Inflated costs in valuing data.gc.ca

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Inflated costs in valuing data.gc.ca

Mark Weiler-2
Hi David,

You've worked hard to bring open government data and should be congratulated. But in his enthusiasm you've made some mistakes in your recent blog posting: http://eaves.ca/2012/03/08/calculating-the-value-of-canadas-open-data-portal-a-mini-case-study

First you wrote: "one fairly tangible value of open data portals is that they cheaply resolve some access to information requests."

That claim is not supported by the post. I'm not sure why published datasets would reduce FOIs. There's even evidence to suggest that posting FOIed documents on-line does not reduce the total number of FOIs.  In BC, the provincial government has a policy of making documents responsive to FOI downloadable at www.openinfo.gov.bc.ca.  In the six months this policy has been implemented, the BC Government has seen the total number of FOIs increase by 28% compared to the same period last year.

You also estimate the value of www.data.gc.ca by comparing the costs of access via an opendata portal (which you assume to be $0) with the method of access defined by the Access to Information Act. The estimate you provide is based on how much it would have cost to access all the data through the ATI Act:

726 downloads of files from Canada for January x $1332.21/ATI = $967,184.46
Over a year, you estimate that to be upwards of $11,606,213

However, it's important to recognize that once information is ordered through the Access to Information Act, other people can subsequently have the department send them the responsive documents.  The catalogues of ATIs you can order are posted on-line. Here is Citizenship and Immigration Canada’s catalogue: http://www.cic.gc.ca/english/department/atip/completed.asp
I'm sure there's a way of reducing the transaction cost of subsequent orders even further (the Office of the Information Commissioner used to have an on-line form).

It's important to note that the estimates you provide appear to be based on approximately 10 data files on www.data.gc.ca that were downloaded multiple times.  For example, "Permanent Resident Applications Processed Abroad and Processing Times", was downloaded 481 times in January 2012.   You are assuming subsequent access of the same data files will cost as much as the initial access.  That’s wrong, as I explained above.

So the lowest estimate would be:

10 data files x $1332/ATI  in one month = $13,322 and not $967,184

And in a year, it would still be $13,322 and not $11,606,213

Currently, subsequent orders via the ATI system have a transaction cost. Those aren't nearly as much as initial costs. And as said, I’m sure there’s ways of reducing even further.

Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?


Mark
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Re: Inflated costs in valuing data.gc.ca

David Eaves
Mark,

Thank you for this response. I'm pretty upfront about the methodology being back of the envelop and I'm want to do some more thinking about this before I respond in full.

While the critiques of the methodology are welcome (and encouraged! - I definitely want us to find ways to measure value that are effective and accurate) I did want to quickly respond to the last line, which I found disconcerting.

"Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?"

There is nothing in my post that is intended to argue that open data is better or worse than FOI. I don't see them as competing and don't think I'm arguing that in my post. In the short run, I'm hopeful open data can be a way to take some of the burden off of the FOI system so that it can operate more efficiently (and, I think we can all agree it needs that). Or, more pessimistically, I hope it can at least ensure that the scarce resources of FOI systems are allocated to requests that couldn't be fulfilled by an open data portal. This was an implicit point in my post (which I should have made more explicit).

With that all said, I struggle to see where in my piece I argue about FOI and Open Data as if it is one of the other. If anything the piece is precisely about about how the two systems can support one another.

The question of convergence is an interesting one that I've talked about (but not sure I've written about). The key barrier to convergence in my mind however, is that the two initiative start from fundamentally different places.

Many Open data initiatives have the underlying goal of resetting the default setting in government to "open." One of the problematic impacts of FOI legislation is that it allowed governments to set the default setting of all documents to closed. It creates a complicated and onerous machinery for all information that, in reality, may only be needed for some information.

