The Genetics Society of AmericaResponse to Office of Science and Technology Policy (OSTP)Public Consultation on Public Access Policies forScience and Technology Funding AgenciesTo:Dr. Diane DiEuliisAssistant Director, Life SciencesOffice of Science and Technology Policy,Office of Science and Technology PolicyAttn: Open Government Recommendations725 17th StreetWashington, DC 20502Submitted 21 January 2010 via e‐mail to: [email protected] on behalf of the GSA by:Sherry MartsExecutive DirectorGenetics Society of America9650 Rockville PikeBethesda, MD 20814301‐634‐7301 phone301‐634‐7079 faxsmarts@genetics‐gsa.orgR. Scott HawleyPresidentGenetics Society of AmericaStowers Institute for Medical Research1000 East 50th StreetKansas City, MO [email protected]

IntroductionFounded in 1931, the Genetics Society of America (GSA) is the professional membership organization forgeneticists and science educators. Its more than 4,000 members work to advance knowledge in thebasic mechanisms of inheritance, from the molecular to the population level. The GSA is dedicated topromoting research in genetics and to facilitating communication among geneticists \. The GSA seeks tofoster a unified science of genetics and to maximize its intellectual and practical impact.GENETICS (, the peer‐edited journal of the GSA, has, since 1916 ,published highquality, original research on a range of topics, including classical transmission genetics, moleculargenetics, theoretical and applied population genetics, developmental and behavioral genetics, cellulargenetics, gene expression, and genome and systems biology. GENETICS is one of the world's most citedjournals in genetics.The GSA welcomes the chance to present its comments to the OSTP. All comments contained hereinrepresent the views of the Genetics Society of America leadership and the responses to OSTP’squestions relate primarily to the needs of the GSA membership and communities we serve.The GSA supports the commitment of the Obama administration to, as stated by the President in hisOpen Government Directive memorandum, “[provide] information for citizens about what theirGovernment is doing.” The principle of transparency and open government requires that citizens haveopen and ready access to information about the expenditure of public funds, including research grants,contracts, and cooperative agreements. The contents of scholarly publications (either the final versionof record or the manuscript version of that record) are, in fact, several steps (and sometimes severalyears) removed from the original action of the Government, i.e. the awarding of the grant, contract, oragreement. We recognize that there are may be compelling reasons why public access to the scientificrecord may be a desirable public good, but we do not believe that this access fulfills the spirit or theletter of President Obama’s memorandum.Whatever the rationale for doing so, the development of a responsive and responsible policy on publicaccess to the scientific record requires a deliberate approach rooted in empirical data and facts. It mustbe developed in collaboration with scholarly publishers and scientific societies, and must address thevarying degrees of formality and process for information sharing found in the different disciplines. Forexample, computer scientists regularly share conference papers and proceedings with one other, andresearchers in physics have developed their own widely‐used repository, arXiv, for sharing conferencepapers. On the other hand, researchers in the biological sciences publish almost exclusively in peer‐reviewed and edited scholarly journals and have had low rates of compliance with voluntary publicationrepositories.The careful development of a public access policy requires determining the true extent of the problem –what is the level of public demand for access to the scientific literature, and in what ways is thatdemand not currently being met? If the problem is such that a broad‐based federal policy is needed toaddress it, care must then be taken to craft a policy that will meet public demand while ensuring thatscientific publishing will not only survive, but will thrive in a way that allows continued innovation inpublishing.GSA Response to OSTP Public Consultation on Public Access PolicyPage 2 of 7

