March, 2008

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Some of the opponents of Open XML have stated that because a final draft of the specification with all approved changes is not available, National Standards Bodies should decide to vote Disapprove.

This is pure FUD, and they know it.

The final draft of the specification can't be made available until after the vote reconsideration period, per ISO/IEC JTC1 rules.  Furthermore, this was announced at the Ballot Resolution Meeting.  Participants were instructed that national bodies need to base their decision on the documents that came out of the BRM.  Doug Mahugh, who was a member of the US delegation to the BRM, blogged about this.  The opponents of Open XML understand this process fully, but are deliberately spreading disinformation to attempt to obfuscate the issue and derail the process.  They should behave more ethically, and stop it.

I've done some research into the exact rules that apply.  Bear with me here, as understanding the procedures fully gets a little technical.  However, the facts are the only recourse that we have when confronted with outright deception.  And my experience is that when these opponents are confronted with the facts, they simply can't respond.

Usually, the opponents say that this period following the BRM comprises the "Final Draft International Specification (FDIS) Vote".

The approval of DIS 29500 falls under the "JTC 1 Directives", which apply to the Joint Technical Committee #1.  The two parents of JTC1 are ISO and IEC. Section 13 of these JTC 1 Directives describes the JTC 1 Fast-Track process, and there is NO "FDIS vote" in this JTC 1 Process.

Here are the facts.  The DIS 29500 vote occurred last September - all that is happening now is a reconsideration of National Body voting positions based on the work done up to and through the BRM. That is why there is no announcement of a new vote, and why the electronic ballot system is not used.

The opponents are using confusion about the exact procedures of the Fast-Track process to spread their misinformation.  There is a different ISO/IEC Fast-Track Process (as opposed to the JTC1 Fast-Track Process), which is described in the ISO/IEC Directives Part 1, Annex F.  This Fast-Track Process applies to other Technical Committees in either ISO or IEC, but not to JTC1.  In that ISO/IEC Fast-Track Process, there is an FDIS vote that lasts two months, and is simply a yes/no vote.  No BRM follows that vote.  There are other important differences, but it is key to understand that the other Fast-Track Process does have a later FDIS vote, but the JTC1 Fast-Track Process does not.

Some individuals and National Bodies who have not studied the JTC1 Directives in detail may be under the misunderstanding that this is an FDIS vote.  The opponents of Open XML are happy with this misunderstanding, of course.

JTC 1 Directives Section 9.6 states:

For a FDIS/DIS/FDAM/DAM/FDISP to be approved, the count taken by ITTF shall meet the following criteria:

• At least two-thirds of the P-members voting shall have approved;
• Not more than one-quarter of the total number of votes cast are negative.

In the case of the JTC1 Fast-Track Process, of the five options in section 13.9 (FDIS/DIS/FDAM/DAM/FDISP), the relevant option is DIS, not FDIS.

JTC 1 Directives Section 13.9 states, "If, after the deliberations of this ballot resolution group, the requirements of 9.6 are met, the Project Editor shall prepare the amended DIS (or DAM) and send it to the SC Secretariat who shall forward it to the ITTF for publication as an IS."

Notice the sequence of events here:

1. Complete the BRM.
2. See if the requirements of section 9.6 are met (e.g., 2/3 of voting P-Members vote Yes, etc.)
3. Then the Project Editor prepares the amended DIS.

There is no statement that the Project Editor must prepare a draft before ISO/IEC determines if the requirements of 9.6 are met.  In fact, the exact opposite is true.

JTC1 Directives 13.12 is as follows:

The time period for post ballot activities by the respective responsible parties shall be as follows:

• Immediately after the vote, ITTF shall send the results of the vote to the JTC 1 Secretariat and to the SC Secretariat, and for the latter to distribute the results without delay to its NBs, to any NBs having voted that are not members of the SC and to the proposer;
• As soon as possible after the distribution of the results of the vote to its NBs but in not less than two and one-half months the SC Secretariat shall convene a ballot resolution group meeting, if required;
• In not more than one month after the ballot resolution group meeting the SC Secretariat shall distribute the final report of the meeting and final DIS text in case of acceptance.

Notice that the final DIS text is distributed only in case of acceptance.

ISO/IEC clearly understood this when they ruled that there would be no new documents released before the end of March.  ECMA has no say about this.

So what should a National Standards Body do (or probably already has done)?

Excerpting from Doug's blog post:

• Study the original DIS29500 submission, or the ECMA-376 specification. That's the starting point: the standard as submitted to ISO/IEC. We started studying this in the US V1 committee in January 2007, and some people were looking at it even earlier as it went through the Ecma process in 2006.
• Next, study the national body comments submitted with the votes last September. The comments from your country show the main concerns of your country, so you'll want to focus on those first, but you can also review other countries' comments as well. (You'll see a lot of duplication, including word-for-word duplication of specific comments across many countries -- that's from the "denial of service attack" strategy the anti-Open XML crowd was using during the ballot period.)
• Now take a close look at the proposed dispositions that Ecma distributed on January 14. For each national body comment, Ecma proposed a change to address the problem (in the majority of cases), or explained why they felt a change wasn't a good idea at this time (in a small minority of comments).
• The final set of documents to review is the BRM resolutions that describe changes approved at the ballot resolution meeting. These are solutions to technical problems, editorial changes, or other changes that were suggested by BRM attendees and approved by the majority of countries attending the BRM.

What should the opponents of Open XML do?

They should stop deliberately misleading National Standards Bodies about the process.