[OAI-eprints] Critique of PSP/AAP Critique of NIH Proposal

[Stevan Harnad]

        ** Apologies for cross-posting **

This is a very detailed critique of the critique of the NIH Public Access
Proposal by the Association of American Publishers (AAP) and Professional
Scholarly Publishing (PSP). It contains many basic points that NIH
can use to support its proposal against the points made by AAP/PSP.
A highlighted MS Word version is attached too.

The public comment period on the NIH proposal ends
on November 16, 2004. If you agree with this critique
(or if you don't!) please let NIH know, using the form at
http://grants.nih.gov/grants/guide/public_access/add.htm 
or e-mail your comments to PublicAccess at nih.gov

    NIH/Open Access -- Grassroots Memo 
    http://www.pspcentral.org/publications/grassroots_email.doc

PSP/AAP wrote:

>   NIH Director Dr. Elias Zerhouni has announced his intention to
>   implement a policy by the end of the year that will require NIH
>   grantees to place in a central repository the final, corrected
>   manuscripts of their articles upon acceptance by peer-reviewed
>   journals. Such deposited articles would then be made freely
>   available within six months after publication, accessible via
>   PubMedCentral, the operation of which NIH proposes to expand
>   as a government-run repository for the open dissemination of
>   any publications that emanate from NIH-funded research.
>
>   The NIH proposal can be found at the following URL:
>   (http://grants1.nih.gov/grants/guide/notice-files/NOT-OD-04-064.html).
>
>   [There are]  unintended negative consequences of its implementation
>   upon the integrity and sustainability of existing journals, and
>   upon the diverse professional bodies whose scholarly and
>   publishing activities are intertwined.

The *positive* consequences of the NIH proposal -- free supplementary public
online access to publicly funded research findings for all their would-be
users, regardless of whether they or their institutions can afford the
paid access to the journal in which the findings are published -- have
already been tested for over a decade and are demonstrated: Research
progress and productivity will be enhanced by free online access, and
so will research applications to the public good.

    http://opcit.eprints.org/oacitation-biblio.html   
   

All talk about *negative* consequences, in contrast, is merely
hypothetical, in the face of counterexamples, the absence of any
supporting evidence, and the existence of very obvious counter-hypotheses
about how the system would evolve quite naturally to avoid any negative
consequences. See for example:
http://www.earlham.edu/~peters/fos/nihfaq.htm#subscribers

(If and when free access to the online supplementary versions should
ever deplete the demand for the journals that publish the original
version, then the windfall savings of each university -- now no longer
paying for incoming journal subscriptions -- will be more than
enough to cover the journal publication costs for all of the outgoing
articles by its own researchers. Widespread subscription cancellations,
however, are still far away; most libraries still want the journal's
paper and online editions. The benefits of free public online access
to research, however, need not wait for any hypothetical future
outcome like this; those benefits are certain, not hypothetical.)

>   If left unchecked, the NIH policy could irrevocably disrupt the
>   system of scholarly discourse that has served the scientific
>   and medical communities honorably for hundreds of years...

Free public online access to research will surely help both research
and the public. If and when the availability of the free public-access
supplementary versions should ever cause cancellation pressure on
the subscription-based journal versions -- and this is all pure
speculation now, as there has as yet been no cancellation pressure
from the public-access supplements to date, even in fields of
research where public-access supplements have reached 100% for some
years -- there will be cost-cutting and the phasing out of any
inessentials (e.g., the paper edition) for which there is no longer
a market. And if and when the time should ever come for the remaining
irreducible publication costs to be paid by the author-institution
instead of the user-institution, there will be more than enough
corresponding institutional windfall savings to cover them. The
system can adapt naturally and gradually to free public online
access, without any "irrevocable disruptions."

>   If implemented, the NIH policy will harm societies, publishers,
>   authors, and libraries, scientific discourse and scholarship,
>   without accomplishing its stated objective to provide access
>   to medical information in a way that can truly help patients.

