“We appreciate the benefits that collaborations with external partners, such as CHORUS, may provide. Because third-party vendors operate under terms that are subject to change, they should serve as a supplement to support compliance, rather than a proxy to indicate compliance. This approach ensures that NASA remains in a strong position to leverage external partners where it benefits the agency and its grantees while retaining flexibility to adapt its approach should the terms change under which services such as CHORUS are offered—without the burden of revising policy.

We further recommend that NASA explicitly emphasize the availability of compliance options that do not present financial barriers. NASA’s plan and associated policies and guidance should clearly describe how authors can fully comply with its public access policy at no cost by depositing the author’s accepted manuscript into NASA’s PubSpace or any other agency-approved repository.

Because authors may be encouraged to pay added Open Access fees in circumstances when they are unnecessary for compliance, NASA should clarify that any charges from publishers are publication charges—not compliance charges. It is critical that authors do not conflate compliance with article processing charges (APCs), which create significant barriers for less-well-resourced authors and institutions to make their research available. It is important for researchers to understand that the option to post their final peer-reviewed manuscript into an agency-designated repository is an affordable and equitable full compliance mechanism that is available to them.

Institutional repositories run by libraries and other research institutions generally do not charge authors to deposit articles or manuscripts. These can play an important role in easing compliance burdens on authors, improving discoverability of research outputs, and providing long-term preservation support. Therefore, we strongly recommend that NASA allow for the deposit of publications into other repositories beyond PubSpace, and suggest that NASA utilize the guidance set out in the U.S. Repository Network’s Desirable Characteristics of Digital Publications Repositories….”