As a result the rules around disclosure created by FOI can paradoxically, make it harder to gain access to government information. (many older reporters will talk about how it was easier to gain access to documents in a pre-FOI era). This is not to disparage FOI. It is a critical and important tool and I don't advocate for its end. Nor am I naive enough to believe that government can be entirely open (nor am sure that would be an entirely good outcome, to say nothing of realistic) but I do hope that open data policies can become the default policy for large parts of the information environment that are currently occupied by FOI as, the fundamental defaults and assumptions it makes are, I believe, more suitable and effective (For both citizens and government) for a great deal (and maybe even the vast majority) of the information governments produce. FOI could serve as a fail safe as well as the necessary tool for documents and information that - for all sorts of reasons (privacy, security, cabinet confidence, etc...) cannot fall under the rubric of an open data initiative.

Whoa, that was all much longer than I intended, but I hope honours, and starts to answer, this last question you raised in your email.

Best,
David Eaves
www.eaves.ca
@daeaves

On 12-03-08 4:57 PM, Mark Weiler wrote:
Hi David,

You've worked hard to bring open government data and should be congratulated. But in his enthusiasm you've made some mistakes in your recent blog posting: http://eaves.ca/2012/03/08/calculating-the-value-of-canadas-open-data-portal-a-mini-case-study

First you wrote: "one fairly tangible value of open data portals is that they cheaply resolve some access to information requests."

That claim is not supported by the post. I'm not sure why published datasets would reduce FOIs. There's even evidence to suggest that posting FOIed documents on-line does not reduce the total number of FOIs.  In BC, the provincial government has a policy of making documents responsive to FOI downloadable at www.openinfo.gov.bc.ca.  In the six months this policy has been implemented, the BC Government has seen the total number of FOIs increase by 28% compared to the same period last year.

You also estimate the value of www.data.gc.ca by comparing the costs of access via an opendata portal (which you assume to be $0) with the method of access defined by the Access to Information Act. The estimate you provide is based on how much it would have cost to access all the data through the ATI Act:

726 downloads of files from Canada for January x $1332.21/ATI = $967,184.46
Over a year, you estimate that to be upwards of $11,606,213

However, it's important to recognize that once information is ordered through the Access to Information Act, other people can subsequently have the department send them the responsive documents.  The catalogues of ATIs you can order are posted on-line. Here is Citizenship and Immigration Canada’s catalogue: http://www.cic.gc.ca/english/department/atip/completed.asp
I'm sure there's a way of reducing the transaction cost of subsequent orders even further (the Office of the Information Commissioner used to have an on-line form).

It's important to note that the estimates you provide appear to be based on approximately 10 data files on www.data.gc.ca that were downloaded multiple times.  For example, "Permanent Resident Applications Processed Abroad and Processing Times", was downloaded 481 times in January 2012.   You are assuming subsequent access of the same data files will cost as much as the initial access.  That’s wrong, as I explained above.

So the lowest estimate would be:

10 data files x $1332/ATI  in one month = $13,322 and not $967,184

And in a year, it would still be $13,322 and not $11,606,213

Currently, subsequent orders via the ATI system have a transaction cost. Those aren't nearly as much as initial costs. And as said, I’m sure there’s ways of reducing even further.

Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?


Mark


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Re: Inflated costs in valuing data.gc.ca

Mark Weiler-2
Hi David,

I appreciate your response.  You wrote "There is nothing in my post that is intended to argue that open data is better or worse than FOI"  However, in your original blog post, you evaluated the value of data.gc.ca (through a $11,606,000 cost savings) by contrasting it with an unrealistic scenario of accessing the same volume of data through the FOI regime.  That comparison, which is inaccurate, creates the impression of "either/or".  Or it at least seemed to elevate the value of OGD at the expense of FOI. 

You wrote:

"Many Open data initiatives have the underlying goal of resetting the default setting in government to "open." One of the problematic impacts of FOI legislation is that it allowed governments to set the default setting of all documents to closed. It creates a complicated and onerous machinery for all information that, in reality, may only be needed for some information."

There are some misunderstandings of FOI legislation in there; but also common ground with it.

