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OOXML

The Carolino Effect

2008/03/04 By Rob 11 Comments

“There is it some game in this wood?”

Pedro Carolino wanted to write and publish an Portuguese/English phrase book.

“Another time there was plenty some black beasts and thin game, but the poachers have killed almost all.”

But one small problem — Carolino did not know English.

“Look a hare who run! let do him to pursue for the hounds! it go one’s self in the plonghed land.”

Undeterred, Carolino hatched a clever plan.

“Here that it rouse. let aim it! let make fire him!”

He had a copy of an Portuguese/French phrasebook, O Novo guia da conversação em francês e português by José da Fonseca. And he had a French/English dictionary.

“I have put down killed.”

With these two resources, writing his phrase book would be easy. Or so he thought.

“Me, i have failed it; my gun have miss fixe.”

Starting from the French half of the text in da Fonseca’s book, Carolino dutifully used his dictionary to translate, word-for-word, the French into English.

The result, O Novo Guia da Conversação, em Português e Inglês, em Duas Partes was published in Paris in 1855, and is now considered to be a classic of unintentional humor.

“Here certainly a very good hunting.”

A similar problem occurs in DIS 29500 “Office Open XML”. The scope of OOXML, as amended by the BRM is stated as:

This International Standard defines a set of XML vocabularies for representing word-processing documents, spreadsheets and presentations. The goal of this standard is, on the one hand, to represent faithfully the existing corpus of word-processing documents, spreadsheets and presentations that have been produced by Microsoft Office applications (from Microsoft Office 97 to Microsoft Office 2008 inclusive). It also specifies requirements for Office Open XML consumers and producers , and on the other hand, to facilitate extensibility and interoperability by enabling implementations by multiple vendors and on multiple platforms.

Faithful representation of Microsoft Office 97-2008. I’ve learned it is rarely polite to ask a man what he means by “faithful”, but let me make an exception here. We have now the binary Office format specifications, not part of the standard, but posted by Microsoft. And we have OOXML specification. In what way does the OOXML “represent faithfully” the “existing corpus” of legacy documents?

Does OOXML tell you how to translate a binary document into OOXML? No. Does it tell you how to map the features of legacy documents in OOXML? No. Does it give an implementor any guidance whatsoever on how to “represent faithfully” legacy documents? No. So it is both odd and unsatisfactory that primary goal of the OOXML standard is so tenuously supported by its text.

Now, certainly, someone using the binary formats specifications, and using the OOXML specification, could string them together and attempt a translation, but the results will not be consistent or satisfactory. It is the Carolino Effect. Knowing the two endpoints is not the same as knowing how to correctly map between them. A faithful mapping requires knowledge not only of the two vocabularies, but also the interactions.

Also, having the two specifications does not help with the 77 features in OOXML which are declared to the “implementation-defined” or “application-defined”. How are these translated from the binary formats?

Note that DIS 29500 bears the obvious marks of its legacy roots, from the use of VML and non-hierarchical run structures in WordProcessingML, to bit fields and idiosyncratic leap year calculations in SpreadsheetML. This suggests the likelihood that the authors of this standard did not just sit down and design the standard from scratch, but that they in fact had access to the binary format specification and mapped it into XML as a preparatory step. It is difficult to explain the presence of elements such as “lineWrapLikeWord6” without positing the presence of such a mapping.

Microsoft should simply publish this mapping. Without such a mapping, conversions will be inconsistent, interoperability will suffer and a primary goal of the standard will not be met. Given the same binary document, Microsoft Office, Apple iWork, OpenOffice.org, etc., will all produce different OOXML documents. How is this “faithfully representing” existing documents? What is needed is a canonical mapping.

Note that the initiation of a open source project to develop a convertor between the binary formats and OOXML is insufficient. What is required is a canonical mapping. Otherwise we are faced with the reality that the true goal of OOXML is more accurately stated as:

To allow Microsoft the ability to represent their legacy documents in XML and pretend that it is a capability that other vendors can practice as well.

Though this issue was of great interest to several NB’s, it was not able to be raised at the BRM for lack of time.

