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[BOAI] =?windows-1252?q?Harnad_Comments_on_Canada=92s_NSERC/SSHRC/CIHR_?= =?windows-1252?q?Draft_Tri-Agency_Open_Access_Policy?=

From: Stevan Harnad <amsciforum AT gmail.com>
Date: Wed, 16 Oct 2013 10:49:57 -0400


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*Harnad Comments on Canada=92s NSERC/SSHRC/CIHR Draft Tri-Agency Open Acces=
s
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=92 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=92s 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=92s 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=92s institution*.
[image: ---]

*=93Grant 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).=94*

*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=92s natural ally in ensurin=
g
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=92s 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 =96 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=92s 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

*=93Option #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.=94*

*Fundee Freedom to Choose Journal.* It is very good to leave the fundee=92s
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=92s
institutional repository =96 and deposited immediately, not after a 12-mont=
h
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 =93Almost-OA=
,=94
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/

*=93The 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/FinancialAdminGui=
de-GuideAdminFinancier/FundsUse-UtilisationSubventions_eng.asp>
*.=94

*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.)

*=93Option #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.=94=
*

*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 =96 *as long as the deposit is made immediately*, and hence depos=
it
is systematically verifiable and the institutional repository=92s
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=92s 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=92s institutional repository, regardless of whether the fundee=92s
chooses option #1 or option #2.*

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<div dir=3D"ltr">















<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
style=3D"font-family:Ve=
rdana">Harnad
Comments on <a 
href=3D"http://www.nserc-crsng.gc.ca/NSERC-CRSNG/policies-po=
litiques/Tri-OA-Policy-Politique-LA-Trois_eng.asp#3">Canada=92s
NSERC/SSHRC/CIHR Draft Tri-Agency Open Access 
Policy</a></span></b></p>

<p class=3D"" style=3D"margin:0cm 0cm 13pt 
72pt"><b><span style=3D"font-fam=
ily:Verdana">Executive Summary:</span></b><span 
style=3D"font-family:Verdan=
a">
The Draft Canadian Draft Tri-Agency Open Access Policy is excellent in pres=
erving
fundees=92 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, 
<i>deposit =
in the fundee=92s institutional
repository immediately upon acceptance for publication</i> needs to be 
requ=
ired,
whether or not the fundee chooses to publish in an OA journal and whether o=
r
not access to the deposit is embargoed for 12 months. This makes it possibl=
e
for the fundee=92s institution to monitor and ensure timely compliance with=
 the
funder OA policy and it also facilitates providing individual eprints by th=
e
fundee to individual eprint requestors for research purposes during any emb=
argo.
Institutional repository deposits can then be automatically exported to any
institutional-external repositories the fundee, funding agency or instituti=
on
wishes<i>. On no account should compliance
with funding agency conditions be left to the publisher rather than the fun=
dee
and the fundee=92s institution</i>.</span></p>


<div class=3D"" align=3D"center" 
style=3D"margin-bottom:13pt;text-align:cen=
ter"><span style=3D"font-family:Verdana"><img 
border=3D"0" height=3D"1" wid=
th=3D"432" 
src=3D"file://localhost/Users/harnad/Library/Caches/TemporaryIte=
ms/msoclip/0clip_image002.png" 
alt=3D"---"></span></div>



<p class=3D"" style=3D"margin:0cm 0cm 13pt 
36pt"><i><span style=3D"font-fam=
ily:Verdana">=93Grant recipients are
required to ensure that any peer-reviewed journal publications arising from
Agency-supported research are freely accessible within 12=A0months of
publication, either through the publisher&#39;s website (Option #1) or an 
o=
nline
repository (Option #2).=94</span></i></p>

<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
style=3D"font-family:Ve=
rdana">Monitoring
and Ensuring Compliance.</span></b><span 
style=3D"font-family:Verdana"> A f=
unding agency Open Access
(AO) Policy is binding on the <i>fundee</i>,
not on other parties. Hence it is a mistake to offer fundees the option eit=
her
to comply or to leave it to another party (the publisher) to comply. </span=
></p>