Freedom of information legislation also has the goal of a default setting of "open."  Section 4 of the Access to Information Act states that everyone in Canada "has a right to and shall, on request, be given access to any record under the control of a government institution." That creates the default position of "open".  It then limits that right in cases where general access could reasonably cause harm to a public interest. These are the exemptions defined in Sections 13-23.   A while ago, Herb said we ought to define which data sets are closed rather than which ones are open. That's pretty much what FOI does. It says everything is open (section 4), and then puts the effort into defining the records that are closed (section 13-23). 

If a government officials withholds information because they're not sure if an exemption applies (or they need to check with a delegated authority), then they might be undertrained or the procedures in place faculty or too strict.  Open Government datasets are prone to this too because they would also have to go through a redaction process before they are ever posted on-line. The Government of Canada should not be posting datasets that have people's names in it or information that would harm criminal investigations.

I think of FOI and OGD as two different chips sets, cast in the same spirit. There's many parallels and some differences. The question is: does anyone have ideas about how they can be integrated onto a common chipboard?

Thanks for the dialogue David. I hope there will be more. 

Mark





From: David Eaves <[hidden email]>
To: [hidden email]
Sent: Thursday, March 8, 2012 11:34:01 PM
Subject: Re: [CivicAccess-discuss] Inflated costs in valuing data.gc.ca

Mark,

Thank you for this response. I'm pretty upfront about the methodology being back of the envelop and I'm want to do some more thinking about this before I respond in full.

While the critiques of the methodology are welcome (and encouraged! - I definitely want us to find ways to measure value that are effective and accurate) I did want to quickly respond to the last line, which I found disconcerting.

"Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?"

There is nothing in my post that is intended to argue that open data is better or worse than FOI. I don't see them as competing and don't think I'm arguing that in my post. In the short run, I'm hopeful open data can be a way to take some of the burden off of the FOI system so that it can operate more efficiently (and, I think we can all agree it needs that). Or, more pessimistically, I hope it can at least ensure that the scarce resources of FOI systems are allocated to requests that couldn't be fulfilled by an open data portal. This was an implicit point in my post (which I should have made more explicit).

With that all said, I struggle to see where in my piece I argue about FOI and Open Data as if it is one of the other. If anything the piece is precisely about about how the two systems can support one another.

The question of convergence is an interesting one that I've talked about (but not sure I've written about). The key barrier to convergence in my mind however, is that the two initiative start from fundamentally different places.

Many Open data initiatives have the underlying goal of resetting the default setting in government to "open." One of the problematic impacts of FOI legislation is that it allowed governments to set the default setting of all documents to closed. It creates a complicated and onerous machinery for all information that, in reality, may only be needed for some information.

As a result the rules around disclosure created by FOI can paradoxically, make it harder to gain access to government information. (many older reporters will talk about how it was easier to gain access to documents in a pre-FOI era). This is not to disparage FOI. It is a critical and important tool and I don't advocate for its end. Nor am I naive enough to believe that government can be entirely open (nor am sure that would be an entirely good outcome, to say nothing of realistic) but I do hope that open data policies can become the default policy for large parts of the information environment that are currently occupied by FOI as, the fundamental defaults and assumptions it makes are, I believe, more suitable and effective (For both citizens and government) for a great deal (and maybe even the vast majority) of the information governments produce. FOI could serve as a fail safe as well as the necessary tool for documents and information that - for all sorts of reasons (privacy, security, cabinet confidence, etc...) cannot fall under the rubric of an open data initiative.

Whoa, that was all much longer than I intended, but I hope honours, and starts to answer, this last question you raised in your email.

Best,
David Eaves
www.eaves.ca
@daeaves

On 12-03-08 4:57 PM, Mark Weiler wrote:
Hi David,

You've worked hard to bring open government data and should be congratulated. But in his enthusiasm you've made some mistakes in your recent blog posting: http://eaves.ca/2012/03/08/calculating-the-value-of-canadas-open-data-portal-a-mini-case-study

First you wrote: "one fairly tangible value of open data portals is that they cheaply resolve some access to information requests."

