“Effectiveness of Federal Agency Participation 

In Standardization in Select Technology Sectors” 

 A public Request for Information on behalf of the 

Sub-Committee on Standards of the 

National Science and Technology Council 

AN INTELLEGERE® WHITE PAPER  

Prepared in Response to Federal Register Notice 

Requesting Comments on the NIST RFI 

January 18, 2011 

Copyright 2010-2011 Intellegere Foundation® 

SM 

Intellegere® response to NIST RFI©

1 

COMMENTS ON NIST RFI 

"Effectiveness of Federal Agency Participation 

In Standardization in Select Technology Sectors." 

A public Request for Information on behalf of the  

Sub-Committee on Standards of the  

National Science and Technology Council  

This paper is in response to the National Institute of Standards and Technology (NIST) Request  

For Information (RFI) for "Effectiveness of Federal Agency Participation In Standardization in 

Select Technology Sectors."i  These comments also address more broadly some additional 

standardization issues within the Information and Communications Technology (ICT)ii area

iii, 

first some broadly general issues followed by some specific examples.  

NEED FOR A NEW APPROACH 

Global leadership of ICT standards is an element of a nation’s international competitiveness.   

The importance of ICT standards leadership to our national interest is ever increasing due to 

many factors such as:  

• Pervasive intrusion of the World-Wide-Web, Internet, and social networking technology 

into every area of public and private sector interface and interchange;  

• Widespread move to networked systems and increasing need for interoperability and 

information sharing;  

• Globalization – companies changing focus from US-only to a global focus;  

• Serious cyber-security and identification protection needs;  

• Growing international threat to reduce US global leadership in ICT and undermine the 

global competitiveness of the US;iv  

• Rising costs and economic uncertainty. 

To meet these new challenges, the US needs a new and better approach to information and 

communications technology (ICT) standardization and implementation – new structures and 

methods, expanded participation, as well as updated Federal policies and proactive support.  

Some will argue that the current approach and attendant infrastructure serves our nation well.  

Others, as argued in this paper, disagree. Significant improvements are needed and must be 

supported by the US Government else the consequences will be detrimental to our economy. 

Needed changes can be made given the likely support of the current administration. 

We have a different approach than most other nations.  For example, the European Union 

underwrites participation in regional standards development organizations (SDOs)/standards 

setting organizations (SSOs) and incorporates standards into public policy and law.  Many 

Intellegere® response to NIST RFI©

2 

regions are developing increasing levels of participation in the creation and use of standards. 

China is aggressively pursuing global standards involvement and leadership. Other nations 

promote and fund standards participation:  their votes on standards and positions on standards 

issues in SDO/SSO reflect their coordinated national policy. The US needs to find ways to better 

represent national interests in global standards fora. 

In the aerospace industry, the Aerospace Industries Association (AIA)  has recognized the 

importance of global standards and is expanding its collaboration with Europe to  set those 

standards. 

In the Federal sector, it is imperative to change our focus from building government-unique 

and/or US national standards to collaborating on and facilitating global standards that reflect 

US interests (or at least are not harmful to US competitiveness). There is a strong need for 

broader Federal participation in external SDO/SSO (de jure, consortia, professional society, 

industry association, etc.) activities. There is a need for proactive and aggressive Federal direct 

involvement in and policy leadership of ICT standardization for the nation. 

Effective Federal stakeholder participation in relevant private sector SDO/SSO is the critical 

breeding ground for addressing Federal requirements in tandem with global ICT standards 

development and implementation. This requires top level management support and adequate 

resources – two elements currently needing serious attention. 

Public law proscribes Federal participation in private sector standardizationv. Yet, the current 

Federal approach is pallid, piecemeal and uncoordinatedvi. There is a need to establish means 

for increased and robust participation, better representation of Federal requirements into 

appropriate and relevant SDOs/SSOs, feedback from SDO/SSO activities back to Federal 

stakeholders, and coordination of Federal positions on cross-cutting standards issues.vii

  Kindly 

note that current Federal presence in a majority of ICT standards activities is nil – and where 

participation does occur, it is usually severely anemic. 

At the national level, there is a need to be more realistic in assessment of what new standards 

projects to support (e.g., the cell phone – two competing standards exist: GSM and CDMA).viii

We note that a majority of the world's cell phone subscribers – more than 80% – use the GSM 

technology standard.  In this case, we found ourselves (the US) isolated from the rest of the 

world – we built and are using one standard and the rest of the globe built and implemented a 

different one. Changed attitudes and international coordination would have produced a better 

result: a single global specification (that US-based vendors could build to and supply the larger 

global market place). 

