Open Consultation on the NPOS2030 Ambition Document — response on behalf of 4TU.ResearchData

Below if the response sub­mit­ted by 4TU.ResearchData to the Open Con­sul­ta­tion on the NPOS2030 Ambi­tion Doc­u­ment. Con­sul­ta­tion doc­u­ments:


1. To what extent do you agree with the NPOS Guid­ing Prin­ci­ples?

  • Agree

2. Do you have com­ments or sug­ges­tions for this ele­ment of the Ambi­tion Doc­u­ment?

4TU.ResearchData appre­ci­ates the oppor­tu­ni­ty to pro­vide input on the NPOS2030 Ambi­tion Doc­u­ment. We observe that this is in full agree­ment with the prin­ci­ple of trans­paren­cy and inclu­sive­ness.

Over­all, 4TU.ResearchData is in full sup­port of the NPOS Guid­ing Prin­ci­ples. Our com­ments and ques­tions are about the imple­men­ta­tion of these prin­ci­ples: how these will be reflect­ed in the gov­er­nance of the nation­al ambi­tion, and also how these will trans­late into spe­cif­ic action lines and fund­ing for these activ­i­ties.

Spe­cif­ic com­ments about the prin­ci­ples:

1. Open as ear­ly as pos­si­ble and pro­tect­ed when nec­es­sary 

How does this prin­ci­ple apply to research out­puts pro­duced by for prof­it organ­i­sa­tions? They are also an impor­tant stake­hold­er when it comes to soci­etal impact. To set the ambi­tion for 2030, this doc­u­ment should not shy away from propos­ing a process to agree on expec­ta­tions for for prof­it organ­i­sa­tions and also for pub­lic-pri­vate part­ner­ships. Such a process should be inclu­sive of rel­e­vant stake­hold­ers out­side of acad­e­mia.

On a small­er note, what is the ratio­nale for devi­at­ing from the “as open as pos­si­ble, as closed as nec­es­sary” broad­ly adopt­ed by the com­mu­ni­ty to “Open as ear­ly as pos­si­ble, and pro­tect­ed when nec­es­sary”?

2. Sub­sidiar­i­ty: each organ­i­sa­tion imple­ments Open Sci­ence with­in their local organ­i­sa­tion and infra­struc­ture in line with (inter)national guide­lines on Open Sci­ence, in a fed­er­at­ed fash­ion

What is the exact vision for the imple­men­ta­tion of this prin­ci­ple? Should this prin­ci­ple be applied to all pro­gramme lines? 

The devel­op­ment, imple­men­ta­tion and main­te­nance of open infra­struc­tures is cer­tain­ly in-line with the sub­se­quent prin­ci­ple “Aca­d­e­m­ic and dig­i­tal sov­er­eign­ty must be safe­guard­ed via con­cert­ed action in the inter­est of trans­par­ent, inclu­sive and reli­able knowl­edge cre­ation”. How­ev­er, it is essen­tial to work togeth­er and share infra­struc­tures to make it scale. Also, a con­crete plan and ambi­tion are need­ed to make this hap­pen. Ongo­ing invest­ment is need­ed to sup­port open infra­struc­tures (see the report “Scop­ing the Open Sci­ence Infra­struc­ture Land­scape in Europe”: https://doi.org/10.5281/zenodo.4159838). Giv­en that there is no fund­ing attached to the cur­rent Ambi­tion Doc­u­ment, it is dif­fi­cult to under­stand how this prin­ci­ple will be realised.

3. We stand for inclu­sive­ness and invite all stake­hold­ers to con­tribute

4TU.ResearchData ful­ly sup­ports this prin­ci­ple. How­ev­er, it is not clear how this prin­ci­ple will be trans­lat­ed into gov­er­nance struc­ture. Inclu­sive gov­er­nance is key for uphold­ing this prin­ci­ple.

Small­er com­ments:

  • The require­ment “Make Open Sci­ence nor­ma­tive through active Com­mu­ni­ty Engage­ment” seems to be lim­it­ing the para­mount role of com­mu­ni­ty engage­ment in enabling open sci­ence only to Open Sci­ence Com­mu­ni­ties. Var­i­ous pro­fes­sion­als also need their peer net­works and com­mu­ni­ties, sim­i­lar­ly to domain and dis­ci­pline-spe­cif­ic com­mu­ni­ties. So the scope there needs to be broad­ened.
  • The map of NPOS stake­hold­ers in fig­ure 2 is miss­ing 4TU.ResearchData and RDNL.