That claim is not supported by the post. I'm not sure why published datasets would reduce FOIs. There's even evidence to suggest that posting FOIed documents on-line does not reduce the total number of FOIs.  In BC, the provincial government has a policy of making documents responsive to FOI downloadable at www.openinfo.gov.bc.ca.  In the six months this policy has been implemented, the BC Government has seen the total number of FOIs increase by 28% compared to the same period last year.

You also estimate the value of www.data.gc.ca by comparing the costs of access via an opendata portal (which you assume to be $0) with the method of access defined by the Access to Information Act. The estimate you provide is based on how much it would have cost to access all the data through the ATI Act:

726 downloads of files from Canada for January x $1332.21/ATI = $967,184.46
Over a year, you estimate that to be upwards of $11,606,213

However, it's important to recognize that once information is ordered through the Access to Information Act, other people can subsequently have the department send them the responsive documents.  The catalogues of ATIs you can order are posted on-line. Here is Citizenship and Immigration Canada’s catalogue: http://www.cic.gc.ca/english/department/atip/completed.asp
I'm sure there's a way of reducing the transaction cost of subsequent orders even further (the Office of the Information Commissioner used to have an on-line form).

It's important to note that the estimates you provide appear to be based on approximately 10 data files on www.data.gc.ca that were downloaded multiple times.  For example, "Permanent Resident Applications Processed Abroad and Processing Times", was downloaded 481 times in January 2012.   You are assuming subsequent access of the same data files will cost as much as the initial access.  That’s wrong, as I explained above.

So the lowest estimate would be:

10 data files x $1332/ATI  in one month = $13,322 and not $967,184

And in a year, it would still be $13,322 and not $11,606,213

Currently, subsequent orders via the ATI system have a transaction cost. Those aren't nearly as much as initial costs. And as said, I’m sure there’s ways of reducing even further.

Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?


Mark


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CivicAccess-discuss mailing list
[hidden email]
http://lists.pwd.ca/mailman/listinfo/civicaccess-discuss

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[hidden email]
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Re: Inflated costs in valuing data.gc.ca

Herb Lainchbury
The argument about open data legislation making access to data more onerous is backed up by my experience.  Before BC got into open data I would talk to government organizations here in BC asking them what the terms were on the data they had released.  Mostly I got "it's public domain, do whatever you want with it, we put it there so people would use it".  The understanding, or norm, was that citizens owned and had a right to access the data.  Now that we have a centralized open data model that sort of independent thinking is pretty much gone and we have data that is currently on the internet that many won't use because it hasn't yet been blessed by the centre.

In addition, now that BC has a closed by default policy on open data, so-called independent agencies, crown corps and even local governments are justified in their closed by default stance on open data.  They don't enjoy that level of discretion when it comes to FOI.

I don't see it as competing either, so we're all in agreement there.  FOI is a foundation upon which open data is built and has a model of open by default to which we in the open data community should aspire to.  In FOI we have explicit rights.  In open data we don't.  I am confident that without FOI, we wouldn't even be having this discussion.  To me FOI is critically important to a healthy democracy, right up there with free speech and secret ballots for elections and now open data.  We are well served to see FOI and OGD as great compliments to each other as Mark suggests.

I applaud David's desire to invent ways to measure value, and though the current FOI regime seems expensive it's really a drop in the bucket, however you cut it.  I am happy to see my tax dollars go there.  Even at $11M it's not even round off error on the $276B in spending.  To show the cost cutting value of open data here in BC I would like to see us apply it to health care costs at $17.8B or education at $11.8B or social services at $3.9B.  In addition I would like to see us focus on economic value generation aspects of open data - job creation for British Columbians, encouraging investment in BC, building better mousetraps, etc..  

To get into where we can create value in terms of how government works I think we need to know a lot more about about what government is trying to achieve, where our money is spent and what we're getting for it so we can help out in the most beneficial places.  FOI may well play a critical role in getting at the type of information we need to prove that value.

Herb


On Fri, Mar 9, 2012 at 1:21 AM, Mark Weiler <[hidden email]> wrote:
Hi David,

I appreciate your response.  You wrote "There is nothing in my post that is intended to argue that open data is better or worse than FOI"  However, in your original blog post, you evaluated the value of data.gc.ca (through a $11,606,000 cost savings) by contrasting it with an unrealistic scenario of accessing the same volume of data through the FOI regime.  That comparison, which is inaccurate, creates the impression of "either/or".  Or it at least seemed to elevate the value of OGD at the expense of FOI. 