Filed Under: OOXML

The Art of Being Mugged

2008/03/02 By Rob 30 Comments

I will never forget that brisk October evening in 1996. I had arrived home from work, and followed the standard routine — drop off the backpack, boot up the PC, put the keys and wallet on the desk, sort through the mail, turn on the TV, etc. But what about dinner? Nothing in the refrigerator interested me, so I grabbed a $10 bill from my wallet, took my keys and headed off to a sandwich shop around 1/2 mile down the street, as I had done a thousand times before.

I ordered a chicken stir-fry sub with American cheese, large, to go, and headed off home. As I walked down one deserted street, I heard foot steps rustling in the leaves. Turning my head, I saw a figure 50 yards away walking in my direction. Nothing to worry about. The city is full of people. Then a few seconds later, I heard the person running in my direction. Nothing to worry about. I was near a bus stop, and no doubt he was rushing to catch his bus.

But there was no bus. Before I realized what was happening, he had come upon me from behind, knocked me to the wall, and with his left arm around my neck, pressed a blade against my throat with his right hand.

“Don’t turn around or I will plunge this knife into your chest cavity,” he said.

Many things enter one’s mind in such a situation. I’d like to say that my thoughts went immediately to self-preservation, or clever plans for escape, but in all honesty, my first thought was on how awkward his demand was phrased, how clichéd it was. “Plunge into my chest cavity”? I wanted a rewrite.

But a look down at the blade reminded me that this was not a prop, and that however inelegant his words, this gentleman and I had a business transaction to complete.

“Gimme your wallet,” was his request, as I had expected.

“I don’t have a wallet,” I replied.

And thus began a protracted negotiation session,where I offered my $3 and change, and even my sandwich, and this was repeatedly refused as being inadequate. We reviewed the alternatives. He suggested an ATM. I said the nearest one was over a mile away. He said I could drive him. I said I didn’t have a car.

And so we went on, trying to find mutually acceptable solution. When he finally demanded that we go to my apartment and I write him a check, I knew I had to take charge. For the first time that evening I was really scared. This needed to end now, on the street, while the mugger was still relatively calm. I was willing to fight and risk the blade before I would let him into my apartment, where I knew my odds would be greatly diminished. But was there any other solution?

Then it hit me. What if I put him in a context he was familiar with? If he is going to give me clichéd lines, why don’t I give him the same? We’ll work this out according to the book.

“This ends here. I’m not moving an inch more. I don’t have a wallet, and if you don’t believe me, then search me!,” I said in a louder voice that startled him a bit.

I threw my sandwich on the ground, faced the building, dramatically placed my hands spread above my head on the wall, and spread my legs, just like in the movies. He quickly got the idea, patted me down and satisfied himself that I was not carrying a wallet.

His final words were: “Don’t try to follow me.” He then tossed $2 of my $3 back to me and ran off, saying “I only need money for the bus”.

I then walked, a bit faster than usual, back to my apartment, locked and bolted the door, called the police and started eating my sandwich, with cold, shaking hands.

I learned two important lessons from that night. First, I now always carry enough money to satisfy a mugger, $40-$50. Carrying too little money is as risky as carrying too much.

The second lesson… Well, I’ll get to that later, after a few words about the DIS 29500 BRM.

I’m just back from Geneva, where delegations from 32 National Bodies (NB’s), plus Ecma, met for five days at the CICG. Present were 104 delegates in a large, double room with tables four deep, in two sections arrayed in a chevron. A microphone was placed between each two delegates. The delegations were generally arranged in alphabetical order by the English names of their countries.

At the front of the room was a table with the meeting officials, including the SC34 Chair and Secretariat, ITTF representatives (one of their responsibilities is to supervise “the application of the ISO and IEC Statutes and Rules of Procedure”), Ecma’s Project Editor and his assistant, and in the center (or centre) was the BRM Convenor, Alex Brown.

The agenda was essentially improvised based on NB interests. Each NB, called in alphabetical order, was invited to raise an item for discussion, from one of the 3,522 NB comments from the failed Sept 2nd. ballot, or from one of the 1,027 Ecma responses. A quick calculation shows that, a 5-day meeting in session 6.5 hours a day (9-5, with one hour for lunch and 15m breaks mid morning and afternoon) will have at most 1,950 minute of meeting time, or less than 2 minutes per Ecma response. This should have raised warning signals. More than warning signals, it should have triggered action. But not in JTC1. Fast Tracking a 6,045 page Ecma standard. No problem. Processing 1,027 Ecma proposals in one week. No problem.