3. To what extent do you agree with the NPOS Vision for 2030?

  • Nei­ther agree nor dis­agree

4. Do you have com­ments or sug­ges­tions for this ele­ment of the Ambi­tion Doc­u­ment?

While the vision sets an over­all direc­tion for the future, it is a bit unclear how this vision will be imple­ment­ed. For exam­ple, the vision state­ment men­tions that ‘jour­nals will change form and for­mat’, but there is no fur­ther elab­o­ra­tion on what the desir­able form and for­mat should be in 2030. The vision should also set out a strat­e­gy for imple­men­ta­tion, which is at the moment unclear, espe­cial­ly since it is unclear whether there is any fund­ing attached to the ambi­tion.


The vision aims at mak­ing “all dig­i­tal forms of schol­ar­ly out­put” FAIR (page 10). How­ev­er, it is unclear why the Ambi­tion Doc­u­ment focus­es so much atten­tion on Open Access, FAIR Data and Cit­i­zen Sci­ence, but not on oth­er ele­ments of Open Sci­ence.


The doc­u­ment even reads “There are many more impor­tant aspects on Open Sci­ence, such as Open Edu­ca­tion, Research Integri­ty and Repro­ducibil­i­ty of sci­en­tif­ic results. Some of these top­ics have already been tak­en up by part­ners in the sci­en­tif­ic com­mu­ni­ty. Oth­ers are rel­a­tive­ly new: we have to see how they devel­op and how they are relat­ed to oth­er top­ics. In the upcom­ing peri­od we will eval­u­ate our progress, mon­i­tor new devel­op­ments, and accord­ing­ly update our activ­i­ties to achieve our goals”. The Nether­lands should do bet­ter than wait­ing and see­ing what hap­pens if it wants to be seen as a leader in the imple­men­ta­tion of Open Sci­ence. Even if there are some par­al­lel efforts to address some issues (there is an expla­na­tion pro­vid­ed that Open Edu­ca­tion needs are being addressed as part of The Accel­er­a­tion Plan for Edu­ca­tion Inno­va­tion with IT), a nation­al strat­e­gy is still need­ed to ensure that these efforts are aligned.


As a min­i­mum, the strat­e­gy should ded­i­cate explic­it atten­tion also to Research Soft­ware. Soft­ware is essen­tial for research nowa­days, as a tool for repro­ducible data pro­cess­ing, but also as a sci­en­tif­ic out­put itself. The accom­plish­ment of FAIR data needs FAIR soft­ware.

Small notes:

  • It would be help­ful if on page 10 there was also a ref­er­ence to the FAIR prin­ci­ples on the FORCE11 web­site (as agreed by the com­mu­ni­ty) in addi­tion to the ref­er­ence to the Lorentz work­shop in 2014 where these were con­ceived.
  • What is meant by an ‘Open Access license’ in the sen­tence “More­over, as much as pos­si­ble, schol­ar­ly out­put should be made avail­able under an Open Access license”?

5. To what extent do you agree with the NPOS Pro­gramme Lines and the Require­ments?

  • Nei­ther agree nor dis­agree

6. Do you have com­ments or sug­ges­tions for this ele­ment of the Ambi­tion Doc­u­ment?

Again, 4TU.ResearchData firm­ly believes that the scope of the cur­rent three pro­gramme lines: Open Access, FAIR Data and Cit­i­zen Sci­ence need to be extend­ed to oth­er Open Sci­ence top­ics.

The vision explains that “the deci­sion to work with a Rolling Agen­da in the com­ing decade will ensure the Pro­gramme is updat­ed when­ev­er new themes and chal­lenges occur” and also that “the Steer­ing Board coor­di­nates the Pro­gramme and its Pro­gramme Lines, and the actions out­lined in its Rolling Agen­da. It facil­i­tates feed­back from and inter­ac­tions between key stake­hold­ers across the Dutch sci­en­tif­ic com­mu­ni­ty and mon­i­tors the align­ment of the Open Sci­ence activ­i­ties in The Nether­lands with sim­i­lar ini­tia­tives else­where in Europe”. How­ev­er, recog­ni­tion of oth­er aspects of Open Sci­ence (thus broad­er than just Open Access, FAIR Data and Cit­i­zen Sci­ence) has already tak­en place in Europe and also in Dutch aca­d­e­m­ic insti­tu­tions which have more diverse and more inclu­sive pro­grammes than depict­ed in the NPOS2030 Ambi­tion Doc­u­ment.

