"Yes with comments" for Open XML

Germany just announced that their vote for Open XML will be “YES with comments”. The INCITS Executive Board in the US has approved a ballot for consideration that is “YES with comments“ and a vote will be taken for this on August 22. Yet, there is an ongoing question from folks in the community as to whether or not “YES with comments“ is a viable vote if those comments are to be considered in both the ballot resolution and long-term maintenance process for a standard. This question ties into the complexity of how specifications get created, what the rules are that govern their consideration, and what commitments are made by organizations and individuals involved with their maintenance. Here is why “Yes with comments” is a valid vote:

  1. The Rules: Before looking at any other factor, it is absolutely within the scope of JTC 1 rules for organizations to cast a YES vote and to add technical and other comments to that vote. Comments may be added to YES, NO, or ABSTAIN votes. If a national body casts a NO vote, they must provide comments with the vote. But, that is not the only way comments get considered. The whole point of the ballot resolution process is that comments get considered and responded to for all comments, which will then be considered by the national bodies. At the end of the process, they have a period of time to revisit their position and communicate a revised vote to JTC 1. The argument that a NB has no leverage in the BRM process if they vote YES is simply not true. 
  2. Precedent: YES with comments is an established practice with national bodies. A small amount of research shows that INCITS, the arm of the US national body that handles all JTC 1 technical matters, has submitted 22 “YES with comments“ votes in the past 4 years – including specs developed at Ecma International, and OSS-related specs such as the Linux Standards Base Core Specification 2.0.1.
  3. Maintenance Commitment: As I have blogged about recently, Ecma has made a clear statement that they are committed to considering ALL comments in the analysis document they will prepare for discussion at the expected Ballot Resolution Meeting. Ecma’s TC45 will be meeting frequently to prepare their analysis after the aggregated comment list is distributed to all voting National Bodies.
  4. Specs are not perfect: Technical specifications are never perfect – they always may be improved. This is the whole reason there is a maintenance plan requirement when specs are submitted for consideration in either the PAS or Fast-Track process. Both PAS and Fast-Track submissions are initially balloted as a proposed DIS (draft international standard) which means significant work was done by a qualified working group or technical committee, and the process and engineering meet the ISO/IEC requirements for PAS or Fast-Track status. But – it also means that the DIS (rather than the WD or CD forms in the case of the full process) is the first formal view of the spec given to a national body. Therefore, unlike the 30 or 45 day norm for timeframe of consideration of a spec at the industry consortia level – the national bodies have a 5-6 month voting period, plus another 3-6 months prior to the BRM, to consider the Fast-Track or PAS DIS. (Just to be clear, ODF 1.0 went through JTC 1 as a spec that clearly needed significant technical improvement as can be seen by the ongoing work from OASIS.)

Aside from these procedural-related elements, there are some big picture considerations for Open XML specifically.

  • Direct Requests For Standardization: Detractors of Open XML often downplay or ignore the fact that the impetus behind the standardization of Open XML in no small part came from governments who felt it was in their best interest to have the Microsoft default XML format used in the Office product be standardized and for the broadest international community to have an ongoing voice in its evolution. Good examples of this are the European IDABC in their Valoris report of 2003, TAC recommendations of 2004, and the PEGSCO recommendations of 2006. Voting YES on Open XML affirms these findings, and the comments (in light of the 4 points above) enable them to express their desire for technical issues to be considered. The BRM process and the commitment from the Ecma TC combine to provide the national bodies with a robust vehicle for technical concerns to be reviewed to address perceived issues.
  • Greater Openness and Choice Is The Goal: It is in the best interest of national governments to aggressively encourage openness in document formats. Interoperability, choice of commercial solutions, competitive opportunity for local software producers, long-term archival – these are a few of the goals of which everyone is supportive. But, this does not mean only one format. Governments want to see innovation, they want technology to progress rapidly and with the maximum opportunity for all parties (level playing field) and choice. Innovation tends to be more about the apps than the formats, but the formats should not become a blocker to the innovation of the app. Nor should innovation around interoperability be limited to standardized components. Voting NO for Open XML, in my most humble opinion, is a vote against greater document openness. 
  • Independent Implementations: In the 9 months since Open XML was standardized at Ecma, there are already significant independent implementations which demonstrates that the spec is absolutely mature enough for real commercial use. Standards organizations, including JTC 1, do care about market relevance of their approved specifications. Given the multiple, independent implementations of the Open XML specification that includes diverse platforms (iPhone, Palm OS, Windows, Mac, Linux) and a broad spectrum of applications, it is clear that the Open XML spec is mature enough, and sufficiently sound from both a technical and legal perspective for implementation. Again, if ISO/IEC ODF version 1.0 is the yardstick to measure Open XML in terms of spec readiness – then there is no question that a YES vote is reasonable. As I stated above, the spec is not perfect and many of the comments included with the votes can improve the specification.
Comments (14)

