2016.1 Fitness for purpose – Analysis – DiscussionPaper

1Purpose

This paper outlines a number of discussion topics that could be discussed in the new MIWP action 2016.1 Fitness for purpose – Analysis. It aims at structuring the discussion for the implementation of action 2016.1 with the aim to, ultimately, identify a number of possible MIWP follow-up actions that could be defined/proposed by this action as a follow up in 2017 or beyond.

This version will serve as input for the discussion of the 2016.1 sub-group at its kick-off meeting on 30 September 2016 at the INSPIRE Conference and should be developed further into a document summarising the proposals of the group for MIWP follow-up actions.

2Introduction

According to its description in the MIWP 2016-2020, action 2016.1 aims at systematically analysing and reviewing INSPIRE requirements in the legal (implementing rules) and technical (guidelines, etc) framework and of the implementation practices and concrete difficulties in the Member States, with the aim to identify and propose to the MIG possible measures for streamlining and simplification of INSPIRE implementation. The MIWP states:

"…the Implementing Acts (except for the 2009 Reporting Decision) and technical guidelines will be screened to identify areas where most gains could be harvested. Repeatedly, the focus of discussion is linked to the interoperability specifications, in particular in relation to Annex III data themes. A more in-depth reflection may be needed for this particular aspect. Based on the identified obstacles and requirements, proposals for streamlining and simplification will be made. These may include, but not be limited to:

  • opportunities to simplify the requirements in the Implementing Acts and Technical Guidelines (e.g. for Annex III data),
  • additional guidance or clarifications through Q/A documents (e.g. to reduce differences in implementation approaches or align thematic priority setting for implementation),
  • promotion or developments of tools supporting INSPIRE implementation and/or usage of INSPIRE data and services,
  • setting up a tiered maturity roadmap for implementation (basic, essential, premium) – see below,
  • IT mainstreaming of the technical components of INSPIRE (ISO/DCAT; GML/JSON; reuse/endorsement of existing vocabularies e.g. ELF …).

As regards the Implementing Acts, any outcome will be reported to the INSPIRE Committee."

Based on the mandate for action 2016.1, the action will prepare a discussion document for MIG-P (or Committee, if appropriate)by November 2016 with the following elements:

  • List of identified issues including their proposed solutions (technical and/or legal)
  • List of proposed MIWP action(s) for 2017 and beyond for implementing the proposals for streamlining and simplification
  • Brief assessment of the impact of the proposed changes on existing implementations

The complete action description is available in the Annex.

In the following, we outline a number of discussion topics the action / sub-group should address. The document includes a number of questions which should guide the discussion of the sub-group. In preparation of the MIG-P, any document should then translate the discussions of the sub-group into possible and proposed actions for the future MIWP.

3Defining “fitness for purpose”

The current action description focuses heavily on streamlining and simplification, mainly for data and service providers. However, the action is embedded in the larger MIWP work package 1, which is aiming at improving INSPIRE’s “fitness for purpose”, i.e. also focusing on how well (or not) INSPIRE data and services can be used for a large number of applications. Any streamlining/simplification should take place within the context of the expected objectives (output/outcome/effect) of the Directive and focus on how these objectives can be realised in a most efficient and effective wayfor the providers and the users of the infrastructure.Also, depending on the purpose, other measures than streamlining/simplification may be appropriate. However, there are still different opinions on what the main/priority purposes of INSPIRE are, so we need to work on a common understanding.

Clearly, the main purpose defined in the Directive is the support of “Community environmentalpolicies and policies or activities which may have an impact onthe environment”. The wide definition of its purpose clearly includedsupport to environmental reporting (in view of the ongoing Fitness Check for environmental monitoring and reporting), support to implementation and monitoring of environmental policies and international initiatives (e.g. UN-GGIM, Aarhus Convention) and easy access of environmental information for the public. However, Member States (e.g. as illustrated in their 2016 reports) and other Commission DGs also see support for (national) eGovernment strategies, other policy areas (e.g. disaster management, energy, intelligent transport systems, Copernicus) and the data economy as important purposes.

4Simplification of implementation

One of the main tasks of the group will be to analyse issues/obstacles for data and service providers in INSPIRE implementation. As outlined in the action description, this task will be supported by the questionnaire developed by the action, but the sub-group shall define in detail obstacles to the implementation in the MS, features in the INSPIRE framework that are not being used and opportunities for streamlining through feedback from the working group members as well as desktop studies.

In particular, the 2016 INSPIRE reports, the minutes from the bilateral meetings between MS and the Commission and MS action plans should be used as a starting point for this analysis.

