Open Data consultations – Answers to the Data Policy Consultation
October 25th, 2011
I am currently responding to 2 Government public consultations, the Data Policy Consultation on the form and role of the Public Data Corporation and the Making Open Data Real consultation on the “culture of openness and transparency in our public services”. In this post I copy my answers to Chapter 4 of the consultation document, on charging for information, this was the section I felt most able to answer. I omit my answers to the other questions as I either skipped them or only gave cursory answers. The answers below are not particularly well considered either, but it felt better to contribute than to sit back and hope for the best.
I am not entirely convinced by the data utility argument which I support in my answer to question 1, however, there is nothing that gets my ire up more than when people limit the spectrum of acceptable opinion with hand wavy arguments (Section 4.17). Not to mention the hypocrisy of doing so whilst at the same time suffixing each question with “Please provide evidence to support your answer where possible.”
Charging for Public Data Corporation information
1. How do you think Government should best balance its objectives around increasing access to data and providing more freely available data for re-use year on year within the constraints of affordability? Please provide evidence to support your answer where possible.
The Government and its organisations should provide services for society, the assumption that the “constituent parts” targeted for absorption into the PDC should act as businesses, requiring “sustainable business model[s]” is a subversion of their place and role in society. To go further down that route rather than retreat from it is a mistake.
The remit of the constituent parts should be restricted to providing the services necessary for the country to operate effectively, and such services should be funded from the budgets of the organs of Government that use them (ultimately the tax payer). Those service should then be provided at marginal cost to any non-Governmental users. Although there is an obvious advantage to the tax payer in having the services subsidised by non-Governmental users such a funding device is regressive, in that it restricts the services to those who can afford the charges. Outstanding issues of affordability should be reconsidered in terms of the net benefit to Society of those services being made available.
The consultation describes this position as the “‘data utility’ pricing model” (S. 4.17) and without evidence or discussion deems it “currently unaffordable” and therefore not for discussion. Further it spuriously argues that a “lack of investment” would result in degraded quality and accessibility of the data, despite said level investment being entirely at the Government’s discretion, and the remit for the production of value-added services also being at its discretion. By discounting a model which they acknowledge without more detailed consideration the authors make their bias clear.
2. Are there particular datasets or information that you believe would create particular economic or social benefits if they were available free for use and re-use? Who would these benefit and how? Please provide evidence to support your answer where possible.
The 2008 “Models of Public Sector Information Provision via Trading Funds” report by Newbery, Bently and Pollock commissioned by the last Government found that changing two OS product categories to a marginal cost regime would result in a net benefit to Society of £168m, for a cost to Government of £30m. Because of the lack of category breakdowns provided to the authors of the report, it is not possible to analyse which of the specific products covered by those categories were produced for use by Government and which are primarily consumed by other users. This report seems like a perfect starting point for identifying such datasets.
3. What do you think the impacts of the three options would be for you and/or other groups outlined above? Please provide evidence to support your answer where possible.
- The status quo already includes some commitment to continue to open up more sources of data, so as there is no perceived change it is difficult to talk about impacts. If the commitments are honoured and carried out in the true spirit of opening up useful data to the public then it would have an impact, but it would seem likely to be less than the other 2 options.
- Cost is an absolute barrier to any use by me and most community organisations I have involvement with and therefore this option would continue to exclude me from data use. Section 4.24 seems to be an arbitrary addition to this option and as explained in my answer to question 4 would naturally lead to a less fair competition with existing providers and act as a barrier to innovation and start-ups.
- The feature limited freemium options seems to be already tacitly used by organisations such as the OS, who give away some low detail data sets such as StreetView but charge for more detailed ones, which has made it useful to a limited extent for community mapping but seems to have been carried out without a real consideration of what would be off value to society. Limiting within certain geographical bounds would seem like a good approach to providing useful data to community and local interest groups whilst persuading commercial users to pay for nationwide access. On a similar theme, a limit based on non-profit usage would provide for mine and many other community use cases whilst still satisfying the Governments need to ‘encourage’ private investment.
4. A further variation of any of the options could be to encourage PDC and its constituent parts to make better use of the flexibility to develop commercial data products and services outside of their public task. What do you think the impacts of this might be?
Unless all the public task data were released for free (re)use such a variation would see the PDC compete unfairly with private organisations, and would likely stifle innovation. If one assumes they would act like a conventional commercial entity when developing such products they would have the ability to erect barriers to entry by weakening or obfuscating the public task data. This variation would run counter to the “stimulat[ion of] the development of an information market”.
It is worrying that this particular ‘issue’ is being raised so prominently within the consultation.
5. Are there any alternative options that might balance Government’s objectives which are not covered here? Please provide details and evidence to support your response where possible.
One such alternative consideration is the impact free access will have if combined with efforts to encourage volunteer and commercial contribution to the services. A prime example is the role the OpenStreetMap project plays in providing up to date information about the condition and route of rights of way; something which is currently not maintained with any degree of consistency or appropriate quality by either local councils or the Ordnance Survey.