Jennifer

ANSI has received the email below submitting a comment on a matter presently out for consideration by the US TAG for JTC 1.

As Administrator of the US TAG, please pass along this comment for their consideration in developing the US position on the question of a Fast Track Ballot for ECMA-376¦ ISO/IEC DIS 29500 Office Open XML File Formats.

Thanks
Henrietta

Henrietta Scully
Program Manager
Standards Facilitation
hscully@ansi.org

-----Original Message-----
From: Tammy Cravit [mailto:tammy@wordsofwonder.net]
Sent: Wednesday, January 24, 2007 11:15 AM
To: hscully@ansi.org
Subject: Comments Re: Ecma 376 Office Open XML standard

Dear Ms. Scully,

Earlier this month the Ecma International standards group submitted a
standard for fast-track ISO approval. That is the "Ecma 376 Office Open XML"
standard.

As an IT professional and the senior partner in a software firm which
generates the bulk of its revenue developing standards-compliant custom
software solutions, I am very concerned about the possibility of this
standard receiving ISO approval. In brief, this specification is so complex
(6,000 pages) and vendor-specific that it can only be successfully
implemented by Microsoft Office (the application on which it is modelled
after). It would effectively block all non-Microsoft IT developers (such as
myself) from competing on a level playing field.

An independent group of software professionals has analyzed the Ecma 376
standard, as submitted to ISO, and has identified a large number of concerns
with the proposed standard. These concerns principally fall into the
following areas:

- The Ecma 376 standard is needlessly complex, and in many places defines
behavior which is self-contradictory, or which contradicts other existing
ISO standards, particularly as regards date handling. (For example, Ecma 376
requires conforming implementations to reproduce a Microsoft Excel bug which
incorrectly identified the year 1900 as a leap year.)

- Ecma 376 relies on undisclosed information, including the behavior of
specific versions of proprietary Microsoft products. Since these behaviors
are not specified in the proposed standard, there remains no way for a
conforming implementation to verify that these behaviors are replicated
faithfully.

- Ecma 376 can not reasonably be implemented by other vendors. No patent
rights to implement Ecma 376 have been granted by Microsoft, and there
remains doubt whether Microsoft's existing End User License Agreements allow
the developer of a conforming implementation to reverse-engineer the
undisclosed information that is required by the standard. Also, significant
concern has been raised about Ecma 376's compliance with Ecma Article 2 of
the Agreemment on Technical Barriers to Trade.

- No significant functionality has yet been identified in Ecma 376 that
could not be expressed using the present ISO/IEC 26300 OpenDocument
standard. And, indeed, the ISO/IEC 26300 standard specifically allows and
enables the creation of new namespaces to extend its functionality as
required by implementing software vendors. As such, the need for a new,
complex and incompatible standard seems unproven.
 
The concerns over Ecma 376, as pertaining ISO approval, are summarized on
this page:

        http://www.grokdoc.net/index.php/EOOXML_objections

The initial review period ends in two weeks, on February 5th. If none of the
"P-Members" of the ISO/IEC JTC1 (Joint Technical Commitee 1) raise an
"contradiction", the specification will go through the "fast-track" process
towards ISO approval. The above page lists many contradictions in Ecma 376
as defined by the ISO rules.

The United States is a P-Member of the ISO/IEC JTC. I would like to make
contact with the individual(s) responsible for the United States' vote on
the JTC to discuss the contradictions in Ecma 376.

I was hoping you could answer a couple of questions:

- When will the US delegation be discussing the proposal to Fast Track the
Ecma 376 standard through ISO?
- What is the current position of the delegation on this proposal?
- Who are the responsible individuals whom I should approach with a detailed
critique?

Thank you very much for your assistance.

Yours truly,
Tamara Cravit, Senior Partner
Taylored Software
Lompoc, California