Title: Comments on ISO/IEC FCD 15897
Date: March 5, 2008
From: INCITS/L2 (US Tag to SC2)
To: INCITS Executive Board

INCITS/L2 notes that SC35 has issued an FCD ballot for ISO/IEC 15897, Information technology - User interfaces - Procedures for registration of cultural elements. The purpose of the associated registry is to gather locale data, which enables software applications to adapt to the cultural conventions in use in various parts of the world. For example, the locale data indicates how dates, times, numbers and currency values are formatted, or how country and language names are translated across the world. To be valuable, a registry of locale data must cover many locales (i.e. many parts of the world), and must provide many elements for each locale.

The registry regulated by ISO/IEC 15897 has been in place since 1997, and has gathered very little data - covering 4 locales in 1997 and 3 locales in 2001 (see http://std.dkuug.dk/cultreg/). The amount of data gathered by this effort is vastly insufficient for any practical use, and there is no sign that this situation would change. Furthermore, this registry is based on the model described in ISO/IEC TR 14652:2004, Information technology - Specification methods for cultural conventions. Not only was this Technical Report a Type 1 report (that is, it did not receive substantial support to be submitted for ballot as an International Standard, despite repeated efforts), but SC22 resolved to cancel the project and withdraw the TR. This clearly undermines the validity of the registry, even if it contained a significant amount of data.

In contrast, the Unicode Common Locale Data Repository project, conducted by the Unicode Consortium, has gathered data about many locales (394 in the last release), often with orders of magnitude more data about each locale than can be found in the 15897 registry. The effort enjoys a broad support in the industry, both in terms of contributors (more than 160 for the last release) and in terms of users (many major software developers incorporate the CLDR data in their products). Finally, the project is very much alive, with 6 releases since 2004. More details about the CLDR project can be found at http://www.unicode.org/cldr.

It seems to us that currently, ISO activities around locale data do not satisfy the needs of the standardization community and in fact conflict with a widely adopted industry standard. We encourage the INCITS Executive Board to bring this issue to the attention of JTC1.