Our universities are deeply concerned about the ramifications and impacts of the new revision. As we review the proposed revision, more and more questions arise as to the interpretation of the language and the definition of specific terms. Our universities conduct specific research that may be funded from a mix of sources of funds including federal competitive grants, federal formula research funds such as the Hatch Act and McIntire-Stennis Act, Cooperative Agreement funds from a number of federal agencies, state funds, and private funds, including industry. Data exist in many forms, including written field and laboratory notes, electronic data files, appendices in theses and dissertations, survey questionnaire records, computer-generated and enhanced data, and interview records. Much of this data may be of limited use or of no value if viewed in isolation without the benefit of contextual supplementary information.
Publication can also take many forms.
The value of the outcomes from scientific research is very much dependent on the sequential steps of the scientific peer review system. Each step moves closer toward consensus by the scientific community. At our universities we are very much concerned as to how theses and dissertations will be viewed, and how public access to these documents might jeopardize a student's ability to publish in peer-reviewed journals. There are many other uncertainties that we as research institutions would face under this revision, and therefore, we join with other national organizations in recommending that this 1998 law be repealed, or at the very least, the National Academy of Sciences be given time to study the federal policy on data sharing to determine how reasonable access to research data can be achieved without significantly jeopardizing or inhibiting the conduct of science and pursuit of new knowledge. Thank you for your attention to this very serious matter.