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About this Blog

European Public Sector Information (PSI) Platform Guest Blog

How the Guest Blog Works …

Every month or so, there will be a new ‘Guest’ Blogger. The Bloggers will come from all sectors within the PSI Community. The topics and issues discussed will cover a wide range of perspectives and experiences.

The aim is to stimulate debate and discussion about the latest news, opinions, and strategies related to PSI re-use.

We hope that you will contribute your thoughts and ideas in response to the issues. We would like to hear your perspectives and views. As you would expect, we won’t publish comments which are abusive or offensive. But, within this basic parameter, the goal is to have discussion between the Blogger and the audience which is open and informative.

If you are interested in becoming a PSI Platform Blogger, please contact us – European PSI Platform Team. We would be pleased to hear from you and to discuss your ideas about topics for the Blog.

To contribute/post your comments to this Blog, please log on to the site and then post your comments.

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Audrey Mandela

Audrey Mandela

Audrey Mandela chairs the Locus Association, an organisation that works to encourage the public sector to maintain a fair and equitable trading environment in relation to licensing and re-use of public sector information (PSI); she is also a director and company secretary for Women in Telecoms & Technology (WiTT).

Audrey was co-founder and director of Multimap, Europe’s leading on-line mapping services company. Multimap was sold to Microsoft in December 2007. Previously, Audrey ran the Yankee Group’s research and sales activities in Europe, Latin America and Asia. Audrey holds a bachelor's degree from Wellesley College, Wellesley, Massachusetts, USA.

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Locus Association’s response to the Ordnance Survey Consultation

Audrey Mandela

15 March 2010

Number of Comments: 0

The Locus Association recently submitted its response to the UK’s Department for Communities and Local Government (CLG) consultation on Ordnance Survey, and thought readers of this blog might be interested to see a synopsis of our submission. The Consultation closes on 17 March, so there’s still a bit of time to get your own views in, if you haven’t already done so.

First, Locus is very pleased to see this Consultation taking place, since we have been concerned for some time that the plan for Ordnance Survey introduced in October 2008 was not appropriate for a number of reasons, which we detail in our full submission document. However, we do still have concerns about the way in which this process has been conducted, and about some of the comments and assumptions in the Consultation Document.

As those familiar with the OS consultation will know, the document that details the UK government’s proposals for OS’s future offers three suggested policy Options for the way ahead (please see http://www.communities.gov.uk/publications/corporate/ordnancesurveyconsultation) for a copy of the consultation document). In general, most Locus members believe that the proposals offered in the Consultation Document have been designed to perpetuate Ordnance Survey’s dominance of the UK GI market, rather than to create a more open and fair environment for all players.

Several statements/assumptions in the report are of significant concern, including:

  • Ordnance Survey does not understand or seek to account for its true costs on a product basis;
  • There is confusion around the concepts of product and service/delivery mechanism;
  • The need for some form of regulation is underestimated and dismissed;
  • There is a lack of appreciation of the conflicts of interest that exist when OS is both a competitor and a supplier of base data; and
  • There is an assumption that OS data is better and more current than data that could be provided by the private sector if there were a level playing field.

Locus does not consider any one of the three Options offered in the Consultation Document to be ideal; our preferred way forward for OS would include the following actions/points:

  • First define Ordnance Survey’s Public Task.
  • Provide free access to all unrefined data that government requires; this would likely include Addressing and Boundary data. These datasets should be definitive and authoritative if at all possible.
  • Where mapping and refined products/services are chargeable the market should be fair and competitive.
  • There must be full structural and accounting separation between an OS DataCo and ProductCo or unrefined/refined business.
  • Locus is supportive of recent discussions to change the OS licensing model, as outlined in the Consultation document and in previous OPSI communications, and believes that work on these changes should continue whichever model is chosen:

- rationalisation of specific use contracts;

- simplified and shortened licences;

- some price reductions; and

- less restrictive licences (especially in relation to derived data).

  • OS should not continue to have a price advantage over its channel when dealing with government as customers. Government should ensure that tendering for supply contracts is fair and does not advantage OS.

