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 <p>The only restriction they would suffer is that they would no longer be at liberty to lock themselves into proprietary formats owned by a single vendor; this can only be considered a good thing. In cases where there is currently no Open Standard available, or where it is not feasible to use, the policy provides sufficient alternative options ("comply or explain", which should be a step taken before a public body releases a call for tender.)</p>
 <p>If, however, application of the policy is restricted to central government alone, this will lead to severe interoperability problems with the rest of the UK's public sector, which remains mired in vendor lock-in. We recommend that UKG should take a bolder stance, apply the policy as widely as possible, and take steps to enable all public sector organisations to implement it.</p>
 
-<h3>3. For businesses attempting to break into the government IT market, would this policy make things easier or more difficult – does it help to level the playing field?</h3>
+<h3>3. For businesses attempting to break into the government IT market, would this policy make things easier or more difficult - does it help to level the playing field?</h3>
 
 <p>Adopting the proposed policy including FSFE's amendments (see Question 1) would be a significant step towards leveling the playing field. Today, 60% of revenue from central government contracts goes to only 10 or so systems integrators. It is not acceptable for the government to pick winners in this fashion. </p>
 <p>The policy, if implemented in full, will be an important step towards opening the UK's public sector IT market to competition. A comprehensive Open Standards policy would greatly lower the bar for UK businesses, in particular smaller ones, to compete for government contracts. In addition, Open Standards naturally circumvent vendor lock-in and therefore guarantee the freedom of choice for future government procurement and a vivid competition inside the government IT market.</p>
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 <h3>10. Does a promise of non-assertion of a patent when used in open source software alleviate concerns relating to patents and royalty charging? </h3>
 <p>Businesses serving government need a firm legal basis to build upon. While a promise not to assert a patent is generally a friendly gesture by the patent holder, it is no replacement for a clear policy requirement for Open Standards, which can be implemented without royalty payments or restrictions. Promises of non-assertion may eventually be rescinded (e.g. when the patents it covers are sold to another company). </p>
 
+<h3>12. In terms of standards for software interoperability, data and document formats, is there a need for the Government to engage with or provide funding for specific committees/bodies? </h3>
+<p>Regarding UKG's approach of setting up an Open Standards Board to steer the implementation of the policy, we consider it essential that discussions of the board are conducted in a transparent fashion. In order to ensure participation is not limited to representatives of the current large suppliers, there needs to be the opportunity for representatives of smaller companies to participate in the board and exercise equal influence. Board discussions need to be structured in a way that minimises the time burden especially on representatives of small companies. UKG should consider setting up a mechanism to encourage and support the participation of smaller companies in the board.</p>
+
+<h2>Chapter 2: Open standards mandation</h2>
+
+<h3>1. What criteria should the Government consider when deciding whether it is appropriate to mandate particular standards?</h3>
+<p>Where it mandates a particular standard for software, data, or document formats, government must make sure that the standard is an Open Standard -- it must carry no restrictions on implementation, and must not require the implementer to pay patent royalties.</p>
+
+<h3>4. Could mandation of competing open standards for the same function deliver interoperable software and information at reduced cost? </h3>
+<p>Competition takes place on top of standards, not between standards. Competition on top of a standard removes barriers, increases interoperability and customer choice. Competition between standards reduces interoperability, fragments the market, and leads to vendor lock-in.</p>
+<p>For example, the frequency used in alternating-current (AC) electricity networks -- 50 Hz -- is largely arbitrary. It might be equally possible to use a frequency of 40 Hz, or 70 Hz, instead. What is important is that everyone connecting to the network -- electricity generators as well as users -- use the same frequency. </p>
+<p>If government decides to mandate standards, it would be best by recommending an initial set of Open Standards. These standards must strictly conform to the definition and should come with a large number of implementations, in order to provide a basis on which the policy can be successfully implemented. Other Open Standards can be added to this list at a later date.</p>
+
+<h3>5. Could mandation of open standards promote anti-competitive behaviour in public procurement? </h3>
+<p>Mandating Open Standards could not conceivably lead to anticompetitive behaviour in the software market. Quite to the contrary, they are the best way to open up competition in the software market. Since Open Standards carry no restrictions on implementation, smaller implementers (all else being equal) are in a better position to challenge incumbents. Conversely, standards with restrictions on their implementation have long been shown to foster anticompetitive behaviour (e.g. Microsoft's proprietary .doc format).</p>
+
+<h3>7. How should the Government best deal with the issue of change relating to legacy systems or incompatible updates to existing open standards? </h3>
+<p>Legacy systems and file formats are a cost factor in any case. Even with proprietary software and formats, new versions of a program frequently are unable to properly process older versions of what is notionally the same file format. Extracting data and converting files into new formats is a significant task in any IT migration. An organisation that adopts Open Standards will only have to do this once in order to move its files to a format that is fully and publicly documented. Thereafter, it is easy to use (and if necessary build) tools to convert files from one open format to another as needed.</p>
+<p>However, UKG should be clear about the fact that breaking free from vendor lock-in will require an initial effort. Experience from numerous other countries in Europe and around the world shows that policies such as the one proposed can only be implemented if the people who are supposed to implement them -- procurement and IT teams in public bodies and private organisations exercising public functions -- receive training and assistance. </p>
+<p>The costs of these efforts (which are really costs that the user organisation incurred at the time it chose a proprietary IT solution or document format) will be quickly offset by savings realised by buyers in a more competitive IT service market.</p>
 
 
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