<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
style=3D"font-family:Ve=
rdana">Funder
Requirements Bind Fundees, Not Publishers.</span></b><span 
style=3D"font-fa=
mily:Verdana"> The fulfillment of
funding agency conditions for receiving a grant is the responsibility of th=
e
fundee, and the funding agency needs a systematic and reliable means of
monitoring and ensuring that</span><span lang=3D"EN-CA" 
style=3D"font-famil=
y:Verdana">
the fundee has indeed complied, and complied in time.</span></p>

<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
lang=3D"EN-CA" style=3D=
"font-family:Verdana">Institutional Monitoring of 
Compliance.</span></b><sp=
an lang=3D"EN-CA" style=3D"font-family:Verdana"> To 
ensure compliance (and =
timely compliance)
with an AO requirement it is imperative that the responsibility rest fully
with=A0 the fundee. The funding
agency=92s natural ally in ensuring compliance is the <i>institution of 
the=
 fundee</i>, 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.</span></p>

<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
lang=3D"EN-CA" style=3D=
"font-family:Verdana">Immediate Institutional Repository 
Deposit.</span></b=
><span lang=3D"EN-CA" 
style=3D"font-family:Verdana"> Hence <i>whether
or not</i> 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 funde</span><span 
style=3D"font-family:Verdana">=
e=92s institutional repository <i>immediately upon publication</i>. 
(Indeed=
,
the most natural, effective and verifiable date is the <i>date of 
acceptanc=
e</i>, since the date of publication varies greatly,
is often not predictable or known to the fundee, and often diverges from th=
e
published calendar date of the journal =96 if it has a calendar date at all=
.)</span></p>

<p class=3D"" style=3D"margin-bottom:13pt"><span 
style=3D"font-family:Verda=
na">The institution of the fundee can then
use the date-stamp of the deposit in the institutional repository and the d=
ate
of acceptance of the article as the means of monitoring and ensuring timely
compliance.</span></p>

<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
style=3D"font-family:Ve=
rdana">Access
Delay and Research Impact Loss.</span></b><span 
style=3D"font-family:Verdan=
a"> 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 i=
t
was published. This maximizes research uptake, impact and progress. Hence t=
his
is why OA is so important and why access-denial is so damaging to the poten=
tial
usage and applications of research. Studies have also shown that delayed ac=
cess
never attains the full usage and citations of immediate OA. Hence a mechani=
sm
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.</span></p>

<p class=3D"" style=3D"margin-bottom:13pt"><span 
style=3D"font-size:8pt;fon=
t-family:Verdana">Gentil-Beccot, A., Mele, S.,
&amp; Brooks, T. C. (2010). Citing and reading behaviours in high-energy
physics. <i>Scientometrics</i> 84(2),
345-355. <a 
href=3D"http://www.slac.stanford.edu/pubs/slacpubs/13500/slac-p=
ub-13693.pdf">http://www.slac.stanford.edu/pubs/slacpubs/13500/slac-pub-136=
93.pdf</a>
</span></p>

<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
style=3D"font-family:Ve=
rdana">Conflict
of Interest.</span></b><span 
style=3D"font-family:Verdana"> It should also =
be noted that publisher interests
are in conflict with the research community=92s interests regarding OA. Exc=
ept
when they are receiving extra money for it, publisher interest is to embarg=
o
and delay OA as long as possible. This means that, far from being a reliabl=
e
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</span><=
/p>

<p class=3D"" style=3D"margin:0cm 0cm 13pt 
36pt"><i><span style=3D"font-fam=
ily:Verdana">=93<u>Option #1</u>:<b> 
</b></span></i><i><span style=3D"font-=
family:Verdana">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=A0months.=94</span></i></p>

<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
style=3D"font-family:Ve=
rdana">Fundee Freedom to Choose Journal.</span></b><span 
style=3D"font-fami=
ly:Verdana"> It is very good to leave the fundee=92s choice of
journal completely free to the fundee. But it is also imperative that 
<i>no=
 matter what journal the fundee chooses to
publish in</i>, the peer-reviewed final draft should always be deposited 
in=
 the
fundee=92s institutional repository =96 and deposited immediately, not afte=
r a
12-month delay.</span></p>