The aim of providing free public online access is to provide free
public online access, and it is met by providing free public online
access -- for all would-be users: researchers building on the research,
doctors applying it, and patients informing themselves about the
potential applications to themselves. 

It is obvious how authors, scientific discourse and scholarship benefit
from this. Whether libraries will benefit is a matter of speculation,
but if and when they ever do, their own windfall savings will be more
than enough to pay publishers' remaining costs.

>   Because articles retain significant value beyond six months,
>   the demand for centralized open archiving six months after
>   publication would likely cause some customers to cancel their
>   subscriptions and wait for free access.  This knock-on effect
>   on subscription and license renewals within the global library
>   marketplace  would give some publishers little choice but to
>   enact author fees to compensate for lost revenue and cover the
>   costs of publication.

This is merely speculation once again, as there is no evidence for
cancellation pressure from supplementary free online-access versions
to date (and particularly after a 6-month delay!). Moreover, a mild drop
in demand would be more likely to have the usual effect of acting as
a stimulus for cost-cutting for better cost-effectiveness by trimming
inessentials and adapting to the new online medium, rather than
price-raising to preserve the status quo. Author fees would only be
pertinent if and when cancellation pressure were ever to become so great
as to make it impossible to recover the remaining costs --  which is
another, still bigger speculation, based on no evidence to date.

>   At present, the NIH policy makes no funding provisions for such
>   author fees, yet risks undermining the economic foundation of
>   established journals in favor of an unsubstantiated open access
>   agenda.

The NIH proposal is neither to mandate nor to fund a transition to
open-access journal publishing or the author-institution-end
cost-recovery model. It is a mandate to provide free public access
online so as to supplement subscription-based access for all those
potential users who cannot afford it. This access-provision proposal and
all of its certain benefits cannot and should not be rejected because
of speculations about hypothetical knock-on effects for which there is
no evidence, and for which there would be natural and highly probable
corrective adaptations, if and when the speculations should ever come
true.

>   Loss of subscription revenues from overseas publishing sales
>   will jeopardize US-based journals and their publishers and
>   societies, ultimately could force U.S. taxpayers to foot the
>   bill for open access by readers around the world...

This speculation is groundless: If and when the hypothesized
institutional subscription cancellations for incoming journals were
ever to occur, the resulting institutional windfall savings would
be more than enough to pay journals for the remaining costs of
publishing their outgoing articles. It is research institutions
worldwide whose subscriptions cover the costs of research journal
publishing today. If and when there should ever be this hypothesized
transition to author-institution-based cost-recovery, the worldwide
distribution of institutional costs would stay the same, without
any extra weight on US taxpayers. If anything, this hypothetical
transition would bring all institutions savings because of the reduced
publishing costs as a result of offloading all access-provision on the
online free-access supplements, and jettisoning the journal's paper and
online versions altogether. 

But this is pure speculation as there is no evidence whatsoever for
decreased subscription demand for either the journal's paper or online
edition in the face of the free public-access online supplement. All
evidence to date is for peaceful co-existence between the publisher's
subscription version and the author's free-access supplement, even in
fields where the free supplements have reached 100%.

There are physics journals whose articles have been made accessible
for free online in author-provided supplements since 1991, and for
some, 100% of their contents have been freely accessible in
this way for years now, yet their subscription revenues have not
eroded. The American Physical Society (APS) was the first publisher
to give its green light to author-provided free-access online
supplements. One physics journal -- Journal of High Energy Physics
(JHEP) http://jhep.sissa.it/ -- launched in 1997 as a (subsidised)
open-access journal, even successfully converted back to subscription-
based cost-recovery in 2002, by migrating to a
subscription-based publisher (IOP http://www.iop.org/EJ/journal/JHEP). All
of JHEP's contents remained freely accessible, before,
during and since.