The specific views of the majority of Locus members on the Consultation and its proposals are as follows:

  • Locus supports several of the policy drivers behind this Consultation: We agree that location is increasingly important and that it should be easier to get hold of government-held Core Reference Data (CRD), meaning data that has to be created as part of OS’s (and other government entities’) Public Task. Examples of CRD are Boundaries, Street Names, Road Traffic Layouts, Planning Consents. We also agree that government should work to coordinate its information requirements and not duplicate work.
  • Government must also be able to transfer the data it needs between central/local government without hindrance.
  • Locus believes Natural Government monopoly data should be made available as PSI. However, Locus’s majority view is that any data that will be made available free of charge must pass a “genuine government monopoly” test first. Without this test, government runs the risk of making the taxpayer fund the creation of data or products which would otherwise be created by the private sector in a normal competitive market.
  • Locus strongly supports the proposal for the creation of not only a single National Address Register, but also a single National Postcode Register, both of which would be provided as free PSI. We recognise that the creation of these registers would require collaboration between a number of organisations and departments (particularly Royal Mail, Ordnance Survey, Local Authorities), but consider it essential that government find a way through the current licensing barriers and ownership issues.
  • Refined products and services should not be provided free of charge/should not be subsidised by Government. Locus has grave concerns about the inclusion of any type of “service”, such as access delivery, or a mapping API, as part of any OS Free option, because:

- It would undermine the existing OS Partner channel;

- It would create additional costs for OS and government;

- Such services go well beyond anything that should be considered part of OS’s public task.

  • Whatever data is released for free, if any, government must satisfy itself that Ordnance Survey is creating data and products cost effectively; any new products or product adaptations should be competed to ensure government receives value for money. This should be considered as part of each review of the OS Public Task.
  • We do not believe that Government should commit any funding for products that are not explicitly part of the Ordnance Survey Public Task (which must first be defined). Any funding would inevitably provide Ordnance Survey with a competitive advantage over alternative suppliers, and also prevents new players from entering and investing in the market.
  • If OS is to charge for the use of any data or compete with commercial entities in any way, then fully separate accounting and structural separation for OS divisions is essential. This is consistent with the PSI regulations, which say that PSIHs should separate clearly and fairly commercial activities from data collection activities. The lack of structural separation leaves the door open to cross-subsidization and anti-competitive trading by PSIHs.
  • Locus is concerned that there is only one mention of Derived Data in the Consultation. In our view, one of the most important reforms that should come out of this Consultation is the removal of the Derived/Associated Data restrictions that currently exist (and this must also apply retrospectively for derived data created in the past). This is a key issue for our members and many other users of OS data and products. Our view is that while no one should be able to re-engineer OS maps from Derived Data, users should be able to retain and continue to use their own data derived from OS maps without paying OS additional license fees.
  • There is a definitely a need for a regulatory body with teeth to ensure that there is fair competition. Although the Consultation appears to reject any form of regulation of OS beyond the IFTS rules, Locus believes this is not sufficient. There are a number of ways in which stronger regulation can and should be introduced without incurring high costs.
  • We strongly agree with the Consultation document that markets must be free and fair. However, many parties in this PSI sector believe that it is impossible to have fair competition between the private sector and government entities, because the government entity will always have an unfair advantage.
  • Further, we do not agree that government should be pushing to put OS at the heart of the value chain, or at the heart of growth in the GI sector. We are supportive of a policy that places government-created or public sector GI data (and wide, straightforward availability of that data) at the heart of growth in the UK GI sector. We do not believe government should attempt to distort the market by favouring one provider over others.
  • Whatever the outcome of the Consultation, there must be flexibility in the way policy evolves so there is not upheaval every few years over discussions on OS’s future; we all need certainty so we can plan for the future.

Again, if you have views on Ordnance Survey, please do ensure that you put in your own submission before the deadline of 17 March. Locus will contribute another blog here once the government publishes its plans for OS, which should be prior to the upcoming election in May.

Geovation Awards Day

Audrey Mandela

1 February 2010

Number of Comments: 0

GeoVation is an Ordnance Survey (OS) initiative that’s funded and managed by OS with input from “external champions”. According to the GeoVation website (www.geovation.org), while GeoVation is founded and currently financially supported by OS, its mission is to: “’encourage and support innovation for social, economic and environmental benefit through the use of all geography’; not just the products and services of Ordnance Survey.” Apparently this decision was the subject of quite a lot of discussion in the OS boardroom. My view is that GeoVation is a more credible initiative if it is not exclusive to OS, so they made the right decision.

