Rob

DIS 29500, Office Open XML, was submitted for Fast Track review by Ecma as 6,045 page specification. (After the BRM, it is now longer, maybe 7,500 pages or so. We don’t know for sure, since the post-BRM text is not yet available for inspection.) Based on the original 6,045 page length, a 5-month review by JTC1 NB’s lead to 48 defect reports by NB’s, reporting a total of 3,522 defects. Ecma responded to these defect reports with 1,027 proposals, which the recent BRM, mainly through the actions of one big overnight ballot, approved.

So what was the initial quality of OOXML, coming into JTC1? One measure is the defect density, which we can say is at least one defect for every 6045/1027 = 5.8 pages. I say “at least” because this is the lower bounds. If we believed that the 5-month review represented a complete review of the text of DIS 29500, by those with relevant subject matter expertise, then we would have some confidence that all, or at least most, defects were detected, reported and repaired. But I don’t know anyone who really thinks the 5-month review was sufficient for a technical review of 6,045 pages. Further, we know that Microsoft worked actively to suppress the reporting of defects by NB’s. So the actual defect density is potentially quite a bit higher than the reported defect density.

But how much higher? This is the important question. It doesn’t matter how many defects were fixed. What matters is how many remain.

There are several approaches to answering this question. One approach is to look at defect “find rates”, the number of defects found per unit of time spent reviewing, and fit that to a model, typical an S-curve (sigmoid) and use that model to predict the number of defects remaining. However, we have no time/effort data for the DIS 29500 review, so we don’t have enough data to create that model. Another approach is to randomly sample the post-BRM text and statistically estimate the defect density by this sample.

Are there any other good approaches?

Here is the plan. I will use the second approach. Since I do not actually have the post-BRM text, I need to make some adjustments. I’ll start with the original text, in particular Part 4, the XML reference section, at 5,220 pages, where the meat of the standard is. I’ll then create a spreadsheet and generate 200 random page numbers between 1 and 5,220. For each random page I will review the clause associated with that page and note the technical and editorial errors I find. I will then check these errors to see if any of them were addressed by BRM resolutions.

Based on the above, I will be able to estimate two numbers:

• The defect density of the text, both pre and post BRM
• The fraction of defects which were detected by the Fast Track review.

So if I find N defects, and 0.9N of those issues were already found during the Fast Track review and were addressed by the BRM, then we can say that the Fast Track procedure was 90% effective in finding and removing errors. Some practitioners would call that the defect removal “yield” of the process. But if we find that only 0.1N of the errors were reported and addressed by the BRM, then we’ll have a different opinion on the sufficiency of the Fast Track review.

Clear enough? Microsoft is claiming something like 99% of all issues were resolved at the BRM. So let’s see if we get anything close.

I’m not done with this study yet. I’m finding so many defects that recording them is taking more time than finding them. But since this is topical, I will report what I have found so far, based on the first 25 random pages, or 1/8th completion of my target 200. I’ve found 64 technical flaws. None of the 64 flaws were addressed by the BRM. Among the defects are some rather serious ones such as:

• storage of plain text passwords in database connection strings
• Undefined mappings between CSS and DrawingML
• Errors in XML Schema definitions
• Dependencies of proprietary Microsoft Internet Explorer features
• Spreadsheet functions that break with non-Latin characters
• Dependencies on Microsoft OLE method calls
• Numerous undefined terms and features

As I said, this study is still underway. I’ll list the defects I’ve found so far, and add to it as I complete the task over the next few days.

