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Friday, March 30, 2007

AAP response to NIH call for an OA mandate

The Association of American Publishers (AAP) has publicly released its March 26 letter to Senator Tom Harkin, Chairman of the Senate subcommittee that funds the NIH.  This is the AAP's response to last week's appearance by NIH Director Elias Zerhouni before the same subcommittee.  Zerhouni testified that the NIH policy should be strengthened from a request to a requirement.  Excerpt:

...We are concerned that a change to the existing NIH policy will negatively impact the private sector funded peer review process and will adversely impact many publishers, including non-profit scientific and medical societies who depend on subscription revenue from their journals to fund many important programs. We believe that the voluntary policy remains the best approach and respectfully request that the Subcommittee not direct NIH to change its public access policy.

In contrast, a public-private partnership with NIH under a voluntary policy can accomplish the goals of the NIH Public Access Policy without undermining scientific discovery or competing with the marketplace....

A mandate that articles be deposited to PMC disregards the complexity of scholarly publishing and imposes a “one-size-fits-all” approach on a diverse community of commercial, non-profit and scientific and medical society publishers....

The 10 to 15 percent figure referenced by Dr. Zerhouni does not appear to reflect the increasing deposit rate resulting from Elsevier’s direct deposit program. Based on an assessment of articles on PMC as well as publisher deposits, we believe that deposits with NIH on a current basis have increased well beyond the 10 to 15 percent rate referenced. If NIH agrees to work with additional publishers who wish to begin depositing on behalf of their authors, as does Elsevier, the deposit rate will continue to increase exponentially....

In responding to your question regarding the policy’s timeframe, Dr. Zerhouni indicated the 12 month timeframe was necessary to prevent damage to peer review. We strongly agree with Dr. Zerhouni on that point. However, we do not agree with his characterization that the 6 month timeframe would not be a problem for most journals, only those who publish less frequently. A recent study by the Publishing Research Consortium which examined librarian preference for free content found that with a six months access delay, 57% of librarians said they would opt for the free content in place of a paid subscription. Many said they would opt for free content even at 12 months....

Another issue I wish to call to your attention is the mission creep of the NIH program beyond the initial goal of Public Access. NIH’s intent goes well beyond simply posting articles for Public Access. NIH is adding extensive electronic tagging and often reentering text which requires further author review of processed manuscripts. These are among the very tasks that publishers have already performed and paid for. NIH is spending scarce taxpayer resources on duplicate processing in order to compete with the private sector with enhanced versions of articles already published....

Voluntary publisher engagement will be much more effective at making the policy a success than NIH attempting to micromanage 65,000 individual scientific researchers and their publishing output....

To implement and enforce a mandatory public access policy would significantly increase NIH’s administrative and technology costs, thereby diverting much-needed funding from the groundbreaking research that NIH funds and from which our country benefits....

Comments.

  1. The AAP fought tooth and nail against the current voluntary policy at the NIH.  Now it's trying to boost compliance with the voluntary policy in order to head off pressure to impose an OA mandate.  Either it believes that it can help bring compliance with a voluntary policy up to about 100% or it doesn't.  If it does, then it shouldn't object to a mandate, which will bring about the same result more quickly and easily.  If it doesn't, then it's arguing in bad faith and supports the voluntary policy precisely because it will never work as well as a mandate.
  2. We are concerned that a change to the existing NIH policy will negatively impact the private sector funded peer review process.... As usual, the argument fails to mention that OA journals provide peer review and that subscription-based journals have suffered no cancellations attributable to OA archiving in physics, the field with the highest levels and longest history of OA archiving. More, the American Physical Society (APS) and the Institute of Physics Publishing Ltd (IOPP) even host their own mirrors of arXiv.
  3. A mandate...disregards the complexity of scholarly publishing and imposes a “one-size-fits-all” approach on a diverse community of...publishers.... The idea is to serve researchers and those (like medical patients) who depend on research, not to serve publishers.  I don't see why the public interest in advancing research should be compromised to different degrees in different niches in order to treat different kinds of publishers differently.  But if it must be done, it can be done by tweaking the embargo period, not by abandoning the mandate.
  4. A recent study by the Publishing Research Consortium.... As I've often pointed out, the PRC study looked at hypothetical preferences of librarians, not actual cancellation decisions, and it disregarded faculty input on cancellation decisions when all librarians admit that faculty input is decisive.  Less hypothetical studies, like Mark Ware's March 2006 study for ALPSP, show that high journal prices far surpass OA archiving as a cause of journal cancellations.
  5. NIH is adding extensive electronic tagging and...spending scarce taxpayer resources on duplicate processing.... Yes, the NIH enhances deposited manuscripts before disseminating them (details here and here).  Most of these enhancements take the form of links to relevant parts of OA databases, usually other NIH-funded databases.  This does not duplicate anything that publishers are already doing and it helps researchers take full advantage of existing publicly-funded resources and therefore increase the taxpayers' return on investment. 
  6. Voluntary publisher engagement will be much more effective at making the policy a success than NIH attempting to micromanage 65,000 individual scientific researchers and their publishing output.... This is a false dilemma.  Like any other funding agency, the NIH already has individual contact with each of its grantees, and deals with them separately when receiving and evaluating their final work.  To require deposit in PMC as part of the report-submission process is a negligible addition to this work and even helps to streamline it.  The AAP argument can be reversed:  it's much easier and more effective to require deposit in PMC than to work indirectly toward the same goal with a shifting coalition of publishers of wavering resolve.
  7. To implement and enforce a mandatory public access policy would significantly increase NIH’s...costs, thereby diverting...funding from...research.... This old argument is always repeated in the same form and never responds to the answer, which is that the cost of the NIH program is about 0.01% of the agency's budget ($2-4 million/year, depending on the compliance rate, out of a $28 billion/year budget).  The question is not whether the program has expenses but whether 0.01% of the budget is a good investment to insure that the research funded by the rest of the budget is as useful as it can be and available to everyone who can make use of it.