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The Foundation for a Free Information Infrastructure (FFII) is a non-profit associationregistered in several European countries, which is dedicated to the spread of data processing literacy. FFII supports the development of public information goods based oncopyright, free competition, open standards.
Ten recommendations on the leaked EIF 2.0 draft
1
Paper or tiger?
 This week a Dutch journalist, Brenno de Winter, alerted the public about a newdraft for an upcoming European Interoperability Framework (EIF) 2.0communication of the European Commission. The leaked draft is a follow-up tothe famous 2004 EIF 1.0 document with a strong emphasis on genuine openstandards (and open source). The IDABC EIF 1.0 is referenced across the world because of its clear definitionof the professional term
open standards
. The release of EIF 1.0 was followed byintense lobbying from stakeholders from third nations which aimed toundermine its contribution to European Digital Independence. Aggressiveintervention to water it down demonstrated for all to see a positive strategicimpact of the EIF 1.0 as a tool to defend interoperability in the market. The EIF update process has been delayed. First a study and proposal of theconsultancy company Gartner was presented which took a vendor-drivenperspective for public procurement and turned the EIF mission into generalprovision of public services
we need 
. In the Gartner proposal
interoperability 
became an empty phrase. Last year a draft for the EIF 2.0 has been presentedby the EU Commission IDABC for broad stakeholder consultations and wasgenerally better received by all sides. The new leaked draft is a trimmed downversion of that text. Like the older draft it still includes many elements whichare unrelated to interoperability. It fails to take the proposals for improvementon board. The document makes undue concessions to the commercialopponents of openness and interoperability. The EIF 2.0 is expected to entersoon into inter-service consultations at the European Commission.FFII quickly analysed the new document and contributes
TenRecommendations
on how to get a better EIF 2.0. Nevertheless, the onlyaspect that actually matters is to preserve a strong definition of "open
1 http://www.bigwobber.nl/wp-content/uploads/2009/11/European-Interoperability-Framework-for-European-Public-Services-draft.pdf 
 
standards and specifications" in a way that patent cartels do not qualify for thegold standard. Admission of patent cartels (RAND licensing terms) is also ameans to make the terminology incompatible with the European Union PublicLicense and compatible licenses as well as some national legal requirements.We further highlight the absence of political or legal endorsement of a softwarepatenting practice on the EU level, although parts of the Commission aim tooutsource a democratic decision on patentable subject matter to newspecialized patent courts governed outside the acquis communautaire("UPLS").
1. Alignment of EIF 2.0 with the new ISA programme
We propose to streamline the principles of the upcoming EuropeanInteroperability Framework 2.0 with the General Principles of the new ISAprogramme, Article 4
2
(a) technological neutrality and adaptability;(b) openness;(c) reusability(d) privacy and protection of personal data; and(e) security.  The EIF 2.0 General Principles are framed as principles of the European PublicServices. In the context of an Interoperability Framework they should rather beframed as Principles for the interoperability of (European) public services.An additional need for interoperability frameworks for purposes other thanEuropean Public Services could emerge from ISA activities. To this end a set of core interoperability principles is beneficial to make the EIF 2.0 more generic.For these reasons we recommend to separate general features for EuropeanPublic Services such as costs ("effectiveness&efficiency"), user friendliness etc.from tangible interoperability related general principles ("core") such asopenness, technological neutrality, adaptability, reusability. As a result wewould get two sets of general principles, for interoperability and for publicservices.As of Principle 2.2 we recommend deletion. It suggests a top-down approach asopposed to voluntary coordination and sharing of best administrative practice.We find the Principle 2.2 too narrow and limited for an European Public Service.Information sharing in an administrative environment is often characterised byopen coordination, informal exchange, imitation and learning. The weakness of the former IDABC programme in terms of enforcement is in fact its uniquestrength.
2. Improve interoperability terminology
According to the definition of the ISA programme, Article 2"interoperability" means the ability of disparate and diverse organisations
2 http://register.consilium.europa.eu/pdf/en/09/st03/st03667.en09.pdf 
 
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)
interoperability 
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
legal harmonisation
asthese means would be on a political decision-making level. Instead
LegalInteroperability 
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
market relations
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.
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