There is a need to help change and improve the global ICT standardization process. Standards 

development activities need to be managed as a project – not as a ‘hobby’ by academics, 

altruistic enthusiasts nor as livelihood for consultants – with specific and measurable objectives, 

scoped boundaries, set deliverables, sufficient resources, and reasonable schedules:  no more 

endless drifting of a standards activity schedule, no more ‘standards-for-standards sake’, no 

Intellegere® response to NIST RFI©

3 

more esoteric technology pursuits that lack practical or market utility.  The US can pressure 

SDO and SSO to address these needs. 

Instead there needs to be standards project management reviews, controlled milestone events, 

and capabilities to work electronically with minimal face-to-face meetings (emulate ISO 

TC184/SC4 and OASIS examples for teleconferences, open source tools such as SourceForge, 

wikis, electronic voting, videoconferencing, collaboration, information sharing, newly available  

tools and techniques, etc.). There is a need to better educate and encourage standards project 

participants and their sponsors of these urgent requirements and the need for them to insist 

upon requisite policy and process changes within the SDO/SSO to make it happen. Federal level 

participation in relevant SDO/SSO could help initiate such needed changes. 

SDO/SSO participants must insist upon producing deliverables that are actually used – that are 

incorporated into conforming commercial-off-the-shelf (COTS) products, i.e., vendors build 

COTS products that employ open standards. With the Federal government being one of the 

largest user communities in the marketix, it could (like the European Union does), certainly 

pressure SDOs/SSOs to adhere to this principle.  

The Federal government can help standards project participants to insist upon ‘good’ processes 

whereby a SDO/SSO quickly and efficiently produces a quality technical specification (standard) 

that reflects a user/business case via an engineering and management process that considers 

relevant user and business/industry input.  The process ought to be requirements driven. It 

must use a proven engineering methodology, be managed as a project with coordinated 

expectations, correctly applied expertise, specific deliverables, adequate resources, realistic 

schedules and associated accountability. Again, the Federal government is well positioned to 

influence this through effective participation and involvement in relevant SDO/SSO (e.g., as 

public law proscribes, Federal participants should seek leadership positions within the SDO and 

SSO). 

There also is a need to find ways for ICT standards development and implementation to better 

keep pace with technology evolution.  We need to be better able to discern when best to 

introduce new standards.  There is a natural tension between technology evolution and 

standards setting.  Timing is critical.  Our experience shows that finding the right timing balance 

is complex  –  introducing a new standard too soon often kills innovation and creativity (the 

root of technology evolution and competitiveness), but introducing new standards too late 

begets significant economic and social costs, e.g., the old home video standards format war:  

Beta (Sony Betamax) vs. VHS (Video Home System). Again, the Federal sector can help influence 

this. 

Our observation is that there seems to be a relationship between hot new technology and the 

level of consortia activitiesx. This ‘metric’ can provide us with some clues about the relevance of 

a new technology for Federal government transformation via new technologyxi.  The key here is 

to encourage the new consortia and other SDOs/SSOs to collaborate with each other to 

produce better technologically current standards that vendors use in COTS products.  The end 

Intellegere® response to NIST RFI©

4 

goal being widespread recognition, acceptance, and use of ICT standardization process 

deliverables.  

It is important for the US to exert influence to encourage SDOs/SSOs to find and employ ways 

to better collaborate across all standards builders – de jure, consortia, professional society and 

industry associations  –  and involve all stakeholders,  public and private,  in a faster, more 

efficient and robust process that emphasizes openness, is financially holistic and secure, 

synergistic, transparent and accountable. Re-vitalizing the US standards infrastructure and 

attendant policies and procedures would help enable this. The Federal government could 

directly encourage this within the US (e.g., offer tax incentives to off-set costs of standards 

participation)xii

.  

There is a strong need to find ways for inclusion of all stakeholders, especially the small-to-

medium-size business enterprises which are conspicuously absent from the current system.  

There is a need to continue to support the ‘bottom-up’ voluntary system and have the private 

sector lead. While consensus, open participation, and due process are negative draws on 

process speed during open standards creation, they are vitally important elements whose 

continuance needs to be supported.  

But we also need more public-private collaboration and partnering to produce needed 

market/user supported open standards. And at the same time, we need to promote 

coordination and collaboration across business, industry, academia, and Federal sectors. 

There is an overwhelming need to foster information sharing and collaboration across the 

entire ICT global standards community. There is currently too much wasted effort that could 

more efficiently be put to better and more productive use. 