Research soft­ware in par­tic­u­lar needs more atten­tion with­in the Ambi­tion Doc­u­ment. Cur­rent­ly, soft­ware seems to be seen as a tool to sup­port data analy­sis. How­ev­er, research soft­ware is a schol­ar­ly out­put in its own right, sim­i­lar­ly to research data or pub­li­ca­tions. Fur­ther­more, FAIR prin­ci­ples can­not be sim­ply applied to soft­ware — they need adap­ta­tion for this to hap­pen. As explained in the report of the FAIR WG of the Euro­pean Open Sci­ence Cloud (Six Rec­om­men­da­tions for Imple­men­ta­tion of FAIR Prac­tice) “…Soft­ware is dif­fer­ent from data: it is a tool to do some­thing (exe­cutable); it is built by using oth­er soft­ware (imple­ments mul­ti-step process, coor­di­nates mul­ti­ple tasks), it has com­plex depen­den­cies and has a short life cycle with fre­quent need of ver­sion­ing (includ­ing depen­den­cies). Some of these char­ac­ter­is­tics also apply to data. How­ev­er, the vari­ety of soft­ware and its pub­lish­ing and dis­tri­b­u­tion chan­nels, and the neces­si­ty to doc­u­ment depen­den­cies and describe data for­mats, pos­es a chal­lenge when adapt­ing the cur­rent FAIR prin­ci­ples.” There­fore, it is essen­tial that there is ded­i­cat­ed effort to tack­le these issues.

The vision right­ful­ly states that the imple­men­ta­tion of the NPOS Pro­gramme Lines will be done in close align­ment in order to “syn­chro­nise activ­i­ties and to build on each oth­er’s progress”. How­ev­er, it is unclear how this will hap­pen. How will this desire trans­late to gov­er­nance struc­ture facil­i­tat­ing such syn­chro­ni­sa­tion? The pro­gramme lines cur­rent­ly feel rather dis­con­nect­ed.

For exam­ple, ambi­tions relat­ed to research infra­struc­ture should be han­dled holis­ti­cal­ly to iden­ti­fy syn­er­gies and avoid dupli­ca­tion of efforts. Instead, the Cit­i­zen Sci­ence pro­gramme line aims to “Devel­op and Invest in Sup­port­ing Infra­struc­tures” and there seem to be no cross-con­nec­tion or ref­er­ences to the rel­e­vant action line of the FAIR Data pro­gramme: “Ser­vices and infra­struc­tures: enable sus­tain­able inter­op­er­a­ble net­works of FAIR Data ser­vices and research infra­struc­tures at the domain lev­el, insti­tu­tion­al lev­el, and nation­al lev­el“. 

Sim­i­lar­ly, the ambi­tions of the pro­gramme line on Open Access does not seem to take into account the needs of oth­er pro­grammes. For exam­ple, pub­lish­ers should make the links between pub­li­ca­tions and oth­er out­puts explic­it in meta­da­ta and they should fol­low the advice of inter­na­tion­al expert groups (such as the RDA Scholix Work­ing Group, JATS4R rec­om­men­da­tions on Data Cita­tion, or the new­ly launched NISO group devel­op­ing rec­om­men­da­tions for inte­grat­ing pub­lish­ers and repos­i­to­ry work­flows).  This should be a require­ment when sign­ing any new deals with pub­lish­ers.

The link between the guid­ing prin­ci­ples and the require­ments for Open Sci­ence is unclear. Most of the require­ments appear to be high lev­el prin­ci­ples or ambi­tion state­ments. What is the role of both? How do they trans­late to pro­gramme lines and key actions? For exam­ple, the fourth require­ment “Make Open Sci­ence reward­ing through incen­tives (Recog­ni­tion & Rewards)” (page 13) is very impor­tant and is indeed a vehi­cle for much need­ed cul­tur­al change. How­ev­er, it is not clear how this require­ment trans­lates to spe­cif­ic actions with­in the pro­gramme lines.


