SPARC response to NIST RFI

"SPARC strongly supports the OSTP Memorandum’s emphasis on ensuring equity in contributing to, accessing, and benefitting from the results of federally funded research, and we appreciate NIST’s specific attention on how to ensure equity in publication opportunities for its funded authors. To ensure equity in publication opportunities, NIST should provide authors with compliance options that do not present financial barriers. To this end, NIST’s plan and associated policies and guidance should clearly state that authors can fully comply with its public access policy at no cost by depositing their author’s accepted manuscripts into PubMed Central (PMC) or any other agency-approved repository.

Further, NIST should clarify that any fee that authors may be asked to pay is a publication fee, and not a fee required by NIST for compliance. It is critical that authors do not conflate compliance with article processing charges (APCs), which create significant barriers for less-well-resourced authors and institutions to make their research available....

NIST should highlight the diversity of publication models available to authors who may face financial barriers in paying for APCs—including Subscribe to Open (S2O) and Diamond Open Access. Additionally, institutional repositories run by libraries and other research institutions generally do not charge authors to deposit articles or manuscripts, and can play an important role in easing compliance burdens on authors, improving discoverability of research outputs, and providing long-term preservation support. Therefore, we strongly recommend that NIST allow for the deposit of publications into other repositories beyond PMC, and suggest that NIST utilize the guidance set out in the U.S. Repository Network's Desirable Characteristics of Digital Publications Repositories...."