Federal Geographic Data Committee • www.fgdc.gov • Email: fgdc@fgdc.gov 

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Federal Geographic Data Committee 

March 4, 2011 

Dr. Patrick Gallagher, 

Director, National Institute of Standards and Technology (NIST) 

Co-Chair, National Science and Technology Council's SubCommittee on Technology. 

Subject : Effectiveness of Federal Agency Participation in Standardization in Select Technology Sectors 

for National Science and Technology Council's SubCommittee on Standardization [Docket No. 

0909100442-0563-02] 

Dear Dr. Gallagher, 

The Federal Geographic Data Committee (FGDC) is pleased to provide comments on the Federal 

Register Announcement [DOCID:fr08de10-46] - Effectiveness of Federal Agency Participation in 

Standardization in Select Technology Sectors for National Science and Technology Council's SubCommittee on Standardization [Docket No. 0909100442-0563-02]. 

The FGDC (www.fgdc.gov) is an interagency committee that promotes the coordinated development, 

use, sharing, and dissemination of geospatial data on a national basis. The Office of Management and 

the Budget (OMB) established the FGDC in 1990 and re-chartered the committee in its August 2002 

revision of Circular A-16, "Coordination of Geographic Information and Related Spatial Data Activities." 

The FGDC is composed of representatives from the Executive Office of the President and Cabinet level 

and independent Federal agencies. The Secretary of the Department of the Interior chairs the FGDC, 

with the Deputy Director for Management, OMB, as Vice-Chair. Numerous stakeholder organizations 

participate in FGDC activities representing the interests of state and local government, industry, and 

professional organizations. 

The FGDC uses voluntary consensus standards in lieu of government-unique standards whenever 

possible, consistent with OMB Circular A-119 on Federal Participation in the Development and Use of 

Voluntary Consensus Standards and in Conformity Assessment Activities. According to OMB Circular A16, “... the FGDC ... will restrict its standards development activities to areas of spatial data 

standardization not covered by other voluntary standards consensus bodies, as defined by OMB Circular 

A-119.” Data standards not covered by other voluntary consensus standards bodies include standards 

for specific data themes; for example, cadastral (parcels), vegetation, and wetlands. These data 

standards help leverage resources across Federal agencies and enable efficient and effective data 

sharing and interoperability. Federal agencies have responsibilities to provide leadership and to facilitate 

the development and implementation of needed FGDC standards, especially data content standards for 

data themes identified in OMB Circular A-16. NIST has “validated” FGDC standards for E-Gov activities, 

as they have been developed through a rigorous standards process. 

FGDC data standards are developed through FGDC Subcommittees and Working Groups that are 

composed of representatives from various Federal agencies and representatives from non-Federal 

entities. The FGDC Standards Working Group is responsible for overseeing the FGDC standards 

process, reviewing standards, and making recommendations for FGDC endorsement of standards. NonFederal entities, including the private sector, may provide input in the development of FGDC standards. 
Federal Geographic Data Committee • www.fgdc.gov • Email: fgdc@fgdc.gov 

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OMB Circular A-16 directs Federal agencies to use FGDC standards. Further, it states that federally 

financed data development should be compliant with FGDC standards. 

The FGDC participates in voluntary consensus standards bodies as directed by OMB Circular A-119. 

The FGDC and its member agencies participate in public/private partnerships on standardization 

activities through organizations such as ISO Technical Committee 211, Geographic 

Information/Geomatics (www.isotc211.org), the Open Geospatial Consortium (OGC, 

www.opengeospatial.org), and International Committee for Information Technology Standards Technical 

Committee L1 (INCITS L1), Geographic information systems. The FGDC was a founding member of 

INCITS L1. INCITS L1 is the means by which both public and private organizations participate in 

national and international geospatial standardization activities. It serves as the U.S. Technical Advisory 

Group to ISO Technical Committee 211. Since the establishment of INCITS L1 in the 1990s, the FGDC 

has provided leadership to INCITS L1. 

