CERF and Consortium of Aquatic Science Societies Comment on New US Public Access Policies

On 29 October 2024, CERF and the nine other societies comprising the Consortium of Aquatic Science Societies (CASS) sent a letter to the US Office of Science and Technology Policy (OSTP) regarding the implementation of the “Ensuring Free, Immediate, and Equitable Access to Federally Funded Research” Memo, commonly referred to as the Nelson memo. The Nelson memo directs all US federal agencies with research and development expenditures to update their public access policies as soon as possible, and no later than 31 December 2025, to make publications and supporting data resulting from federally funded research publicly accessible without an embargo on their free and public release, establish transparent procedures that ensure scientific and research integrity is maintained in public access policies, and coordinate with OSTP to ensure equitable delivery of federally funded research results and data. The CASS letter strongly supports the principles of open science and the importance of freely sharing research results in a timely and equitable manner while also expressing concern about potential unintended consequences of revised public access policies on professional societies and the quality and equity of the research enterprise. The letter outlines six specific concerns about the implementation of the Nelson memo:

1. Scientific societies play a critical role in the research enterprise that was not adequately considered when developing new policies.
2. Scientific societies may face significant financial impacts because of the proposed policies.
3. Scientific societies were not engaged during stakeholder outreach by OSTP and federal funding agencies.
4. The proposed policies may lower the quality of published research.
5. The proposed policies may exacerbate existing inequities in the research enterprise.
6. Lack of coordination across federal agencies will hinder the goal of allowing all Americans to benefit from the returns of federally funded research results.

In the letter, CASS provides five recommendations on how the implementation of the Nelson memo may be improved to ensure it meets its intended goals and avoids unintended impacts on the research enterprise and scientific societies:

1. Engage professional societies to inform draft policies.
2. Support partnerships with professional societies for policy implementation.
3. Require agencies to include open science costs in future budgets.
4. Develop policies to support less-resourced researchers.
5. Analyze inconsistencies across agencies and require alignment where possible.

You can read the full CASS letter at https://bit.ly/CASSPublicAccessLetter.

The letter was also sent to US congressional committees with oversight of federal research funding agencies. On 13 November 2025, Estuaries and Coasts Coeditor in Chief Paul Montagna represented CERF as a panelist for a House Science, Space, and Technology Committee staff briefing on the implementation of public access policies for federally funded research results and data and, specifically, the Nelson memo. We were honored to join this esteemed panel and share our perspective as a small scientific society along with experts Paolo Mangiafico (Duke University Libraries), Meagan Phelan (AAAS Science journals), Lori Schultz (The University of Texas at San Antonio), and moderator and past OSTP Director Dr. Kelvin Droegemeier (University of Illinois Urbana-Champaign). We thank Dr. Victoria Long Rubin, House Committee on Science, Space, and Technology Republicans Senior Professional Staff and estuarine scientist, for inviting CERF and Montagna to participate.

During the congressional staff briefing, Montagna reiterated many elements of the CASS letter. He highlighted the importance of Estuaries and Coasts in supporting CERF’s non-profit mission of disseminating high-quality science to advance the understanding and management of coastal and estuarine systems worldwide, and how the journal provides funds for CERF’s other programs that help the coastal and estuarine research, management, and education community. He noted potential impacts to both the research enterprise and professional societies, including the increased administrative burden of compliance, increased difficulty of finding some research results, diminished quality of published research, reduced financial sustainability of scientific societies, and increased obstacles for researchers with fewer resources to support open access publishing. CERF will continue to monitor the Nelson memo and its effects on our members and the journal.

US House Committee on Science, Space, and Technology Ranking Member Zoe Lofgren (D-CA) provides welcoming remarks. Credit: Susan Park	The panelists and moderator prepare for the briefing to begin; from left to right: Paolo Mangiafico, Meagan Phelan, Paul Montagna, Lori Schultz, and Kelvin Droegemeier. Credit: Susan Park	Paul Montagna (left) and Victoria Long Rubin (right). Credit:Susan Park