  1. marc says:

    "A small amount of research shows that INCITS, the arm of the US national body that handles all JTC 1 technical matters, has submitted 22 “YES with comments“ votes in the past 4 years "

    yes…but here ( with OOXML) you have +400 comments in less than 4 months !!

  2. jasonmatusow says:

    Hi Marc – I’m not following your comment. I think you are mixing up issues. The Open XML DIS has many comments (primarily from IBM – hundreds more than anyone else in most countries).

    That is different than a national body voting "yes with comments." There have been concerns raised about the validity of that vote, and some present it as a "just not done" kind of thing. Clearly, that is not the case, and I’m sure those same folks would not want to revisit the Linux Standards Base vote which carried comments.

    The real issue is about the ballot resolution process and how these comments are addressed.



  3. yoonkit says:

    > has submitted 22 “YES with comments“ votes in the past 4 years

    Can you point to some of these yes with comments?

    I would like to see if these comments are merely editorial or general comments, or have extensive technical issues with the DIS.

    I hope you are not pointing to submissions like Romania’s recent "Yes to Fast Tracking" with comments of "we agree with the project as it is"


  4. Imi cer scuze fata de cei care s-au saturat de postarile mele legate de standardizarea Open XML, dar

  5. marc says:


    i will quote the JTC1 directives for you:

    JTC1 Directives1, Section 9.8: Votes on Fast-track DISs:

    “The period for fast-track DIS (or DAM) voting shall be six months, consisting of a 30-day JTC 1 National Body review period followed by a five-month ballot

    period. NBs may reply in one of the following ways:

    ● Approval of the technical content of the DIS as presented (editorial or

    other comments may be appended);

    ● Disapproval of the DIS (or DAM) for technical reasons to be stated,

    with proposals for changes that would make the document acceptable

    (acceptance of these proposals shall be referred to the NB concerned for

    confirmation that the vote can be changed to approval);

    ● Abstention (see 9.1.2).

    [Note: Conditional approval should be submitted as a disapproval vote.]”

    As it says, an "approval" vote is approval of the technical content "as presented."  

    For a Disapproval vote, the language clear says disapproval is made for specifically stated technical reasons along with proposals that would make the DIS acceptable, and that if these changes are made the NB has the opportunity to change their vote to Approval.  

    This mechanism is called out again a few lines later when it speaks of "conditional approval" and that it should be registered as a Disapproval vote.

    What part do you don’t understand ?

    With my respect, are you or MS "gaming" the system? you are crossing many lines with this …  does the "ISO stamp" worth it?

  6. andre m says:

    It is a gift with nothing in return. Germany approves a broken spec and submits 12 pages for improvement that can only be taken into account enough nations vote no

    Time to put the kibosh on Microsoft. I don’t understand at all why Microsoft Germany sits a national standard committee.

    IBM comments are bug reports. It does not matter who finds an othographic mistake, same for technical issues. It would be appropriate to thank IBM for their review work rather than to attack Kenia for their submission. But what you did with Kenia and Germany was totally inadmissable.

