DIS 29500 Technical Comments not Adequately Resolved Response 0001 This response is inadequate. Correct use of standards control language (shall, shall not, etc.) is not a matter for an un-reviewed “editorial pass”. Such changes are at the core of what the normative provisions of the standard are and how conformance is defined, and the definition of conformance is a primary purpose of a standard and critical to procurement decisions. NB's must see, review and approve such changes before deciding whether to approve DIS 29500. In the NB comments there are listed specific cases of where the control language was unacceptable. It is puzzling that Ecma has decided not to include specific text changes to address these specific points in their proposed Disposition of Comments. Response 0005 We disagree with the assertion that there “is no confusion” caused by the choice of the name Office Open XML. We raised concerns1 last year about the unfortunate confusion caused by the choice of the name “Office Open XML”, where mistakes were made by the press, analysts, even in Microsoft press releases. For example, Microsoft hosts a report on “Document formats and the value of choice in healthcare” on their web site2. This report argues against ODF and in favor of “Open Office XML”, but repeatedly referring to “Open Office XML”, making this error five different times. Within even the last few weeks we have seen many examples of confusion, by users, by analysts, by the press, and even by Microsoft's own enterprise architects. For example: ● January 11th – Cossacks.org.uk reports “Version 6.1 of Office Mobile finally brings support for Microsoft’s Open Office XML document formats, over a year after Office 2007 was released to businesses” ● January 14th – WindowsWorldNews.com reports on the Becta report “It also has recommended schools stick with the Open Document Format for storing files, rather than Microsoft's Open Office XML” ● January 15th, Pravda, with lead sentence “Microsoft’s Open Office XML and its competitor OpenDocument Format have always been rivals in the field of document formats.” ● January 15th -- eHacks blog announcing availability of a DocX convertor, “Microsoft introduced a new file format in Microsoft Office 2007 called the Open Office XML Format or simply known as .docx” ● January 15th – HighPosition.net article on recent EC investigation, “The Commission investigators will see if Microsoft has withheld information needed for interoperability from rival companies. They will also study the Open Office XML file format to see if Microsoft is releasing technologies that in effect, reduce compatibility.” 1 http://www.robweir.com/blog/2007/01/amusing-but-still-confusing.html 2 http://www.microsoft.com/uk/nhs/content/articles/document-formats-and-the-value-of-choice-in-healthcare.aspx ● January 16th Philippe Destoop, Microsoft's Enterprise Architect for Belgium and Luxembourg, posts a blog entry titled, “Document Standards : MS Open Office XML versus ODF”. ● January 17th Owen Allen, a Microsoft “technical specialist” reports in his blog the headline “Ecma Open Office XML Comments Completed Today” ● January 29th, ComputerWord New Zealand – “A second vote on whether to accept Microsoft’s Open Office XML document format as an official standard is slated for March.” ● February 8th, CNet leads an article with “European Union antitrust officials are looking into whether Microsoft violated regulations in its pursuit of making Open Office XML a standard”. This confusion is persistent and widespread. In fact, even the DIS 29500 Project Editor himself seems to have been confused, when in Response 374 he writes: “There is no specific definition of macro languages in the Open Office XML specification”. Our recommendation: We reiterate the request that DIS 29500 adopt a different name, one that is not frequently confused with a closely related product. Response 0016 Although the proposed resolution indeed removes the ST_LangCode, it keeps the legacy language ID table and simply associates it with the “\l” field argument. So, the proposed resolution does nothing but shift some text around and leave the same underlying flaw, namely two ways of identifying languages. We recommend the sole use of BCP-47 language tags, based on ISO 639. The dual-mode solution offered by Ecma provides no additional expressivity for developers, or any user benefit, but it does increase the cost to implementors. The need for legacy compatibility is acknowledged, but we believe that BCP-47 tags are directly and unambiguously mappable from the legacy codes, in a lossless way. In fact, at the BRM such a mapping table was provided. It should be the responsibility of those applications and converters that read the legacy binary documents to perform this conversion. It should not be a burden on implementors of OOXML. Further the resolution of this item was mangled by the BRM, when the Ecma proposed Response was replaced by a NB proposal as BRM Resolution #4. This BRM Resolution missed several of the fixe proposed by