ESRI has sent an open letter to government – with a number of co-signatories who are in effect competitors – fretting about the proposal (commitment really) to make a number of OS datasets free.

Below is the letter, which I’ve blockquoted to make it clear what’s the letter and what’s not. I’ve inserted some comments, based on my personal knowledge; and of course some of this is coloured by my advocacy of the Free Our Data campaign.

Dear Sir,

Following the Prime Minister’s announcement on November 17th 2009 which set out his vision for Making Public Data Public, a consultation has been taking place on three options for making certain Ordnance Survey datasets available for free with no restrictions on re-use. Submissions to the consultation must be received by March 17th.

We the undersigned, represent companies who employ 630 staff in the UK GIS industry. We represent over 50% of this market and as such are effectively competitors. Whilst each of our companies has submitted an individual response to the consultation, we are writing this letter to express our shared, serious concerns about both the manner in which this consultation is being undertaken and the potential negative impacts that could result, not for our companies, but for the Ordnance Survey and for the UK economy.

Before saying anything else, we wish to record our full support for the role of the Ordnance Survey as a world leader in the collection, maintenance and distribution of the highest quality geographic information and mapping.

CA: That’s in common with the Free Our Data campaign, which has always praised the OS’s work in collecting data and said that it should remain in government ownership.

The Government press release entitled “Re-mapping the future for Ordnance Survey – making public data public” stated that “…any change would be implemented from April 2010.” We insist that following the close of the consultation on 17th March, adequate time be allowed for a full analysis of the submissions, prior to any decision being taken. We are very concerned that the decision to release a selection of mid- and small- scale products for free appears to have already been made by the Prime Minister’s office.

CA: Actually, it was made before the consultation – he announced it back in November. The consultation was in effect asking if more should be done, or if there might be some overwhelming reason why the old OS model should be retained, with all the fun of derived data restrictions and so on that have given us so much enjoyment over the years.

The consultation document states that were this decision to be taken, it would “drive improved transparency and accountability of government and, by facilitating greater innovation, create new economic and social value”. Whilst this may drive transparency and create social value, we do not consider that any significant economic value would result.

CA: This is an interesting assertion, but it’s not backed up by any evidence. It was trivial for us to show that it costs more to restrict the use of the CodePoint database by JobCentreProPlus than it actually benefits the economy (because the fees paid to lawyers are greater than the cost of the database licence, and of the benefits that would be paid to someone who can’t find a job). As for mid-scale data, it’s similarly easy to show that people who are put off by (a) licence prices and (b) derived data rules will embrace the economic possibilities of free data.

Another question might be: what’s the specific difference between social value and economic value?

We work on a daily basis with a very wide range of public and private sector customers who need large scale Ordnance Survey data in order to improve the effectiveness and efficiency of their organisations. Currently the cost of this data puts it beyond the reach of many organisations, particularly in the private sector. If we are to create real economic value for the UK, it is the availability of large scale datasets, at reasonable prices, that needs to be addressed, rather than releasing mid- and small- scale datasets for free.

CA: the consultation does point out that the public sector has been getting its data cheap, and the private sector in effect overcharged. That’s likely to be realigned – but equally, some public sector organisations may opt out of some OS products.

The consultation document says very little about the revenue impact on the Ordnance Survey of releasing datasets for free. The Ordnance Survey is a Trading Fund which is completely self-funded from the revenues it receives from licensing its datasets. If any of these datasets were to be made freely available, this lost revenue would need to be replaced. We would be extremely concerned if this were achieved by increasing the charges for large scale datasets to either the public or private sector or both.

CA: basically, the concern is that prices of the large-scale [MasterMap level] data will be increased to pay for the free stuff.

We cannot see how any decision to release Ordnance Survey datasets for free can be made without putting the necessary changes in place to compensate the Ordnance Survey for this lost revenue. In the present economic climate we cannot see the Government or Ordnance Survey public sector customers making up this short-fall and our experience tells us that the private sector will not pay more. Furthermore it is already evident that as a result of this proposed change, Ordnance Survey is feeling considerable pressure to generate additional revenue streams, through the rapid introduction of additional innovative and/or automated product lines. These pressures may encourage Ordnance Survey to risk its long term strategies of high quality geospatical data production for the sake of short term revenue gains.

CA: well, this may be one of those extremely rare times where being a journalist, with the access it sometimes provides to decision-makers, is more useful than being in business. From speaking to ministers and the people who are working on making the data free, I’m confident that the Treasury has accepted the idea that it needs to fund the shortfall. (But there’s also an interesting question to be posed to ESRI: if OS data is so price-inelastic – that is, people will pay anything for them – and the GIS data so useful, then why can’t ESRI and the others contemplate a rise in OS pricing? After all, they’d all be using the same datasets, have the same prices, and so be able to pass them on to customers equally, because the usefulness of the datasets would have the same price inelasticity. I suspect ESRI’s sources on this are within Ordnance Survey. Mine are within Whitehall. Whitehall is where the money lives.

If the Government is serious about making Government geospatial data more readily available, it also needs to look beyond the Ordnance Survey. Current restrictions on the availability of postal address file data from The Royal Mail and Communities and Local Government identifiers for properties and streets need to be removed. Making all such data more readily available would lead to greater innovation and play an important role in placing the UK at the forefront of the knowledge economy in the twenty-first century.

CA: that sounds like a complaint about derived data, but it’s not quite clear what “restrictions… need to be removed” actually means.

We appear to be moving towards a decision to release a selection of mid- and small- scale Ordnance Survey products for free, without due regard being given to the future funding of the Ordnance Survey or whether this will drive real economic growth for the UK. This gives us serious cause for concern.

Dr Richard Waite, managing director, ESRI (UK) Ltd; Howard Papworth, executive director SG&I Western Europe, Intergraph; Dr Michael Sanderson, executive chairman, 1Spatial Group Ltd; Mike O’Neill, managing director, Cadcorp Ltd.

CA: what’s interesting about this is the lack of numbers. I’d have thought there was enough detail in the consultation that these companies could have set out their worries in financial terms – especially with a budget coming. I find the lack of hard numbers intriguing.

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