1. Page 692, Section 2.7.3.13 — no errors found
2. Page 1457, Section 2.15.3.45 — This is a compatibility setting which creates needless complexity for implementers who now must deal with two different ways of handling a page break, one in which a page break ends the current paragraph, and another where it does not. This is not a general need and expresses only a single vendor’s legacy setting.
3. Page 490, Section 2.4.72 — This defines the ST_TblWidth type, used to express the width of a table column, cell spacing, margins, etc. The allowed values of this type express the measurement units to be used: Auto, Twentieths of a point, Nil (no width), Fiftieths of a percent. I find these choices to be capricious and not based on any sound engineering principle. It also mixes units with width values (Nil) and modes (auto). This should be changed to allow measurements in natural units, such as allowed in XSL-FO or CSS2, such as mm, inches, points, pica. Also, do not mix units, values and modes in the same attribute. Nil is best represented by the value 0 and Auto should be its own Boolean attribute.
4. Page 328, Section 2.4.17 — The frame attribute description says it “Specifies whether the specified border should be modified to create a frame effect by reversing the border’s appearance from the edge nearest the text to the edge furthest from the text.” This is not clear. What does it mean to reverse a border’s appearance? Are we doing color inversions? Flipping along the Y-axis? What exactly? Also a typographical error: “For the right and top borders, this is accomplished by moving the order down and to the right of its original location.” Should be “moving the border down…” Also, it is not stated how far the border should be moved.
5. Page 1073, Section 2.14.8 — This feature is described as: “This element specifies the connection string used to reconnect to an external data source. The string within this element’s val attribute shall contain the connection string that the hosting application shall pass to a external data source access application to enable the WordprocessingML document to be reconnected to the specified external data source.” Since connection to external data typically requires a user ID and a password, the lack of any security mechanism on this feature is alarming. The example given in the text itself hardcodes a plain-text password in it the connection string.
6. Page 4387, Section 6.1.2.3 — For the “class” attribute it says “Specifies a reference to the definition of a CSS style.” The example implies that some sort of mapping will occur between CSS attributes and DrawingML. But no such mapping is defined in OOXML. The “doubleclicknotify” attribute implies some sort of event model that us undefined in OOXML. How do you send a message for doubleclicknotify? Why do we describe organization chart layouts here when it is not applicable to a bezier curve? What happens if this shape is declared to be a horizontal rule or bullet or ole object? The text allows you label it as one of these, but assigns no meaning or behavior to this. Why do we have an spid as well as an id attribute? The “target” attribute refers to Microsoft-specific I.E. features such as “_media”. Although the text says that control points have default values, the schema fragment does not show this.
7. Page 3164, Section 4.6.88 — This and the following two elements are all called “To” but this seems to be a naming error. 4.6.89 is essentially undefined. What does “The element specifies the certain attribute of a time node after an animation effect” mean? It doesn’t seem to really signify anything. Ditto for 4.6.90.
8. Page 5098, Section 7.1.2.124 — The example does not illustrate what the text claims it does. The example doesn’t even use the element defined by this clause.
9. Page 4492, Section 6.1.2.11 — The “althref” attribute is described as “Defines an alternate reference for an image in Macintosh PICT format”. Why is this necessary for only Mac PICT files? Why would “bilevel” necessarily lead to 8 colors? We’re well beyond 8-bit color these days. “blacklevel” attribute is defined as “Specifies the image brightness. Default is 0.” What is the scale here? This needs to be defined. Is it 0-1.0, 0-255 or what? And what is “image brightness” in terms of the art? Is this luminosity? Opacity? Is this setting the level of the black point? For “cropleft”, etc. — what units are allowed? (implies %) How does “detectmouseclick” work when no event model is defined? “emboss effect” is not defined. “gain” has the same problem as “blacklevel” — no scale is defined. This element has two different id attributes in two different namespaces, with two different types. “movie” attribute is described as “Specifies a pointer to a movie image. This is a data block that contains a pointer to a pointer to movie data”. Excuse me? “A pointer to a pointer to movie data”? This is useless. The “recolortarget” example appears to contradict the description. It shows shows blue recolored to red, not black. The “src” attribute is said to be a URL, yet is typed to xsd:string. This should be xsd:anyURI.
10. Page 1431, Section 2.15.3.30 — no errors noted
11. Page 3405, Section 5.1.5.2.7 — The conflict resolution algorithm should be normative, not merely in a note.
12. Page 875, Section 2.11.21 — Instead of saying that the footnote “pos” element should be ignored if present at the section level, the schema should be defined so as to not allow it at the section level. In other words, this should be expressed as a syntax constraint.
13. Page 1955, Section 3.3.1.20 — This facility for adding “arbitrary” binary data to spreadsheets is said to be for “legacy third-party document components”. No documentation or mapping for such legacy components has been provided, so interoperability with this legacy data cannot be achieved. Why isn’t this expressed using the extension mechanisms of Part 5 of the DIS?
14. Page 4526, Section 6.1.2.13 — The “allowoverlap” attribute is not sufficiently defined. In particular, what determines whether the object shifts to right or left? ST_BWMode is not adequately defined. For example, one option is “Use light shades of gray only”. How light? And what is the difference between “hide” and “undrawn”? Also, concept of “wrapping polygon” is not sufficiently defined. For example, what is the wrapping polygon for an oval? The purpose of “dgmlayoutmru” is obscure. Wouldn’t the most-recently-used layout option be the one which is actually in use, “dgmlayout”? The “dgmnodekind” attribute is undefined, said to be “application-specific”. Is interoperabilty not allowed? The text seems to imply that applications must use application-specific values. The “href” attribute is give a string schema type. Shouldn’t this be xsd:anyURI. The “id” attribute is said to be a “unique identifier”. Unique in what domain? Among shapes of this type? Among all shapes? All shapes on this page? Among all ID’s in the document? The “preferrelative” attribute is not sufficiently defined. Where is the original size stored? After what reformatting? This appears to be a specification for runtime behavior, not a storage artifact. But it is not clear what is required. For the “regroupid”, where is the list of these possible id’s? The Hyperlink targets _media and _search are Internet Explorer proprietary features.
15. Page 1193, Section 2.15.1.39 — no errors noted
16. Page 1459, Section 2.15.3.46 — no errors noted
17. Page 2671, Section 3.17.7.150 — no errors noted
18. Page 2347, Section 3.10.1.69 — An “AutoShow” filter is not defined in this standard, though it is called for in several places of this section. “Average” aggregation function is not defined. In fact, none of these aggregation functions are defined. Although some have common mathematical definitions, in a spreadsheet context it is critical to make an explicit statement on treatment of strings, blanks, empty cells, etc. For dataSourceSort, what type of sort is required? Lexical or locale-sensitive? This element seems to mix field-specific settings, like dragToCol with pivotTable-wide settings like hiddenLevel. This will result in large data redundancy as settings like hiddenLevel are stored multiple times, once for each pivotField. “Inclusive Mode” is not defined. “Measure based filter” is not defined. “AutoSort” mode is not defined. The resolution of pivot table versus cell styles is ambiguous. “If the two formats differ, the cell-level formatting takes precedence.” Is this negotiation done at the level of the entire text style? Style ID? Or at the attribute level? “Outline form” is not defined. “server-based page field” is not defined. (what is a page field?) “member caption” is undefined.
19. Page 2885, Section 3.18.51 — The values of the given type (ST_OleUpdate) are explicitly tied to the Microsoft Windows OLE2 technology via the two method calls IOleObject::Update or IOleLink::Update
20. Page 3951, Section 5.5.3.4 — The base values “margin” and “edge” are ambiguous. Is it specifying positioning from the left or right page edge?
21. Page 2710, Section 3.17.7.200 — The description of “lookup-vector” is insufficient. It seems to be saying that the range should be sorted. Is this really correct? Spreadsheet functions typically do not have side effects. Also, the sorting procedure is explicitly defined only defined for the Latin alphabet. What about the rest of allowed Unicode characters, including the C0 control characters which are allowed in SpreadsheetML cell contents? Where are they sorted?
22. Page 934, Section 2.13.5.5 — The “id” attribute is required to be unique, but it is not specified over what domain it must be unique.
23. Page 607, Section 2.6.2 — What does “reversing the borders’s appearance mean”? How much offset is required for a shadow?
24. Page 201, Section 2.3.2.19 — This feature allows the suppressing of both spell and grammar checking for a text run. These should be two different settings, one for spelling and one for grammar proofing. There are many cases where it is important to check one, but not the other, just as in content comprised of sentence fragments, which are not grammatically complete, but where correct spelling is desired.
25. Page 1240, Section 2.15.1.74 — This setting specifies that the document should be saved into an undefined invalid XML format. But it is not stated how an XSLT transfor can be applied to an OOXML document, since OOXML is a Zip file containing many XML documents. So what exactly is the specified XSLT applied to?

