Zero Embargo

Issue 45 · August 2022

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This is a special single-topic issue of The Brief that analyzes the recent OSTP public access policy changes and their implications

A scenario that has been on the minds of publishers over the past decade (and incorporated into strategic planning scenarios by many publishers) is the possibility of “zero embargo.” In 2013, the White House Office of Science and Technology Policy (OSTP) issued policy guidance to agencies in the form of the OSTP memorandum on “Increasing Access to the Results of Federally Funded Scientific Research” (the “2013 Memorandum,” also widely referred to as the “Holdren Memo” because it was issued by John Holdren, at the time the Director of OSTP). The Holdren Memo directed federal agencies in the US with annual research and development budgets of more than $100 million to develop access policies to ensure public access to federally funded research. While the Holdren Memo provided wide latitude to agencies on many of the specifics, the memo put forth a 12-month post-publication embargo period as a guideline. By “post-publication embargo period,” the Holdren Memo was referring to the period between publication of an article resulting from funded research in a journal and the freely accessible public release of that journal article in the form of either the author accepted manuscript (AAM) or the final published version of record (VOR). 

OSTP is an office of the White House and as such sets policy on behalf of the US President. The US federal agencies—including the National Institutes of Health (NIH), Department of Energy (DOE), Department of Defense (DOD), National Science Foundation (NSF), Department of Agriculture (USDA), National Aeronautics and Space Administration (NASA), and so on—are part of the Executive Branch and therefore under White House oversight. Any OSTP policy can be revised by a subsequent administration, and one possibility has always been that the 12-month post-publication embargo could be shortened, potentially to zero. Indeed, such a scenario almost occurred during the Trump administration when such a memorandum was drafted, though it was never ultimately issued.  

Rumors have been circulating for months that the Biden administration has been reviewing the Holdren Memo as part of a wider review of open science policy. Last week, Alondra Nelson (currently heading OSTP) issued a memorandum titled “Ensuring Free, Immediate, and Equitable Access to Federally Funded Research” (the “2022 Memorandum, or the “Nelson Memo”). The Nelson Memo is accompanied by an impact statement titled “Economic Landscape of Federal Public Access Policy” (the “2022 Impact Statement”), which was submitted to Congress pursuant to the Consolidated Appropriations Act, 2022. The 2022 Memorandum directs federal agencies to develop policies that will require free public release of research articles upon publication, and that all supporting research data behind the articles be similarly made immediately and freely available.

The zero embargo scenario has arrived.

What’s in the 2022 Memorandum?

There is a lot packed into this 8-page memo. It outlines an ambitious policy agenda that goes well beyond eliminating the 12-month embargo period. While there is a great deal of detail that will need to be clarified by agencies through their implementation plans, the key aspects of the directive include:

