OFFICE OF SCIENCE AND TECHNOLOGY POLICY Compilation of E-Mailed Comments for Public Access Policy Forum Part 2 Compiled on February 1st 2010 Thank you for the opportunity to comment briefly on this public access policy forum. I wish to echo the comments of my counterpart at the American Anthropological Association, since the American Statistical Association (ASA) was also a part of the NHA study on financing scholarly journal publications (see http://www.nhalliance.org/bm~doc/hssreport.pdf <https://exchange.amstat.org/exchweb/bin/redir.asp?URL=http://www.nhalliance.org/bm~doc/hs sreport.pdf> ). While access to research is clearly important, a mandate to federal agencies that fund research to provide free access to journal articles published by scholarly societies like the ASA will have unintended consequences to the authors and readers of these journals, and to the ability of scholarly societies to sustain their publications programs. Scholarly societies would be set back severely by such a mandate due to loss of the subscription revenue that makes it possible to operate these journals. We already offer these journals to libraries at relatively minimal cost because much of the labor is done by volunteer editors and reviewers. However, there are still basic production costs, and if the revenue to cover these costs is eliminated, we're faced with finding other revenue sources. Good alternatives have yet to be discovered. As the aforementioned study notes, shifting the cost to authors is not feasible, and places a significant obstacle to publication for many authors. Scholarly societies are not enriching themselves at the expense of providing access to researchers. We ask for caution in rushing to mandate free access. We applaud the spirit of the proposal, but the reality of it may be to put scholarly society publishers out of business, an outcome from which no one benefits. Ron Wasserstein Executive Director American Statistical Association The American Association of Physics Teachers (AAPT) supports President Obama’s call for an “unprecedented level of openness in government,” and we are grateful for the opportunity to submit comments to help guide policy making regarding public access to scholarly publications resulting from research funded by agencies of the United States government. AAPT is a professional society with about 10,000 members, a vast majority of whom reside in the United States. AAPT publishes two scholarly journals: The American Journal of Physics and The Physics Teacher, both of which a re peer-reviewed archival publications and are broadly considered to be among the leading physics education journals in the world. As with many scholarly organizations engaged in publishing, AAPT holds the position that scholarly publishers add significant value to research manuscripts through by managing the peer-review process, by maintaining in perpetuity the archival version of record, and by leveraging state-of-the-art technology to make journal articles accessible and creatively usable tools for advancing 2 knowledge. And, like many in the scholarly publishing industry, AAPT has a long-term fiduciary interest in the scholarly and business integrity of its publications, as a service to our members and to the broader society. With regard to OSTP’s interest in developing policies related to public access, AAPT welcomes the January 12, 2010 publication of the “Report and Recommendations from the Scholarly Publishing Roundtable,” (the Report) See: http://www.aau.edu/policy/scholarly_publishing_roundtable.aspx?id=6894 AAPT thanks the Committee on Science and Technology of the United States House of Representatives and OSTP for convening the Scholarly Publishing Roundtable. AAPT endorses the Shared Principles and Recommendations of the Report. AAPT also feels that the Report adequately addresses the nine questions posed in OSTP’s Invitation to Comment. Furthermore, AAPT encourages OSTP and the many stakeholders engaged in the public access issue to use the Report as a starting place for carefully and responsibly developing policies that maximize public access and opportunities for creative uses of research publications. Any new policies should also explicitly promote the entrepreneurial role played by scholarly publishers in sustaining the peer-review process, in pushing the state-of-art in access and use technologies, and in stewarding in perpetuity publishers’ intellectual property. AAPT would welcome the opportunity and is prepared to work with OSTP to develop public access policies that adhere to the principles in the Report and which are further delineated above. Philip W. Hammer, PhD Associate Executive Officer AAPT -- Physics Education I attach BioMed Central's comments in response to the OSTP's request for contributions to its Policy Forum on Public Access to Federally Funded Research. We welcome the opportunity to contribute to this important debate, and we look forward with great interest to future developments in this area. Yours faithfully, Matthew Cockerill, Ph.D. Managing Director BioMed Central BioMed Central’s comments in response to the US Office of Science and Technology Policy request for contributions to its Policy Forum on Public Access to Federally Funded Research BioMed Central operates a commercially viable business as an open access publisher. Under our publishing model, the costs associated with research publication are covered by open access publication fees rather than by subscription revenue. We now publish over 200 online journals operating on this model. These journals go from strength to strength, and are highly ranked by 3 journal citation metrics such as Impact Factor. Open access journals such as Genome Biology, Malaria Journal and BMC Systems Biology, to name just a few, are among the most highly- ranked journals in their respective fields. The success of BioMed Central’s open access journals provides important evidence that immediate open access to the official and authoritative version of published research results is not only desirable but is also achievable and sustainable. The success of the open access model is especially notable given that, until recently, in contrast to the substantial library budgets devoted to subscriptions to serials, there has been little funding explicitly allocated by academic institutions to cover open access publication fees. Authors have therefore had to make direct use of their research grant funding in order to publish in open access journals. The Compact for Open Access Publishing Equity is an important recent initiative, involving Harvard and other leading research universities, which seeks to address this disparity by providing central institutional funding support for open access journals. This can be expected to add to the already considerable momentum driving the growth of the open access publishing model. BioMed Central supports both the goal of open access and the goal of ensuring that the value added by publishers is properly recompensed. In contrast to some of the contributors, we do not feel there is a need to ‘balance’ these two goals as we do not feel that they are in opposition. As noted by other participants in this debate, the benefits resulting to the scientific community from open access to research are substantial. What may be less obvious is that open access need not threaten the role of STM publishers. The open access publishing model, in which publishers are paid directly for the service of publication, is proving in practice to be just as viable a business model than as the traditional model whereby publishers recover the costs associated with publication by taking exclusive rights and then selling access via subscriptions. Given that there is a viable business model for publishing scholarly research that does not depend on restricting access, we do not feel that the US government needs to arbitrarily limit the extent and reach of its open access deposit requirements attached to its research funding. We therefore recommend that the mandatory Public Access Policy which has operated successfully with respect to National Institutes of Health funding since 2008, be extended to cover all federally funded research. We also recommend that consideration is given, over time, to reducing or eliminating the 12 month embargo period, because this embargo period covers the very period during which the results of research are most timely and valuable. Gradual reduction of the embargo period would provide a natural mechanism to encourage publishers to adopt business models compatible with open access, while avoiding disruptive upheaval. About BioMed Central BioMed Central (www.biomedcentral.com) is the world’s largest open access scientific, technical, and medical (STM) publisher. All research articles published by BioMed Central are peer reviewed and are made freely and permanently accessible online upon acceptance. In 2009, biomedical scientists from across the globe submitted over 29,000 research papers to BioMed Central’s 205 journals, a 30% increase over 2008. 4 Research articles published in BioMed Central’s journals are universally and freely accessible via the Internet without charge or any other barrier to access; articles are immediately deposited and permanently archived in multiple international archives (including PubMed Central) and authors retain copyright of their article, which can be freely distributed and reused under a Creative Commons as long as correct attribution is given. Like many other open access publishers, BioMed