You wrote:

"Many Open data initiatives have the underlying goal of resetting the default setting in government to "open." One of the problematic impacts of FOI legislation is that it allowed governments to set the default setting of all documents to closed. It creates a complicated and onerous machinery for all information that, in reality, may only be needed for some information."

There are some misunderstandings of FOI legislation in there; but also common ground with it.

Freedom of information legislation also has the goal of a default setting of "open."  Section 4 of the Access to Information Act states that everyone in Canada "has a right to and shall, on request, be given access to any record under the control of a government institution." That creates the default position of "open".  It then limits that right in cases where general access could reasonably cause harm to a public interest. These are the exemptions defined in Sections 13-23.   A while ago, Herb said we ought to define which data sets are closed rather than which ones are open. That's pretty much what FOI does. It says everything is open (section 4), and then puts the effort into defining the records that are closed (section 13-23). 

If a government officials withholds information because they're not sure if an exemption applies (or they need to check with a delegated authority), then they might be undertrained or the procedures in place faculty or too strict.  Open Government datasets are prone to this too because they would also have to go through a redaction process before they are ever posted on-line. The Government of Canada should not be posting datasets that have people's names in it or information that would harm criminal investigations.

I think of FOI and OGD as two different chips sets, cast in the same spirit. There's many parallels and some differences. The question is: does anyone have ideas about how they can be integrated onto a common chipboard?

Thanks for the dialogue David. I hope there will be more. 

Mark





From: David Eaves <[hidden email]>
To: [hidden email]
Sent: Thursday, March 8, 2012 11:34:01 PM
Subject: Re: [CivicAccess-discuss] Inflated costs in valuing data.gc.ca

Mark,

Thank you for this response. I'm pretty upfront about the methodology being back of the envelop and I'm want to do some more thinking about this before I respond in full.

While the critiques of the methodology are welcome (and encouraged! - I definitely want us to find ways to measure value that are effective and accurate) I did want to quickly respond to the last line, which I found disconcerting.

"Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?"

There is nothing in my post that is intended to argue that open data is better or worse than FOI. I don't see them as competing and don't think I'm arguing that in my post. In the short run, I'm hopeful open data can be a way to take some of the burden off of the FOI system so that it can operate more efficiently (and, I think we can all agree it needs that). Or, more pessimistically, I hope it can at least ensure that the scarce resources of FOI systems are allocated to requests that couldn't be fulfilled by an open data portal. This was an implicit point in my post (which I should have made more explicit).

With that all said, I struggle to see where in my piece I argue about FOI and Open Data as if it is one of the other. If anything the piece is precisely about about how the two systems can support one another.

The question of convergence is an interesting one that I've talked about (but not sure I've written about). The key barrier to convergence in my mind however, is that the two initiative start from fundamentally different places.

Many Open data initiatives have the underlying goal of resetting the default setting in government to "open." One of the problematic impacts of FOI legislation is that it allowed governments to set the default setting of all documents to closed. It creates a complicated and onerous machinery for all information that, in reality, may only be needed for some information.

As a result the rules around disclosure created by FOI can paradoxically, make it harder to gain access to government information. (many older reporters will talk about how it was easier to gain access to documents in a pre-FOI era). This is not to disparage FOI. It is a critical and important tool and I don't advocate for its end. Nor am I naive enough to believe that government can be entirely open (nor am sure that would be an entirely good outcome, to say nothing of realistic) but I do hope that open data policies can become the default policy for large parts of the information environment that are currently occupied by FOI as, the fundamental defaults and assumptions it makes are, I believe, more suitable and effective (For both citizens and government) for a great deal (and maybe even the vast majority) of the information governments produce. FOI could serve as a fail safe as well as the necessary tool for documents and information that - for all sorts of reasons (privacy, security, cabinet confidence, etc...) cannot fall under the rubric of an open data initiative.