    1. This is (presently) an unfunded mandate. No additional funding to cover the cost of publication or data availability is referenced in the memo, though section 3d of the memo directs federal agencies to “allow researchers to include reasonable publication costs and costs associated with submission, curation, management of data, and special handling instructions as allowable expenses in all research budgets.” It is unclear if additional federal funds will be made available to cover these expenses or if publication costs will reduce the funds available for research. The impact assessment report notes that “several federal agencies, including NSF and NIH, currently permit including publication costs in allowable expenses” and that an “expansion of this allowance by all federal agencies with research and development budgets that support scholarly publications would improve public access policy implementation and help to control costs by offsetting any new financial burden on authors.” Whether this “expansion” will entail additional funds added to grants or a shifting of existing funds away from research and toward publication is yet to be determined. Any additional funds will need to be assessed and budgeted by agencies and appropriated by Congress.
    2. The memo describes a “public access” policy, not an “open access” policy. The memo directs agencies to develop “public access” plans. As defined by OSTP and federal agencies, that means the papers and the data must be made publicly available, but without any reuse license requirements (e.g., CC BY licenses that allow liberal reuse and repurposing). However, the policy does leave to the agencies discretion as to the necessity for reuse terms in their individual policies. It is possible that there could be specific license requirements at the agency level. 
    3. All federal agencies that fund research are included in the policy. The 2013 Memorandum only specified agencies spending more than $100M annually on research funding. The 2022 Memorandum expands the requirements to all federal agencies (and that includes the National Endowment for the Humanities and the National Endowment for the Arts by the way—so humanities journals are not exempt).
    4. The policy applies to all authors on a publication, not just corresponding authors. The memo specifies that the policy applies to “all peer-reviewed scholarly publications authored or co-authored by individuals or institutions resulting from federally funded research…” 
    5. The memo does not clearly specify what version of research papers this policy will apply to. It appears up to each agency to determine whether the requirement to make research papers freely accessible (via agency-designated repositories) will apply to author accepted manuscripts (AAMs) or the final, published version of record (VOR). Current agency policies accept either the AAM or VOR. 
    6. The memo is not just applicable to original research papers. The policy includes “peer-reviewed research articles or final manuscripts,” but leaves agencies latitude to also include book chapters, editorials, and conference proceedings.
    7. Immediate public access to the underlying data is required. The policy requires that scientific data underlying peer-reviewed scholarly publications be made publicly available at the time of publication (with recognition that there will be some limitations on data access and use in some cases). This part of the policy seems underdeveloped, and does not feature at all in OSTP’s cost estimates provided to Congress via the 2022 Impact Statement. 
    8. Metadata is a focus. The policy requires collecting and making publicly available metadata (using persistent identifiers) associated with scholarly research and publication such as author names and affiliations (for all authors), dates of publication, and sources of funding (including grant awards). This section of the memo is notably tied to maintaining and restoring public trust in federally funded science, and that such metadata will allow the public to “identify which federal agencies support given investments in science, the scientists who conduct that research, and the extent to which peer-review was conducted.”
    9. The policy goes into effect by 2026. It remains to be seen whether that means papers and data from existing grants will be subject to the new requirements, or (more likely) the new policy will take effect with grants issued after January 1, 2026. This is an ambitious timeline, as it took several agencies more than three years to formulate a policy in response to the lesser demands of the 2013 Memorandum (and even more time to put those policies into practice and enforce them).

Industry Impact and Implications

The 2013 Memorandum—developed with extensive input from publishers and professional societies, and using as a model policies and practices already in place at NIH—outlined an approach that would provide free public access to articles resulting from federally funded research, would not require additional federal funding, and  would not undermine the dominant business model for scientific journals (the subscription). All policies come with trade-offs, and the current administration has determined that the 12-month embargo window is no longer an acceptable trade-off, noting:

“Years of public feedback have indicated that the primary limitation of the 2013 Memorandum is the optional 12-month embargo from public access of any publication resulting from federally funded research.”

By removing the 12-month embargo, the 2022 Memorandum necessarily makes different trade-offs. The 12-month embargo allowed for the continuation of the subscription model and did not require additional funding for publication costs. A zero embargo will likely (eventually) make the subscription model unfeasible for many, if not most, journals and will necessitate increases in agency funding to support publication costs. This is broadly acknowledged in the 2022 Impact Statement, which provides cost estimates for a “full flip” scenario and provides this (under)statement: 

“Recognizing that the global scholarly publishing industry is already in this active transition toward greater public access through the open access movement, any change in federal policy is likely to result in some downward pressure on publishers to adapt business models.”