  7. hAl says:

    [quote]It is a gift with nothing in return. Germany approves a broken spec and submits 12 pages for improvement that can only be taken into account enough nations vote no[/quote]

    That is actually not true. The IS/IEC JCT1 committe could go with a ballot resolution meeting even if only one countries has a no vote and all others have approval with comments.

    Also since Ecma already indicated it is working on the comments they will also prefer a ISO standardization related version update of Office Open XML to implement the findings in those comments thru the ballot resolution process.

    [quote]It would be appropriate to thank IBM for their review work [/quote]

    Which would have appropriate if they has participated in Ecma TC45 in stead of submitting them during the ISO standardization process.

  8. Sam Hiser says:


    It’s all beside the point.

    OOXML cannot reasonably be permitted to be a standard or part of a harmonized standard because it contains ties to proprietary software services outside the technical scope and domain of the document format & its immediate application.

    This is why your statements about openness & interop are falling on deaf ears.

    There is every reason your bid should succeed because your company is successfully infiltrating the standards process with money & influence. That does not make OOXML open in any way.

    Your ‘openness’ and ‘choice’ language is noxious because of its deceptive intent. Your own reputation is suffering because it makes you a participant in a Fraud.

  9. I was out for the past week at a family event in Winnipeg. I didn’t have any access to e-mail or internet

  10. I was out for the past week at a family event in Winnipeg. I didn't have any access to e-mail or

  11. jasonmatusow says:

    Yoonkit and others – the point of the posting is that there is precedence for the yes with comments vote. In fact, the vote for ODF was yes with comments – not just in the US, but in many other countries as well.

    Marc – it is not about "gaming" the system. It is about working towards the approval of the specification. I find it interesting that the efforts to have a broadly implemented specification that has a huge amount of market relevance is considered "gaming" and the work to block that same standard is considerd just behavior. I realize as I write this that you guys are going to snipe at this comment – but a dispassionate view will show that all parties are working hard towards their desired end goal.

    For others who keep brining up the idea that MS having people sitting on the committees and chairing some are not paying attention. IBM and others hold seats and chairs in committees as well. Ctrambler and Rob Weir called me on this on an earlier posting as I went to far in insinuating that having the ODF editor as chair of the V1 committee raised questions. Standards professionals are often expected to both represent their interests in the standards setting activities AND be impartial committee chairmen who run the meetings etc. etc. Let’s not lose site of this as it was a good point when made before.



  12. Andre M says:

    Okay, we have two positions:

    a) "Approval of the technical content of the DIS **as presented** (editorial or other comments may be appended)"

    This is what the rules say.

    b) Yes to the unmodified specification or disagreement with the unmodified spec (Yes with Comments, No with comments, NO)

    That is what you claim.

    But after all the Microsoft format is no needed as we already have ISO 26300. Why get a buggy second file format? Why a second format where we expect Microsoft to play games with us, I mean the patent stuff.

    Rob Weir and numerous other people found over 200 issues because the format is as bad as that. I can only fully endose what Avi from IBM Brazil wrote: "I was a member of the technical group that have studied OOXML specification extensively. I learned that it is unbelievable how ECMA … can think that a wannabe spec like OOXML is ready for submission. It is incomplete (does not provide mappings with legacy standards, since compatibility is OOXML goal), too long (6000+ pages), fully tied to a single product, uses deprecated substandards, promotes bad practices (embedded binary objects), has clear proprietary hooks (like “formatAsWord95″ XML tags), reinvents the wheel all around (date and color formats etc), and most of all does not have a standards-grade look and feel required for a universal and (virtually) eternal document format (doesn’t have to be perfect, but can’t be that imperfect)."

    Why don’t you support ODF. File conversion from the old legacy formats is better anyway.

  13. As I said in my last post, Open XML did not get approved. Frankly I was going to leave the topic alone