[BOAI] Harnad Comments on Canada’s NSERC/SSHRC/CIHR Draft Tri-Agency Open Access Policy

[Stevan Harnad]

*Harnad Comments on Canada’s NSERC/SSHRC/CIHR Draft Tri-Agency Open Access
Policy<http://www.nserc-crsng.gc.ca/NSERC-CRSNG/policies-politiques/Tri-OA-Policy-Politique-LA-Trois_eng.asp#3>
*

*Executive Summary:* The Draft Canadian Draft Tri-Agency Open Access Policy
is excellent in preserving fundees’ free choice of journal, and afree
choice about whether or not to use the research funds to pay to publish in
an OA journal. However, *deposit in the fundee’s institutional repository
immediately upon acceptance for publication* needs to be required, whether
or not the fundee chooses to publish in an OA journal and whether or not
access to the deposit is embargoed for 12 months. This makes it possible
for the fundee’s institution to monitor and ensure timely compliance with
the funder OA policy and it also facilitates providing individual eprints
by the fundee to individual eprint requestors for research purposes during
any embargo. Institutional repository deposits can then be automatically
exported to any institutional-external repositories the fundee, funding
agency or institution wishes*. On no account should compliance with funding
agency conditions be left to the publisher rather than the fundee and the
fundee’s institution*.
[image: ---]

*“Grant recipients are required to ensure that any peer-reviewed journal
publications arising from Agency-supported research are freely accessible
within 12 months of publication, either through the publisher's website
(Option #1) or an online repository (Option #2).”*

*Monitoring and Ensuring Compliance.* A funding agency Open Access (AO)
Policy is binding on the *fundee*, not on other parties. Hence it is a
mistake to offer fundees the option either to comply or to leave it to
another party (the publisher) to comply.

*Funder Requirements Bind Fundees, Not Publishers.* The fulfillment of
funding agency conditions for receiving a grant is the responsibility of
the fundee, and the funding agency needs a systematic and reliable means of
monitoring and ensuring that the fundee has indeed complied, and complied
in time.

*Institutional Monitoring of Compliance.* To ensure compliance (and timely
compliance) with an AO requirement it is imperative that the responsibility
rest fully with  the fundee. The funding agency’s natural ally in ensuring
compliance is the *institution of the fundee*, which is already very much
involved and and shares a strong interest with both the fundee and the
funding agency in ensuring the fulfillment of all funding agency conditions.

*Immediate Institutional Repository Deposit.* Hence *whether or not* the
fundee publishes with a publisher that makes the article OA immediately, or
after an embargo, the fundee should be required to deposit the final,
peer-reviewed draft in the fundee’s institutional repository *immediately
upon publication*. (Indeed, the most natural, effective and verifiable date
is the *date of acceptance*, since the date of publication varies greatly,
is often not predictable or known to the fundee, and often diverges from
the published calendar date of the journal – if it has a calendar date at
all.)

The institution of the fundee can then use the date-stamp of the deposit in
the institutional repository and the date of acceptance of the article as
the means of monitoring and ensuring timely compliance.

*Access Delay and Research Impact Loss.* The purpose of OA is to make
publicly funded research accessible to all potential users and not just to
those whose institutions can afford subscription access to the journal in
which it was published. This maximizes research uptake, impact and
progress. Hence this is why OA is so important and why access-denial is so
damaging to the potential usage and applications of research. Studies have
also shown that delayed access never attains the full usage and citations
of immediate OA. Hence a mechanism for ensuring timely compliance is
essential for the success of an OA Policy, and immediate institutional
deposit, regardless of locus of publication, is the optimal mechanism for
ensuring timely compliance.

