Preparing a Response to the UK Government’s Open Standards: Open Opportunities Document

 

The UK Government’s Open Standards Consultation

The UK Government is currently seeking comments for its Open Standards Consultation for the Open Standards: Open Opportunities – Flexibility and efficiency in Government IT document (a 30 page document available in PDF format). I am currently formulating my responses to the consultation process. In light of the interests in open standards by many developers, managers and policy makers in the higher and further education sector I would encourage participation form those with interests in this area – it should be noted, however, that the consultation closes on 1 May!

Update 27 June 2012: The deadline has now been extended to Monday, 4^th June 2012.

The Open Standards Survey 2011

As described in two posts entitled UK Government Survey on Open Standards: But What is an ‘Open Standard’? and “UK Government Will Impose Compulsory Open Standards” published a year ago I responded to the initial survey and gave my thoughts on the definitions of an open standard. I also commented on the flaws in the survey process which made it difficult to provide meaningful feedback.

My response was one of 970 received – and it was interesting to read in the Summary of lessons learned from the UK Government Open Standards Survey, 2011 (pdf, 246kb) that the majority came from the private sector. Looking at the pie chart given in the report I would estimate that about 200-300 responses came from the public sector (excluding central government). How many of these are from the UK higher and further education sector I do not know.

It should also be noted that although “the policy resulting from this consultation will apply to all central government departments, their agencies, non-departmental public bodies (NDPBs) and any other bodies for which they are responsible” the document goes on to add that “Local government and wider public sector bodies will be encouraged to adopt the policy to deliver wider interoperability benefits“. There is therefore an opportunity to influence government policy in an area which make affect IT development policies in the future.

Reflections on 20 years Involvement in Open Standards in UK Higher Education

Although I had serious reservations about last year’s survey in many respects I feel that the Open Standards: Open Opportunities – Flexibility and Efficiency in Government IT consultation document has its merits.

The feedback I gave in last year’s survey were based on work related to policies on use of open standards in higher education which I have been involved with since the launch of the eLib national digital library programme back in the mid 1990s. Back then those of us who were involved in contributing to the eLib Programme Technical Standards document had, in retrospect, a very naive view on open standards, with the document suggesting that standards such as VRML and whois++ could have a role to play for eLib projects. Some projects may have used these standards (I know that for a period the who++ was felt to be important for the eLib Subject Based Information Gateways) but in retrospect we were over-enthusiastic in encouragement take-up of what at the time seemed to be potentially significant standards.

The dangers of promoting (or, worse, mandating) use of emerging open standards which are being actively promoted by their supporters (and by standards bodies themselves) became apparent when we realised that W3C standards such as SMIL and SVG were not significantly challenging proprietary solutions such as Flash. In addition in 2005 a panel session entitled Web Services Considered Harmful argued that a series of overly complex open standards (several thousand pages when printed out!) was proving costly to implement and that use of ‘grassroots’ approaches, including RSS and REST, would provide more cost-effective approaches to development.

In the UK higher education sector we are aware of the dangers of mandating inappropriate open standards, with universities being mandated to support OSI networking protocols, with Coloured Book software providing a transition to this environment. Then the Internet came along and universities were initially permitted to access Internet services by a TCP/IP tunnel across JANET before the clear benefits provided by the Internet eventually became apparent to policy-makers and the sector made native use of TCP/IP.

Our understanding of the benefits which can be gained by use of open standards together with the risks of a naive and uncritical acceptance of the realities of use of open standards led to a series of papers which sought solutions to this minefield being written by myself, my colleague Marieke Guy and Rosemary Russell, my former colleague Pete Johnston, Paul Hollins and Scott Wilson (JISC CETIS), Alastair Dunning (at the time of AHDS), Sebastian Rahtz and Randy Metcalfe (then of JISC OSS Watch) and Lawrie Phipps (then of JISC TechDis):

• Openness in Higher Education: Open Source, Open Standards, Open Access, elPub 2007.
• Addressing The Limitations Of Open Standards, MW 2007.
• A Contextual Framework For Standards, WWW 2006.
• A Standards Framework For Digital Library Programmes, ichim05, 2005.
• Ideology Or Pragmatism? Open Standards And Cultural Heritage Web Sites, ichim03, 2003.

In addition to these papers, a position paper on “An Opportunities and Risks Framework For Standards” was presented at the “Future of Interoperability Standards Meeting 2010” organised by CETIS in February 2010. The paper described how the experiences of the past led to the need for a risk management approach to use of open standards, especially emerging open standards which may not yet have achieved critical mass.

Open Standards: Open Opportunities – Flexibility and Efficiency in Government IT

In light of this background, what feedback am I planning to give to the report? I have highlighted a number of comments in the report which I intend to comment on.

Report	Comment
Information technology across the government estate is expensive. (p. 4)	The opening foreword highlights that the aims of the policy are cost-savings. There will be a need to ensure that the policy supports this key goal.
The Government ICT Strategy … has already committed the Government to creating a common and secure IT infrastructure based on a suite of compulsory open standards, adopting appropriate open standards wherever possible. [my emphasis] p. 5).	The challenge will be in identifying what is compulsory and what the criteria are for defining “wherever possible”. The compulsory aspects could mandate specific technical standards or could mandate specific processes (e.g. an open summary of the decision-making processes).
The mandation of specific open standards will • make IT solutions fully interoperable to allow for reuse, sharing and scalability across organisational boundaries and delivery chains; • help the Government to avoid lengthy vendor lock-in, allowing transfer of services or suppliers without excessive transition costs, loss of data or functionality. (p. 8)	If the main goal of the open standards policies is to achieve cost savings, should this be mentioned here?
The European Commission’s EIF version 2.0 does not provide a definition of open standard, but instead describes ‘openness’ … (p. 11)	This approach, which seeks to characterise open approaches, provides the flexibility to allow use of cost effective standards such as RSS (which have not been ratified by an open standards body) as well as use of design approaches (such as RESTful design) rather than over-complex open standards (such as the WS- series).
For the purpose of UK Government software interoperability, data and document formats, the definition of open standards is those standards which fulfil the following criteria: … (p. 12)	It is unclear whether there should be an ‘and’ or an ‘or’ linking the five criteria.
When specifying IT requirements for software interoperability, data and document formats, government departments should request that open standards adhering to the UK Government definition are adopted, unless there are clear business reasons why this is inappropriate, in order to … (p. 13)	This process-driven approach relates closely to the approaches developed in the UK HE sector and described in a paper on “Openness in Higher Education: Open Source, Open Standards, Open Access“.
Standards for software interoperability, data and document formats that do not comply with the UK Government definition of an open standard may be considered for use in government IT procurement specifications if … (p. 13)	This flexibility is to be welcomed in light of the complexities related to open standards. However there will be a need to ensure that such flexibility does not allow inappropriate proprietary solutions to continue to be used.
Any standard specified that is not an open standard must be selected as a result of a pragmatic and informed decision, taking the consequences into account. The reasons should be fully documented and published, in line with the Government’s transparency agenda. (p.13)	This clause is welcomed.

I welcome your comments on my views on the consultation document. More importantly, however, I’d encourage you to give your views on the consultation web site – as that is the place where your views can influence government policy decisions. Note that if you would like to see responses which have already been submitted, I suggest you visit Jenni Tennison’s post on UK Open Standards Consultation.

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