In der 19. Sitzung der INSPIRE Maintenance and Implementation Group (MIG) wurde der derzeitige Sachstand und der Zeitplan der GreenData4All-Initiative vorgestellt. Im Rahmen der Sitzung wurde auch ein Workshop durchgeführt, in dem Rückmeldungen zu den unten genannten Fragen zu den identifizierten Problemen und möglichen Maßnahmen im Rahmen der Fortschreibung der INSPIRE-Richtlinie gesammelt werden sollten. Den Mitgliedstaaten wurde bis zum die Möglichkeit gegeben, schriftlich konsolidiertes Feedback zu diesen Fragen zu geben. Einer Fristverlängerung bis zum hat die Europäische Kommission bereits zugestimmt.
Wer sollte sich an der Kommentierung beteiligen?
Ein Austausch zum Fragenkatalog ist am im Rahmen der 18. Sitzung des AK INSPIRE geplant. Alle interessierten Mitglieder des Lenkungsgremiums GDI-DE sind eingeladen an der Sitzung des AK INSPIRE teilzunehmen. Neben dem AK INSPIRE und dem Lenkungsgremium GDI-DE werden die Kontaktstellen GDI-DE und die Leitungen der weiteren Arbeitskreise der GDI-DE an der Abstimmung beteiligt.
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Fragenkatalog & Antwort-Vorschlag
Disclaimer
Many of the questions are rather vague and do not explicitly state the underlying assumptions or related policy options. Furthermore, it was not possible for us to collect and consolidate feedback from all relevant stakeholders in the short period given for feedback. We therefore focus on trying to sharpen the questions and teasing out some of the underlying assumptions or policy options.
What is necessary/needed to simplify of the provisions for harmonization/standardization of data currently covered by INSPIRE:
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Question
Comments
1.1
What would be a minimum level of harmonization/standardization?
Does this question refer only to legal provisions (in the IRs) or also the technical provisions (in the TGs and Good Practice documents)?
Does this question refer only to the provisions on data interoperability or also on the technical provisions on network services and metadata?
For data interoperability, there will always be the need for some processing (ETL) steps before being able to use data from different sources in an application or integrate it in a (pan-European/cross-border) data set. The main question here is how this necessary transformation is performed – by requiring all providers to transform their data to a common (exchange) model (the current obligation) upfront, from which a user/application developer can then transform the data to their application needs, or whether to put more burden for the transformation from the source format (data “as-is”) on the user/application developer.
It should be considered that even with the current approach, harmonised INSPIRE data can usually not be used in an application/integrated in a dataset “off-the-shelf” (i.e. with minimum extra effort), but that there is still considerable effort involved at the application developer side, as illustrated e.g. by the work of ESTAT on building pan-EU data sets.
For any transformation to a target application/data set, the user/application developer will need as a minimum a clear documentation of the structure and semantics of the data that is provided (ideally also in English and/or some machine-readable format).
Also, the use of well-established vocabularies for category-based attributes and common approaches for the encoding of identifiers and coordinate information is crucial.
1.2
What would be the consequence of abandoning the one-size-fits-all approach to harmonization of data?
What exactly is meant by “abandoning the one-size-fits-all approach to harmonization of data”? Do you mean the obligation to transform all data sets under the scope of INSPIRE to the defined common data models upfront? What would this obligation be replaced with? For example, simplification of obligations or a reduction of the burden on data providers could also mean a common approach/common requirements for all data sets, but with fewer ex-ante obligations or focusing obligations on documentation of “as-is” data rather than transformation.
Removing the obligation to harmonise all data upfront could potentially also remove the duplicate implementations in some (most?) MS, where “as is” data are used in national applications and use cases, that is done only to meet the INSPIRE requirements, i.e. the same “as-is” data that is available in the national SDI would also be made available under INSPIRE.
1.3
What issues do you see related to interoperability when simplifying the technical provisions?
The fewer technical provisions for upfront harmonisation exist, the more labour-intensive will be the transformation to a target application/data set. Therefore, if requirements for upfront harmonisation were to be reduced/abolished, sufficient documentation of data structures and semantics (e.g. including a mapping to well-established vocabularies) would be crucial.
1.4
What would this mean in terms of cost reductions for data providers?
Dropping the obligation to harmonise all data sets within the scope of the INSPIRE Directive upfront would mean considerable cost reductions for data providers, especially if duplicate implementations could be avoided through this.
Of course, additional costs for implementing alternative measures (e.g. an obligation for thorough documentation) would need to be considered when calculating cost reductions.
1.5
Would MIMs (Minimal Interoperability Mechanisms) be the solutions as used in Open and Agile Smart Cities and Communities (OASC)?
Some OASC MIMs (e.g. MIM-2, MIM-7) could be good sources for inspiration for alternative obligations, but they seem to still be at an early stage in their development, so should not be taken up 1:1.
1.6
How do you assess the impact of the alignment with HVD, OPD, Green Data Space?
The question is not really clear. What is meant by OPD? The impact of what precisely?
Generally, the overall future vision for the provision, sharing and use of geospatial and environmental data should be defined first. Then it should be discussed how this vision can be achieved and which (parts of which) existing legislation should be changed how and which aspects can be covered through soft measures (e.g. the Green Deal dataspace).