<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
style=3D"font-family:Ve=
rdana">Fulfilling Eprint Requests During
Embargoes.</span></b><span 
style=3D"font-family:Verdana"> Institutional
repositories have a Button with which users can request and authors can pro=
vide
a single electronic reprint for research purposes with one click each. This
Button facilitates uptake, access and usage immediately upon deposit, rathe=
r
than having to wait till the end of a publisher embargo. Hence this =93Almo=
st-OA,=94
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.</span></p>

<p class=3D"" style=3D"margin-bottom:13pt"><span 
style=3D"font-size:8pt;fon=
t-family:Verdana">Sale, A., Couture, M.,
Rodrigues, E., Carr, L. and Harnad, S. (2012) Open Access Mandates and the
&quot;Fair Dealing&quot; Button. In: <i>Dynamic
Fair Dealing: Creating Canadian Culture Online</i> (Rosemary J. Coombe 
&amp=
;
Darren Wershler, Eds.) <a 
href=3D"http://eprints.ecs.soton.ac.uk/18511/">ht=
tp://eprints.ecs.soton.ac.uk/18511/</a>
</span></p>

<p class=3D"" style=3D"margin:0cm 0cm 13pt 
36pt"><i><span style=3D"font-fam=
ily:Verdana">=93The Agencies consider
the cost of publishing in open access journals to be an eligible expense un=
der
the <a 
href=3D"http://www.nserc-crsng.gc.ca/Professors-Professeurs/Financia=
lAdminGuide-GuideAdminFinancier/FundsUse-UtilisationSubventions_eng.asp"><s=
pan style=3D"color:rgb(190,0,6);text-decoration:none">Use of Grant 
Funds</s=
pan></a></span></i><span 
style=3D"font-family:Verdana">.=94</span></p>


<p class=3D"" 
style=3D"margin-bottom:13pt"><b><span 
style=3D"font-family:Ve=
rdana">Fundee
Freedom to Choose Whether to Pay for OA.</span></b><span 
style=3D"font-fami=
ly:Verdana"> 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 ret=
ain
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 th=
ey
publish in an OA journal) there is no harm in allowing grant funds to be us=
ed
to pay publishers for making their article OA, <i>if fundees 
wish</i>. (Giv=
en the options, and the scarcity of research
funds, it is unlikely that many fundees will choose to pay, rather than jus=
t
deposit.)</span></p>

<p class=3D"" style=3D"margin:0cm 0cm 13pt 
36pt"><i><span style=3D"font-fam=
ily:Verdana">=93<u>Option #</u>2:<b> 
</b></span></i><i><span style=3D"font-=
family:Verdana">Grant
recipients archive the final peer-reviewed full-text manuscript in a digita=
l
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.=94</span></i></p>

<p class=3D""><b><span 
style=3D"font-family:Verdana">Institutional
Deposit and Institution-External Export. </span></b><span 
style=3D"font-fam=
ily:Verdana">It is fine to leave it
up to authors to sort out whether their final peer-reviewed manuscript is m=
ade
immediately OA or access to the deposit is embargoed for 12 months =96 
<i>a=
s long as the deposit is made immediately</i>,
and hence deposit is systematically verifiable and the institutional
repository=92s eprint-request Button is immediately available to allow user=
s to
request individual copies for research purposes. For this reason it is agai=
n
important to require immediate institutional deposit in all cases. The depo=
sit
can be automatically exported by the reposository software, at designated
dates, to designated institution-external repositories, as the fundee or fu=
nder
or institution may wish. </span></p>

<p class=3D""><b><span 
style=3D"font-family:Verdana">Facilitating
Verification of Compliance.</span></b><span 
style=3D"font-family:Verdana"> =
But it is almost as great a
mistake to allow institution-external deposit instead of institutional depo=
sit
(making it needlessly diffuse and complicated to systematically monitor and
ensure compliance for both the institution and the funder) as it is to allo=
w
publisher fulfillment of funding agency requirements instead of fulfillment=
 by
the fundee (and the fundee=92s institution). </span></p>

<p class=3D""><i><span 
style=3D"font-family:Verdana">The
only change that needs to be made to optimize the NSERC/SSHRC/CIHR Draft Tr=
i-Agency
Open Access Policy is to require immediate deposit in the fundee=92s
institutional repository, regardless of whether the fundee=92s chooses opti=
on #1
or option #2.</span></i></p>

</div>

--f46d0444e8d79d918a04e8dcd0e4--

        
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