Centre for Internet & Society

In November 2010, the Central Government released the Draft 0.6 of the Technical Standards for the Interoperability Framework for e-Governance (Phase I), requesting comments by January 27, 2011. Here are the comments that CIS submitted.

General Review Comments

  • The present document is an excellent step in the right direction, following very ably the policy guidelines laid down in the National Policy on Open Standards for e-Governance.
  • The Expert Committee and other contributors have made excellent choices as to the 19 standards that have been laid down in the IFEG. It is praiseworthy that of these 18 are designated as mandatory, and only two are designated as interim standards. Furthermore, the system has been very transparent with the selection of standards, providing concise descriptions for each.
  • It is also important to note that while accessibility has been mentioned while talking of HTML, accessibility standards should preferably also be specifically mentioned in the presentation and archival domain.
  • However, many other governmental interoperability frameworks are going beyond merely listing technical standards. Some governments, such as Germany and the EU, go beyond technical interoperability, and also have documents dealing with organizational, informational, and legal interoperability. These are equally important components of an interoperability framework. Other governments also also lay down best practice guides, and other aids to implementation, sometimes even including application recommendations. Further, there are many which lay out standards for the the semantic layer, business services layer, etc.
  • We at the Centre for Internet and Society are currently advising the government of Iraq on development of their e-Governance Interoperability Framework, and would be glad to extend any support that the Department of IT may require of us, including comments on all further phases.

Specific Section-wise Review Comments

Section 5.2.7 - In the “additional remarks” row, it is stated that “If Adobe Systems Incorporated’s intent to make it royalty free is achieved then no further reviews will be necessary.”
This should be changed to indicate that (a) there might be entities other than Adobe that hold necessary patents over PDF v1.7, and (b) that a desirable feature—of there being multiple implementations of the standard—might not be fulfilled by PDF v1.7.
Adobe has in fact published a public patent licence that covers PDF v1.7 (ISO 32000-1:2008), and makes all of Adobe’s essential claims over PDF v1.7 available royalty-free.
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