The scientific publication landscape is very different than it was in 2013, with three important developments:

    1. Much more research is published via open access venues. The new OSTP policy follows the implementation of Plan S, which requires immediate open access to research funded by cOAlition S funders (a coalition of largely European funding agencies along with the Bill & Melinda Gates Foundation and HHMI). It also follows the development of publish and read agreements between publishers and academic institutions and consortia, a phenomenon described in some detail in the 2022 Impact Statement. Such agreements support open access publication of affiliated faculty, staff, and students. Many of these agreements are at the national level, providing (for example) support for open access publication for nearly all researchers in Germany (Projekt Deal), the Netherlands (VSNU), Sweden (Bibsam), the UK (Jisc), and so on. While not as widespread in the United States, such deals are beginning to be brokered, with notable arrangements between publishers and the University of California, MIT, and the Big 10 Academic Alliance, among others. Beyond these initiatives, Gold OA (immediate open access, paid for by the author) publication has grown organically. “Born-OA” publishers such as PLOS, Frontiers, MDPI, JMIR Publications, eLife, PeerJ, and others are flourishing. Established publishers, including Springer Nature (publisher of Scientific Reports, the world’s largest open access journal), Elsevier, Wiley, and others have developed extensive portfolios of fully open journals and have converted nearly the entirety of the subscription journals in their portfolios to hybrid publication models (publishing both OA and subscription content). These publishers collectively publish hundreds of thousands of articles on an open access basis annually (as of 2020, approximately 30% of all articles were published via Gold OA), many of which are authored by researchers with no current open access mandates. 
    2. Open content is more easily discoverable across platforms. Following the 2013 Memorandum, publishers began voluntarily depositing federally funded papers to agency repositories (such as PubMed Central) as well as via CHORUS. While many of these papers are author accepted manuscripts (AAMs) and not the final published paper or version of record (VOR), they are included in Google Scholar search results as well as in other indexing services. Scientific collaboration networks such as ResearchGate and Academia also host millions of open access articles originally published elsewhere. 
    3. New tools enable librarians to carefully analyze open access content in journals. Unsub, COUNTER 5, and similar analysis tools help libraries evaluate subscriptions based on the usage of subscribed content and to factor out any content that is openly accessible. As a result, librarians are actively monitoring the proportions (and usage) of subscribed versus open content in journals and these analyses are already resulting in subscription cancellations

In 2013, it may have been possible for the subscription model to continue with a zero-embargo OSTP policy. In 2022—given the amount of content already being published OA, the discoverability of open content in repositories and scientific collaboration networks, and the analysis tools employed by librarians—the era of the journal subscription may be nearing its end. 

We do not mean to imply that widespread subscription cancellations will take place immediately upon implementation of the OSTP policy by agencies. That is highly unlikely. More likely is that subscriptions to scholarly journals will become decreasingly viable over an extended period (and no one will be launching new subscription journals—an increasingly rare phenomenon). How long this period of subscription viability extends for will depend greatly on the implementation plans developed by federal agencies.

Consequential Decisions: Which License and Article Version?

The two most consequential (for journal publishers) decisions to be made by agencies are requirements related to reuse licenses and the article version deposited in agency-designated repositories.  If the major agencies require a liberal CC BY reuse license, for example, that will greatly accelerate subscription decline. This is because it will allow anyone to aggregate these articles, including for commercial purposes. A “supercontinent” is the inevitable result, making it challenging for publishers to retain sufficient usage on their own websites (even if the supercontinents host only AAMs), accelerating subscription cancellations and reducing advertising revenues. Liberal licenses also forestall secondary journal revenue streams, such as reprints, permissions, and licensing; these are substantial revenue streams for some journals. A less-permissive license (such as CC BY-NC-ND, which restricts commercial and derivative reuse), or none at all (e.g., publisher or author retains copyright), would likely extend the viability of subscriptions longer. Similarly, immediate deposit of the Version of Record would accelerate subscription erosion faster than deposit of the Author Accepted Manuscript. 

Life Span of the Subscription Model

Depending on these details, the life span of subscriptions may be longer or shorter—noting, however, that the policy will impact each journal differently and subscriptions for some journals will become unviable sooner than subscriptions for others. A slow decline in subscriptions over 10–15 years is very different from a rapid decline over 5 years. Other provisions present in Plan S (such as a prohibition against the use of grant funds for publication in hybrid journals or the assertion of a “rights retention strategy”) would shorten the viability window for subscriptions even further. (There is no mention of either a prohibition against hybrid journals or a rights retention strategy in the 2022 Memorandum, and it is unclear if the latter would be legally feasible in the US.) 