“Forward, the Light Brigade!”
Was there a man dismay’d?
Not tho’ the soldier knew
Someone had blunder’d:
Their’s not to make reply,
Their’s not to reason why,
Their’s but to do and die:
Into the valley of Death
Rode the six hundred.
— Tennyson

So with a bit of derring-do, we plunged into the work on Monday morning. We had a delightful mix of personalities. We had world-renowned experts in XML technologies (I won’t mention any by name for fear of giving offense by leaving one out), experts in JTC1 process, experts in accessibility, RTL writing conventions, computer security, etc. We also had many people who had never attended an ISO meeting before. Individual delegates came from a mix of backgrounds, some government bureaucrats, some standards professionals, independent XML consultants, academics and employees of small and large corporations. The presence of open source and open standards advocates was notable, and I’ll write more on the significance of that another day.

Monday went well. There was a little commotion and several objections when it was announced that detailed minutes would not be recorded. And one delegate did protest that the Head of Delegation for his country was improperly determined. But we plowed ahead and started hearing from delegations by 9:30am, starting in alphabetical order with Australia.

One NB, in lieu of a technical comment raised the objection that the DIS was too long and inappropriate for Fast Track. The response from ITTF was that we should do a “best effort” in the time available this week. If this is not sufficient, NB’s should change vote to No, or maintain No vote.

By lunch time we had made it to India. And what had we resolved? Ten substantive technical issues were raised by NB’s. One was resolved (add Ecma’s OOXML accessibility report as an informative annex) and 9 issues are taken off-line for further discussion.

Six more issues are brought up in the afternoon, as we made it through Malaysia. These items were discussed, and all taken-off line for further discussion. So net for Monday is 15 issues raised, and one resolved. Many of us had homework to do.

Tuesday and Wednesday proceeded much the same, but with time given in the morning and upon returning from lunch to update the BRM on the progress of the “off-line” discussions. But we were still clearly in the accumulation stage. Issues were piling up faster than they were being resolved.

By Tuesday at 12:11 we had made it once through the alphabet, so every delegation had the opportunity to raise, thought not necessarily resolve, a single issue of importance to them. We started again with Australia and end the day with Ireland. The BRM never completed the second pass through the delegations. As the days progressed, more and more time was given to reports from the off-line discussions and trying to gain consensus on those issues. Less time was given to raising new issues.

Given the constraints of the meeting, this was the appropriate thing to do. But the net result was that New Zealand had the last opportunity to raise new issues, on Thursday at 4:34pm. The US, being last in the alphabet, was able to raise only a single issue during the week.

As we reached mid week, we were presented with a set of ballot choices, to deal with the responses that could not be discussed during the meeting, for lack of time, which would at the current rate of processing amount to 800-900 of the 1,027.

As any real estate agent will tell you after a few drinks, the trick to selling a house is to make the buyer think they have made a wise decision. To do that, first show them a few overpriced, dilapidated houses, and then show them the house you want them to buy. A similar approach was used on the BRM.

The four options presented were:

  • Option 1: Submitter’s responses (Ecma’s) are all automatically approved.
  • Option 2: Anything not discussed is not approved.
  • Option 3: Neutral third-party (ITTF) decides which Ecma responses are accepted
  • Option 4: Voting (approve + disapprove) must be at least 9 votes. Abstentions not counted.

We were told that these options are not in the Directives and that we have been given these choices because ITTF “needs to act in the best interests of the IEC”. I don’t quite get it, but there appears to be some concern over what the press would think if the BRM did not handle all of the comments. One NB requested to speak and asked, “I wonder what the press would think about arbitrarily changed procedures?” No response. I thought to myself, why wasn’t ITTF thinking about the ‘best interests” of JTC1 when they allowed a 6,045 page Fast Track submission, or ignored all those contradiction submissions, or decided to schedule a 5-day BRM to handle 3,522 NB comments. Isn’t it a bit late to start worrying about what the press will think now?

We break for lunch.

After lunch and after more discussion, the meeting adopted a variation of option 4, by removing the vote minimum. I believe in this vote the BRM and ITTF exceeded its authority and violated the consensus principles described in JTC1 Directives.