Whoa, that was all much longer than I intended, but I hope honours, and starts to answer, this last question you raised in your email.

Best,
David Eaves
www.eaves.ca
@daeaves

On 12-03-08 4:57 PM, Mark Weiler wrote:
Hi David,

You've worked hard to bring open government data and should be congratulated. But in his enthusiasm you've made some mistakes in your recent blog posting: http://eaves.ca/2012/03/08/calculating-the-value-of-canadas-open-data-portal-a-mini-case-study

First you wrote: "one fairly tangible value of open data portals is that they cheaply resolve some access to information requests."

That claim is not supported by the post. I'm not sure why published datasets would reduce FOIs. There's even evidence to suggest that posting FOIed documents on-line does not reduce the total number of FOIs.  In BC, the provincial government has a policy of making documents responsive to FOI downloadable at www.openinfo.gov.bc.ca.  In the six months this policy has been implemented, the BC Government has seen the total number of FOIs increase by 28% compared to the same period last year.

You also estimate the value of www.data.gc.ca by comparing the costs of access via an opendata portal (which you assume to be $0) with the method of access defined by the Access to Information Act. The estimate you provide is based on how much it would have cost to access all the data through the ATI Act:

726 downloads of files from Canada for January x $1332.21/ATI = $967,184.46
Over a year, you estimate that to be upwards of $11,606,213

However, it's important to recognize that once information is ordered through the Access to Information Act, other people can subsequently have the department send them the responsive documents.  The catalogues of ATIs you can order are posted on-line. Here is Citizenship and Immigration Canada’s catalogue: http://www.cic.gc.ca/english/department/atip/completed.asp
I'm sure there's a way of reducing the transaction cost of subsequent orders even further (the Office of the Information Commissioner used to have an on-line form).

It's important to note that the estimates you provide appear to be based on approximately 10 data files on www.data.gc.ca that were downloaded multiple times.  For example, "Permanent Resident Applications Processed Abroad and Processing Times", was downloaded 481 times in January 2012.   You are assuming subsequent access of the same data files will cost as much as the initial access.  That’s wrong, as I explained above.

So the lowest estimate would be:

10 data files x $1332/ATI  in one month = $13,322 and not $967,184

And in a year, it would still be $13,322 and not $11,606,213

Currently, subsequent orders via the ATI system have a transaction cost. Those aren't nearly as much as initial costs. And as said, I’m sure there’s ways of reducing even further.

Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?


Mark


_______________________________________________
CivicAccess-discuss mailing list
[hidden email]
http://lists.pwd.ca/mailman/listinfo/civicaccess-discuss

_______________________________________________
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[hidden email]
http://lists.pwd.ca/mailman/listinfo/civicaccess-discuss


_______________________________________________
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[hidden email]
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--
Herb Lainchbury
Dynamic Solutions Inc.
www.dynamic-solutions.com
http://twitter.com/herblainchbury
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Re: Inflated costs in valuing data.gc.ca

David Eaves
+1 Herb.

Also, I refined my comments form *late* last night into a blog post:
http://eaves.ca/2012/03/09/access-to-information-open-data-and-the-problem-with-convergence/

Very grateful to Mark for pushing me to write and think more on this.

Dave

On 12-03-09 12:10 PM, Herb Lainchbury wrote:
The argument about open data legislation making access to data more onerous is backed up by my experience.  Before BC got into open data I would talk to government organizations here in BC asking them what the terms were on the data they had released.  Mostly I got "it's public domain, do whatever you want with it, we put it there so people would use it".  The understanding, or norm, was that citizens owned and had a right to access the data.  Now that we have a centralized open data model that sort of independent thinking is pretty much gone and we have data that is currently on the internet that many won't use because it hasn't yet been blessed by the centre.

In addition, now that BC has a closed by default policy on open data, so-called independent agencies, crown corps and even local governments are justified in their closed by default stance on open data.  They don't enjoy that level of discretion when it comes to FOI.

