Years ago I read an interesting article about the encyclopedia entry for the keyword “Longitude”. According to the article, the entry merely said “See Latitude”. With that short, two-word sentence the encyclopedia author conflated these two concepts as mere orthogonal dimensions, lumped together, each as boring as the other. This ignored the fact that latitude is boring, easy, trivial, known to the ancients and as easy to calculate as measuring the altitude of Polaris. But longitude, there lies an epic adventure, something fiendishly difficult to calculate accurately, something that propelled a great seafaring nation to a search for accurate timepieces that would work at sea, just in order to more accurately calculate longitude. Books have been written about longitude, lives lost, fortunes made. But latitude — latitude is for children.
So when I hear people lump Fast Track and PAS process in JTC1 together, I roll my eyes and think… If only they knew how different they really are.
Let’s give it a try, starting with PAS.
PAS stands for “Publicly Available Specification” and the PAS process in JTC1 allows an existing standard from outside of JTC1 to be submitted, reviewed and approved in an accelerated review cycle. An organization that wishes to make a PAS submission (typically a standards consortium) must first seek recognition as a PAS Submitter. This requires that they submit to JTC1 for approval a list of standards they wish to submit, as well as documentation that explains their organizational qualifications. The long list of organizational acceptance criteria are outlined in JTC1 Directives, Annex M:
M7.3 Organisation Acceptance Criteria
M7.3.1 Co-operative Stance (M)
There should be evidence of a co-operative attitude toward open dialogue, and a stated objective of pursuing standardisation in the JTC 1 arena. The JTC 1 community will reciprocate in similar ways, and in addition, will recognise the organisation’s contribution to international standards.
It is JTC 1’s intention to avoid any divergence between the JTC 1 revision of a transposed PAS and a version published by the originator. Therefore, JTC 1 invites the submitter to work closely with JTC 1 in revising or amending a transposed PAS.
There should be acceptable proposals covering the following categories and topics.
M.126.96.36.199 Commitment to Working Agreement(s)
- What working agreements have been provided, how comprehensive are they?
- How manageable are the proposed working agreements (e.g. understandable, simple, direct, devoid of legalistic language except where necessary)?
- What is the attitude toward creating and using working agreements?
M.188.8.131.52 Ongoing Maintenance
- What is the willingness and resource availability to conduct ongoing maintenance, interpretation, and 5 year revision cycles following JTC 1 approval (see also M6.1.5)?
- What level of willingness and resources are available to facilitate specification progression during the transposition process (e.g. technical clarification and normal document editing)?
M.184.108.40.206 Changes during transposition
- What are the expectations of the proposer toward technical and editorial changes to the specification during the transposition process?
- How flexible is the proposing organisation toward using only portions of the proposed specification or adding supplemental material to it?
M.220.127.116.11 Future Plans
- What are the intentions of the proposing organisation toward future additions, extensions, deletions or modifications to the specification? Under what conditions? When? Rationale?
- What willingness exists to work with JTC 1 on future versions in order to avoid divergence? Note that the answer to this question is particularly relevant in cases where doubts may exist about the openness of the submitter organisation.
- What is the scope of the organisation activities relative to specifications similar to but beyond that being proposed?
M7.3.2 Characteristics of the Organisation (M)
The PAS should have originated in a stable body that uses reasonable processes for achieving broad consensus among many parties. The PAS owner should demonstrate the openness and non-discrimination of the process which is used to establish consensus, and it should declare any ongoing commercial interest in the specification either as an organisation in its own right or by supporting organisations such as revenue from sales or royalties.
M.18.104.22.168 Process and Consensus:
- What processes and procedures are used to achieve consensus, by small groups and by the organisation in its entirety?
- How easy or difficult is it for interested parties, e.g. business entities, individuals, or government representatives to participate?
- What criteria are used to determine “voting” rights in the process of achieving consensus?
M.22.214.171.124 Credibility and Longevity:
- What is the extent of and support from (technical commitment) active members of the organisation? b) How well is the organisation recognised by the interested/affected industry?
- How long has the organisation been functional (beyond the initial establishment period) and what are the future expectations for continued existence?
- What sort of legal business entity is the organisation operating under?
M7.3.3 Intellectual Property Rights: (M)
The organisation is requested to make known its position on the items listed below. In particular, there shall be a written statement of willingness of the organisation and its members, if applicable, to comply with the ISO/IEC patent policy in reference to the PAS under consideration.