Consider 1.2 of the Directives, the General Provisions:

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)]

However, 80%+ of the resolutions of the BRM were resolved by a ballot, without discussion, without taking into account any dissenting views, without reconciling any arguments. Indeed, there was not any opportunity to even raise an objection to an issue decided by the ballot. Many of the issues were decided in 6-5 or 7-6 split votes, with no discussion. How can that be said to be a consensus? This is an utter failure to follow the cardinal principles of JTC1 process.

Note that votes are explicitly allowed at a BRM, though they are discouraged. Section 13.8 of the Directives states:

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.

What are normal procedures? Section 9.1.4 says:

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.

(Somehow this got this confused and O-member votes were included in the initial reported totals, but I assume this will get fixed and the results restated.)

The key observation is that there are a number of solitary experts at the BRM, those who bring a perspective or expertise that cannot be matched by anyone else at the BRM. For example, the Israeli delegation speaks with authority on matters of Hebrew writing, counting and calendaring systems. In fact, they made a number of valuable contributions to the meeting in these areas. Similarly, other delegation or specific delegates bring their own unique expertise to the table. If an issue is brought up,and the question is asked whether Ecma’s resolution is satisfactory, if Israel objects, their objection should be heard. Period. It doesn’t mean we necessarily will agree with, or adopt their suggested change. But they should be heard. This is what is meant by “seeking to take into account the views of all parties concerned and to reconcile any conflicting arguments”.

The majority has the right to have its will enacted. That is the easy part. The responsibility of the Convenor, however, is to ensure that the minority has the right to be heard, and the equal opportunity to make their case. That is the price of consensus. This is the price of open standards.

This point was demonstrated when one set of comments was being approved. The list of response numbers was projected on the screen. The Convenor asked if there were any objections to approving this batch of comments, which were said to be all related. Three hands went up, objecting, from three delegations, including the US. “So resolved” was the response, without asking the nature of the objections. Certainly, if the only thing that mattered was majority rule and efficiency, and if JTC1 did not have explicit consensus goals, then this might be the correct thing to do. But how, in practice, can one determine the “absence of sustained opposition to substantial issues by any important part of the concerned interests” without hearing what the objections are?

In this case the US Head of Delegation continued to gesticulate and was eventually recognized to speak. We stated that we observed that the list of response numbers in this resolution was in error and included a response number that should not have been part of this bunch. Once pointed out, the proposer of the resolution agreed, and the US change was adopted without dissent.

This is the kind of thing you lose with an electronic ballot. There is no way to object, no way to discuss, no way to amend or to substitute language. It is not a consensus process. It is just a Hobson’s Choice — take it or leave it, and the BRM suffers for it, as the value of solitary expertise is the room is neutralized by the NB’s who voted blanket approval for all of Ecma’s proposals.

As the meting progressed into Thursday, the tension mounted. As new issues were identified, they were taken off-line and told they could be brought up “Friday morning”. But no one really believed that. It was clear that there was not enough “Friday morning” to go around.

Thursday 9:20am, a delegation objects that they were told only to review Ecma’s responses to their own comments, and that there was never sufficient time to review all 1,000 Ecma responses since January 14th. ITTF’s response: “Nothing we can do about it in the rules — Nothing we could have done in our judgment”.

2:18pm the Convenor announces “This is zero hour”.

There is clearly not even enough time to fully discuss in the meeting the resolution of items that were taken off-line for further discussion. The US is not allowed to present our multi-part proposals to the meeting. We are told get consensus outside of the meeting first, so it can be brought up for quick approval.

Into Friday the BRM spirals further downwards. The issue is not now that NB’s cannot raise new issues. The problem is now that NB’s who have been diligently working on issues off-line with other delegations, meeting over lunch, or early in the morning or into the evening, may not be able to have their proposals heard and acted on.

There simply is not enough time. The anxiety-driven, frantic delegates push even harder. More resolutions are approved with 2 or 3 delegations trying to raise objections, but without being recognized. Tempers grow short. One highly respected Head of Delegation, of unimpeachable reputation and experience started to voice an objection “I am extremely disgusted by the way procedures have been…” before being called out of order by the Convenor, saying that discussion of procedural issues will not be allowed. Another delegation tries to raise a new issue, as they had for the last two days without luck. “We’re using the public money from NNN to come here to speak on our issue. Can we speak on our issue?” Convenor – “We have run out of time.”