A longer subscription viability window would not only be easier to manage for publishers, but may also prove preferable for federal agencies. The existence of fewer subscription journals over time will mean more and more federally funded research will need to be published via Gold OA venues. Depending on the deposit and reuse requirements, publishers may require authors with zero-embargo mandates to publish via the Gold OA model even in existing hybrid journals. A rapid decline in subscription journals would require federal agencies to adjust their budgets more rapidly, either by requesting additional funds (funds that the US Congress may or may not be willing to provide) or by issuing fewer (or smaller, once publication fees are factored in) research grants. A longer window of subscription viability would be easier for agencies to plan for and manage. 

OSTP Financial Analyses

In order to assess the potential costs to agencies (and ultimately to taxpayers), OSTP used some back-of-the-envelope math based on NSF and OECD data (why OSTP did not conduct a more robust analysis is not clear). The math is described in the 2022 Impact Statement. OSTP estimates that there are between 195,000 and 263,000 federally funded research articles published annually. This is probably a conservative (low) estimate because the 2022 policy includes all authors on a paper whereas most analyses of a paper’s country of origin or funding source rely only on corresponding authors. OSTP, citing a report from SPARC, states that the average cost per publication (i.e., a journal article publishing charge, or APC) is between $2,300 and $3,000. Again, it is unclear why a more detailed analysis was not performed, starting, for example, with a review of the APCs of journals where federally funded research is typically published. Research from federal agencies skews toward publication in higher-profile journals, which tend to have higher APCs. Using an APC of $3,000 and a total annual paper output of 263,000 results in an (upper-bound estimate) of $789 million in annual publication costs in a scenario where 100% of federally funded research is published via Gold OA journals. 

As noted above, we think the figures for both the total paper output and the average APC are conservative. More so because APCs are likely to increase in the wake of this policy, a likelihood acknowledged (but not modeled) in the 2022 Impact Report, which notes the higher “potential costs” of “increased fees to publish (i.e., through the use of article processing charges) should publishers adopt greater fidelity to such business models….”. This is because APCs in hybrid journals are offset by subscription revenues. If publishers perceive that the policy will trigger a flip of a journal to full OA in the near future, they will start to price APCs accordingly, factoring out the offset, as well as factoring in the loss of revenues associated with advertising, reprints, permissions, and licensing. Additionally, publishers will need to factor in waivers of publication charges. Presently, those without funds for publication charges can publish free of charge in hybrid journals. Once subscriptions to such journals are no longer possible, the cost of such waivers will need to be accounted for in the publication fees of those authors with sufficient funding. With higher APCs and a larger number of papers affected by the policy (factoring in all authors on the paper and the addition of editorials and conference proceedings), the costs could easily be double the estimates in the impact report. Even at $1.5 billion in annual publication cost, however, the figure represents only a small percentage of the $150 billion in annual federal spending on research. Even this much higher estimate may not cause the impact report’s authors to adjust their assessment that “the societal and economic benefits of a change in federal policy toward immediate public access to federally indeed research results greatly exceed costs.”

Equity Matters

In addition to the economic costs associated with the policy changes, the 2022 Impact Statement discusses the significant inequities the policy will create for early-career researchers “who are less likely to have funding available than their more senior counterparts, but under greater pressure to publish their research more frequently.” Also discussed are inequities related to researchers without federal funding, noting concerns that “funds available to pay rising APCs create a two-tiered system between funded and unfunded researchers where only funded researchers can publish their research in open access journals.” OSTP offers no solutions to these inequities, pushing the problem to agencies to solve (from the 2022 Impact Statement: “federal agencies’ public access policies should be accompanied with support for protecting against any inequities that might arise from a change toward a zero-embargo public access model”). Ultimately, the 2022 Impact Statement concludes with regard to inequity concerns: “On balance, OSTP estimates that the potential financial and social gains realized from increased access to federally funded research—by removing the 12-month publication embargo—greatly outweigh the potential costs.”