That’s as far as I’ve gone. But this doesn’t look good, does it? Not only am I finding numerous errors, these errors appear to be new ones, ones not detected by the NB 5-month review, and as such were not addressed in Geneva. Since I have not come across any error that actually was fixed at the BRM, the current estimate of the defect removal effectiveness of the Fast Track process is < 1/64 or 1.5%. That is the upper bounds. (Confidence interval? I’ll need to check on this, but I’m thinking this would be based on standard error of a proportion, where SE=sqrt((p*(1-p))/N)), making our confidence interval 1.5% ± 3%) Of course, this value will need to be adjusted as my study continues. However, it is starting to look like the Fast Track review was very shallow and that detected only a small percentage of the errors in the DIS.

[20 March Update]

As one commenter noted, the page numbers I’m using above are PDF page numbers, not the page numbers on bottom of each page. If I used the printed pages then I would need to deal with all the Roman numeral front matter pages as an exception. Simpler to just use the one large domain of PDF page numbers.

PDF Page Number = Printed Page Number + 7

I will continue to report new defects, according to the original random number list I generated. I’ll update the statistics every 25.

Here’s some more for today:

26. Page 4192, Section 5.8.2.20 — “fPublished” attribute is defined as “Specifies whether the shape shall be published with the worksheet when sent to the spreadsheet server. This is for use when interfacing with a document server.” What worksheet? This section is in the DrawingML reference material. Charts could appear in presentations as well. This should not be limited to worksheets. Also what is a “spreadsheet server”? No such technology has been defined in this standard. Also no protocol has been defined for publishing to a spreadsheet server. Is this some proprietary hook for SharePoint? The “macro” attribute allows the storage of application-defined scripts. We are told that the macro “should be ignored if not understood.” However there is no mechanism for determining what language the script is in. How do we know if we understand the macro? Content sniffing? Attempt to execute it and see if we get a runtime error? But by that time, once we find out that we do not understand it, it is too late to ignore the macro. We may have already triggered runtime side effects. What we really need here is some way to declare what scripting language is being used, via a namespace or an additional attribute like “lang”.
27. Page 3526, Section 5.1.5.4.21 — The “algn” attribute specifies the text alignment. Allowed values include left, right, center, justified, etc. However, what is lacking is “start” and “end” alignment, which are sensitive to writing direction and are part of internationalization bets practices, for example, XSL-FO. When translating a document between RTL and LTR systems, the approach used by OOXML will harder to deal with and be more expensive to translate, since the translator will need to manually play with styles on not just perform an semi-automated translation.

[End Update]

I’ll continue to review the remaining 173 pages of my random sample and update the numbers and the defect list as I go. If you want to play along at home, the upcoming random page numbers will be:

• 1039
• 4933
• 3334
• 1993
• 1632
• 4787
• 460
• 481
• 4497
• 310
• 282
• 2383
• 1793
• 2451
• 3310
• 3716
• 1261
• 1077
• 2219
• 4236
• 285
• 3090
• 737
• 2370
• 741
• 164
• 5044
• 364
• 2272
• 1377
• 4512
• 1410
• 964
• 5079
• 5030
• 4110
• 3620
• 3588
• 2301
• 3222
• 4485
• 5082
• 193
• 3632
• 985
• 1593
• 5155
• 1054
• 3371
• 3717
• 5015
• 1071
• 2965
• 2294
• 1809
• 161
• 4922
• 5219
• 1719
• 1040
• 4259
• 3134
• 1195
• 4232
• 4444
• 3931
• 2302
• 2788
• 3584
• 8
• 5092
• 2580
• 1080
• 1239
• 1415
• 1170
• 1501
• 151
• 148
• 4754
• 1350
• 3714
• 1895
• 3926
• 4833
• 2886
• 2983
• 1439
• 3622
• 4960
• 2000
• 2555
• 671
• 2388
• 352
• 222
• 1630
• 3033
• 4994
• 3346
• 531
• 2393
• 482
• 207
• 2252
• 4074
• 3302
• 2459
• 751
• 1891
• 1635
• 3120
• 2226
• 1119
• 810
• 1728
• 837
• 4570
• 4474
• 1072
• 3901
• 300
• 4895
• 1764
• 2332
• 619
• 4392
• 2112
• 1653
• 4339
• 2384
• 4566
• 4085
• 1171
• 2238
• 5144
• 1399
• 4157
• 1352
• 27
• 4118
• 4167
• 5046
• 4460
• 4053
• 1258
• 4252
• 922
• 3748
• 1742
• 458
• 4448
• 963
• 2227
• 1404
• 593
• 4140
• 1739
• 1102
• 1611
• 3016
• 2646
• 3083
• 5105
• 747
• 1142
• 2596
• 845
• 626
• 4047
• 1415
• 5143
• 3997

I sometimes hear it said that formats like OOXML, or ODF for that matter, are simply XML serializations of a particular application’s native data representation. This is said, seemingly, in an attempt to justify quirky or outright infelicitous representations. “We had no choice. Office 95 represents line widths in units of 1/5th of a barleycorn, so OOXML must as well”. This technological determinism indicates poor engineering judgment, laziness, or both.