The FGDC is also a member of the Geospatial-Intelligence Standards Working Group (GWG) chaired by 

the National Geospatial-Intelligence Agency (NGA). Participation ensures that there are common 

standards across military, intelligence, and civilian communities, when appropriate, as these 

communities establish a common operational environment. As noted in NGA’s response to this Request 

for Information (RFI), the GWG recommends GEOINT standards for the Department of Defense IT 

Standards Registry (DISR) and Intelligence Community Standards Registry (ICSR). Over 80% of the 

GEOINT standards cited in the DISR and ICSR by the GWG have been developed through voluntary 

consensus standards bodies such as ISO Technical Committee 211 and the OGC. Through participation 

on the GWG, the FGDC leverages the resources of the military and intelligence communities to review 

and evaluate the many standards that were developed through ISO, OGC, and other standards bodies. 

In 2010, the FGDC endorsed 64 standards that were either voluntary consensus standards or de facto

standards that have been adopted through widespread use and implementation. Many of the external 

standards that the FGDC endorsed are also listed in the DISR. The FGDC and GWG are exploring 

opportunities for alignment of their standards processes, as they recognize the benefits of shared 

standards and expertise. 

The FGDC notes the following challenges that hinder participation in standardization activities and/or 

adoption and use of standards: 

 

• ISO and ANSI charge for standards. Many Federal agencies do not agree with the idea of paying 

for standards when they have actively participated in the development of the standards, paying 

significant staff time, membership fees to the standards bodies, and travel expenses to meetings for 

collaborative standards development. Occasionally, Federal agencies lead standardization activities 

in voluntary consensus standards bodies. In cases where most of the cost of developing standards 

is borne by the Federal government, it does not make sense to Federal agencies that the user pay 

for standards when he/she has already paid for standards development through taxes. Although fees 

for geospatial standards are actually quite modest (especially for federal agencies), promotion of 

voluntary standards adoption is easier when there is no fee incurred. The FGDC recognizes, 

however, that the business model of ISO and ANSI involves the sale of standards. 

The Open Geospatial Consortium provides another business model for a voluntary consensus 

standards body: while the membership fees are high (relative cost), the standards developed through 

that organization are freely available to anyone (not just members) and very widely adopted. It is 

difficult to promote standards adoption to 50 states, 3200 counties and 39,000 local and tribal 
Federal Geographic Data Committee • www.fgdc.gov • Email: fgdc@fgdc.gov 

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governments in this economic climate, when organizations are obliged to purchase standards. This 

is an important point, since geospatial data from state, county, tribal, and local governments are 

ingested by the federal government. 

• Voluntary consensus standards often have copyright restrictions that negatively affect their 

promulgation and use. The FGDC recognizes, however, that OMB requires Federal agencies to 

“observe and protect the rights of the copyright holder and any other similar obligations” through 

OMB Circular A-119. 

• Federal agencies have limited resources to commit to standardization activities. As noted in 

the RFI, “... changing priorities or changes in an organization's budget may impact the resources an 

agency commits to an ongoing project.” The return on investment for an agency in standards 

activities is often a long-term outcome, reducing its priority level when agencies need to show shortterm benefits. In contrast to the situation in many civilian agencies, the defense and intelligence 

communities have mandated funding and dedicated staff for standardization activities. 

• The Federal civilian community needs better incentives to adopt standards for use, despite 

the pronouncements in OMB Circulars A-16 and A-119. In response to a recent FGDC 

standardization activity, one agency noted that an unfunded workload to use a particular standard 

would add work-years of additional burden to its already strained operational units. Another 

disincentive to using and adopting standards is the lack of a mechanism to enforce the use of 

standards; by contrast, standards in the DISR are acquisition-binding for the Department of Defense. 

The FGDC remains committed to participating in public/private partnerships in standardization activities. 

The FGDC leverages the knowledge, skills, and talent of the geospatial community for the development 

of standards that enable information, data, and service interoperability across government and nongovernment entities. The FGDC encourages the use of solutions that are supported by multiple vendors 

through standards developed through a voluntary consensus process. Standardization promotes open 

and fair competition in the marketplace. 

If you are interested in learning more about FGDC participation in geospatial standardization, you may 

contact me at ideloatch@usgs.gov, phone: 703-648-5752. 

Ivan B. DeLoatch 

Executive Director, FGDC 

U.S. Geological Survey 

U.S.Department of the Interior