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Subject: Member Consultation: Planned OASIS comments on European Interop. Framework

To OASIS members:

From time to time, OASIS is asked to provide comments on policy and related documents that are relevant to our global standardization communities and environments.  While OASIS does not always respond to those inquiries, there are occasions on which a formal written response, from the standpoint of the consortium, may be appropriate and helpful to the open standards community environment generally.   In those cases, we are benefited by the views and comments of our members come whenever possible, and so may share drafts of public process documents with our membership, seeking your input through this discussion list vehicle.  (OASIS never speaks on behalf of its members, makes explicit disclaimers to that effect, and always encourages its members and stakeholders to provide their own distinct submissions to any public requests for policy comments.)

In this case, the European Commission's ISA-2 program is considering revisions to the "European Interoperability Framework" policy document, and recently held public meetings and open queries to gather comments.  This revision process also has been discussed in several of the standards cooperation forums where we participate, including the European Commission's Multi-Stakeholder Panel on ICT Standardization.

General Information on the revision project can be found in the attached EC workshop slide set (PDF file).

The text of the EIF contains 25 recommendations, many of which either are obvious conclusions that do not require comment from OASIS, or have limited relevance to our consortium's activities and scope.  Therefore, OASIS plans to submit limited comments on a few select matters:  our preliminary draft is appended below.  The ISA team indicated to us that they welcome our input at this time, and so we are circulating this draft, inviting member reactions, before it is made final and submitted.   Please note that we will review all comments received, and appreciate your feedback, though OASIS may not necessarily use all suggestions received.  Please direct your comments back to this discussion list, if they're open, or to OASIS staff directly if you prefer to share non-public reactions with us.  Please make any comment available to us by November 30, 2015.  Thanks for your attention.


OASIS, as an active participant in the European Commission's MultiStakeholder Panel on ICT Standardization and other global open standards coordination activities such as the ISO/ITU/IEC/UN eBusiness MoUMG, and as the host for a large number of open standards actively in use by European governments, is pleased to provide the following brief comments to ISA's plans to revise your European Interoperability Framework.  OASIS is one of the larger and oldest global open data standards consortia, with approximately 5000 active participants representing about 500 member organizations and individual members in over 80 countries, hosting approximately 70 active technical committees.  However, OASIS as a consortium does not speak on behalf of our diverse group of industry, academic and governmental members, who do not necessarily share the same views on all matters, and may choose to submit their own opinions.

We are pleased and grateful to see the draft revision plan reaffirm its support for principles of openness, data protection, cybersecurity, and preservation of public administration documents and data, consistent with OASIS' own emphasis on open, standardized data and document formats.  Many standards from OASIS already are widely at work supporting the Digital Single Market, including our OpenDocument Format (ODF) and Universal Business Language (UBL).  Preferences for openly-available and freely-adaptable open data exchange and data format standards, giving no preference to specific vendors or systems, obviously support and help drive these goals. 

We also very much appreciate the direction of EIF Recommendations 20, 21 and 22. which advise public administrations to use existing, established standards developed under open processes, rather then reinvent or duplicate methods or adopting proprietary methods, and advise agencies to conduct thoughtful and transparent design and purchasing processes, when selecting data standards.  That approach supports and gives life to Europe's "Strategic Vision for European Standards" (COM/2011/311) and Regulation (EU) No 1025/2012. 

OASIS benefits from significant and active participation from public administration representatives, from many jurisdictions, in its consortium technical committees, consistent with Recommendation 23, and we are grateful that this objective is explicitly supported by the EIF policy.  In a fully-realized Single Market, industrial, government, and academic stakeholders obviously appropriately may collaborate in such panels to achieve the best open solutions.

Footnote 15 on page 12 of the document associates the use of open source software components to implement Principle 10, "reusability".  The relationship between open-source and commercial software products in public administration settings and standards-setting is a matter of some focus for OASIS, and also has been a topic of conversation at the standardization MSP as well.  OASIS would like to share with ISA the observation that our own activities, as a standards-setting organization, most often include developers both from open source and commercial software sectors.  This encourages multiple tools in support of a standards project to "compete" on features, usability, and functionality.  For example, our widely-deployed OpenDocument Format standard for office documents is supported both by multiple, well-developed sets of open source tools, and many (perhaps most) commercial suites of office software as well.

OASIS is extremely grateful for, and actively facilitates, contributions of open source code that help power and define many of our standards projects, often in their developmental stages.  However, we also permit our standardization committees to select from among a variety of licensing and royalty-related options.  OASIS conducts by far the majority of its work on a royalty-free basis:  we note that this has not prevented commercial software developers from participating in most cases. 

We encourage future standardization policies to consider ground rules that permit all sectors of software development to participate in a meaningful way, subject to the differing needs that various agencies, jurisdictions and applications may have regarding availability, accessibility, and cost.  Most data standards are best supported by a healthy ecosystem of multiple independent interoperable implementations, not by designating any one as preferred or "reference" code.  That market-awareness is consistent with Regulation 1025/2012, and the intent described in the current Public Consultation (launched 23 September) to leverage existing innovative projects and methods to quickly build the Digital Single Market.  

The foregoing matters also have been related to the specific elements of the EIF in the attached table format, as requested.  The table is composed of the same issues addressed in this textual reply.

Respectfully, etc.

James Bryce Clark, General Counsel
OASIS: Advancing open standards for the information society

Attachment: EC_Workshop_with_Standardisation_Bodies_v1_FINAL.pdf
Description: Adobe PDF document

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