I don't see it as competing either, so we're all in agreement there.  FOI is a foundation upon which open data is built and has a model of open by default to which we in the open data community should aspire to.  In FOI we have explicit rights.  In open data we don't.  I am confident that without FOI, we wouldn't even be having this discussion.  To me FOI is critically important to a healthy democracy, right up there with free speech and secret ballots for elections and now open data.  We are well served to see FOI and OGD as great compliments to each other as Mark suggests.

I applaud David's desire to invent ways to measure value, and though the current FOI regime seems expensive it's really a drop in the bucket, however you cut it.  I am happy to see my tax dollars go there.  Even at $11M it's not even round off error on the $276B in spending.  To show the cost cutting value of open data here in BC I would like to see us apply it to health care costs at $17.8B or education at $11.8B or social services at $3.9B.  In addition I would like to see us focus on economic value generation aspects of open data - job creation for British Columbians, encouraging investment in BC, building better mousetraps, etc..  

To get into where we can create value in terms of how government works I think we need to know a lot more about about what government is trying to achieve, where our money is spent and what we're getting for it so we can help out in the most beneficial places.  FOI may well play a critical role in getting at the type of information we need to prove that value.

Herb


On Fri, Mar 9, 2012 at 1:21 AM, Mark Weiler <[hidden email]> wrote:
Hi David,

I appreciate your response.  You wrote "There is nothing in my post that is intended to argue that open data is better or worse than FOI"  However, in your original blog post, you evaluated the value of data.gc.ca (through a $11,606,000 cost savings) by contrasting it with an unrealistic scenario of accessing the same volume of data through the FOI regime.  That comparison, which is inaccurate, creates the impression of "either/or".  Or it at least seemed to elevate the value of OGD at the expense of FOI. 

You wrote:

"Many Open data initiatives have the underlying goal of resetting the default setting in government to "open." One of the problematic impacts of FOI legislation is that it allowed governments to set the default setting of all documents to closed. It creates a complicated and onerous machinery for all information that, in reality, may only be needed for some information."

There are some misunderstandings of FOI legislation in there; but also common ground with it.

Freedom of information legislation also has the goal of a default setting of "open."  Section 4 of the Access to Information Act states that everyone in Canada "has a right to and shall, on request, be given access to any record under the control of a government institution." That creates the default position of "open".  It then limits that right in cases where general access could reasonably cause harm to a public interest. These are the exemptions defined in Sections 13-23.   A while ago, Herb said we ought to define which data sets are closed rather than which ones are open. That's pretty much what FOI does. It says everything is open (section 4), and then puts the effort into defining the records that are closed (section 13-23). 

If a government officials withholds information because they're not sure if an exemption applies (or they need to check with a delegated authority), then they might be undertrained or the procedures in place faculty or too strict.  Open Government datasets are prone to this too because they would also have to go through a redaction process before they are ever posted on-line. The Government of Canada should not be posting datasets that have people's names in it or information that would harm criminal investigations.

I think of FOI and OGD as two different chips sets, cast in the same spirit. There's many parallels and some differences. The question is: does anyone have ideas about how they can be integrated onto a common chipboard?

Thanks for the dialogue David. I hope there will be more. 

Mark





From: David Eaves <[hidden email]>
To: [hidden email]
Sent: Thursday, March 8, 2012 11:34:01 PM
Subject: Re: [CivicAccess-discuss] Inflated costs in valuing data.gc.ca

Mark,

Thank you for this response. I'm pretty upfront about the methodology being back of the envelop and I'm want to do some more thinking about this before I respond in full.

While the critiques of the methodology are welcome (and encouraged! - I definitely want us to find ways to measure value that are effective and accurate) I did want to quickly respond to the last line, which I found disconcerting.

"Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?"

There is nothing in my post that is intended to argue that open data is better or worse than FOI. I don't see them as competing and don't think I'm arguing that in my post. In the short run, I'm hopeful open data can be a way to take some of the burden off of the FOI system so that it can operate more efficiently (and, I think we can all agree it needs that). Or, more pessimistically, I hope it can at least ensure that the scarce resources of FOI systems are allocated to requests that couldn't be fulfilled by an open data portal. This was an implicit point in my post (which I should have made more explicit).