>   and will provide a windfall benefit for those corporations and
>   institutions that now willingly purchase and benefit from (but
>   do not themselves produce and publish) original research.

The relevant windfall savings are those of the research-institutions,
and they will be more than enough to cover the irreducible costs
of publishing their outgoing articles.

>   The NIH has not clarified what total cost would be entailed in
>   implementing this government-operated repository; however, it
>   is clear that every dollar spent on this redundant publishing
>   activity means less funding for new research.

NIH is only proposing free public online access provision. The rest
is hypothetical. If the hypothetical cancellations ever occur,
cost-cutting, downsizing, and institutional windfall savings will
cover any redirection of the irreducible costs.

>   Beyond these economic concerns, the NIH policy would establish
>   a dangerous precedent by enabling government intervention that
>   would limit an author's freedom to publish how, when, and where
>   he or she chooses.

The NIH proposal has absolutely no effect on the author's choice
of journal: It merely requires that free public online access be
provided to the article.

>   A central government-operated open access repository could compromise
>   the integrity of the scientific record, could be subject to government
>   censorship, and would be susceptible to the politicization of science
>   and the vagaries of funding cycles and changes in agency management.

The NIH proposal is merely to provide free public online access to
NIH-funded research articles. It has no effect on the "integrity
of the scientific record" --  it just provides free public online
access to it. There is no "government censorship," just peer review,
by the very same journals, exactly as before. It entails no
"politicization of science," only free public online access to it;
nor is it in any way governed by "vagaries of funding cycles and
changes in agency management." It just provides free public online
access to NIH-funded research articles, published, exactly as they
are now, in exactly the same journals they are published in now.

>   The real issue being considered is not one of access, but of
>   who will pay for the cost of publication.

No, the real issue is access. The *hypothetical* issue is: who will
pay for the hypothetical costs if and when they can no longer be
paid the way they are paid now. And the hypothetical reply is: the
hypothetical costs will be paid out of the hypothetical windfall
savings.

>   The published scientific literature is routinely and readily
>   available to all who need and want it, through paper subscriptions,
>   online licenses, electronic pay-per-view, individual document
>   delivery, free interlibrary loan, paid sponsorship or philanthropic
>   donation of online access.

Free public online access is a supplement for all those would-be
users worldwide who cannot afford "paper subscriptions, online
licenses, electronic pay-per-view, individual document delivery."

Interlibrary loan is not free, and not available online (this is
all about online access). 

"Paid sponsorship or philanthropic donation" are not just hypotheses
but downright fiction for the would-be users in question. Statistics
on what proportion of the peer-reviewed research literature even the
richest universities today can afford to access are available from the
Association of Research Libraries. These show that even in the U.S. much
of this literature is inaccessible to much of its potential usership:
http://fisher.lib.virginia.edu/cgi-local/arlbin/arl.cgi?task=setuprank

>   Many publishers (including, but not limited to, the coalition
>   of 60 biomedical publishers that adhere voluntarily to the DC
>   Principles) already have made considerable amounts of original
>   biomedical research openly available via the Web.

Whatever articles are already publicly accessible online for free today
already conform to the NIH proposal, so it is not clear why they are
even being mentioned here. -- The proposal is obviously intended for
the vast majority of NIH-funded articles that are *not* yet publicly
accessible for free online today.

>   The promise of the NIH proposal, to deliver free access to
>   medical research so that US taxpayers can benefit from
>   government-subsidized research, sounds compelling at face value.
>   The fact is, however, that the NIH proposal is an unfunded
>   mandate that will not meet the information needs it purports
>   to address.

The research is publicly funded, hence the funder can mandate that
the research should also be publicly accessible online for free.
No further funds are required, and the mandate itself meets its
own stated requirements fully.

