Consultation response – NPOS2030 Ambition Document

In November-December 2021, the Dutch National Program Open Science (NPOS) set up an open consultation (archived link) to give all Dutch stakeholders the opportunity to provide input on the NPOS2030 Ambition Document, comprised of NPOS’ vision for 2030, the guiding principles underlying this vision, and the proposed program framework and key action lines.

Here we share our submitted response to the consultation. The response was drafted in collaboration and submitted on 2021-12-22.

Jeroen Bosman  (@jeroenbosman)
Bianca Kramer (@MsPhelps)
Jeroen Sondervan  (@jeroenson)

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NPOS2030 Ambition document infographic (source)

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Part 1: NPOS Guiding Principles

General remarks:

• The document lacks a sense of urgency. Apart from the Citizen Science aspect it is not sufficiently clear in what ways this ambition document adds to or deviates from the previous NPOS programme. We also miss reflection on the previous programme. Has that been successful in all respects and if not, how does the current ambition address that? Will those acting in this space (esp. on open access and FAIR data) do anything differently because of this ambition? Will they feel inspired or supported by guidance offered in the abition?

• We are somewhat disappointed by the relatively narrow scope of the ambition and by the lack of concrete proposals to make real steps forward in practising open science. Especially so, because this should be an ambition for the next 8 years. A period in which it is expected to see lots of developments in different aspects regarding Open Science.
  
  Just a few suggestions of the type of actions and goals that we miss:
  • in open science in education: embed the open science skill set and mindset in all bachelor and master programmes at universities and universities of applied sciences;
  • in open access: move towards 50% diamond article publishing by 2027 and create a national open source and publicly governed ORE type publication platform;
  • also in open access: create a national campaign to deposit all retrospective output of current  affiliated researchers using Taverne;
  • in rewards & recognition: foster a culture in which journal/publisher level evaluation of publications/researchers is no longer desired;
  • in public engagement: create support to help researchers to add plain language summaries to all their publications and deposit those with the articles in repositories and also create infrastructure to leverage those summaries in public engagement
  • also in public engagement: explicitly reward researchers for using 1% of their research time to check and improve wikipedia on their topics

• Overall the structure of the entire document could be better and we suggest shortening of the document. Parts of chapter 1 (especially section 1.3) could be integrated in the following chapters 2, 3 and 4. As a reader it is confusing to first read quite elaborately about these topics and then see them detailed even more in separate chapters. We suggest to integrate 1.3 into the three following chapters, thus dealing with the vision, mission and action lines in a coherent way in one place for each of the three domains.

• The structure of Chapter 1 is unbalanced. It begins with the UNESCO Recommendation on Open Science, But on further reading, this definition seems to keep standing on its own. Throughout the document, little or no connections are made with the recommendation and to what extent the NPOS adopts this definition in full. By making this more clear and more importantly justify the choices being made that are guided by the UNESCO Recommendation, it would make the NPOS statement much stronger and ‘embedded’. By doing so, it is probably also much easier to connect principles to vision and action lines. 

• In line with the previous comment, the ‘Guiding Principles’ as they are currently presented seem to be a selection. Moreover, it is not well motivated why especially this set of principles is chosen. This should be explained/justified more. Now section 1.1.1 works as a perfect hook, but the following section(s) are not using that hook sufficiently.

• We suggest adding a glossary with definitions of the main concepts, to make the document more accessible to readers that are new to open science discussions. It will also help with the consistent use of definitions throughout the document (e.g. now confusion is created by using all kinds of alternatives to the ‘as open as’ adage). 
  

Remarks on specific Guiding principles:

• The concepts of digital and academic sovereignty need much more explanation, especially as they are relatively new concepts and because they play an important role in various parts of the document. Also, it should be made more clear to what extent these are considered a driving force for open science (‘the interest of transparent, inclusive and reliable knowledge creation’) or, conversely, as a barrier to openness.
  
• The concept of subsidiarity also needs further clarification. It is implied that it will guide the process of the transition and which stakeholder will take up which role. It invokes the question of who this document is for. Is the document voicing the ambition of all stakeholders in NPOS? Also, the implications of this principle should be made more clear. What type of issues do require more national or centralized action even if that might deviate at some points from when and how all individual stakeholders would have acted (as for instance has been done in the case of national read and publish deals). The report mentions several instances of national initiatives, esp. for a number of platforms, OKB and such, as if decisions have already been taken. How does that fit into the subsidiarity principle?