Note: Each JTC 1 National Body should investigate and report the legal implications of this section.
- How willing are the organisation and its members to meet the ISO/IEC policy on these matters?
- What patent rights, covering any item of the proposal, is the PAS owner aware of?
- What copyrights have been granted relevant to the subject specification(s)?
- What copyrights, including those on implementable code in the specification, is the PAS originator willing to grant?
- What conditions, if any, apply (e.g. copyright statements, electronic labels, logos)?
M.126.96.36.199 Distribution Rights:
- What degree of flexibility exists relative to modifying distribution rights; before the transposition process is complete, after transposition completion?
- Is dual/multiple publication and/or distribution envisaged, and if so, by whom?
M.188.8.131.52 Trademark Rights:
- What trademarks apply to the subject specification?
- What are the conditions for use and are they to be transferred to ISO/IEC in part or in their entirety?
M.184.108.40.206 Original Contributions:
- What original contributions (outside the above IPR categories) (e.g. documents, plans, research papers, tests, proposals) need consideration in terms of ownership and recognition?
- What financial considerations are there?
- What legal considerations are there?
Once this documentation is provided, a three-month JTC1 ballot is held on the question of whether to approved the applicant as a Recognized PAS Submitter. If approved, this status last for 2 years, but may be renewed by reapplying with updated organizational documentation. Renewals must also be approved by a 3-month letter ballot.
Once an organization has Recognized PAS Submitter status, it may now propose a PAS submission. Such a submission must be within scope of the Submitter’s original application, and must be accompanied by an Explanatory Report that speaks to JTC1’s strategic interests in Interoperability, Cultural and Linguistic Adaptability, as well as the following document-related acceptance criteria:
M7.4 Document Related Criteria
Within its scope the specification shall completely describe the functionality (in terms of interfaces, protocols, formats, etc) necessary for an implementation of the PAS. If it is based on a product, it shall include all the functionality necessary to achieve the stated level of compatibility or interoperability in a product independent manner.
M.220.127.116.11 Completeness (M):
- How well are all interfaces specified?
- How easily can implementation take place without need of additional descriptions?
- What proof exists for successful implementations (e.g. availability of test results for media standards)?
- What means are used to provide definitive descriptions beyond straight text?
- What tables, figures, and reference materials are used to remove ambiguity?
- What contextual material is provided to educate the reader?
M.18.104.22.168 Testability (M)
The extent, use and availability of conformance/interoperability tests or means of implementation verification (e.g. availability of reference material for magnetic media) shall be described, as well as the provisions the specification has for testability.
The specification shall have had sufficient review over an extended time period to characterise it as being stable.
M.22.214.171.124 Stability (M):
- How long has the specification existed, unchanged, since some form of verification (e.g. prototype testing, paper analysis, full interoperability tests) has been achieved?
- To what extent and for how long have products been implemented using the specification?
- What mechanisms are in place to track versions, fixes, and addenda?
M.126.96.36.199 Availability (M):
- Where is the specification available (e.g. one source, multinational locations, what types of distributors)?
- How long has the specification been available?
- Has the distribution been widespread or restricted? (describe situation)
- What are the costs associated with specification availability?
M7.4.2 Consensus (M)
The accompanying report shall describe the extent of (inter)national consensus that the document has already achieved.
M.188.8.131.52 Development Consensus:
- Describe the process by which the specification was developed.
- Describe the process by which the specification was approved.
- What “levels” of approval have been obtained?
M.184.108.40.206 Response to User Requirements:
- How and when were user requirements considered and utilised?
- To what extent have users demonstrated satisfaction?
M.220.127.116.11 Market Acceptance:
- How widespread is the market acceptance today? Anticipated?
- What evidence is there of market acceptance in the literature?
- What is the extent and use of conformance tests or means of implementation verification?
- What provisions does the specification have for testability?
The specification should be aligned with existing JTC 1 standards or ongoing work and thus complement existing standards, architectures and style guides. Any conflicts with existing standards, architectures and style guides should be made clear and justified.
M.18.104.22.168 Relationship to Existing Standards:
- What international standards are closely related to the specification and how?
- To what international standards is the proposed specification a natural extension?
