to interact towards mutually beneficial and agreed common goals,involving the sharing of information and knowledge between theorganisations, through the business processes they support, by means of the exchange of data between their respective ICT systems" Therefore we found it very intuitive to reconcile the EIF 2.0 definition of interoperability with that ISA programme definition, a view shared by the draftpersons. For clarity reasons we propose to eliminate the additional "sharedvalue of the community" sentence (Section 1.2.2). It is not well defined what a"community" means and how interoperability relates to an internationalunderstanding ("entente cordiale", "Völkerverständigung") cause.For technical purposes (Chapter 4)
ought to be defined morenarrowly than 'cooperation'. For pragmatic reasons the term "TechnicalInteroperability" should be defined in accordance with the applicable technicalISO definition.Furthermore "Legal interoperability" does not relate to
asthese means would be on a political decision-making level. Instead
relates to arrangements (e.g. standardisation of licensingcontracts and other legal conventions) under an existing, positive law.
3. Market Order and public constituency
Section 1.1 notes briefly "The EIF contributes to the better functioning of theInternal Market through increased interoperability among European publicadministrations.". It would be very helpful to further elaborate on thatmessage. It is apparent that A2A relations are not characterized by
but administrative needs are the building block of an interoperabilityframework for the public sector.Presumably the EIF 2.0 remark relates to "positive spillover effects on thesingle market" (ISA Recital 12). Significant here are external effects of publicaction: "Citizens and enterprises would also benefit from common, reusableand interoperable solutions and interoperable administrative back-officeprocesses, as those solutions and processes would promote the efficient andeffective delivery of public services to citizens and enterprises across bordersand sectors." (ISA Recital 7)Such language from ISA could be added to stress the implications of publicprocurement action for the market order, and the expectations of the masters,the constituency of a public authority, the people who are served by a publicservice and ultimately govern it by democratic means.
4. Deletion of Chapter 3 and its empty talk
As we stressed before the centralist vision of aggregated European PublicServices provision has little in common with an Interoperability Framework. TheChapter 3 from the draft EIF 2.0 is considered superfluous annoyance. It shouldbe released as a separate document in its epic form, provided there was anypractical merit found in it, which we seriously doubt.