Question 2: Establishment of a feedback mechanism (user feedback on data)
Objective: Introduce mechanisms for capturing evolving information needs in the field of the environment
INSPIRE provides the governance structure for the data covered. When revising the directive reflection is also needed on optimizing the governance structure:
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Question
Comments
2.1
Who should be responsible for the governance of
collecting/assessing the requirements,
identification of core datasets,
endorsment of technical solutions.
This strongly depends on how many details are regulated in the Directive/Implementing Acts and how much is left to guidance or standardisation. However, it could be useful to set up a process for collecting/assessing user requirements with a central point of contact at the EC that receives requirements from the community. We have already established such a process in Germany (https://bedarf.gdi-de.org).
What is meant here by “identification core data sets”? The definition of what data sets shall be in scope of the revised Directive? Or who in each MS identifies which of the data sets comply with that definition?
The development of technical solution could be left to technical communities (e.g. in the GDDS), projects or standardisation bodies. There should still be a step of formal endorsement of recommended solutions (similar to the current Good Practice Process).
2.2
How should it be organised?
The current process for the management of INSPIRE Good Practices and Artefacts (Technical Guidance Documents, XML schema, UML-models, INSPIRE Registry content) seems to work well.
2.3
What will be the costs/who will cover?
The development should be community-driven (and –paid), the endorsement and management process should be covered by the EC.
Question 3: Data confidentially (mechanism, standards)
Objective: Develop new mechanisms for data confidentially in order to reuse non-open and non-personal public environmental data (forest plot data, location of endangered/protected species, soil plot data, ...)
There is a need to:
finding mechanisms for facilitating the sharing of non-open environmental data
providing guarantees for intellectual property rights when sharing end-use data
Options are to:
Develop standards between the data provider and the data user (possibly based on a set of standard terms, with common frameworks that could be developed).
Placing geodata services for non-open environmental data and data covered by intellectual property rights behind a security certificate protected firewall.
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Question
Comments
3.1
Who should be responsible and how to organise?
non-open data should be discoverable through SDIs (based on standardised metadata) and usable in protected environments like data spaces
3.2
What are the key issues?
data providers have already implemented mechanisms to protect their data, a common framework will be difficult to establish (e. g. Germany has failed to introduce federated access control in the past)
Question 4: Capacity for reusing environmental data
Objective: Build capacity for reusing environmental data for supporting environmental processes (e.g., monitoring, reporting, environmental impact assessments)
When simplifying INSPIRE and transferring responsibility for data processing/harmonization/data product development to others than the providers
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Question
Comments
4.1
What will be the needs for capacity building for green and digital skills to capture evolving data needs in the field of the environment on the side of the:
Data providers (share data as-is)
Data Intermediaries* (harmonization, additional processing, product development)
Users (data product requirements)
* A data intermediary under the DGA is an entity that facilitates the sharing of data between various parties while ensuring neutrality, transparency, and compliance with strict regulatory requirements to protect the interests of both data subjects (individuals) and data holders (providers, intermediaries).
Is it planned to include capacity building in the scope of the revised INSPIRE Directive? If so, in which form – setting obligations on Member States, setting up a funding programme for capacity building, developing common skills frameworks/certificates?
In general, all roles need to have an understanding of metadata, APIs, licences, shared vocabularies, data models, identifiers, versioning/archiving, data harmonisation/ETL, but from slightly different perspectives – why is the distinction between the roles relevant (at this stage)?
4.2
What are the costs/efforts that will be transferred?
It is unclear what is meant by "cost/effort transfer" here.
Question 5: Simplify and reduce burden of EU data sharing legislation
Objective: Simplify and reduce burden of EU data sharing legislation
In view of the scope of the Implementing Regulation on high value datasets under the Open Data Directive (categories geospatial data, environmental data and earth observation, and mobility), the promotion of reuse of public data under the Data Governance Act, and the drive for a common public sector interoperability from the Interoperable Europe Act:
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Question
Comments
5.1
Would you prefer one common data sharing regime under horizontal legislation?
Generally, the overall future vision for the provision, sharing and use of (geospatial and environmental) data should be defined first. Then it should be discussed how this vision can be achieved and which (parts of which) existing legislation should be changed how. In the second step, it would of course be welcome if obligations are streamlined and relationship between legal acts were clear and consistent.
5.2
What would be the possible future role of the INSPIRE Directive? Is it still needed? For what?
For the past 15 years, INSPIRE has been the main driver of sharing spatial & environmental data in Europe. Any future EU legislation on spatial & environmental data sharing should ensure that all spatial/environmental data in Europe is made accessible in such a flexible way that it fulfils the requirements of data-using environments and applications such as data spaces, digital twins, etc. in terms of interfaces, formats, etc.
The INSPIRE Directive Annexes as they stand are an open-ended obligation to harmonize almost everything upfront and offer this to everybody, while there is no easy way to see EU-wide use-cases like maps or so based on the data provided by all Member States that prove the added value of INSPIRE beyond the good idea of sharing data. The now existing High Value Datasets may serve as the focus of EU activity in the future while for all other datasets a reasonable documentation on Member State level would be sufficent (see comments above).