- How is the specification related to emerging and ongoing JTC 1 projects?
M.22.214.171.124 Adaptability and Migration:
- What adaptations (migrations) of either the specification or international standards would improve the relationship between the specification and international standards?
- How much flexibility do the proponents of the specification have?
- What are the longer-range plans for new/evolving specifications?
M.126.96.36.199 Substitution and Replacement:
- What needs exist, if any, to replace an existing international standard? Rationale?
- What is the need and feasibility of using only a portion of the specification as an international standard?
- What portions, if any, of the specification do not belong in an international standard (e.g. too implementation specific)?
M.188.8.131.52 Document Format and Style
- What plans, if any, exist to conform to JTC 1 document styles?
The Explanatory Report also sets the maintenance regime for the submission, if approved
The proposed standard, along with the Explanatory Report is then distributed to JTC1 NB’s for a 6-month ballot. Approval criteria is 2/3 approval of voting P-members, and no more than 25% disapproval in total. At the end of the ballot a Ballot Resolution Meeting may be held if needed.
So, that is PAS process, in brief. PAS process is how ODF was approved back in 2006, with OASIS as the Recognized PAS Submitter.
Fast Track process, is almost the same from the time the ballot is issued. The six-month period is split into a 30-day “contradiction period” and a 5-month ballot. (That is an odd difference, with no clear reason). But the voting criteria, the BRM process, etc., this is all the same between the two. What is different (and there are critical differences) is everything that happens before the ballot.
Who can submit a Fast Track? Any JTC1 P-member, or any Class A Liaison can propose a Fast Track.
We all know about P-members. They are NB’s, typically the highest standardization committee in any country. A P-member used to also mean that you had a broad interest in many or most JTC1 matters. But now it may mean merely that Microsoft asked you to join as a P-member.
Class A Liaison are “Organisations which make an effective contribution to and participate actively in the work of JTC 1 or its SCs for most of the questions dealt with by the committee”. Any organization can apply to be a Class A Liaison and be voted in via a letter ballot or at a meeting. There are no formal organization qualifications, no requirement to state an interest in eventually making Fast Tracks, or to answer any of the types of questions that PAS Submitters must answer.
Further, once approved as a Class A Liaison, the status lasts forever. There is no requirement to renew or reapply. In fact JTC1 Directives even lack a documented procedure for removing a Class A Liaison.
So what about the proposals for Fast Track submission. What is required of them? No Explanatory Report is required. No checklist of document-related criteria must be answered. JTC1 Directives say merely “The criteria for proposing an existing standard for the fast-track procedure is a matter for each proposer to decide.” That’s it. It is at the sole discretion of the Class A Liaison.
So you can see what great power Ecma has over JTC1 — they can submit any standard they want for Fast Track, and no one in JTC1 can stop them, or even remove their right to submit more Fast Tracks.
This may explain why Ecma is able to command such high membership fees. A full voting membership in OASIS, which would allow a company to help produce an OASIS Standard for later submission to JTC1 under the arduous PAS process, this costs $1,100 for a small company. To join the US NB and be able to lobby for a Fast Track submission from the US, this will cost you $9,500. But to join Ecma as a voting member (what they call an “Ordinary Member”) this will cost you 70,000 Swiss Francs, or $64,000. That is what no-questions-asked Fast Track service is worth. I think that, from Microsoft’s perspective, the extra $62,900 is money well spent. But what about from JTC1’s perspective? They don’t get this extra money. So what’s their excuse for having these permissive Fast Track procedures that give Ecma so much control?
In any case, that is why I roll my eyes when people lump PAS and Fast Track together, and say that they are essentially the same process. They clearly aren’t. PAS Submitters like OASIS are given intense scrutiny, and are required to document in great detail how their organization and their proposals meet JTC1 criteria. The scrutiny never ends, as a new Explanatory Report is required for every submission, and their status as Recognized PAS Submitter only lasts for a few years before requiring re-approval.
Fast Track submitters, as Class A Liaisons, on the other hand, are the monarchs of JTC1. They serve for life and are answerable to no one. They can submit a Fast Track on any subject they want, at any time. So a standards consortium like Ecma, with primary expertise in optical disk standards, but never having produced an XML standard before, can rubber stamp the world’s largest XML standard and submit it for Fast Track processing to JTC1. And no one can do a thing about it.
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