One of the problems is self-imposed. Experience shows that in the US we have been using a 

short-sighted approach of corralling standards building into industry sectors whereby the 

various participants in these sectors operate only within their “swim lanes”.  This limited 

approach is what is prescribed in the “US National Standards Strategy”xiii

 and it might work well 

in some industry sectors – but it is actually counter-productive and exacerbates the inherent 

‘rice bowl’ issues within the area of ICT technology.  It ill serves our nation in addressing 

business and social changes and global competitiveness challenges of evolving new ICT 

technology (e.g., cyber-security, etc.), user needs (information sharing, interoperability, 

networking, mobility, etc.), and the semantic web.  Instead, it results in fragmentation and 

duplication of effort, re-enforces turf struggles, and ignores cross-sector needs and issues. It 

does not encourage cross-sector information exchange and collaboration. 

The convergence of computer and communications technology highlighted the shortcomings of 

this non-synergistic approach and exacerbated the standards community turf issues and the 

duplication and fragmentation of efforts that is unnecessary and so costly [e.g., IEC TC100xiv

 and 

the Digital Audio Visual Council - DAVIC]. Yet we continued the same approach when the 

Intellegere® response to NIST RFI©

5 

American National Institute for Standards - ANSI published the revised US National Standards 

Strategyxv

.  

We are finding this issue to be even more perplexing as we pursue the current administration’s 

ambitious goals for cloud computing,  smart grid, health information exchange, education, 

clean energy, better security, etc. xvi

  Today’s global economic competitiveness and the 

pervasiveness and pace of new technology evolution require new approaches to this specific 

problem.xvii

The challenges we now face require new and better standards and profiles to be developed, 

tested and implemented quickly across very complex business and industry sectors and domain 

interfaces.  They beg for widespread and comprehensive coordination and collaboration when 

creating and implementing new standards and profiles. They require a more efficient and 

effective approach. As a nation, we simply cannot afford to continue encouraging the narrow 

“swim-lane” approach to ICT standardization. 

The author has been working with the ICT global standards community for a very long time and 

one observation is the frequent fragmentation and duplication of effort that occurs – usually 

rooted in rice bowls and egos.  This drains and dilutes the precious few resources that can be 

devoted to important new standards development activities. 

This problem is exacerbated by the fact that there is little incentive for individual SDO/SSO to 

voluntarily reach out and collaborate with other SDOs/SSOs to address comprehensive and 

complex cross-sector standards issues (e.g., smart grid, cyber-security, semantic web, etc.).  

This is an area where the Federal government could help provide a solution, for example, 

provide incentives such as seed funding certain initiatives, sponsoring public technology 

workshops and summits that address specific standardization needs, initiating public-private 

partnerships such as highly successful new standards and technology project examples like 

CALS, PLCS, NCOIC, Smart Grid (NIST-SGIP)xviii

, etc. 

Collaboration, cooperation and information sharing among standards-setting organizations 

(SSOs) working in the same area is a good thing.  It can happen through government incentives, 

procedural mechanisms at ANSI (for US accredited SDO), regular communications between 

SDOs and SSOs, and direct open communications among their overlapping members/ 

participants (who have strong business and economic incentives to minimize unnecessary or 

undesirable conflict or duplication of efforts).  

Across the Federal sector, NIST could serve as the focal point for Federal level information 

sharing and collaboration on ICT standards relevant to government transformation.xix

  Indeed, 

NIST is beginning to take this approach with Cloud Computing. 

NIST could also provide training to the Federal level representatives participating in various 

SDOs/SSOs to teach them how to formulate, coordinate and promulgate US interests in their 

SDO/SSO processes and substantive deliverables.  For example, Federal participants in the 

Intellegere® response to NIST RFI©

6 

SDOs/SSOs could insist upon efficient and effective SDO/SSO processes and procedures be 

employed that exhibit characteristics such as: 

• Performance vs. processxx

• Marketplace support 

• Technology relevance 

• Managed as a project 

• Published quicklyxxi

PROJECT EXAMPLES 

Following are twelve standards projects that the author either initiated, or participated in, that 

provide excellent examples of various aspects of public-private ‘partnerships’ and/or novel 

approaches for standards creation and which are offered as examples to be emulated. 

eForms – An internal Department of Defense (DoD) project to automate business forms 

used in the government. Began with all interested parties  –   government sponsors, 

government users, independent testers, vendors, standards ‘techies’, etc. starting with a 

‘blank sheet of paper’. The joint team simultaneously developed requirements and 

conformance test specifications in parallel. Thus, Vendors were provided up front with 

test harnesses which enabled them to reduce project risk, eliminate the ambiguity of 

requirements common to other projects, expedite their development schedule, and 

perform quality checks to ensure compliance. By collaborating and jointly working 

together a complete new specification was ready for publication within only 11 months.   

