OSC responds to UK COI

OSC response to UK COI

COI logo

The OSC has responded to the Public consultation on browser standards for public sector websites issued by the UK COI (Central Office of Information).

“We consider the suggested approach based on supporting specific browsers and / or operating systems to be misguided … [rather] the COI should actively promote the exclusive use of W3C standards on public sector websites.”

Full Text

Main Response

The OSC has reponded to the “Public consultation on browser standards for public sector websites” [link (new page)] issued by the UK COI (Central Office of Information).

We consider the suggested approach will encourage:

  • increasing the balkanisation of the internet
  • Tincreasing the cost of maintenance of public sector websites
  • eliminating new entrant technologies, so increasing barriers to entry
  • reducing actual or potential competition.

We consider this to be of importance in relation to issues associated with market distorting activities or State aid.

Rather we consider that the COI should actively promote the exclusive use of W3C standards on public sector websites. Apart from creating a consistent and plannable workload for departments, by enabling a ‘write once’ approach, it also avoids any potentially market-distorting behaviour.

Supporting Information

The OSC’s Chairman, Gerry Gavigan, also provided the following supporting information.


We consider that any discussion of browser standards must be set in the context of related EU guidelines, in this case the publication of the draft European Interoperability Framework V2 ‘EIF V2’ [link (new page)] and relevant case law [link (new page)].

In general terms we consider that the COI draft guides need to ensure consistency with the entire EIF V2.

Specifically we consider the guidelines should reflect the sentiment expressed concerning interoperability. Interoperability is about creating a level playing field; competitive neutrality, if you prefer.

Page 11 EIF V2 rightly states the benefits of a level playing field:

  • Avoidance of vendor lock-in results in lower costs, to administrations to develop services, plus more freedom of choice is available to citizens and businesses as a result;
  • Increasing the number of suppliers of standards-based products should lead to increased competition;
  • Increased competition deriving from the lowering or elimination of barriers (resulting from the migration towards open standards).

True interoperability is only obtained when using truly open standards, and we rely on the definition for open standards provided elsewhere by the EU [link (new page)].

The Government has already acknowledged the importance of standards in a study published in October 2000 [link (new page)].

While that BERR study is not a long document there are certain key phrases that tell us most of what we need to know for the purposes of the current exercise:

“Standardisation is a key factor in support of […] competitiveness, innovation, reduction of trade barriers, fair trading, protection of consumer interests, environmental protection and public procurement.”  (paragraph 1)

“Market forces are necessary for the development of efficient standards.  But standards have some of the characteristics of ‘public goods’ and market forces alone will not enable the benefits of standardisation to be realised.” (para 3)

“The UK is expected to maintain a standards infrastructure consistent with European standards policy […] Certain obligations are now enshrined in EC law, e.g., Directive 98/343.” (para 4)

“One class of standards which is growing in importance is concerned with interoperability.  Such standards have long been vital in the defence sector […] interoperability an essential feature of  […] communications and information industries.” (para 7)

“If it believes it is in a position to do so, a company may seek to impose its own private “standards” on the market [leading ultimately to] a need for intervention by the competition authorities or courts to prevent abuse of a dominant position (The concern of the US anti-trust authorities with the activities of Microsoft might be thought of in this light).” (para 19)

(quotes from BERR report end)

More recently in September 2007 the European Court of First Instance (CFI) in its decision on interoperability, upheld the Commissions original concerns.

“The issue of standards is seen as important because if all Web browsers do not use the same standards, Web site developers are likely to design their Web sites to work with the most widely-used browser, which is Internet Explorer. That gives people a disincentive to use other browsers.” quoted at [link (new page)].


We consider the analysis at Appendix  A of the draft COI guidelines to be at best insufficiently worked through, though possibly merely irrelevant.

Unless the COI site is deployed in a manner that enables the use of any browser then over time site statistics will reflect the bias created by the distorting effects of COI technology preference.  We are inclined to quote Tim Berners-Lee:

Anyone who slaps a ‘this page is best viewed with Browser X’ label on a Web page appears to be yearning for the bad old days, before the Web, when you had very little chance of reading a document written on another computer, another word processor, or another network.

Source: Technology Review, July 1996

And if the COI site is genuinely technology neutral then there is no more to be done as it would be viewable with any browser.


We note the exclusion of issues such as graceful degradation as being out of scope but suggest that a requirement to enable graceful degradation immediately limits potential excesses arising from unnecessary over elaboration of web sites that by their very nature should be driven by function (access to public services and/or public information) rather than form or attraction to particular (usually proprietary, non-standard) technologies.

We would draw your attention to the published views of Gerry McGovern. He is a leading authority on creating effective content and a keynote speaker at a recent Socitm conference [link (new page)].

He helpfully reminds us that customers of government websites are only interested in obtaining a service, downloading a form or providing information.  All of this would be easily deliverable merely by using W3C standards rather than by attending to the quirks of any particular technology.

Moreover, as demonstrated by [link (new page)] avoiding ‘vanity publishing’ based on (usually proprietary) animation programmes does not leave banal unattractive sites as the only option.