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.
http://blog.ostp.gov/2009/12/09/ostp-to-launch-public-forum-on-how-best-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).
http://blog.ostp.gov/wp-login.php?action=register

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