Where’s the Data?

Curiously absent from the 2022 Impact Statement is any estimate or discussion of the costs associated with the implementation of the 2022 Memorandum’s policy on open data. The open data directive is perhaps the element of the memo that has the most potential to positively impact research, but it also has the highest potential cost to agencies and the greatest hurdles to adoption. Research data is much harder to manage than research articles, and the costs involved are likely to be magnitudes higher. It will also require much greater researcher socialization, training, infrastructure, and enforcement efforts. Researchers are used to writing and publishing papers; many do not presently archive their data and appropriate digital archives do not exist for all data types. Privacy, competition, national security, and other considerations also impact data sharing and accessibility. Further, standards to allow discovery and interoperability, preservation protocols, and metadata will need to be developed for many data types. The variation in data types across agencies is great (from telescope data to clinical data to social sciences data). For these reasons, a great many details will need to be developed by agencies and we anticipate full implementation of open data policies to lag those related to research publication.

What Are the Implications for Publishers and Societies?

While many important details remain unclear, these details will largely have bearing on the timetable as opposed to the direction of travel. For example, if agencies do not require a CC BY reuse license and only require deposit of an author accepted manuscript (AAM), subscriptions will still decline but more gradually. Gold OA publishing revenues will likely increase gradually over a similar timeline. Call this the orderly transition scenario. If, on the other hand, agencies require a CC BY license or require deposit of the version of record (VOR) in repositories, the timeline for a full transition to Gold OA will be much shorter. Call this the rapid flip scenario. 

Two Strategies for Publishers

In either scenario, publisher responses will fall into two categories: extending the lifespan of subscription revenues as long as feasible (the “Green strategy”) or increasing Gold OA publication revenues (the “Gold strategy”).

There are a number of strategies and tactics publishers might use to extend subscription revenues, including pursuing more papers authored by researchers without OA mandates (for example, researchers in China), putting as much content unaffected by the OSTP mandate behind the paywall as possible (particularly back content currently made freely available through “Bronze OA”), and developing more commissioned editorial and review content (that does not fall under agency OA mandates). It seems a risky proposition for publishers, however, to rely only on a Green strategy. There is little potential room for growth (it is entirely a defensive strategy) and if the publisher later needs to ramp up a more extensive Gold OA program it will be harder to do as the competition will be further ahead. 

A Gold strategy therefore seems inevitable for most publishers, even if pursued in tandem with a defensive Green strategy. It is possible that much Gold OA growth could still come from hybrid titles for some time (as noted above, the Nelson Memo makes no mention of a prohibition on using research funds for publication fees in hybrid journals, as with Plan S, and the Impact Statement specifically proposes that agencies remain “agnostic” toward business models), though any new titles (and any titles that wish to compete for papers with cOAlition S funding) will almost certainly need to be Gold. Some publishers may wish to direct papers subject to zero-embargo policies to Gold OA venues (hybrid or Gold). Others may take a more permissive view depending on the amount of federally funded research they publish and their overall proportion of subscription vs. OA content. As noted above, the deposit and reuse license requirements may prove determinative.

Strategies will be very different for publishers with substantial existing subscription revenues as compared to “born-OA” publishers. The former will likely pursue both subscription extension strategies as well as Gold OA growth strategies—and Gold OA growth will likely be offset by subscription erosion. Born-OA publishers, by contrast, will view the new OSTP policy as leading to entirely new, additive revenues (in the form of APCs) for them. Some born-OA publishers may see this as an opportunity to expand their market share and extend their already-prolific author-marketing tactics.

Publisher Data Policies

Publishers will also need to anticipate their own open data policies. While these are likely to develop in response to agency policies—and will be highly dependent on the field and types of data that support published articles—it is likely that publishers will be involved in linking published papers to data repositories and (potentially) validating data availability prior to publication. 