>   Questions the NIH Has Not Addressed
>
>   Does the NIH fail to acknowledge the value added by publishers?
>   By stipulating that authors should post their final published
>   articles on PubMedCentral, the NIH clearly recognize that the
>   unrefereed reports it receives from its grantees are not as
>   valuable as the peer-reviewed articles published in scholarly
>   journals. -- Yet the NIH proposal minimizes the substantial
>   investments and contributions of publishers in this process.

The NIH makes no judgment about value-added, it merely mandates
free public online access to articles based on the results of
NIH-funded research. Publishers can continue recovering their costs
as they always did. It is merely speculation that the NIH mandate
will cause cancellations, but if it ever does, it will thereby also
cause the corresponding institutional windfall savings from which
all essential values can continue to be paid for (in particular,
the cost of providing peer review).

>   We can work together to find a way to more effectively meet the
>   NIH's objectives without the government expropriating publishers'
>   investments and causing disruption to the entire fabric of
>   scientific communication.

The NIH's objective is immediate free public online access to
NIH-funded research articles for all would-be users. This objective
is met by making those articles publicly available online for free,
with or without an NIH mandate. As it is clear that publishers are
not themselves providing immediate free public online access for
all would-be users today --  and it is unlikely that they will do so
in the near future -- the NIH mandate is the only way to meet the
immediate objective.

>   What will be the impact on the many scientific and medical
>   publications and professional societies that rely on the
>   subscription income to pay for their operations? The NIH mandate
>   for open archiving six months after publication will have the
>   effect of forcing publishers to adopt author-paid models of
>   open access because it puts journal licenses and subscriptions
>   at risk of cancellation. The six-month stipulation will be
>   especially damaging for those journals with longer publication
>   cycles, those that support small specialized fields, or those
>   that publish more articles that stem from NIH-funded research.
>   This could cause the demise of many scientific and medical
>   publications and professional societies and, as a result, an
>   erosion of scholarship and professionalism in these fields.

This is all speculation, but if and when it should ever prove true
that free public online access generates cancellations, there will
be cost-cutting, downsizing, and the institutional windfall savings
to make a transition to covering the remaining irreducible costs
from author-institution-end payment per outgoing article instead of
user-institution-end payment per incoming journal out of the institutional
windfall savings.

>   Will the plan encourage censorship or politicization of science?
>   Would centralized government control over the provision of
>   public access to the results of NIH-funded research carry
>   necessary safeguards to ensure that access is not improperly
>   manipulated for political objectives or otherwise controlled
>   in conjunction with debates over public policy?

This in unfortunately just nonsense. The NIH proposal is to provide
free online public access to the peer-reviewed articles in exactly
the same peer-reviewed journals they are published in now. This is
peer review, not "censorship or politicization."

>   How will author-researchers be affected? How would implementation
>   of the NIH plan impact the rights of NIH- funded researchers
>   regarding articles they generate based on their research?

Authors will continue to submit their papers to the peer-reviewed journals
of their choice, exactly as before. Their papers will be peer-reviewed,
revised and accepted (or rejected), exactly as before. The only two
things that will change are (1) that all would-be users will now be
able to access, read, use, build-upon, cite and apply their findings,
not just those users whose institutions can afford to subscribe to the
journal version; and (2) the impact of the research findings -- the degree
to which they are accessed, read, used, built-upon, cited and applied
will be maximized -- http://opcit.eprints.org/oacitation-biblio.html --
and thereby also the progress and productivity of NIH-funded research.

>   How would it impact multi-author papers?

All authors would benefit from the maximized access, usage and
impact.

>   How would it impact the publication of results from research
>   funded by multiple sources in addition to NIH?

The other funders would benefit too, even though they have not yet
had the wisdom to mandate that the findings they fund should be
made publicly accessible online for free.

>   How would it impact academic freedom in the university research
>   and publishing settings?

Academic freedom? NIH-funded researchers continue to be free to do
the research they have been funded to do. They continue to be free 
(in fact they continue to be *mandated*!) to make their research findings
public, so they can be used, by publishing them ("publish or perish")
in the journal of their choice, but now the usage and impact of
their research will be maximized, by making a supplementary version
publicly accessible online for free for all their would be users.

