The Office of Science and Technology Policy (OSTP) has issued an RFI on “Accelerating the American Scientific Enterprise,” seeking input on modernizing federal science policy for the AI era.

Gemini 3.0, Deep Research Analysis

ChatGPT-5.1 Analysis

Executive Summary: OSTP RFI Analysis for Scholarly Publishers

by Claude

Overview of the RFI Context

The Office of Science and Technology Policy (OSTP) has issued a Request for Information on “Accelerating the American Scientific Enterprise,” seeking input on modernizing federal science policy for the AI era. This represents a critical juncture where the traditional “hardware” of science (labs, equipment) must be matched by robust investment in the “software” of science—data curation, validation, and dissemination.

Key Themes and Opportunities for Publishers

Strategic Positioning

The Gemini and ChatGPT analyses position scholarly publishers not as vendors of subscriptions, but as essential knowledge infrastructure providers—custodians of the “Version of Record” and partners in organizing scientific information for national benefit. This reframing is central to both analyses.

Major Policy Proposals Relevant to Publishers

1. Research Knowledge Infrastructure (RKI) Procurement Category

• New federal procurement category explicitly for publisher-grade data curation, metadata enrichment, and AI-ready corpora

• Elevates publishers from service providers to infrastructure partners

• Enables agencies to purchase curated content assets, not just software/hardware

2. National AI-Ready Research Corpus (NARC)

• Federally licensed, high-integrity dataset of peer-reviewed research

• Publishers would curate and provide the “Version of Record”

• Establishes clear copyright frameworks for AI training

• Creates potential revenue streams through tiered access models

3. “Trusted Data Provider” Accreditation

• FedRAMP-style certification for research content providers

• Reduces negotiation friction with federal agencies

• Creates competitive advantage for certified publishers

4. Knowledge Intermediary Recognition

• Modernizes Bayh-Dole Act to recognize publishers’ translational role

• Acknowledges curation, validation, and contextualization as essential to tech transfer

• Opens funding for “translation layers” (semantic tagging, reproducibility documentation)

5. Research Integrity AI Systems

• Federal investment in tools to detect fabricated data, image manipulation, citation manipulation

• Publishers already developing these capabilities—opportunity for partnership/procurement

• Positions publishers as guardians of scientific integrity in the AI age

Critical Watchpoints for Publisher Responses

Must Address:

1. Copyright and AI Training Clarity

   • Both analyses emphasize need for “copyright-respecting AI training agreements”

   • Publishers should articulate clear licensing frameworks that balance rights protection with innovation needs

   • Avoid appearing obstructionist while protecting legitimate IP interests

2. Sustainable Business Models

   • Analyses warn against “unfunded mandates that destabilize scholarly communication”

   • Must demonstrate how proposed models support long-term sustainability

   • Show how public-private partnerships can work without undermining publisher viability

3. Metadata and Standards Leadership

   • Heavy emphasis on PIDs (DOIs, ORCID, ROR), FAIR data, structured XML/JSON

   • Publishers should showcase existing capabilities and investments

   • Demonstrate interoperability commitment

4. Regional Equity and SME Access

   • Strong focus on democratizing access beyond elite institutions

   • “Knowledge Commons Charters” for regional hubs

   • Federal vouchers for SMEs to access research content

   • Publishers need to show commitment to broad access while maintaining quality

5. Research Integrity Infrastructure

   • Frame publishers as providing “trust infrastructure” not just content

   • Emphasize peer review, provenance tracking, retraction/correction systems

   • Position as essential for research security

Potential Pitfalls to Avoid:

1. Appearing Self-Serving

   • Responses that merely advocate for more publisher revenue will fail

   • Must demonstrate clear public benefit and national security rationale

   • Frame proposals in terms of accelerating discovery, not protecting business models

2. Ignoring Open Access Realities

   • Federal policy momentum toward immediate public access is strong

   • Responses that resist this trend will be dismissed

   • Better to shape how OA is implemented sustainably

3. Underestimating Procurement Complexity

   • Creating new procurement categories requires significant regulatory change

   • May face resistance from existing IT/software contractors

   • Need to show clear cost-benefit over current approaches

Pros and Cons of This RFI Exercise

Potential Pros:

