On March 28, 2023, the US Department of Transportation (DOT) released a request for information on “Increasing Public Access to the Results of USDOT-Funded Transportation Research (DOT-OST-2023-0045).” The Association of Research Libraries (ARL) is pleased to offer the following comments in response to this request.
ARL Comments on the Request for Information for Increasing Public Access to the Results of USDOT-Funded Transportation Research
May 18, 2023
US Department of Transportation
1200 New Jersey Avenue SE
West Building
Washington DC 20590-0001
Re: Request for Information for Increasing Public Access to the Results of USDOT-Funded Transportation Research (DOT-OST-2023-0045)
On behalf of the members of the Association of Research Libraries (ARL), thank you for the opportunity to provide comments on “Increasing Public Access to the Results of USDOT-Funded Transportation Research.” ARL and its members are committed to the advancement of open scholarship and open access to accelerate scientific advances and to expand diverse, public participation in federally funded research. We appreciate DOT’s commitment to making the results of federally funded research widely available without embargo, leveraging persistent identifiers to support scientific integrity, and ensuring equitable access.
We submit the following comments on the DOT request for information (RFI) “Increasing Public Access to the Results of USDOT-Funded Transportation Research.”
In addition to the specific actions below, overall, we recommend that DOT:
- Minimize administrative and financial burden on researchers and institutions for compliance by working with campus-based service providers to educate and support the preparation of materials for sharing for public access
- Monitor costs and expenses for public-access policies by tracking not just expenses included in the grant, but across the institution (from campus IT, research library, and research office) through a grant close-out report or commissioned study
- Collaborate with scholarly societies, researchers, and libraries to define a public-access deposit package that is inclusive of policy requirements (such as manuscript, protocols, reports, data, metadata and documentation, etc.)
1. How best to improve access to textual research outputs.
ARL recommends that DOT:
- Explore use of institutional repository, persistent identifier registration agencies, and publisher APIs, such as Crossref and Open Archives Initiative Protocol for Metadata Harvesting (OAI-PMH) feeds, to discover and harvest metadata and textual research outputs to populate the DOT National Transportation Library digital repository
- Work with emerging technologies, such as the Public Access Submission System (PASS), to automate the deposit of public-access versions of manuscripts to meet policy requirements
2. How best to improve accessibility of textual research outputs.
ARL applauds the efforts of DOT to develop and launch the National Transportation Knowledge Network, especially the Section 508 compliance community of practice. Initiatives such as this are critical for advancing the accessibility of all research outputs.
ARL recommends:
- Encouraging open licenses that allow for text and data mining
- Requiring that all deposited manuscripts or final publications meet Web Content Accessibility Guidelines (WCAG) and Section 508 compliance standards, so publications can be properly rendered to assistive technologies
3. How best to improve access to scholarly publications from DOT-funded research.
If a researcher chooses to accept funding from DOT or other federal R&D agencies, they must agree to grant the funding agency a nonexclusive license to their scholarly outputs funded by the grant. In this scenario, the researcher retains their copyright, unless and until they assign it to another party, such as a publisher. According to the August 2022 Nelson memo,[1] agency policies must describe the prerequisites needed to make publications freely and publicly available by default, including reuse rights and attribution, which has implications for the type of license that the researcher may use. Retaining copyright enables researchers to make those license choices.
ARL recommends that DOT:
- Continue to allow researchers to deposit public-access versions of their manuscripts in institutional repositories. Much like federal repositories, institutional repositories, and in particular those supported by research libraries, have made significant commitments and investments in making accessible and preserving the intellectual outputs of their institutions.
- Work more closely with research librarians to educate and inform researchers on their campuses about the DOT public-access policy and compliance workflow.
- Provide rights-retention language (for researchers to use upon submission of manuscripts to journals) that encourages authors to retain their copyrights and assign a Creative Commons Attribution (CC BY) or similar license to their work in order to enable full reuse rights. Open licenses are easy to understand for both researchers and users, so more users can access and reuse content, and more researchers can provide access to and reuse of their work.
- Consider using the following language, modeled after the Wellcome Trust language:
This research was funded in whole or in part by the Department of Transportation [grant number]. For the purpose of public access, the author has applied a CC BY public copyright license to any author-accepted manuscript version arising from this submission.
According to cOAlition S funders, “In the two years or so since this [rights retention] approach was introduced by many cOAlition S funders, [the funders] are only aware of one example where a publisher rejected a manuscript due to the existence of a prior licence.”[2]
- Develop a mechanism to ensure that funds are available post-closeout for publication expenses. Post-award publication funding may be particularly important for early-career, postdoctoral, and graduate student researchers whose publication costs may not have been factored into the original grant budget.
- Consider additional supplemental funding or new grant models to support innovative institutional services for researchers in meeting public-access requirements. ARL member institutions and their libraries help researchers navigate the various publishing options, manuscript versions, publisher policies, and the differences between public-access publishing and repository deposit.
4. How best to improve access to datasets.
ARL supports DOT’s determination to allow researchers to share data in an institutional, third-party, domain-specific, or generalist repository or with DOT. Institutions, and in particular, research libraries, have made significant investments in institutional data repository infrastructure and services. In a recent analysis of research-data services within an institution, libraries were found to offer and support the greatest number of services for researchers to meet data-related public-access activities.[3] As seen in Figure 1 below, research libraries provide research-data services and infrastructure for public access across many points in the research-data life cycle.
As stewards of the scholarly record, research libraries have made a long-standing commitment to preserve the research outputs of their institutions and researchers and to make them broadly available; these outputs may include publications, datasets, code, virtual machines, and other research outputs, such as operational capacity and software.
