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                               INSPIRE Draft Implementing Rules for the Discovery and View Network Services: Comments Sheet
  1         2           3             4                                           5                                                                      6
Comm     Chapter, Paragraph/Fi of comment
                           Type                                Comment (justification for change)                                               Proposed change
ent ID
          section  gure/Table
         or clause
         no./Subcl
         ause No./


         Note [1]    Note[2]       Note[3]                                                                                                            Note[4]

  1      Table of    1 to 5          G       current strucuture takes focus from essential Ch 7 and 8                       if 1 to 5 cannot be combined into Introduction, maybe omit
         contents                                                                                                           subchapters for indicidual terms under "Definitions"

  2                                  G       A description and definition of all types of services referred to in Article   Definitions should be made for all services referred to in
                                             11(1) of the directive is necessary before details of the implementation of    Article 11(1), specifying the technical andlegal features
                                             single services are specified. In particular clear differentiation between     (access, use, costs for the user) briefly. Differentiation
                                             view services, download services and services to invoke services are           between view services, download services, services to
                                             necessary for technical reasons but as well for legal reasons. The             invoke services and applications. - Define requirements,
                                             definitions are essential for data and service providers, who are obliged to   standards for implementation and only prescribe the
                                             apply charges for using their data/services, to offer personal data or data    implementation for the services for which there is a
                                             of protective-worthy goods (art. 13 of the INSPIRE directive). Referring to    defined standard.
                                             the INSPIRE architecture a differentiation between the INSPIRE-services
                                             and applications is also necessary .

  3                                  G       The paper prescribes international standards for the implementation.           Define requirements, standards for implementation and
                                             Actually for most requirements of the directive (e.g., GeoDRM) no              only prescribe the implementation for the services for
                                             adopted or realized standards exist at the moment. This fact obstructs a       which there is a defined standard.
                                             uniform implementation of the requirements of directive.
  4                                  G       In the paper contained standards (for example, WMS 1.3.0) will be              In the IR the general default and the technical default
                                             developed. A specified naming in the IR is not proper.                         should be separated or suggest a WMS-version as
                                                                                                                            minimum requirement (e.g. WMS 1.1.0)
  5                                  G       From our point of view the INSPIRE-IR should continue to rely on OGC-          No Change.
                                             standards, because we and many offices use open-source software
                                             (OSS), which is in line with these standards. Our concern is especially
                                             towards the plan of making SOAP the only standard for messaging until it
                                             is sufficiently supported by OGC-based OSS.
6                        T   The use of words like "can", "could", etc. is unclear in general.          Clarify and review usage of language expressing
                             Paragraphs 8.2.3.2 and 8.3.2 are just examples. Probably "could" should requirements, recommendations or options throughout the
                             be replaced by "might" and "can" by "may", but this is not entirely clear. document.

7    1                   G   Too much information in one document.                                     Split text into one document for "Discovery Network
                                                                                                       Services" and another document for "View Network
                                                                                                       Services".
8    1   1st paragraph   E   Adding date the directive entered into force.                             Change to: "The INSPIRE Directive proposed by the
                                                                                                       European Commission in July 2004 entered into force on
                                                                                                       May 15th 2007. It defines …"
9    1   2nd paragraph   G   Wrong statement: "INSPIRE builds on the infrastructures for spatial       Change to text from Recital 5: "Inspire should be based
                             information that have already been created by the                         on the infrastructures for spatial information that are
                             Member States."                                                           created by the Member States [and that are made
                                                                                                       compatible with common implementing rules and are
                                                                                                       supplemented with measures at Community level]."
10   1   4th paragraph   G   Wrong statement: " … and Member States have two years from the date       Use text from Article 24: "Member States shall bring into
                             of adoption to bring into force … "                                       force the laws, regulations and administrative provisions
                                                                                                       necessary to comply with [the] Directive by 15 May 2009."

11   1   4th paragraph   E   Outdated: "The committee will be established within three months …"       Change to: "The committee has been established within
                                                                                                       three months …" (or give exact date)
12   1   5th paragraph   E   Outdated: "The Member States have 2 years (2007–08) …"                    Change to: "The Member States have 2 years (May 2007
                                                                                                       – May 2009) …"
13   2   1st paragraph   E   The first sentences under the heading "Purpose of this document"          Move first sentences of chapter 2 to chapter 3.
                             describe the scope of the document.
14   2   2nd paragraph   E   Wrong statement: "Five services are required by the INSPIRE Directive." Change to: "Five types of services are required by the
                                                                                                     INSPIRE Directive."
15   2   4th paragraph   E   Text: "This priority is also depends on the availability …"             Change to: "This priority is also in consequence of the
                                                                                                     availability …"
16   3   1st paragraph   E   The first sentence under the heading "Scope of this document" describes Move first sentence of chapter 3 to chapter 2.
                             the purpose of the document.
17   3   3rd paragraph   G   Too many full text quotations from Directive.                           Make technical statements and give references to the
             et sqq.                                                                                 Directive passages where needed.
18   3     2nd to last   T   The text implies that access control is related to e-commerce services. Separate security aspects from e-commerce.
           paragraph,        This is mixing concepts.
             item 1
19   4                   T   The list of references seems to include all cited documents, whether or   Revise list of references to those that are not normatively
                             not they are cited in a normative way and which makes them                referenced. This includes at least OCG 05-025r2, 06-
                             indispensable.                                                            079r2, 06-129, 06-180, ISO/TS 15000-3:2004, ISO
                                                                                                       Directives, but probably others, too. Consider moving
                                                                                                       these documents to the bibiography.
20     4                      T   Some references are conflicting as different versions of the same               Reference a single version for each document only.
                                  document are referenced. This includes the draft IR on metadata and
                                  WMS 1.3 (ISO and OGC).
21     4                      T   Reference to ISO/TS 19139 uses the incorrect year                               ISO/TS 19139:2007
22   5.1.1                    T   This does not seem to be a general definition of "availability"                 Revise definition
23   5.1.4                    T   The INSPIRE Directive uses a different definition (although it is for spatial   Replace by definition from INSPIRE Glossary
                                  data set; however, only such data sets are within the scope of INSPIRE)

24   5.1.6                    T   These definitions seem to conflict with the use of the term. This seems to Revise definition
                                  be more related to the phases "evaluation" and "use" than discovery.

