OKFN response to EU Consultation on scientific information in the digital age

The response has been submitted.

About
The European Commission have set up a questionnaire (PDF version) regarding their future Open Access policy, and it has been suggested that the Open Knowledge Foundation draft a response to it as an organization. This page shall facilitate the drafting. Note that several organizations are drafting a response in public, of which some are listed under See also - the final submissions will be separate, but the message may be even stronger if the drafting of the submitted text has been coordinated. The submission deadline for the questionnaire is September 9, 2011.

Full text
Taken from http://ec.europa.eu/research/consultations/scientific_information/consultation_en.htm.

In late 2011, the European Commission intends to adopt a Communication and Recommendation on access to and preservation of digital scientific information. This initiative builds on earlier policy developments in this area, and is being developed within the policy contexts of the EU Flagship Initiatives Innovation Union and Digital Agenda for Europe, and of the push for improved knowledge circulation in the European Research Area.

The Communication will take stock of the developments in the area of scientific information, and set out the actions that the Commission intends to take on open access to publications and data in the context of research projects funded by the Union budget. The Recommendation will detail specific actions to be taken at Member State level.

Consultation of interested parties forms part of the policy process. The purpose of this open consultation is to gather information from as many sources as possible, including governments, research institutions and universities, libraries, scientific publishers, research funding organisations, businesses, individual researchers, and other interested parties on their views on scientific information in the digital age. The consultation will feed into the development of possible policy options to be considered, and will contribute to the ex-ante impact assessment that will be carried out.

The consultation is set up as follows:


 * 1) The respondent
 * 2) What role for Europe?
 * 3) Access to digital scientific information (including open access): scientific publications
 * 4) Access to digital scientific information (including open access): research data
 * 5) Preservation of digital scientific information
 * 6) Comments

It will take you approximately 15 minutes to complete the survey. The consultation will close on 9 September 2011.

Results will be published on the Commission's website, including a list of respondents (without e-mail addresses). Regarding personal data protection, please also refer to the European Commission's legal notice:http://ec.europa.eu/geninfo/legal_notices_en.htm.

The Commission thanks you in advance for your collaboration and valuable input.

Definitions:

In this questionnaire, "scientific information" refers to both 1) scientific (and scholarly, academic) publications published in peer-reviewed journals and 2) research data.

"Research data" or "data" may be numerical/quantitative, descriptive/qualitative or visual, raw or analysed, experimental or observational. Examples are digitised primary research data, photographs and images, films, etc.

"Open access" refers to access over the internet that is free of charge for the reader.

"Preservation" refers to policies, strategies and actions that ensure permanent access to digital content over time.

I am replying as /on behalf of a(n) (if you represent more than one category, please choose the most relevant one):* (compulsory)
National government

Regional or local government

Research funding organisation

University/research institute

Library

Publisher

International organisation

Individual researcher

Citizen

Other

What role for Europe?
'' There are already many developments regarding access to and preservation of scientific information in Europe, at governmental, funding body and institutional level. For some years, the European Union has also been developing policies in these areas. ''

==== In your opinion, in what specific areas can and should the European Union best contribute to improving the circulation of knowledge, and specifically access to and preservation of scientific information (including both publications and data)? ====

Policy formulation at European level on access and preservation issues (optional)

agree strongly agree no opinion disagree disagree strongly

Co-ordinating existing initiatives in EU Member States (optional)

agree strongly agree no opinion disagree disagree strongly

Supporting the development of a European network of repositories (online archives) (optional)

agree strongly agree no opinion disagree disagree strongly

Encourage universities, libraries, funding bodies, etc., to implement specific actions (optional)

agree strongly agree no opinion disagree disagree strongly

Comments
(optional) (maximum 400 characters)

Raising awareness for open licensing is the most important aspect. Focussing on repositories as the primary infrastructural tool might not be a good thing. It is more important to establish shared practices of publishing research, data and metadata. Fostering open web standards of the Linked Open Data community is a promising way to go.