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Part 2: NPOS Vision for 2030

• We miss a more elaborate and contextualised vision for those aspects in the ambition that are new compared to the previous programme. It should be made clear why aspects like citizen science, digital/academic sovereignty, and the ambition to look at public values and to become less dependent on (commercial) publishers are so important. It should be clear to the reader what would go wrong if these were not addressed in the ambition. That is the case as the document is now. We also miss reference to the latest version of the Guiding Principles on Management for Research Information and its recommendations.

• We appreciate the aspect of making open science normative, but would suggest to not only leave this as something for open science communities to address. There is a clear need for leadership and influential role models to explicitly state a preference for practicing open science and expecting it from others. These could be deans, prize winners, and others.

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Part 3: Programme lines and requirements

• The justification for the programme lines should be made much more prominent. Further on in the document, it is stated that the three programme lines are not the only developments that are deemed important, but that these are the ones where central coordination is considered crucial. The question why this is crucial is unanswered. This should be made much more prominent as an explanation of the choices made for NPOS2030. Also the reason for disregarding other aspects of open science (Open Education, Research Integrity and Reproducibility of scientific results are mentioned) is not very strong. It is stated that these are either already being taken up or relatively new. In our view both do not justify leaving these aspects out
  
• The central role of recognition and rewards in the transition to open science should be mentioned early on in the document, and a justification given as to why it is not in itself considered part of NPOS2030. Currently, it is only explicitly linked to Open Access. Similarly, research integrity gets a mention in relation to the organization of publishing, but in the current ambition document it does not seem to be considered an integral aspect of open science.
  
• We support the suggestion for alternative programme lines as proposed by the Open Science Communities Netherlands in their feedback (available at https://docs.google.com/document/d/1B4XGJQQSGwvGy1LzevB6n2nUoHiB2qDz/ ).
  
• The programme line Citizen Science seems to take a specific view on the relation between Open Science, Citizen Science and RRI (Figure 3). The emphasis on these as separate developments with only limited overlap encourages compartmentalization, rather than considering open science as an integrated approach towards more relevant, robust and efficient research. 
  
• The requirements are not well integrated with the rest of the document. In the introduction to the requirements, it is mentioned that ‘(…) the Programme Lines will address a set of essential requirements needed for this culture change‘ – but this is not reflected in the description of the programme lines themselves.

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Part 4: Key lines of action for the programme lines:

We only highlight the most pressing issues here. We won’t go into specific details (issues around consistent use of definitions, terminology and (business) models, etc.) 

Open Access

• The action line on applying open access to all output is great but there is not a beginning of ideas on how to realize that. Also it is unclear whether the 100% OA goal is also applied to all outputs.
  
• The importance of metadata is lacking in the mission and action lines for open access, though it is said to be part of the OA programme line. Explicit attention for metadata is important in relation to OA of all scholarly output, as well as openness of this metadata. It could be part of negotiations with publishers as well as a consideration in creating publishing infrastructure.

FAIR data

• We regret that there is no action line on increasing the amount of publicly shared research data sets. It is somewhat disappointing that there is no guidance or ambition on what is expected regarding making data open and open-licensed, beyond just making it FAIR. Additionally we regret that the adage ‘as open as possible, as closed as necessary’ has been watered down to ‘Open as early as possible, and closed when necessary’. We welcome that early opening up is seen as important but would advise to maintain the gradual nature of closedness, as in the original adage. In that context the concept of protected sharing introduced in this ambition should be framed as a way to share data that would otherwise remain closed and not as an excuse to not share in a fully open manner in cases where that is perfectly viable.

Citizen science

• We suggest adding a few lines defining citizen science. Also it would help to make clear how citizen science and public engagement are related, but also how they are different concepts.

• Currently the Citizen Science sections feels not very well integrated with the other sections. We would welcome a vision on the relation between FAIR and open data, open access and citizen science.

Consultation on Guiding Principles on Management of Research Information and Data

For the sake of transparency and to stimulate discussion we share our submitted responses to the Consultation on Guiding Principles on Management of Research Information and Data, held in June 2020 in the Netherlands by the Dutch association of universities (VSNU). Below, please find the responses by:

Jeroen Bosman orcid.org/0000-0001-5796-2727 (@jeroenbosman)
Bianca Kramer orcid.org/0000-0002-5965-6560 (@MsPhelps)
Jeroen Sondervan orcid.org/0000-0002-9866-0239 (@jeroenson)

The responses were drafted independent of each other and were submitted on 20200619.

A detailed annotation of the guiding principles, with comments from all three of us, can be accessed here:
https://tinyurl.com/vsnu-gp-comments

Finally, in the appendix we share information on a discussion session on the topic at the 2020 Open Publishing Fest.

