OOXML ballot comments 
2007-09-09, 10:46
The DIS 29500 ballot comments have been published on the SC34 web site (ZIP of Word documents).

Glancing through them, I am struck by how much is word-for-word identical between countries. Maybe countries shared comments (and certainly the open Wiki for UK comments may have been a source), or maybe some of the larger multi-national organisations reviewing DIS 29500 fed their pooled comments down to many different nations. Ultimately, though, the source of comments does not matter; what matters is whether they have technical merit.

Ecma, faced with the unenviable task of handling these comments, will need to de-duplicate them. My impression is that this will reduce the headline figure of “thousands” of comments to “hundreds”. I suspect the majority of these will probably prove resolvable without contention (indeed Ecma's own submission of around 80 comments already points in this direction). This will leave us with “scores” of comments, some of which could prove decidedly thorny. France's proposal, for example, that a core subset of OOXML is extracted for harmonisation with ODF, is unlikely to go through on the nod. And some types of comments, in the legal/IPR domain (demanding disclosure of patent information, for example) will need to be addressed in forums other than the BRM, which is concerned with creating the text of a technical specification, not a legal document.

When “Yes” means “No”?

One curiosity of the ballot results is the degree of skepticism accompanying the votes of approval. Normally an approval vote in an ISO ballot means that the technical content has been approved. However, some of the comments accompanying approval votes look to me like they crave resolution. Indeed, Greece has gone so far as to accompany its approval vote with the following statement:

If the Ballot Resolution Group fails to resolve satisfactorily the issues, then ELOT will reconsider its position and may cast a vote of disapproval during the BRG meeting(s) according to article 13.8 of the JTC1 directives, or may even appeal to the final adoption of the Standard.

This introduces a complication for the BRM. As convenor, one of my responsibilities is to run the meeting in a such a way that it maximises the chances of approving a text. One natural way of doing this is to de-prioritise comments that accompanied an approval vote, on the basis that those countries are already happy with the text. However, for Greece this evidently isn't an accurate assumption – and the same may be true of other countries too. I need to find out which ...

Felix Oxley 
2007-09-09, 12:05
"Ecma, faced with the unenviable task of handling these comments, will need to de-duplicate them."

Is it required or expected that ECMA publish its de-duplicated list? If so, is there a deadline for this?

Luc Bollen 
2007-09-09, 15:23
Alex, I'm surprised to see that the comments are provided by SC34 in ".doc" format. SC34 being part of ISO, I had expected that the files are provided in an ISO standard format, i.e. either PDF or ODF.

Are there any ISO rules or recommendations about the file formats to be used by the SC's ?

Administrator (Alex Brown) 
2007-09-09, 16:12

It's not required that Ecma publishes their de-duped list – it's up to them how they cope with the comments. While, for everyone's sanity, I expect them to de-dupe and identify comments, the only official obligation they have (as I understand it) is to produce a response document to the comments by mid-January 2008.

- Alex.

Administrator (Alex Brown) 
2007-09-09, 16:15

Looking at the relevant section of the JTC 1 Directives, you can see Word documents are an acceptable format. For ballots, the ISO templates are Word templates, which rather pre-decides the matter.

I believe ODF will shortly become an acceptable format within ISo too!

- Alex.

franco merletti 
2007-09-09, 21:29
Hello, Mr. Brown

Would you be kind enough to give your view about the following comment, regarding the goal and nature of the "fast-track" process? ( i have read it at IBM's Rob Weir blog ):

"Jason Matusow claims that "The next 6 months will be where the rubber really meets the road for the work on Open XML." This is nonsense. The work should have been done back in Ecma, before submission to ISO. Fast Track is not a standards development process. It is intended for standards that are already completed and for which there is already industry consensus, to quickly transpose them into International Standards. Fast Track starts at the last stage, the Approval stage, of ISO's 5 steps. By this point it is assumed that the text is complete, accurate, and has already been thoroughly reviewed." ( http://www.robweir.com/blog/2007/09/how ... k-iso.html )

By the way, i would like to ask one more question: do you find "reasonable" that ECMA had submitted DIS 29500 to ISO fast-track and then the same ECMA had auto-submitted +75 comments[1] to redraft it?

Thank you very much.

Franco Merletti

[1] http://www.jtc1sc34.org/repository/0904.zip file "J1N8726-14.pdf"

Administrator (Alex Brown) 
2007-09-09, 22:27

Well, the UK has come to take the view (with which I naturally agree) that these big standards like ODF or OOXML are not suitable for accelerated ISO standardisation.

