Fwd: By 12/15: Send us comments to rally the Dept. of Ed. toward free licensing
Amichai Rotman
amichai at iglu.org.il
Sat Dec 12 12:53:24 IST 2015
I guess some of you will find this interesting...
Amichai.
---------- Forwarded message ----------
From: Free Software Foundation <info at fsf.org>
Date: 2015-12-08 20:14 GMT+02:00
Subject: By 12/15: Send us comments to rally the Dept. of Ed. toward free
licensing
To: Amichai Rotman <amichai at iglu.org.il>
[image: Free Software Foundation]
The U.S. Department of Education has issued a notice of proposed rule
making (NPRM) with a request for comments from the public regarding new
regulations relating to the licensing of grant-funded works -- both
software and courseware.
These proposed regulations
<http://tech.ed.gov/files/2014/06/OET-Open-License-NPRM-FINAL-Web-Posting.pdf>
are meant to facilitate public reuse of works funded by Department of
Education grants. Currently, as explained in the NPRM, grantees are allowed
to make their federally-funded works proprietary. The Department of
Education receives a special license to share the works with the public,
but in practice it rarely does so. Worse, teachers and students absolutely
cannot use them in freedom (except for those few that happen to be made
free).
Since the course materials are works of practical use, they should carry
the four freedoms of free software, just as programs and manuals should
<https://gnu.org/philosophy/free-sw.html>.
The proposal would require grantees to publish the works under an "open"
license. In the case of software, they may be thinking of "open source",
which is not quite as strong as free; in the case of courseware, many
"open" courses are *not* free. The flaw in the proposed specific rules is
that they don't require that the license permit redistribution of modified
versions. Without that freedom, the works will be nonfree.
With a small change, this proposal will more clearly do what is needed. The
small change is to add "redistribution of modified versions" to the list of
uses these works must permit users to do.
If you are a US citizen or you are living in the US, then you can help make
that change happen by submitting a comment advocating it.
If you are not a US citizen, then we hope you will use this as an
opportunity to reach out to the department of education or the appropriate
government rule makers in your own country and encourage them to adopt
similar rules -- ones that require grant funded works of a functional
nature be distributed under free licenses. If you do contact your own
government with such a request, please, email licensing at fsf.org and let us
know!
Unfortunately, submitting a comment digitally <http://www.regulations.gov>
requires the user to run nonfree JavaScript (JS) code
<https://www.gnu.org/philosophy/javascript-trap.html>. We are taking a
stand against that by submitting the FSF's comment another way. We are
going to submit it by post so that it gets to the DOE by Friday, December
18th (the date comments are due).
To help you submit a comment without running the US government's nonfree
JS, we offer to print and send your comment along with ours. To do that, we
need to receive your comment by email sent to licensing at fsf.org with the
subject "DOE comment" by 12:00PM EST on December 15th. We can print PDF
files, ODF files and plain text. You need to follow the rules for
submissions 100%, because we don't have staff to correct even minor errors.
The eRulemaking Initiative has some guidance on how to write a good comment
<http://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf>.
But in the very least: your comment should clearly cite the above
referenced NPRM, it should express your support for these proposed
regulations, and it should cite the exact section (§3474.20 (a)) that you
believe should be updated and why you think it should, including any
relevant personal or professional experience or knowledge.
We may skip comments that are too long or that are inconsistent with the
goal. Please say in your email message whether you give permission for us
to publish your comment.
While we would like to deliver a large packet of comments to the Department
of Education, you can also mail your own: address them to Sharon Leu, U.S.
Department of Education, 400 Maryland Avenue SW., Room 6W252, Washington,
DC 20202-5900.
In addition, if you are interested in becoming a cosigner to the comment
the FSF is going to write and submit, then please email us at
licensing at fsf.org with the subject "DOE comment cosigner." In your email
please provide your full name, city and state, and be aware that we will be
making that information public as part of publishing our comment.
Lastly, there should be no doubt in your mind that the FSF's work in free
licensing, licensing education, and advocacy has played a meaningful part
in the circumstances that have lead to the US Department of Education
reforming its policy from promoting proprietary works to one that requires
the development of only free works. We know that the GNU GPL and the FSF's
work in free licensing education serves as a guiding light to policy makers
everywhere. But, in order for us to continue positively influencing public
policy, we need your help: please, become an associate member or make a
donation today <https://www.fsf.org/appeal>.
*Read this online:
https://www.fsf.org/blogs/licensing/send-comments-to-doe-12-15
<https://www.fsf.org/blogs/licensing/send-comments-to-doe-12-15>*
Follow us on GNU social <https://status.fsf.org/fsf> | Subscribe to our
blogs via RSS <https://fsf.org/blogs/RSS> | Join us as an associate member
<https://www.fsf.org/jf>
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