For Publishers:

• Legitimizes publisher role in federal science infrastructure beyond traditional publishing

• Opens new revenue streams through RKI procurement, NARC licensing, integrity services

• Protects copyright interests by establishing clear AI training frameworks

• Elevates publishers to strategic partners rather than passive service providers

• Creates barriers to entry through “Trusted Data Provider” accreditation

• Positions publishers as solution to research integrity crisis in AI era

For the Research Ecosystem:

• Could accelerate discovery by professionalizing data curation

• May improve research quality through better integrity infrastructure

• Could democratize access to high-quality research for SMEs and regional institutions

• Might solve copyright uncertainty around AI training

Potential Cons:

For Publishers:

• Increased scrutiny and regulation of publisher practices and pricing

• Pressure for broader access may undermine subscription models

• Federal funding may favor open infrastructure over commercial publishers

• Compliance burdens from new accreditation requirements

• Risk of being “infrastructuralized” with regulated pricing like utilities

• Competition from non-traditional players (tech companies, universities) for federal contracts

• May not translate to actual procurement if proposals require too much regulatory change

For the Research Ecosystem:

• Risk of further concentrating power with large publishers who can meet federal requirements

• May create two-tier system: federally-approved vs. non-approved content

• Could slow innovation if federal standards become prescriptive

• Tension between national infrastructure goals and global nature of research

• Privacy and security concerns with centralized research corpora

Strategic Risks:

1. Regulatory Capture Appearance: Publishers advocating for policies that benefit themselves may face credibility challenges

2. Open Access Conflict: Proposals may conflict with broader federal push for immediate, unrestricted access

3. Tech Company Competition: Amazon, Google, Microsoft may compete for “knowledge infrastructure” contracts

4. Academic Pushback: Universities may resist ceding control of research outputs to commercial publishers

5. Implementation Failure: Even if policies are adopted, actual procurement changes may take years or never materialize

Recommendations for Publisher Response Strategy

1. Lead with Public Benefit: Frame every proposal in terms of accelerating discovery, protecting research integrity, and national competitiveness—not publisher revenue

2. Be Specific and Technical: Provide concrete examples of how RKI procurement would work, what NARC architecture would look like, with cost estimates

3. Acknowledge Tensions: Address open access, pricing concerns, and competition honestly rather than ignoring them

4. Demonstrate Existing Capabilities: Showcase investments in metadata, integrity tools, AI-ready formats that federal government can leverage

5. Coalition Building: Coordinate with societies, libraries, universities to present unified vision rather than appearing isolated

6. Propose Pilot Programs: Suggest limited trials (e.g., NARC pilot with 3 agencies) rather than wholesale system changes

7. Emphasize Interoperability: Show commitment to open standards and working with diverse partners, not creating walled gardens

Conclusion

This RFI represents both significant opportunity and substantial risk for scholarly publishers. The opportunity is to be recognized as essential infrastructure providers in the federal science ecosystem, with access to procurement channels and policy frameworks that legitimize their role beyond traditional publishing. The risk is that poorly crafted responses could accelerate movement toward federal policies that undermine publisher business models while strengthening competitors (tech companies, open infrastructure) or leading to regulatory constraints.

The optimal strategy is to position publishers as indispensable partners in solving genuine federal challenges (AI integrity, research security, tech transfer) while demonstrating flexibility on access and pricing models. Publishers should frame themselves as the “operating system” of scientific knowledge—essential infrastructure that requires sustainable funding, whether through procurement, licensing, or public-private partnerships—rather than as content vendors protecting market position.

The analyses are sophisticated advocacy documents. Publishers following this approach should ensure they can deliver on promises and that proposals genuinely serve the public interest, as federal scrutiny of these claims will be intense.

Gemini & GPT-5.1 Analyze The "LAUNCHING THE GENESIS MISSION" Executive Order. Claude provides the Executive Summary.

PASCAL HETZSCHOLDT

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25 NOV

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