However, we are where we are and there is nothing to be gained, so far as DIS 29500 is concerned, by re-visiting these past arguments. The UK's view was out-voted in the contradiction phase of this process, and things have moved on.

Rob Weir is right to suggest the text should have been in a better state when it was submitted, and Jason Matusow is right to assert that there is still work to do. Ecma's comment submission is line with both these views, and moves things forward. The countries had a chance to express their views on the quality of the text and it their views, not yours, mine, or other bloggers', which govern the process ...

- Alex.

2007-09-10, 12:43
Alex looking through the documents I woder whether the amount of duplication itself may actually prove to be quite helpful to your goal as convenor of "maximising the chances of approving a text" at the BRM.

I suggest this because the duplication also appears to give some indication of consensus amongst the NSBs on how to address the comments.

This may also resolve (bad pun) the complication you mention wrt comments such as Greece's too.

Alex Owen 
2007-09-10, 17:43
The proposal to split DIS 29500 into two TS docs with the aim of merging at leas the core TS into ISO/IEC 26300 (ODF) sounds interesting.

The question is does ISO procedure allow that kind of thing as an outcome of a fast-tack ballot resolution meeting?

Dark Phoenix 
2007-09-10, 19:38
Well, I imagine you can thank Microsoft for situations like the Greek vote, since it was them that have been telling the ISO committees that if they have problems with the spec, they should vote "Yes with Comments"... despite this violating ISO's own voting rules.

Todd Knarr 
2007-09-10, 19:56
On issues like the Greek vote of "yes with comments" when the comments appear more in line with a "no with comments" vote, it might be informative to ask them what they were under the impression "yes with comments" meant and where they got that impression from. If it turns out a significant number of voting bodies were under a misapprehension about what the voting options meant, that to me should be grounds for calling a halt and sending the matter back with clarifications. If NSB votes aren't being counted the way the NSB intended, that's a major issue I'd think.

Stefan Gustavson 
2007-09-10, 23:34
> One curiosity of the ballot results is the degree of skepticism
> accompanying the votes of approval. Normally an approval vote
> in an ISO ballot means that the technical content has been
> approved. However, some of the comments accompanying approval
> votes look to me like they crave resolution.

There was considerable confusion over this matter in the NB voting process. Lobbying actively encouraged a misunderstanding that criticism could (even should) be expressed as "yes with comments", and ECMA made premature and unwise promises that comments submitted even with approval votes would be addressed. This seems to leave you no other option than to address all comments, or at least ask each NB what their actual conditions for approval are. If not, you might end up with a lot of "yes" votes being changed to "no" at the BRM.

While this would be highly irregular, we have seen so many irregularities in this matter already that such a turn of events would not really be all that surprising.

David Farning 
2007-09-11, 00:12
Alex Brown,

I appreciate you taking the time to add some transparency to the BRM process through this blog.

I am also wondering about the public availability of the comments list. It would help remove confusion if the list could be broken down by duplicates, trivial fixes, and show stoppers.

David Farning

David Farning 
2007-09-11, 00:18

Sorry for repeating a duplicate question in my last post. For some reason, I was only seeing one comment when I just read your blog even though some of the comments seem to have been posted hours ago.

David Farning

Another Stephen 
2007-09-11, 03:20
ECMA should be asked to produce a reference implementation as part of their reply. Given the extaordinary complexity of the proposed standard there's no way to really assess all the permutations without actually seeing the proposed standard being applied in real life.

Administrator (Alex Brown) 
2007-09-11, 09:50

Will the duplication be helpful? Yes, the more consensus there is on ways to resolve the common comments, the better. Then the meeting can move on to those thornier-to-resolve comments ...


Formally, there is no constraint on what the meeting may decide, but practically speaking it won't be possible, in the time, to formulate instructions to the project Editor on how he might amend the text to merge it with ISO/IEC 26300 (ODF). Any country that maintains the position of requiring such a merge now is effectively bound to disapprove the DIS 29500 text - effectively this position would be a wrecking amendment, and would be a way to reassert an objection of "contradiction" from early in the process (which countries are perfectly entitled to do).

Any initiative to merge the standards into a Grand Unified Document Format is more likely down the track, possibly as a new ISO work item, and maybe it that case would be a good idea then to think about incorporating stuff from UOF too. However, I understand there are still scars in ISO from the politically contentious and ultimately futile ODA project, to which this might seem similarly grandiose.