The completed draft specification was then input to a major private sector SDO for 

adoption and publication (did not want to publish a government-unique standard).  

However, the project was hi-jacked at that point by a single individual.  There was a 

serious flaw in that particular SDO’s process requiring all members to unanimously 

agree before publication  –   which enabled a lone disgruntled ‘techie’ who was as a 

member of the SDO (but outside the project team) to object and thus wrongly veto the 

entire process. The specification never was published as a standard but the vendors 

went ahead and marketed their implementations separately. Thus each unique 

implementation soon migrated to the point that interoperability among 

implementations was lost (i.e., subsequent versions deviated from the draft 

specification that had been agreed upon but not published). Several important lessons 

were learned by all including the SDO which subsequently changed their voting rules 

and publishing process. 

Intellegere® response to NIST RFI©

7 

PLCSxxii

 – Born in the NATO data model experience, collaborated with British Ministry of 

Defense (MOD), supported by US DoD and other resources, a consortium was 

established as a government-private sector partnership to build a new standard in ISO 

and then create a corresponding detailed set of data exchange standards for tailored  

implementation.  The PLCS consortium worked closely with US and other National 

Standards Bodies, Government agencies (US, UK, Norway, Finland and Sweden) and 

global business and industry entities.  The result was published as an ISO standard [ISO 

10303 AP 239]. Subsequently, the joint team took the additional follow-on work to 

another SDO  – the OASIS consortium –  to develop and publish detailed data exchange 

set standards that are used in the implementation of PLCS in various user sectors (e.g., 

logistics, electronic commerce, etc.). This is an excellent example of governments, the 

private sector, de jure SSO and consortia SDO working together to quickly and efficiently 

build a new major standard and corresponding detailed implementing standards. 

SC4 Harvestingxxiii

 – the ISO TC184/SC4 Committee for Industrial Data established a 

mechanism whereby specifications created outside the de jure standards setting arena 

(e.g., government specifications, consortia documents, etc.)  can very quickly  be 

“harvested” by bringing them into the international de jure standards community and 

adopted as an accredited international standard. This approach offers the US 

government a significant opportunity to “harvest” relevant internal specifications to 

become internationally accredited standards. This concept needs to be expanded 

throughout the ICT standards global arena. The US standards community could exert 

influence and insist upon this happening. 

CALSxxiv

 standards – Two Federal agencies formed a public-private partnership for 

creation and maintenance of the CALS series of standards with government and industry 

co-chairing the standards committeexxv

. Extensive collaboration between the 

government (numerous agencies/organizations throughout the logistics and electronic 

commerce communities) and the private sector (multi-national companies, vendors, 

system integrators, consultants) and academia was the result. The deliverable results 

were published as a series of new standards (MIL-PRF- 28000 series) and subsequently 

transformed into succeeding projects to incorporate these requirements into accredited 

international standards published by private sector SDOs/SSOs. 

CALS  test network  – An example of public-private sector shared resources in operating 

the CALS test network that was formed to test vendor produced CALS standards 

implementations. 

Intellegere® response to NIST RFI©

8 

VRML/Web 3d – government ‘seed funding’ example to accelerate standards project 

schedule.  As Federal agency representatives participated in a project to develop a new 

global standard, it was discovered that slow progress on creation of the standard was 

beginning to lag behind the pace of technology evolution and market place needs. So 

the government agency provided a minimal level of “seed funding” to accelerate the 

project schedule (by paying for the cost of the editing process, thereby collapsing the 

schedule).  This particular project and resulting international standard [Virtual Reality 

Modeling Language (VRML)]xxvi

 then evolved to the global Internet’s widespread 

acceptance and implementation. 

OOXMLxxvii

 – Three Federal agencies were participating in the de jure standards process 

for creating a new global  de jure standard for office automation.  The project became 

very controversial with competing sides attempting to divide the government into 

opposite factions. Thus, the Federal participants agreed to caucus and thereby present a 

unified Federal government input/position on this controversial major new standard. 

DOCUMENT INTERCHANGE SYMPOSIUM – A Federal agency sponsored/hosted an 

invitation-only symposium of internationally known technology experts to address how 

emerging new technology can help the government with efficient document 

interchange and interoperability management (specifically, consensus resolution of 

ODA, ODIF, PCL, PostScript, SGML, etc. standardsxxviii

 issues). The government invited 

certain global experts to participate off-site and covered all symposium expenses 

including a stipend for the expert’s time. The symposium results were shared with 

various SDO/SSO and had an impact on the subsequent private sector development of 

interoperable document format specifications and standards. 