An easy counter-example is HTML. Does HTML reflect the internals of NCSA Mosaic? Does it represent the internals of Netscape Navigator? Firefox? Opera? Safari? Are any faults in HTML properly justified by what a single browser does internally? Applications should follow standards, not the other way around.

The question we should be asking is not whether a standard is similar to an application’s internal representation. That in itself is not necessarily a fault. We need to go a step further, and ask if this encoding represents reasonable engineering decisions, not just for that one application, but for general use? Or in ISO terms, does it represent the “consolidated results of science, technology and experience”? If it is a good, reasonable engineering choice with general applicability, and the original application already found that solution, then this is a good thing. We should be encouraging standards to encode the best practices of industry.

Take colors for example. There are only so many ways one can represent colors in markup. You can have an RGB value encoded as triplets where red= (255,0,0). Or you can have a hexadecimal integer encoded as RRGGBB, where red=FF0000. You can do it W3C style, like CSS or XSL-FO with a hash mark in front, like #FF0000″. There are variations on this, adding an alpha channel, using a different color model, etc. These are all reasonable engineering choices, and no one would fault a standard for choosing any one of them, even if the choice happens to match what a particular application does. They are all reasonable choices.

The final arbiter is engineering judgment. Making a capricious choice, merely because a particular application made that same choice, in spite of contrary engineering judgment, this would be a bad thing.

With this in mind, let’s take a look at how OOXML and ODF represent a staple of document formats: text color and alignment. I created six documents: word processor, spreadsheet and presentation graphics, in OOXML and ODF formats. In each case I entered one simple string “This is red text”. In each case I made the word “red” red, and right aligned the entire string. The following table shows the representation of this formatting instruction in OOXML and ODF, for each of the three application types:

Format	Text Color	Text Alignment
OOXML Text	<w:color w:val=”FF0000″/>	<w:jc w:val=”right”/>
OOXML Sheet	<color rgb=”FFFF0000″/>	<alignment horizontal=”right”/>
OOXML Presentation	<a:srgbClr val=”FF0000″/>	<a:pPr algn=”r”/>
ODF Text	<style:text-properties fo:color=”#FF0000″/>	<style:paragraph-properties fo:text-align=”end” />
ODF Sheet	<style:text-properties fo:color=”#FF0000″/>	<style:paragraph-properties fo:text-align=”end”/>
ODF Presentation	<style:text-properties fo:color=”#FF0000″/>	<style:paragraph-properties fo:text-align=”end”/>

The results speak for themselves.

What is the engineering justification for this horror? I have no doubt that this accurately reflects the internals of Microsoft Office, and shows how these three applications have been developed by three different, isolated teams. But is this a suitable foundation for an International Standard? Does this represent a reasonable engineering judgment? ODF uses the W3C’s XSL-FO vocabulary for text styling, and uses this vocabulary consistently. OOXML’s representation, on the other hand, appear incompatible with any deliberate design methodology.

I fear that before we can tackle harmonization of ODF and OOXML, we will first need to harmonize OOXML with itself!

Here begins the lesson on Embrace, Extend and Extinguish (EEE). Classically, this technique is used to perpetuate vendor lock-in by introducing small incompatibilities into a standard interface, in order to prevent effective interoperability, or (shudder) even substitutability of competing products based on that interface. This EEE strategy has worked well so far for Microsoft, with the web browser, with Java, with Kerberos, etc. It is interesting to note that this technique can work equally well with Microsoft’s own standards, like OOXML.

An easy way to find these extension points is to search the OOXML specification for “application-defined” or “implementation-defined”. You will find dozens of them, such as:

1. In general, scripting
2. In general, macros
3. In general, DRM
4. Part 1 — “Application-Defined File Properties Part” which is totally undefined, but is referenced 13 times for specific fields in Part 4.
5. Section 2.16.4.1 — implementation-defined date/time formatting
6. Section 2.16.5.34 — implementation-defined document filters
7. Section 3.17.2.6 — implementation-defined string–>number conversions in a spreadsheet
8. Section 2.8.2.2 — character sets supported by a font
9. Section 2.9.6 — the interpretation of the mysterious hex “template code” in numbered list overrides — “The method by which this value is interpreted shall be application-defined.”
10. Section 2.14.27 — application-defined storage of exclusion data for a mail merge
11. Section 2.15.1.28 — application-defined cryptographic hash algorithms
12. 2.15.1.76 — “Specifies a string identifier which may be used to locate the XSL transform to be applied. The semantics of this attribute are not defined by this Office Open XML Standard – applications may use this information in any application-defined manner to resolve the location of the XSL transform to apply.”
13. Section 5.6.2.12 — application-defined macro string reference for connection shape
14. Section 5.6.2.15 — application-defined macro string reference for graphic frame
15. Section 5.6.2.24 — application-defined macro string reference for a picture object
16. Section 5.6.2.28 — application-defined macro string reference for a shape
17. Section 5.8.2.9 — application-defined macro string reference for a connection shape
18. Section 5.8.2.12 — application-defined macro string reference for a graphic frame
19. Section 6.2.2.14 — “This element specifies the presence of an ink object. An ink object is a VML object which allows applications to store data for ink annotations in an application-defined format.”
20. Section 7.6.2.60 — implementation-defined bibliographic citation formats
21. And many, many more.

