========== Following are my comments, in two parts, ====== ========== exactly as submitted to NIH ==================
FROM: Albert Henderson, Editor, PUBLISHING RESEARCH QUARTERLY <70244.1...@compuserve.com> We share a vision of effective science using the rapid communication features of information technology. We differ when it comes to the means of reaching this goal. My comments focus on (A) problems inherent in the present rather radical proposal and (B) solutions that I believe you have not considered The complaint of NIH director Harold E. Varmus that, "researchers spend hundreds of dollars of their NIH awards on subscriptions to scientific journals," (1) reveals serious defects in policy choices made over the last 30 years or so. Using grant money for subscriptions has always been an option. My recollection is that universities, not research grants, once paid for most subscriptions found in offices and laboratories. Universities canceled most such "duplicates" in the 1970s. In recent decades, over the protests of faculty and faculty senates, universities continued to cut library spending. They have been canceling the last remaining copies of many journals. (2) Studies indicate nevertheless that researchers use libraries more than ever, with library borrowing rates sharply increased. (3) It also appears that better financed researchers now order their own copies of journals no longer found in the library. Although they purchase these publications with public money, they neither share them generally nor maintain formal collections. In other words, local colleagues may still have to order interlibrary photocopies of articles that they identify via information services and citations rather than browsing. Vannevar Bush charged universities with the responsibility to conserve knowledge as part of the government-academic research partnership. (4) It was a Faustian bargain. Instead of maintaining information produced and used by government research programs, universities cut library spending (and Federal agencies permitted it!). Universities seek further relief from library costs, even in the robust economy of the 1990s, while confessing that the imbalance between library and research growth is a source of serious problems. (5) The millions of dollars of subscriptions now paid by research grants, described by Dr. Varmus to Congress, represents the unloading of universities' traditional responsibility onto researchers who have grants. The cancelations also drove publishers' prices upward, providing a foundation for denunciation and calls for new solutions. Taking the prospect of "no library" another step, provosts at CalTech and elsewhere propose that researchers divert even more grant money to self-publishing their work. (6) The present proposal falls directly into this trap. It would make it easy for universities to justify the further elimination of their subscriptions to advanced research journals and information services by shifting the full responsibility for conserving knowledge to the government. The present proposal serves such financial goals without realistically solving problems in dissemination and the quality of research. I note generous use of the appeal of "free" information. What is the cost to the taxpayer? How much equipment, labor, time, and other resources will be needed? How many articles a year will be served electronically? What about standards and obsolescence? Who will pay for equipment required for access? What will be the impact on scientists and institutions who are not fully wired? What will be the impact on the use of publications produced only in paper, including the corpus of previously published literature? Will NIH take responsibility for digitizing that? What about copyrights? There are also major questions of permanance being asked about the use of fragile storage for journals often called "archival." How will the E-Biomed proposal deal with the growth of science -- now generating millions of articles a year and growing exponentially? Is NIH prepared to face Congressional challenges to technology that is far from perfect? I am certain there are other good reasons that faculty who quickly embraced email, bibliographic databases, mainframe computing, and laptops are reluctant to join administrators' undaunted support of support electronic journals. I believe Federal agencies were in error when they ended studies of science communication in the mid-1970s. The present proposal has no recent science or scientists to provide a context for evaluation. It has only lobbies with financial, rather than scientific, priorities and enthusiasts who more often than not have no experience as publishers. Many recommendations of pre-1977 studies meant to improve dissemination. They