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Brazil's letter to ISO on OOXML

This is an unedited version of the letter Brazil sent to the ISO for the decision of the Ballot Resolution Meeting to be reconsidered.

Dear Sirs,

The Associação Brasileira de Normas Técnicas (ABNT), as a P member of ISO/IEC/JTC1/SC34, would like to present, to ISO/IEC/JTC1 and ISO/IEC/JTC1/SC34, this appeal for reconsideration of the ISO/IEC DIS 29500 final result.

This appeal is based on two main considerations:

1.Brazil considers that the BRM was inconclusive.

2.Brazil considers that the final version of the ISO/IEC DIS 29500 text shall be released immediately.

1. About the BRM

At the BRM, the Brazilian delegation was not allowed to present an important proposal regarding the legacy binary mapping. This proposal was a complementary part of USA delegation proposal regarding the new organization of the ISO/IEC DIS 29500. It also shall complement the scope change proposal approved at the BRM.

Brazil has tried to present this proposal, during the debates, on the first day of the meeting and, attending to a request made by the convenor, Brazil has taken offline discussions with USA and other delegations and prepared its proposal to be presented on Friday, during USA proposal presentation.

On Friday, when USA ended their part of presentation and asked for Brazil to present its part of it, the convenor denied this opportunity to Brazilian delegation.

Several delegations has protested against that arbitrary decision, but those appeal was in vain and until the end of the BRM, the Brazilian delegation was not able to present its proposal. The main reason alleged by the convenor was “lack of time”.

The proposal here mentioned, is the one available on the file “Br_Multipart_Proposal.ppt” available to all BRM members the ISO/IEC/JTC1/SC34 website at least since the fourth day of the meeting.

Brazil also noticed that most of the decisions taken during the BRM were based on the “lack of time” argument, and we think that this is completely incompatible with the kind of decisions that should have be taken on that meeting.

During the BRM, some decisions were also taken based on the argument that “we need to give answers to journalists”, and we think that the media coverage of that meeting was not so important as the meeting results, to be used as a decision making criteria.

Even with the “lack of time” alleged, some members of ECMA delegation, and not members of any NB, was allowed to do half-hour speeches during the two first days of the meeting.

The voting rules of that meeting were not taken in accordance with ISO/IEC/JTC1 directives subclause 9.1.4. Brazil also notes that the ISO/IEC DIS 29500 was voted under ISO/IEC/JTC1 but the BRM was organized by ISO/IEC/JTC1/SC34. Even if the directives subclause 9.1.4 was intended to be used, Brazil cannot understand if the P member status considered, should be the ISO/IEC/JTC1 or the ISO/IEC/JTC1/SC34 one.

Brazil also considers that if most part of the issues was to be decided by vote, without any kind of discussion allowed.

About the same subject, Brazil considers that the elected “default voting criteria” was only elected because it was the “less bad” criteria that could be analyzed, and we do not consider that this voting decision represents the intent of the vast majority of BRM delegates. They went there to discuss the technical propositions.

Analyzing the document “SC 34 N 990 – EDITED NOTES OF THE MEETING”, on page 7, we have found the register of BR objection to themulti-part split decision but analyzing the document “SC 34 N 989 – RESOLUTIONS OF THE MEETING” we do not find that objection registered.

During the BRM, the delegations were asked to vote in block for the rejection of a set of responses that was considered by the convenor as “responses without any editing instructions”. Those responses are listed on the file “dis29500-nochange.txt”, available at the SC34 website during the BRM and, as far as Brazilian delegates remember, this set of responses was “rejected in block” as requested.

When we analyze the documents N989 and N990 we do not see any reference to that decision and also at the ISO/IEC/JTC1/SC34 document with title “Result of Proposed disposition of comments (SC 34 N 980)”, that presents a table with the status of each response, some of the “block rejected responses” appears as accepted (e.g. responses 3, 5, 10 and 11 among others).

To finalize our considerations about the BRM, analyzing the document N 989, we’ve found that the BRM can be summarized by:

Total of responses available for discussion: 1027 – 100 %
Total of responses addressed at the BRM: 189 – 18,4 %
Total of responses decided by “default” vote: 838 – 81,6 %

We use the term “responses addressed at the BRM” above because the majority of those responses was decided by block vote without any discussion at the BRM.

For the above-mentioned reasons, Brazil considers that the ISO/IEC DIS 29500 BRM was inconclusive.

2. About the final version of ISO/IEC DIS 29500 text

According to the directive item 13.12, the final version of the ISO/IEC DIS 29500 text shall be distributed on not more than one month after the end of the BRM.

Seen that almost three months has passed after the end of BRM, without any final version of the text distributed or published, and based on directive subclause 13.12, Brazil request the distribution of ISO/IEC DIS 29500 final text.

For all those reasons presented, Brazil kindly request that the final result of ISO/IEC DIS 29500 should be reconsidered by ISO/IEC/JTC1 and ISO/IEC/JTC1/SC34.
Best regards,

Marcia Cristina de Oliveira

ABNT – Manager Standardization Process