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Responses to Consultations
31 October 2012 - APPSI Response to the PAF Advisory Board Consultation
Please find below APPSI's response to the Postal Address File Advisory Board Consultation, which closed on 31 October 2012.
APPSI Response to PAF Advisory Board Consultation (PDF, 0.05Mb)
27 October 2011 - APPSI responses to the Cabinet Office Open Data and Public Data Corporation consultations
APPSI has responded to the Cabinet Office Open Data and Public Data Corporation consultations. Please see:
APPSI covering letter to consultation responses (PDF, 0.07Mb)
APPSI response to the Open Data consultation (PDF, 0.22Mb)
APPSI response to the PDC consultation (PDF, 0.24Mb)
23 November 2010 - APPSI's Response to the European Commission's PSI Directive Consultation
APPSI has responded to the European Commission's online PSI Directive Consultation. Read:
APPSI response to PSI Directive consultation (PDF, 0.11Mb)
1 April 2010 - Government's response to Policy options for geographic information from Ordnance Survey - Consultation
Government has considered the many responses to its consultation. Responses were received from a varied range of stakeholders including businesses, trade bodies, industry experts, public sector bodies and individuals involved with, or with an interest in, the UK geographic information market. A wide range of views were expressed in response to the consultation, although a clear majority (68%) of respondents agreed that at least some Ordnance Survey data should be made available for free. The consultation set out three possible options for the future of Ordnance Survey. There was no clear consensus on which policy option of those set out is the favoured one. In light of consultation responses government has decided to pursue a modified approach. This is outlined below.
Release of data for free
In response to this support, government will release a range of Ordnance Survey data and products for free on 1 April 2010, known as OS OpenData™. The datasets to be released are those set out in the original consultation document as the Free package, with the following changes:
- replacement of 1:25 000 and 1:50 000 Scale Colour Raster products with OS VectorMap District
- addition of OS Locator™ and Land-Form PANORAMA to the product list
- replacement of Code-Point by Code-Point Open, which provides accurate locations for 1.7 million postcodes in England, Scotland and Wales
Full details of the products to be released are set out in the main body of this consultation response.
The modifications to the data to be released have been made in order to:
- meet the most important needs identified by consultation respondents
- maximise the ability to make best use of other public data released under the Making Public Data Public initiative
- reduce the impact on existing market participants, in light of consultation Feedback
- ensure that core reference information is freely available while protecting the ability of all market participants, including the Ordnance Survey, to add value
- ensure that Ordnance Survey continues to provide high-quality products and services to those customers, including government, who need them
- ensure the sustainability of Ordnance Survey paper maps
- meet affordability criteria; and
- ensure a sustainable business model for Ordnance Survey.
Public Sector Mapping Agreement
A significant number of consultation responses reinforced Ordnance Survey's role as the national mapping agency and provider of the definitive 'MasterMap' of Great Britain, referencing the organisation's unique history and high-quality data. Respondents also commented on the restrictions or complications involved in sharing data between different parts of the public sector, including between organisations involved in the different types of collective procurements. Government's intention is therefore to move to a commercial relationship with Ordnance Survey to provide products and services to government, and, subject to discussions, the entire public sector, under a centrally funded Public Sector Mapping Agreement. Provision of a Public Sector Mapping Agreement would allow government to make geographic information provided by Ordnance Survey, including high specification OS MasterMap products, free at the point of use for public sector bodies, and subject to no limits on re-use when used internally within the public sector for public sector activities. This would cover all the definitive national datasets that the public sector needs in order to provide vital and valuable services to the public. Subject to discussions, this change will come into effect on 1 April 2011.
Ordnance Survey Licensing
Ordnance Survey will also be proposing changes to the derived data policy for the commercial sector, including 'Free To Use' data, as part of its work on revised pricing and licensing. Ordnance Survey, The National Archives and the Cabinet Office will also work together to ensure that derived data issues do not unnecessarily impede the release of public datasets by other public bodies, balancing the significance of the data taken, the impact of release of any dataset on Ordnance Survey's commercial business and that of its partners, and any legal or regulatory consequences for Ordnance Survey. This reflects concerns expressed in the consultation responses about licensing of Ordnance Survey products, and in particular derived data.