were ignored, even after such goals were explicitly adopted by the National Science and Technology Policy, Organization, and Priorities Act of 1976. (Public Law 94-282; 42 USC 6601+) (7) The incorporation of library fair use into the 1976 copyright law apparently misled policy makers to the presumption that photocopies would solve all dissemination problems. Researchers obviously did not agree. They simply circumvented the bureaucracy, its decimated library collections, and the red tape of interlibrary photocopying. They ordered their own subscriptions. As a promise of better dissemination, photocopying backfired by justifying substandard library collections. Twenty years later, it still takes an average of two weeks to obtain an interlibrary loan. (Many referees are asked to respond in that time.) The present proposal echoes the unfulfilled promise of the plain paper copier. If NIH truly wishes to improve dissemination, it must have the courage to ask how the unarticulated policy that bars its evaluation of its researchers' information resources -- mainly academic libraries -- interferes with its mission and its performance. The systemic impoverishment of academic libraries created a bottleneck in communications and a hostile environment for investment of resources. (8) One of the worst effects has been publishers' curtailment of editorial coverage of indexes. (9) It is questionable whether one can prepare a comprehensive review relying on Biosis, Index Medicus, Agricola, and other bibliographic databases. (10) It was the forbidding commercial nature of the library market that led the American Physical Society and many others to avoid aggressive investments in electronic publishing. (11) This opened the door for Paul Ginsparg's experiment in welfare for rather rich scientists and universities. It also provides the foundation for lobbying that spurred the E-Biomed idea. NIH's earlier adventure with preprints, in the 1960s, ended in disaster. (12) Plunging into commercial conflict now with thousands of privately-owned science journals and indexes will end similarly. It can only aggravate the present defect in policy. A proposal with striking similarities to E-Biomed was made to the Senate committee on government operations shortly after Sputnik. Modeled on the Soviets' unified information system, it was quickly rejected. (sorry I don't have a reference handy) Policy focused then on improving libraries and encouraging the development of electronic bibliographic databases by organizations with appropriate experience. The 1960s became a period remembered for its outstanding accomplishments in research and development as well as for the development of electronic bibliographic services, translation journals, author prepared cold-type publication, and the science citation index -- all developed in the private sector, many by entrepreneurs. First, recalling this highly successful solution to the Sputnik situation, I suggest another path you must consider. The tenets of Federal policy promise a fair share of the indirect costs of research. (13) Government science accounts for sixty per cent of academic research spending. Yet grant overhead allowances support only about ten per cent of library spending at research universities -- none of it tied to purchase of journals. If libraries matched the growth of research, neither NIH nor its scientists would complain about dissemination. Backlogs of accepted articles would be lower and information technology would be more fully exploited. NIH would do well to investigate how better-financed and systematically evaluated academic libraries would further its interest in rapid dissemination. A more hospitable economic environment -- supporting robust academic libraries, open to the public -- would encourage private investments in technology, synthesis, indexing, and competition. Second, as a government agency, NIH also has a perfect right and a moral responsibility to qualify research contractors' equipment and resources. The present blind spot has done more to promote mediocrity at research universities than any other policy. I question whether researchers at an institution with spotty local resources can prepare effective proposals and provide reliable peer review. Finally, there are good reasons that there are thousands of journals rather than a single unified "government" system envisioned under E-Biomed. Solutions to dissemination should evolve as they have since Henry Oldenberg launched the Philosophical Transactions, aiming for a commercial profit of 40 pounds a year. That would leave the economic risks and opportunities in the private sector, where they belong. Sincerely, Albert Henderson, Editor Publishing Research Quarterly POB 2423 Noble Station Bridgeport CT 06608-0423 203-380-0021 fax 203-380-1703 messages 203-367-1555 email: 70244.1...