Can AFNOR really change the OOXML vote to "abstain"?
Forum » News / Front-page » Can AFNOR really change the OOXML vote to "abstain"?
started by: davidbldavidbl
on: 1207120159|%e %b %Y, %H:%M %Z|agohover
number of posts: 7
rss icon RSS: new posts
summary:
The case of France is particularly interesting, because in early September 2007, the French standardization organization AFNOR had taken a very strong position against accepting OOXML as a separate ISO/IEC standard besides ODF. The ISO/IEC JTC1 directives say in section 9.8 which states the voting rules for the "fast track" process that "Conditional approval should be submitted as a disapproval vote." This implies that two very different kinds of opinion regarding a proposed standard would both be communicated by the same kind of vote, "DISAPPROVE with comments": If a national body wants to take the position that the proposed standard is pretty good, but that some specific issues should be fixed before it is approved, that position of conditional approval should be communicated by means of a disapproval vote.
Can AFNOR (France NB) really change the OOXML vote to "abstain"?
davidbldavidbl 1207120160|%e %b %Y, %H:%M %Z|agohover

Can AFNOR really change the OOXML vote to "abstain"?
I fully(as stated in its licence) reproduce this article by Nortbert Bollow on how France possibly broke the JTC1 rules by suddenly changing its vote from Disapproval to Abstention at the eleventh hour:

Having participated within the responsible technical committee of the Swiss Association for Standardization and considering the decision-making process that has been used to be unsatisfactory, I find it interesting to look at how things have been handled in other countries, in order to see what can be learned from that. I plan to focus my attention in this regard on countries where the primary language is German, English or French, so that I will be able to understand any relevant documents which might become available to the public or personally to me.

The case of France is particularly interesting, because in early September 2007, the French standardization organization AFNOR had taken a very strong position against accepting OOXML as a separate ISO/IEC standard besides ODF (official announcement in French, English translation on Groklaw).

The ISO/IEC JTC1 directives say in section 9.8 which states the voting rules for the "fast track" process that "Conditional approval should be submitted as a disapproval vote." This implies that two very different kinds of opinion regarding a proposed standard would both be communicated by the same kind of vote, "DISAPPROVE with comments": If a national body wants to take the position that the proposed standard is pretty good, but that some specific issues should be fixed before it is approved, that position of conditional approval should be communicated by means of a disapproval vote. If on the other hand the national body is of the opinion that the proposed standard is very bad and totally unsuitable for acceptance without an in-depth revision and reworking which is not realistically possible during the fast-track process, that position would also be communicated by the same kind of vote. The only way to find out whether a national body submitting a disapprove vote just wants some specific issues to get fixed before the proposed standard is approved, or whether the national body really wants the proposed standard to be disapproved, is to analyze the comments which were submitted with the disapproval vote.

In the case of France it was as clear as it could possibly be that the disapproval vote was meant seriously. This makes the decision to now change the vote to "abstain" doubly interesting: What were the motivations and politics behind deciding to make this change? Has the decision been reached by means of a reasonable process?

I plan to comment on these questions in later blog posts, as more information becomes available. Right now I want to focus on a different question which I stumbled across when checking the ISO/IEC JTC1 directives for the precise reference for the above quote. Namely, I noticed in that section 9.8 an indication that it is not permissible to vote "abstain" for just any reason. Specifically, in the list of possible ways of voting, it says "Abstention (see 9.1.2)."

Since I am currently seeking to understand the context of AFNOR's decision to vote "abstain", I checked what section 9.1.2 says about this topic. To my surprise, I found that voting "abstain" is tied to a particular procedural condition:

A P-member which has given appropriate notification that it will abstain from participation in specific work items (see 3.1.2) is entitled to abstain from voting on these work items.

