As I reported recently, the Massachusetts ITD has announced its intention to add Microsoft's OfficeOpen XML specification (now Ecma 376) to its list of approved "open standards," subject to a very short comment period that will expire on July 20. I have great concern that such a decision may be as influential outside of Massachusetts as was the original decision by the ITD in August of 2005 to include ODF, and exclude OOXML. That first decision raised the credibility and visibility of ODF dramatically, and it is fair to say that all of the later successes of ODF were made possible by that decision.
While the ITD has now announced that it believes that Ecma 376 has met its requirements, it is important to note that two years ago it reversed a similar conclusion as a result of energetic public input. That can happen again, and interim CIO Bethan Pepoli has stated as much in a widely reported quote.
Whether the ITD truly believes that Ecma 376 meets its requirements, or whether it has finally folded to the significant and ongoing pressure to which it has long been subjected cannot be known. But what is clear to me is that if enough people provide carefully considered and persuasive comments to the ITD prior to the expiration of the comment period, the ITD will be given an opportunity and the "cover" to reverse its position if it so wishes.
Preparing such comments is time consuming, but it is also important. I took several hours to do so yesterday, and have just sent them to the ITD. You can to, and I hope that you will. The ITD's comment address is email@example.com, and the deadline is next Friday. If you're a believer in open standards, please don't let that deadline pass without making your thoughts known.
Here are the comments that I sent in:
July 9, 2007
- Will Ecma 376 become a true consensus standard? Like any other vendor, Microsoft will be free to completely implement Ecma 376, or only partially implement it. As the dominant product implementing Ecma 376 as a complete office productivity suite for the indefinite future, there will be little chance that the working group further developing the standard will include any feature that Microsoft does not intend to support, as the utility of such an extension of the standard would likely be nil. As a result, any future evolution of Ecma 376 will be far more influenced by Microsoft than has any prior "open" standard been influenced by any single vendor.
- Will Microsoft continue to contribute all new features it develops to Ecma 376? Like any other vendor, Microsoft will have no obligation to offer future technology to Ecma. But as the dominant office suite provider, any proprietary extensions included by Microsoft in Office will become part of the environment of the "billions and billions of documents" that Microsoft has pledged to protect with OOXML. Past history has shown that the creation of proprietary extensions to standards by Microsoft has often served to weaken, or defeat such standards. If any such extensions are created, then many, and perhaps most, users will conclude that the only "safe" office suite to use will be Office. Again, is any standard truly "open" if its continuing utility is based upon the future product decisions of a single vendor?
- Will there be true choice in the marketplace? At 6,039 pages, it is unlikely that any office suite will be created that fully implements Ecma 376. Not only would the smagnitude of the challenge of developing a full office suite that natively supports OOXML (as compared to merely saving to OOXML through translators, as will be the case with Novell’s version of OpenOffice) be daunting, but Microsoft would always have too vast a lead, as well as too much of an advantage in Ecma regarding future features. As a result, the ability to exchange documents with true fidelity between Office and any other product is likely to remain low. Can any specification that is today fully and natively implemented by a single proprietary product be truly considered to be an "open standard?" Is such a standard not instead simply useful for creating conversion tools to be used in connection with a single proprietary product?
- Will there be true innovation in the marketplace? The microscopic level of detail represented by those same 6,039 pages will place a straitjacket on innovation, restricting any implementation to rigid conformance.
- Will there be true competition in the marketplace? For more than a decade, no new effort of significance has been launched to challenge Microsoft’s dominance in office productivity software. Since the ITD’s decision, however, that marketplace has become energized, with more than a dozen proprietary and open source office suites available, all of which share one characteristic in common – they all implement ODF, and their developers are all relying upon the hope that customers will find value in that fact.
Very truly yours,