It’s been hard to turn to email, chats, Twitter, or any of my other informational feeds since Thursday and not hear an analysis or opinion about the OSTP Policy Memo (a.k.a. the Nelson Memo) that came out last week. The subject? Ensuring Free, Immediate, and Equitable Access to Federally Funded Research. Now that’s going to get attention!

While the language is soft in places, using words like “recommends” and “should” and perpetuating the term “public access”, the memo is a push to open — and its intention is clear.

So we quickly asked the Chefs: What are your initial thoughts about the OSTP policy announcement?

(The Chefs had a lot to say about OSTP so this is Part I of a two-part post.)

Tim Vines: Being an Open Data enthusiast, my initial thought is ‘Wooohooo!’. I’ve been telling anyone who’ll listen that governments will one day mandate sharing of data produced by their researchers and are very likely to push responsibility for enforcement onto journals. And that day has just drawn a lot closer.

For comparison, the Holdren Memo (section 4) is very general about data (“digitally formatted scientific data resulting from unclassified research supported wholly or in part by Federal funding should be stored and publicly accessible”), whereas the Nelson memo (section 3.b.i) goes directly to:

“Scientific data underlying peer-reviewed scholarly publications resulting from federally funded research should be made freely available and publicly accessible by default at the time of publication”

This approach makes a lot of sense: only journals have consistent access to manuscripts that can still be changed to incorporate complete data sharing statements. Journals also have a clear ‘moment of attention’ (do ‘X’ or we won’t publish this manuscript) when authors can be compelled to comply with a funder data sharing policy.

A potential workflow would see journals pass ‘in review’ articles to a third party to assess compliance with the relevant funder policies, and the authors told what they need to do to comply. Having article-level compliance monitoring also sidesteps a major point of contention for these policies: defining what datasets should be shared. We could (and let’s face it, probably will) labor for years to draw up detailed guidance for every conceivable type of data and study, and still researchers would complain that the advice didn’t apply to their particular situation. With article-level compliance monitoring one can just formulate a broad policy and use the article-level report to tell authors exactly which data (and other outputs) they need to share to comply with the policy; everyone – funders, journals, researchers – is then clear about what needs to be done.

…the Nelson memo doesn’t mention additional resources being made available to support the new approach to OA articles and data. Nonetheless, it makes clear sense for funders to cover the costs of promoting compliance with their policies.

As the excellent Clarke & Esposito summary notes, the Nelson memo doesn’t mention additional resources being made available to support the new approach to publicly accessible articles and data. Nonetheless, it makes clear sense for funders to cover the costs of promoting compliance with their policies. For example, the National Institute of Neurological Disorders and Stroke had a 2021 budget of $2.7 billion, which generated on the order of 10,000 published articles. That’s probably all that the money generated: most of the datasets, code objects, protocols, and new lab materials associated with the articles are still hidden away on lab computers. Getting all of those outputs onto public servers and linked into the scholarly infrastructure to maximize their discoverability seems mission-critical for funding agencies and would be possible for less than the 5% of budget that Barend Mons recommends that funders put aside to promote open data. (Interestingly, the Economic analysis that accompanies the Nelson memo also cites this Mons article).

Another bit of good news is that non-government funders have made a lot of progress on promoting open science with article level monitoring already, with Aligning Science Across Parkinson’s recently released Blueprint for Collaborative Open Science being a particularly good example.

One other thought: the Memorandum also states that the OSTP will remain neutral with respect to business models, but I think they could achieve a lot by trying to move away from APCs.

APCs heap the costs of handling and reviewing all submitted articles onto the authors whose articles get accepted, while authors whose articles are reviewed and rejected pay nothing. Authors from countries with high acceptance rates (e.g. the US) thus pay for the peer review of articles from countries with lower acceptance rates. Chinese research output has grown spectacularly over the last few decades but the quality remains very variable. A substantial fraction of APCs paid by the US taxpayer thus goes toward reviewing (and rejecting) Chinese articles; it seems high time for the Chinese funding agencies to pick up these costs themselves.

The OSTP could instead recommend that US funding agencies replace APCs with the submission + publication fee model, which ensures that they pay only for the peer review and publication of articles with US based authors.

The OSTP could instead recommend that US funding agencies replace APCs with the submission + publication fee model, which ensures that they pay only for the peer review and publication of articles with US based authors. Journal revenues would remain the same, but the publication costs for the US taxpayer would probably halve, if not more (particularly since US researchers tend to publish in high impact journals where the ratio of APCs to submission + publication fees is highest).

Robert Harington: I was taken by surprise – perhaps I should not have been – but surprised I am.

The first words that formed in my brain were “Well I never…”, followed by a classic quote from Monty Python’s Flying Circus:

“We interrupt this program to annoy you and make things generally more irritating.”

