OFFICE OF SCIENCE AND TECHNOLOGY POLICY Compilation of E-Mailed Comments for Public Access Policy Forum Part 4 Compiled on February 6th 2010 Comments of the Special Libraries Association regarding Public Access Policies for Science and Technology Funding Agencies across the Federal Government The Special Libraries Association (SLA) firmly supports expanding public access to information and materials arising from federal research. Representing more than 10,000 corporate, academic, and government information professionals in 75 countries, we have interests in: 2. 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? SLA has repeatedly expressed support for open public access to the results of NIH-funded research and supports access to all documents that are federally funded. Though the NIH practices are an excellent policy model to follow, SLA would make improvements to any new federal policy by shortening the embargo period to six months or less. A short (or no) embargo period would more accurately reflect the pace of research and discovery within all scientific fields and, at the same time, align U.S. policy with others in use around the world. In our highly competitive global economy, a minimal embargo period is critical to ensuring that our research institutions remain competitive with the rest of the world. It is also crucial that final electronic documents/manuscripts of federally funded research are stored in standardized archives and made publicly available, as they are in the NIH policy. This ensures that the U.S. government has a permanent archive of critical publicly funded research, allowing scientists, researchers and the public to easily collaborate on and engage in new discoveries and the creation of derivative works, further fueling the growth and advancement of society in the United States and around the globe. Respectfully, Doug Newcomb, Chief Policy Officer The American Dental Association (ADA) is pleased to comment on your efforts to enhance public access to archived, scientific peer-reviewed publications resulting from federally funded research. We offer these comments in response to your Federal Register notice of December 9, 2009 (74 FR 235: 65173). The ADA supports the goal of providing timely health information to the public, particularly when it comes to taxpayer supported research. However, efforts to hasten such access should not jeopardize the understandability and trustworthiness of the information. It should also preserve the public’s trust in journal publishers as credible, reliable filters of scientific information. Toward that end, we encourage you to incorporate the following principles into your efforts to enhance public access to archived publications resulting from research funded by Federal science and technology agencies: Grant access to final published versions only. The content of an author’s final peer-reviewed manuscript can be substantially different from a copyedited manuscript and a final published 2 journal article. The differences can be significant enough to cause the intentional or unintentional suppression or distortion of “peer-reviewed” research findings. To preserve the integrity of federally supported research, we recommend limiting the public’s access to anything other than the final published version(s) of peer-reviewed journal articles. Allowing publishers to voluntarily assume liability for author submissions should help accomplish this in a manner consistent with federal copyright law. Protect Intellectual Property. It is critical that the intellectual property of scientific papers be protected against plagiarism and misrepresentation—a problem in both the U.S. and in other countries. We do not feel that the public’s best interest is being served in this regard because the current digital system does not have appropriate software to guard against such violations. We strongly encourage the government to work with all vested stakeholders to identify the appropriate digital controls that will protect the integrity of the peer-reviewed content. Preserve the digital image of the final published article. Publishers vary widely in the types of research they publish and the manner in which the content is presented. The availability of tables, charts and other “extras” add value to the narrative text and sometimes lead to a greater understanding of the narrative itself. An author’s final peer-reviewed manuscript is lacking in these “extras.” A one-size-fits-all submission format (such as text-only) may also not accommodate these “extras.” We strongly urge that you require federal agencies to establish a journal article collection process would preserve the style and format of the final published version(s) of peer-reviewed journal articles. This might be done through the use of certain scanning technologies or proprietary digital images, such as the portable document format (PDF) developed by Adobe Systems, Inc. • Limit access until 12 months after publication. Once an author’s manuscript has been accepted for publication, publishers – who are typically not party to federally-funded research grants – incur significant costs for peer review. Our own Journal of the American Dental Association (JADA) recovers its peer-review and other operating costs through advertising and subscription revenue. The incentive, to advertise or subscribe would be threatened, however, once it is realized that the journal’s content can be obtained for free on a federal agency Web site. Our current policy is to make JADA articles freely available to the public 12 months after publication. This has historically provided sufficient time for JADA to recover its peer review costs and sustain its ongoing activities. Based on this experience, we strongly urge you to limit public access until at least 12 months after publication. We strongly encourage you to incorporate the principles described into any public access policies you may develop. Doing so would expedite public access to publications resulting from federally supported research. It would also maintain the public’s trust in journal publishers as credible, reliable filters of scientific information. We would welcome the opportunity to discuss this issue with you further. If you have any questions or would like additional information, please contact Mr. Robert J. Burns in our Washington Office. Ronald L. Tankersley, D.D.S. Kathleen T. O’Laughlin, D.M.D., M.P.H. President Executive Director 3 John Wiley & Sons (Wiley) is pleased to respond to OSTP’s December 9, 2009 Federal Register notice requesting comments on “Public Access Policies for Science and Technology Funding Agencies Across the Federal Government.” We appreciate the opportunity to participate in the Administration’s open consultation with all stakeholders who support the scientific research enterprise. Founded in 1807, Wiley is North America’s oldest independent publisher, and has a distinguished history as a literary, scientific, technical, medical, and scholarly publisher, serving researchers and practitioners in the US and around the world. Today, we employ approximately 2600 staff across the country and 5300 globally. We are one of the world’s foremost academic and professional publishers. We publish over 1,500 scholarly peer-reviewed journals, and our online service Wiley InterScience (www.interscience.wiley.com) provides electronic access to more than three million articles across these journals. Wiley-Blackwell is also the world’s largest society publisher, working in partnership with over 700 learned and scholarly societies that represent close to 1,000,000 members globally. Among them are the American Cancer Society (ACS), for which we publish Cancer, the flagship ACS journal; the Sigma Theta Tau International Honor Society of Nursing, with more than 120,000 members; and the American Anthropological Association, for which we publish 23 journals. Wiley supports the Open Government Directive issued by President Obama and Director Orszag’s December 2009 memorandum to the heads of executive departments and agencies. The three principles outlined in those documents–transparency, participation, and collaboration– form the cornerstone of an open government. However, in creating an open government and a sustainable public access policy, it is critically important that these objectives be accomplished without damaging the private institutions on which the Government depends. To quote Dr. Kathryn Jones, President of the American Association of Anatomists and Professor at Loyola University Chicago’s Stritch School of Medicine, “there is no crisis in the world of scholarly publishing or in the dissemination of scientific materials. Unlike so many other issues faced by this Administration, there is no emergency to address.” Not only is there no crisis, there is no lack of public access to the scholarly peer-reviewed literature, including those works based on federally funded research activities. The combination of investments in digital and online technology (by publishers as well as others), and the formation of library consortia John Wiley & Sons—Public Access Policy Recommendations (January 2009) (assisted by publishers in many cases) around the country and the world, has accelerated and broadened access to the peer- reviewed literature by orders of magnitude. Publisher innovation and investment over the