On March 17, 2008, SPARC responded to the NIH call for comments held in conjunction with a public meeting to be held on the NIH Public Access Policy, March 20. A copy of those comments follows:

Subject: SPARC continues to support the timely implementation of the NIH mandate
Submitted by: Dr. Ray English, Chair, SPARC Steering Committee, Azariah Smith Root Director of Libraries, Oberlin College

SPARC (the Scholarly Publishing and Academic Resources Coalition) is very pleased that the revised National Institutes of Health (NIH) Public Access Policy is moving toward timely implementation. We strongly believe that effective, immediate implementation of this policy will greatly improve the ability of researchers to access, share, and use the results of the critical biomedical research funded by your agency.

As an organization of more than 220 academic and research libraries on campuses across the U.S., SPARC and its members are committed to the promotion of programs and policies that expand the dissemination of research results, reduce barriers to the use of those results, and leverage the networked digital environment in an efficient, cost-effective manner. We believe that the NIH Public Access Policy provides an important opportunity to further these aims. It is a major development that enhances our member institutions’ ability to fulfill their commitment to the advancement of scientific knowledge.

SPARC has been strongly supportive of this policy since it was first proposed in 2004 and, along with many of our institutional members, has created several programs to help to pave the way for the smooth implementation of the revised policy. The variety of educational initiatives and practical tools we have prepared are specifically designed to help the higher education community leverage this groundbreaking new opportunity. For example:

SPARC has deployed a comprehensive educational initiative to inform authors of their rights and responsibilities as copyright holders. This campaign emphasizes that authors must be aware of the rights they need to retain in order to comply with the NIH Public Access Policy, and features the SPARC Author Addendum as one tool authors may deploy to ensure they have retained the rights they need. (See http://www.arl.org/sparc/author for details.)

Recently, SPARC (along with the Association of Research Libraries and Science Commons) also published a white paper outlining six alternative copyright management strategies that campuses may consider adopting to guarantee that the institution and its researchers meet the policy’s requirement for compliance with current copyright law. (See http://www.arl.org/sparc/advocacy/nih/copyright.html.)

Author rights, copyright policies, and the NIH policy are the focus of SPARC’s recent and ongoing campus presentations, Web casts, and meetings with university administrators – including vice provosts for research.

Many SPARC institutions have also been actively working to build awareness of the policy and its requirements, and to create mechanisms to smooth the compliance process. Member campus libraries have established online resources with up-to-date information and guidance on compliance; a number of campuses have convened meetings to provide researchers with further support; and some campuses have used e-mail, newsletters, and online grants management systems to ensure that researchers know about the policy and its requirements in a timely manner.

Many SPARC members have established robust author rights management campaigns. These are now being deployed to specifically address questions related to the NIH policy and how authors may comply. Many universities are also providing explicit language to their authors to ensure proper copyright compliance. (See: http://www.mclibrary.duke.edu/nihpolicy for just one of many examples.)

While these libraries are playing central roles in facilitating communication and compliance programs, they are by no means acting alone. On many campuses, these efforts have involved close collaboration among librarians, researchers, research administrators, and university counsel. SPARC’s members view the NIH policy as a welcome opportunity to work in concert with their campus colleagues and contribute directly to the mission of the institution – to promote and advance knowledge.

SPARC commends the National Institutes of Health for issuing implementation guidelines in a timely manner and for being consistently responsive to queries about the process from our member organizations.

SPARC applauds the National Institutes of Health for advancing this important policy, which will provide a rich and innovative suite of new resources – as well as access to critical biomedical research findings – to researchers on our campuses and beyond. Prompt implementation of this policy will accelerate the pace of research and discovery, fuel innovation, and serve the public good.

SPARC looks forward to continuing to work with both its member libraries and the broader American academic community to ensure the policy’s success.