And so the BRM came to an end, with the announcement of the results of the paper ballot. Five delegations gave default approval to the Ecma comments (Chile, Cote D’Ivoire, Czech Republic, Finland, Norway) and four gave default disapproval positions on the undiscussed Ecma responses (India, Malaysia, South Africa, United States). Most delegations gave a default abstain position, or registered no position. A delegation could additionally override their default position on any particular issue.The net is that, although the discussions on Monday and Tuesday demonstrated that the quality of the Ecma responses was such that almost every one required substantial off-line work to make it acceptable, we gradually lowered our standards, so that by week’s end, we approved 800+ comments without any discussion, even in the presence of clear objections.

I want to make it clear that I in no way wish to criticize the Convenor. I think Alex did a remarkable job in trying to carry out his duties and be fair in this no-win situation. He was given an impossible task and had to find out how to fail in the least offensive way. There is an art to crash-landing an airplane and we must acknowledge that.

There is an art to being mugged successfully as well and I have learned that lesson. But when someone tells you, “Your money or your life”, although one is better off having that choice than not having it, one can still complain vigorously at the injustice of having a choice forced onto you. It is an artificial constraint, determined entirely without your consultation, and without considering your welfare, that limits you to those two choice. Similarly, the choices given at the BRM were arbitrary, artificial, and not to the benefit of JTC1, NB’s or to users and implementors of DIS 29500.

As the meeting concluded, ITTF requested that we not call the vote a “default” vote. “These were your choices, voted according to the rules you adopted,” we were told. I reject this revisionist portrayal of the events. This was not my choice. This was merely the least bad of several bad choices that the ITTF deigned to allow us at the end of a grueling week trying to resolve 3,522 issues in bloated, technically immature proposal that has been mismanaged from the start.

“Your money or your life”. Not a day goes by that I am not appreciative I was given that choice. But that decision was made under duress, and does not diminish my revulsion of the person who forced that choice upon me. The question is, why do NB’s put up with this OOXML Fast Track nonsense? Who is holding a knife to our throats?

Filed Under: OOXML

Legacy Inflation

2008/02/21 By Rob 8 Comments

When I was a child I stumbled upon the dark secret that all the adults were hiding. A simple mathematical calculation revealed their conspiracy. I was 10 years old, and my mother was 30. So she was 3x my age. I observed that in 10-years time I would be 20, and my mother would be 40. She would then be only twice my age. A few more calculations and the ominous truth was clear: At some point I would surely catch up, and perhaps even surpass her age!

Well, to be fair, I haven’t quite caught up yet.

But I am reminded of this when I hear Microsoft’s claims about “legacy document compatibility”. At first they used the term “legacy documents” to refer to the masses of existing binary documents, these “exobytes” of documents in Office binary formats. The argument seemed to be, that since Microsoft Word 95 had a bug, therefore Apple iWork 08 must also have this same bug when using OOXML format. This form of argument is used to defend all manner of defects in OOXML.

But in recent weeks, the argument has morphed. The legacy era is catching up with us. Microsoft’s unwillingness to fix errors in OOXML is now being defended because the fixes (Microsoft claims) would break compatibility with Ecma-376. In other words, Office 2007 files are now part of this large legacy that must be preserved. I can only call it call this “legacy inflation”.

First, note that Microsoft shipped Office 2007 with support for OOXML as the default, and this was entirely their choice. Beta versions of Office 2007 did not have OOXML as the default. If Microsoft had left the binary formats as the default, it would have been far easier for their customers. They could have waited for the Mac Office to support OOXML, Mobile Office, developer tools, etc., and then have a coordinated rollout of the new format, rather than dump it on an unprepared world. They could have also waited for standards approval for OOXML, wait for the standard to stop changing before forcing on their customers. But the didn’t do that. They took the approach that caused maximum disruption for their customers. And now that Office 2007 is in use, Microsoft wants ISO to bail them out, and not make any changes that would result in even a single attribute in OOXML differing from Ecma-376.

We see similar brinkmanship in wireless networking protocols where chip manufacturers rush to be the first to ship support for “draft” standards like 802.11n, build up an inventory of chips, and then lobby to ensure that the draft does not change, so they can cement their first mover advantage. This does not benefit the consumer, this does not benefit the standard, this does not benefit interoperability. It is all about maneuvering for market advantage. We should not be encouraging or supporting this.

