Yesterday, SIIA submitted comments to the Office of Management and Budget (OMB) in response for its request for feedback on its draft Federal Source Code Policy – Achieving Efficiency, Transparency, and Innovation through Reusable and Open Source Software.

SIIA recognizes and supports the goal of the Administration to promote the reuse of certain custom-developed Federal source code broadly across the Federal Government.  Overall, SIIA is supportive of the objectives of the draft policy for several reasons. 

First, we strongly support that the draft policy reiterates the long-standing Federal policy to rely on COTS as a first priority, and to refrain from seeking the development of custom software unless Government needs cannot be met with COTS.  Additionally, we are pleased that the drafters refrained from proposing an “open source by default” approach, which would not be an effective option for many vendors who would refrain from doing business with the Federal Government to avoid the requirement.  And finally, we support the proposal to evaluate the policy through a temporary pilot project, providing for the opportunity to effectively evaluate the impact of the policy before making it permanent. 

However, in our comments we also posed the following recommendations to ensure that the pilot program is implemented effectively:  

1.      SIIA supports reinforcement of the current COTS-first approach to Federal software procurement, but the requirement should be strengthened and clarified.

2.      The draft policy could present serious market impediments to provision of SaaS and other cloud computing solutions and partially customized solutions or “ad-ons.” 

3.      Continued Federal emphasis on open standards is critical, but lacking in this policy.

4.      The scope and application of the draft policy is best suited for a pilot project application, but arbitrary percentage goals should be approached with caution.

5.      Implementation should rely on existing open source licenses.

6.      Clarification is needed regarding funding by third parties.

Click here to view SIIA’s full comments.

David LeDuc is Senior Director, Public Policy at SIIA. He focuses on e-commerce, privacy, cyber security, cloud computing, open standards, e-government and information policy. Follow the SIIA public policy team on Twitter at @SIIAPolicy.