@Stefan, Todd, Dark Phoenix

The JTC 1 Directives are clear that NBs should vote to disapprove if they have technical concerns which need to be overcome.

Ultimately, one could take the view that this doesn't matter, as countries are free to flip their vote to "disapprove" after the BRM. This is permitted, but unusual - but then lots of things about this process are unusual.


As I've commmented elsewhere, it's up to Ecma how they go about managing the comment response process. It's possible that in the UK their response document will be reviewed on an open (to read) Wiki ...

@Another Stephen

ISO rules forbid reference implementations. The thinking is that the text must itself by complete, self-contained, and authoritative; a reference implementation opens the possibility of deviation from the text, thereby creating uncertainty about which is "right".

That said, in SC34, we follow the practice of informally requiring that our "home-grown" standards (RELAX NG, NVDL, Schematron etc) are proved efficiently implementable during standardisation. If my time wasn't so taken up with DIS 29500 I would be working on an implementation of DTLL in Java to accompany the draft standard, for example!

Todd Knarr 
2007-09-11, 16:44
The JTC1 instructions are clear, yes. But there've been reports that NSB members have been told that "yes with comments" is the proper vote for a conditional approval if issues need to be addressed before the standard is finalized. In addition, it appears that a large number of NSBs have some very new members sitting on them who've not been through this process before and may not be completely familiar with the JTC1 rules. That would be the perfect combination for a misunderstanding. And while those reports may be biased, you aren't (at least I hope you aren't) and you've noted major aspects of the votes that seem to indicate a misunderstanding (as you noted, many of the comments are of the sort that indicate major technical problems with the standard in the view of the NSB, yet the vote is a yes). When a neutral party is noticing the same things those reports are indicating, to me that makes it much more likely that there's something there beyond just bias on the part of the reporters.

I don't think a clarification can hurt here. There's enough time, it shouldn't interfere with anybody's schedule to confirm with the NSB representatives that they really mean to approve basically as-is (which, AIUI, is what "yes with comments" means to JTC1). And if it turns out they were under an incorrect impression that "yes with comments" meant the comments had to be addressed or the standard wouldn't be finalized, then there's time for them to deal with the situation before the BRM and nobody will be blindsided.

Jim Black 
2007-09-11, 19:13
Please explain the following line from your initial entry:

This introduces a complication for the BRM. As convenor, one of my responsibilities is to run the meeting in a such a way that it maximises the chances of approving a text.

In the parlance of my part of the world, this will always be interpreted that the BRM must try to Ram the document through regardless of the comments. I find it difficult to believe that the is the purpose of the convenor since it essentially says to ignore all negative votes and comments.

Administrator (Alex Brown) 
2007-09-11, 19:49

The ISO mechanism for NBs to express what "they really mean" is provided by the ballot resolution process - that is their next input into this standardisation project. Until then, of course, there is nothing to stop NBs issuing public statements to clarify their position; but that is the domain of public relations, not standards activity.

@Jim Black

Ramming through? No, on the contrary - the requirement to maximise the chance of resolution at the meeting (which is, after all, its purpose) will mean that negative votes/comments get priority and are not (as you suggest) "ignored".

- Alex.

Todd Knarr 
2007-09-11, 20:03
@Jim: I don't think it's meant that way. What it means is the meeting itself isn't supposed to throw any roadblocks in the way of approval. Negative votes scotch the approval, but if the majority voted in the affirmative then quibbles over comments and procedural technicalities aren't supposed to block that affirmative vote.

That's the reason, I believe, that JTC1 says conditional approval (ie. the standard would be OK but only if issues are addressed first) is supposed to be expressed as a negative vote with comments describing the issues.

Andrew Sayers 
2007-09-11, 22:03

While I don't like Jim Black's implication that the standard would be rammed through without respect for comments, I'd like to press you on a related issue: that the BRM might give undue emphasis to comments from swing voters.

If it's natural for you to de-prioritise comments that accompanied an approval vote, it seems natural that you'd also de-prioritise comments that accompanied a wrecking amendment (since those countries will never be happy with the text). And if you choose to enforce a hard limit on the amount of time for the BRM, any comment that would take too long to address would automatically become a wrecking amendment.

It seems to me that your best strategy is therefore to concentrate on NBs with only minor comments, ignoring countries with major concerns. Do you expect the BRM to concentrate on these swing voters, and if so, do you see that as a problem?