The Association of Research Libraries recommends that DOT:
- Continue to recognize research libraries as partners in making research data publicly accessible
- Work with organizations, such as the National Transportation Knowledge Network and the Data Curation Network, to develop curation best practices to ensure the ongoing availability of datasets
- Partner with scholarly societies to define appropriate data retention and data review schedules
5. How to implement evolving ethical frameworks to DOT-funded research.
DOT-funded research is not immune to biases and ethical considerations. With the growth of artificial intelligence (AI), including advanced facial-recognition software and pattern-synthesis tools, DOT has a responsibility to ensure that research leveraging these tools protects privacy and that individuals involved in the research are informed of, and give consent for, data-sharing practices. Not only that, ensuring shared research outputs are deidentified and these AI tools cannot reconstruct human likeness (in the case of video or image data), or identify individual addresses or other sensitive information (in the case of research involving human interaction).
ARL recommends that DOT:
- Develop mechanisms for creating and reviewing ethical frameworks for DOT-funded research. For example: convene a task force or leverage the National Transportation Knowledge Network in partnership with experts in risk assessment and such organizations as the Global Indigenous Data Alliance, to create effective practices for research involving minoritized communities and the sharing of DOT-funded research.
- Encourage DOT-funded researchers who may utilize Indigenous Knowledge, which is a “body of observations, oral and written knowledge, innovations, practices, and beliefs developed by Tribes and Indigenous Peoples through interaction and experience with the environment,”[4] to recognize it as such in their research outputs. The recognition of Indigenous Knowledge as an important body of knowledge that supports the research enterprise may not only strengthen research, but this recognition may support Indigenous self-determination.
- Consider working closely with other federal agencies to define a framework for ethical use of AI and transparent reporting practices for AI use.
6. How to implement persistent identifiers (PIDs) for people, research documents and outputs, and research entities.
The Association of Research Libraries recommends that DOT:
- Adopt the Implementing Effective Data Practices report recommendations from higher education associations,[5] including the adoption of the following persistent identifiers (PIDs) at a minimum:
- Digital object identifiers (DOIs) for each publication and research output (data, code, software, etc.)
- Open researcher and contributor identifiers (ORCID IDs) to uniquely identify authors
- Research Organization Registry (ROR) IDs to link authors with known organizations
- Crossref Funder Registry IDs to associate a research output with a granting agency
- Crossref Grant IDs to uniquely identify a research award with an author, an organization, and a funding agency
The Implementing Effective Data Practices report also provided considerations that would help support this necessary PID infrastructure. DOT could lead the following to advance the sharing of research and research data.
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- DOT, in coordination and harmonization with other federal agencies, could fund the design and development of tools and services to support the use of PIDs. DOT could fund researchers developing research-related workflows and systems that enable the collection of PIDs, storage of PID metadata, and connections to PIDs in other systems.
- DOT, in coordination and harmonization with other federal agencies, could invest in infrastructure and initiatives that support the use of PIDs by supporting member organizations that promote open scholarly infrastructure, such as Crossref, DataCite, and ORCID; funding organizations and data repositories that follow best practices for FAIR (findable, accessible, interoperable, and reusable) data; and supporting community-led initiatives such as the Research Organization Registry and DMPTool.
- DOT, in coordination and harmonization with other federal agencies, could minimize the burden on researchers by making it easy and seamless for researchers to use PIDs by designing workflows and systems to assign and collect them automatically and by supporting PID services or data repositories.
- Finally, DOT could work with vendors of tools to require them to adopt workflows and software that automatically collect PIDs. This will be especially necessary for less-resourced institutions that may not have research librarians to provide these services.
We look forward to continued engagement with DOT during the development of the agency’s public access plan. We are happy to work with DOT to identify ARL member institutions to participate in conversations regarding any of these specific topics. Please feel free to contact me or my colleague Cynthia Hudson Vitale, director of Science Policy and Scholarship, cvitale@arl.org, with any questions about these comments.
Sincerely,
Mary Lee Kennedy
ARL Executive Director
Endnotes
[1] Alondra Nelson, “Ensuring Free, Immediate, and Equitable Access to Federally Funded Research,” US Office of Science and Technology Policy, August 25, 2022, https://www.whitehouse.gov/wp-content/uploads/2022/08/08-2022-OSTP-Public-Access-Memo.pdf.
[2] “Making Full and Immediate Open Access a Reality,” cOAlition S, April 11, 2023, https://www.coalition-s.org/wp-content/uploads/2023/04/cOAlitionSresponseForNIH.pdf.
[3] Shawna Taylor, “Realities of Academic Data Sharing (RADS) Initiative: Research Update #2—Activities for Making Research Data Publicly Accessible,” ARL Views blog, November 28, 2022, https://www.arl.org/blog/realities-of-academic-data-sharing-rads-initiative-research-update-2-activities-for-making-research-data-publicly-accessible/.
[4] “White House Releases First-of-a-Kind Indigenous Knowledge Guidance for Federal Agencies,” The White House, December 1, 2022, https://www.whitehouse.gov/ceq/news-updates/2022/12/01/white-house-releases-first-of-a-kind-indigenous-knowledge-guidance-for-federal-agencies/.
[5] Chodacki, John, Cynthia Hudson-Vitale, Natalie Meyers, Jennifer Muilenburg, Maria Praetzellis, Kacy Redd, Judy Ruttenberg, Katie Steen, Joel Cutcher-Gershenfeld, and Maria Gould. Implementing Effective Data Practices: Stakeholder Recommendations for Collaborative Research Support. Washington, DC: Association of Research Libraries, September 2020. https://doi.org/10.29242/report.effectivedatapractices2020.
