Association of Research Libraries (ARL®)

September 23, 2004

Dr. Elias Zerhouni
Director
National Institutes of Health
9000 Rockville Pike
Bethesda, MD 20892
United States of America

Dear Dr. Zerhouni,

Our company, BioMed Central Ltd, publishes a large number of NIH-funded research articles, all with full and immediate open access (ca. 15% - almost a thousand of the 6500 research articles we have published to date - indicate some form of NIH funding; all 6500 articles have been deposited immediately and in full in PubMedCentral). As the only commercial entity operating on a publishing model that ensures immediate and full open access to research literature, we feel it appropriate to comment on your notice regarding "Enhanced Public Access to NIH Research Information" (Notice Number: NOT-OD-04-064; September 3, 2004).

We are impressed with and enthusiastic about your initiatives to bring open access to research literature closer to reality, not just for the sake of the tax paying public, but for scientific progress itself, which stands to benefit significantly.

Since we publish research articles with open access and have done so for the last five years, we have come to conclude that there is a viable and feasible business model that ensures immediate open access, based on article processing charges payable by or on behalf of the author, as an integral part of the research process, instead of the traditional subscription charges to users and institutional libraries, which restrict access. All the open access articles we publish are deposited immediately in PubMed Central and in a number of other repositories in Europe as well, ensuring redundancy in accessibility. Whilst we have not reached our break-even point yet, our growth is in line with our business plan and we expect to reach profitability late in 2005 or early in the following year, thus demonstrating a sustainable business model for a commercial open access science publisher.

Our experience should be seen as a counter-argument to the reservations expressed by traditional publishers as to the economic sustainability of an open access publishing model. Any difficulties encountered by traditional publishers must be regarded as problems associated with the transition from the old model to an open access one, not as fundamental impediments. Given that our business is within sight of breaking even, in spite of the considerable handicap of having to build up name recognition and prestige for our journals from the start, an open access model will be much easier to implement for publishers with already established journals. With the right incentives we have no doubt that publishing with immediate and full open access can provide a fully sustainable business model for science publishers. We also believe that immediate open access publishing is essential for the effective conduct of scientific research and provides substantial benefits for society as a whole.

We fully recognize that these changes require adjustment on the part of traditional publishers and your proposal of a six months' initial delay of open access for published articles provides, in our opinion, a sufficient and appropriate help in this respect. We admire your initiative and will support it in any way we can.

Yours sincerely,

Jan Velterop
Publisher and Director
BioMed Central Limited