25   5.1.7                    T   These definitions seem to conflict with the use of the term. This seems to Revise definition
                                  be more related to the phases "evaluation" and "use" than discovery.

26   5.1.8                    T   This is not a proper definition. In addition, it conflicts with the terminology Replace by definition from the INSPIRE glossary
                                  used in the INSPIRE Directive which uses spatial object instead of
                                  feature.
27   5.1.11    sentence 2     T   This is not a proper definition. In addition, it is unclear in which way they Change into a NOTE and clarify meaning.
                                  are supposed to be unique. For example, metadata elements may be
                                  shared between metadata entities or some metadata elements may occur
                                  multiple times in a metadata entity (e.g. keywords).

28   5.1.23                   E   Question: Is it possible to write GETCAPABILITIES, etc. in upper case           Check typography.
                                  when addressing a web service?
29   5.1.23                   T   This is not a definition for a service request. A service request is the        Revise definition
                                  *invocation of* an operation of a service, not the operation itself.
30     6                      G   The roles of documents D3.5 and D3.7 respectively should be defined             Suggestion: All requirements for Discovery & View
                                  more clearly. Mutual cross references should be avoided.                        services are to be stated in their entirety within D3.7.
                                                                                                                  Document D3.5 then may give an architecture view,
                                  D3.5 should not be used as reference for requirements.                          making reference to D3.7, not vice versa.
31     6                      G   Clarification needed.                                                           Please state more clearly, which requirements are
                                                                                                                  mandatory or optional and which text is informative only.

32     6                      T   The role of WSDL is not clear.                                                  Please clarify.
33     6.                     G   The development of the SOAP geoservice take second place behind the             Define SOAP as optional and fall back on the OGC
                                  developments of the OGC services. The OGC web service are                       standard as obliging.
                                  established as standard in the GI world today. The present level of
                                  development of SOAP is unsuitably for implementing.
34     6      1st paragraph   G   Wrong text: "The architecture also describes the “horizontal services”, not     Change to: "The architecture also describes the
                                  mandated by the Directive …"                                                    “horizontal services”, as mandated in Article 14 (4) of
                                                                                                                  the Directive …"
35   6                     G   GeoDRM is spedified as the third point. Thus it appears that the
                               horizontal services should be implemented by the OGC GeoDRM
                               frameworks. Since March 2007 there is an abstract specification. This
                               says nothing about the implementation. Therefore, this point should be
                               explained.
36   6       Protocol      T   This chapter is referenced to the document D3.5. It is pointed out that the      Only trusted standards should be required, not those
             Bindings          use of SOAP bindings for all INSPIRE Network Services is required.               whose practical suitability is under examination.
                               However, there is still no SOAP Binding for most OGC services.
                               According to the document D3.5, it must first carry out a study in order to
                               review the practicability of SOAP bindings (page 10, last paragraph in
                               D3.5).
37   6     paragraph 1     E   The INSPIRE architecture is specified by more than the two documents,            Clarify
                               essentially all IRs and referenced documents describe aspects of the
                               architecture, too. Furthermore, the list contains three bullet items, not two,
                               which is confusing.
38   6     paragraph 3     T   This paragraph contradicts the rest of the document. If the W3C                  Drop claim to support the W3C architecture and remove
                               architecture is adopted, then both the View and the Discovery Service do         paragraph (or change IR on View services and IR on
                               not fulfil the requirements as they are not described in WSDL (see               Discovery services to conform to this statement).
                               clauses 7 and 8) and service descriptions are mainly provided as specific
                               responses to a GetCapabilities operation which is to some extent
                               overlapping with WSDL descriptions. In addition, the draft IR on metadata
                               uses a different way to describe services that is not consistent but largely
                               overlapping with WSDL descriptions.
39   6     3rd paragraph   G   The quoted documents (D3.5, D3.7 and INSPIRE Technical architecture              Align content of quoted documents.
                               Overview) contradict each other in several places, e.g. with respect of
                               using WSDL.
40   6     paragraph 4     T    The usage of SOAP ist not specified in all OGC Web Services commonly    Usage of the established OGC Services with the protocols
                                                        used within the national SDI.                         specified in this commonly used standards (like
                                                                                                                       HTTP/GET within WMS 1.1.1).
41   6     paragraph 4     T   SOAP binding is stated as mandatory, yet the View service does not even Remove paragraph (or provide binding)
                               support this binding.
42   7.1                   G   Too many full text quotations from Directive.                            Make technical statements and give references to the
                                                                                                        Directive text, where needed.
43   7.2                   E   Too much information in one document.                                    Suggestion:Make one document for Discovery Network
                                                                                                        Services and one document for View Network services.
44   7.2   paragraph 3     T   The selection of the geo-specific catalogue services for discovery seems Remove requirement to support e-Government
                               to contradict the intended support for e-Government frameworks. This is frameworks or - if it is a requirement - change 7.4 to
                               in particular relevant for the discovery service.                        instead adopt general IT discovery standards like UDDI or
                                                                                                        ebXML Registry which are typically adopted in e-
                                                                                                        Government frameworks (specify spatial extensions if and
                                                                                                        where required).
45    7.2      paragraph 4     G       It is not clear how a service with multiple layers is referenced in the                            Clarify
                                                                      metadata.
46    7.3                      E   Amount of background information in 7.3                                     Suggestion: Put this material into an annex.
47   7.3.2     Harvest use     T   Harvesting should not be limited to a file system or other catalogues only Replace "file system" by "resources accesible on the
                  case                                                                                         internet" or similar
48   7.3.3.1                   G   Point 1 describes, that the level of standardization on Discovery Services A sufficient standardization doesn't exist. That's why there
                                   reached a sufficient level. It pointed to the OGC CSW. But it is only an    is no interoperability. We not support the term "ISO
                                   abstract specification, with few definitions about the data exchange. The 19115/19119 is well implemented" (Page 21).
                                   OGC CSW should not take as an example for a mature specification. The
                                   existing implementations are based on various versions (2.0.1/2.0.2).
                                   The reported Catalogue services are based on different exchange
                                   formats. Regarding to the CSW interfaces were cut during the last 3 years
                                   in the semantics and in the format (ISO19139) extensive changes.