Government has also asked Ordnance Survey to take on the technical delivery role of the services that are required to meet Britain's obligations under INSPIRE, which is an EU Framework Directive seeking to introduce greater harmonisation, interoperability and wider access to public sector electronic spatial information across Europe.
Government response to Ordnance Survey consultation (PDF, 0.40Mb)
22 March 2010 - Michael Wills' views on APPSI's response to the Department for Communities and Local Government consultation on Policy options for geographic information from Ordnance Survey
In his letter to Professor David Rhind, Chair of APPSI, Michael Wills, Minister of State for Justice says:
'I read APPSI's expert and detailed analysis of the points raised in the consultation with interest. APPSI's
response offers an informative consideration of a number of key issues...'
Michael Wills letter to Chair of APPSI (PDF, 0.03Mb)
9 March 2010 - APPSI's response to the CLG consultation on Policy options for geographic information from Ordnance Survey
APPSI has today submitted its response to the DCLG consultation on Policy options for geographic information from Ordnance Survey.
APPSI response to CLG consultation (PDF, 0.28Mb)
29 May 2009 - APPSI's response to Ordnance Survey's new Business Strategy
APPSI's overall response to Ordnance Survey's new business strategy is two-fold:
- to welcome and acknowledge the principles underpinning Ordnance Survey's new Business Strategy and their importance in facilitating resolution of one of the longest running and most distracting issues in the public sector information world
- to highlight many of the issues which need to be resolved before any Strategy can be realised and make some constructive comments on these.
For details on the key issues emerging from Ordnance Survey's new Business Strategy, read:
APPSI response to Ordnance Survey Business Strategy (PDF, 0.21Mb)
26 May 2009 - APPSI's response to the consultation on the transposition of the INSPIRE Directive [2007/2/EC]
APPSI's overall comments on this consultation are:
- The Impact Assessment (IA) looked generally well-prepared, covering many of the impacts that needed to be measured. The benefits assessment has been undertaken in a conservative manner minimising the risk of optimism. However, it is important that steps are taken to ensure that the benefits are actually realised.
- We are concerned that Statutory Instruments (SIs), and the IA, may not have recognised that the geographic area relevant to the Directive is wider than the UK - the Directive includes all areas where the UK has or exercises jurisdictional rights. Hence, for example, it appears to include surrounding sea areas and the atmosphere above them. The position of other areas, such as the Falklands (and surrounding areas), Gibraltar and the Channel Islands is not clear.
- For clarity, the SIs should note that INSPIRE includes data held on behalf of Public Authorities - thus data collected by the private sector may well be included if it is part of a statutory requirement.
- As a clarification, the Consultation Document should have made clear, in Annex 5 (on Related UK legislation) that the EIR does not require all information to be made available electronically and hence INSPIRE will not apply to such information.
- The underpinning idea of providing better access to information is strongly supported by APPSI; however this approach can easily become over-bureaucratic and expensive so safeguards to avoid this are essential.
Read in full:
APPSI response to INSPIRE consultation (PDF, 0.09Mb)
7 May 2009 - EC publishes the Review of the PSI Directive 2003/98/EC
The aim of the PSI Directive was to introduce basic conditions to facilitate the re-use of PSI throughout the EU.
The review of the PSI Directive concluded that since its launch in 2003:
- progress has been made but big barriers still exist
- commercial re-use of PSI has been allowed
- monopolies have been broken
- fair trading conditions have been introduced
- prices have been decreased
- there is more transparency
The main barriers identified by the review include:
- attempts made by public sector bodies to maximise cost recovery
- competition between public and private sectors
- practical issues hindering re-use, such as the lack of information on available PSI
- the mindset of public sector bodies failing to realise the economic potential of PSI re-use
The review recommends that Member States should:
- focus their efforts on full and correct implementation and application of the Directive
- terminate exclusive arrangements
- apply licensing and charging models that facilitate the availability and re-use of PSI
- ensure equal conditions for public sector bodies re-using their own documents and other re-users
- promote quick and inexpensive conflict and resolution mechanisms
The review says that the Commission will:
- closely monitor implementation and application of the Directive
- scrutinise exclusive arrangements (2009-10) in particular
- analyse the economic case for marginal cost
- encourage the exchange of good practices (proactive re-use policies, public tasks, conflict resolution)
- further review by 2012, accompanied where appropriate by a proposal for amendments to the Directive.