Responses to numbered questions posed by the OSTP for discussion1. How do authors, primary and secondary publishers, libraries, universities, and the federalgovernment contribute to the development and dissemination of peer reviewed papers arising fromfederal funds now, and how might this change under a public access policy?Each of these parties plays a specific and important role in the creation, evaluation, and distributionof scientific research. Authors conduct the research, often with funding from federal governmentagencies, review and interpret the resulting data, write up their results and interpretation theselect a journal to which to submit their work. Researchers choose the journals to which they sendtheir work on the basis of several factors, including journal reputation, niche, editors, impact, reach,and other aspects.Scholarly publishers (in particular, nonprofit society publishers such as the GSA) add value by addingquality. 1 Publishers provide the infrastructure, staff support, and financial support for peer review ofmanuscripts; professional editing of the final version; and the distribution, archiving and promotionof published research findings. Publishers appoint editors and select reviewers who have theappropriate expertise for evaluating submitted manuscripts. Final presentation, including graphicdesign and content presentation that maximizes search, retrieval, and usability, is also handled bythe publisher.Scholarly publishers drive the development of new technologies for delivering content andreaching readers. These technological developments have transformed the traditional research“paper” into a multi‐media product that may include significant supplemental material containinginformation on methods and additional data, video clips, figures that can be downloaded asPowerPoint slides for teaching, and links to external sources. In one recent example of how journalsadd value to publications through technology GENETICS has developed a way to seamlessly linkresearch articles with annotated and curate data contained in model organism databases. Thisallows the reader to click on a hyperlink in the article (e.g., a gene name) and land, on theinformation about the corresponding gene in a database.The development of this technological innovation involved many hours of work on the part ofGENETICS staff and editors, the staff at the model organism databases, and Highwire Press, theonline host for GENETICS. This kind of significant investment of time and financial support isillustrative of the value of scholarly publishers to the research enterprise, and is done withoutgovernment support.Scholarly publishers work closely with libraries and universities to ensure that the results of researchare accessible and properly archived. Society publishers such as GSA are sensitive to the needs oflibraries and research institutions, as evidenced by our recent decision to freeze subscription pricesin the wake of the economic crisis facing universities.1Morris, Sally, 2008. What is quality in journals publishing? Learned Publishing, 21, 4–6 doi: 10.1087/095315108X248383GSA Response to OSTP Public Consultation on Public Access PolicyPage 3 of 7

Federal funding for research projects contributes to the production and analysis of research data,but this funding does not pay for the materials, work, or technology that make up the currentstate‐of‐the‐art in scholarly publishing. To claim that federal funding “pays for” the content ofGENETICS ignores the cost and added value of the publishing process.A public access policy has the potential to limit the ability of publishers to recoup the costs ofpublication and to have sufficient net revenue to drive further innovation in the field of scholarlypublishing. For this reason, the development and implementation of such a policy must be donewith care, based on sound empirical evidence that such a policy is truly needed or desired bytaxpayers.Indeed, such a policy may be quickly superseded by the marketplace. For example, DeepDyve( is now offering the content of scholarly journals (including GENETICS) on arental basis. Right now, anyone who doesn’t want to wait six months for an article in GENETICS tobecome accessible for free can pay .99 to view the full article from the journal for 24 hours. Otherrental options are available.2. What characteristics of a public access policy would best accommodate the needs and interests ofauthors, primary and secondary publishers, libraries, universities, the federal government, users ofscientific literature, and the public?This question presumes that each of these interest groups needs or is interested in a public accesspolicy. The truth of that assumption is not known, and research is needed to determine exactly whatare the needs and interest of these stakeholders, particularly the public, which a “public accesspolicy” would address). Does a problem exists (i. e., is there a public demand for this content?) and,if so, how is it best addressed? In the biomedical sciences, where data on demand for and usage ofthe content available in PubMed Central presumably exist, these data have not, as far as we know,been made available to anyone (including the taxpayers who have paid for PubMed Central) foranalysis.3. Who are the users of peer‐reviewed publications arising from federal research? How do they accessand use these papers now, and how might they if these papers were more accessible? Would othersuse these papers if they were more accessible, and for what purpose?Researchers and teachers are the primary users of GENETICS. Our readers access the journal’s issuesfrom 1916 until December 2009 as print copies in university and institutional libraries or asindividual subscribers, or in electronic form online through university and institutional or individualsubscriptions. Beginning in January 2010 GENETICS is available only online. As mentioned above,articles are available to anyone on a rental basis for six months after the date of publication. Accessto the content of GENETICS online becomes available to anyone free of charge six months after thedate of publication.4. How best could Federal agencies enhance public access to the peer‐reviewed papers that arise fromtheir research funds? What measures could agencies use to gauge whether there is increased returnon federal investment gained by expanded access?GSA Response to OSTP Public Consultation on Public Access PolicyPage 4 of 7