49   7.3.3.2                   G   Point 1 describes, that the level of standardization on Discovery Services A sufficient standardization doesn't exist. That's why there
                                   reached a sufficient level. It pointed to the OGC CSW. But it is only an   is no interoperability. We not support the term "ISO
                                   abstract specification, with few definitions about the data exchange. The 19115/19119 is well implemented" (Page 21).
                                   OGC CSW should not take as an example for a mature specification. The
                                   existing implementations are based on various versions (2.0.1/2.0.2).
                                   The reported Catalogue services are based on different exchange
                                   formats. Regarding to the CSW interfaces were cut during the last 3 years
                                   in the semantics and in the format (ISO19139) extensive changes.


50   7.3.3.2                   E   Reference to unproductive reference material is more relieving for the      Omit it.
                                   author than helpful for the reader.
51   7.3.3.2                   E   Big footnotes.                                                           Put footnotes into text if really needed. Consider putting
                                                                                                            7.3.3.2 into an annex - and quote only essentials in the
                                                                                                            text.
52   7.3.3.2     Figure 3      E   Double graphics.                                                         Omit one.
53   7.3.3.2     Figure 3      T   Usage of ISO 19115 is split.                                             Give figures of total share (sum) for overall usage of ISO
                                                                                                            19115.
54   7.3.3.2      Fig. 3       G    44% voids: is it known what is behind that? Could there be problems for       Do deviating standards in general read into OGC
                                                               some member states?                                                     standard?
55   7.3.3.2   4th paragraph   E   Giving percentages in text hampers readability.                          Use a table.
56   7.3.3.2    paragraph 4    E   The entry: ISO 19139-DEProfile is not correct. The correct wording is DE change wording and category
                                   Profil 1.0.1, which is not an other standard" but fully compliant to ISO
                                   Application profile 0.9.3
57   7.3.4                   T   No clear distinction between "Harvesting" and different kinds of               Give a logical connection of "Distributed search" and
                                 "Distributed Catalogue" concepts. Distributed search and harvesting are a      "Harvesting" to the "primary use case" of 'discover'.
                                 kind of "secondary use cases", that are invisible for the human user in        Classify these technical solutions as a means to speed up
                                 most cases.                                                                    metadata search.
                                 NOTE: Distributed search and harvesting are not covered by the INSPIRE         Make a clear difference between:
                                 Directive.                                                                     1) Harvesting (it may be using distributed catalogues, too)
                                                                                                                and
                                                                                                                2) Distributed online search.
58   7.3.4    Distributed    T   The role of the registry service in this context has not been understood. It Clarify and align with technical architecture overview
                search           obviously is different from the registry service in the technical architecture
                                 overview, but the details are unclear.
59   7.3.5                   G   Point 1 describes, that the level of standardization on Discovery Services A sufficient standardization doesn't exist. That's why there
                                 reached a sufficient level. It pointed to the OGC CSW. But it is only an       is no interoperability. We not support the term "ISO
                                 abstract specification, with few definitions about the data exchange. The 19115/19119 is well implemented" (Page 21).
                                 OGC CSW should not take as an example for a mature specification. The
                                 existing implementations are based on various versions (2.0.1/2.0.2).
                                 The reported Catalogue services are based on different exchange
                                 formats. Regarding to the CSW interfaces were cut during the last 3 years
                                 in the semantics and in the format (ISO19139) extensive changes.


60    7.4         title      E   Typo: "rules"                                                                Change to: "Rules".
61   7.4.1   2nd paragraph   G   Basically: conformitiy to OGC CSW ISO 19115/19119 is the basic
                                 component. Could the main implementing rules be summarized in the
                                 beginning, so that when all reports become available, the main
                                 requirements can be more easily be extracted?
62   7.4.1                   T   Are the requirements of INSPIRE Article 11 (2) (with respect to              To be checked, if there is a reference to Article 11 (2).
                                 combination of search
                                 criteria) mentioned?
63   7.4.1                   G   The title of this paragraph is "Core requirements …".                        Clarify, what the requirements are - and state solutions
                                 ISO 19115 is a solution, but no requirement.                                 separately.
64   7.4.1   3rd paragraph   E   Typo: "IS0 19119 standards"                                                  write ISO instead of IS0
65   7.4.1    paragraph 2    T   The version of CSW ISO AP is missing                                         add version no.
66   7.4.2        Table 3       T   There is no need for every service to harvest metadata from other           Change operation requirements for CSWT
                                    services or allow transactions. These features are only relevant for single Manager.Harvest and CSWT Manager.Transaction to
                                    central services, for example on the national level, which are designed to Optional
                                    harvest metadata from smaller local services. Local services on the other
                                    hand don't need harvesting mechanism. A mandatory requirement of
                                    these features would raise the cost seriously for local services.

                                    INSPIRE should not make requirements to the internal SDI
                                    implementation of a MS which is not part of a communication between
                                    INSPIRE on EC level and MS level.
                                    As it is behind the interfaces between INSPIRE on EC level and MS level,
                                    the harvesting operation on MS level should be out of scope of this
                                    document.
                                    At least it should not be a mandatory requirement.