SGIP (Smart Grid).  An example of a new approach to standards creation that includes 

public-private partnerships, new processes, extensive collaboration, and seed funding.  

The Smart Grid Interoperability Panel (SGIP) is a consensus-based group of public and 

private organizations, created by NIST to support the agency in its role to coordinate the 

development of Smart Grid standards. While the SGIP has more than 630 member 

organizations with almost 1,800 individual representatives engaged, it seems that the 

ICT community is under-represented.  

A significant factor in the success of this new approach is the seed funding provided via 

Congressional direction. While the SGIP does not develop or write these standards 

directly, it works with existing standards organizations (de jure, consortia, industry 

associations and professional societies) to coordinate and accelerate the development 

of standards considered critical to achieving a nationwide Smart Grid. A significant new 

Intellegere® response to NIST RFI©

9 

approach to standards building includes the use of “Priority Action Plans (PAPs)”.  PAPs 

arise from the analysis of the applicability of Standards to the Use Cases of the Smart 

Grid. PAPs include identified experts in relevant SDOs, known as the PAP Working Group 

Management Team.  A PAP addresses either:  

A gap where a standard or standard extension is needed:  i.e., The need for 

meter image-download requirements is an example of a non-existing standard 

needed to fill an identified gap. 

An overlap where two complementary standards address some information that 

is common but different for the same scope of an Application:  i.e., Metering 

information where CIM, 61850, ANSI C12.19, SEP 1&2 all have non-equivalent 

methods of representing revenue meter readings. 

PAPs are created when the SGIP determines there is a need for interoperability 

coordination on some urgent issue. The PAPs themselves are executed within the scope 

of the SDOs and Users Groups that sign up for tasks that implement the plans. The SGIP 

facilitates this process, ensures that all PAP materials are publicly available in real time 

on a TWiki, and provides guidance when the participants in the PAP are at odds or 

unsure of its goals. 

NCOIC – Established a CRADAxxix

 to jointly (government and industry) work on net 

centric issues. Three tasks were formulated and resulted in individual working groups 

for each task. Significant contributions to the technology resulted (e.g., “patterns” 

approach to requirements and standards analysisxxx

). 

NCOIC TASK1 - [netcentricity task].   Established a working group to jointly 

(government and industry) work on definitions and meaning of netcentricity and 

its significance to the Federal government as well as the public and private 

sectors. 

NCOOIC TASK 2– [Standards task].  Established a working group to jointly 

(government and industry) work on identifying standards needed for net centric 

operations implementation. Produced a standards framework and useful 

taxonomy.  

NCOOIC TASK 3 – [Cloud Computing task].  Established a working group to jointly 

(government and industry) work on means for establishing a geospatial cloud 

computing application. 

Country Codes Tiger Team –  An ad hoc team created by an agency to establish a new 

profile and implementing guidelines for replacing an obsolete Federal standard (FIPS 10-

Intellegere® response to NIST RFI©

10

4). The team is collaborating with Federal government-wide agency representatives and 

with private sector SDO and SSO to build a new profile of ISO 3166 and FIPS 10-4. 

ISO 8000 – A Government agency provided seed funding for the development of ISO 

8000, the international standard for data quality and ISO 22745, the international 

standard for the exchange of quality data, as a means of encouraging industry to 

provide faster, better and lower cost access to the data required to describe items of 

supplyxxxi

. 

SUMMARY 

It is strongly in the best interest of the US to properly invest in the ICT global standardization 

infrastructure and processes. Such investments have great dividends: in cost savings and in 

enhancing national security and global competitiveness. 

The private sector led voluntary ‘bottom up’ consensus aspects of the US ICT standards 

approach are good but the overall standards making system faces serious problems and is in 

need of significant improvement – issues such as:   

• viscosity of embedded procedures,  

• dwindling participation,  

• absence of small to medium size businesses,  

• anemic Federal participation,  

• lack of Federal-wide information sharing and collaboration, and the  

• counter-productive ‘swim-lane’ (sectorial) approach.  

These issues place the US at a disadvantage with respect to other nations in the ICT-standards-

aspect of global competitiveness.  It is suggested that these complex problems and issues will 

increase  –  not diminish  –  in the future if ignored. 

More government collaboration and coordination of standards creation and adoption is needed 

(internal and external).  The Federal government now has an opportunity to significantly affect 

US ICT standardization infrastructure and processes.  The Federal sector is able (if willing) to 

exert significant influence on private sector standards development and implementation.  

