The Duke University Libraries and the Duke University Medical Center Library are grateful for the opportunity to continue to engage the National Institutes of Health in the ongoing efforts to craft the best possible policy for public access to NIH funded research.  Duke has been and remains supportive of those efforts, as evidenced by our earlier comments in response to an NIH request, by our Provosts decision to sign a 2006 letter in support of taxpayer access to federally funded research and by the ongoing involvement of the University Vice-Provost for Research and the School of Medicines Vice-Dean for Clinical Research in planning for implementation of the policy effective as of April 7, 2008.

Because Duke has been planning for compliance with the NIH public access policy at a high level and for almost six months, we want to emphasize that changes in the policy should be implemented carefully, if at all, to avoid a substantial loss of resources that have already been allocated.  It would be very difficult to step back from the commitment to public access at this point.  We also feel that our researchers and the institution gain significant opportunities and benefits from having Duke research, as well as the research done at other institutions, made available in PubMed Central; we have been working to demonstrate that benefit to our researchers and would be extremely disappointed if the NIH reversed or weakened its own commitment in that regard.

As we have proceeded with educational efforts to help researchers comply with the new policy, we have been pleased at many of the reactions we have received.  We have been relieved to find that the submission process is not at all difficult.  The interface provided for submission is easy to use.  In general, our researchers have indicated a positive attitude towards both the process and the policy.  In fact, one reservation that we have heard is that the potential for a twelve month delay after publication for research to be publicly available is too long.  Researchers generally see the value of public access for supporting their own continuing research as well as for meeting the needs of the public, and some are concerned that such a long delay will hamper the pace of research in a digital age.

While the submission process is simple, we do urge NIH to work with the publishers and gain their cooperation in submitting manuscripts or the final published version on behalf of authors.  The publishers that are willing to submit on behalf of authors should be added to the list maintained by NIH, and not limited to PMC publishers.  Both of these actions would greatly reduce the compliance burden on authors and their institutions, while ensuring timely submission of all manuscripts.  It would also help eliminate the concerns of both authors and librarians that inaccurate versions of manuscripts will be submitted and accessible through PMC.


The length of the potential embargo leads us to make one final comment.  As the University officials with final responsibility for library purchasing decisions, we have no expectation (as well as no specific plans) that we will cancel journal subscriptions because of increased access to research articles through PubMed Central.  Although loss of subscription revenues has been frequently cited as a potential negative effect of the Public Access Policy, such cancellations are simply not a practical option given the realities of how research is conducted, the contents of the PubMed Central database, and the speed with which information in the bio-medical sciences is disseminated and used.


Sincerely,

Deborah L. Jakubs						Patricia L. Thibodeau
Rita DiGiallonardo Holloway University 			Associate Dean for Library
Librarian & Vice Provost for Library Affairs		Services, Duke Medicine