IBM Statement For the Commonwealth of Massachusetts Senate Audit and Oversight Committee

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As I have noted here and others have mentioned elsewhere, there is a hearing today in Boston to discuss the decision by the CIO’s office that support for OASIS OpenDocument Format be required for documents that are created, modified, and saved. IBM sent our statement to Senator Pacheco, Chair of the Senate Audit and Oversight Committee, on Saturday. Here, for the record, is what we sent. For those of you who have been following this blog, what we say shouldn’t be anything new. We’ve refined a few things and how we say them but we’re basically staying on message: support of ODF is good for Massachusetts and good for other governments as well.

IBM Statement
For the Commonwealth of Massachusetts
Senate Audit and Oversight Committee

October 28, 2005

Dr. Robert Sutor
Vice President, Standards and Open Source
IBM Corporation

Mr. Chairman and members of the Committee, IBM welcomes this opportunity to submit written testimony for the public record on our views of the Commonwealth of Massachusetts publication of its Enterprise Technical Reference Model v.3.5, which identifies the OASIS OpenDocument Format for Office Applications to be the standard for all official records the Commonwealth creates and saves.

IBM appreciates the leadership of your Committee in examining this issue and the efforts of the CIO’s office to have an inclusive process for arriving at this decision: engaging stakeholders, holding forums, posting draft technical references and soliciting comments. IBM, with its nearly 5,000 employees in Massachusetts, was pleased to participate in some of these discussions and looks forward to continuing to support the efforts of this Committee and the work of the Commonwealth.

This decision of the CIO’s office, similar to that of many public and private institutions across the globe, recognizes the value—personal and economic—of choice with information technology. IBM supports the recent publication as it guarantees citizens and governments access to and control of their own data. I will lay out four key reasons why IBM believes this decision is the right decision for Massachusetts. I will conclude with IBM’s call to action to governments across the globe on this issue. But first, let me set the context.

This decision to insist on open document formats for office applications is the right critical decision at the right critical time. In technology, life sciences, healthcare, and other areas, there is a strong trend toward “openness.” With the creation of the Internet and the World Wide Web, both based on open standards, the value of open standards for interoperability and innovation became readily apparent. This openness is continuing to shift control of information and technology choices from vendors to individuals, businesses and government. OpenDocument Format (ODF) which, as you know, is a new open standard from OASIS (with headquarters in Billerica) based on literally decades of industry experience, enables this openness and shift of control. With ODF, governments gain greater control of their information and the technology that supports it. Governments get increased efficiency, more flexibility and options in technology choices, and enhanced capability to communicate with and serve the public.

Let me elaborate on these ideas along four key dimensions: accessibility; cost; freedom of action and control, including archiving and preservation; and innovation, competition, and economic opportunities for companies large and small.

First, I will address IBM’s position on accessibility. IBM is committed to, and is a leader in, providing and ensuring accessible products. We have been working closely with the accessibility community for a number of years and have engaged with them on this specific issue. We have also engaged with the OASIS ODF technical committee to form a sub-committee on accessibility to review the specification in order to enhance, as needed, accessibility compatibility. IBM is committed to working with the Commonwealth of Massachusetts, the accessibility community, and other vendors, including those on the technical committee of OASIS, to create a marketplace of ODF-compliant and fully accessible products, such as our Lotus Workplace managed client, a product developed in Massachusetts.

Second, when measuring costs, there are two main financial considerations: the cost of migrating to open standards-based products versus the cost of accepting the status quo and the attendant lack of interoperability. Obviously, the number of records in electronic form is growing every day and therefore migration costs will grow as legacy issues compound. It is likely that migration to an ODF-based product will be substantially less costly than alternatives in the long run since purchasers will have many more cost-competitive alternatives available to them and greater freedom of action in their use of their technology.

As for training costs, I want to bring to your attention a recent study by Gartner, a leading global technology analysis and research company headquartered in New England. Conversion to a new product or migration to a new product upgrade may present some technical challenges, largely in the area of training. Gartner published that “Office 12,” next year’s update to Microsoft Office 2003, which will use a new XML-based Microsoft proprietary document format, will differ significantly from its current form. The report concludes that migration may be rough for some users and the IT departments that support them. We believe that moving to an ODF implementation would involve the same, if not less, technical complexity, training and compatibility challenges than migrating to Office 12.

Third, let me address freedom of action in terms of future access and control, both of which should not to be underestimated. The ODF standard is maintained by an open group ensuring that the specification can not be changed by the whim of a single vendor to its own advantage. This vendor neutrality also creates a shift in control from the seller of information technology to the users. Indeed, users can actively participate in the future development of the standard, contributing both their requirements and knowledge. Further, owners of the data and documents can control how they can use them. Open document formats provide governments with options that were not previously feasible. With unnecessary vendor control points removed and a level playing field created, technology and service procurers can now be far more flexible and responsive to changes in the economy, new technological advances and citizen needs. That is, ODF is good for procurement.