>   Would authors of research papers continue to have the right to
>   make their own choices among journals or other venues of first
>   publication?

Of course. There is no mention of where NIH fundees should publish. That
continues to be entirely up to the researchers (and the peer-reviewers!).
The only change is that a supplementary version of all peer-reviewed
journal articles arising from NIH-funded research will be publicly
accessible online for free.

>   Will they have less money to spend on research if a portion of
>   their funding must be earmarked to cover the costs of publication?

The mandate is to make a supplementary version of peer-reviewed articles
publicly accessible for free online, not that they should be published
in any particular journal, with any particular cost-recovery model. The
speculations about a transition to author- instution-end cost-recovery
are merely speculations.

>   The NIH has gone on record saying it will not provide additional
>   funds to grantees to support these costs. Authors who cannot
>   afford to pay will be disenfranchised; others will be forced
>   to reduce the number of articles they publish.

Which costs? The costs being referred to here are hypothetical, contingent
on a speculation about the possible future course of evolution in
peer-reviewed journal publishing in the online age. The NIH proposal
concerns only the actual, not the hypothetical: actual articles, in the
same peer-reviewed journals that they are published in now, will have
a supplementary version publicly accessible online for free for all
its would-be users who cannot afford access to the journal version. No
disenfranchisement; no reduction in articles published; no additional
costs.

>   Is a central government-run repository the best approach? Will
>   it compromise the integrity of the scientific record? The NIH
>   policy advocates the transformation of PubMedCentral, which
>   currently houses content from only a small fraction of the
>   biomedical literature, into a huge central repository without
>   even looking at the alternatives.

Although there is much to be said for making the supplementary
versions of articles resulting from NIH-funded research publicly
accessible online for free by depositing them in the fundee's own
institution's repository (and having only its metadata harvested
by PubMedCentral), that is merely an implementational detail that
is neither relevant nor at issue here. Whether the free public
online access is provided by locating the text itself centrally or
institutionally is immaterial, as the access will be public and
free webwide either way.

>   Publishers have invested millions of dollars in digitizing their
>   content building a successful distributed aggregation network
>   of cross-linked journals, and the majority of STM publishers
>   worldwide now participate in CrossRef, a not-for-profit
>   collaborative enterprise (www.crossref.org) that uses a unique
>   and permanent system of identification, the Digital Object
>   Identifier, to facilitate reliability, authentication, and
>   discoverability via the web. The NIH should leverage this
>   successful and significant investment, rather than try to
>   "reinvent the wheel" with its own "one size fits all" solution.

The essential difference between the cross-linked STM journals, valuable
as they are, and the NIH proposal, is that the NIH proposal will make
the full-text articles publicly accessible online for free, whereas
the cross-linked STM journals are not publicly accessible online for
free. These free public-access supplements, however, need not
replace the enhanced journal version, for those users whose
institutions can afford it; they merely provide access for those
would-be users whose institutions cannot afford the enhanced journal
version.

Moreover, providing public access online for free was not invented
by NIH: The scientific community has been doing it for a decade and
a half now, and in some areas (such as High Energy Physics as well
as Computer Science) it has already been near 100% for a half decade.
The NIH proposal is intended to propagate and accelerate this
already existing practice (for which 92% of journals have likewise
already given their green light)..
http://romeo.eprints.org/stats.php 

>   Who will foot the bill for a central repository? Publishers
>   know from recent experience that the costs of developing and
>   sustaining a publishing platform that can handle the capacity
>   of the government-funded scientific output (including activities
>   such as collecting, converting, and archiving articles, hosting
>   the site, providing search capabilities, tagging and standardizing
>   files for retrieval, for example) will not be insignificant.
>   The NIH has not addressed the issue of operating costs, leaving
>   open the likelihood that the costs will reduce the funding
>   available for research itself or create an additional burden
>   for taxpayers.