67   7.4.2       paragraph      T   The transaction operation is not mentioned in any description of the        Delete the transaction operation at this position and keep
               below table 3,       manage use case, neither in 7.3.2 nor in Annex A 1.6 - it has no            this fact in mind regarding the demand of a mandatory
               last sentence        relevance for this use case!                                                transaction operation for INSPIRE discovery services (see
                                                                                                                comment 2).
68   7.4.2                      G   The demand of defining quality criterions and the demand to publish         Only the quality criterions should be prescribed and the
                                    these is supported, indeed, the default of values is not proper. (e.g.      obligation to publish the associated values.
                                    reponse time of WMS 3 seconds)
69   7.4.3                      G   The terms "Availability", "Capacity", "Reliability", "Security", "Regulatory" Omit: "… as part of the INSPIRE directive"
                                    are not mentioned explicitly within the INSPIRE Directive as Performance
                                    criteria. Consequently, the following text is not applicable:
                                    "The following three criteria shall be monitored and reported as part of the
                                    INSPIRE directive:"

70   7.4.3                      E   "Regulatory" is an adjective, that makes no sense standing alone. A noun    Add an appropriate noun.
                                    is missing.
71   7.4.3                      T   Remark: Performance requirements for the combination of search criteria     Please check.
                                    (in Article 11 (2)) are not mentioned. On purpose?
72   7.4.3.1                    T   The requirements seem to be high. Especially smaller institutions do not    Increase response time and lower the requirement of
                                    have high-performance webservers.                                           nominal performance with 100 simultaneous service
                                                                                                                requests. The latter is quite tremendeous.
73   7.4.3.1                    E   As "Performance" is the overall term in the title of 7.4.3 it should not    Change term "Performance" to: "Response time".
                                    reappear as a performance criteria denomination.
74   7.4.3.1   Paragraph 1   T   According to “8.3.6.1 Performance” a “response time” of 3 seconds has         It follows that the standards given are too inexact to reach
                                 to be reached for a picture of 1024 * 768 picture points at GIF- or PNG       a real performance. Therefore the exact depth of colour,
                                 format. It is certainly true to speak of “initial response to service         picture size and the technological marginal conditions
                                 request”but I seems to be only efficient if the picture is sended             have to be defined more exactly. Additionally it has to be
                                 completely.Let us assume a PNG format for the digital orthophotos, so         defined how to measure the initial response time and the
                                 the picture has a size of 2.178.248 Bytes or 17.425.984 Bit. To send this     time up to the complete data delivery. To call for a
                                 within 3 seconds you need a band width of 5.8 Mbit/s ( with Header it         minimum response time is efficient only when all marginal
                                 means ca. 6Mbit/s). Because referring to the capacitiy of 100                 conditions as picture size, colour depth, content, minimum
                                 simultaneous requests should have to be served, you have to assume a          band width, simultaneous access etc. are given.
                                 (minimum) band width of 600Mbit/s for the central server to fulfil this
                                 requirements (to send 100 pictures with 1024*768 picture points at PNG
                                 format each about 2 MByte within 3 seconds). Using a JPG format the
                                 figures are definitely lower (with a picture size of 233.235 Byte or
                                 1.865.880 Bit and accordingly of a band width at the Client of 622kBit/s
                                 and at the Server of about 65Mbit/s). The JPG-standards can be
                                 positively reached for Thueringen (Thuringia) too.
75   7.4.3.1                 T   Response time should not contain delays at the requestors network, etc.       Define more clearly, between which points in the network
                                                                                                               the response time shall be taken.
76   7.4.3.1                 T   We doubt that the specified speed can be reached. Depending on the
                                 complexity of the XML data structure and the requests, it will be much
                                 longer response times.
77   7.4.3.2                 T   Availability: Unclear definitions. Is there something like European working   Define more clearly the the reference (100%) and
                                 hours - to be defined across all European time zones?                         Working hours.
78   7.4.3.2   Paragraph 1   T   According to IR1 an availability of 99 % has to be guaranteed                 Obviously in this case a more accurate definition of
                                 corresponding to a “Downtime” of about 3.7 days per year. Additionally a      “downtime” has to be given. It includes a definition of the
                                 maximum “Downtime is required being within the “work time” a day of           maximum failure time “at the whole” and additionally the
                                 maximum 15 minutes a day. It is very difficult to ensure a maximum            availability required in percent.
                                 continuous (?) failure time of 15 minutes during business time because
                                 during this time mostly the fault is realized but not eliminated. The
                                 shortest response time is two hours. To obtain an even more shortened
                                 time of re-establishing some “Failover systems” have to be installed that
                                 could take action in case of system failure.The “failover systems “ have
                                 to refer to the connection of the internet and network components within
                                 the member state.
79   7.4.3.3                   T   Capacity: The auxiliary constraint of Response time (7.3.4.1) must be           Lower requirements considerably, e.g. 5 parallel requests
                                   taken into account. This would result in 100 times 250 Metadata records         and 15 seconds response time for a request yielding 10
                                   (of 400+ ISO 19115 fields; some in several languages) = 25 thousand             metadata records. The response time should be taken at
                                   metadata records within 3 seconds for every metadata service present            the catalogue server side, neutralising client and network
                                   within INSPIRE (some thousand metadata services in Germany alone).              time effects.
                                   All this including distributed search, too. This postulation would result in
                                   high costs in the member states. At this time, such a requirement does
                                   not seem sensible. It may be a matter of research and re-organizing
                                   existing metadata servers, as in the GDI-DE "Geodatacatalogue_DE"
                                   project.
80   7.4.3.3                   T   The requirements seem to be high. Especially smaller institutions do not        Increase response time and lower the requirement of
                                   have high-performance webservers.                                               nominal performance with 100 simultaneous service
                                                                                                                   requests. The latter is quite tremendeous.
81   7.4.3.4                   T   Text logic: "In order to allow comparison between responses …"                   Change to: "In order to allow comparison between
                                                                                                                   responses of different catalogue installations …"
82   7.4.3.4                   T   Text: " … it is also recommended to provide reference metadatasets."            it is also required to provide reference metadatasets
                                                                                                                   within the INSPIRE community.
83   7.4.3.4    paragraph 1    T   "It is recommended ..." - to whom? The requirement is unclear.                  Clarify
84   7.4.3.5    paragraph 1    T   "It is recommended ..." - to whom? The requirement is unclear.                  Clarify
85   7.4.3.6    paragraph 1    T   "It is recommended ..." - to whom? The requirement is unclear.                  Clarify
86    7.4.4                    T   If it is relevant for the IR, this cannot be left blank.                        If it is not relevant for the (first version of the) IR, remove.
                                                                                                                   Otherwise provide contents.
87     8                       E   Too much information in one document. The reader is forced to oscillate         Suggestion: Make one document for Discovery Network
                                   between "Discovery service" and "View service" paragraphs.                      Services and one document for View Network services.