Review of PSI Directive (PDF, 0.05Mb)
EC staff working document (PDF, 0.17Mb)
26 March 2009 - APPSI's letter to Royal Mail re: Postal Address File Licence Consultation
APPSI wrote to the Head of Commercial Licensing at Royal Mail in response to the recent consultation on new licenses for the Postcode Address File (PAF). In response to this consultation, several organisations have highlighted possible consequences not only for the use of addresses, but also postcodes. Our letter sets out some of these concerns which we consider as major barriers to the re-use of PAF.
We are now awaiting reassurance that Royal Mail's new licensing model will not interfere with long-established use of a dataset which has become part of the national data infrastructure.
Read our letter in response to the Postal Address File Consultation:
PAF consultation letter (PDF, 0.08Mb)
16 February 2009 - APPSI's response to the draft Power of Information Task Force Report
On 1 February 2009, the Power of Information Task Force published an online draft report, inviting comments on the Task Force's recommendations to Government on
- how modern media can facilitate and embed the re-use principles of public sector information and improve public services
- how data can be presented in re-usable formats
- on the need for simplification of license models
- the need to improve access to government information.
APPSI's response is a majority report but is not agreed by all members. The Trading Fund representative on the Panel is not able to agree with or support this submission.
The response addresses:
- Overview: the need to develop the knowledge economy and the re-use of public sector information through a more simplified licensing regime
- Recommendation 9
- Recommendation 10
- Recommendation 11
- Recommendation 12
- Recommendation 18
2 December 2008 - EC report: Assessment of the Re-use of Public Sector Information (PSI) in the Geographical Information, Meteorological Information and Legal Information Sectors
This report is the outcome of a study undertaken by MICUS Consulting GmbH during 2008 on the behalf of the European Commission.
The report states that:
- the PSI Directive has had its strongest impact in the sector of geographical information (GI)
- 66% of GI re-users' income has increased and the market is enriched by new re-user groups which offer innovative application for GI
- 79% of private re-users would like to access more public GI, but some do not take it up, primarily because of unfavourable pricing and licensing conditions
- 79% of holders of legal and administrative information provide their information free of charge on the internet
- since 2002 the market for legal and administrative information has grown by 40%
- in the sector of meteorological information the Directive has had little impact, even though the National Meteorological Services (NMSs) have introduced numerous changes in their data policy, only 5 of 25 NMSs have reported that they changed their data policies based on a change in their national legislation
- the market for private weather services is growing, with 74% respondents recording a data volume download
- re-users in all three sectors - geographical Information, legal and administrative information, and meteorological information, still complain about restrictive licensing and high prices.
1 December 2008 - EC summary report on the results of the EC Review of the PSI Directive
The European Commission has published a summary report on the results of the Review of the EC PSI Directive. The Review received 37 responses in total from a range of stakeholders including PSI content holders re-users, non-profit organisations, commercial associations, and private individuals. Many of these responses have also been published along with the report. This report does not indicate how the Commission intends to address the issues raised by the consultation as the Commission's Communication on the Review of the Directive is still currently under preparation. A general overview of the replies are as follows:
- Respondents have signalled that the Directive has had a positive impact on promoting PSI re-use in their respective countries by providing and establishing a legislative framework in a previously unregulated market.
- A majority of respondents say that significant barriers remain that would need to be addressed to fully exploit the PSI re-use potential in the EU.
- A majority of re-users suggest legislative amendments to the Directive to make it 'sharper' and 'tighter'.