It is almost as if there was a decision to kick the hornets’ nest and just see what happens.  In this day and age, who needs to consult with stakeholders to see what sustainable open policies should look like?

What’s done is clearly done. However, I can’t stop myself ruminating over how startling it is that a policy mandate like this was crafted without trying to engage with the hard questions it raises, with an apparent lack of understanding of discipline culture, the role of stakeholders such as scholarly societies, and the effects on research itself.

There is no question that all stakeholders in the publishing ecosystem — researchers, funders, institutions, libraries, and scholarly societies — understand that a move to equitable and inclusive open research and open access publishing is necessary.

There is no question that all stakeholders in the publishing ecosystem — researchers, funders, institutions, libraries, and scholarly societies — understand that a move to equitable and inclusive open research and open access publishing is necessary. What is not so clear is how this may be done in a sustainable way. This latest mandate to US Federal funding agencies to develop new (or update existing) public access plans is laudable, but leaves out how this will be paid for. It also pays no heed to scholarly societies who rely on publishing revenues, but, depending on the field of endeavor, may have communities that are unable to pay an APC. There is scant mention in the OSTP memorandum of costs:

“In consultation with OMB, federal agencies should allow researchers to include reasonable publication costs and costs associated with submission, curation, management of data, and special handling instructions as allowable expenses in all research budgets.”

Does this mean that funders are committed to providing more money in their grants to cover the costs of publication? There is no mention of increased levels of funding. In some communities, such as mathematics, funding is relatively low, and what monies there are go to supporting the research itself rather than article processing charges (APCs). Nor is there mention of the suppressive effect that the need to pay for each article will have on authors’ willingness to publish – particularly junior researchers who might otherwise usefully exploit the data produced by research with spin-off work, but who might have limited access to monies to cover the APC.

The American Mathematical Society (AMS) is already experimenting with open access models. Our Green OA policies apply to peer reviewed author final manuscripts. Our Gold options are free to AMS members – little take-up among non-AMS members. Our new flagship journal, Communications of the AMS, is Diamond open access – free to publish in, and free to read, with Creative Commons reuse licenses attached. We are members of CHORUS, and as such comply with existing Federal funder mandates.

It is too early to say how this will play out of course. I do worry that for mathematicians in particular, an unfunded mandate of this sort may place undue burden on researchers.

David Crotty: Publishers who have been paying attention generally assumed that immediate public access to papers and open data requirements were in the pipeline, and that it was a matter of when rather than if. With these policies released, timelines are set, and planning that was hopefully in place can be accelerated.

It is noteworthy that this is a set of policies written with seemingly little input from publishers nor the same level of consultation with key stakeholders as was undertaken for the Holdren Memo. The fact that this is now the second consecutive US administration that chose to craft research publishing policy in this manner speaks volumes about the poor relationships between the research publishing industry (particularly the industry’s advocacy organizations) and the federal government.

The financial impact report sent by the OSTP to Congress includes some significant leaps in logic due to inadequate information. There are several acknowledgments in the report about the lack of available data that a more thorough research process should have surfaced (e.g., actual publisher data on what it costs to publish a paper from EMBO, or from PLOS, as just two of many examples). Had this administration’s policymakers reached out more broadly to publishers, necessary information would have been readily available and more accurate projections could have been made without relying on questionable sources. The OSTP cites a “study” to back up a point about the cost to fund “long-term management of public access to research results and data,” which is actually not a study at all, but rather an editorial opinion piece. In one case, an out-of-date quote in a news article, from before the launch of illuminative library tools like Unsub and COUNTER 5, is used to claim that libraries won’t cancel subscriptions due to the availability of free materials. We know that these tools are being promoted to libraries for this purpose, and the long list of subscription cancellations available from SPARC suggests they are effectively being used.

The Nelson Memo outlines an ambitious policy agenda. Careful planning, and a clear-eyed understanding of likely secondary effects and unintended consequences will be required if it is to succeed.

There is also no analysis of the economic impact of the open data policy in the document sent to Congress. Open data requirements are a much bigger undertaking (with potentially greater upside) than policies toward public access to research papers. To be effective, such policies will require extensive infrastructure, ongoing maintenance and improvements, data-type and associated metadata standards, and significant cultural change within the scientific community. The Nelson Memo calls for agencies to develop plans to eventually archive and make public all data resulting from federal funding, rather than just the tip of the iceberg of data associated with published papers. A bio-imaging lab or an astronomy research group can churn out terabytes of data every single day. Organizing and perpetually storing those data to meet FAIR principles is not a task to be underestimated. I note that above my colleague Tim Vines, using the OSTP’s favored 5% figure, suggests that it would cost $135M per year to make available the data from one sub-agency of just one of the many agencies under these requirements, which then runs out to $8.25B annually for the 2021 federal research budget of $165B.