It is critical to understand that this freedom of action is guaranteed by the openness of the standard and the community standards creation process. We define a document format as being open if it adheres to all four of the following elements. The definition aligns with that of many governments, including this Commonwealth CIO’s office, and the Berkman Center at Harvard Law School’s report on Open Ecosystems that had 13 nations participating in its definition. The elements of openness are:

  1. Supported by multiple applications with demonstrated interoperability,
  2. Preferably produced by, but at least maintained by a standards group with transparent governance and participation guidelines, with representation from many companies, organizations and individuals,
  3. Not under the control of a single vendor who can change the format and the licensing at any time for reasons of its own choosing, and
  4. Available on a royalty-free basis and has no restrictions that might limit its use for any reason in any software, be it customer-unique code, a vendor product or open source.

With respect to the last element, careful attention needs to be paid to product and specification licenses. Some purported “open” specifications have limits in the licensing detail which preclude their use in open source applications based on the GNU General Public License. To understand the impact of this “detail,” consider the fact that this GNU General Pubic License is the one used by roughly 69 percent of the 69,000 projects on (the biggest repository in the world of open source projects) that use licenses approved by Open Source Initiative. What this means, for example, is that if the Commonwealth of Massachusetts relies on software covered by such a limited license, you will have lost the freedom to procure or create GPL-licensed open source software to use with your data, regardless of the cost and value of this software. That is, you will have limited your current and future options for using your own data and documents, and given control to a third party. What will be the cost of your thusly limiting your freedom?

Lastly, and most important in IBM’s view, is the innovation, competition and economic opportunities that any open standard, and especially ODF, enables. The economics of an open, freely available and implementable specification enable any number of commercial and non-commercial entities to bring truly innovative functions to the market. These companies, large or small, can realistically pursue both marginal niches as well as mainstream areas of market opportunity. Because the standard provides a common foundation that many can build on, true innovation, differentiation, and competition can take place. This directly benefits users, including governments such as your own. The open, non-proprietary standard development process creates more potential to collaboratively innovate on future generations of the specification itself. Like we all saw with the development of the Internet and World Wide Web, numerous new industries and businesses of all sizes can spring up offering specialized or broad services and applications based on open standards. IBM believes that increased use of open standards will be good for Massachusetts’ businesses, both the ones you have now and the ones that are still just sparks in the minds of your entrepreneurs.

OpenDocument Format, like the Internet and Web before it, will enable exchange and collaboration at a scale we have not seen before. This is needed in today’s society to solve both global and local challenges from, for example, disaster management coordination to electronic health records interoperability. Innovation and collaboration through open standards is our best way to make the next giant leap. From a customer/consumer/citizen perspective, the adoption of open standards is a big win.

Before I close, let me share with you a call to action that, when adopted, could make these discussions moot. It is important to remember that all vendors can implement the OpenDocument Format specification. This is why open standards promote real choice and remove restrictions. Many vendors have announced their support and their adoption plans for ODF. If every vendor had done this instead of maintaining their preference for privately-controlled proprietary formats, then we would not be here discussing migration costs or accessibility issues. We would, instead, be discussing how best to capitalize on the exciting growth, innovation, and interoperability opportunities that this standard enables. We believe three actions are needed from users:

  • One, insist today that the provider of your office applications (word processor, spreadsheet, and presentation software) implements the OASIS OpenDocument Format for Office Applications in their products by January 1, 2007. The Commonwealth is the client. Vendors should meet their clients’ needs.
  • Two, insist today that the office applications you deploy allow your users to easily set the OASIS OpenDocument Format standard as the default “save” format for documents. That is, you and your citizens should not have to go to a lot of trouble to avoid using proprietary, non-open formats.
  • Three, strongly encourage your office applications providers to join and actively contribute to the OASIS OpenDocument Format standard technical committee. For your information, IBM, Microsoft, Sun and others are Board Members of OASIS.

In conclusion, your documents—your government and cultural history, your medical records, your financial data—belong to you. They should be controlled by the Commonwealth. You should be able to do whatever you want with them, whenever you want, with whatever application software you wish. OpenDocument Format can help ensure that the Commonwealth maintains this control in the future. This can help prevent any vendor from telling you what you can and cannot do with your information.

Thank you again for the opportunity to share IBM’s position. We look forward to your resolution of these issues and the on-schedule implementation of the ETRM. Your Committee’s decision and the actions of the CIO’s office in support of ODF can be a model to guide other states and governments in their migrations to protect their future. They are watching your actions and leadership carefully. I would be happy to submit additional testimony and appear in person before your Committee should you wish any additional information.

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