Naturally, my next step was to turn to section 3.1.2 to learn what "appropriate notification" would be:

A P-member may have an interest in the field of JTC 1 without having interest or competence in all of the work items which may be dealt with. In such an instance, a P-member may inform the JTC 1 Secretariat, the SC Secretariat and the ITTF at the beginning of the work, or at a later stage, that it will abstain from participation in discussion or voting on specific items. Such a position, established and recorded by JTC 1, shall entitle the P-member to be absent from meetings and to abstain from voting on the relevant FDISs.

This means that it is not acceptable for P-members to abstain for just any reason. Abstaining is acceptable when there is lack of interest or competence regarding a specific work item, but with regard to work items concerning which the P-member has interest and competence, the P-member is required to somehow reach a decision of approval or disapproval.

I think that the intention behind this rule is probably to minimize the influence of lobbying on approval/disapproval decisions. When abstention is allowed only for the specified reasons, the technical committees are under much stronger pressure to evaluate proposals in a fact-oriented manner that can lead to a genuine, factually justified consensus decision.

I suppose that if during the initial review period in spring and summer 2007, a national technical committee failed to reach a consensus of any kind, that maybe could be interpreted with just a little stretching of the meaning of the words as a lack of competence and used to justify submitting an "abstain" vote at that stage.

But in view of the excellent technical quality of the comments document from France, I really don't see how AFNOR could now claim lack of competence, and a claim of lack of interest would be equally absurd.

Could it be that the French standardization organization officials really were not aware of the rules regarding abstention? I suppose I will ask them.

I will edit this blog entry to add a link to AFNOR's reply if/when I receive one.

Author: Norbert Bollow
Posted: 2008-04-02
License: Permission is hereby granted to faithfully reproduce this article in any medium, provided that a prominent link to http://Adaptux.com/blog/2008-04-02/OOXML/France is included as attribution.

last edited on 1207232164|%e %b %Y, %H:%M %Z|agohover by davidbl + show more
Re: Can AFNOR (France NB) really change the OOXML vote to "abstain"?
arebentiarebenti 1207124500|%e %b %Y, %H:%M %Z|agohover

I don't get the point. As far as I understood national bodies are free to vote what they like. Of course ISO gives recommendations how to vote in what situation but only disapproval votes need to be formally justified.

We know that in the case of France "strange things happened". Better dig into these.

last edited on 1207124514|%e %b %Y, %H:%M %Z|agohover by arebenti + show more
Re: Can AFNOR (France NB) really change the OOXML vote to "abstain"?
leo_franceleo_france 1207149447|%e %b %Y, %H:%M %Z|agohover

How nice it would be if Norbert Bollow was true, but I think that he missed the point :

Voting "abstain" is not the same as abstaining from "participating in specific work items". In this case AFNOR did not abstain from participating, it just expressed that it neither approved nor disapproved OOXML and was unable to express a strong opinion on that issue.

Although it is right that in this case changing from "No" to "Abstain" is almost the same as voting "Yes" since it makes the opponents to OOXML lose a voice, I can't see any formal irregularity in this move, even if we can agree that it must have been caused by some strong lobbying from the Microsoft's side.

You should also note that in september AFNOR voted NO with the opinion that there was already ODF as an existing ISO standard for office documents so that it should be better to make ODF and OOXML converge in a separate process since the fast track procedure is not appropriate for that. It did not firmly disapprove OOXML as such. So its new abstain position is not completely incoherent, though it may seem odd.

Re: Can AFNOR (France NB) really change the OOXML vote to "abstain"?
Norbert BollowNorbert Bollow 1207157512|%e %b %Y, %H:%M %Z|agohover

First a clarification: I am in no way affiliated with noooxml.org and have not suggested or requested for this article to be posted here, all I did was to simply post it on my own site as a blog entry and grant a global license that it may be freely reproduced.

@arebenti: In the current situation I am not trying to stir up momentum for an appeal (maybe I would be interested in that if I thought that there was any realistic chance of success, but I don't think that that is the case) or otherwise seeking to attack AFNOR or ISO/IEC over what has happened. Rather, what I am interested in is reaching a situation where the written rules for standardization are clear and are being followed. I speak up because this doesn't seem to be the case.

