http://grants1.nih.gov/grants/guide/notice-files/NOT-OD-04-064.html

This is a public comment on NOT-OD-04-064, "Enhanced Public Access to NIH
Research Information."

Feedback on the proposed Public Access CONCEPT:

NIH's proposed plan for mandating free public access to published research
reports is an excellent idea whose implementation comes none too soon.

Historically, the subscribers-only nature of scientific journal publishing
was driven by physical limitations of the print medium: the administrative
cost of the editorial process often was a minor factor in comparison to
the costs of printing and distribution by the journal and archiving by the
subscribing libraries.  With the nearly universal implementation of electronic
distribution, though, the print medium has become largely superfluous:
though presses continue to turn out glossy-covered artefacts as a sort of
justification for their work, researchers looking for a specific paper almost
always find it electronically.  Thus the only remaining external justifications
for subscription fees are the funding of the editorial process which maintains
the quality of the work presented in the journal (much of which is done
without pay by peer reviewers), and the cost of producing high-quality copy
for (electronic) publication.  Neither of these justifications seem absolute.

Existing systems of pay-per-article access for non-subscribers seem to
generate more hassle for readers than they do any revenue for publishers.  As a
working scientist, I hardly ever actually pay to download a paper.  Instead,
I send a reprint request to the author, or download remotely to an institution
that does have a subscription.  Though I often spend a significant amount of
time getting round access restrictions, I hardly ever spend money to do so,
since the high prices set by publishers for online access don't seem worth it.

Open access is an idea whose time has come - in fact it came a decade ago -
and the only factor that's prevented its implementation is the fact that
hardly any high-impact or speciality journals follow the open access model.
As a result, the best papers keep going to closed-access journals, and the
process becomes a vicious circle.  A mandate from a large funding agency
such as the NIH is precisely what's needed to level the playing field for
all the publishers, so that business competition can no longer be a factor
in their decisions on open access.

Outside the United States there are successful analogues of the proposed
mandate - for instance, reports of research conducted intramurally by
government institutions in the United Kingdom is subject to Crown Copyright
and may be freely distributed, even if it's published in scientific journals.
The journals accept this mandate because they want to be able to publish
research of high quality.  Furthermore, the success of new open access
publishing ventures, including Biomed Central in the United States,
demonstrates the viability of open access as a business model.

Feedback on the proposed IMPLEMENTATION PLAN:

The six-month lag seems a workable initial compromise between completely
open access and subscription.  Eventually I'd like to see research reports
available to the public as soon as they're generated and reviewed.

Some research not funded by NIH is funded by foundations and other
non-governmental organisations which may be keen to see the results of
their investments made public but which likely will not have the resources
to implement and to maintain the computing infrastructure for open-access
storage and retrieval.  It would be a boon to these organisations, as well
as to researchers, if they were permitted to participate voluntarily in the
open-access system maintained by NIH.