If even close to accurate, that’s certainly not a figure to gloss over when considering economic impacts and vastly higher than the likely costs to be seen for public access to papers. As one of the authors of a Day One Project proposal for a federal open data policy, I can vouch for the importance and value of open data, but also the complexity involved and the unlikelihood of success with no additional funding and an abbreviated timeline.

The Nelson Memo outlines an ambitious policy agenda. Careful planning, and a clear-eyed understanding of likely secondary effects and unintended consequences will be required if it is to succeed. As with the Holdren Memo before it, policy documents like this are deliberately vague – they offer a set of requirements and the actual details and implementation are pushed to the funding agencies to figure out. The opportunity to bring some real-world data and an understanding of how best to proceed will hopefully happen as the agencies put together their plans.

Tao Tao: Since this federal policy guideline was announced, everyone is talking about its impact, which obviously will not be confined to the United States. One cannot help but wonder how the other governments will react. For example, will the Chinese government announce a similar policy soon? In my opinion, that won’t happen. For a country that publishes as heavily as it reads, the government’s approach toward open access is continuing to develop.

Only a few years ago, the attitude toward open access was still ambiguous. When a Chinese committee announced, at a publishing meeting in Berlin, full support of Plan S, it was the first official voice from a major Chinese funder to support the bold EU open assess policy. Even then, I heard Chinese STM publishers saying that the OA advocates are librarians, and that they don’t represent us. Back then there were also many popular posts describing open access journals as predatory journals.

But in the last few years, the attitude has quietly changed. The criticizing voices have almost disappeared and there are now many webinars discussing open science which are either organized or sponsored by the government. Still, while the government’s attitude may no longer be ambiguous, a nation-wide mandatory OA policy is unlikely to happen soon.

…less than 5% of Chinese papers are published in journals owned by Chinese publishers. This OSTP policy announcement adds urgency for China to develop its STM publishing.

For Chinese authors, while publishing OA may be more accepted and encouraged than before, a journal’s publishing model has never been much of a concern compared to its impact. We can expect that, with this US mandatory OA policy, more publishers will accelerate their transition to open access, and China’s spending on publishing will inevitably increase. There is just one problem: less than 5% of Chinese papers are published in journals owned by Chinese publishers. This OSTP policy announcement adds urgency for China to further develop its own STM publishing ecosystem. The quote “publishing papers in the motherland” has been accepted more than questioned. I will not be surprised if this new policy leads to stronger plans to drive the development of Chinese-owned journals.

Alison Mudditt: My initial reaction? AT LAST!! I don’t mean to dismiss the genuine challenges that the new policy presents for some (the humanities and society publishers, to name two obvious ones) but I’m confident that my fellow Chefs will do more than justice to those. This is a big win, not only for OA advocates but also for equitable access, trust in research, and scientific progress. For me, open access is at the core of a sustainable, equitable, and inclusive open science future.

This a big win, not only for OA advocates but also for equitable access, trust in research, and scientific progress. For me, open access is at the core of a sustainable, equitable and inclusive open science future.

The most important benefit is free and unfettered access to research. It still matters in the Global North at a time when research is more critical than ever. The number and scale of domestic and global challenges is unprecedented; broad access to trustworthy research is non-negotiable if we’re to address these successfully. The inclusion of data will increase the impact of the policy and facilitate understanding of the reliability and robustness of findings, and also the trustworthiness of science (as in “we’re prepared to share evidence of our claims”). I also hope that this will spur innovation here given the number of challenges involved in making data truly FAIR.

The inclusion of data will increase the impact of the policy and facilitate understanding of the reliability and robustness of findings, and also the trustworthiness of science (as in “we’re prepared to share evidence of our claims”).

And in spite of the progress we’ve made over the past two decades, open access still matters across lower and middle income countries. They are currently bearing the brunt of problems created by the Global North – whether the climate crisis, environmental degradation, or the war in Ukraine. Meeting these challenges starts with open and immediate access to the research literature.

My main quibble: I do wish that there was mention of business models beyond endorsement of the green route. Instead, the mechanism by which public access is to be achieved if left to the individual agencies. There is a not insignificant risk of a default to gold and further entrenchment of the big commercial players. But for now, I’m letting my inner optimist shine through and believing that the new policy will spur long overdue innovation in this arena (especially given that the policy focuses on the importance of equity in implementation).

The Chefs had so much to say that we are publishing the remaining responses tomorrow. In the meantime, please join the discussion in the comments!

What are YOUR initial thoughts about the OSTP policy announcement?