ILUG-Delhi position on proposed e-governance policy of the Government of India

Below is the draft of a letter that I propose should be sent to various officials in the Government of India as an official ILUG-Delhi stance on the policy. The policy itself is quite encouraging, apart from some loopholes. You might have seen posts on the ILUG-Delhi mailing list pertaining to this issue, and here are some blogs discussing it: Venkatesh Hariharan, Kapil Hari Paranjape. The standard itself is here as a PDF file, and also attached to this entry as a file.

It might be a good idea to read the standards document first. It is only 9 pages long. Please add your views by directly editing this entry.

To
Shri Shankar Aggarwal
Joint Secretary (e-Governance)
Department of Information Technology
Ministry of Communications and Information Technology

We were pleased to read a copy of the Standards Policy for
e-Governance, dated 26th Feb, 2009, and would like this letter to
serve as the official position of the India Linux User's Group,
Delhi, (http://www.linux-delhi.org/) on this issue.

Firstly, we would like to congratulate the Department of
Information Technology on a remarkably forward-looking, and well
thought-out policy document. We strongly feel that if this is
indeed adopted as official policy of the Government of India, it
would greatly strengthen the IT infrastructure of the country's
government, and enable it to better serve the populace of
India. Over and above that, it will serve as a precedent to other
developing countries, as well as to the rest of the world. India can
then count itself as a trend setter in institutionalizing free and open
policies in government.

We should also point out that there are some aspects of the
documents that we look askance at. This stems from the past
experience of the Free/Open Source Software community with
attempts by vendors of proprietary technologies, and other vested
interests, to subvert other such efforts at open standards. In
particular, we see the following items as being of concern:
  * 2.2: The phrase, ``internal representation can vary'' is not
    acceptable, as it can cause an inability for interested parties
    to store, retrieve, or convert the data, leading to vendor
    lock-in.
  * 2.3: For legacy systems, the emphasis should be on a
    migration to open systems and open standards, rather than
    seeking to keep them in place at huge maintenance costs.
  * 6.2, first paragraph: The policy should explicitly prohibit
    relaxation in any of the mandatory requirements. Wherever there
    is a lack of open standards in a given domain, the preferred
    action should be that the Government of India evolves a new,
    open standard with the help of various governmental standards
    bodies, in consultation with various stakeholders.

    At the very least, there should be a requirement that an
    agency of the Government of India, such as the Apex Body on
    e-governance Standards, (a) signs off on the claim that there
    is no standard meeting the mandatory, and (b) is required to
    ask for, receive, and respond to public responses to such a
    claim.
  * 6.2.1: A for-profit organisation maintaining a standard is a
    contradiction in terms. In the usual cases that we are aware
    of, such so-called standardization efforts are usually not much
    more than an attempt by the organisation in question to promote
    their own interests. Even when a new standard is necessary to
    meet the needs of some cutting-edge technology, an organisation
    seeking genuinely open standards would develop one, and release
    it to a non-profit body.
  * 6.2.2: The terms Fair, Reasonable and Non Discriminatory terms
    (FRAND) or Reasonable and Non Discriminatory terms (RAND) need
    to be defined in detail. Fair and reasonable to whom?
    Non-discriminatory against which stakeholders?  In general, the policy
    would be more effective if, when an open standard is not available
    in a specific domain, the Government of India takes steps to enhance
    an existing open standard to meet its requirements rather than
    adopting a proprietary standard. Doing otherwise could lead to
    incompatibilities in data formats, vendor lock-in and an inability to share
    or even access data in the future.
  * 6.2.3: This item leaves a serious loophole in the entire process of setting 
    up standards, to such an extent that it would undermine the whole purpose 
    of this document. If anything can be relaxed as desired, then we are not 
    really setting up mandatory standards.
  * 6.3: The last point, ``Specifications as per published
    proprietary extensions;'' should be dropped entirely as this is
    in direct conflict with this policy and can lead to vendor
    lock-in.

We appreciate the effort that has gone into this document, and the breadth 
of the vision that has enriched it. Provided that the caveats in the above paragraph
are addressed, we urge adoption of this policy by the Government of India.

Sincerely yours,

Kishore Bhargava,
President, India Linux User's Group, Delhi
On behalf of ILUG-Delhi

-- GoraMohanty - 07 Jul 2009