Holger: http://okfn.org/about/vision/ -> "Develop tools and services in relation to the above" also would justify a slightly stronger point on repositories. Fine with the answer as is too, though.

Do you agree with the following statement: "there is NO problem with access to scientific publications in Europe"? (optional)
agree strongly agree no opinion disagree disagree strongly

How would you rate the importance of the following potential barriers to access to scientific publications?
Insufficient national/regional strategies/policies on access to scientific publications (optional)

very important important no opinion not very important not important at all

High prices of articles/journal subscriptions (optional)

very important important no opinion not very important not important at all

Limited or reduced library budgets (optional)

very important important no opinion not very important not important at all

Different Value Added Tax (VAT) rates for online media and printed material (optional)

very important important no opinion not very important not important at all

Lack of awareness and interest within the research community on access and open access (optional)

very important important no opinion not very important not important at all

No incentive system in place encouraging and rewarding practices that enhance access (optional)

very important important no opinion not very important not important at all

Comments (optional) (maximum 400 characters)
In the online era, there is no reason that research should be inaccessible to any potential user, even if publications were sold at no profit. As the rate and amount of publications are rapidly expanding, the current predominant model – via journals subscriptions – is hardly sustainable and not working effectively. There are no clear and consistent correlations between price, quality and impact.

Holger: "even if publications were sold at no profit" -> do not understand what that clause stands for. Can live with text as is though.

Do you think that publications resulting from publicly funded research should, as a matter of principle, be available free of charge to readers on the internet (i.e. open access mode)? (optional)
agree strongly agree no opinion disagree disagree strongly

Do you think that open access can increase access to and dissemination of scientific publications? (optional)
agree strongly agree no opinion disagree disagree strongly

Do you think that open access to scientific publications can co-exist with the traditional scientific publication system? (optional)
agree strongly agree no opinion disagree disagree strongly

Green or Gold?
Open access to scientific publications can be achieved in different ways, in particular through researchers self-archiving in repositories ("green open access") and through publication in open access journals for a fee ("gold open access").


 * Which of the following different modes should public research policy facilitate in order to increase the number and share of scientific publications available in open access? Please rate the following options from 1 to 4 (1 = first choice; 4 = last choice):

Open access publishing (author-pays model/"gold open access") (optional)

1

Self-archiving ("green open access") (optional)

3

A combination of self-archiving and open access publishing (optional)

2

Funded conversion of traditional subscription-based journals to open access journals (optional)

4

Comments
(optional) (maximum 400 characters)

"Author pays" is a deeply misleading term. Most OA journals charge no fees at all, and in many cases, fees will be paid by the author's funder or employer or sometimes waived on grounds of economic hardship. "Article processing charges" is more accurate. Mandating Libre OA provides opportunities for reuse. Overlay journals are missing here. These combine journal publishing and repository deposit.

Holger: IEEE is at about 2x00-3000 USD/article, and for SMEs that is a good amount of money. I would be careful with putting "author pays" at option one.

In the case of self-archiving ("green open access"), what embargo period (period of time during which publication is not yet open access) is desirable?
18 months (optional)

agree strongly agree no opinion disagree disagree strongly

12 months (optional)

agree strongly agree no opinion disagree disagree strongly

9 months (optional)

agree strongly agree no opinion disagree disagree strongly

6 months (optional)

agree strongly agree no opinion disagree disagree strongly

Other embargo period/comments
(optional) (maximum 400 characters) There is no need for any OA embargo period at all. But if the only way that a Green OA mandate can be agreed is if embargoes are allowed, then (1) they should not exceed 6 months, (2) deposit should be required at the time of acceptance anyway, (3) embargoed deposits can be made Closed Access, and (4) the repositories' "email eprint request" button can allow authors to fulfill researcher needs.

