Comments on openness of accessibility, participation and incentives

Assuming the text to comment on is the interim HLEG report ‘Prompting an EOSC in practice’ (and in particular Chapter 5 of this report), I have the following overall comments:

1. The proposed rules of participation (including limitations on accessibility, and data security) seem very much aimed at ensuring closed access where needed. While this is obviously important in specific cases, care should be taken not to unduly limit accessibility and (re)use of data that can be made openly available without such restrictions.  
2. Together with limited accessibility for (re)use of data, in the current vision of EOSC business models, possibilities for contributing data to EOSC seem limited to either EU beneficiaries or beneficiaries of participating institutions (e.g. through the EOSC coin model). It would be good to consider the consequences of this for the openness of EOSC, esp. the openness of participation by e.g. citizen scientists, unaffiliated researchers and researchers from organizations with limited funding.
3. The inclusion in the current recommendations of development of services as independent, interoperable and exchangeable building blocks, open software development and open standards is recommendable. It would be good to be clear on how to safeguard these principles in the rules of participation.
4. Linking career-enhancing incentives for researchers to the use of EOSC, rather than to good open science practices independent of the platform(s) used is potentially problematic, as it creates a circular dependency and disadvantages researchers who are excluded from EOSC as discussed in point 2.  

More detailed comments can be found at the following link (GDoc, open to comments):
https://docs.google.com/document/d/1oZnXYFyzx26pinUL2WjGz0KDdIzSGdGPGRfk...