On September 27, 2023, and October 10, 2023, the US Department of Agriculture (USDA) held stakeholder listening sessions around their 2023 Implementation Plan to Increase Public Access to USDA-Funded Research Results, which included scheduled oral comments from stakeholders. The Association of Research Libraries (ARL) presented oral comments at the October 10, 2023, session. ARL is pleased to now offer the following written comments in response to this request.
ARL Comments on the 2023 Implementation Plan to Increase Public Access to USDA-funded Research
November 29, 2023
Cynthia Parr
National Agricultural Library
United States Department of Agriculture
10301 Baltimore Ave #115
Beltsville, MD 20705
Re: Stakeholder Listening Sessions Regarding Increasing Public Access to the Results of USDA-Funded Research
On behalf of the members of the Association of Research Libraries (ARL), thank you for the opportunity to provide comments as follow up to the Stakeholder Listening Session Regarding Increasing Public Access to the Results of USDA-Funded 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 USDA’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 USDA request for comments (NAL-2023-0001):
How can USDA best implement its plans to improve public access to USDA-funded research results?
ARL recognizes that institutional support to funded researchers may vary vastly. To ensure new researchers have support to meet requirements, ARL recommends that USDA:
- Minimize administrative and financial burden on researchers and institutions for compliance by working with institution-based service providers to educate and support the preparation of materials for sharing for public access.
- Specify allowable (and unallowable) costs for data management and sharing activities. This includes clearly stating if data storage and repository expenses post-award is allowed.
- Develop a mechanism to ensure that funds are available post-closeout for publication and research data storage and/or sharing expenses. Post-award publication funding may be particularly important for early-career, postdoctoral, and graduate student researchers whose publication and data sharing costs may not have been factored into the original grant budget.
- 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.).
- Adopt the Implementing Effective Data Practices report recommendations from higher education associations,[1] 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, including Funder IDs
How can USDA ensure equity in publication opportunities?
ARL appreciates the framing of “publication opportunities,” recognizing both publishing and access to publishing as equity issues, and recommends that the USDA:
- Work with research institutions, their libraries, and their professional and scholarly associations on coordinated education for investigators about their options for no-fee manuscript deposit.
- Explore preprint services to accelerate sharing of research findings and the potential of recognizing peer-reviewed preprints that are substantially similar to author-accepted manuscripts for the purposes of compliance with the policy.
- Ensure final publisher PDF versions are accessible. This is critical to enable equitable delivery of federally-funded research results. While publishers of scholarly works are able to add accessible features most effectively and efficiently, PDFs provided by publishers are not always 508 compliant. We recommend that public access plans include a plan to remediate non-compliant works in accordance with US copyright law, which explicitly grants a broad exception for remediation and distribution of accessible works to people with print disabilities. This exception is bolstered by the Marrakesh Treaty.
- Provide rights-retention language (for investigators 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.
- Adopt an evolving ethical framework, such as the US Department of Commerce Data Ethics Framework,[2] and specifically consider research that involves human participants and local communities.
How can USDA use partnerships to improve public access and accessibility to results of USDA-funded research?
ARL recognizes the importance of partnerships in improving public access and accessibility of federally funded research and recommends that USDA:
- Given the expansive nature of data management and sharing under the 2022 Nelson memo, we recommend that USDA review and prioritize the adoption of rights-holder centered principles for the ethical care of research data and engage stakeholder communities. For example, the CARE Principles for Indigenous Data Governance were created to allow Indigenous People to assert greater control over the use of Indigenous data and knowledge.[3] Tribal stakeholder engagement should be expected for research done on or about Indigenous Peoples.
- Engage US land-grant institutions, libraries, and cooperative extension programs to engage the public in federally funded agricultural research and innovation.
How can USDA monitor impacts on communities impacted by its public access policies?
ARL recognizes that public access policies have associated and highly varied costs, whether that be APCs to publish open access articles, costs to make data and manuscripts publicly available, such as data curation, or costs to run and maintain preprint servers or repositories. With these considerations in mind, ARL recommends that USDA:
- Work with research institutions to monitor costs and expenses for public access policies by tracking not just expenses included in the grant, but across the institution (from campus IT units, research libraries, and research offices) through a grant close-out report or commissioned study. These efforts will demonstrate a baseline level of expenses, and continued monitoring will ensure reasonable costs are maintained for the sharing of manuscripts and other scholarly outputs.
- Monitor publication trends across publication formats, including journal articles, book chapters, and other peer-reviewed publications.
- Review the publication costs of journal titles that USDA-supported researchers most commonly publish in.
Regarding non-cost related impact on communities, ARL recommends that USDA:
- Track data citations for USDA-funded datasets over time to best understand dataset use and reuse, and the impact of data reuse on advancing science. Depending on the discipline, project, or dataset, data reuse may not occur for many years after publication, and this delay in citation (re)use may impact new researchers or those seeking career advancement.
We look forward to continued engagement with USDA and the National Agricultural Library (NAL) during the development and refinement of the USDA’s Public Access Plan. We are happy to work with USDA to identify ARL member institutions—in addition to NAL—interested in participating in conversations regarding any of these specific topics. With any questions about these comments, please feel free to contact me or my colleague Cynthia Hudson Vitale, Director, Science Policy and Scholarship, ARL, cvitale@arl.org.
Sincerely,
Mary Lee Kennedy, Executive Director
Association of Research Libraries
Endnotes
[1] 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.
[2] United States Department of Commerce. “Commerce Data Ethics Framework.” 2022. https://www.commerce.gov/sites/default/files/2023-02/DOC-Data-Ethics-Framework.pdf
[3] Carroll, Stephanie Russo, Ibrahim Garba, Oscar L. Figueroa-Rodríguez, Jarita Holbrook, Raymond Lovett, Simeon Materechera, Mark Parsons, et al. “The CARE Principles for Indigenous Data Governance.” Data Science Journal 19 (2020): 43. https://doi.org/10.5334/dsj-2020-043.