Gentil-Beccot, A., Mele, S., & Brooks, T. C. (2010). Citing and reading
behaviours in high-energy physics. *Scientometrics* 84(2), 345-355.
http://www.slac.stanford.edu/pubs/slacpubs/13500/slac-pub-13693.pdf

*Conflict of Interest.* It should also be noted that publisher interests
are in conflict with the research community’s interests regarding OA.
Except when they are receiving extra money for it, publisher interest is to
embargo and delay OA as long as possible. This means that, far from being a
reliable ally in ensuring that fundees comply with a funding agency OA
requirement, publishers are likely to delay making articles OA as long as
they possibly can

*“Option #1: **Grant recipients submit their manuscript to a journal that
offers immediate open access to published articles, or offers open access
to published articles within 12 months.”*

*Fundee Freedom to Choose Journal.* It is very good to leave the fundee’s
choice of journal completely free to the fundee. But it is also imperative
that *no matter what journal the fundee chooses to publish in*, the
peer-reviewed final draft should always be deposited in the fundee’s
institutional repository – and deposited immediately, not after a 12-month
delay.

*Fulfilling Eprint Requests During Embargoes.* Institutional repositories
have a Button with which users can request and authors can provide a single
electronic reprint for research purposes with one click each. This Button
facilitates uptake, access and usage immediately upon deposit, rather than
having to wait till the end of a publisher embargo. Hence this “Almost-OA,”
made possible by the Button, is another strong reason why all papers should
be required to be deposited in the institutional repository immediately
upon acceptance for publication.

Sale, A., Couture, M., Rodrigues, E., Carr, L. and Harnad, S. (2012) Open
Access Mandates and the "Fair Dealing" Button. In: *Dynamic Fair Dealing:
Creating Canadian Culture Online* (Rosemary J. Coombe & Darren Wershler,
Eds.) http://eprints.ecs.soton.ac.uk/18511/

*“The Agencies consider the cost of publishing in open access journals to
be an eligible expense under the Use of Grant
Funds<http://www.nserc-crsng.gc.ca/Professors-Professeurs/FinancialAdminGuide-GuideAdminFinancier/FundsUse-UtilisationSubventions_eng.asp>
*.”

*Fundee Freedom to Choose Whether to Pay for OA.* It is very good to leave
it entirely up to fundees to choose whether or not to use their grant funds
to pay publishers extra to make their work OA. As long as fundees retain
their free choice of which journal to publish in, and all are all required
to deposit in their institutional repository immediately upon acceptance
for publication (whether or not the deposit is embargoed, and whether or
not they publish in an OA journal) there is no harm in allowing grant funds
to be used to pay publishers for making their article OA, *if fundees wish*.
(Given the options, and the scarcity of research funds, it is unlikely that
many fundees will choose to pay, rather than just deposit.)

*“Option #2: **Grant recipients archive the final peer-reviewed full-text
manuscript in a digital archive where it will be freely accessible within
12 months (e.g., institutional repository or discipline-based repository).
It is the responsibility of the grant recipient to determine which
publishers allow authors to retain copyright and/or allow authors to
archive journal publications in accordance with funding agency policies.”*

*Institutional Deposit and Institution-External Export. *It is fine to
leave it up to authors to sort out whether their final peer-reviewed
manuscript is made immediately OA or access to the deposit is embargoed for
12 months – *as long as the deposit is made immediately*, and hence deposit
is systematically verifiable and the institutional repository’s
eprint-request Button is immediately available to allow users to request
individual copies for research purposes. For this reason it is again
important to require immediate institutional deposit in all cases. The
deposit can be automatically exported by the reposository software, at
designated dates, to designated institution-external repositories, as the
fundee or funder or institution may wish.

*Facilitating Verification of Compliance.* But it is almost as great a
mistake to allow institution-external deposit instead of institutional
deposit (making it needlessly diffuse and complicated to systematically
monitor and ensure compliance for both the institution and the funder) as
it is to allow publisher fulfillment of funding agency requirements instead
of fulfillment by the fundee (and the fundee’s institution).

*The only change that needs to be made to optimize the NSERC/SSHRC/CIHR
Draft Tri-Agency Open Access Policy is to require immediate deposit in the
fundee’s institutional repository, regardless of whether the fundee’s
chooses option #1 or option #2.*
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