In his "Analysis of Comments and Implementation of the NIH Public Access
Policy <http://edocket.access.gpo.gov/2009/E9-3442.htm>," Dr. Raynard
Kington <http://www.nih.gov/about/director/index.htm>, Acting Director,
National Institutes of Health (NIH), writes that

*"direct feeds from [institutional repositories (IRs) are]... worthwhile...
but... raise important technical and logistical challenges regarding author
approval, copyright permissions, quality control, and formats for electronic
transfer. The NIH remains open to closer collaboration with institutional
[repositories] and will consider this issue as the Policy matures."*

It is virtually certain that all technical and logistical challenges to
designating Institutional Repositories
(IRs)<http://roar.eprints.org/?action=home&q=&country=&version=&type=institutional&order=name&submit=Filter>
as
NIH's preferred locus of direct deposit (followed by "direct feed" to PubMed
Central (PMC) <http://www.pubmedcentral.nih.gov/>) can be successfully met
(and most already have been: see below). The benefits of NIH/institutional
collaboration<http://blogsearch.google.ca/blogsearch?hl=en&num=100&c2coff=1&safe=active&oi=spell&ie=UTF-8&q=%28mandate+OR+mandates%29+%28%28integrate+OR+integration%29+OR+convergence%29++OR+NIH+blogurl%3Ahttp%3A%2F%2Fopenaccess.eprints.org%2F&btnG=Search+Blogs>
on
direct feeds will be enormous, and will far exceed the current reach of the NIH
mandate<http://www.eprints.org/openaccess/policysignup/fullinfo.php?inst=National%20Institutes%20of%20Health%20%28NIH%29>
(which
is now restricted to the 80,000 articles a year resulting from NIH funding,
no more, no less).

The NIH mandate touches the institutions of every one of NIH's fundees. If
the NIH mandate preferentially encourages its fundees to deposit their
NIH-funded output in their own respective IRs (with direct feed to to PMC
therefrom, instead of direct deposit in PMC, as now), it will also motivate
their fundees to deposit -- and motivate their fundees' institutions to
mandate the deposit of -- the *rest of their institutional output* in their
IR too, not just the NIH-funded fraction of it. Not so if the 80,000 NIH
articles must be directly deposited institution-externally (in PMC): That
has the exact opposite effect, competing with and complicating, hence
demotivating institutional deposits and mandates. (And we must not forget
that the institutions are the universal providers of all research output:
funded and unfunded, across all disciplines.)

The "technical and logistical challenges" for "direct feeds" from IRs to PMC
have already been largely met:

*(1)* The SWORD transfer
protocol<http://openaccess.eprints.org/index.php?/archives/484-guid.html>
has
already solved the problem of automatically exporting IR deposits to other
respoitories.

*(2)* "Author approval" is not a problem at all: Authors are mandated by NIH
to deposit, and NIH specifies the locus of deposit. Currently that
designated locus is PMC. The recommendation here is that the preferred locus
of deposit should instead be the author's IR, with the deposit then
automatically ported by "direct feed" (via SWORD) to PMC. (Institutional
deposit will in fact simplify deposit for authors, increasing their
motivation to comply with the NIH mandate.)

*(3)* "Copyright permissions" are not a problem either: Authors are mandated
by NIH to deposit and NIH specifies the locus of deposit. If copyright is
not an issue with PMC deposit, it is even less of an issue with direct
institutional deposit in the fundee's own IR. (Publisher embargoes can be --
and are -- implemented by IRs just as they are by PMC.)

*(4)* "Quality control" is not a problem either. Authors are mandated by NIH
to deposit their final, refereed, revised draft, and NIH specifies the locus
of deposit. The IR deposit can be exported by "direct feed" (via SWORD) to
PMC, where exactly the same quality controls can be performed as are now
being performed by PMC. (The IR direct-deposit protocol can easily be made
to conform to the PMC direct-deposit protocol: they are almost identical
already.)

*(5)* "Formats for electronic transfer" is not a problem either. The SWORD
protocol does the electronic transfer, and the format for deposit of the
author's final, refereed, revised draft is exactly the same.

It is very welcome and timely news that NIH's Acting Director is "open to
closer collaboration with institutional archives." The sooner a
collaborative deposit policy, with IR deposit and direct feed to PMC can be
adopted and announced, the sooner its potentially enormous knock-on effects
will begin to make themselves felt in helping to wake the "slumbering
giant<http://openaccess.eprints.org/index.php?/archives/522-guid.html>"
-- the US and global network of universities and research institutes, not
only the NIH-funded ones, but all of them: the universal providers of
research, worldwide -- to create their own IRs (if they don't have them
already) and to mandate the deposit of all of their own research output into
them, not just NIH-funded research.

This global enabling effect of the NIH mandate for accelerating and
facilitating universal OA should also be cited in the defense of NIH's
historically invaluable public access policy against the Conyers
Bill<http://blogsearch.google.ca/blogsearch?hl=en&num=100&c2coff=1&safe=active&oi=spell&ie=UTF-8&q=Conyers+blogurl%3Ahttp%3A%2F%2Fopenaccess.eprints.org%2F&btnG=Search+Blogs>'s
attempt to overturn it.

(And the other research funding councils worldwide, too, should be
encouraged to consider the enormous potential OA gains -- at no loss -- from
stipulating IR deposit rather than institution-external deposit in their own
OA policies as well.)

*Stevan Harnad <http://www.eprints.org/openaccess/>*
American Scientist Open Access
Forum<http://amsci-forum.amsci.org/archives/American-Scientist-Open-Access-Forum.html>