To improve the US ICT standards infrastructure and processes, lessons learned from past 

projects of public-private partnerships, such as depicted in Table 1 below, should be 

incorporated in Federal initiatives designed to change the current approach. There are many 

opportunities available through government incentives (“seed funding”, other financial 

incentives, etc.), procedural mechanisms at ANSI (for US accredited SDO), regular 

Intellegere® response to NIST RFI©

11

communications between SDOs and SSOs, and facilitating direct open communications 

(teleconferencing, web-conferencing, wikis, etc.).  

We must also address how to best engage government agencies on standards policy issues, 

articulate a US model of public-private cooperation in standard setting to domestic and 

international audiences, and develop increased awareness within the Federal government of 

best practices in addressing-standards policy and procedural issues. 

Across the Federal sector, NIST could serve as the focal point for Federal level information 

sharing and collaboration on ICT standards relevant to government transformation.xxxii

  It is in 

the best interests of the nation to sufficiently empower and resource NIST to lead the Federal 

sector in ICT standardization. 

NIST could also provide training to the Federal level representatives participating in various 

SDOs/SSOs to teach them how to formulate, coordinate and promulgate US interests in 

SDO/SSO processes and substantive deliverables.  Trained Federal participants in SDOs/SSOs 

could then insist upon efficient and effective processes and procedures to be employed. 

We do believe very strongly that it is critically important to support creativity and innovation in 

technology and standards evolution! Indeed, the marketplace shall ultimately decide the 

winners when there are multiple versions and new technology thrusts – as opposed to some 

standards committee determining the outcome of such issues. Finally, what is most important 

is not a particular standard in itself but rather what is done with that standard – its 

implementation and use is vital.  Robust Federal engagement in the US national and the global 

ICT standardization community can help ensure adherence to these important principles. 

Intellegere® response to NIST RFI©

12

Intellegere® response to NIST RFI©

13

END NOTES:  i Federal Register /Vol. 75, No. 235 /Wednesday, December 8, 2010 /Notices 76397.  DEPARTMENT OF COMMERCE, National Institute of Standards and Technology, [Docket No. 0909100442–0563–02], Effectiveness of Federal Agency Participation in Standardization in Select Technology Sectors for National Science and Technology Council’s Sub-Committee on Standardization, AGENCY: National Institute of Standards and Technology (NIST), Department of Commerce. ACTION: Request for Information. 

 ii ICT is the generic name used by the author to include the information technology (IT) and the communications (including telecommunications) technology areas.  Many currently simply use “IT” to include both.  iii Perceptions based upon the author’s extensive and longstanding direct involvement in myriad consortia, professional society, industry association, and national and international and, de jure Standards Development Organizations/ Standards Setting Organizations (SDO/SSO). This experience includes current and/or past involvement as a standards committee chair, vice-chair, co-chair, rapporteur, convenor, editor, secretary, and national body head of delegation, as well as service on standards management committees and consortia executive boards.  iv In late 1990 European standards organizations (such as CEN, et al)  began increasingly introducing new standards that many observed directly undermine U.S. competitiveness in the global marketplace. SEE: American National Standards Institute (ANSI) – “ANSI On The World Stage”.  

 v SEE: National Technology Transfer and Advancement Act of 1995, Public Law 104–113, 110 Stat. 775— 784 (1996).  OMB Circular A–119 Revised, Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities (rev. Feb. 10, 1998). 

 vi This is the author’s observation in at least the ICT area. 

 vii e.g., the OOXML office document format standards debacle – Federal level consensus on engagement 

was needed. In the OOXML case, three Federal agencies were involved –  Department of Homeland Security (DHS), NIST and the Department of Defense (DoD) –  and the author proposed a Federal caucus with NIST in the lead: a good example for replication of Federal involvement in ICT SDO/SSO and standards activity information sharing and collaboration across the Federal sector.  viii GSM is Global System for Mobile Communications developed and published by the European 

Telecommunications Standards Institute (ETSI). CDMA is Code Division Multiple Access adopted by the US Telecommunications Industry Association (TIA).  CDMA is a Qualcomm-created mobile technology that originated in the U.S as a second-generation digital mobile telephone standard which took a different approach to a competing standard: GSM.  It is the author’s perception that, in this case, ego and rice-bowl concerns overruled the necessary global collaboration and coordination. 

 ix The United States Government is the world’s largest consumer of information technology, spending over $76 billion annually. 

 x Kindly note the current proliferation of Cloud Computing activities. 

 xi “Use technology and lessons learned from the private sector to improve efficiency across every level of government ...”  President Obama.  