As noted above, in the US federal funding for research projects contributes to the production andanalysis of research data but this funding does not pay for the materials, work, or technology thatmake up the current state‐of‐the‐art in scholarly publishing. To claim that peer‐reviewedpublications “arise from” research funds ignores the cost and added value of the peer reviewprocess.It is not clear what kind of “increased return” is expected from “expanded access” that will come ata cost to scholarly publishers. Therefore, it is difficult to suggest ways to measure this return. Asmentioned above, the government has a current investment in PubMed Central, and the return onthat investment has not yet been determined or measured. We suggest that efforts to calculate theincreased return on the government’s investment in public access begin with an analysis of theusage statistics for PubMed Central.5. What features does a public access policy need to have to ensure compliance?A successful public access policy must be grounded in empirical evidence for need and demand, andmust be the result of careful, deliberate, and cooperative efforts to earn the full support of fundingagencies, the scientists whose work is to be disseminated, publishers, and scientific societies. It iscrucial than a public access policy be structured so that it does not undermine the quality of thescientific record (by providing access only to the final version of record) or the survival of scientificpublishers.6. What version of the paper should be made public under a public access policy (e.g., the author’speer reviewed manuscript or the final published version)? What are the relative advantages anddisadvantages to different versions of a scientific paper?The GSA believes that the version of record should be the final published version, without exception.The final published version has had value‐added by the publisher, including editing, copy‐editing,layout, table and figure work, the addition of technological features such as the database linksdescribed above. The simplest means of providing this access would be to provide a link to the finalversion of record, rather than establishing a separate repository of manuscripts.7. At what point in time should peer‐reviewed papers be made public via a public access policy relativeto the date a publisher releases the final version? Are there empirical data to support an optimallength of time? Should the delay period be the same or vary for levels of access (e.g. final peerreviewed manuscript or final published article, access under fair use versus alternative license), forfederal agencies and scientific disciplines?To our knowledge, there are no data to support an optimal subscription embargo period. Delayperiods should be determined by each publisher, because the optimal delay likely varies bydiscipline and publishers themselves are best equipped to decide how best to provide access to thearticles submitted to the journals they publish and whose value they have helped to create.GSA Response to OSTP Public Consultation on Public Access PolicyPage 5 of 7

GENETICS recently participated in a randomized, controlled study that measured the impact ofimmediate, free access to randomly selected articles in the journal on the rate of citation of thosearticles in subsequent publications. The study found that immediate free access did not confer acitation advantage. 2 In other words, the articles in GENETICS were read, accessed, or cited at asimilar rate regardless of free access or subscription control. This was true for all of the 36participating journals and over 3000 articles in the study.8. How should peer‐reviewed papers arising from federal investment be made publicly available? Inwhat format should the data be submitted in order to make it easy to search, find, and retrieve andto make it easy for others to link to it? Are there existing digital standards for archiving andinteroperability to maximize public benefit? How are these anticipated to change?This question implies that it is currently not “easy to search, find, and retrieve and . . . link to” peer‐reviewed papers that report on federally funded research. Search engines such as Google, GoogleScholar, and DeepDyve have worked with publishers to allow crawling of content for rapid and easysearch and retrieval. These search engine technologies are currently capable of locating and listingarticles that carry the proper attribution of funding by the federal government.Data formats and metadata specifications for interoperability and preservation change rapidly, asillustrated by the changes over the past 10 years. Successful publishing industry‐led initiatives likeCrossRef, Portico, and LOCKSS are examples of effective collaboration that fosters innovativeadvances in archiving and retrieval. Similar efforts continue to improve discoverability and the abilityof researchers to “mine” published data.9. Access demands not only availability, but also meaningful usability. How can the Federalgovernment make its collections of peer‐reviewed papers more useful to the American public? Bywhat metrics (e.g. number of articles or visitors) should the Federal government measure success ofits public access collections? What are the best examples of usability in the private sector (bothdomestic and international)? And, what makes them exceptional? Should those who access papersbe given the opportunity to comment or provide feedback?The results of government funding of research can be made meaningful to the American publicindependent of access to peer‐reviewed papers. Access to databases containing data on fundedgrants, contracts, and agreements such as abstracts, funding levels, award dates, and progressreports in lay language would serve the purposes of transparency and openness better than wouldaccess to peer‐reviewed publications.Scientific societies and publishers have been and are, appropriately, focused on developing andimproving usability of publication archives, databases, and other private‐sector repositories for theirprimary users – scientists – whose needs are readily determined and addressed.A constructive government policy would direct funding and efforts to determine the wants andneeds of the American public for scientific research results – in other words, what is are the uses ions/Fri530 Davis.pptGSA Response to OSTP Public Consultation on Public Access PolicyPage 6 of 7

which they will put this information. From this, it will be possible to define “usability” and thendetermine how to achieve it.One of the best examples of public demand driving usability is the development and growth ifiTunes. iTunes has, with some measure of success, addressed the consumer’s desire to sample andshare published content while protecting the financial interests of music publishers and recordingartists. iTunes’ (and other Apple products’) exceptional quality and usability is the result ofsignificant investment in software development, architecture and design, human factors andusability research, documentation and customer support.The Genetics Society of America appreciates the opportunity to submit these comments.Sincerely yours,R. Scott Hawley, Ph.D.PresidentGSA Response to OSTP Public Consultation on Public Access PolicySherry A. Marts, Ph.D.Executive DirectorPage 7 of 7

Dr. Diane DiEuliis . Submitted on behalf of the GSA by: Sherry Marts R. Scott Hawley Executive Director President . 301‐634‐7301 phone City, MO 64110Kansas 301‐634‐7079 fax [email protected] smarts@genetics‐ .