@leo_france: I understand very well that casting an "abstain" vote is not necessarily the same thing as abstaining from a work item, and I am aware that the JTC1 directives are generally interpreted as if they allowed casting an "abstain" vote in a letter ballot on a DIS even without having formally abstained from the work item in its entirety. However, when checking what the directives actually say regarding "abstain" votes, to my surprise I found that this generally-accepted interpretation seems to be invalidated by what is actually written in the directives. If you think that my analysis is wrong, please point out where specifically you think that I have made a mistake.

How standardization directives are interpreted in ISO/IEC JTC1
Norbert BollowNorbert Bollow 1207227084|%e %b %Y, %H:%M %Z|agohover

I've followed up in today's blog post with some more thoughts on how standardization directives are interpreted in ISO/IEC JTC1.

Re: How standardization directives are interpreted in ISO/IEC JTC1
davidbldavidbl 1207231788|%e %b %Y, %H:%M %Z|agohover

Norbert, I did not express myself correctly when presenting your post. I meant that your will was that the if the post was reproduced elsewhere it should be done fully, and not that you requested it to be published here. Sorry about the confusion. Hope it is ok for you and that the link to your site was sufficiently clear.
Best regards.

last edited on 1207232214|%e %b %Y, %H:%M %Z|agohover by davidbl + show more
Re: How standardization directives are interpreted in ISO/IEC JTC1
leo_franceleo_france 1207315613|%e %b %Y, %H:%M %Z|agohover

Norbert, first please forgive me if my first message appears a bit crude to you.

I took a look at the ISO JTC1 directives and must admit that, concerning this point of abstention, it is not very clear to say the least.

Effectively, section 9.8 "Votes on Fast-track DISs" specifically says:

9.8 Votes on Fast-track DISs
The period for fast-track DIS (or DAM) voting shall be six months, consisting of a 30-day JTC 1 National Body review period followed by a five-month ballot period. NBs may reply in one of the following ways:
• Approval of the technical content of the DIS as presented (editorial or other comments may be appended);
• Disapproval of the DIS (or DAM) for technical reasons to be stated, with proposals for changes that would make the document acceptable (acceptance of these proposals shall be referred to the NB concerned for confirmation that the vote can be changed to approval);
• Abstention (see 9.1.2).
[Note: Conditional approval should be submitted as a disapproval vote.]
The criteria for approval are given in 9.6. If these criteria are not met initially, but are subsequently met at the conclusion of ballot resolution in accordance with 13.9, the DIS (or DAM) is approved.

and when looking at 9.1.2, one sees that :

9.1.2 A P-member which has given appropriate notification that it will abstain from participation in specific work items (see 3.1.2) is entitled to abstain from voting on these work items.

One would think, as I did, that voting "Abstain", is not the same as abstention from voting, but the way section 9.8 is written and refers to 9.1.2 may indeed lead to conclude that they are actually the same for a P-member or at least that a P-member can only use this option if it has notified that it would abstain from participation to the ongoing work.

Anyway I still don't think there is something in the "abstain" vote of AFNOR that contradicts the rules of JTC1 on Fast-track procedures. Lets dig a bit more into it.

If you take a close look at 3.1.1 and 3.1.2 you may see that:

3.1.1 P-members of JTC 1 and its SCs have an obligation to take an active part in the work of JTC 1 or the SC and to attend meetings. P-members of JTC 1 and its SCs have an obligation to vote approval, disapproval, or declared abstention within the time limits laid down on all questions submitted for voting (unless 3.1.2 applies) within JTC 1 or the SC. "Abstention" is an appropriate response (with or without comment) if an NB is not confident that their technical review is sufficient to cast an "approve" or "disapprove" vote. P-members of JTC 1 have an obligation to vote on FDISs prepared by JTC 1 or its SCs as well as DISs distributed for fast-track processing.