Intellegere® response to NIST RFI©

14

                                                                                                                                                                                           xii E.g., enable participation in accredited SDO/SSO standards activity actual costs (membership fees, 

travel, and labor)  to be accepted as allowable deductible expenses.   xiii The National Standards Strategy for the United States (NSS), published by the American National 

Standards Institute (ANSI) was approved in August 2000. This first NSS reaffirmed that the U.S. is committed to a sector-based approach to voluntary standardization activities, both domestically and globally. It established a standardization framework that was built upon the traditional strengths of the U.S. system — such as consensus, openness, and transparency — while giving additional emphasis to speed, relevance, and meeting the needs of public-interest constituencies. Strategic and tactical initiatives contained within this framework were developed so that they could then be used by diverse interests to meet their own national and individual organizational objectives.   

 xiv

  International Electrotechnical Commission Technical Committee 100: Audio, Video and Multimedia 

systems and equipment   

 xv The revision of the NSS is now known as the United States Standards Strategy (USSS), was published 

by ANSI in 2005. The name change recognizes globalization and the need for standards designed to meet stakeholder needs regardless of national borders. The name also reflects a standardization environment that incorporates new types of standards development activities, more flexible approaches, and new structures. However, the basic approach is still a sectorial approach to standards building.   xvi “ ... harness technology to confront the biggest challenges that America faces ...” President Obama 

 xvii

 “The current standards development infrastructure was never designed to create the closely integrated  

standards needed to solve the complex problems embedded ... in the technology and innovation agenda ...” Andy Updegrove  xviii

 The acronyms are:  CALS – Computer Aided Logistics Support 

PLCS – Product Life Cycle Support NCOIC – Net Centric Operations Industry Consortium Smart Grid (NIST-SGIP) – Smart Grid Interoperabiity Panel  

xix “Unleash creativity ... Drive transparency ... Ensure accountability ... “  President Obama 

 xx Standardize on desired performance instead of process – specify interfaces rather than components; 

i.e. data formats and protocols rather than software modules. “ ...any place we can get a critical mass of 

the marketplace to get together and do the hard work of testing, internationalization, accessibility in a reasonably timely, fair and accountable way is a place ... to do more good than harm.” Dan Connolly  xxi It is critical that new standard development projects establish and publish deliverables quickly (apply 

the Pareto Principle – the “80-20 rule” to their work and schedule) then make improvements to be published in subsequent editions.  The PREMO standards projects is a good example how schedule slippage can torpedo a good standard. The Presentation Environment for Multimedia Objects (PREMO) project began well with widespread participation and technical contributions from many experts and vendors. The project quickly built a good specification but the academic project editors held the document back for an additional 18 months to “perfect it”.  Consequently, when it was finally voted on and published, all of the vendors had lost interest in building conforming implementations. Thus, the published standard is technically excellent [See: ISO/IEC 14478-Information technology – Computer graphics and image processing – Presentation Environment for Multimedia Objects (PREMO)] but it has zero implementations! 

Intellegere® response to NIST RFI©

15

                                                                                                                                                                                           xxii Product Life Cycle Support (PLCS) is an ISO STEP standard (ISO 10303-239) that enables the 

creation and management through time of an Assured set of Product and Support Information which can be used to specify and control required support activities throughout a complex product's life. ISO 10303-239 provides an application-specific, but flexible, information model as part of the ISO STEP series of standards. The information model can be tailored by industry and organizations through the use of Reference Data Libraries (RDL). The role of RDL is to complete the semantics of the PLCS model necessary for deployment in industry. The benefit of ISO 10303-239 (PLCS) is its integrated view. However this means that it has a large and generic information model that is larger in scope than most business processes require or most IT applications can manage. This problem is addressed by defining sets of "Data Exchange Specification (DEX)". A DEX is a way of dividing up the ISO 10303-239 (PLCS) information model into sections suited for a particular business process. A DEX provides a subset of the PLCS information model and usage guidance. A DEX can be used to contract against or for setting conformance but AP239 implementations do not have to use DEXs. ISO 10303-239 (PLCS) has been published as an ISO standard. The DEXs are initially being standardized by publishing the subset of ISO 10303-239 (PLCS) and associated usage guidance material as OASIS standards. Once they have been used extensively, they will be included as conformance classes of ISO 10303-239 . xxiii

 The concept of “harvesting” was first introduced by Dr. Steve Carson when he was chairman of the ISO/IEC JTC1 SC24 international standards committee. 

xxiv CALS (Continuous Acquisition and Life-cycle Support) was a Federal initiative for electronically 

capturing documentation and linking related information.  The initiative has developed a number of standard specifications (protocols) for the exchange of electronic data with commercial suppliers (MIL-PERF 28000 series). CALS includes standards for electronic data interchange, electronic technical documentation, and guidelines for process improvement which have been adopted by several other allied nations. Also, The CALS initiative has endorsed the internationally accredited  IGES and STEP standards as formats for digital data. The CALS Table Model is a DTD standard for representing tables in SGML/XML. (see also DocBook). The CALS Raster file format was developed to standardize on graphics data interchange for electronic publishing for the federal government.  

