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Maintaining OpenXML if it becomes an ISO/IEC standard

My father was an inveterate reader of notice boards. He explained that all manner of interesting things were put on them for those who took the trouble to look. I should have paid more attention and spent more time looking at the JTC1 website, or more specifically the SC34 website.

SC34 is the JTC1 committee dealing with the fast-track proposal that the MS OpenXML standard for office documents should become an ISO/IEC standard. At the moment most attention is focussed on the letter ballot that closes on 2 September. I have explained in many previous articles, most recently here that about a hundred “National Bodies” (NBs) who are ISO members are eligible to vote by submitting a voting form “G18″. Submitting a form gives you a ticket to the Ballot Resolution Meeting (BRM) which is currently pencilled in for February 2008. Comments submitted with the voting forms are pooled. The BRM goes through the comments and sees whether a subset can be adopted for inclusion in the draft so that the amended draft will attract the requisite majority (3/4 of those voting and 2/3 of P-members voting).

So (except in rare circumstances, unlikely to apply here) the proportion of yes, no and abstains in the letter ballot is of no consequence. What matters is whether a subsequent vote at the BRM is able to muster he requisite majority for an amended draft. The conduct of the BRM will be substantially in the hands of the “Convenor” Alex Brown. If an amended draft is approved, then the “Project Editor” (who appears to be Rex Jaeschke of MS) has the job of producing the actual text of the amended draft in accordance with the BRM decisions. Presumably in practice he is overseen by the Convenor and SC34 secretariat. According to the SC34 website completion of the process is currently forecast for December 2008.

But what would happen then (if it was ultimately approved)? 13.13 of the JTC1 Directives provides that

If the proposed standard is accepted and published, its maintenance will be handled by JTC 1 and/or a JTC 1 designated maintenance group in accordance with the JTC 1 rules.

Now what do you think has happened? Well just go to the SC34 website and find document 885:

maintain1.jpg

maintain2.jpg

The full proposal is about 45 lines long, but the important part is those words with Ecma TC45 … carrying out the key duties. Anyone who thinks this might be an unwise procedure needs to make sure that their NB is appropriately briefed for the SC~34 Plenary meeting in December 2007 when this proposal is to be discusssed.

“Yes with comments”" and “abstain”

The noOOXML.org blog had an article on whether you can add comments when you vote Yes on the letter ballot. I found it interesting because it included a reference to the G18 DIS Letter Ballot form, which I had not previously looked at.

jtc1ballot.jpg

Two points arise. The first is that it turns out that a vote of “abstain”, as opposed to a failure to return a G18 form, does give a National Body (NB) a ticket to the Ballot Resolution Meeting (BRM). This has recently been clarified by ISO, according to Alex Brown (in Comment 2), who will be the convenor of the BRM. So my earlier guess on what the JTC1 Directives meant on that point (which I repeated here) was wrong.

The second point is whether this document supports the idea that a NB can vote “Yes with comments” rather than simply “Yes”. Unfortunately, it is as badly drafted as the rest of the JTC1 Directives and supports both interpretations. In the middle we have if a national body votes affirmatively, it shall not submit comments. That seems clear-cut. But then lower down we have a space to tick the line comments (editorial or other) appended, which apparently implies that a NB can append non-editorial comments.

So this really does not advance matters. In earlier posts, I discussed how the wording of the main part of the JTC1 Directives bore on this issue. Irrespective of whether there is a majority for or against approval in the letter ballot, there is a BRM. NBs who return a DIS Letter Ballot form (shown above) before the deadline get invited to the BRM. All “comments” are pooled and essentially form the agenda for the BRM. It is fairly clear that the procedure envisages that NBs voting Yes will continue to support the draft in the BRM. Those voting No, must give “technical reasons”, informally known as “comments” for their vote. The concept is that those who voted No will change their votes to Yes if enough of their “comments” are met by changes to the draft. So the BRM goes through the comments trying to see which are worth adopting. However, any NB at the BRM is free to vote any way it wants. If the BRM is able to get the requisite majority for an amended draft, then that is adopted. If not the draft fails completely.

