Here is the statement that Sun filed for today’s Massachusetts State Senate hearing on the issues around OpenDocument and state’s new Enterprise Technical Reference Model.

Statement of Douglas W. Johnson, Ph.D.
Corporate Standards Manager
Sun Microsystems, Inc.

Submitted to the Senate Committee on Post Audit and Oversight Hearing
on the Massachusetts Adoption of the OpenDocument Standard
October 31, 2005

On behalf of Sun Microsystems, Inc., I appreciate the opportunity to provide our views in strong support of the Massachusetts Information Technology Division’s (ITD) recently announced decision to implement OpenDocument v. 1.0, an open, vendor-neutral, standard format for office applications.

Massachusetts is one of Sun’s core global engineering sites, with nearly 2,000 employees working at our 850,000 square-foot east coast campus in Burlington. As a Burlington-based member of Sun’s industry standards team, I participated with the ITD and numerous other technology vendors and industry experts in the extensive review and comment process leading to the new office data format guidance issued in the Enterprise Technical Reference Model v.3.5.

This statement addresses Sun’s perspective on the process that led to that guidance, and describes a number of important ways in which the Commonwealth will benefit by adopting the OpenDocument standard for office applications. Chief among the benefits are:

  • unfettered ownership of and access to one’s own documents;

  • increased choice in office applications with reduced switching costs;

  • new opportunities for developing open source accessibility technologies; and

  • greater ease in exchanging information with other organizations.

Sun’s Perspective on the ITD Office Data Format Review Process · Sun Microsystems commends the leadership role the Commonwealth is taking in embracing open, interoperable standards. Nearly two years of internal review and nine months of industry discussion, including two public comment periods, preceded the ITD’s selection of a standards-based open document format. As in many areas of the computing industry, new options appeared during the review period. One option in particular, the OpenDocument v. 1.0 Format specification (ODF), reached the milestone of becoming an approved OASIS standard in May 2005. OASIS, headquartered in Billerica, MA, is an industry sponsored, voluntary consensus organization hosting the OpenDocument work and many other standardization activities.

The creation of ODF through open participation in an industry-recognized forum is a vital element in meeting the ITD’s requirements for an openly created and maintained, non- proprietary format. ODF is available to anyone for implementation and use on a royalty-free basis, with no intellectual property encumbrances on that use. Submission of the format by OASIS for ISO approval, which is currently under way, should further ensure those benefits by making ODF an international standard.

Upon learning of the progress of ODF in the standards process, the ITD began a due diligence process examining any potential Intellectual Property Rights (IPR) issues that might impact the new specification. Sun Microsystems is a significant contributor to the ODF standard, and the ITD asked us about any license that would be needed for others to use the specification. Sun had already submitted a royalty free statement to OASIS covering our contributions to the ODF specification when the work began in 2002. However, once the specification had been approved by the full membership of OASIS, the ITD requested additional information and clarification. This examination of ODF was very similar to the steps taken earlier in 2005, when the ITD reviewed intellectual property issues surrounding the Microsoft (MS) Office 12 XML specifications.

Within weeks, Sun provided additional information regarding any IPR that we may have bearing on the ODF specification. That statement, available on the OASIS web site, promises fully open access and use of the specification by anyone. Sun requires no fees or licenses for its use or development.

Massachusetts’ use of open formats will preserve office document accessibility in the future as well as provide greater choice for the Commonwealth’s citizens in accessing state generated documents and information. The ITD guidelines on office data formats are an affirmation of the value of truly open standards in preserving choice and interoperability in software applications.

Benefits of ODF Adoption · The chief benefit of ODF adoption will be to break the long cycle of costly migrations from one proprietary format to another, or between successive versions of a single vendor’s format. Multiple office suites on the market today already support this format, and every office applications vendor has equal and free access to the format and its specification.

Greater Return on Investment · The ability to reuse information and services based on open standards greatly improves the ROI of government investment in IT assets. Further, ODF adoption will enable the Commonwealth to maximize value through competition. Several office suites, including Sun’s StarOffice 8, IBM’s WorkPlace, and the open source implementations OpenOffice 2.0 and KOffice, already support ODF. Other vendors of office suites have announced future support. But more importantly, we are aware of no barriers of any kind for anyone to incorporate ODF support into their products. This is in marked contrast to the usual practice of nearly every office suite vendor using closed proprietary formats tied to the office applications themselves. That approach leads to considerable difficulty in exchanging documents and spreadsheets among users of competing office suites, even preventing access to older documents created with the same vendor’s earlier proprietary formats. The resulting problems spur expensive migrations to the latest office versions, often also requiring operating system and hardware upgrades, simply because support for earlier formats is marginalized. The new formats are not readable by older, but still entirely adequate, applications.