4.1Simplification of Implementing Rules, in particular data interoperability requirements, especially for Annex III

Overall, most of the existing Implementing Rules are now widely used and tested, but there is still a lack of implementation experience and practical examples in particular for the IRs on data interoperability for Annex III. Due to perceived difficulties in implementation, there has been some push from some Member States to take out Annex III from the IRs on data interoperability and to re-cast it as Technical Guidance, following theminimum requirements defined in Art. 7(4) of the INSPIRE Directive for Annex III data models in the IRs: “the definition and classification of spatial objects … and the way in which those spatial data are geo-referenced”. However, there has not yet been a detailed analysis of the concrete implementation problems leading to this proposal. Also in the bilateral meetings and in several environmental reporting communities, the complexity and the potential costs (with limited benefits for the community itself) of the Annex III data models have been raised repeatedly.

At the same time, some MS point out in their 2016 reports that some of the data models are actually too simplistic and would need to be extended in order to be useful for specific applications.

Moreover, this review should also allow addressing similar issues with other Implementing Rules, should they exist. So far, no significant problems in the implementation have been highlighted (except for the burden of reporting which will be addressed in a separate exercise, see action 2016.2).

Therefore action 2016.1 should aim at understanding in detail where (theme by theme) data models are too complex (compared to the data actually held in the public authorities).Under this heading, the main focus of discussion should be on the legally binding provisions and the flexibility that is already enshrined in the INSPIRE Directive and its IRs. It should identify whether the revision of the IRs would actually be the most effective way of addressing the issues and what type of amendments would be needed. As part of the wider discussion, it should be explored whether some of the identified issues could not be overcome through other measures within the existing legal framework, in particular better tool support, alternative encodings (in addition to GML), common applications to specific environmental legislation (monitoring and reporting) and best practices/guidelines for creating extensions (ongoing). This will be discussed in more detail under section 5.

Questions for discussion:

  • Are the IR on data specifications for Annex III the most important (only) issue that should be considered for revision or are there other issues in the legally binding IRs (e.g. metadata, network services) which need attention (see also questionnaire)?
  • What precisely is the problem with the data specifications given the degree of flexibility in the current IRs?
  • Is there a clear differentiation between the provisions of the Directive, IRs and guidance? How can these be separated to make sure that legal compliance is not measured in light of non-binding guidance materials?

4.2Implementation approach & compliance & conformity

One possible way forward (for the issue discussed above) without making (m)any further changes to the existing legal framework and TGs is a clearer approach to implementation and compliance which makes better use of the existing flexibilities and introduces clear priority setting. This is based on the assumption that we will not reach 100% compliance for all components by the final 2021 deadline if we consider all elements in the IRs and the TGs.

While clearly expressed in all TG documents and in the work of action 2016.3 on validation and conformity testing, there seems to also be a lack of clarity (at management level) of what is legally binding (without any flexibility) and where are requirements which can be applied in a more flexible way so to maximise benefits and avoid unnecessary costs. For example, some Member States have reported in the bilateral that they consider the Technical Guidance requirements as binding, which is "legally speaking" not correct. Thus, we may have to be more precise (in communication at all levels) when talking about "legal compliance" (with the IRs) and "technical conformity" (with the TGs). In this respect, it will be important to stress that the common validator developed by action 2016.3 focuses on conformity with the TGs only and should be seen as a tool for supporting implementers (to check the progress of their implementations) rather than for checking legal compliance. This is also reflected by the fact that the work in action 2016.3 already recognises that, instead of black-or-white conformity (yes/no), conformity should be measurable and expressed in percentages or similarly in conformance classes.

This discussion could also include the further development of the proposed framework of implementation levels (INSPIRE basic / essential / premium) and how to use it, including possible prioritisation of implementation at different levels (national, regional, local).

In order to still achieve a coherent and comparable progress of INSPIRE implementation across Europe (rather than the many different implementation priorities and approaches), this would require a coordination between countries and the EC on a common priority setting and on an alignment of implementation approaches (of course allowing for national differences where necessary because of the administrative situation). The 2016 MS reports and action plans provide already significant and detailed information on that direction.

Potentially, this discussion should consider dedicated approaches for

  1. the reference data in Annex I (NB the data interoperability deadline at the end of 2017)
  2. the environmental data in Annexes II+III (with strong relevance for the INSPIRE/reporting discussion)

Questions for discussion:

  • How can we address identified implementation challenges? Are there flexibilities in the legal system that we are not using sufficiently? Do we need a discussion about "what is compliance" and "what should be our priorities"?
  • Do you consider it useful to further develop the proposed framework of implementation levels (INSPIRE basic / essential / premium)?

4.3Dependency on standards

Standards are often very complex because they try to cover all possible cases. The INSPIRE profiles defined in the TGs already restrict the possible choices, but still allow a number of different alternative implementations (based on different base standards), e.g.

  • The TG for discovery servicessupports 3 federated scenarios, multiple protocols.
  • The TG for download services define options based on Atom for predefined dataset download (currently the option used by the majority of services) and options based on WFS, WCS and SOS standards for direct access download.
  • The TG for view services support different versions and flavours (e.g. WMS, WMTS) and a wide range of CRS.

