Subject: Letter ballot on JTC 1 SC 35 N 1616, New work item for a TR titled Specification method for cultural conventions.
From: Eric Muller, L2 chair
Date: February 17, 2011

Dear INCITS/L2 members:

This accelerated letter ballot covers JTC 1 SC 35 N 1616 (= L2/11-013), New work item for a TR titled Specification method for cultural conventions. The 24 hours ballot closes on Friday February 18, at noon PT. Please send your answer to both Lisa and myself.

This letter ballot proposes to disapprove the new work item proposed in JTC 1 SC 35 N 1616, answering the questions as follow:

1. Do you accept the proposal in the attached NWI Proposal document as a sufficient definition of the new work item? YES.

2. Do you support the addition of the new work item to the programme of work of the joint technical committee? NO.

First, the WD document accompanying the NP ballot is a minor revision of a nearly decade-old document that was the object of an unsuccessful project to create a TR of the same title in the context of JTC 1/SC 22. (See http://std.dkuug.dk/JTC1/SC22/WG20/docs/projects#14652.) No consensus could be reached at that time due to extensive technical concerns with the draft as well as concerns other larger concerns questioning the value of the TR. As observed in ballot comments at that time, "Germany sees little use in this DTR. It has only very limited support in the industry (not even in the Linux community..." (See "Summary of Voting on JTC 1 N 6721", ISO/IEC JTC 1/SC 22/N3405.)

The same technical and general concerns exist today. The document is inextricably tied to POSIX conventions that were already dated in 2001 and have little interest in 2011. Moreover, in the meantime different technical solutions have emerged that have generated a strong following and are defining best practices in a way that render the present document irrelevant and obsolete.

Beyond the specifics of the WD document that accompanied the NB ballot, the US has more general concerns with this project proposal. On the one hand, there is merit to the idea of specifying methods to describe various culturally-dependent conventions for one or many cultures and, in particular, of doing so in ways that facilitate easy development of user interfaces or other types of applications so as to be culturally-relevant for users of many different cultures. That is an objective that the US strongly supports. However, we strongly object to this NP because it completely overlooks the fact that this objective is already being achieved in the context of existing and vigorous standardization activities outside of ISO/IEC JTC 1/SC 35. This project would directly compete with the Common Locale Data Repository (CLDR) project of the Unicode Consortium. This project in SC 35 would needlessly duplicate efforts, and it is doubtful that it would be possible to match the depth of participation and collaboration of the CLDR effort.

The CLDR project has been underway since 2002. It is widely adopted across the software industry; it has support from standards associations in several countries and is building on the ongoing contributions of hundreds of contributors. The project has compiled and provides data specifying a wide range of cultural data categories of use in user interfaces and applications with coverage spanning 187 languages and 166 territories. In addition to the data repository, the CLDR project has developed a standard that specifies a data format for interchanging cultural-convention data, "Unicode Technical Standard #35, Unicode Locale Data Markup Language" (LDML). Moreover, the proposed project covers only a small fraction of the depth and scope of types of data covered by LDML.

The justification for the NP states,

"The purpose of the proposed specification is to make it possible for a program to adapt itself to the cultural and linguistic environment that it is being used in. It would thus be possible to write programs, that can via these specifications be given a number of cultural and linguistic user interfaces, without changing the program itself."

The reality is that this purpose, thanks to the success of the CLDR project, has already been largely achieved, and that the CLDR approach is widely considered to represent best practice in this area. Nearly a decade of experience with CLDR has shown that this is an area that is eminently suited to its chosen approach, which is a broad-based, open source collaboration of cultural and industry experts from all areas of the globe. Because of this, it is unlikely that a competing specification developed by JTC 1/SC 35 could add significant value and it is equally unlikely that there would be any significant adoption of such a specification by industry. Instead, if such a project were to be approved, the attempt could lead to a fragmentation of effort and waste of resources.

In summary, the WD submitted is not an appropriate basis to develop best-practice recommendations today, and the very project would stand

in direct competition to existing standards efforts elsewhere that are widely endorsed. Therefore, this proposal should not be approved as an SC 35 project.

3. Do you commit yourself to participate in the development of this new work item? NO

4. Are you able to offer a project editor who will dedicate his/her efforts to the advancement and maintenance of this project? NO

5. Do you have a major contribution or a reference document ready for submittal? NO

6. Will you have such a contribution in ninety days? NO

7. Which standard development track is proposed? Not applicable.


A yes vote on this letter ballot means disapproval of the new work item.

___ yes
___ no; reason ___
___ abstain; reason ___


Eric Muller,
INCITS/L2 Chair.