In 2022, the Office of Science and Technology Policy issued the Nelson Memo, a memorandum on new public access requirements for federally funded research. The memo requires federal agencies to make juried, peer-reviewed publications and their supporting data freely and easily accessible to the public upon publication. Martin Halbert, National Science Foundation Program Director for Public Access at the U.S. National Science Foundation, discusses the memo.
Gerry Bayne: This is Gerry Bayne at the Coalition for Networked Information Spring 2023 Meeting, and I'm here with Martin Halbert, National Science Foundation Program Director for Public Access at the U.S. National Science Foundation. Welcome.
Martin Halbert: I'm delighted to be here, Gerry.
Gerry Bayne: I'll just get into the questions here. There's been a lot of talk and speculation surrounding the 2022 Office of Science and Technology Policy memorandum on new public access requirements for federally funded research. This is also often referred to as the Nelson Memo. Would it be possible for you to briefly summarize the crux of the memo and some key issues resulting from the memo that folks in technology in higher education should be aware of?
Martin Halbert: Certainly, Gerry. This memorandum issued by the White House OSTP was actually the second such memorandum in a number of years. The first one came out in 2013 under then-director of OSTP, John P. Holdren. The gist of these two memoranda are around the sentiment that publicly funded research should be publicly accessible. It's the core of it. The particular stipulations that the Nelson Memorandum came out with were that... It's a very dense memorandum. First of all, I would encourage everybody to take a look at it if you're interested in the specifics of it.
But the most salient points of it that got the most attention are the facts that it was requiring federal agencies to put processes and policies in place such that specific research outputs, specifically in the form of juried, peer-reviewed publications, and the data that was used as evidence in conjunction with these publications, be made immediately accessible upon publication, freely and easily accessible to the public. That is something that I think many groups in higher ed should be aware of, and agencies will be implementing those requirements over the next few years. In particular, this is going to have ramifications for repositories of various kinds, both repositories that store publications and repositories that store data.
Gerry Bayne: Is it retroactive?
Martin Halbert: It is not retroactive. It is going forward from this point.
Gerry Bayne: Okay, gotcha.
Martin Halbert: In fact, it does not take effect until 2025. Agencies have a couple of years to implement these requirements. What many people may have heard about is that agencies are developing their planning processes right now, and major agencies submitted our planning process documents to the White House at the end of February just recently. We will be making those plans to plan publicly available pretty soon, and we'll have more discussions. We're very interested in hearing from the various stakeholders and the research community about this memorandum, their thoughts on it, their perspectives as we start moving toward implementing the requirements of the memorandum.
Gerry Bayne: What are the pain points here for libraries and researchers?
Martin Halbert: A lot of different groups have a lot of perspective on this and what their respective pain points are. Libraries, in particular, are very positive on this memorandum. For example, the Ivy Plus group of libraries issued a statement in support of the memorandum in all of its different stipulations. They're very eager to see agencies implement these practices and policies. There is concern in the publishing community in some scientific societies that moving to a, quote, unquote, "zero embargo" situation upon publication, it may have effects on their overall business models and so forth. Then there are lots of perspectives from individual research communities who are fretting about the burden of reporting requirements and the associated dissemination of their findings and their results. It's a complex situation right now, and both agencies and the different research communities that they serve are in a dialogue, especially this year, 2023, which has been designated the Year of Open Science, as a series of discussions and engagements between the different members of the research community.
Gerry Bayne: In light of that discussion, is there anything, in particular, that you feel has been commonly misconstrued about the memo that you could help clarify?
Martin Halbert: Yes, indeed. Many times we get approached in the agencies with concerns that this memorandum is somehow going to obligate people to release and disseminate data that cannot be released with personally identifiable information, for example, national security secrets, or any of the whole variety of restricted data types. It doesn't say that. It only says that in the case of data that can be released in this way, that there aren't any of these sorts of sensible, logical, long-standing restrictions to public access to that data if and only then, if it is in use in a supporting capacity for particular claims in articles that are peer reviewed. Only that data is what is being required for public access.
Gerry Bayne: That makes a lot of sense. You mentioned the Year of Open Science. What are some of the possible implications of this effort for higher ed?
Martin Halbert: The advent of the Nelson Memorandum and just the general interest and a lot of different individual developments in the field this year led a number of different federal agencies, more than a dozen at this point, major agencies, to really decide to come together and try to synergize and align our efforts in 2023 on and around open science and methods and activities that can broaden the participation in sharing scientific results, synergistic activities that agencies are funding. I can give you some examples at NASA, the TOPS initiative transition to open science at NSF, the FAIROS RCN solicitations with complicated acronym, but that represents advancing fair data guiding principles, open science in the form of what NSF calls Research Coordination Networks, RCNs. We just thought that many agencies saw it as an opportunity for coordinating on catalytic efforts to advance open science more broadly in the nation and the country as a whole.
Gerry Bayne: It's an exciting time, it sounds like.
Martin Halbert: It is.
Gerry Bayne: In light of that, what's your view on the evolving focus on research integrity as part of OSTP's work, and how are you relating it to open science?
Martin Halbert: It's such a good question. Research integrity unpacks into so many great different themes, reproducibility of results, discoverability of results. Research integrity is a broad topic that NSF and other federal agencies that fund research are very committed to and very interested in seeing advanced. Just very interested in this focus by OSTP, very supportive of it, and we see it as very integrally linked to open science and the dissemination of research results.
Gerry Bayne: Can you compare or contrast that view that you have with what our friends in the UK and you are doing and elsewhere?
Martin Halbert: While I can't speak for those-
Gerry Bayne: Of course.
Martin Halbert: ... overseas agencies, I think that in general, the broad issues of open science have gotten a lot of attention, especially in Europe, among our colleagues over there. I do think that there are things that we can learn from our colleagues in Europe on these topics. We are listening very carefully, not only to research stakeholders in the United States but the positions and observations of our colleagues in overseas research funding groups and so forth.
Gerry Bayne: On a personal and professional level, you had a career primarily in research library-
Martin Halbert: Yes.
Gerry Bayne: … before moving to the NSF. Can you talk about the transition and your experiences with that?
Martin Halbert: Absolutely. Indeed, I was a dean of academic libraries at several different institutions for fifteen years. I found that, first of all, I love the NSF culture. It is an incredible place to work. It is the greatest minds in the country coming together to foster research across all the different areas of science and technology that NSF serves. I have been delighted to be a part of NSF. I've found that all of my career experiences in research libraries have been very relevant, actually, to working with different groups of scientists and scientific endeavors through the agency. I do encourage other librarians to consider getting involved in federal agencies and publicly funded research efforts. I think librarians have a lot of insights, especially around the organization and dissemination of knowledge, that are very relevant to the kinds of work and just the publicly funded awards that different federal agencies that our grant making make every year.
Gerry Bayne: That's great. It's an interesting work. I'd like to ask, is there anything about the Nelson memo or otherwise, things going on at the NSF that we haven't covered?
Martin Halbert: Just that NSF is committed to the broad range of open science activities and synergistic efforts that are great opportunities for coordinating in the context of the Nelson Memorandum. We celebrate this particular accomplishment, this memorandum by Dr. Alondra Nelson and her staff and Dr. Prabhakar, the new director of OSTP, and we really see this as a wonderful new day and a new opportunity for advancing open science concerns nationally.
Gerry Bayne: Great. Thanks so much for your time.
Martin Halbert: You bet.
This episode features:
National Science Foundation Program Director for Public Access
National Science Foundation