Response to U.S. Open Access RFI - #OAintheUSA

The U.S. Office of Science and Technology Policy (OSTP) recently issued a Request for Information on “Public Access to Peer-Reviewed Scholarly Publications, Data and Code Resulting From Federally Funded Research”.

Responses were due in by end May 6 2020. I have posted my response below:

“To whom it may concern,

I am a private individual and American taxpayer who regularly requires access to federally-funded research for my work on the American STEM workforce and STEM education. For example, I have served as a member of the National Academies of Sciences, Engineering and Medicine study, the “Next Generation Researchers Initiative”, mandated under the 21st Century Cures Act of the U.S. Congress. 

Currently, in order to access federally-funded research before the current 12-month embargo period, I must first attempt to request these materials from the original authors in an individual and laborious process. More frequently I have had to resort to a website that illegally provides PDFs to these published articles. The site in question is run by an individual currently being investigated by the U.S. Justice Department for Russian Intelligence links. This site, used by myself and many others seeking access to this work, is not the ideal location for the American taxpayer to access research articles that they support.

I am able to speak here from my perspective as a former postdoctoral researcher funded by the American taxpayer, the former manager of a non-profit organization and as an individual currently running a sole-proprietor LLC. At all times in my career, I have faced barriers to accessing American taxpayer-funded research, even during my time as an American taxpayer-funded researcher, as access to research is based on institutional subscriptions to certain journals. In my work I have also learned of the barriers faced by patient advocates, citizen scientists, and even students at American educational institutions. The system currently in place is a hindrance to science, and the work and education of Americans.

I am therefore in full support of OSTP and SOS efforts to increase access to unclassified published research, digital scientific data, and code supported by the U.S. Government at the point of publication or release.

What current limitations exist to the effective communication of research outputs (publications, data, and code) and how might communications evolve to accelerate public access while advancing the quality of scientific research? What are the barriers to and opportunities for change?

The major barrier to change is a political one. Under the current system a number of organizations rely on revenue from publishing to sustain their business models. OSTP has already received letters from a number of these organizations coordinated by U.S. scientific societies, the Association of American Publishers, and the International Association of Scientific, Technical and Medical Publishers.

These actors consider any changes to the current system as an extreme threat to their business model. I argue that the correct moral, educational and innovative move is to make research products free at the point of production.

As an American taxpayer, and a researcher supported by taxpayer dollars, I have had the privilege of viewing scientific publishing as both an author and reader. The current publication system can act as an hindrance to scientific research and innovation. A focus on profit and maintaining an artificial scarcity of publication space (based historically on print, now largely irrelevant in the Internet Age) has resulted in a lengthy and inefficient process, where it can take years to publish research, which in turn holds up the careers of American-funded trainee scientists. As a reader, I have at every stage of my career both in the academy and outside it faced paywalls and barriers to research that I and others support through our taxes. Most scientists in the U.S., like myself, are not at academic institutions, and so a system that allows science only to be shared within academic institutions (and even then, only at institutions that can afford to buy into publishing subscription cartels) hinders both American innovation and education. 

It is understandable why publishing organizations are attempting to establish their financial priorities as American priorities, over public and scientific interests. In the case of for-profit publishers, of course because of the income this model generates. But I would like to here highlight the case of “scientific”, or rather academic, societies, which has been taken as the stronger moral argument against releasing research products.

These organizations are in effect academic societies because they are run by senior academics, not scientists representative of the field. They represent the interests of not only a minority of scientists (most scientists are outside the academy) but also a minority of academics, having in most cases no representation from: students, postdocs, early career faculty or faculty from teaching-focused or minority-serving institutions. It is from the perspective of a senior faculty at research intensive institutions that their statements should largely be considered. 

Such societies will claim that they are lobbying on behalf of their membership. As someone who was, but is now no longer, a member of some of the societies who wrote in opposition to public access to federally-funded research (e.g. December 18 2019 letter to President Trump), I can testify to the absence of my opinion or input to their advocacy, but the use of my membership to provide a mandate to you for it. Indeed, it should be pointed out that one reason academic societies are concerned about losing publishing revenue is that they are already losing membership revenue, despite the ever-increasing number of scientists in the U.S. This could in part due to the very lack of representation of early career researchers and their interests in their organizations, many of whom may simply join as part of a reduced registration for the society’s annual conference.