So, one might ask, what exactly does “implementation-defined”mean? Here is how OOXML defines it and related terms:

behavior, implementation-defined — Unspecified behavior where each implementation documents that behavior, thereby promoting predictability and reproducibility within any given implementation. (This term is sometimes called “application-specific behavior”.)

behavior, locale-specific — Behavior that depends on local conventions of nationality, culture, and language.

behavior, unspecified —Behavior where this Standard imposes no requirements. [Note: To add an extension, an implementer must use the extensibility mechanisms described by this Standard rather than trying to do so by giving meaning to otherwise unspecified behavior. end note]

Note that this is not an entirely novel definition. Anyone who has spent time reading over the C and C++ Programming Language standards, in ANSI or in ISO, will recall a similar set of definitions. For example, these from ISO/IEC 9899:1999 C-Programming Language:

implementation-defined behavior
unspecified behavior where each implementation documents how the choice is made

locale-specific behavior
behavior that depends on local conventions of nationality, culture, and language that each implementation documents

unspecified behavior
behavior where this International Standard provides two or more possibilities and
imposes no further requirements on which is chosen in any instance

So, you can see that OOXML pretty much copies these definitions. However, ISO standards like ISO/IEC 9899:1999 go one step further and make an additional statement in their conformance clause, something that is distinctly missing from OOXML:

“An implementation shall be accompanied by a document that defines all implementation-defined and locale-specific characteristics and all extensions.”

If you poke around you will see that all conformant C compilers indeed do come with a document that defines how their implementation-defined features were implemented. For example, GNU’s gcc compiler comes with this document.

So, by failing to include this in their conformance clause, OOXML’s use of the term “implementation-defined” is toothless. It just means “We don’t want to tell you this information” or “We don’t want to interoperate”. Conformant applications are not required to actually document how they extend the standard. You can look at Microsoft Office 2007 as a prime example. Where is this documentation that explains how Office 2007 implements these “implementation-defined” features? How is interoperability promoted without this?

(This item not discussed at the BRM for lack of time.)

I have a lot of respect for Patrick Durusau. He has taught me much about how ISO standards work in practice, and I have benefited from his thoughts on that subject. I hope I can repay my debt to Patrick even in part, by teaching him something about how Microsoft works, in practice, a subject where I have expertise he lacks.

From the start Patrick has remained publicly silent on the topic of OOXML. No blog posts, no press, nothing. If you asked, he would say that this was his policy. Privately, you would get an earful (all negative), but as befits the unbiased chair of the committee which is responsible for the technical recommendation for the US NB, he kept his personal opinions out of the public arena.

This public orientation changed recently. As best I can figure it, on returning from a conference in Seattle in late January, Patrick was a changed man. Patrick is now an enthusiastic OOXML supporter and is eager to inform the world of his delight in OOXML at every opportunity. He posts his “open letters” on his web site, which are linked to, often within minutes, by the various Microsoft bloggers, and then sent around by Microsoft employees to the press and the various JTC1 NB’s.

Patrick is entitled to his own opinions. Free speech (and free enterprise for that matter) are things which all red-blooded Americans believe in, among other things. So long as Patrick makes it clear that he is speaking for himself, I have no problem with this.

Of course, Microsoft will not be so careful to distinguish Patrick’s personal opinions from his professional affiliations. So a post from Patrick’s personal web site is retold on a Microsoft blog as “The ODF Editor says….”, and then the next day is sent in an email to NB’s with a larger set of “endorsements”:

Chair, V1 – US TAG to JTC 1/SC 34
Convener, JTC 1/SC 34/WG 3 (Topic Maps)
Editor, OpenDocument Format TC (OASIS), Project Editor ISO/IEC 26300
Co-Editor, ISO/IEC 13250-1, 13250-5 (Topic Maps)

By the time it is actually discussed at the NB committee level, I wouldn’t be surprised if it morphs into an assertion that JTC1/SC34, INCITS, the ODF TC and the City Council of Covington, Georgia have all approved OOXML. It is dangerous to wear many hats when dealing with Microsoft. They are not ones for fine distinctions.

But now on to the substance of Patrick’s letters.

In his first note, the “OpenXML Poster Child“, Patrick says:

OpenXML has progressed from being developed in a closed environment to being handed over to approximately 70% of the world’s population for future development so I am missing the “not open” aspect of OpenXML. If anything, the improvements made to OpenXML during that process make it a poster child for the open standards development process.
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I understand that SC 34 will be taking on the maintenance and future development of OpenXML (with the participation of Ecma). That will mean that approximately 70% of the world’s population will have a say (through their respective national bodies) on how OpenXML continues to develop. I can’t speak for anyone other than myself but that sounds pretty open to me. (That presumes approval of OpenXML as an ISO standard, which must be decided by every national body for itself.)

We’ve covered this before. Let’s go down the list again. Where are the minutes from Ecma TC45 teleconferences? Where are the public archives of their mailing list? Where is the list of individuals participating in the TC? Where is the list of voting members? Where are the public comments they have received on OOXML? You call this open?

For ODF, all of this information is easily available to the public, here, here and here.

And don’t give me the canard about how moving to SC34 results in greater representation.

In the US who represents our population? The 7 members of V1 before the DIS 29500 process began? Or the 26 members after Microsoft stuffed V1 (the committee that you chair) with business partners last summer? Or V1 after several of them were kicked out for not paying their dues? Or the V1 after the DIS 29500 procedure completes and the warm bodies fade away? In your opinion, which one do you believe truly represents our US population?

Similarly, SC34 was stuffed with new P-members and swelled from 9 P-members in 2006 to 40 today, most of which voted in favor of OOXML and then failed to participate in any other SC activities. Are you seriously suggesting that SC34 was increasing the world’s influence over Microsoft’s decisions? That sounds quite naive. To me this looks much more like Microsoft is increasing their influence over the world, and JTC1 NB’s in particular.

The long list of shenanigans recorded, from Sweden to Portugal, from Poland to Switzerland is further evidence that the second interpretation is the accurate one. Is offering Microsoft partners rewards for joining a committee a way of increasing openness? Is joining JTC1 three days before the Sept. 2nd vote, then voting Yes without comments the way in which the world is able to gain a seat at the table?