@compuserve.com References: 1. Paulette Walker Campbell. 1999. NIH may use the internet to distribute findings of research financed by its grants. Chronicle of Higher Education. 45,35:A33. (May 7) 2. Albert Henderson. 1999. Information science and information policy. The use of constant dollars and other indicators to manage research investments. JASIS: Journal of the American Society for Information Science. 50,4:366-379. 3. Carol Tenopir and Donald W. King. 1997. Trends in scientific scholarly journal publishing in the United States. Journal of Scholarly Publishing. 28,3 (April):135-170. 4. Vannevar Bush. 1945. Science -- The Endless Frontier. A Report to the President on a Program for Postwar Scientific Research. Washington DC:National Science Foundation. Reprint 1990. NSF 90-8. 5. Anonymous. 1998. To Publish and Perish. Policy Perspectives. 7,4. (March) Co-sponsored by the Association of Research Libraries, The Association of American Universities and the Pew Higher Education Roundtable. Published by Institute for Research on Higher Ecucation. http://www.irhe.upenn.edu/pp/pp-main.html 6. Lisa Guernsey. 1998. A provost challenges his faculty to keep copyright on journal articles. Chronicle of Higher Education. 45,4. (Sept. 18). 7. Charles R. McClure and Peter Hernon. 1989. U.S. Scientific and Technical Information (STI) Policies: Views and Perspectives. Norwood NJ: Ablex. 8. Albert Henderson. 1994-95. The bottleneck in research communications, in Publishing Research Quarterly. 10,4:5-21. 9. Richard T. Kaser. 1995. Secondary information services. Mirrors of scholarly communication. Publishing Research Quarterly. 11,3:10-24. 10. L. L. Deitz and L. M. Osegueda. 1989. Effectiveness of bibliographic databases for retrieving entomological literature: a lesson based on the Membracoidea (Homoptera). Bulletin of the Entomological Society of America. 35:33-39. 11. American Physical Society. 1991. Report of the APS task force on electronic information systems, in Bulletin of the American Physical Society. 36,4:1119-1151. 12. Eugene A. Confrey. 1966. (Letter) The information exchange groups experiment. Science. 154:843. (18 Nov.) 13. Vannevar Bush. Op cit.; J. Merton England. 1982. A Patron for Pure Science. The National Science Foundations Formative Years, 1945-57. Washington DC: National Science Foundation. =0= Albert Henderson Editor, PUBLISHING RESEARCH QUARTERLY <70244.1...@compuserve.com> PS. Princeton professor Robert Darnton [not Darnham] is the author of the article in New York Review of Books. . . . ADDENDUM In my earlier remarks, I indicated that I did not have citations referencing a 1958 proposal similar to E-Biomed handy. I can supply some now: (A) The proposal is described in SCIENCE AND TECHNOLOGY ACT OF 1958. ANALYSIS AND SUMMARY PREPARED BY THE STAFF ... SENATE COMMITTEE ON GOVERNMENT OPERATIONS ON S.3126. Washington DC: Government Printing Office. 1958. pages 26-27; 178-195. (B) It was quickly disposed of by W. O. Baker et al. in IMPROVING THE AVAILABILITY OF SCIENTIFIC AND TECHNICAL INFORMATION IN THE UNITED STATES; PANEL REPORT OF THE PRESIDENT'S SCIENCE ADVISORY COMMITTEE. 7 Dec. 1958. It says, "The case for a Government-operated, highly centralized type of center can be no better defended for scientific information services than it could be for automobile agencies, delicatessens, or barber shops." Recalling that the concern in 1958 was competition with foreign research, it might be appropriate to consider E-Biomed from the same perspective. The Cold War is over. Our contemporary concerns were outlined by HELPING AMERICA COMPETE. THE ROLE OF FEDERAL SCIENTIFIC & TECHNICAL INFORMATION (Office of Technology Assessment 1990. OTA-CIT-454) It said, in part: A key area of U.S. strength could and should be our scientific and technical information. I think we should consider whether making that information available "free" to foreign scientists serves to help the U.S. compete in a world where technological advantage often makes a critical difference. The LANL experiment, I am told, has more than a dozen copies being made systematically abroad. Indeed, one of its most vocal advocates, emphasizing the "free" nature of information that would otherwise be sold by publishers and documentation services, is located in England. It would serve this particular concern to build stronger library collections that are "free" to researchers located geographic regions within the U.S. The network of 125 research universities and major public libraries fits this description. The LANL server and the proposed E- Biomed do not. Albert Henderson Editor, PUBLISHING RESEARCH QUARTERLY <70244.1...@compuserve.com>