The NIH mandate is not about a publishing platform, simply about
providing free public access online to already published articles.

Moreover, footing any bill would seem to be NIH's worry, not
publishers'. It may indeed be more economical for NIH to offload
the cost and burden of archiving the full-texts to each fundee's
own institution (not just to distribute the costs, but to propagate
the policy and practice of providing free public access online to
research that is not funded by NIH, across departments in institutions
and across universities). Distributed storage and central harvesting
of interoperable metadata is much more congruent with the nature
of the online networked medium itself. But again, this is NIH's
concern, not publishers'!

>   What would happen if the principle that "the taxpayers have
>   already paid for the research" were applied also to patents,
>   pharmaceuticals, and other products of government-funded research?

But nothing of the sort is being proposed; nor does this speculation
have anything to do with the purpose of the proposal: Making funded
research findings public through publication is already mandated,
so the findings can be used, built-upon and applied. That has never
entailed renouncing patent or production rights. Supplementing the
publication with a publicly accessible free version online does
not conflict with patent or production rights either.

>   Mandating the deposit of research articles to a repository
>   reduces the value of the license or copyright transfer that an
>   author can make, by eliminating the exclusivity of the grant
>   and making it impossible for the publisher to recoup investment.

What is mandated is the provision by the fundee of supplementary
public access to the article online for free. This is compatible with
license or copyright transfer, and indeed 92% of journals have already
confirmed this by giving their authors the green light to do exactly
that: http://romeo.eprints.org/stats.php 

The rest is just another repetition of the speculation about hypothetical
future cancellations (for which please see above, concerning windfall
cancellation savings).

>   It could set a dangerous precedent with respect to an independent
>   investigator's control over patent and trademark rights. It
>   runs counter to established US law that affords investigators
>   and their employers the right to benefit financially from the
>   results of federally funded research conducted under their
>   auspices.

The commentary above has made the logical error of saying: 

    "Mandating free public online access to the published results
    of NIH-funded research would lead to mandating that the results
    of NIH-funded research cannot be patented or applied to produce
    revenue-bearing products"

(but they are not the same, and nothing of the sort has
been proposed!) -- and then going on to treat the NIH mandate as if
it had been for the latter rather than the former. 

Quite the contrary, mandating free public online access to the published
results of NIH-funded research has the effect, among other things,
of maximizing the fundee's research impact, by maximizing access to it
for its would-be users, which in turns has implications for benefiting
the fundee financially in terms of employment, promotion, tenure, future
research funding, prestige and prizes, all of which are associated with
enhanced research impact.

Let me point out for the attentive reader that the quoted passage
above makes a rather profound error in reasoning: It first makes a
hypothesis about what *might* turn out to be the eventual effect (say,
D, the destruction of the publisher's capacity to recover costs and
make a fair profit) of adopting a certain measure (say, P, mandating
the provision of free public access online), and then reasons as if
that hypothesized effect, D, were not merely a speculative guess, but
identical to the actual measure itself, P: The exact same error is made
in the quoted passage, but this time equating the NIH free-access mandate
with the destruction of the fundee's capacity to make patents or produce
revenue-bearing products based on his NIH-funded research!)

>   What will be the impact of the NIH's proposal on US jobs and
>   exports, particularly if other federal funding agencies follow
>   suit?  STM publishing is a major export business for US-based
>   publishers, both commercial and not-for-profit.  Billions of
>   dollars of revenue--money that supports US jobs and that adds
>   considerably to federal, state, and local federal tax coffers--come
>   from international publishing sales. An open archive would be,
>   by its very nature, open worldwide and so it would put a swift
>   end to this revenue stream and the jobs it supports.  If other
>   government and private funding agencies follow the NIH's lead,
>   the harmful consequences would intensify.

