UMass Libraries comments to NSF on open access

The UMass Libraries have submitted comments to the NSF for its 2017-2018 Strategic Plan update.  (Further reading: Summary of current Strategic Plan, and full text of current Strategic Plan, published in 2014.)

Re: Comments on Strategic Plan, 2017-18 Update

Dear National Science Foundation,

Thank you for providing this opportunity to comment on the 2017-18 update to the NSF Strategic Plan. We are librarians at the University of Massachusetts Amherst, University Libraries, who jointly work to administer open access and data management services at our institution. We write to comment on several aspects of open access and data management.

We are pleased that the NSF introduced a public access policy and has begun to implement it. This was a welcome and necessary first step in ensuring access both by the public and by fellow researchers. Our comments highlight additional steps that can build upon this initial work.

First, experience has shown that both public and researcher access is maximized by use of a central repository, such as PubMed. We would encourage the NSF to join forces with other federal science researchers in developing such a centralized repository, or in working to expand PubMed beyond the the broad biomedical fields. This would enhance the discoverability of works, as well as their utilization. Distributed access through publisher websites does not provide adequate discoverability, access, or utility of the works by researchers, and is particularly challenging for members of the public.

Second, to support the full use of the NSF’s funded scholarly research, the public access policy must mandate that works and data be fully text-and-data mineable. This will require both standard licensing, such as Creative Commons licensing, and full implementation of open standards for metadata and machine-readable XML formatting of the articles.

In particular, all data needed to validate or reproduce published findings should be required to be publicly available at time of publication. We recommend adoption of the FAIR Data Principles (Findable, Accessible, Interoperable, and Reusable) or an equivalent.

Finally, we urge the NSF to investigate and improve the transparency of funding and publication processes. The NSF has the power to support positive transformations in the sharing of research data, dissemination of model data management policies, data about grant compliance, and other aspects of publicly funded research. This would have the double benefits of enhancing transparency and accountability among both the NSF and researchers, and highlighting and increasing the discoverability of the research.

We would be happy to elaborate further on any aspect of our comments.


Simon Neame, Dean of Libraries
Thea Atwood, Science and Engineering Librarian
Marilyn Billings, Scholarly Communication and Special Initiatives Librarian
Erin Jerome, Open Access and Institutional Repository Librarian
Ellen Lutz, Science and Engineering Librarian
Laura Quilter * , Copyright and Information Policy Librarian
Jeremy Smith, Digital Project Manager

University of Massachusetts Amherst

Laura Quilter is the corresponding author. Please address correspondence to her at

Leave a Reply

Your email address will not be published. Required fields are marked *