Greater Innovation in Accessibility Solutions for People with Disabilities · Sun Microsystems is pleased that the Commonwealth is explicitly including the disability community in its implementation process. We understand that one solution under consideration for ensuring the productive, efficient access to ODF files for employees and citizens with disabilities is the use of open source accessibility technologies on an open source desktop. Important among those technologies is an accessibility framework developed at Sun and contributed to the Gnome 2.0 open source desktop project. Citing that project and a rich history of accessibility work, the American Foundation of the Blind (AFB) honored Sun with the 2002 Helen Keller Achievement Award for success in driving advanced computer accessibility support. Sun continues today as the architect and maintainer of this open source desktop accessibility architecture used, in Solaris and many Linux operating systems. We would warmly welcome the opportunity to work with the ITD in collaboration with the disability community, other industry partners, and open source contributors to close any current accessibility tools gaps and provide continued innovation in computer accessibility for people with disabilities.

The accessibility tools used today in Massachusetts come from a software ecosystem developed during the last 15 years. The relevant proprietary products are expensive, brittle (in that even minor patches or upgrades often cause failures), and difficult to extend to other applications.

While accessibility technologies available today for OpenOffice in the MS Windows operating system do not provide equal productivity to the Windows-MS Office-JAWS combination, by most measures open source accessibility is further along today than it was during the first five years of Windows accessibility. We believe that continued efforts in accessibility technologies for the desktop will lead to parity in a relatively short time. In fact, two open source tools have already surpassed the best commercial products for certain severe physical disability needs. The dynamic Gnome On-screen keyboard enables dramatic productivity and efficiency gains for single switch, head tracker and eye-gaze users, and paralyzed users of Dasher, a gesture driven text entry application, are typing at 35+ words per minutes using nothing more that eye movement. Finally, open source accessibility does something commercial offerings cannot: it addresses the economic aspects of the digital divide for people with disabilities and the burdensome cost of today’s commercial accessibility solutions.

Sun firmly believes that open source accessibility technologies hold great promise. Already Sun, IBM and Adobe (among others) are working to create international accessibility architecture standards based on the open source work Sun contributed to the developer community. This rich framework for supporting accessibility technologies, built into the open source desktop from the start, is a first for the industry. This architecture has already been built into not only an open source desktop, but also StarOffice and, the open source Mozilla web browser, the open source Evolution e-mail and enterprise calendaring application, the Java platform, and Adobe Reader 7 for Linux and Solaris.

Freedom of Choice · The OpenDocument Format provides freedom of choice for government IT purchasers, enabling them to choose among competing vendors’ applications without getting locked into any one vendor.

Some have contended that the ITD decision unfairly dictates software preferences. This is entirely wrong for a number of reasons, not the least of which is that the guidelines simply indicate that any acceptable application must support an open, unencumbered document format. Basing software acquisition on meeting the state’s requirements is a crucial element in a fair and unbiased acquisition policy.

The ITD guidelines do not limit any vendor’s ability to compete for state business since the required open formats are equally available to all. The guidelines are no more limiting than such widely used acquisition requirements as UNIX operating system branding, adherence to Common Criteria certifications for security, Linux Standards Base conformance, etc.

Through the Enterprise Technical Reference Model and associated documents, the ITD clearly supports the notion that its requirements for office documents are better met with open document formats. It is immaterial whether these requirements are met by open source applications (OpenOffice or KOffice), supported applications based on open source such as StarOffice, or proprietary applications. Vendor selection will be made based on the outcome of the usual competitive procurement process, which typically ranks costs and other characteristics for those products that meet the requirements.

Any vendor who declines to support the selected open, unencumbered data format is making a business decision based on its own company policies and competitive strategies. Upgrade, migration and conversion costs are present regardless of the specific office applications chosen by the state. The MS Office 12 XML format will entail just as much migration and conversion as the XML-based OpenDocument format. Excessive upgrade and migration costs for moving to a competitive platform are typical hallmarks of vendor lock-in. By asserting that the state will suffer a “prohibitive cost to change” from its products, a vendor is essentially admitting that the state is already locked into its products.

Increased Citizen Access and Enhanced Interoperability · An important goal for any government or agency is to better serve its constituents by ensuring the maintenance and preservation of public documents. Today, proprietary formats jeopardize the long-term accessibility of these important records. The greater choice of a range of solutions, particularly the availability of free and low-cost offerings, will increase public access to the government’s data.

Open formats for documents enable the exchange of richly formatted information between different applications, agencies and/or business partners in a platform-independent way, eliminating the need for all parties to use a single vendor’s offerings.

Sun Microsystems appreciates the opportunity to provide this statement in support of ODF adoption to the Senate Committee on Post Audit and Oversight.

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