Ecma, and has left this language code section in an inconsistent state. For example, the original Ecma Response made changes to more field switches, to /f, /l, /m, etc. The meeting resolution, however, only changes /z. Response 0018 The changes made at the BRM maintain the legacy date basis as the default. We believe this is bad practice. For most date calculations, especially when dealing with issues of elderly health care or other citizen benefits, serious errors can occur when an application, by default, cannot handle dates before 1900. The default value for dateCompatibility should be false. Response 0031 Requests for harmonization of OOXML and ODF are seen in the ballot comments of many NB's, including requests from Canada, Korea, South Africa, Peru, France, Belgium and New Zealand. AFNOR, the French NB, gave a detailed proposal, which said in part: After 5 months of extensive discussions between stakeholders in the field of revisable document formats, AFNOR, in the aim to obtain a single standard for XML office document formats within 3 years, makes the following proposal: ● Split the current ECMA 376 standard in 2 parts in order to differentiate the essential OOXML core functions necessary for easy implementation from those functionalities that are needed for the exchange of legacy office file formats; ● Incorporate the technical comments below and those in the attached comment table submitted to the Fast Track; ● Attribute the status of Technical Specification to both parts; ● Establish a process of convergence between ODF (already standardized as ISO/IEC 26300) and the above mentioned OOXML core. ISO/IEC shall invite parties involved to commit themselves to initiate simultaneously the revisions of the existing ODF v1.0 and the OOXML core in order to obtain at the end of the revision process a standard as universal as possible. New Zealand's proposal was similar: ● OOXML should be considered by JTC 1 for publication as a Type 2 Technical Report. ● Seek to harmonize with the existing ODF standard to reduce the cost of interoperability, cost of having two standards, and cost of support/maintenance . In addition, the NB's of Great Britain, Brazil, Chile, Columbia, Great Britain, Iran, New Zealand, and the United States requested that specific features be added to OOXML in order to improve interoperability with ISO ODF, in total 40 features such as the ability to have more than 63 columns in a table, to have background images in tables, or to have font weights beyond “normal” and “bold”. These were the exact features that Microsoft's translator project on SourceForge identified as needed to improve translation with ODF3. Ecma rejected all of these requests. Ironically, their response was that harmonization is not necessary because there exist tools that will translate between OOXML and ODF. However, those very tools are restricted in their fidelity because of the lack of these features. So their argument is contradictory and circular. On the question of harmonization, we are either moving toward it, or we are moving away. The Ecma response does not move us toward harmonization, but starts down the road toward further divergence. 3 http://odf-converter.sourceforge.net/features.html#hUnsupportedDOCX Harmonization starts from looking at where the two formats overlap – and there is a significant, perhaps 90%+ area where they do overlap – and expresses the functional overlap in identical markup. As Tim Bray (co-editor of the W3C XML standard) pointed out in 2005, “The world does not need two ways to say 'This paragraph is in 12-point Arial with 1.2em leading and ragged-right justification'.” This common functionality between ODF and OOXML would also include a common extensibility mechanism. The remaining 10% of the functionality would represent the focus of the harmonization work. That portion of it which represents a general need could be brought into the core standard. That remaining portion of it which only serves one vendor's needs, such as flags for deprecated legacy formatting options, could be represented using the extensibility mechanism. Note that translation is a poor substitute for having a single format. If the translation can be done perfectly, then the necessity of two formats is questionable, and if translation introduces errors, it is clearly inferior to having vendors work more to converge their formats. There is no reason why, by a harmonization process, all of the functionality of Microsoft Office cannot be represented on a base of ISO 26300 OpenDocument Format. In fact, Microsoft acknowledges this much, in a recent statement by Gray Knowlton, Group Product Manager for Microsoft Office, quoted in PC Word4: Also, if individual governments mandate the use of ODF instead of Open XML, Microsoft would adapt, Knowlton said. The company would then implement the missing functionality that ODF doesn't support. However, those extensions would be custom-designed and outside of the standard, which is counter to the idea of an open document standard, Knowlton said.