Publish and Read Agreements

How will this policy impact publish and read agreements? While there have been a number of notable deals in the US, the vast majority of US research institutions have not yet entered into such agreements. This presents an opportunity as publish and read deals provide a mechanism for publishers to accelerate their OA publishing programs. That said, it is unclear if the new OSTP policy will dampen or intensify dealmaking. If federal funding agencies are pledging to cover the costs of this policy, then why should author publication fees come out of the university library’s budget? Why would a university surrender its grant overheads instead of putting the onus on researchers to pay publication fees out of their research budgets (as that seems to be the intention of the new OSTP policy)? On the other hand, some universities may be weighing likely inequities caused by the new policy on the researchers they employ without federal funding (or with insufficient federal funding relative to publication needs). A publish and read agreement would level the playing field. A compromise solution may prove to be the “multi-payer” model pioneered by the University of California, which provides some funding for publication fees from the university and some from researcher grants (thus, multiple payers). 

Implementation of Strategy

Adjusting to the new policy is not just about strategy, however. To compete effectively in the zero-embargo OA publishing landscape that is likely the result of the new OSTP policy, publishers will need effective marketing practices and technology, sophisticated analytics, and an organization focused on authors and author experience. Where the author is the paying customer (or is directing payment), the author’s perception of the  publishing process will become increasingly important and a critical differentiator for publishers. Publishers will also need to develop well-articulated portfolio strategies that provide publishing venues to balance the various requirements of Plan S and US agencies (as well as researchers in China and elsewhere) and that do not result in rejecting good papers that are ultimately published by competitors. Article market share, publishing process efficiency, and author experience will become key metrics. 

Societies that Partner with Publishers

Societies that partner with commercial publishers or large university presses via publishing services agreements will need to work with their publisher to align their respective publishing strategies. Important areas of discussion to have with a publishing partner related to the new OSTP policy include:

  • Green and Gold strategies—What combination of strategies and tactics will be pursued over what time frame? What are agreed-upon goals and measures? 
  • Portfolio development—How might the publisher support the society in developing new open access journals? 
  • Article transfers—How might the publisher support the society in better facilitating article transfers (with appropriate author opt-in and editorial review) between journals in the society’s portfolio? Are there opportunities to facilitate transfers between the society’s titles and the publisher’s wider portfolio? 
  • Publish and read agreements—Should some or all of the society’s journals participate in publisher publish and read agreements? Are Gold OA journals included? What will be the likely revenue implication for the society? How many subscriptions will be impacted? Can the publisher provide a “minimum guaranteed APC” to the society so the society can better assess participation? 
  • Marketing—How will the publisher help the society with author marketing? What tools and services might the publisher provide?  How can society tools integrate with publisher platforms? What data are available related to authors, and how can the society use and protect those data? 

Depending on the course of action determined through these discussions, publishing services agreement addendums may be necessary. Alternatively, depending on the timing of the society’s current agreement, changes may be built into the next contract (but it may be prudent to begin discussions well in advance). 

Now more than ever, societies will be well served to pay close attention to material adverse conditions (MAC) clauses in reviewing current or future contracts. These clauses define trigger events that can result in renegotiation of financial terms of the contract. It is possible that the new OSTP policy will cause MAC clauses to be triggered (directly or indirectly) in some contracts. Whenever possible, MAC clauses should be avoided or carefully defined (based, for example, on quantifiable trigger events such as specific revenue thresholds) and limited in scope (impacting only certain categories of revenue, for example). 

The seismic shift in the market prompted by the new OSTP policy may prompt a broader reassessment of the strategic rationale for journal publishing for some societies. Journal publishing represents both a significant portion of overall revenues and an important strategic activity for some societies, advancing their field and fostering their communities. For other societies, journal publishing can be either less remunerative or of less strategic importance. Societies in this latter group may wish to evaluate whether the society is better off divesting its journals and investing the proceeds in reserves or in other initiatives. 