88    8.1      1st paragraph   E   Obsolete reference.                                                             Refer to the official version of the INSPIRE Directive.
89    8.1      8th paragraph   E   Typo: "Vew"                                                                     Change to: "View"
90   8.2.1                     E   Text: "… request over …"                                                        Change to: "request for …"
91   8.2.2        Figure 5     T   Use case "request capabilities" is missing.                                     Add it.
92   8.2.2     2nd paragraph   T   The following is not true in general: "A layer is a well-defined set of         Omit this sentence or give a more general definition,
                                   INSPIRE features portrayed according to portrayal rules.".                      including graphic layers, too.

                                   There may exist map layers in picture formats like jpg, where the
                                   underlying portrayal rules are not published or not present at all, like with
                                   orthoimagery.
93    8.2.2                    E   Sub-heading: "Request info on a feature use case"                               Change to: "Request feature info use case".
94   8.2.3.1    last paragr.   G   replace Metadata Implementing Rules (D3.1)                                      replace Metadata Implementing Rules (D1.3)
95    8.2.3.1                   T   The document refers to the ISO 19119. In relation to the XML file, the
                                    XML schema should specified, in which the other descriptive data to be
                                    collected. The ISO 19119 contains no scheme, but only an abstract view
                                    of the general Geo Webservice. Therefore, a different standard must be
                                    referenced (eg ISO 19139 - with the correct version).
                                    It is also not clear, which metadata comes from the Capabilities and
                                    which must be record in addition externally.

96    8.2.3.1        b)         E               Table 4 is referenced but missing in this document.                                    Insert table 4.
97    8.2.3.2                   G   In order to support environmental policies in Europe, CRSes from all          Widen the requirements on CRSes optionally, even if this
                                    around the world may be required: Environmental issues, like air pollution, is not covered by the Directive.
                                    temperature distribution etc. are not confined to member states' territorial.

98    8.2.3.3    paragraph 1,   T   How are the axes x, y, z defined in any 2D CRS? How are they defined         Avoid using x, y and z as axis labels. The same applies to
                items 2 and 3       with any 3D CRS that uses different axis labels?                             8.3.2.5 and 8.3.2.6, too.
99    8.2.3.3                   T   Not every view service must be able to cover every use case of viewing       Discern between different types of viewing services.

100   8.2.3.3                   G   A temporal data dimension is not common practice in GIS-services             Make it optional
101   8.2.3.4                   T   Not every view service must be able to cover every use case of viewing       Discern between different types of viewing services.

102   8.2.3.5                   T   Not every view service must be able to cover every use case of viewing       Discern between different types of viewing services.

103   8.2.3.6                   T   Not every view service must be able to cover every use case of viewing       Discern between different types of viewing services.

104   8.2.3.6                   G                      …shall be defined for each layer…                          could it be stated when and where it is forseen to devote
                                                                                                                 to this (thematic teams?). Listing such items from each DT
                                                                                                                      could help to specify the terms of contents for the
                                                                                                                                        thematic teams
105   8.2.3.6                   T   If you want to have default rendering styles you need default layers or      Offer an optional styling-set, e.g. like the "ATKIS-
                                    themes. This seems to be difficult to implement across europe with           Signaturenkatalog" used in germany.
                                    hundreds or thousands of publisher-participants, each with his own set of
                                    data and themes.
106   8.2.3.7                   G   For GeoDRM neither standards nor standardised solutions are known,           Describe existing solutions, which fulfil the requirements
                                    which fulfil the requirements on the functionality of view services on the   for GeoDRM in a freely accessible view service (without
                                    one hand and for the protection of the data on the other hand. Because       access constraints, but use constraints). The
                                    GeoDRM is only at the stage of research and development, it cannot be        requirements for GeoDRM could be implemented
                                    prescribed as an obliging standard for the implementation. With reference    temporarily by an application, until a standard is available.
                                    to the demands of the directive such protective services are necessary for
                                    data and service providers, who are obliged to apply charges for using
                                    their data/services, to offer personal data or data of protective-worthy
                                    goods (Article 13 of the INSPIRE directive).
107   8.2.3.7     G   The paper prescribes international standards for the implementation.         Specify requirements, quote available international
                      Actually for most requirements of the directive (e.g., GeoRM) no adopted     standards and realize for the time being only this for which
                      or realized standards exist at the moment. This fact obstructs a uniform     standards are available.
                      implementation of the requirements of directive.
108   8.2.3.8     T   Text: "The legend of the displayed dataset(s) must be provided" is not       Change text: "The legend of the displayed dataset(s) shall
                      valid in every case, e.g. with orthoimagery.                                 be provided where appropriate."
109   8.2.3.9     G   it seems that common keywords are a crucial item, which can be realized      would it be helpful to highlight the relevance of the item, in
                      based on the fulfillment of data specification IR                            particular cross-reference to other IR?
110   8.2.3.9     G   There are only possibilities listed. A concrete solution to the problem is   Concrete suggestions should be nominated.
                      not presented.
111   8.2.3.10    T   Unclear text.                                                                Please state exactly, which elements in the Capabilities
                                                                                                   (and accordingly in the metadata) shall be multilingual.