- Andrew Sayers

Rick Jelliffe 
2007-09-12, 04:29
Ecma's response in January will obviously have enough changes to get DIS 29500 at least over the line. One would expect that MS, for their marketing requirements, would be pushing that at least some of each NBs comments are addressed, rather than it being a simple-minded "lets satisfy the minimum number of NBs" however.

So if Ecma's fixes are uncontentious, that leaves more scope in the BRM to look at the contentious issues, hopefully to come up with some creative solutions that satisfy all the interested parties. If Ecma's response is enough to get over the line, then I suppose the priorities of the NBs against Open XML switches from opposition to harm-reduction, and a collaborative stance. Cool.

I strongly suspect that MS/Ecma would not accept changes that make existing documents invalid, however, since that counter runs to the point of the format. So existing ways of doing things are more likely to be maintained but deprecated rather than stripped out, I suspect.

(Similarly, I suspect there would be pushback from NBs on any attempt to increase the size of the standard by anything other than trivial amounts.)

But this is just the start of this part of the review: things will become clearer over the next months.

Administrator (Alex Brown) 
2007-09-12, 07:59

I think your line of reasoning is right, but I'm not sure your conclusion - that only minor comments will get aired - is. I hope the meeting will be able to dispose of the minor comments quickly and have time to get onto bigger questions.

Swing countries? Swing issues? Maybe - in my view it's right that the meeting should prioritise those issues which are of most concern to the NB participants, so long as they are realistically resolvable ...

- Alex.

Administrator (Alex Brown) 
2007-09-12, 08:08

One wrinkle in the process is that Ecma has no discretion over which meeting resolutions to accept. If the meeting agrees a new text, its will is absolute, and the project editor has to implement its instructions.

ISTR when we were standardising Schematron you argued (successfully) that SC34 should not make alterations to the spec which would invalidate the existing corpus of Schematron documents.

It remains to be seen whether a parallel argument, about the existing corpus of OOXML documents, will hold sway with the NBs participating in this project ...

- Alex.

2007-09-13, 19:30
"One wrinkle in the process is that Ecma has no discretion over which meeting resolutions to accept. If the meeting agrees a new text, its will is absolute, and the project editor has to implement its instructions."

IMHO, this is relative. The only "new text" that seems will be discussed in the BRM is the one which will be proposed by ECMA ( Microsoft ), which for sure will be crafted in such way to avoid any problem to Microsoft and his investments ( MS Office 2007 and "interoperable" related server products ).

i.e.: MS won't pay the "damages" of this rushed fast-tracking +6000 pages beast, they will try to minimize the changes to the spec and the important issues will be superseded by minor changes, mostly editorial or new deprecated-XML-soup.

Sad year for XML and for standardization.

Something is wrong that needs fixing.

Administrator (Alex Brown) 
2007-09-14, 08:17

Ecma's new text informs the process, but the NB participants will no doubt have their own ideas about how comments can be satisfactorily resolved. Their deliberations at the meeting will ultimately decide what the final "new text" is, and in order for it to be accepted they (not Ecma, not MS) need to approve it.

- Alex.

Rick Jelliffe 
2007-09-14, 12:26
Alex: Sure. But it is a mistake to think of Ecma and MS being reflexively against any changes, them against the BRM.

2007-09-15, 00:57
"@Rick Jelliffe said:
Alex: Sure. But it is a mistake to think of Ecma and MS being reflexively against any changes, "

good joke :-), keep writing this master-pieces rick

"Their deliberations at the meeting will ultimately decide what the final "new text" is"

@Alex, i appreciate your work and how you try to be optimistic about this.

But with my respect, some of your comments seems to follow the premise that all this process ( fast-track of DIS 29500 ) was ( and is ) a "normal" one. I don't think so. It has been convoluted and subverted. i.e: 9 national bodies suddenly becoming P members and voting approval to +6000 pages ( 5 of them "inconditional approval" ), while others like UK submits 98 pages with +600 technical comments, other NBs annulling ballots ( Sweden, Mexico ), a lot of NBs abstaining, other voting "Yes" but saying that could appeal the adoption of the standard ( Greece ), etc.etc.

I believe that this will continue to be a polemical/political/commercial process and the technical discussions will again be relegated and superseded by "system gaming" ... Microsoft is interfering too much in this process, i have lost my trust on it. I hope i'm wrong.

Why ISO JTC1 didn't press the brakes when so many countries alerted that this +6000 page beast was not suited to a fast-track process, at the end 30-month ballot period ( this is common sense[1] ! ) ? ( rethorical question )


[1] http://en.wikipedia.org/wiki/Common_sense

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