The joint letter from the Association of Public and Land-grant Universities (APLU), Association of American Universities (AAU), and the Council on Governmental Relations (COGR) provides detailed feedback on the National Science Foundation’s (NSF) Public Access Plan 2.0. The organizations commend the NSF’s engagement with the research community and its flexibility regarding publication venues and the inclusion of manuscript versions in its access requirements. They also recognize NSF’s acknowledgment of the need for investments in research cyberinfrastructure and training to ensure equitable participation in public access initiatives. However, significant concerns are raised about the expanded definitions of scientific data and metadata, stating that the proposed definitions are overly broad and could impose undue compliance burdens on researchers, particularly those at less-resourced institutions. The letter emphasizes the importance of aligning definitions with the 2022 OSTP memorandum to maintain consistency and reduce uncertainties.
Further, the organizations express reservations about requiring data sharing for juried and especially non-juried conference proceedings, warning that such policies may inadvertently stifle the early sharing of research findings. They also caution against extending public access requirements to software without clear definitions and consideration of disciplinary differences and intellectual property issues. The letter recommends that NSF explicitly recognize institutional repositories as acceptable venues for archiving research data and urges the foundation to ensure that public access mandates are accompanied by clear guidance and sufficient funding for compliance costs. In summary, the letter supports the NSF’s public access goals but calls for clearer definitions, stakeholder guidance, and equitable funding mechanisms to achieve these objectives without exacerbating inequities or imposing excessive burdens.