It is interesting to note that in the wifi world, any company that plays this game with draft standards takes a big risk. They may win, or they may lose. It is a gamble. Only a monopolist would assume that they can play this game risk free. Microsoft does not face the same market risks that others would face for making a bad decision.

In any case, the argument that DIS 29500 must remain identical to Ecma-376 is technically deficient. Consider: Ecma-376 is not identical to the binary formats, but Microsoft Office can still read both. That is because Office can tell these files apart and call different code to parse the two different formats. Similarly, if OOXML diverges from Ecma-376, Microsoft can tell, with 100% certainty, which documents were created in Ecma-376 format versus which ones were made according to the ISO version of the standard.

The key is that all OOXML documents describe the application that created them, as well as a detailed version number. These are described in DIS 29500, Part 4:

7.2.2.1 Application (Application Name)

This element specifies the name of the application that created this document.

7.2.2.2 “AppVersion (Application Version)”

to differentiate between different versions of the same producer

If we look at three Office 2007 documents, we see the following in app.xml:

<application>Microsoft Office Word</application>
<appversion>12.0000</appversion>

<application>Microsoft Excel</application>
<appversion>12.0000</appversion>

<application>Microsoft Office PowerPoint</application>
<appversion>12.0000</appversion>

So the way to ensure compatibility in the fact of the standard changing through the approval process is clear. If the version is “12.0000” then interpret as Ecma-376. But when Office is updated to support an approved DIS 29500 (if this ever occurs) then they can simply update the version number in the files. That way Microsoft Office and every other application can tell them apart and process them correctly.

So let’s reject Microsoft’s push for legacy inflation. Otherwise we will soon find that the next version of OOXML is also unchangable, since Office 14 will be out before the next version of OOXML is standardized. Will we then be unable to change anything in OOXML 1.1 because Office 14 is already in beta? Where does this end?

This doesn’t mean we should be capricious with changes in DIS 29500, but where something is clearly wrong, let’s fix it. The assumption should be that the future is bigger than the past, that no matter how many documents existed before, there will soon be many more created in the future. We should be optimizing for that future.

Filed Under: OOXML

Fast Track versus PAS

2008/02/16 By Rob 14 Comments

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.7.3.1.1 Commitment to Working Agreement(s)

  1. What working agreements have been provided, how comprehensive are they?
  2. How manageable are the proposed working agreements (e.g. understandable, simple, direct, devoid of legalistic language except where necessary)?
  3. What is the attitude toward creating and using working agreements?

M.7.3.1.2 Ongoing Maintenance

  1. 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)?
  2. 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.7.3.1.3 Changes during transposition

  1. What are the expectations of the proposer toward technical and editorial changes to the specification during the transposition process?
  2. How flexible is the proposing organisation toward using only portions of the proposed specification or adding supplemental material to it?

M.7.3.1.4 Future Plans

  1. What are the intentions of the proposing organisation toward future additions, extensions, deletions or modifications to the specification? Under what conditions? When? Rationale?
  2. 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.
  3. 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.7.3.2.1 Process and Consensus:

  1. What processes and procedures are used to achieve consensus, by small groups and by the organisation in its entirety?
  2. How easy or difficult is it for interested parties, e.g. business entities, individuals, or government representatives to participate?
  3. What criteria are used to determine “voting” rights in the process of achieving consensus?

M.7.3.2.2 Credibility and Longevity:

  1. 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?
  2. How long has the organisation been functional (beyond the initial establishment period) and what are the future expectations for continued existence?
  3. 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.

M.7.3.3.1 Patents:

  1. How willing are the organisation and its members to meet the ISO/IEC policy on these matters?
  2. What patent rights, covering any item of the proposal, is the PAS owner aware of?

M.7.3.3.2 Copyrights:

  1. What copyrights have been granted relevant to the subject specification(s)?
  2. What copyrights, including those on implementable code in the specification, is the PAS originator willing to grant?
  3. What conditions, if any, apply (e.g. copyright statements, electronic labels, logos)?

M.7.3.3.3 Distribution Rights:

  1. What distribution rights exist and what are the terms of use?
  2. What degree of flexibility exists relative to modifying distribution rights; before the transposition process is complete, after transposition completion?
  3. Is dual/multiple publication and/or distribution envisaged, and if so, by whom?