- A majority of respondents believe that the implementation of the Directive has had very little impact on the pricing of PSI, although some exceptions have been signalled.
- The problems that have been frequently signalled are:
- lack of awareness of the potential of PSI re-use and of the Directive amongst public sector bodies, especially at regional and local level - little effort from public sector bodies for facilitating and promoting re-use
- lack of knowledge or mechanisms to identify what information is available for re-use
- the non-mandatory requirements for PSI re-use
- strict licensing conditions imposed by public sector content holders
- the limits of the public task when public bodies commercially compete with private firms
- unfair competition practices by public sector bodies
- very limited transparency on public sector bodies' re-use policies and notably on the way charges are calculated
- the absence of efficient means of redress.
- Diverging views exist between public sector bodies (the supply side) and re-users (the demand side) on the PSI current re-use environment.
- The public sector bodies that represent the supply side believe that the Directive is working well.
- Re-users consider that the implementation of the Directive has been much too slow.
- Some respondents state that the Directive has been neither properly implemented nor applied in Member States.
- A significant number of stakeholders have expressed their support for extending the scope of the Directive to cultural, research, and broadcasting institutions.
- Respondents suggested the implementation of national asset lists / repositories and the obligation for Member States to report annually to the Commission on their actions towards promoting PSI.
- It was strongly recommended that guidance should be issued on specific terms of the Directive, e.g. the definitions of 'public tasks', 'documents', 'marginal cost pricing', and 'reasonable return on investment.'
31 July 2008 - APPSI's response to the review of the Directive 2003/98/EC on the re-use of public sector information
The EC Directive on the re-use of public sector information was adopted on 17 November 2003. It regulates the behaviour of public sector bodies when they act in the market by trading information (e.g. geographical, statistical or meteorological data) or making it available for re-use.
In the UK, the implementation of the Directive resulted in legislation for the re-use of PSI: The Re-use of Public Sector Information Regulations 2005.
The purpose of the EC consultation on the EC Directive (2008) is to gather information from Member States on their views on different aspects related to the implementation, impact and scope of the Directive. The results of this consultation will feed into the debate regarding the review of the Directive. The consultation closes in September 2008.
To inform the review of the Directive, APPSI has answered the EC's consultation questions by drawing on its report to the EC.
APPSI Submission to the European Commission (DOC, 0.24Mb)
The majority view within APPSI is that:
- with certain explicit exceptions, Public Sector Bodies (PSBs) should be required to make PSI available for re-use
- Public Sector information (PSI) originally created as part of the public task of a PSB or integral to the discharge of a public function should be within the scope of the Directive
- high level EC policy guidance should be provided on interpretation of the concept of 'public task' and the UK government should create and operate a public process for its definition and periodic review; the process should include provision for public consultation and challenge
- the scope of the exclusion of documents in which third parties own intellectual property rights should be clarified, so as to bring within the scope of the Directive documents (i.) where the third party is another EU public sector body; (ii) documents containing re-usable content that is not protected by the third party rights; and (iii) documents where the third party has licensed the document for re-use
- EC guidance be provided to give much greater encouragement in the Directive for adoption of a marginal cost regime (for most documents), and clarification provided as to whether, and the extent to which, the costs that can be re-charged to re-users should relate to the documents in question or to documents in general; and also that guidance be provided on the principles that should apply to the calculation of costs, following best practice in Member States. The bulk of the APPSI members urge the UK government to move to a marginal cost pricing model for PSI
- wherever exclusive arrangements remain, a justification should be published, and that all information about exclusive arrangements should appear in one place
- the UK government should launch an awareness-raising campaign on the merits of PSI re-use.
29 July 2008 - OPSI publishes the United Kingdom's Response to the EC's Review of the PSI Directive
The UK's response to the EC's Directive review was informed by the UK's report on the Re-use of PSI 2008.
The UK Government has also published its official response to the EC's questionnaire on the Review of the EC Directive.
UK official response to the EC's questionnaire on the Review of the PSI Directive.
Earlier Responses to Consultations
Previous Responses to Consultations can be found on the UK Government Web Archive.
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