112   8.2.3.10.   G   The demand for multilingualism is not proper with the view services.      Delete; multilingualism is only proper with the discovery
                                                                                                service
113    8.2.4      G   The definition of view services as a WMS does not fulfil the requirements Standards - if existing - or proven technical solutions are
                      referred to in point (b) of Article 11(1). A WMS is a download service    to be used which provide the demanded functionalities of
                      whose functionality exceeds the pure viewing by allowing the integration view services by Article 11(1)(b) and protect the data of
                      of data into the user’s application. This aspect has in particular        the supplier against further use (download). An example
                      consequences on suppliers who are obliged to charge for the use of their given is the view service www.bayernviewer.de. This
                      data. The requirements on the functionality of a presentation service can application fulfils the requirements for a presentation
                      be realized at the moment only in form of an application.                 service and guarantees at the same time the protection of
                                                                                                the contained geodata. The application can be easily
                                                                                                developed to allow the integration of free data via WMS. It
                                                                                                is suggested to establish such applications at the level of
                                                                                                every member state and the EU. Data supplier can
                                                                                                provide data via protected WMS to the applications.

114    8.2.4      T   SDI Germany does explicitly NOT endorse ISO 19128. There is a                Specify WMS 1.1.1. , at least as an option.
                      great number of WMS 1.1.1 servers already working within SDI
                      Germany (GDI-DE). ISO 19128 does not bring substantial benefits
                      above WMS 1.1.1. Furthermore there is no reference to SLD.
                      Switching to ISO 19128 would be too costly, as most existing
                      WMSes (estimated for German GDI-DE: more than two thousand
                      WMS instances) must then be changed and capabilities for layers
                      etc. reorganised - mostly by hand. A messy conglomerate of WMS
                      1.1.1 and WMS 1.3 would be the result, as not every provider will
                      follow the change path.
115   8.3                   G   The search is the main problem for the description of the services. As      The whole concept should be further reviewed and
                                indicated in the document, the normal search should based on the service adjusted if necessary.
                                records in the catalogues. There can only be found one URL to a
                                Capabilities document. The layers are not visible up to the examination of
                                the Capabilities document. However, a search for layers is possible on
                                the metadatasets (specifying a getRecordByID by the metadataURL is
                                indeed required). Therefore datasets for the layers are required. These
                                contains no additional information and it must specify the reference to the
                                respective Service. For users, this type of search will not purposeful.
                                Especially for Layer groups this approach can effect larger problems.In
                                addition to these things, there are problems with the upgrade of the meta
                                database.
116   8.3.1                 T   More mandatory parameters.                                                  VERSION, FORMAT and UPDATESEQUENCE should be
                                                                                                            mandatory, too.
117   8.3.2                 E   Text: "… the second one is related to the layers this service is able to    Change to: "… the second one is related to the layers the
                                visualize."                                                                 service has at hand to visualize."
118   8.3.2                 T   Comment on "- Restricted access (Access constraints and Fees)": It is       Discern between "access constraints" that may be
                                well known in the community that it is impossible to describe               described with words and keywords, and "fees", which
                                customary fees, that are in normal use in Geobusiness, within a             rather could be a link to a registry entry.
                                Capabilities document.
119   8.3.2                 T   Unclear: The proposed direction within the Implementing Rules of using The direction of using either ISO 19119 or WSDL or
                                either ISO 19119 or WSDL. There are many references to WSDL in the          both should be stated more clearly - also in the
                                documents. What does it mean: "WSDL is not considered now"? When            related architectural documents.
                                will it be considered?

                                Unclear: What does it mean "A mapping between these two descriptions
                                must be done to guarantee
                                consistency"??
120   8.3.2   paragraph 3   T   It is stated that a mapping between the two descriptions must be done. It   Provide mapping.
                                is unclear who's responsibility this is and how the current draft can be
                                adopted without the mapping.
121   8.3.2                 T   In general it is often not clear how statements are supposed to be          Review all statements and align with the ISO Directives
                                interpreted. For example, in 8.3.2.10 how should a statement "scale         Part 2, 6.6.1 and Annex G. This includes replacing
                                ranges are closely related with CRS" be implemented by a view service?      statements like "is PNG" to "shall be image/png" etc.

122   8.3.2                 G   not all readers will be OGC experts                                         It would be helpful to provide some more technical, easy-
                                                                                                            to-understand guidance as to how assure that the
                                                                                                            required response can be generated by the hosting
                                                                                                            system (publisher). Maybe an Annex similar to Annex A,
                                                                                                            with some practical experience from a "publisher" already
                                                                                                            conform to this IR
123   8.3.2.1                   T   When will GeoRM be reality? As a matter of fact, many View services can Please state more clearly, what is expected by View
                                    be provided without GeoRM or other technical means using a flat rate.      service providers with respect to GeoRM - and when this
                                                                                                               is to be expected.
124   8.3.2.1                   G   For GeoDRM neither standards nor standardised solutions are known,         Describe existing solutions, which fulfil the requirements
                                    which fulfil the requirements on the functionality of view services on the for GeoDRM in a freely accessible view service (without
                                    one hand and for the protection of the data on the other hand. Because     access constraints, but use constraints). The
                                    GeoDRM is only at the stage of research and development, it cannot be requirements for GeoDRM could be implemented
                                    prescribed as an obliging standard for the implementation. With reference temporarily by an application, until a standard is available.
                                    to the demands of the directive such protective services are necessary for
                                    data and service providers, who are obliged to apply charges for using
                                    their data/services, to offer personal data or data of protective-worthy
                                    goods (Article 13 of the INSPIRE directive).

