competing with and complicating, hence demotivating institutional deposits and mandates. (And we must not forget that the institutions are the universal providers of all research output: funded and unfunded, across all disciplines.) The "technical and logistical challenges" for "direct feeds" from IRs to PMC have already been largely met: *(1)* The SWORD transfer protocol<http://openaccess.eprints.org/index.php?/archives/484-guid.html> has already solved the problem of automatically exporting IR deposits to other respoitories. *(2)* "Author approval" is not a problem at all: Authors are mandated by NIH to deposit, and NIH specifies the locus of deposit. Currently that designated locus is PMC. The recommendation here is that the preferred locus of deposit should instead be the author's IR, with the deposit then automatically ported by "direct feed" (via SWORD) to PMC. (Institutional deposit will in fact simplify deposit for authors, increasing their motivation to comply with the NIH mandate.) *(3)* "Copyright permissions" are not a problem either: Authors are mandated by NIH to deposit and NIH specifies the locus of deposit. If copyright is not an issue with PMC deposit, it is even less of an issue with direct institutional deposit in the fundee's own IR. (Publisher embargoes can be -- and are -- implemented by IRs just as they are by PMC.) *(4)* "Quality control" is not a problem either. Authors are mandated by NIH to deposit their final, refereed, revised draft, and NIH specifies the locus of deposit. The IR deposit can be exported by "direct feed" (via SWORD) to PMC, where exactly the same quality controls can be performed as are now being performed by PMC. (The IR direct-deposit protocol can easily be made to conform to the PMC direct-deposit protocol: they are almost identical already.) *(5)* "Formats for electronic transfer" is not a problem either. The SWORD protocol does the electronic transfer, and the format for deposit of the author's final, refereed, revised draft is exactly the same. It is very welcome and timely news that NIH's Acting Director is "open to closer collaboration with institutional archives." The sooner a collaborative deposit policy, with IR deposit and direct feed to PMC can be adopted and announced, the sooner its potentially enormous knock-on effects will begin to make themselves felt in helping to wake the "slumbering giant<http://openaccess.eprints.org/index.php?/archives/522-guid.html>" -- the US and global network of universities and research institutes, not only the NIH-funded ones, but all of them: the universal providers of research, worldwide -- to create their own IRs (if they don't have them already) and to mandate the deposit of all of their own research output into them, not just NIH-funded research. This global enabling effect of the NIH mandate for accelerating and facilitating universal OA should also be cited in the defense of NIH's historically invaluable public access policy against the Conyers Bill<http://blogsearch.google.ca/blogsearch?hl=en&num=100&c2coff=1&safe=active&oi=spell&ie=UTF-8&q=Conyers+blogurl%3Ahttp%3A%2F%2Fopenaccess.eprints.org%2F&btnG=Search+Blogs>'s attempt to overturn it. (And the other research funding councils worldwide, too, should be encouraged to consider the enormous potential OA gains -- at no loss -- from stipulating IR deposit rather than institution-external deposit in their own OA policies as well.) *Stevan Harnad <http://www.eprints.org/openaccess/>* American Scientist Open Access Forum<http://amsci-forum.amsci.org/archives/American-Scientist-Open-Access-Forum.html>