Do you agree with the following statement: "generally speaking, there is NO access problem to research data in Europe"? (optional)
agree strongly agree no opinion disagree disagree strongly

How would you rate the importance of the following potential barriers to enhancing access to research data?
Insufficient national/regional strategies/policies on access to research data (optional)

very important important no opinion not very important not important at all

Lack of funding to develop and maintain the necessary data infrastructures (optional)

very important important no opinion not very important not important at all

Insufficient credit given to researchers making research data available/lack of incentives (optional)

very important important no opinion not very important not important at all

Lack of mandates to deposit research data (optional)

very important important no opinion not very important not important at all

Lack of data management requirements in research projects (optional)

very important important no opinion not very important not important at all

Confidentiality/privacy issues (optional)

very important important no opinion not very important not important at all

Comments
(optional) (maximum 400 characters) Incentives for publishing data must be created, e.g. by making data publications citeable, by giving them scientific reward functions and by integrating them into research publications. There are specifics for many research fields, which legal regulations should take into account (e.g. concerning data with implications for patient privacy or endangered species).

==== Do you think that research data that is publicly available and that results from PUBLIC funding should, as a matter of principle, be available for re-use and free of charge on the internet? (optional) ====

agree strongly agree no opinion disagree disagree strongly

Comments
(optional) (maximum 400 characters) Making publicly funded data openly available will foster innovation. It fosters scientific discourse & progress, so large cost savings can be expected. As OA to research data provides transparency, it facilitates the detection of scientific fraud. Explicit dedication of data behind published science into the public domain e.g. via CC0 is strongly recommended, as per http://pantonprinciples.org/.

==== Do you think that research data that is publicly available and that results from PARTLY PUBLIC AND PARTLY PRIVATE funding should, as a matter of principle, be available for re-use and free of charge on the internet? (optional) ====

agree strongly agree no opinion disagree disagree strongly

Comments
(optional) (maximum 400 characters) For simplicity and enforceability, it is better not to distinguish between different degrees of public funding and to follow instead the example of most funding agencies, i.e. to apply their open access and open data policies to research they fund "in whole or in part".

Holger: is it so that open access and open data policy are usually applied to partially funded projects? If so, it would be good to name one or two funding agencies that have this policy for partially funded projects. (The 400 char limit would still allow this.)

Do you agree with the following statement: "Generally speaking, the issue of preservation of scientific information is at present sufficiently addressed"? (optional)
agree strongly agree no opinion disagree disagree strongly

Do you agree with the following statements regarding potential barriers to enhancing preservation of scientific information in the digital age?
It is not always clear which scientific information should be preserved (optional)

agree strongly agree no opinion disagree disagree strongly

It is not always clear who is responsible for preserving scientific information (research organisations, libraries, governments?) (optional)

agree strongly agree no opinion disagree disagree strongly

There is no harmonised approach to legal deposit (legal requirement that copies of publications be submitted to a repository, usually a library) (optional)

agree strongly agree no opinion disagree disagree strongly

Funding for preservation is inadequate (optional)

agree strongly agree no opinion disagree disagree strongly

The quality and interoperability of repositories need to be further developed (optional)

agree strongly agree no opinion disagree disagree strongly

Comments
(optional) (maximum 400 characters) Preservation has technical aspects (standards, storage media, file formats) as well as legal (licensing) and editorial ones (what to preserve). What needs preservation is the published version of record, along with supplementary materials. Repositories do not and cannot provide long-term preservation. Libre OA solves the licensing problems & open standards the technical problems of preservation.

Holger: but does libre OA not also address repository issues? (I'd also vote to put "inadequate funding" to top priority.) Maybe weaken to "Without supporting measures for interoperability and sharing/mirroring of data, repositories do not and cannot provide long-term preservation." Can live with text "as though" too.

Please provide any further comments or inputs in the space below. (optional) (maximum 600 characters)
Generally, the EU should seek to develop a scholarly communication infrastructure based on open access to, open licensing of and open standards for both publications & data, in short: an infrastructure that conforms to http://www.opendefinition.org. This would maximize transparency, efficiency & innovation. The Linked Open Data approach should be seriously considered. Exceptions from a general open access & open data mandate should be possible but require public justification for each publication. If such an opt-out is possible, no general embargo period for OA or OD is necessary.