Internal:Public Policy/Federal government Open Source Policy

In early March 2016 OMB announced a new Open Source Policy applying to federal agencies. Public comment is invited till April 11. Wikimedia DC should comment before then. Here are notes to prepare.

What we're commenting on

• The invitation for public comment -- they're inviting the format of github issues which we might or might not find convenient
• Source Code Policy draft -- 15 page PDF. I think this is the main thing we are supposed to comment on. Lines are numbered inviting precise commentary.
• Tangentially, the draft policy fills in a promise in the 2nd "Open Government National Action Plan" which slots it into a venue for other national governments to copy it or count it as admirable progress toward open government. We do not need to follow up on this angle for this comment period, but Peter may add links or notes.

Some thoughts for the comment (by Peter, so far)

• on page 1, line 23: "challenges" doesn't quite describe what's to be addressed ; perhaps "opportunities for improvement" is better
• page 1, footnote 7: "vendor lock-in" is a bit narrowly defined here; we might note also that it can create mismatches in hiring ; they might cite Varian & Shapiro's Information Rules here
• Peter to invite comment from Open Source Practices team at work and possibly also Public Policy listserv from the foundation.
• the policy refers to source code procured by the govt meaning custom-developed ; and to source code developed by the govt
• line 174: agencies procuring software source code must make it available to other agencies. interesting.
• footnotes 8 and 24 are too much the same
• record definition of OSEHRA, line 208
• three year pilot program pushing the agencies hard toward OSS:

• line 229: each agency shall release 20% of newly-developed source code -- and some agencies develop a lot
• lines 240-242: "all new custom code developed by covered agency employees as part of their official duties shall be released to the public—subject to certain exceptions—as enumerated in Section 6" -- but wait, what about one-time research? you mean all CPI code too?

• line 414-5: "Excepted software must still be listed in the agency’s enterprise code inventory" -- this suggests that a public database will have this inventory, but I didn't catch that elsewhere in the document
• line 415-6: "certain redactions allowed. Please refer to Project Open Source for additional guidance on this topic." -- when we find the relevant sections at Project Open Source, list them above as source materials for possible comment
• lines 465-466: the binding definition of “Open Source” is coming from the Open Source Initiative (https://opensource.org/osd).