The precise BRM procedure is likely to be largely determined by the “convenor”, who will be Alex Brown. So his views are clearly important. He gave them in comment 6 to Bob Sutor’s blog on 2 August. Like me, he thinks that a NB probably can submit “comments” with a Yes vote, but “The fact remains, though, that comments accompanying an approval vote are less likely to get addressed than comments accompanying a disapproval vote”.

Since comments are pooled, it only matters in the case of a comment which is not submitted by any NB voting No. But then, it is hard to be sure until it is too late whether a comment will fall into that category or not. Because one thing is completely clear - comments submitted after the 2 September 2007 deadline will be ignored.

Of course, MS wants people to vote “Yes with comments” rather than “No with comments” in the letter ballot, because they think that will tie the hands of the NB’s delegate to the BRM. A delegate from a NB which has voted Yes is likely to feel an obligation to vote for approval at the BRM irrespective of what changes are made or not made, whereas a delegate from a NB which has voted “No with comments” is likely to feel an obligation to refuse to vote Yes until the comments are adequately dealt with.

At least I assume they think that. It may be that MS just misunderstands the JTC1 procedure and thinks the draft will go through without a BRM.

USA National Body apparently deadlocked on OpenXML

Michael Zenke, a Slashdot editor, put up without comment a submission from realdodgeman, an anonymous but presumably American contributor, last Sunday, about the deliberations of INCITS on OpenXML. Noting that there were apparently insufficient votes for approval, he concluded that “This will mean a huge slowdown in the standardization to the OOXML format”.

realdodgeman was correct on the deadlock in the International Committee for Information Technology Standards (INCITS) executive commitee which voted 8-7 against approving OpenXML according to the official INCITS site. But the “International” in INCITS is misleading. It is not an international body, it is simply the “National Body” which represents the US at JTC1 which is currently conducting a letter ballot on OpenXML. The INCITS executive committee vote is simply the latest step in the attempts to decide which way the US will vote.

Although the US vote is obviously interesting, it is just one among many. Approval of OpenXML as an ISO/IEC standard requires a 75% majority of those members of ISO that cast a vote (that is a simplification - the full detail is here and in several other articles on this site around the same time.). Moreover, the current letter ballot is most unlikely to be the decisive vote. It is far more likely that there will be a “Ballot Resolution Meeting” which will probably meet several times next year before getting to a final ballot.

It seems quite possible that the US will end up abstaining, in which case it will have no voice in the way this issue is decided. But even if it does vote, its vote has just the same weight as that of the smallest voting country! In some ways that it clearly unreasonable, but that is the way many international bodies work.

Of course, in this case a US company, MS, is clearly having a substantial influence on the votes of many National Bodies, much more than it appears to have had on the US body.

The ISO/IEC process

Bob Sutor (IBM) blogged on 6 August 2007 that “I predict we will see will be widespread re-evaluation of national standards body membership and voting rules.” In particular, he thought, that the process should be more open. Commenting on this on 11 August 2007, Alex Brown blogged that “openness, like choice, is one of the most over-sold concepts of our age”.

The BSI (British Standards Institute) is the “National Body” which decides how the UK should vote on ISO/IEC standards and represents the UK at ISO/IEC and JTC1 meetings. The BSI process is open in that anyone who looks technical qualified can participate in the bottom committee (which does most of the detailed work), but it is otherwise opaque. The membership of the committees is confidential, and their proceedings are confidential. But Alex saw “absolutely no evidence” that the process had been abused, and implied that the BSI process was of high quality.

From what I saw of it (as a member of the bottom committee and an observer at some discussions of the advisory committee above), I agree with that judgment. The MS and IBM members both behaved courteously and reasonably and neither made any obvious attempt to pack the committee. The BSI rules require that it proceed by “consensus”. That is a somewhat ambiguous term and is not the same as “unanimity”. It requires those who are obviously in a small minority to back down and not press their views beyond a certain point. I certainly watched that happening on a number of issues.

But I still disagree fundamentally with Alex. It may be true that confidential proceedings in committees whose membership is not known can, on occasion, give excellent results. It is certainly true that such proceedings are easier for the participants, who are not exposed to lobbying or abuse. But standard-setting needs to be conducted in the open, just as courts need to conduct their business in the open. Exactly the same principles apply. I would favour opening all meetings to press and public and keeping reasonably full minutes which were published on the internet. Justice needs to be seen to be done.

