Palakkad/OpenStandardsPolicyComments

To: Secretary IT, secretary at mit.gov.in, NASSCOM: chairman at nasscom.in, Mait: Vinnie Mehta  Economic Times: Harsimran Julka 

Subject: Comments on National Policy on Open Standards for e-Governance

As members of Palakkad Libre Software Users Group (PLUS http://plus.sarovar.org), we would like to congratulate the Government for coming up with a National Policy on Open Standards for e-Governance.

Palakkad Libre software Users Society [Formerly Palakkad GNU/Linux User Society] supports FOSS related activities in Palakkad. PLUS is dedicated to promoting computer users' rights to use, study, copy, modify, and redistribute computer programs. PLUS promotes the development and use of free software, particularly the GNU operating system, used widely in its GNU/Linux variant.

We support the Free Software Foundation's mission to preserve, protect and promote the freedom to use, study, copy, modify, and redistribute computer software, and to defend the rights of Free Software users. We support the freedoms of speech, press, and association on the Internet, the right to use encryption software for private communication, and the right to write software unimpeded by private monopolies.

In a country like ours with fairly adavanced Information and Communications Technology, information exchange between the people and their representatives plays an even bigger role. If tools needed for this interaction are controlled by some and not accessible to the masses it would have an adverse effect on governence. So it is heartening to see Indian government leading the way with a policy like this, which will ensure tools for information exchange with governement are available and affordable to the masses. This will also ensure Libre Software users will not be left out from this important role.

But we are concerned about the efforts by some quarters to subvert this great initiative by adding loop holes into the policy to allow patent encumbered and single entity controlled namesake open standards to be showed in. But section 6.4 of the draft version 2.0 is completely negating the nature of the policy itself. When you have more than one standard in the same domain, it not only increase the effort required to implement all competing standards, but ensuring perfect interoperability will be near to impossible as there is going to be some loss of information during conversion (if both were mapped one to one, there would not have been a need to have one or more additional standards in the first place). We request the government of India to remove section 6.4 and preserve the spirit of the policy.

The Second meeting of the Apex Body on Standards for eGovernance held on 17th June 2009 introduces "Royalty Free / RAND Standard" standards. We believe it will severely affect our ability to exchange information with the Goverment. Paying royalties are not only incompatible with Free/Open Source Software but it is practically impossible to implement. Free/Open Source Software are not developed/distributed by a single entity and it is not possible to track every copy of Free/Open Source Software, even if payment of royalties is desired. Even Microsoft has realised this with their recent announcement of Community Promise for The ECMA C# and CLI Standards and earlier Open Specification Promise for many of their specifications. We strongly request the Government of India not to accept these provisions as it would make it impossible for Free/Open Source implementations of any standard.

Also the definition of Open Source in Appendix A.11 mentions intellectual property restrictions. Since we don't allow software to be patented and trademarks does not come into piture in deciding whether a software is Open Source or not, it would be better to change it to copyright resrictions (assuming intellectual property is used as an umbrella for copyright, patents and trademarks, which itself is a bad idea).

Once again we congratulate the goverment for coming up with this bold pro-people policy and request the government to incorporate our comments.

Praveen Arimbrathodiyil, Hiran Venugopalan

Palakkad Libre Software Users Group (PLUS)

http://plus.sarovar.org

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