Policy Engagement

The 2022 Memorandum also underscores the importance of publishers engaging meaningfully in policy development on an ongoing and proactive basis (as opposed to a reactive basis). There appears to have been little publisher or research society input into the formulation of this policy (unlike the 2013 policy), although OSTP and the federal agencies now pledge to coordinate with publishers and other stakeholders on implementation. However, this marks the second administration in a row that has caught the publishing industry and their advocacy organizations flat-footed and that has advanced research publishing policies through extensive review and revision without consultation with (or leaks to) publishers. We leave what this says about relations between publishers and policymakers up to the reader, although it is perhaps worth noting that SPARC had a press release and fact sheet ready for immediate release upon the policy’s announcement.

What’s Next?

Each society’s or publisher’s situation is different, and careful analysis of the specifics is required to develop an appropriate set of strategies and tactics. Reviewing the size and construction of one’s portfolio, funding sources for published papers, and metrics like revenue per article published and revenue per submission received can guide strategy. An intentional portfolio strategy is needed to provide risk mitigation through diversification and to drive growth. Well-developed article transfer strategies can help publishers and research societies become more competitive and cost-effective. 

Additional steps that may be on the path for some organizations include:

  • Development of a situation analysis to position your portfolio in the context of this coming-soon environment
  • Development of portfolio strategy (including plans for new journals) and portfolio policies (e.g., transfer strategies)
  • Scenario planning and modeling 
  • Communication to governing bodies such as boards to help them understand the potential impact of the new policy
  • Development and implementation of open data policies
  • Marketing and author experience reviews
  • Publisher assessment and selection (for societies that partner with publishers)
  • Publisher contract review and negotiation (for societies that partner with publishers)

C&E has helped research societies and publishers navigate business model transitions for nearly a decade. In addition to the items above, our support extends to other shifts this new OSTP policy will require related to creating an author-centric experience, such as data-driven marketing, marketing technology competencies, and brand differentiation. Let us know if you’d like to set up a discussion about how Clarke & Esposito can help your organization. 

News and Commentary on the OSTP Policy

Below are links to notable news and opinion stories related to the Nelson Memo: 

Anderson, “A new OSTP memo: Some initial observations and questions,” The Scholarly Kitchen, 29 August 2022. 

Association of American Publishers, “Statement from Shelley Husband, Senior Vice President, Government Affairs, AAP, on Decision by The White House Office of Science and Technology Policy to Make Private Sector Publications Freely Available,” Association of American Publishers, 25 August 2022. 

Association of Research Libraries, “ARL Celebrates Biden-Harris administration’s historic policy to make federally funded research immediately available,” Association of Research Libraries, 25 August 2022.

Brainard and Kaiser, “White House requires immediate public access to all U.S.-funded research papers by 2025,” Science, 26 August 2022. 

cOAlition S, “cOAlition S welcomes the updated open access policy guidance from the White House Office of Science Technology and Policy,” cOAlition S, 26 August 2022. 

D’Agostino and Lederman, “No paywall for taxpayer-funded research, U.S. declares,” Inside Higher Ed, 26 August 2022. 

Parikh, “AAAS statement on OSTP federally funded research guidance,” AAAS, 25 August 2022. 

Patel, “White House pushes journals to drop paywall on publicly funded research,” The New York Times, 25 August 2022. 

Pooley, “The Big APC Question Mark Hovering Over the OSTP Announcement,” Jeff Pooley, 26 August 2022. 

SPARC, “Taxpayers to get immediate access to publicly funded research,” SPARC, 25 August 2022.

Tollefson and Van Noorden, “US government reveals big changes to open access policy,” Nature, 26 August 2022. 

Zahneis, “‘A historic moment’: New guidance requires federally funded research to be open access,” The Chronicle of Higher Education, 25 August 2022.