Oddly enough, I suspect that Alex is not completely unsympathetic to this view. He was the convenor (a kind of chairman) of the bottom BSI committee, so was presumably responsible for the decision to display its technical work in a Wiki on the internet. Although the public could not see who was responsible for which entries, the Wiki did have the effect of placing the key technical work into the public domain. In practice, I think that will make it exceedingly difficult for the BSI to vote anything but “No with comments”. It would look ridiculous if it abstained or voted “yes”, or even voted No with only trivial comments, when everyone can see that its technical committee has come up with large numbers of significant comments.

However, we will have to wait and see!

Back to Basics - why OpenXML should not be an ISO/IEC standard

Since I began this blog in mid-June, less than two months ago, I have put up over 60 articles about OpenXML, going into considerable detail. So it is perhaps time to step back from the trees and look at the wood.

The purpose of a standard is to standardize - to establish a single way of doing something. This is generally of considerable benefit to users, because it allows them to use the products of any vendor. That is usually a prerequisite for competition. It can also benefit vendors, but not always. Indeed a dominant vendor often prefers a proprietary specification.

OpenXML is the latest MS file format for office documents. It has already been approved as a standard (Ecma 476) by the standards body Ecma International. “Office documents” is a well-defined area. It means documents that are intended to be printed, usually on regular office paper (A4 in Europe, Letter in the USA), and which are subject to editing. Once they have been finalized they can be “archived” in a different file format (usually pdf). Different standards are appropriate for archived documents, web documents and various more specialist categories.

Last year, ISO/IEC 26300 (popularly known as ODF or OpenDocument Format) was adopted as the ISO/IEC standard for office documents. ISO/IEC standards carry a particular prestige and uniqueness because ISO and IEC are intra-governmental bodies, so the standards are effectively government-endorsed standards. Not all important standards get this imprimatur. For example, in the internet software area most of the important standards are “W3C Recommendations”, and some ISO/IEC standards have flopped (failed to gain acceptance in the marketplace).

Attempts have been made over the last few months to argue that we need “competition in standards”. If you pause for thought, that is silly. Competition in standards is precisely the evil that standardization is designed to eliminate! Attempts have also been made to argue that OpenXML covers a different type of document from ODF. This argument is also totally bogus, see for example this article and many others on this site.

The first product using OpenXML, Office 2007, was only released this year, so it currently has only a modest market share. However, MS has over 95% of the market for office document software, so it is likely that OpenXML will become the overwhelmingly dominant format over the next few years.

95% market dominance is almost invariably an indication that competition is not working. Such extreme dominance is rarely sorted out by the market; it requires government action. In MS’s case this was recognized by the US government, which brought an anti-trust case. This established a consistent pattern of abuse by MS over a long period and also showed that MS had been able to “lock-in” customers by file formats and other devices. For reasons that have not yet been adequately explained, the incoming Bush administration decided to take no effective action against MS. A parallel case by the European Union has not yet been resolved.

In the meantime, the MS monopoly in office document software persists. A glance at the latest 10K shows that about a quarter of MS’s revenues come from such software and that the profit margins are extraordinary. An article on this site explains the peculiar characteristics of software that make this possible, and shows the serious scale of the problem.

Historically, MS has used proprietary “binary formats” for saving office documents. Apart from the anti-competitive effect, this has also meant that users have been forced to use MS software in order to access their own documents. This is clearly a highly unsatisfactory situation for governments and major businesses. This issue has been substantially ameliorated by the publication of Ecma 476 (the existing OpenXML standard). There is no doubt that the publication of this standard was a major benefit to users. Not because it is a standard, but because the specification has been put into the public domain and because MS’s freedom to change it arbitrarily has been reduced (although not by much, given the way Ecma seems to work).

It is certainly an unsatisfactory situation when the dominant vendor does not support the ISO/IEC standard. But adopting a second standard is not the answer. The answer is obvious: MS should adopt the existing ISO/IEC standard. It would also be highly desirable for governments to mandate the existing ISO/IEC standard for their own documents, in order to put pressure on MS to adopt it.

Of course, this prospect is highly unappealing to MS. It will be forced to incur some significant cost and will be opening the door to its competitors. I find it hard to be sympathetic. It chose to boycott the development of the ODF standard. It should suffer the consequences of its misjudgment.