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Consultation response Jeroen Bosman

Do the principles offer clear and effective guidance for Dutch research institutions?

• The principals come too late. They have been spurred by and drafted during the most important negotiation for which they should apply. That means that they have lost a chance to make a difference and perhaps more important that the issues dealt with in the principles are potentially too much oriented towards the type of deals and collaborations of that specific deal. They are molded for that (Elsevier) deal but not applied to that Elsevier deal.
• Overall the principles are too vague in content and language. Terms like community and knowledge institutions, scholarly capital etc. should be used more consequently and should be better defined.
• Overall it should be made much more clear who has which role in the process and who is to be held to which principles.
• It should be made more clear to what type of projects/services, with what type of partners, these guidelines pertain. Currently that scope is not exactly clear.
• The decision process, roles and timeline for an OKB should be made more transparent. There is reference to an ambition, but it is unclear where that comes from. 
• Many aspects of the guidelines pertain to scholarly metadata. It is common practice for most publishers and certainly for institutions practicing open science to share data fully openly, often with a CC0 license. For those (meta)data you cannot strive to be in control, because you already set the data free. So the guidelines partially conflict with the institutions’ own open science practices.

Are there any significant aspects missing within the principles?

• The decision process, roles and timeline for an OKB should be made more transparent. There is reference to an ambition, but it is unclear where that comes from. 
• Many aspects of lock-in and oligopolistic market behaviour are not addressed by these principles. Especially package deals, UX-compatibility, procedure adaptation and collaboration opportunity still make it difficult to switch to another vendor of combine offerings from vendors. See Figure 1 below with forms of lock-in.
• Principles currently do not preclude public investment to be commercially appropriated, while they allow creativity and IP created collaboratively to be become fully owned by the commercial partner, without the right for institutions to re-use its own creativity and investment in future collaborative endeavours. The principles should very clearly reserve the rights of publicly generated IP to the institutions, allowing them to share in any way they like, preferably fully open with a very liberal license allowing reuse for any purpose by any party.
• The principles should make it clear that collaborations to create infrastructure or contracts to buy services should not be an integral part of a publish & read contract for content, but dealt with separately and publicly procured. That is important to make sure there will not be too much pressure to creatively search for options that are barely compliant with the guiding principles just to not jeopardize the deal as a whole.

Figure 1 – Six forms of vendor lock-in

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Consultation response Bianca Kramer

Do the principles offer clear and effective guidance for Dutch research institutions?

There is unclarity regarding both the scope of the principles and how they are to be implemented:

• It is unclear whether the principles apply to infrastructure regarding research information (metadata on research outputs) or also to infrastructure supporting the creation of research output (e.g. data analysis and archiving, publication from preregistration to peer review). 
• More specifically, it is unclear whether the principles apply only to the creation of a ‘Dutch Open Knowledge base’ (or projects that could contribute to that) or also to collaboration on, or procurement of, other research tools/platforms – either by individual institutions and/or consortia of institutions.
• It is unclear whether the principles apply only to collaboration with commercial parties, or equally to collaborations with non-profit and/or public parties. This is not simply a distinction between ‘buy’ and ‘make’ – as collaborations with external non-profit and public third parties can be considered and invested in similar to agreements with commercial third partners.
• It is unclear to what extent the main aim of the principles is to ensure open availability of metadata (including provenance) for any party to use and build upon (consistent with open science practices), or conversely, to control access to and use of metadata. If the former, it could be helpful to separate requirements for provenance and openness of metadata from ownership and governance of the infrastructures themselves. 

The above points are fundamental questions that are, in my opinion, not sufficiently answered in the document. Part of this is due to ambiguous use of terminology in the document. More clarity on scope, and specificity in use of terminology, would be helpful. 

Are there any significant aspects missing within the principles?

• In the principles, focus seems to be on transparency and interoperability at the level of (meta)data: “data in-data out” (including attention to enriched/derivative data, which is good). However, what is lacking is attention for open source, open algorithms, and IP for creation of the infrastructure.
• It is not sufficiently outlined what the role of public procurement in the selection of third parties will be, and what measures are envisioned to prevent soft vendor lock-in, for instance uncoupling unique content provision from exchangeable service provision.
• The participation of third parties in infrastructure governance (GP6) should not jeopardize the principle of community-owned governance. In particular, public contributions to infrastructure should not be allowed to be commercially enclosed, but should remain open to the community to use and build upon, also after a contract with a third party has ended.
• The fact that these principles have been developed as an extension of an initial set of principles agreed upon with Elsevier for collaboration on services for a Dutch Open Knowledge Base remains deeply uncomfortable. It would have been far preferred if the Dutch Research Institutions would have independently drafted and consulted on such principles, and defined ambitions for a project like an Open Knowledge Base, prior to negotiations with any third party.