125   8.3.2.1                   T   In the field "fees" the entry "no fees" should be entered. Is this conform to
                                    the definition of the ISO 19128 ( "none")?
126   8.3.2.4    paragraph 1,   T   Why epoch 1994.0 and not any other, e.g. the current, epoch?                  Clarify
                    item 6
127   8.3.2.4                   Q   Should this list really be fixed here already when the specifications for     Reconsider creating potentially conflicting lists of CRSs
                                    coordinate reference systems are still to be developed?
128   8.3.2.4                   T   Is it really necessary that every Member State view service implements        Reconsider this mandatory requirement
                                    the non-continental European CRSs? The benefits seem disproportionate
                                    to the costs involved.
129   8.3.2.4    Paragraph 1    G   According the "WMS-DE Profile" the Coordinate Reference Systems are
                                    implemented in Germany. Other CRS are not supported.
130   8.3.2.5                   T   The definition of complex geometry selections is not applicable for every     The definition of complex geometry selections should only
                                    View service.                                                                 be considered with specialised View services.
131   8.3.2.6                   T   The definition of complex temporal data dimensions is not applicable for      The definition of complex temporal data dimensions
                                    every View service.                                                           should only be considered with specialised View services.

132   8.3.2.7                   E   title                                                                         Change title to: "Legend URL"
133   8.3.2.8                   T   It should be considered that the SLD is not referred to within ISO 19128.     Give some explanation.

134   8.3.2.9                   T   In the Draft Implementing Rules for Metdata the TIME parameter is not         If the temporal extent of the records is meant, this should
                                    explicitly mentioned.                                                         also be described.
135   8.3.2.11                  T   A default exception format is missing.                                        A default exception format should be defined.
136   8.3.2.12                  T   A complete list of fields is missing.                                         A complete list of fields should be given.
137   8.3.2.12                  T   Multilinguality is an important aspect, but not covered by the INSPIRE        Multilinguality in Capabilities should be made optional.
                                    Directive except for Article 8 (2) c.
                                    It will take much effort and time (and cost) to implement multilinguality.

138   8.3.2.12                  E   Text: "Originally the ISO12128 is not foreseen for multilingualism. As turn- Change to: "ISO12128 is not designed for multilingualism.
                                    around ..."                                                                  As work-around ..."
139   8.3.2.12                 E   Text: "the translations to the other(s) supported language(s) …"                Change to: "translation to other supported languages ..."

140   8.3.2.12                 T   Is "GetMap image result" language dependent?                                    Please check.
141   8.3.2.12                 E   "by supported language"                                                         Change to: "for each supported language"
142   8.3.2.12                 T   The requirements stated in this sub-clause regarding the GetCapabilities        Clarify requirements
                                   response have not been understood.
143   8.3.2.12                 T   The multilingualism is certainly very useful. Unfortunately, by the ISO-
                                   19128 is it not supported. You should approach to the appendages of the
                                   OGC Web Service Common Specification. Here was the problem solved
                                   in a different way.
                                   The implementation of this proposal would mean a considerable expense.
                                   The Capabilities must be hold secondary. The handling of the exceptions
                                   is still problematic. It would be useful to completely renounce a provider
                                   language and only allow english error messages.
144   8.3.2.13   paragraph 2   T   The paragraph is unclear. How can this be specified here when it is the         Revise wording to clarify that this is meant as an example
                                   responsibility of the IR on the particular theme to specify the layers?         and not as a requirement.

145   8.3.2.13     Table 7     E   Text: "List of keywords describing the layer, to help catalogue searching"      Change to: "List of keywords describing the layer, to
                                                                                                                   support catalogue search"
146   8.3.2.13                 G   There are layers, where style parameters are not applicable, like               Make style parameters and LegendURL optional.
                                   orthoimagery. In this case, a LegendURL cannot be given.
147   8.3.2.13 ScaleDenomin    T   The use of the ScaleDenominator is, in any case, reasonable (especially         The ScaleDenominator should therefore be mandatory
                    ator           for the clients and users).                                                     required.
148   8.3.2.13 MetadataURL     T   The value "ISO19115: 2003" is defined for the attribute "type". Before the      Harmonisation is required.
                                   value "INSPIRE" was requested.
149    8.3.3                   T   Too costly to change to WMS 1.3.                                                Make VERSION element optional.
150    8.3.5                   Q   Would it be allowable for a data specification to require support of            Clarify
                                   GetFeatureInfo for a particular layer of a view service in exceptional
                                   cases?
151    8.3.6                   G   The terms "Availability", "Capacity", "Reliability", "Security", "Regulatory"   Omit: "… as part of the INSPIRE directive"
                                   are not contained within the INSPIRE Directive as Performance criteria.
                                   Consequently, the following text is not applicable:
                                   "The following three criteria shall be monitored and reported as part of the
                                   INSPIRE directive:"

152    8.3.6                   E   "Regulatory" is an adjective, that makes no sense standing alone. A noun Add an appropriate noun.
                                   is missing.
153    8.3.6                   G   The demand of defining quality criterions and the demand to publish      Only the quality criterions should be prescribed and the
                                   these is supported, indeed, the default of values is not proper. (e.g.   obligation to publish the associated values.
                                   reponse time of WMS 3 seconds)
154   8.3.6                   T   The requirements seem to be high. Especially smaller institutions do not      Increase response time and lower the requirement of
                                  have high-performance webservers. This type of performance depends            nominal performance with 100 simultaneous service
                                  also largely on the network-capacity, which is usually not under control of   requests. The latter is quite tremendeous. If you want to
                                  the service provider.                                                         serve 100 requests per second each with a 1024x768 pix
                                                                                                                png-image, this could result in more than 70MB/s
                                                                                                                datastream which equals the capacity of two gigabit
                                                                                                                ethernet-adapters: we do not have this equipment!

