in070181
From: Paul J. Morris [mole@morris.net]
Sent: Wednesday, January 24, 2007 12:57 PM
To: Garner, Jennifer; Scully, Henrietta
Cc: bryden@iso.org
Subject: Paul Morris Contribution in Response to JTC 1 N 8455 -
30 Day Review for Fast Track Ballot ECMA-376 | ISO/IEC DIS 29500 Office Open
XML File Formats
Dear Sir or Madam,
Earlier this month ECMA International submitted a standard for "fast-track"
ISO approval. That is the "ECMA 376 Office Open XML"
standard. (ISO/IEC DIS 29500)
ECMA-376 is a standard for "word-processing documents, presentations, and
spreadsheets" which overlaps completely with an existing, approved standard
ISO/IEC 26300:2006 (OpenDocument (ODF)). Therefore it conflicts directly
with ISO's goal of having one standard for any area.
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).
ECMA-376 also violates section 2.14 of the ISO/IEC Directives, Part 1, in
that not all of what it takes to implement the standard is covered by the
licensing conditions offered by Microsoft.
Numerous concerns over ECMA-376, as pertaining to ISO approval, are summarized
on this page:
http://www.grokdoc.net/index.php/EOOXML_objections. The page lists many contradictions
in ECMA-376 as defined by the ISO rules.
ECMA-376 contradicts numerous international standards. To give three
examples out of many, contradictions include the Gregorian Calendar, ISO
8601 (Representation of dates and times), and ISO 639 (Codes for the
Representation of Names and Languages). ECMA-376 section
3.17.4.1 (page 3305) conflicts with the Gregorian calendar in the calculation
of dates. It requires spreadsheet implementations to incorrectly treat
the year 1900 as a leap year. This contradicts the Gregorian calendar, ISO
8601 and the civil calendar adopted by most nations of the world. This
section further stipluates that dates must be counted as numeric codes from
1900 or 1904, and that applications may not support years prior to 1900.
In the field of Biodiversity Informatics, the correct representation and
handling of dates from 1758 to the present is important for the correct handling
of species names under the rules of the International Commissions for Zoological,
Botanical, and Microbial nomenclature. ECMA-376 section 2.18.52 page
2530, ST_LangCode, requires the use of a fixed list of numeric language codes
encoded in two hexidecimal digits rather than the already existing set provided
by ISO 639. This is a conflict with ISO 639. The limitation of the
language code to two hexidecimal digits restricts the total possible number
of language codes in ECMA-376 to 256. This is substantally fewer than
the number that can be represented with the three letter code of ISO 639-3,
a standard that is capable of indicating each of the more than 6700 languages
in the world. In Biodiversity Informatics, we deal with both the scientific
and common names of organisms, and and those common names may be in any of
the 6700 odd languages of the world. Metadata conforming to ISO 639
are thus important.
The 1900 as a leap year requirement of ECMA-376 illustrates many of the problems
with ECMA-376. ECMA-376 puports to be a document storage format, but
repeatedly proscribes the behavior of applications that open documents in
that format. Rather than specifying date storage in a form consistent
with ISO 8601 and leaving a fix of the incorrect behavior of MS Office up
to code that exports documents from MS Office to ECMA-376,
ECMA-376 stipulates that all applications which open documents in the
ECMA-376 format must replicate the incorrect behavior of MS Office.
ECMA-376 is very long and complex, and appears to duplicate ISO/IEC 26300:2006,
much of the additional length and complexity appears to come from poor generalization,
lack of adherance to existing standards, and overall poor design.
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 a
"contradiction", the specification will go through the "fast-track"
process towards ISO approval.
I believe, and I hope that you will agree, that this standard should not
be allowed "fast-track" approval. Rather it should be remanded to Ecma International
for: (i) harmonization with ISO/IEC 26300:2006 and numerous other standards
and (ii) development of more suitable intellectual property documents.
Sincerely,
-Paul
--------------
Paul J. Morris, Ph.D.
Biodiversity Informatics Manager
Harvard University Herbaria/Museum of Comparative Zoölogy mole@morris.net
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