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Subject: RE: Representation Types Alternatives

Probert, Sue
> BTW I do not have a copy of 11179 as it is an extensive set of 
> documents which ISO like to be paid for! Like most other ISO docs 
> it is rarely at hand electronically. 

As a small business person I would like to formally protest
these EBXML activities based on copyrighted "standards" which 
cannot be obtained without payment. 

This includes all of ISO, and it apparently includes all of
the X12 dictionary and supporting documents.  This may also
include EDIFACT and X12 MIGs.  Why are NGOs treated better than
software companies? 

It is inappropriate and systematically unfair, especially for
Quasi-governmental organizations like UN/CEFACT, to be setting
standards that individuals and small businesses will be required
to follow, but which cannot be understood without paying for
documentation.  The cost of participating in ebXML and other
bodies is already excessive to small business, resulting in
disenfranchising them from the tradeoffs that are being made.

Further, these pricing policies have the effect of driving away
technical and business domain participation, needed by ebXML.

I'm fully aware standards work has economic costs. But charging
for copies of standards is the wrong way to recover them.

The same situation exists in GAAP reporting: the AICPA and FASB
in the US are private organizations who set rules, which are
then strongly enforced by federal and state regulators.  These
GAAP requirements cost approximately $500 per year to subscribe to.
But if I don't pay this money, it is de-facto impossible to
follow the rules.  As a CPA I can lose my license, and be put in 
prison if I don't obey every word of those rules, even when
preparing financial statements for nonpublicly listed companies.

For your information, the result of this structure is that it
incents the private organization to needlessly churn the rules, 
and to create unnecessarily complex rules, in order to maximize
their own roles and revenue stream.  Many small practitioners 
believe these incentives are a significant problem affecting
the AICPA and FASB.  

It is widely agreed that tax laws are driven by the same dynamic, 
of intentional churn and rule complexity to garner economic gains
for particular industries.  Churn and complexity are common strategic
tools in software companies to defend market positions, and have
been applied by the legal profession in some areas of commercial 
law as well.

Think about it.  The "data standards" industry may have parallels.
What if nobody can even play the game until they are $30,000 invested
in the rules?  Then they have incentives to prevent newcomers from
entering the industry for free.  It's like a cancer.  Actors in
the data standards wars already have enough incentives for complexity!
Now you have permanent standards bodies, requiring churn as their
revenue model.

The key issues are fairness and goodwill, leading to wider adoption,
and simplifying standards by increasing transparency, and reducing 
incentives for churn and complexity.

Todd BOyle CPA
Kirkland WA

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