FUD About Availability of the Final Specification

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.

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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.

Comments (9)

  1. Andre says:

    Who wrote the JTC1 fast-track procedures?

    Note that these rules would not pose any problems under normal situations but here large percentages of a monster spec are changed.

    It doesn’t matter what the rules say unless the rules don’t permit you to carry out a faithful review. It only confirms that the OOXML case does not fit into the fast-track rules.

    Your facts that can’t be ignored are using the Nuremberg defense. The BRM results are not applicable to produce a text that does not require further review or decisions, simply because there are contradictions.

    The rules don’t say that a draft text will not be produced to base your decisions on. If you only have minor changes that does not pose any problems on your national committee. (*) It only mandates who will deliver the final official text.

    Will the final text be delivered one month after the ballot resolution group meeting in the case of approval?

    (*) Let me give you an example from EU-Parliament. We have a committee draft report, we have amendments to them filed. And then the Committee votes and it goes to plenary. Prior to a plenary vote the text is made available. In theory you don’t need it, because you can take the list what was voted and produce a consolidated version prior to the plenary vote. You need to do it, when you want to file useful amendments for the plenary because when the official report is made available to be voted in plenary you don’t have the time to collect signatures for your plenary amendments anymore. Now, the same applies to international standards. When submitted fast-track the document should be ready. The BRM would normally include changes where you can take the BRM report and produce the text yourself. In the case of OOXML its impossible. You just have the original text and massive changes you cannot properly consolidate in time to base your decision on.

  2. Eric,

    Yes, the JTC1 rules allow the project editor to prepare the amended DIS *after* the

    vote, BUT…

    The JTC1 rules had been written for "regular" fast-track processes, where the

    initial DIS is almost OK, and where the BRM produces a few minor editorial

    comments. The present situation (i.e. a huge specification with a huge todo

    list resulting from hundreds of editorial, technical and general comments) is

    unparalleled in the whole history of the standardization.

    You are attempting to take unfair advantage of the "JTC1 rules" while

    the whole process has been driven out of the rules. The fast track option had been designed for nearly perfect drafts, not for projects that need a full reorganization and where a lot of paragraphs are waiting for a full rewriting. As long as you are off limits, you should not invoke the rules that apply to regular projects.

  3. Rob Weir says:

    Your steps 2 & 3 are not sequential.  They are concurrent.  Both must be completed in the same 30 day period after the BRM.  

    The only stated restriction is on when the SC Secretariat delivers the approved text to ITTF for publication.  That makes sense, since you don’t want to confuse ITTF with non-approved text.  But there is nothing here that prohibits the Project Editor from making this text available to NB’s.

  4. Rob,

    Regarding whether the steps are concurrent or sequential, ISO/IEC already ruled on this, and *you know it*.  And the text that I cite in the post clearly is an If/If/Then statement.

    You say, "But there is nothing here that prohibits the Project Editor from making this text available to NB’s".

    You are giving the IBM opinion about this, and this opinion is not in line with the ISO/IEC directives on what would be available before the end of the vote reconsideration period.  It was announced at the BRM that only the documents produced by the BRM can be used by National Bodies for their consideration.  Do you actually deny this?

    *Part* of the reasoning is that if the Project Editor produced a new draft of the standard and made it available after the BRM, it would be available for consideration only by National Bodies who reconsidered their earlier vote after the new draft was produced.  This would be unfair to National Bodies who’s scheduled meetings occured before the new draft was available.

    But the definitive reason that it can’t be delivered to National Bodies is that ISO/IEC prohibit it.  ISO/IEC have a number of reasons for this decision.  If you think that this is an erroneous decision, you should have taken this up with ISO/IEC.

    But you *SHOULD NOT* be informing National Bodies that it is an option to see the final draft.


  5. Rob Weir says:

    Eric, were you even at the BRM? I was sitting right next to the Ecma delegation and you weren’t there.  And you certainly weren’t on the US delegation.  You weren’t even on the Malaysian delegation.  So you are speaking on 2nd hand information.  I was there.  Don’t tell me what was said.

    The text you quoted clearly said that the final text of the DIS was due to the SC Secretariat "not more than one month" after the BRM.  So this is in fact concurrent with this 30 day voting period, and is due on Saturday.

    I and many others have serious reservations about approving a 6,000 page standard that is being refactored into 5 parts, with new scope and conformance clauses, the schema being divided into transitory and strict levels, over 1,000 other, sometimes conflicting, changes being made to it, and we’re not allowed to see the document we’re voting on?

    If you think that making the final draft available mid-month is unfair to those who voted earlier, then I’d say not having the final draft at all is unfair to all NB’s.

    Show me where ISO prohibits Ecma from making a new draft available? Remember, nothing said at the BRM has any binding effect on the process.  There were no JTC1 officers present at the BRM, and the BRM was not a JTC1 Plenary meeting. JTC1 does not make procedural rulings by word of mouth.  If there was a ruling, it would be in writing and you could point us all to it.

  6. Doug Mahugh says:

    Rob, Eric doesn’t need to show you where ISO prohibits Ecma from making a new draft available — the ITTF officer at the BRM already explained to all of us that the new draft would not be made available this month.  You heard that straight from ITTF, the people who will do the final review before publication of the draft.

  7. Some national bodies expressed an interest in seeing an updated draft of the specification that demonstrated how the 1,000 dispositions would be applied. The dispositions already had all the necessary information, but some folks wanted to see how it would be applied to the final spec. So the editor provided an updated draft of the spec and the XSDs before the BRM with all proposed changes applied.  While there were no outright conflicting resolutions, there were some that impacted others, and in those few cases the editor also provided a report explaining how he resolved them.

    Ecma made this available *before* the BRM, and every national body has access to it. The BRM then took on some additional changes which were fully defined at the BRM. There has been more than enough information available for a national body to know what the final spec will look like.


  8. Here are a few Open XML nuggets I’ve collected in the final days of consideration of DIS 29500 by the

  9. Its been two months since, and we still haven’t got the final text.

    It has even passed the SC34 Resolution which states that it should be distributed to SC34 members by MAy 1st. Its now the 5th.



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