Moving on.

Patrick’s next post is “Co-Evolution“. This, plus Microsoft’s recent interoperability announcements (yes, yet more announcements) give the impression that they believe it is better to talk about interoperability than to do something about it. Interoperability is something we only talk about now, but accomplish sometime in the nebulous future, like weight loss or reducing the national debt. Create studies, write reports, open labs, make test cases, write more reports. But when given the opportunity to do something now which would actually improve interoperability, like adding missing features to OOXML to accommodate the richer text model in ODF, then just say “No”. You can always do a study on this later, and write another report, and make a test case.

But if announcements alone could improve interoperability, then Microsoft would have solved this problem long ago and many times over.

The perspective that is missing in Patrick’s analysis is that of the vast part of the world’s population that does not benefit, and in fact is distinctly disadvantaged by having multiple incompatible document standards. We’ve been here before, in the 1980’s and 1990’s. It was not fun. We should not be seeking ways to repeat that failure.

Much of the world is also disadvantaged by the monopolist’s rent paid on Microsoft products and the associated lack of choice in today’s software monoculture. I’d rather help the world free itself of this oppression than appease the oppressor in hopes that he’ll wield a more lenient whip.

Last September, the NB’s of Great Britain, Brazil, Chile, Colombia, New Zealand, and the United States all requested that specific features be added to OOXML in order to improve interoperability with ISO ODF, in total 40 features such as the ability to have background images in tables or to have font weights beyond “normal” and “bold”. These were the exact features that Microsoft’s translator project on SourceForge identified as needed to improve interoperability with ODF. Ecma rejected all of these requests. They did not reject them because the features were unreasonable. They were rejected purely because they were ODF features.

So given the chance to do more than just write reports and have panel discussions, Ecma refused to move interoperability forward even one inch. If this is them on their best behavior (they desperately need NB approval votes), then why would we expect greater consideration from them if OOXML were approved?

In his next letter,”Confusion“, Patrick responds to Andy Updegrove, but not having followed that debate, I’m the one who is now confused. Patrick seems to be arguing that it doesn’t matter whether OOXML is “good” or not (in fact he seems to argue that there is no “good” or “bad” when it comes to XML) but that it will be better if OOXML was someplace where we could talk at it more.

I don’t know whether I’d choose to use moral terms when describing engineering artifacts either, but I would note that if the basic protocols and formats of the web were as poorly designed as OOXML, the web would never have thrived to become the glory it is today.

In “On the Importance of Being Heard” Patrick generously gives us his opinion of the DIS 29500 BRM he did not attend. The argument formally comes down to this:

1. Based on published and unpublished reports from the BRM, it appears that “everyone at the table was heard” and “Microsoft was listening to everyone” in a “public and international” forum.
2. If we now reject OOXML, we “all lose a seat at the table where the next version of the Office standard is being written”.
3. If we approve OOXML, even though “rough” then this “gives all of us a seat at the table for the next Office standard”.
4. Therefore, Patrick recommends approval of DIS 29500.

This argument has several critical flaws.

First, it is inaccurate to call the BRM proceedings “public”. Neither the public nor the press was allowed to attend. Security guards were posted at the door to enforce this mandate. JTC1 is a private, Swiss-headquartered NGO, answerable to no one, with no statutory responsibility to the public. Patrick talks about “ordinary users, governments, smaller interests” having a seat at the table. This is a fantasy. I did not see any such representation at the table in Geneva. One in five BRM attendees were Microsoft employees. Over 25% of the 114 people in attendance were either Microsoft or Ecma TC45 members. I fear that Patrick underestimates the extent to which NB’s have been stacked over the past two years and that he preserves some illusion of SC34 NB’s comprised of “ordinary users, governments, smaller interests”. Maybe that was true a few years ago, but the neighborhood has changed.

Was everyone at the table heard? Formally, it is true that every delegation had the opportunity to raise a single issue during the week. Some (those earlier in the alphabet) had the opportunity to raise two issues. But I think it is disingenuous to cast that as “everyone at the table was heard”. For many delegations it was true that for every issue they were able to raise, they had 10 or 20 more that they wanted to raise, based on their analysis of Ecma’s proposed dispositions, but were unable to because of insufficient time.

Was Microsoft listening? Yes. Everyone in the room was listening. Formally only the BRM itself could authorize changes to the standard at this point, regardless of Microsoft’s or Ecma’s opinion. So it is moot as to whether Microsoft was attentive. Whether they listened or not has zero impact on the ability of the BRM to make changes.

Patrick also appears to be impressed that this discussion all takes place “at a table where a standard for a future product was being debated by non-Microsoft groups?” What future product? The future product is Office 14 (Office 2009). Microsoft has not informed JTC1 nor Ecma on what the changes to OOXML will be for Office 14, due out later this year in beta form.

And then we come to main point of Patrick’s argument. Vote “Yes” so we all have a seat at the table. Before we buy into that logic, I suggest we examine other Microsoft/Ecma standards and see how their approval has or has not lead to increased participation.

Microsoft has two primary ways to negate broader participation in a standard’s maintenance. The first is standards abandonment. Take for example Ecma-234 “Application Programming Interface for Windows”. A contemporary observer might have been just as enthusiastic as Patrick is now. Wow! Isn’t this great? They are finally opening up and listening to the world! We finally have a seat at the table! I have a feeling that things are going to be better from now on!

Unfortunately, this standard was approved in December 1995 and covers the Windows 3.1 API only. Since Windows 95 shipped in August 1995, this Ecma standard was obsolete on the day it was approved. No revision of the standard was ever issued. Microsoft abandoned it.