So according to 3.1.1, ""Abstention" is an appropriate response [for a NB] if [this NB] is not confident that their technical review is sufficient to cast an "approve" or "disapprove" vote".

Abstention is clearly allowed to P-members, be it interpreted as voting "abstain" or "abstaining to vote", as long as it is declared in time and to the competent authorities.

Clause 3.1.2 does not seem to hold here. Concerning this last one, here is what it says:

3.1.2 A P-member may have an interest in the field of JTC 1 without having interest or competence in all of the work items which may be dealt with. In such an instance, a P-member may inform the JTC 1 Secretariat, the SC Secretariat and the ITTF at the beginning of the work, or at a later stage, that it will abstain from participation in discussion or voting on specific items. Such a position, established and recorded by JTC1, shall entitle the P-member to be absent from meetings and to abstain from voting on the relevant FDISs.

Even though we have seen that section 3.1.1 allows abstention during a voting process, there is another point in clause 3.1.2 that, I think, could make AFNOR's abstention perfectly legal:

It is the fact that this notification of abstention may be done at the beginning of the concerned work, or at a later stage.

There is no mention that this later stage cannot be the latest vote itself. And indeed, since the intention of voting or abstaining itself must be notified to the JTC 1 Secretariat, the SC Secretariat and the ITTF, that is the same authorities as those that must be notified in clause 3.1.2, declaring abstention in a voting process couldn't it be considered as a notification of abstention from participation as allowed by clause 3.1.2? As long as it is declared to the competent authorities and within the time limits, abstention seems definitely allowed during a voting process.

I know this last interpretation of clause 3.1.2 may seem a bit "tirée par les cheveux" (as we say in french and as I don't remember the english equivalent).
But I don't think clause 3.1.2 even needs to be considered here since clause 3.1.1 clearly allows P-members to declare their abstention as long as they do it in due form, i.e. within the same time limits and to the same authorities as the ones for approval or disapproval.

In fact, if we take both 3.1.1 and 3.1.2 clauses, we see that, provided its declaration is made in due time and to the competent authorities (which are the same for both clauses), abstention is allowed to a P-member for the following reasons:

  • It "feels" that its technical review is not sufficient to cast an "approve" or "disapprove" vote. (clause 3.1.1)
  • It lacks of interest or competence in an ongoing work. (clause 3.1.2)

Do you think that AFNOR's reasons for abstention don't pertain to the above categories?

Of course one could contest the fact that AFNOR lacks of interest or competence in the present case in view of their participation to all previous works concerning DIS 29500, but this is not their official position.

I don't have the text accompanying their vote but at least here is what has said Tony Hittema, AFNOR's technical director, according to Les echos:

"A la lumière des contributions et des commentaires, il nous est apparu qu'une "Désapprobation" n'était plus justifiée. Pour autant, il demeure encore des incertitudes sur les textes et les engagements, ce qui nous a conduit à nous prononcer par une "Abstention"."

which translates into :

"At the light of contributions and commentaries, it appeared to us that a "Disapproval" was no more justified. However, it remains uncertainties on texts and engagements, which has led us to announce an "Abstention"."

This stated reason would rather belong to the ones allowed by clause 3.1.1: insufficient technical review or in this case impossibility to achieve complete technical review.

I agree that this seems rather "twisted" and one could argue that the same justifications could have led to cast a "No" vote, but this whole ISO process is such that noone really has to give solid technical justification to its position.

So I don't think one has any way to contest the change of position of AFNOR, at least according to JTC1 directives. The only thing that can be contested is the way AFNOR has established internally and/or under external pressures its last voting position. But this concerns AFNOR internal rules rather than JTC1 directives.

last edited on 1207323924|%e %b %Y, %H:%M %Z|agohover by leo_france + show more
new post