The following comments were posted in response to the OSTP’s call as posted here: http://www.ostp.gov/galleries/default-file/RFI%20Final%20for%20FR.pdf. The first wave, comments posted here, asked for feedback on implementation issues. The second wave requested input on Features and Technology (our post is here). For the third and final wave on Management, Chris Wiggins, Matt Knepley, and I posted the following comments:
Q1: Compliance. What features does a public access policy need to ensure compliance? Should this vary across agencies?
One size does not fit all research problems across all research communities, and a heavy-handed general release requirement across agencies could result in de jure compliance – release of data and code as per the letter of the law – without the extra effort necessary to create usable data and code facilitating reproducibility (and extension) of the results. One solution to this barrier would be to require grant applicants to formulate plans for release of the code and data generated through their research proposal, if funded. This creates a natural mechanism by which grantees (and peer reviewers), who best know their own research environments and community norms, contribute complete strategies for release. This would allow federal funding agencies to gather data on needs for release (repositories, further support, etc.); understand which research problem characteristics engender which particular solutions, which solutions are most appropriate in which settings, and uncover as-yet unrecognized problems particular researchers may encounter. These data would permit federal funding agencies to craft release requirements that are more sensitive to barriers researchers face and the demands of their particular research problems, and implement strategies for enforcement of these requirements. This approach also permits researchers to address confidentiality and privacy issues associated with their research.
Examples:
One exemplary precedent by a UK funding agency is the January 2007 “Policy on data management and sharing”
(http://www.wellcome.ac.uk/About-us/Policy/Policy-and-position-statements/WTX035043.htm)
adopted by The Wellcome Trust (http://www.wellcome.ac.uk/About-us/index.htm) according to which “the Trust will require that the applicants provide a data management and sharing plan as part of their application; and review these data management and sharing plans, including any costs involved in delivering them, as an integral part of the funding decision.” A comparable policy statement by US agencies would be quite useful in clarifying OSTP’s intent regarding the relationship between publicly-supported research and public access to the research products generated by this support.