Now certainly, there was nothing in principle that prevented the non-Microsoft Ecma members from continuing to maintain Ecma-234, creating errata documents, polishing up the language of the clauses, etc. But they had no effective way of actually evolving the standard when Microsoft withdrew from the process. That is the danger when you approve a single-vendor standard on the false assumption that this leads to openness.

The other way to negate broader participation in standards development is to create technical revisions at a rapid pace, and to create them within Microsoft with little outside participation. Note that this is how OOXML was created in the first place. And this is how Microsoft/Ecma maintains standards like the C# Programming Language. Ask your friends in JTC1/SC22 whether “70% of the world’s population” has a “seat at the table” in evolving that standard. Let me know what you hear. I believe you’ll hear that there has been negligible WG activity around C# maintenance, and that new revisions are promulgated by Microsoft, rubber stamped by Ecma, and sent on to SC22, canceling the previous standard and replacing it with the new one.

This trick can be very effective whenever the underlying Microsoft product has an update every 2-3 years. If your product revisions are more frequent than the required JTC1 maintenance checkpoints, then you can effectively ignore JTC1. That’s how Microsoft/Ecma has played the game in the past.

Note that Office 2007 has been out since late 2006. Office 14 (Office 2009) is due out in beta form this year, with expected release next year. Any bets on whether the file format will require a technical revision to accommodate Office 2009? There is absolutely nothing that prevents Microsoft from submitting a revised file format specification for Ecma, getting a rubber stamp approval and then Fast Tracking it back into JTC1. Since that is how they have treated other Microsoft/Ecma standards, the burden is on those who argue the contrary to support their optimism.

So consider the facts:

1. Microsoft has not supported the JTC1 maintenance process with their other Ecma Fast Tracks. There is no broader “seat at the table”, no power sharing, no ownership by “70% of the world’s population”. It is 100% Microsoft.
2. Microsoft’s current charter in Ecma TC45 explicitly calls for Ecma to own maintenance of OOXML if approved, not SC34.
3. Ecma in fact has submitted a proposal [PDF] to SC34 asking for control of OOXML to be handed back to them.
4. With their “rejuvenation” of SC34 (from 9 to 40 P-members in 2 years) Microsoft clearly has the votes it would need to force any maintenance regime they desire.
5. No one at Microsoft has made an official statement in writing confirming Patrick’s vision of future maintenance. In fact their only official statement, the Ecma proposal to SC34 cited above, contradicts what Patrick is suggesting. So why are only 3rd parties speaking so glowingly about the future control of OOXML? Plausible deniability, anyone?

Until the following occur I’d advise a bit more skepticism, considering that we’re dealing with a company with a clear record of abusing, subverting, abandoning, embracing and extending etc., standards:

1. Ecma changes their TC45 charter to explicitly call for all maintenance activities (corrigenda as well as technical revisions) to be performed in an SC34 WG.
2. Ecma explicitly withdraws their submission on DIS 29500 maintenance from the agenda of the Oslo SC34 Plenary and instead submits a proposal asking for future OOXML work to be done in a new WG in SC34, with a non-Microsoft chair.
3. Microsoft publicly states that they will hand operational control of OOXML to SC34, not only for maintenance of OOXML 1.0, but also for technical revisions, and that they will support this being done under JTC1 IPR rules, and using the JTC1 process, and that they will implement whatever revisions SC34 develops within 1 year of approval.

Until you have that, you have nothing. Get that, and then you can start talking about having a “seat at the table”.

In his most recent post, “Russian Peasant” Patrick suggests that the only reason one would vote against OOXML is spite, and that any problems could be fixed in maintenance.

Let’s try another analogy. You are shopping for a new TV and you go to your local consumer electronics store and look at the array of television sets lined up. Most come with a warranty. Any defects detected within the maintenance period will be fixed at the manufacturer’s expense. This is generally a good thing, having a maintenance period to fix problems that were not evident at purchase time.

So you find the model TV you want, the salesperson rolls out the box and just before you hand over your credit card, you notice a big gash on the side of the box, where a forklift had pierced it. You say, “I can’t accept this TV, it has been smashed!”. The salesperson says, “Don’t worry. No TV is perfect. We can fix this in maintenance. You’re fully covered.”

Do you hand over your credit card? Of course not. Maintenance periods, with TV’s as with standards, are for defects detected after the fact. It is not a replacement for proper inspection, review and approval processes. You expect a TV to work properly at the start.

No standard is perfect. We all know that. But at the time of approval, NB’s should be confident that their technical review was sufficient to find all of the important issues, and that these issues have all been fixed in the standard. OOXML should not be approved unless it is suitable now. The maintainers of OOXML will be busy enough fixing other problems that will be found later. We should not willingly approve a defective standard and set up a future maintenance group for failure by front-loading their agenda with defects that we already know about.

Consider: If we do that, then on what grounds can we reject another Fast Track proposal ever again? This slippery argument — we can fix that in maintenance — can be used for every single proposal that ever comes along. Why even have JTC1 at this point? Easier for everyone involved just hand the “International Standard” stamp over to Ecma and allow them to rubber stamp their own International Standards. This will save the time and expense of engaging hundreds of representatives from 87 JTC1 NB’s for a year for a sham review.

My advice is this. Let’s turn this train wreck around. Vote No on DIS 29500 and send a clear message that 6,000 page immature standards are not appropriate for JTC1 Fast Track. It showed poor judgment and great disrespect toward JTC1 NB’s for Microsoft to send this mess via Fast Track in the first place.

Microsoft has every right to feel that they are late to the game, and risk being left behind for their lack of an open document standard. But they should not expect that they can simply throw money around and remedy their long neglect overnight. And certainly they should not expect JTC1 NB’s to do the work for them. Microsoft should work on their specification at the consortium level and get it right first. Once when they have something mature, then they should send it along, preferable in smaller parts submitted sequentially. If they are unwilling or incapable of fixing the specification in Ecma then they could propose it as a new work item in SC34, where they may find some assistance. But if they persist on the standard remaining a single vendor standard, unilaterally controlled to benefit that single vendor, then I wouldn’t expect a warm reception in SC34 either.