155   8.3.6.1                 E   As "Performance" is the overall term in the title of 8.3.6 it should not      Change term to: "Response time".
                                  reappear as a performance criteria denomination.
156   8.3.6.1                 T   Text: "The time for sending initial response to service request in normal     Change to: "The time betweeen complete reception of a
                                  situation shall be 3 secondes. This time includes sending view service        service request and sending a complete response shall
                                  errors or exceptions."                                                        be less than 3 seconds in normal situation. In case of an
                                                                                                                error, exception messages shall be sent in the same
                                                                                                                time."
157   8.3.6.1                 T   Peak load: Insufficient definition.                                           Define Peak load more clearly.
158   8.3.6.1   Paragraph 1   T   According to “8.3.6.1 Performance” a “response time” of 3 seconds has         It follows that the standards given are too inexact to reach
                                  to be reached for a picture of 1024 * 768 picture points at GIF- or PNG       a real performance. Therefore the exact depth of colour,
                                  format. It is certainly true to speak of “initial response to service         picture size and the technological marginal conditions
                                  request”but I seems to be only efficient if the picture is sended             have to be defined more exactly. Additionally it has to be
                                  completely.Let us assume a PNG format for the digital orthophotos, so         defined how to measure the initial response time and the
                                  the picture has a size of 2.178.248 Bytes or 17.425.984 Bit. To send this     time up to the complete data delivery. To call for a
                                  within 3 seconds you need a band width of 5.8 Mbit/s ( with Header it         minimum response time is efficient only when all marginal
                                  means ca. 6Mbit/s). Because referring to the capacitiy of 100                 conditions as picture size, colour depth, content, minimum
                                  simultaneous requests should have to be served, you have to assume a          band width, simultaneous access etc. are given.
                                  (minimum) band width of 600Mbit/s for the central server to fulfil this
                                  requirements (to send 100 pictures with 1024*768 picture points at PNG
                                  format each about 2 MByte within 3 seconds). Using a JPG format the
                                  figures are definitely lower (with a picture size of 233.235 Byte or
                                  1.865.880 Bit and accordingly of a band width at the Client of 622kBit/s
                                  and at the Server of about 65Mbit/s). The JPG-standards can be
                                  positively reached for Thueringen (Thuringia) too.

                                  A uniform rule of calculation to determine the statistics is necessary. A
159   8.3.6.2                 T   persistent monitoring may affect the performance of the services.
                                  Availability: Unclear definitions.                                            Define more clearly the reference (what is defined as
                                                                                                                100% ?) and working hours. Is there something like
                                                                                                                European working hours - to be defined across all
                                                                                                                European time zones?
160     8.3.6.2   Paragraph 1        T     According to IR1 an availability of 99 % has to be guaranteed                Obviously in this case a more accurate definition of
                                           corresponding to a “Downtime” of about 3.7 days per year. Additionally a     “downtime” has to be given. It includes a definition of the
                                           maximum “Downtime is required being within the “work time” a day of          maximum failure time “at the whole” and additionally the
                                           maximum 15 minutes a day. It is very difficult to ensure a maximum           availability required in percent.
                                           continuous (?) failure time of 15 minutes during business time because
                                           during this time mostly the fault is realized but not eliminated. The
                                           shortest response time is two hours. To obtain an even more shortened
                                           time of re-establishing some “Failover systems” have to be installed that
                                           could take action in case of system failure.The “failover systems “ have
                                           to refer to the connection of the internet and network components within
                                           the member state.
161     8.3.6.3                      T     Capacity: The number of simultaneous service requests is meaningless if      Lower requirements considerably, e.g. 3 parallel requests
                                           there are no definitions given for what is requested.                        and 3 seconds response time for a request yielding 2
                                                                                                                        Megabytes of imagery. The response time should be
                                           If we assume the 1024x768 pixel size GIF mentioned in the text, this will    taken at the server side, neutralising client and network
                                           result in about 2 Megabytes per image to be transferred through the          time effects.
                                           server chain.

                                           A simultaneity of 100 then will result in 200 Megabytes, to be transferred
                                           within 3 seconds, or 67 Megabytes per second. Such performance will
                                           result in very high cost for the Member states.
162     8.3.6.4                      T     Heading ("Reliability") does not match text ("conformity").               Change one of it.
163     8.3.6.4                      T     Text logic: "In order to allow comparison between responses …"            Change to: "In order to allow comparison between
                                                                                                                     responses of different service installations …"
164     8.3.6.4                      T     Text: " … it is also recommended to provide reference datasets."          it is also required to provide reference datasets for tests
                                                                                                                     within the INSPIRE community.
165     8.3.6.5                      T     There are no definitions given for "security" and "security regulations". Please give definitions.
166      8.3.7                       T     If it is relevant for the IR, this cannot be left blank.                  If it is not relevant for the (first version of the) IR, remove.
                                                                                                                     Otherwise provide contents.
167      A.3                         E     The wording in this sub-clause is misleading and in conflict with the OGC Revise language to align with the OGC TC Policies &
                                           TC Policies and Procedures. For example, most of the documents            Procedures.
                                           referenced in this section are not OGC standards, but candidate
                                           standards at this time.
168       A                          T     The annex is informative but contains normative language.                 Revise annex to remove all normative statements (or
                                                                                                                     remove annex altogether). Or, if required, move normative
                                                                                                                     statements to main body of the document.
169       C                          T     The example does not seem to be valid Symbology Encoding (e.g., see       Correct example
                                           the missing namespace declarations for SLD and SE)

[1] Use "3.1" instead of "Clause 3.1" or "Chapter 6.1". This makes grouping of comments easier.
[2] E.g., Table 1
[3] Type of comment can be G (general), E (editorial), T (technical)
[4] The proposed change must be as precise and specific as possible.
any worksheets.

								
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