7. To what extent do you agree with the NPOS Key Lines of Action for the Pro­gramme Lines?

  • Nei­ther agree nor dis­agree

8. Do you have com­ments or sug­ges­tions for this ele­ment of the Ambi­tion Doc­u­ment?

The main reser­va­tion which 4TU.ResearchData has towards the pro­gramme line is their lack of inclu­siv­i­ty to oth­er aspects of Open Sci­ence. How­ev­er, we are broad­ly in agree­ment with the spe­cif­ic action lines of the three pro­grammes. Our com­ments high­light spe­cif­ic areas for improve­ment with­in the key actions of the three pro­gramme lines.

Open Access 

Action lines in this pro­gramme line would ben­e­fit from bet­ter artic­u­la­tion of spe­cif­ic objec­tives and tasks. For exam­ple, the action line “Main­tain­ing high qual­i­ty and research integri­ty” seems to be a list of obser­va­tions and reflec­tions on the cur­rent sit­u­a­tion and what should change, but doesn’t pro­pose any spe­cif­ic actions to tack­le these prob­lems. Sim­i­lar issues are observed with some oth­er actions, e.g. “Nov­el ways of Recog­ni­tion & Rewards, away from quan­ti­ta­tive mea­sures “ and “Con­trol over own­er­ship, pub­lic val­ues, and aca­d­e­m­ic and dig­i­tal sov­er­eign­ty”. Anoth­er exam­ple, there is an ambi­tious state­ment that “We will estab­lish a sus­tain­able, inno­v­a­tive open pub­lish­ing-infra­struc­ture for all schol­ar­ly data”. What exact­ly is meant here? Who will build this, how, when and what are the plans for sus­tain­able financ­ing?

4TU.ResearchData finds it rather con­fus­ing that action lines 4–6 (4. Main­tain­ing high qual­i­ty and research integri­ty; 5. Nov­el ways of Recog­ni­tion & Rewards, away from quan­ti­ta­tive mea­sures; 6. Con­trol over own­er­ship, pub­lic val­ues, and aca­d­e­m­ic and dig­i­tal sov­er­eign­ty) are list­ed as only applic­a­ble to the Open Access pro­gramme line. We believe that these action lines should also apply to FAIR Data and Cit­i­zen Sci­ence pro­gramme lines.

Small com­ments:

  • What is meant by ‘schol­ar­ly data’ in “We will estab­lish a sus­tain­able, inno­v­a­tive open pub­lish­ing-infra­struc­ture for all schol­ar­ly data”? 

FAIR data 

4TU.ResearchData sup­ports the Mis­sion and Ambi­tion of the FAIR Data pro­gramme line, as well as the indi­vid­ual actions. 

One reser­va­tion that we have is that the FAIR Data pro­gramme line seems to be focus­ing pri­mar­i­ly on the ‘use’ and ‘reuse’ of research data and the suit­abil­i­ty of FAIR data. The key aspects of research integri­ty and research repro­ducibil­i­ty are cur­rent­ly miss­ing. This is also one of the pri­ma­ry dri­vers for FAIR Data and not rec­og­niz­ing this clear­ly is a miss. Note that the VSNU code of con­duct for research integri­ty men­tions the word ‘data’ over 40 times.

In addi­tion, 4TU.ResearchData want­ed to express dis­ap­point­ment about the lack of ref­er­ences to 4TU.ResearchData in the NPOS doc­u­ment over­all, but with­in the FAIR Data Pro­gramme line in par­tic­u­lar. 4TU.ResearchData is an impor­tant infra­struc­ture and exper­tise cen­tre in the domain of sci­ence, engi­neer­ing and design, and has not only nation­al, but also an inter­na­tion­al scope. A rep­re­sen­ta­tive of 4TU.ResearchData is part of the team lead­ing the for­ma­tion of the the­mat­ic DCC for nat­ur­al and engi­neer­ing sci­ences. Mem­bers of 4TU.ResearchData have also con­tributed to the first line of action of the FAIR Data pro­gramme line. We hope that the con­tri­bu­tion that 4TU.ResearchData makes to the nation­al open sci­ence land­scape will be bet­ter reflect­ed in the sub­se­quent ver­sion of this doc­u­ment.

Small com­ment:

  • Research Soft­ware Engi­neers are a sep­a­rate pro­fes­sion to the data stew­ards. As such, they should not be men­tioned under “Capac­i­ty build­ing: cre­ate a pro­fes­sion­al com­mu­ni­ty of skilled data stew­ards”.

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