GeoVation’s aims are to:

  1. promote the use of geography in innovation
  2. make innovating with geography easier
  3. provide support to new innovations that use geography by connecting people with geographic expertise to those who require it in realizing their objectives.

Membership is open to all. There is a small management committee organizing GeoVation’s activities right now.

In early October GeoVation announced “the GeoVation Awards Programme (GAP)”: a competition to develop new ideas that use geography. Entries opened on the 6th of October 2009 and closed on 4 January 2010. The judges were looking for ideas that demonstrated their innovative potential, sustainability and how they use geography.

The Awards were supported by OS, Ideas in Transit, ESRI, and the Technology Strategy Board, and attracted 150 ideas for 60 ventures. The judges created a short list of 9 finalists, who were all asked to present to and answer questions from the judges and attendees at Tuesday’s event, for the opportunity to win one of four cash prizes, with the money to be used to develop the winning ideas.

Full descriptions of the short-listed projects can be found on the GeoVation blog, here, http://www.geovation.org.uk/blog/. They were:

  1. Mapland England & Wales: a massive (13m x 11m) walk-on map of England and Wales with full topographical detail.
  2. Online Route cards for hill walkers: A site to provide walkers with tools to help plan appropriate routes, and the ability to have automatic messages sent to a designated emergency contact if the walker doesn’t arrive on time.
  3. Mission: Explore London: a project to engage young people with geography through playful and thought-provoking missions.
  4. Mapping Britain on Horseback: a British Horse Society initiative that aims to collate all equestrian routes in the UK.
  5. Goodfindr iPhone App: using geography to source soft commodities in season.
  6. London Blue Plaque: a search facility showcasing the hundreds of Blue Plaques erected over the years to commemorate famous people and places that have helped shape London and the world.
  7. MaxiMap: a large-format educational floor map.
  8. The Open Climate Data Repository: a service to provide a set of web-based tools to allow the public to view, analyze and feed back on climate data.
  9. Open.HistoryMap: A project to map historic features, events and maps against a background of today’s maps or aerial imagery.

The entries ranged from existing, profitable businesses to ideas and vague plans for the creation of sustainable services.

The original plan had been to award four cash prizes: one for £10,000, two for £5,000, and the community choice award, voted by the audience, of £1,000. In the end, the judges decided to split the money differently, awarding £3,000 to London Blue Plague; £7,000 to Mission:Explore; and £10,000 to MaxiMap. MaxiMap also won the community prize.

I was pleased to see MaxiMap take home first prize: it’s run by two women, one of whom was a schoolteacher, who have created a simple and easy-to-use tool to help overcome some of the challenges of teaching children geography. Their presentation was clear and concise, their financials were sound, and they’ve already tested their idea and achieved some success. Well done, MaxiMap! And of course all of the other finalists.

The GeoVation champions also deserve congratulations, not only for creating an interesting event and encouraging innovation: for every person who attended the awards showcase (which was free), GeoVation donated £10 to MapAction. The day raised £750 for MapAction (www.mapaction.org), and chair Steven Feldman encouraged all of us to go home and match that contribution, to help the charity do more on its upcoming trip to Haiti. If you’re not familiar with MapAction, I’d encourage you to take a look at their site, and also consider a donation.

GeoVation plans to put on these awards next year, with the expectation that they will be more independent from OS. It will also be interesting to see where all of the finalists are with their businesses and projects in a year. If you’re interested in GeoVation, or the awards, check out the GeoVation site for information on the finalists’ progress, and upcoming events.

PSI - The Next Ten Years

Audrey Mandela

28 January 2010

Number of Comments: 0

We assembled an excellent panel to discuss Labour and Conservative PSI policies and Locus’s perspective on issues surrounding PSI licensing, pricing and regulation. We also left plenty of time for attendees to ask questions, and raise their own issues for discussion.

Our panelists were:

Francis Maude MP, Conservative Shadow Cabinet Office Minister and Shadow Chancellor of the Duchy of Lancaster. The Minister leads the Party’s Implementation Unit, which is tasked with determining how policies will be implemented should the Conservatives win the General Election;

Professor Nigel Shadbolt, Professor of Artificial Intelligence (AI) and Deputy head (Research) of the School of Electronics and Computer Sciences at the University of Southampton, and the Prime Minister’s Information Advisor; and

Sir Bryan Carsberg, Locus President, and former Director General of the Oftel and the Office of Fair Trading.