M.7.3.3.4 Trademark Rights:

  1. What trademarks apply to the subject specification?
  2. What are the conditions for use and are they to be transferred to ISO/IEC in part or in their entirety?

M.7.3.3.5 Original Contributions:

  1. What original contributions (outside the above IPR categories) (e.g. documents, plans, research papers, tests, proposals) need consideration in terms of ownership and recognition?
  2. What financial considerations are there?
  3. 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

M7.4.1 Quality

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.7.4.1.1 Completeness (M):

  1. How well are all interfaces specified?
  2. How easily can implementation take place without need of additional descriptions?
  3. What proof exists for successful implementations (e.g. availability of test results for media standards)?

M.7.4.1.2 Clarity:

  1. What means are used to provide definitive descriptions beyond straight text?
  2. What tables, figures, and reference materials are used to remove ambiguity?
  3. What contextual material is provided to educate the reader?

M.7.4.1.3 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.7.4.1.4 Stability (M):

  1. How long has the specification existed, unchanged, since some form of verification (e.g. prototype testing, paper analysis, full interoperability tests) has been achieved?
  2. To what extent and for how long have products been implemented using the specification?
  3. What mechanisms are in place to track versions, fixes, and addenda?

M.7.4.1.5 Availability (M):

  1. Where is the specification available (e.g. one source, multinational locations, what types of distributors)?
  2. How long has the specification been available?
  3. Has the distribution been widespread or restricted? (describe situation)
  4. 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.7.4.2.1 Development Consensus:

  1. Describe the process by which the specification was developed.
  2. Describe the process by which the specification was approved.
  3. What “levels” of approval have been obtained?

M.7.4.2.2 Response to User Requirements:

  1. How and when were user requirements considered and utilised?
  2. To what extent have users demonstrated satisfaction?

M.7.4.2.3 Market Acceptance:

  1. How widespread is the market acceptance today? Anticipated?
  2. What evidence is there of market acceptance in the literature?

M.7.4.2.4 Credibility:

  1. What is the extent and use of conformance tests or means of implementation verification?
  2. What provisions does the specification have for testability?

M7.4.3 Alignment

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.7.4.3.1 Relationship to Existing Standards:

  1. What international standards are closely related to the specification and how?
  2. To what international standards is the proposed specification a natural extension?
  3. How is the specification related to emerging and ongoing JTC 1 projects?

M.7.4.3.2 Adaptability and Migration:

  1. What adaptations (migrations) of either the specification or international standards would improve the relationship between the specification and international standards?
  2. How much flexibility do the proponents of the specification have?
  3. What are the longer-range plans for new/evolving specifications?

M.7.4.3.3 Substitution and Replacement:

  1. What needs exist, if any, to replace an existing international standard? Rationale?
  2. What is the need and feasibility of using only a portion of the specification as an international standard?
  3. What portions, if any, of the specification do not belong in an international standard (e.g. too implementation specific)?

M.7.4.3.4 Document Format and Style

  1. 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.

Filed Under: ODF, OOXML

A Pre-BRM Miscellany

2008/02/16 By Rob 8 Comments

I’ll be attending the BRM as part of the US delegation, leaving for Geneva a week from today. I am awed by the security apparatus which is being rolled out to ensure the integrity of the open standards process. Photo ID requirements, badged access to the meeting room, prohibitions against cameras and recording devices, no observers, no press. Truly, this is what open standards are all about.

Our delegation has been warned that there will be a dangerous group of agitators at the event and we may need to walk past them to get to the meeting room, and we should not lend our support in any fashion to this event, which includes such known disruptive elements as Vint Cerf, Håkon Wium Lie, Bob Sutor, and Andy Updegrove. Eyes front, do not look to the left, do not look to the right.

I’m certainly impressed that JTC1 is taking the BRM process so seriously, and everyone is so concerned with the integrity of the process. But I must wonder where all this attention was when NB’s were reporting to JTC1 that OOXML was too large to review under Fast Track procedures? Where was the concern when NB’s were objecting that the proposal contradicted numerous international standards? Where were the precautions when committees were being stuffed, and new NB’s were joining JTC1 only days before the ballot ended? Who was watching out for the integrity of the process then? Why is an OFE panel discussion on “Standards and the Future of the Internet” by international experts on the subject a threat to the international standards system, but no one in JTC1 even blinked when Côte-d’Ivoire joined JTC1 as a P-member three days before the end of a 6-month standardization process and voted “Yes” without comments on a 6,000 page proposal?


