De FSFE heeft vrijdag een brief gestuurd aan alle e-government hoofden van alle lidstaten.Om dat de brief nog niet op de site van FSFE staat, wordt deze hieronder onverkort weergegeven. Voor achtergrond informatie verwijzen wij naar beide voorgaande nieuwsberichten over dit onderwerp. U vindt daar het EIF document, eerdere reacties enzovoorts.
Dear CIO and Head of eGovernment,
Since 2004, the European Interoperability Framework (EIF) has helped
guide Member States of the Euroean Union to build their eGovernment
services in a way that lets such services work with each other. In
this first version, the EIF was an important enabler for the delivery
of pan-European eGovernment services to citizens and enterprises.
This valuable instrument is now in danger. The draft for the second
version of the EIF, which has been distributed to Member States and
leaked to the press this week, is a cause for serious concern about
the future of interoperability in Europe.
Unlike the first version of the EIF, the present draft does not
provide leadership for the European public sector. Instead of taking
Europe forward, the text's passive stance on openness means that it
fails to meet the high standards set by the first version of the EIF.
FSFE's main concerns regarding the present draft are the lack of
transparency in the drafting process, and the failure to include Open
Standards as a crucial element of interoperability
Today is the final day for EU Member States to comment on the
draft. For the reasons described below, FSFE urges you to register
your opposition to this highly deficient document with the European
Commission. We also ask you to contact other Member States, urging
them to delay the adoption of the current text until a new
Commissioner has had a chance to refocus the discussion.
Lack of transparency
FSFE notes a clear lack of transparency and openness in the process
which led to the present draft for version 2 of the EIF. The European
Commission produced a consultation document  and held a public
consultation  from June to September 2008, gathering no fewer than
53 comments  from businesses, industry associations and citizens.
Yet the comments that were submitted are largely not reflected or even
addressed in the document. Comments referring to open standards, Free
Software (also known as "open source") and the concept of openness in
general were silently dropped. The definition of open standards which
were present in the consultation document have been largely removed.
These changes from the consultation document can only be explained by
pressure that has been exerted on the European Commission outside the
democratic and transparent processes to which European institutions
are bound. Member states should not reward or justify such practices
with their support.
Threat to interoperability
In its current form, the text is a threat to the interoperability of
European eGovernment services, and a recipe to maintain and even
increase vendor lock-in.
The draft abolishes the clear definition of Open Standards used in EIF
version 1, and replaces it with the notion of an "openness continuum"
which includes proprietary standards and software. This notion of such
an "openness continuum" abuses the term "openness" to support
proprietary positions. By the same token, Free Software as a major
instrument in the delivery of interoperability has been all but
removed from the text.
It appears that the drafters of the document are trying to adapt the
EC's strategy of moving towards Open Standards to their actual
regrettable practice of procuring proprietary software on a large
scale . This goes directly against statements such as the following
by Commissioner Neelie Kroes:
"The European Commission should not rely on one software vendor and
must not accept closed standards". 
"Homogeneity" of proprietary ICT systems is in no way a replacement
for open standards. Procurement, which forms the link between strategy
and effective adoption of interoperable ICT systems, is ignored in the
Core points which are sorely lacking in the present draft text are:
- the clear definition of open standards from EIF version 1, or a
stronger definition such as the one provided by FSFE .
- a clear distinction software which is based on open standards
and specifications, as well as Free Software, from proprietary
The current text is not a viable successor to version 1 of the
EIF. Instead of leading Europe forward into an interoperable future,
it will promote vendor lock-in, block interoperability of eGovernment
services, and damage the European software economy. If adopted, it
will be a testament to the power which is exerted outside democratic
and transparent processes, and will give rise to Euro-scepticism.
FSFE appeals to you to urge the European Commission to withdraw the
current draft, in order to avoid replacing the sound and and widely
accepted EIF version 1 with an extremely weak text prepared in an
intransparent process. At stake are both interoperability in the
public sector and the credibility of European institutions.
President, Free Software Foundation Europe