I've noted before that writing to MPs/MEPs seems to be remarkably effective in terms of generating a response. The naïve among us might even assume that democracy is almost functional in these cases. I'm not sure whether that applies to something as large and inscrutable as the European Commission, but it's certainly worth a try, especially in the context of open source and open standards.
Here's an opportunity to put that to the test. Version 2 of the grandly-named European Interoperability Framework (EIF) is currently being put together; there is a draft, and comments are invited:
Everyone who sees interoperability as an effective means to provide better pan-European eGovernment services is invited to read the draft document and to provide feedback on its content by sending comments to [email protected] by the 22nd of September 2008 at the latest.
“Interoperability” has become a hot issue in the open source world recently, with Microsoft trying to morph the term into a kind of watered-down version of openness, and everyone else – including, significantly, the EU – pushing back, and trying to prise information from the company that would allow true interoperability with its products.
This makes the details of the EIF extremely important: they will determine the landscape for software procurement by EU governments over the next few years. In particular, they could play a key role in breaking the stranglehold of Microsoft applications and their file formats on EU computer systems.
For this reason, I urge you to read the document – it's quite long, but surprisingly well written – and offer your views. I've attached below my own letter; as usual, feel free to draw on it, but please don't copy anything verbatim: any suggestion that some mindless, robotic campaign is being directed at the EU will actually weaken, rather than, strengthen the arguments. As noted above, the deadline is September 22, and the contact address is [email protected]
First, I would like to congratulate the authors on an extremely thorough document that addresses all of the main issues concerned with the important area of interoperability. What follows are a few incidental comments rather than any fundamental criticism of the points made in the draft.
Interoperability is about creating a level playing field, something currently not present in the European computer market. As the draft rightly notes, benefits that accrue from such a level playing field include (page 11):
• Avoidance of vendor lock-in results in lower costs, to administrations to develop services, plus more freedom of choice is available to citizens and businesses as a result;
• Increasing the number of suppliers of standards-based products should lead to increased competition;
• Increased competition deriving from the lowering or elimination of barriers (resulting from the migration towards open standards)
A critical issue that needs to be addressed in creating a level playing-field is ensuring that open source solutions can compete on equal terms, whoever they are created by. This, in its turn, means that only truly open standards should be permitted. Unfortunately, this has become a very pertinent issue as a result of the deeply flawed process adopted by the ISO in considering Microsoft's OOXML as an international standard. Despite documented irregularities at the national level, and appeals by countries representing a significant proportion of the world's population who were concerned by those irregularities, the ISO has chosen not to strengthen itself and its independent role by addressing these problems, and has emerged considerably diminished in the eyes of many in the computing community as a result. As the draft rightly notes:
Practices distorting the definition of open standards or technical specifications should be addressed by protecting the integrity of the standardisation process.
Against this background, the EIF could usefully add some guidelines as to what should be done in cases where the “integrity of the standardisation process” is already compromised – for example, in terms of rejecting any nominally open standards that result.
A related issue concerns patents. The draft states:
The intellectual property - i.e. patents possibly present - of (parts of) the open standard is made irrevocably available on a royalty free basis.
Leaving aside the fact that software patents “as such” are not, in any case, admissible in Europe, this is a fundamental issue. Standards that depend on patents are not compatible with open source unless royalty-free licences are granted irrevocably. I therefore urge the European Commission not to compromise on this point, since doing so would vitiate the creation of a playing-field that is level for all – and not just those with deep pockets - and nullify the entire point of the interoperability framework. There is no halfway house here.
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