This is another repetition of the speculation that providing free
public access to research online will cause subscription cancellations
that will ruin the journal publishing industry. This is purely a
speculative (and rather shrill!) hypothesis. There is no evidence
in support of it; indeed all existing evidence to date is against it
(see the counter-example of JHEP, above). And there is a natural and
obvious counter-hypothesis, which is that if and when there should ever
be subscription cancellation losses, the essential costs of peer-reviewed
publishing will continue to be covered out of the institutional windfall
savings, by paying per outgoing article published instead of per incoming
journal subscribed to (see above). But as this is all speculation upon
speculation, it would seem more prudent not to renounce the certain and
obvious and immediate benefits of maximizing research access and impact on
the strength of a hypothesis that has all existing evidence against it,
no evidence to support it, and an obvious and natural counter-hypothesis
to accommodate it.

>   Will it really help patients and families?  There is no evidence
>   that open access will accelerate research for medical cures.

Yes, of course free public access online will help patients and
families by making otherwise-inaccessible information available
to them. But strong and growing quantitative evidence from all
fields of research also indicates that making research accessible
to all of its would-be users to use and build further research upon
substantially enhances its impact, and hence research productivity and
progress. http://opcit.eprints.org/oacitation-biblio.html
(So, yes, that should also facilitate cures!)

>   Patients and their families would be better served by efforts
>   that addressed the crisis in health literacy, yet the NIH
>   proposal does not address how to help the layperson interpret
>   the high- level science reported in journal articles in an
>   appropriate context, so that they can understand and apply the
>   clinical relevance of such studies to their own situations.

This is a both/and matter, not an either/or matter: Yes, helping
health literacy would be beneficial too. But not *instead* of providing
free public access to research online, but *in addition* to it. It
is no argument against public access. And among the would-be users
benefited are the researchers who do not need help in health literacy,
they just need help in research accessibility!

>   Should government dictate how, when, and where researchers
>   publish?  Is it appropriate for the U.S. government to put its
>   thumb on the scale in favor of one business model and thereby
>   dictate how, when, and where researchers publish?  Are we
>   prepared to accept the socialization of biomedical publishing?

The NIH (and any other research funder) has never dictated how, when or
where researchers should publish their NIH-funded research findings. (It
dictates only *that* they must publish them, so as to assure that they
can be accessed and used by their potential!) In addition, updating for
the online age, NIH is now further mandating that however, whenever and
wherever fundees choose to publish those NIH-funded research findings
(as they always did), they must now also provide a supplementary version
that is publicly accessible online for free to all of its would-be users
webwide (irrespective of whether those users or their institutions can
afford access to the journal in which it happens to be published)
in order to maximize the degree to which those findings are accessed,
read, used, built-upon, applied and cited: in other words, in order to
maximize the impact and benefits of having done the research at all
-- for the researcher, for his institution, for his funder, and for 
the funder of his funder: the tax-paying public. 

The public comment period ends on November 16, 2004. If you agree with
this critique (or if you don't!) please let NIH know, using the form at
http://grants.nih.gov/grants/guide/public_access/add.htm 
or e-mail your comments to PublicAccess at nih.gov

Stevan Harnad
Moderator
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http://amsci-forum.amsci.org/archives/American-Scientist-Open-Access-Forum.html
        Post discussion to:
    american-scientist-open-access-forum at amsci.org

UNIVERSITIES: If you have adopted or plan to adopt an institutional
policy of providing Open Access to your own research article output,
please describe your policy at:
        http://www.eprints.org/signup/sign.php

UNIFIED DUAL OPEN-ACCESS-PROVISION POLICY:
    BOAI-2 ("gold"): Publish your article in a suitable open-access
            journal whenever one exists.
            http://www.earlham.edu/~peters/fos/boaifaq.htm#journals
    BOAI-1 ("green"): Otherwise, publish your article in a suitable
            toll-access journal and also self-archive it.
            http://www.eprints.org/self-faq/
    http://www.soros.org/openaccess/read.shtml

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