I chaired the event.

The presentations were thought-provoking and there was plenty of stimulating discussion. Here are some of the highlights:

Nigel Shadbolt spoke first, going through some of the key elements of the manifesto for government data that he and Tim Berners-Lee have published, (and which I referenced in my last blog; you can find it here: http://www.guardian.co.uk/news/datablog/2010/jan/21/timbernerslee-government-data), and talking about the new data.gov.uk website. Some interesting points:

  • “We’re now moving from a web of documents to a web of data”.
  • Most of the government PSI that has gone onto the website is in spreadsheet format.
  • On release day, the data.gov.uk website had 700,000 hits; the web servers had to be replaced three times to keep up with demand. Within the first 40 minutes of the site going online, users had created three new web applications using government data. The site is currently in Beta: it’s not “complete” and it’s hoped it never will be.
  • The site is all open source, done quickly and at low cost. It uses the same platform as Wikipedia.
  • In creating the data.gov.uk site Professor Shadbolt and Tim Berners-Lee had to grapple with the issue of what data should be free. Their view is that if creation of the data has been paid for by the taxpayer, then the public should have it. Further, if information is available through a Freedom of Information (FoI) request, why should it not be published as an RSS feed?
  • When it comes to determining what data should be made public, the question should be not why, but why not.

Next up was Francis Maude, who opened by stating that “there is a decent chance of continuity” — that the Conservatives would very likely continue the great work that’s been done to release government data already. Other points made:

  • The Conservatives recognize that having open data is uncomfortable for government ministers. “Transparency is not always agreeable.”
  • We need public money to be spent better. Government spends £4 for every £3 it generates in revenue. That has to change. “We see transparency as a friend of that process.”
  • We need to enlist the public to crowd-source consultancy, to be “armchair auditors” to scrutinize government spending.
  • It’s understandable how we got to the current situation. OS and the Met Office are required to cover their costs; they then felt empowered to create added value and have squeezed out the private sector. This is not for the benefit of the economy as a whole. There’s in-built conflict in this arrangement.
  • If we have the data, we should just put it out there. The Conservatives would release information on the salaries of the 35,000 most senior government employees and all contracts over £25,000 in value; provide an XML feed of council decisions; and publish the COINS database (this is the Combined Online Information System. It contains the Treasury's detailed analysis of departmental spending under thousands of category headings). Some of this will be uncomfortable.
  • We need to balance getting the data out there with making everything just right; we would be inclined to trade off some quality in the interests of making data available more quickly.
  • We propose to carry forward the work Nigel and Tim have done.

Our final speaker was Sir Bryan Carsberg, Locus’s President, and formerly the Director General of Oftel (Ofcom’s predecessor) and the Office of Fair Trading.

Sir Bryan opened with “Carsberg’s principles of regulation”: The best form of regulation is the promotion of competition. Monopolists often have an interest in postponing uses of new technology. Liberalization has been a tremendous boon in the telecom sector; there would be enormous benefits if we can open up use of information. Other points included:

  • Pricing: Locus has always been cautious on price. It’s a no brainer that data financed by tax-payers should be released free; In other cases, we believe data should be provided at marginal cost.
  • Locus is mainly seeking fair competition, whether or not the information is free.
  • Information should be made available in an easy way: in telecom, we had the CLASS license. That provided ready access to the base infrastructure and the constraint that providers compete fairly. All players had access to the raw materials on the same terms, at the same price, with no-cross-subsidization by the incumbent.
  • You could argue that many of the Trading Funds shouldn’t provide value-added services at all.
  • No matter what the outcome of the OS consultation, “This will not work without regulation.”
  • We can understand the reluctance to set up a regulator: it could be costly. Right now, though, we have OPSI, but it doesn’t have the power. So we’re incurring the cost and not getting the benefit.
  • It needn’t be enormously expensive to regulate this sector. If there are big penalties for breaking the rules, that can be very effective.

The panel discussion was followed by a very lively question and answer session.

I asked to panel to comment on Sir Bryan’s assertion that we must have regulation if current PSI holders are to continue to act commercially. Nigel Shadbolt’s response was that quite a lot of time had been spent on the management of data to be released, the technology, and getting it all out under a Creative Commons license; how to regulate is still to be determined.