With that all said, I struggle to see where in my piece I argue about FOI and Open Data as if it is one of the other. If anything the piece is precisely about about how the two systems can support one another.

The question of convergence is an interesting one that I've talked about (but not sure I've written about). The key barrier to convergence in my mind however, is that the two initiative start from fundamentally different places.

Many Open data initiatives have the underlying goal of resetting the default setting in government to "open." One of the problematic impacts of FOI legislation is that it allowed governments to set the default setting of all documents to closed. It creates a complicated and onerous machinery for all information that, in reality, may only be needed for some information.

As a result the rules around disclosure created by FOI can paradoxically, make it harder to gain access to government information. (many older reporters will talk about how it was easier to gain access to documents in a pre-FOI era). This is not to disparage FOI. It is a critical and important tool and I don't advocate for its end. Nor am I naive enough to believe that government can be entirely open (nor am sure that would be an entirely good outcome, to say nothing of realistic) but I do hope that open data policies can become the default policy for large parts of the information environment that are currently occupied by FOI as, the fundamental defaults and assumptions it makes are, I believe, more suitable and effective (For both citizens and government) for a great deal (and maybe even the vast majority) of the information governments produce. FOI could serve as a fail safe as well as the necessary tool for documents and information that - for all sorts of reasons (privacy, security, cabinet confidence, etc...) cannot fall under the rubric of an open data initiative.

Whoa, that was all much longer than I intended, but I hope honours, and starts to answer, this last question you raised in your email.

Best,
David Eaves
www.eaves.ca
@daeaves

On 12-03-08 4:57 PM, Mark Weiler wrote:
Hi David,

You've worked hard to bring open government data and should be congratulated. But in his enthusiasm you've made some mistakes in your recent blog posting: http://eaves.ca/2012/03/08/calculating-the-value-of-canadas-open-data-portal-a-mini-case-study

First you wrote: "one fairly tangible value of open data portals is that they cheaply resolve some access to information requests."

That claim is not supported by the post. I'm not sure why published datasets would reduce FOIs. There's even evidence to suggest that posting FOIed documents on-line does not reduce the total number of FOIs.  In BC, the provincial government has a policy of making documents responsive to FOI downloadable at www.openinfo.gov.bc.ca.  In the six months this policy has been implemented, the BC Government has seen the total number of FOIs increase by 28% compared to the same period last year.

You also estimate the value of www.data.gc.ca by comparing the costs of access via an opendata portal (which you assume to be $0) with the method of access defined by the Access to Information Act. The estimate you provide is based on how much it would have cost to access all the data through the ATI Act:

726 downloads of files from Canada for January x $1332.21/ATI = $967,184.46
Over a year, you estimate that to be upwards of $11,606,213

However, it's important to recognize that once information is ordered through the Access to Information Act, other people can subsequently have the department send them the responsive documents.  The catalogues of ATIs you can order are posted on-line. Here is Citizenship and Immigration Canada’s catalogue: http://www.cic.gc.ca/english/department/atip/completed.asp
I'm sure there's a way of reducing the transaction cost of subsequent orders even further (the Office of the Information Commissioner used to have an on-line form).

It's important to note that the estimates you provide appear to be based on approximately 10 data files on www.data.gc.ca that were downloaded multiple times.  For example, "Permanent Resident Applications Processed Abroad and Processing Times", was downloaded 481 times in January 2012.   You are assuming subsequent access of the same data files will cost as much as the initial access.  That’s wrong, as I explained above.

So the lowest estimate would be:

10 data files x $1332/ATI  in one month = $13,322 and not $967,184

And in a year, it would still be $13,322 and not $11,606,213

Currently, subsequent orders via the ATI system have a transaction cost. Those aren't nearly as much as initial costs. And as said, I’m sure there’s ways of reducing even further.

Rather than compare FOI legislation and Open Gov Data as if it’s “one or the other”, do you think there's a way of talking about how the two might converge?


Mark


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