In other news, Martin Bekkelund has a look at some of the much vaunted “support” for OOXML on the Mac. Despite the claims, the support is quite underwhelming. As Gertrude Stein said, “There is no there there”. (That probably won’t translate well, so for my non-native English-speaking friends, trust me, that was hilarious.)


From ZDNet Australia and Brett Winterford comes a summary of some analysis by IP law practitioners and academics of OOXML and IPR. “Can Microsoft be trusted on OOXML covenants?” My summary: individuals, small companies and open source projects are roadkill.


Google searches for “ODF” and “OpenDocument” or even “noooxml” are now returning sponsored links with phrases like “Learn the truth about the standard for interoperability” that lead you to a pro-OOXML petition on Microsoft’s faux OOXML community site. For example, try this query.

Let’s see if I understand how this pay-per-click system works. Every time I click these sponsored links, money gets transferred out of some pro-OOXML supporter’s bank account and is sent to Google? These seems the expensive route to go, but there is some logic to it. A look at Google Trends shows that Google queries for “ODF” far outnumber queries for “OOXML”.

On the other side, at the real <NO>OOXML petition, the count stands at 82,422 signatures. Apparently they did not need to trick people into visiting their web site.


Three ODF applications in the news this week.

IBM Lotus Symphony takes Datamation’s “Product of the Year” award in the “Office Productivity Software” category, beating out Microsoft Office. Congratulations to Symphony team!

Also, CNet TV puts OpenOffice.org in the #1 slot in their “Top 5 Best downloads of 2007“.

As reported by <NO>OOXML, the OpenDoc Society has an interesting tease in their February newsletter about a proposal “under investigation” by an “ODF standards group” within Microsoft to add better support to MS Office for ODF. Interesting.


Get it while you can. Microsoft is making their legacy binary format documentation available for download. This timely disclosure comes a few month after they silently disabled access to many of their legacy formats in Office 2003 SP3.

My advice — download these binary formats, burn them to CD and store them in a safe place. Over the years Microsoft has made these formats available for download (ca 1996), put them on MSDN CD’s (ca 1998), then added restrictive terms that specifically forbade use by competitors (ca 1999), removed the documentation entirely from the web and MSDN CD’s (ca 2000), made the formats available under commercial license only, made a RF license available only after filling out an intrusive questionnaire and only when the use was “complementary to Office” (ca 2005), to the present download terms. So get them now, since there are no guarantees on how long they will remain available this time.

In any case, it is good to have this material available once again. We now have a file format specification, controlled exclusively by Microsoft, with all sorts of quirks and bugs necessary to be an accurate and compatible description of the billions of existing Microsoft Office documents, available for anyone to download and implement under terms granted by Microsft’s Open Specification Promise. In fact, the observant reader will note that the same could be said about OOXML. But why should either be an ISO Standard? They both remain a description of the anomalous quirks of a single vendor’s proprietary products, with no generality or applicability to other uses.

In fact, if a claim is made for needing ISO standardization, the better claim should be given to the legacy binary formats, since they indeed are widely implemented, and are used for billions of legacy documents. Microsoft would not even need to pad their résumé with toy implementations. The binary formats are implemented in everything from MS Office, to OpenOffice, to Lotus SmartSuite to Lotus Symphony, to Corel WordPerfect Office, to KOffice, Google Docs & Spreadsheets, to Apple iWork, to MindJet. In fact, for every partial implementation of OOXML that Microsoft claims, we could point to dozens of fuller implementations of the legacy binary formats.

So why the rush to make an ISO standard for OOXML? I wonder if instead we should be taking Adobe’s example and standardizing the existing binary formats, as insurance for long-term access to the legacy base of MS Office documents. Then moving forward, MS Office could use a clear, modern format like ODF, enhanced with Microsoft’s participation in the ODF TC, to ensure that it includes all of the capabilities that they require for moving forward in the office productivity market. Do we really want to drag deprecated VML and incorrect leap calculations into the 21st Century?


Filed Under: OOXML

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