Francis Maude said he was reluctant to set up a range of new bodies: He feels that the OFT is good at this. But, “we’re open-minded.”

One participant said it would be “terrible if the whole environment changed on the first of April.” We’ve had years of consultation, but we do need to be able to prepare for whatever changes are brought in. We also need a set of principles that we can be sure will survive changes of government .

Other topics of discussion included:

The consultation on the future of Ordnance Survey: A key point: How much Ordnance Survey data should be made available for free, and the potential negative impact on existing commercial providers if, for example, OS maps, rather than raw data, are made freely available. Nigel Shadbolt responded that he and Tim Berners-Lee couldn’t avoid the issue of location and place when looking to open up government data. He felt the OS consultation didn’t need to be “as complex as it is.” He also finds it “odd to pay for information that you need to live your life.” There was general agreement in the room that raw data, such as boundaries, should be released. There is an argument that detailed mapping should not be released for free, but that all players, including OS, should have access to the raw data to create those maps, and should compete on the same terms to provide them.

Nigel said, :”Tim and I were told not to deal with OS. But we knew we had to. We will have to grasp the nettle…. We must decide what are the ‘totemic datasets’”.

How to find the right cost model to make data available for free: Francis Maude expressed relief that those of us who spend time of this issue also find it complex. Sir Bryan referenced the Cambridge Study, and noted that the cost of making basic data sets available is actually small. Some participants, though, disagree with the findings of the Cambridge Study, which assumes price elasticity of demand: it was noted that while there has been a 30% real price fall in MasterMap over the last few years, there has been no increase in use.

This led to a discussion of the whether or not Ramsey pricing (pricing according to the elasticity of demand of different customer groups through price discrimination) is appropriate where data is charged for. Sir Bryan noted that the OFT study concluded that the market could be greatly expanded if data was made available at marginal cost. He could see how Ramsey pricing could distort the market. Others considered it a mixed blessing for the mapping sector. Nigel Shadbolt suggested more work was required from economists.

Postcodes: There was a fair amount of discussion surrounding access to the postcode database. One participant said, “There will be trouble if we don’t release postcodes soon: OS and the Royal Mail have crucial pieces of data. Have we got a plan for dealing with postcodes and addresses?” The Ordnance Survey consultation document is vague on this issue. Nigel Shadbolt suggested that we should determine what the developer community would find most useful. However, if government doesn’t find a way to release postcodes, it’s likely the community will crowd-source them. Other participants made the point that there is a cost of maintaining the postcode address file, and that must be covered somehow.

Our Locus event highlighted the considerable progress that is being made in PSI policy in this country, but also emphasized that there is a long way to go in the next decade to unlock the full potential of the UK PSI marketplace. In particular, government must “grasp the nettle” of freeing up access to the postcode database and Ordnance Survey raw data so all can benefit fully from the PSI that has already been released.

UK Government releases data through new website

Audrey Mandela

25 January 2010

Number of Comments: 0

According to the press release, “All of the data is non-personal and in a format that can be reused by any individual or business to create innovative new software tools, such as applications about house prices, local amenities and services, or access to local hospitals.”

Read the full press release, including quotes from Stephen Timms MP, Sir Tim Berners Lee and Professor Nigel Shadbolt, who will be speaking at the Locus event this evening.

And of course the website is here: http://www.data.gov.uk/

Data sets include information on crime, health, education, property prices, travel, the environment, agriculture, etc. It’s time-consuming, but fascinating, to browse through the list to see types of data that are being collected, and are now available for use. The plan is for the site to continue to add data from government departments each month.

In conjunction with the launch of data.gov.uk, the UK’s Office of Public Sector Information (OPSI), part of the National Archives, has drafted a new set of terms and conditions for the site that are “interoperable with any Creative Commons Attribution 3.0 Licence.” The new model will replace the existing Click-Use Licence; OPSI expects to launch the new terms in May 2010.

