Critique of PSP/AAP Critique of NIH Proposal

From: Stevan Harnad <>
Date: Wed, 10 Nov 2004 23:44:51 +0000

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 at:

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
or e-mail your comments to

    NIH/Open Access -- Grassroots Memo

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:
> (
> [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 are 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 were published, These
positive conseqeunces have already been tested objectively for over a
decade and hence have already been quantitatively demonstrated: Research
progress and productivity will definitely be enhanced by free online
access, and so will research applications to the public good.

All claims about *negative* consequences, in contrast, are purely
hypothetical, and hypothesized 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:

(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,
and they are needed now.)

> 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 those fields of research
where public-access supplements already reached 100% several years ago --
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 those costs. The system can adapt naturally and gradually
to free public online access, without any "irrevocable disruptions."

    "The Green Road to Open Access: A Leveraged Transition"

> 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 stated objective of providing free public online access is to provide
free public online access, and that objective 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 and their families.

It is obvious how authors, scientific discourse and scholarship benefit
from this enhanced access.

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 objective 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

> 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 too is groundless: If and when the hypothesized
institutional subscription cancellations for incoming journals were
ever to occur, each institutions' own resulting windfall savings would
be more than enough to pay journals for the remaining costs of
publishing that institution's own 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
those fields where the free supplements have already 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) -- 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 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 (hypothetical) windfall savings would be those of the
research-institutions, and they would be more than enough to cover the
irreducible costs of publishing their own outgoing articles if and
when the hypothetical conditions arose that necessitated it.

> 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 not publishing, nor is it funding publishing costs. It is
merely mandating free public online access provision for its funded
research. All else is hypothetical. (If the hypothesized cancellations
were ever to occur, cost-cutting, downsizing, and institutional
windfall savings would 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 one way or the other on the
"integrity of the scientific record": It just *supplements* that record
by providing free public online access to the portion of it that NIH
funded for all would-be users who cannot afford access to the journal
in which it appeared

There is no "government censorship," just peer review, provided by
the very same journals, exactly as before. The proposal entails no
"politicization of science," only free public online access to the
portion if is that NIH funded; nor is the proposal in any way governed by
"vagaries of funding cycles and changes in agency management." (It Is not
a proposal to use research funds to pay open-access journal publication
costs.) 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

> 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. (The NIH
proposal 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:

> 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. -- NIH's 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 proposal makes no judgment whatsoever 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, those very
cancellations will thereby also constitute the corresponding
institutional windfall savings out of which all essential values can
continue to be paid (in particular, the cost of providing peer

> 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 (and this will
surely not be because the NIH portion alone of journal articles have
free-access supplements), 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 is difficult to describe as anything other than 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 just classical peer review; no new "censorship or

> 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 -- --
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

> 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 applied) 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 NIH mandate is that NIH fundees must make a supplementary version
of peer-reviewed articles reporting NIH-funded research publicly
accessible for free online -- not that they must be published in any
particular journal, with any particular cost-recovery model. The
speculations about a transition to author-institution-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 cited above are purely *hypothetical,*
contingent on a speculation about the hypothetical 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 those 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 storing 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 ( 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 supplementary 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)..

> 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 being 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: ).

The rest of the above passage 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:

    "(1) Mandating that free public online access to the published
    results of NIH-funded research must be provided for the published
    results of NIH-funded research would lead to (2) mandating that
    the results of NIH-funded research cannot be patented or applied to
    produce revenue-bearing products"

and then going on to treat the NIH mandate as if it had been for (2)
rather than (1). (Yet (1) and (2) are not the same, and nothing remotely
like (2) has been proposed!)

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 impact of each fundee's research, by
maximizing access to it by all would-be users -- which in turns has
benefits 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 far
more prudent not to renounce the direct and objectively demonstrated
and documentd benefits of maximizing research access and impact --
merely on the basis of a speculative 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
(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 (many other things would be). But not
*instead* of providing free public access to research online, but *in
addition* to it. This is no argument against public access! And among
the potential users benefited are other researchers -- who need help not
in health literacy but 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 research access policy 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 their would-be users webwide (to ensure online
accessibility irrespective of whether those users or their institutions
can afford access to the journal in which the findings happen to be
published) in order to maximize how fully 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 the researcher's institution, for the
researcher's funder, and for the research funder's 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
or e-mail your comments to

Stevan Harnad
A complete Hypermail archive of the ongoing discussion of providing
open access to the peer-reviewed research literature online (1998-2004)
is available at:
        To join or leave the Forum or change your subscription address:
        Post discussion to:

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:

    BOAI-2 ("gold"): Publish your article in a suitable open-access
            journal whenever one exists.
    BOAI-1 ("green"): Otherwise, publish your article in a suitable
            toll-access journal and also self-archive it.
Received on Wed Nov 10 2004 - 23:44:51 GMT

This archive was generated by hypermail 2.3.0 : Fri Dec 10 2010 - 19:47:40 GMT