Not only are the leadership of academic societies considered about the society staying financially solvent, but their leaders may also resent being required to pay for open access costs from grants awarded to them on behalf of the taxpayer, which I often hear them refer to as “their” money. Instead it is preferable to them that the taxpayer still pays the cost of publication through indirect/F&A costs on grants paying for university library subscriptions to journals. In this way we taxpayers pay for other researchers to read papers, but still have no access ourselves. 

I would like to specifically refute claims in the letter from academic societies to the President dated December 18 2019. Societies have opposed attempts to open access to research for decades, and opportunities for them to constructively change their business models have been squandered in favor of resisting change that would be of benefit to many in their fields and membership. They argue, for example, that the funds generated by publishing aid them in supporting diversity and education efforts. But while they may use these funds to offer travel grants to students at American educational establishments, such as the University of Puerto Rico, they are at the same time depriving students at such institutions of their ability to access federally-funded research. This is because a number of institutions cannot afford to pay into publishing cartels. One could even argue that the society is undermining its own work by providing a greater hindrance to their scientific education and careers membership in the society can provide. 

They claim in the letter that moves to release research earlier would “upset the current proven and successful model for reporting, curating and archiving scientific results and advancing the U.S. research enterprise” and that “this current system allows scientific societies to meet the needs of researchers and U.S. taxpayers“. As both a researcher, and a U.S. taxpayer, I would argue to you that it does neither, and that the current system is in great need of reform. 

I would point to the fact that many other societies have chosen not to participate in opposing reform. They are likely more forward-thinking and innovative. It does not seem appropriate for the federal government to provide handouts to academic societies who are unable to adapt to changing times and help themselves.

Arguments have been made in favor of the proposed move in letters by members of the Scholarly Publishing and Academic Resources Coalition and coordinated by the American Libraries Association. I commend their letters and arguments to you, and they have my full support. As they are stewards of knowledge, I feel it is librarians, and not the scientists whose careers, societies and funding depend on the publication industry, that should provide the guiding principles in your steps forward.


What more can Federal agencies do to make tax-payer funded research results, including peer-reviewed author manuscripts, data, and code funded by the Federal Government, freely and publicly accessible in a way that minimizes delay, maximizes access, and enhances usability? How can the Federal Government engage with other sectors to achieve these goals?

Repositories such as PubMed provide a model for collating and distributing peer-reviewed articles. A government-owned preprinting service that is responsible to the taxpayer may also provide faster dissemination of results; currently preprinting is largely in the domain of the private sector and so is liable to either financial instability, or restrictions on community-based control and accountability.

This could also be an opportunity to link papers, research products and data with individual researchers through assignment of an individual number, or use of existing numbers such as ORCID. This can assist in not only helping collate data and research, but could provide a much-needed method of following individual researchers and their careers, which is not currently adequately undertaken.

How would American science leadership and American competitiveness benefit from immediate access to these resources? What are potential challenges and effective approaches for overcoming them? Analyses that weigh the trade-offs of different approaches and models, especially those that provide data, will be particularly helpful.

Currently, a financial barrier exists to accessing taxpayer-funded published research products in America and while there are a number of organizations and individuals able to circumvent this barrier, anytime you put any kind of obstacle in the way of accessing information, you restrict some number of people from accessing it. I have experienced this even as a postdoc in Boston, as not all university libraries subscribe to all journals. And indeed, a large proportion of the use of illegal paper-sharing websites is that they simply provide a PDF in fewer clicks or with fewer website redirections than legitimate sites. 

Any barrier will hinder American competitiveness and leadership in science, and access to information has become restricted to those with access to the resources. It is already well-documented that there are too many researchers to be accommodated by American universities. So preventing Americans who aren’t able to fit into the employment ranks of such institutions from also accessing research exacerbates the loss of talent that America already suffers from. If America truly wants to fuel innovation and entrepreneurship, an obvious basic step is providing all talented and aspiring Americans with easy access to research and innovation resources such as already published articles.

Free access to taxpayer-funded research products is therefore necessary, and models that do not necessitate private internet access would be helpful. For example, providing access to research products at public libraries, and in a way that also makes such products accessible to Americans with disabilities, could be factors under consideration.

Provision of data also requires that clear data standards be provided for sharing, to make data (and associated metadata) as clearly interpretable as possible, and facilitating use by as many people as possible. Clear and enforced standards in sharing and reporting data will be extremely helpful to research under current circumstances - with many people in transient or contingent positions in the academy there is already an issue that poorly annotated or standardized data is useless once the only person who knows what it meant departs from the project. There are organizations considering standards for publication of such data and a multi-stakeholder and interdisciplinary group could be gathered to provide a basis for such guidelines now, and for possible future data types.”

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