The Guardian has an interesting article on how data.gov.uk came to be; Professor Shadbolt and Sir Tim Berners-Lee’s manifesto for government data; and an interview with both on the announcement and thinking behind the release of the data. These can be found here:

http://www.guardian.co.uk/technology/2010/jan/21/how-official-data-freed

http://www.guardian.co.uk/news/datablog/2010/jan/21/timbernerslee-government-data

http://www.guardian.co.uk/politics/video/2010/jan/21/uk-national-data-website-launched

And if you’ve never seen Tim Berners-Lee’s TED talk on the subject of public data provision, where he asks the audience to join him in calling, loudly, for “Raw Data Now!”, it can be found here:

http://www.ted.com/talks/tim_berners_lee_on_the_next_web.html

Locus is very pleased by the announcement of the data.gov.uk website, and the release of so many government datasets. Of course, we, like many other parties, still believe that for this data to fulfill its potential, government must also find a way to make Ordnance Survey map data (raw data, in particular) and the postcode database available, without barriers. The data.gov.uk site is, however, a very good first step.

London’s Mayor announces “London Data Store”

Audrey Mandela

15 January 2010

Number of Comments: 0

The initiative is part of a campaign to boost the transparency and accountability of City Hall, and will be formally launched at the end of January 2010. Plans are for the Datastore to contain over 200 different sets of information, such as crime rates, abandoned vehicles, schools data, hospital waiting lists and recycling rates. Here’s a link to the Datastore website: http://data.london.gov.uk/; more information can also e obtained by emailing datastore@london.gov.uk.

In a statement, Johnson said, “"I firmly believe that access to information should not just be the preserve of institutions and a limited elite. Data belongs to the people - particularly that held by the public sector - and getting hold of it should not involve a complex routine of jumping through a series of ever decreasing hoops.”

According to the Datastore site, the policy will be “to only withhold data where to release it would infringe privacy legislation or a contractual obligation eg commercial confidentiality.” The license conditions under which data can be used will vary for each data package; however, the site says that “in general the data held in this site can be used for most purposes, provided the Terms and Conditions of this site are not infringed.” The data comes in several different formats; each data package has its own licensing terms.

Locus is very pleased to see this initative coming to fruition, and we’re looking forward to seeing the rest of the datasets that are to be released at the end of the month. We believe that enhancing access to Public Sector Information (PSI) for re-use brings economic benefits as well as improving services to citizens. This move by the Mayor of London sets an excellent example which we hope to see repeated across Government in the coming weeks.

Locus planning key industry event: “PSI – The Next Ten Years"

Audrey Mandela

11 January 2010

Number of Comments: 0

Locus, as some of you will know, was established to encourage the public sector (primarily in the UK) to maintain a trading environment that is fair and equitable, in particular in relation to the licensing and re-use of public sector information. Our members are private sector companies that are committed to working with PSI holders to maintain and develop a vibrant, information-driven UK economy that ultimately works to the benefit of the public sector, private sector and end consumer.

Locus acts as a forum for exchange of information, keeps its members up to date with latest policy developments, and provides advice and guidance. Each year we hold several events that are open to non-members, to raise the level of discussion on a particular topic. In January, we’re hosting what we expect to be a landmark PSI event examining the future of the UK PSI marketplace in light of the upcoming General Election. Right now the Labour Government is pushing forward a number of plans to give away data, and to change the structure of Ordnance Survey. However, if we have a change of Government in May (or before), that would very likely all change, making it difficult for those of us who work with PSI to know what the future will hold.

We’ve therefore put together a top-notch panel to discuss Government and Conservative PSI policy. Our speakers are:

  • Francis Maude MP, Conservative Shadow Cabinet Office Minister;
  • Professor Nigel Shadbolt, the Prime Minister’s Information Advisor, and
  • Sir Bryan Carsberg, Locus President, and former Director General of the OFT and Oftel.

I’ll be chairing the event.

We believe this timely and exciting event will be an excellent opportunity to hear about Government and Conservative PSI policy ahead of the next General Election, and to provide policy-makers with input at a key time for PSI in the UK.

The event will be held on Monday 25th January, 5.30-7.00pm, at Olswang LLP, 90 High Holborn, London, WC1V 6XX. For further information, or to register for the event, please contact Harriet Crosthwaite, of Luther Pendragon on

Tel : +44 20 7618 9136

or email: harrietcrosthwaite@luther.co.uk

This promises to be a very busy month for PSI in the UK; over the next few weeks I’ll provide blog posts with Locus’s views on the Communities and Local Government Consultation on Ordnance Survey; the London Datastore (announced today); derived data, and other topics as they come along.

Locus thanks the ePSIplatform for the opportunity to contribute our views to the PSI debate.