xxv The CALS initiative has endorsed the internationally accredited  IGES and STEP standards as formats 

for digital data. IGES is Digital Representation for Communication of Product Definition Data, first published by the U.S. National Bureau of Standards (now NIST) as NBSIR 80-1978 is an ANSI (US national) standard (also referred to it as ASME Y14.26M)  The IGES project was initiated by a group of CAD users and vendors, including Boeing, General Electric, Xerox, Computervision and Applicon, with the support of NIST and the U.S. Department of Defense (DoD).  

STEP (ISO 10303) is an ISO standard for the computer-interpretable representation and exchange of product manufacturing information. Its official title is: Automation systems and integration — Product data representation and exchange. It is known informally as "STEP", which stands for "Standard for the Exchange of Product model data". The International standard's objective is to provide a mechanism that is capable of describing product data throughout the life cycle of a product, independent from any particular system. The nature of this description makes it suitable not only for neutral file exchange, but also as a basis for implementing and sharing product databases and archiving. Typically STEP can be used to exchange data between CAD, Computer-aided manufacturing, Computer-aided engineering, Product Data Management/EDM and other CAx systems. STEP is addressing product data from mechanical and electrical design, Geometric dimensioning and tolerancing, analysis and manufacturing, with additional information specific to various industries such as automotive, aerospace, building construction, ship, oil and gas, process plants and others. STEP is developed and maintained by the ISO technical committee TC 184, Automation systems and integration, sub-committee SC 4, Industrial data. 

xxvi VRML (Virtual Reality Modeling Language is a standard file format for representing 3-dimensional (3D) 

interactive vector graphics, designed particularly with the World Wide Web in mind, and developed by 

Intellegere® response to NIST RFI©

16

ISO/IEC JTC1 SC24. The Web3D Consortium was formed to further the collective development of the format. VRML (and its successor, X3D), have been accepted as international standards by the International Organization for Standardization (ISO). The first version of VRML was specified from, and very closely resembled, the API and file format of the Open Inventor software component, originally developed by SGI. The current and functionally complete version is VRML97 (ISO/IEC 14772-1:1997). VRML has now been superseded by X3D (ISO/IEC 19775-1).  xxvii

 Office Open XML (also informally known as OOXML or OpenXML) is a zipped, XML-based file format developed by Microsoft

 for representing spreadsheets, charts, presentations and word processing 

documents. The Office Open XML specification was initially standardized by ECMA (as ECMA-376) and later by ISO and IEC (as ISO/IEC 29500).  xxviii

 These acronyms are:  ODA – ISO Standard 8613 "Office Document Architecture (ODA) and Interchange Format"  ODIF – Open Document Interchange Format  PCL –  Printer Control Language  SGML – Standard Generalized Mark up Language  xxix CRADA - Cooperative Research and Development Agreement 

 xxx

 Patterns can provide incremental architecture guidance to enable specific networking collaborative capabilities through a recommended structure of related architectural functions and standards. These patterns promise to have a positive impact on reducing the complexity, risk, and costs for development of architectures within the context of multi-enterprise, multi-system environments.  xxxi

 This is a good example of the effectiveness of Federal agencies' participation in standards-setting efforts led by the private sector.  ISO 8000 and ISO 22745 are the result of a minimal investment by a Federal agency to seed fund the editing work of standards creation and collaborative efforts by private sector SDOs – the ECCMA and ISO TC184/SC4. The result is effectively driving transparency in the international data supply chain by implementing a standard method across industry sectors for identifying and describing individuals, organizations, locations, assets, goods, services, processes, rules and regulations in a multilingual environment.  xxxii

 “Use technology and lessons learned from the private sector to improve efficiency across every level of government ...”  President Obama.   

_____________________________  

Comments prepared by Jerry Smith for Intellegere Foundation® 

www.intellegere.org 

The non-profit Intellegere Foundation® is a public service enterprise dedicated to science and 

technology research and education and created for the purpose of establishing a standards 

clearinghouse.  Intellegere® is a 501(c)(3) non-profit public service charitable foundation and is 

CCR/DUNS registered.  Intellegere® is supported through tax deductible grants and contributions, and 

through the provision of technical support services.   Contact: Pete Nielsen, Chief Operating Officer (888) 

696-4497.  pete.nielsen@intellegere.org