JTC1 has been improvising its Fast Track processing from the start of the DIS 29500 procedure.

The latest “let’s invent a new rule” came at the BRM in Geneva, where a novel approach to tallying meeting votes was surreptitiously foisted on delegations, one which is clearly against the plain text of JTC1 Directives.

The question is how votes should be counted at a Fast Track BRM, where consensus cannot be reached, in this case for lack of time. Specifically, in that final batch-vote on 1027 comments, how should votes be counted. I believe the rules call for positions to be established by the majority of P-members. The leadership of the meeting instead counted both P-members and O-members. In the balance lies the fate of over 100 Ecma proposals which may or may not be included in the final text of the DIS, depending on how this question is resolved.

Let’s review the rules, from the current JTC1 Directives (5th Edition, Version 3.0)

First let’s start with the overriding rule from section 1.2 “General Provisions”:

These Directives shall be complied with in all respects and no deviations can be made without the consent of the Secretaries-General.

Or in plain English — “These are the rules, you can’t just make stuff up”.

So what is a P-member and an O-member? This is covered in chatper 3 “Membership Categories and Obligations”. P-members are defined as:

P-members within JTC 1 shall be NBs that are Member Bodies of ISO or National Committees of IEC, or both. Only one NB per country is eligible for membership in JTC 1. P-members have power of vote and defined duties.

and O-members are defined as:

Any NB that is a Member Body of ISO or National Committee of IEC, or both, may elect to be an O-member within JTC 1. Correspondent members of ISO are also eligible to be O-members of JTC 1. O-members have no power of vote, but have options to attend meetings, make contributions and receive documents.

So clear enough? O-members can attend meetings and contribute, but cannot vote. P-members can vote at meetings.

Section 9 deals with the voting rules, and 9.1.4 speaks about meeting votes in particular:

In a meeting, except as otherwise specified in these directives, questions are decided by a majority of the votes cast at the meeting by P-members expressing either approval or disapproval.

So, in a meeting, only P-members vote and they vote by majority. “Except as otherwise specified in these directives” means that this rule can be overridden in specific cases. But the override must be “specified”, i.e., actually written down that it is an override of the normal meeting voting rules.

So drilling down a level deeper we come to the Fast Track rules themselves in chapter 13, where in 13.8 is covered meeting votes at a Fast Track BRM:

At the ballot resolution group meeting, decisions should be reached preferably by consensus. If a vote is unavoidable the vote of the NBs will be taken according to normal JTC 1 procedures.

So on the surface this seems to be a vague statement. What are “normal JTC 1 procedures”? However, a moment’s reflection on 9.1.4 above shows that the Directives have already declared this as the normal procedure for meeting votes by saying that this is the rule that holds unless specified otherwise.

One can easily seek confirmation of this by looking at the parallel rules for PAS process BRM votes, given in 14.4.3.9. Here it is more explicit:

At the ballot resolution group meeting, decisions should be reached preferably by consensus. If a vote is unavoidable, the approval criteria in the subclause 9.1.4 is applied.

So despite the clear and plain text of the Directives, the JTC1 leadership decided to improvise a new rule, or more precisely the application of a different rule in the wrong context. The argument appears to be that section 9.5 applies to BRM votes. Section 9.5 “Combined Voting Procedure” is introduced as:

The voting procedure which uses simultaneous voting (one vote per country) by the P members fo [sic] JTC 1 and by all ISO member bodies and IEC national committees on a letter ballot is called the combined voting procedure. This procedure shall be used on FDISs, DISs, FDAMs, DAMs and FDISPs.

This is absurd. JTC1 Directives are not a menu. You can’t just pick what voting procedure you want to use from the list. The Directives tell you what procedure to use. First, the combined voting procedure is for letter ballots given to an NB, not for a BRM meeting vote by a delegation. Second, the BRM was not voting on an FDIS, DIS, FDAM, DAM or FDISP. We were voting on whether to include changes into a set of meeting resolutions. We were told repeatedly that the BRM could not take a position on the DIS. Finally, if combined voting procedures are read as applying to Fast Track, then they would also, by that same logic, need to apply equally to PAS, since both PAS and Fast Track are DIS’s. But as shown earlier, the PAS process explicitly calls for P-member majority voting according to 9.1.4.

One does not arrive at the voting rules of 9.5 by any straightforward or natural reading of the Directives.

So again, repeating from JTC1 Directions 1.2:

These Directives shall be complied with in all respects and no deviations can be made without the consent of the Secretaries-General.

I wasn’t in favor of having any batch ballot, because it violates the spirit of the consensus process, as defined in JTC1 Directives 1.2:

These Directives are inspired by the principle that the objective in the development of International Standards should be the achievement of consensus between those concerned rather than a decision based on counting votes.

[Note: Consensus is defined as general agreement, characterised by the absence of sustained opposition to substantial issues by any important part of the concerned interests and by a process that involves seeking to take into account the views of all parties concerned and to reconcile any conflicting arguments. Consensus need not imply unanimity. (ISO/IEC Guide 2:1996)]

To resort to “counting votes” on the vast majority of the technical issues of DIS 29500, without discussion or opportunity for objection, this is a failure of the JTC1 process. But if we are to have a vote at all, then let it be done in accordance with the rules.

So, let’s stop the nonsense. Let’s quit the tortuous post facto reinterpretation of the rules. Let’s recount and republish the results of the BRM counted according to the Directives and move on with the process. If JTC1 cannot consistently adhere to its own rules, then it should consider another line of business.