Complexity is also introduced by the fact that the NS IR is adding requirements that go beyond OGC standards (e.g. language parameter, extended capabilities and the requirement to also support pre-defined dataset download also if you are supporting direct access), so that OGC-compliant off-the-shelf products and existing services are not 100% INSPIRE-compliant, unless extensions are implemented.

The heavy dependency on OGC specifications itself could also be considered to be an issue. Certain functionalities could be simplified by alternative standards and best practices, e.g. those defined for (spatial) data on the web[1] (see also section 5.2).

Questions for discussion:

  • Should the implementation options in the TGs be (further) limited or kept flexible (different implementation options)?
  • Is the dependency on OGC specifications an issue for implementation? If so, what could be alternative standards or technologies?

5Simplification of use

As mentioned above, the perceived complexity of the IRs could also be addressed through simplifying the use. In other words, some of the identified issues could be overcome through other measures within the existing legal framework, in particular better tool support, alternative encodings (in addition to GML), common applications to specific environmental legislation (monitoring and reporting) and best practices/guidelines for creating extensions (ongoing). This will be discussed in more detail under section 5.

The other main task of the group will be to analyse issues/obstacles for the use of INSPIRE data and services. It has been frequently highlighted that there are problems of using the INSPIRE infrastructure in practice; however, also here there has not yet been a detailed analysis of the concrete problems encountered by users.

For this area, it will be important to collect feedback from actual or potential users of INSPIRE data and services, either through the questionnaire, MS reports or other means. Users will generally not necessarily be “end users” (e.g. EC or MS policy makers or the general public), but rather GI/SDI professionals, software/application developers or system-integrators, who perform spatial analyses or build value-added services or applications.

Discussion questions:

  • Are other EU-level measures necessary to simplify the use of the INSPIRE infrastructure, e.g. related to tools and/or capacity building and training?

5.1Where (for which tasks specifically) do potential users of INSPIRE data and services encounter problems?Data sharing and access by public to environmental information

When talking to MS representatives, we often get the impression that data sharing is not an issue. Yet, it is identified as one in the REFIT evaluation, and will become even more important when starting to developing applications based on INSPIRE data and services or when trying to build pan-European data sets (see the example of ELF). Again, an analysis of the relevant chapter in the 2016 MS reports will provide useful evidence. Easy and user-friendly access to environmental information by the public (including citizens and) is also an important objective of the INSPIRE framework. The bilateral meetings have shed light on the fact that many Member States implement data-sharing by ensuring open access to all of the relevant information under Annexes I-III. This approach is also in line with initiatives under the DSM (eGovernment) and the Aarhus Convention, in particular as regards active dissemination of environmental information.

Questions for discussion:

  • When doing an analysis or creating an applicationbased on pan-European or cross-border data, is there an impact of the existing heterogeneous licences and access control approaches across Europe?
  • If this is a problem, what could be possible solutions that can be easily implemented to solve (parts of) the problem?

5.2Technological evolution

Technologies and standards keep evolving, and there is a push by some to move away from the geo-ICT standards (OGC and ISO/TC 211) and related “niche” technologies, which INSPIRE is now heavily based on, to more mainstream ICT/web standards and technologies. This includes the fundamental question whether the service oriented architecture (SOA) paradigm, that INSPIRE is built on, is still timely.

Of course, we always need to find a balance between stability and up-to-dateness of the INSPIRE IRs and TGs. On the other hand, simply adding additional guidelines for new technologies or standards might also be counter-productive, since it will ultimately lead to less interoperability.

The role and functionality of the INSPIRE geoportal should also be discussed in this context. It is currently providing access to all data and services on an equal basis and provides only basic search, viewing and downloading functionalities. It should be discussed if the geoportal’s functionality should be extended and/or whether its content should be curated in some way, e.g. in order to promote “gold/premium” data sets.

This is another area where feedback from actual users (incl. data analysts and application developers) is crucial. It is, however, important to ground these discussions on real implementation examples.

Questions for discussion:

  • Is the service oriented architecture (SOA) paradigm, that INSPIRE is built on, is still timely? If not, what could be alternative paradigms, or how could the current architecture be augmented to make it easier to use?
  • Should the implementation options in the TGs be (further) limited or kept flexible (different implementation options)?
  • Is the dependency on OGC specifications an issue for users? If so, what could be alternative standards or technologies?
  • How should the INSPIRE geoportal evolve?

Annex: 2016.1: INSPIRE fitness for purpose – Analysis

Title / INSPIRE fitness for purpose – Analysis
ID / 2016.1
Status / ☐ Proposed / ☒ Endorsed / ☐ In Progress / ☐ Completed
Issue / Member States and stakeholders have repeatedly expressed concerns regarding the (perceived) complexity of the INSPIRE data models and guidelines, in particular for Annex III, and the expected difficulty to have them implemented by the 2020 deadline. In the report to Council and European Parliament[2], the Commission is recommended to “review, and possibly revise, the INSPIRE rules, in particular on spatial data harmonisation, to take into account the implementing risks and complexities with a view to reducing them (simplification of requirements)”.