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Consultation response Jeroen Sondervan

Do the principles offer clear and effective guidance for Dutch research institutions?

This set of principles is a good and important start for the urgent discussions on this topic and which we should be addressing continuously within academia for the next few years. But this is only a start. It seems that important aspects (e.g. ownership, interoperability and ‘community’ governance) are being addressed, but what is confusing in the entire structure of the document is how ‘metadata (and research information)’ and ‘research data’ are as it seems being used as similar entities. 

The introduction (heading 2) is focusing on metadata and the importance of this type of data to be open for others to ‘access, reuse, enrich and describe according to existing, open standards, identifiers, ontologies and thesauri’. Principles for research data, which are very much needed and may have similarities with, but also specificities compared to metadata, are not made explicitly. 

However, it’s important to make these principles meaningful for both categories from the start to leave out any ambiguity in following discussions. This must be made much clearer across the entire document. Are these principles applicable to both categories? Are there any exemptions, and why? Will they differ regarding the use of third party infrastructure and services? Are there principles missing, which can only be applied to one of the categories?

Another important issue, which can lead to a tunnel vision in the discussion(s) is the use of the term ‘commercial third parties’. This is too narrow. These principles should be applied to every entity (profit, non-profit, governmental, etc.) academia will be dealing with outside its own premises in regard to developing infrastructure and publishing services. 

The way in which the ‘Open Knowledge Base’ is presented in the document reads as it is already in jugs and jars. A sentence like ‘the Dutch research institutions have the ambition to create themselves an Open Knowledge Base (OKB)’ could be read as if the idea of the OKB was first, and we needed these principles to back it up. 

Is this idea of the OKB consolidated amongst the institutions? Have discussions being held in faculty and amongst universities? This is unclear. I’m not aware of any consolidation of this idea of an OKB other than two public blog posts published recently that address the concept of an  OKB. The discussion should be the other way around. We first work on a common ground and broad acceptance of these principles and then we should start thinking about an OKB and its features.

Are there any significant aspects missing within the principles?

• It’s important to have clarity on definitions that are being used throughout the document. What do ‘we’ mean with specific terms being used. What do we mean by e.g. ‘community’, ‘ownership’, etc. etc. A list of definitions could help clarification.
• The word licensing, or better ‘open’ licensing is nowhere to be found. The document would gain strength if this is explicitly stated as part of the principle(s) (e.g. in the ownership and/or interoperability sections). The scholarly metadata should ideally be licensed under a CC0 license in order to be reusable as much as possible. How does this relate to the ownership as stated in GP6 – Community owned governance? This principle seems to focus on research data only. For this type of data other licenses could or should apply. Here you see the evident importance of being absolutely clear about the typologies of ‘data’.    
• Make more explicit under what conditions the future infrastructure (and/or publishing services) would be operating (e.g. open source, open standards/APIs, data licensed under CC0, etc.etc.). Important to define the bare minimum. 
• Add ‘control’ to ownership, so it is clear that academia not only owns but also keeps control (under these guiding principles) of the research (information) data. 
• How to achieve transparency in the entire process should be made more explicit. Something like the ‘transparent agreement system’ (GP3) is too vague or even more so unclear and should be explained. So, not only transparency measures for ‘technical, legal and operational agreements for metadata sharing’ but for the entire governance on these guiding principles. 

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Appendix:

Fig. 2 Open Publishing Fest session

On May 28, we organized and moderated a 1-hour panel discussion on the proposed guiding principles during the Open Publishing Fest, with participants including researchers, non-profit and for-profit tool providers, and proponents of open infrastructure. A video registration of the session is available on YouTube.

Below some of the points that were raised in this discussion:

• It is important to take a values-driven approach, which can then be translated into what is built and how
• Focus should be on providing rights, rather than on regulating/restricting collaboration
• Opportunities and barriers for (smaller) players, and the need for clarity on the criteria for participation
• Do the principles represent the needs of the research community?
• More clarity is needed on what is wanted, also in terms of openness
• Better alignment with existing principles, like the SPARC NA Good Practice Principles for Scholarly Communication Services
• Tools from external parties can be used, but implementation and control of infrastructure has to remain in an academic-controlled organization