|Subject: [Hangout-NYLXS] Free Software for Education
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By 12/15: Send us comments to rally the Dept. of Ed. toward free licensing
by Joshua Gay — Published on Dec 07, 2015 04:21 PM
The U.S. Department of Education has issued a notice of proposed rule
making (NPRM) with a request for comments from the public regarding new
regulations relating to the licensing of grant-funded works -- both
software and courseware.
These proposed regulations are meant to facilitate public reuse of works
funded by Department of Education grants. Currently, as explained in the
NPRM, grantees are allowed to make their federally-funded works
proprietary. The Department of Education receives a special license to
share the works with the public, but in practice it rarely does so.
Worse, teachers and students absolutely cannot use them in freedom
(except for those few that happen to be made free).
Since the course materials are works of practical use, they should carry
the four freedoms of free software, just as programs and manuals should.
The proposal would require grantees to publish the works under an "open"
license. In the case of software, they may be thinking of "open source",
which is not quite as strong as free; in the case of courseware, many
"open" courses are not free. The flaw in the proposed specific rules is
that they don't require that the license permit redistribution of
modified versions. Without that freedom, the works will be nonfree.
With a small change, this proposal will more clearly do what is needed.
The small change is to add "redistribution of modified versions" to the
list of uses these works must permit users to do.
If you are a US citizen or you are living in the US, then you can help
make that change happen by submitting a comment advocating it.
If you are not a US citizen, then we hope you will use this as an
opportunity to reach out to the department of education or the
appropriate government rule makers in your own country and encourage
them to adopt similar rules -- ones that require grant funded works of a
functional nature be distributed under free licenses. If you do contact
your own government with such a request, please, email licensing-at-fsf.org
and let us know!
Unfortunately, submitting a comment digitally requires the user to run
submitting the FSF's comment another way. We are going to submit it by
post so that it gets to the Dept. of Ed. by Friday, December 18th (the
date comments are due).
To help you submit a comment without running the US government's nonfree
JS, we offer to print and send your comment along with ours. To do that,
we need to receive your comment by email sent to licensing-at-fsf.org with
the subject "Dept. of Ed. comment" by 12:00PM EST on December 15th. We
can print PDF files, ODF files and plain text. You need to follow the
rules for submissions 100%, because we don't have staff to correct even
minor errors. The eRulemaking Initiative has some guidance on how to
write a good comment. But in the very least: your comment should clearly
cite the above referenced NPRM (Docket ID ED-2015-OS-0105), it should
express your support for these proposed regulations, and it should cite
the exact section (§3474.20 (a)) that you believe should be updated and
why you think it should, including any relevant personal or professional
experience or knowledge. See our NPRM Basics guide for citing and
formatting your comment.
We may skip comments that are too long or that are inconsistent with the
goal. Please say in your email message whether you give permission for
us to publish your comment.
While we would like to deliver a large packet of comments to the
Department of Education, you can also mail your own: address them to
Sharon Leu, U.S. Department of Education, 400 Maryland Avenue SW., Room
6W252, Washington, DC 20202-5900.
In addition, if you are interested in becoming a cosigner to the comment
the FSF is going to write and submit, then please email us at
licensing-at-fsf.org with the subject "Dept. of Ed. comment cosigner." In
your email please provide your full name, city and state, and be aware
that we will be making that information public as part of publishing our
Lastly, there should be no doubt in your mind that the FSF's work in
free licensing, licensing education, and advocacy has played a
meaningful part in the circumstances that have lead to the US Department
of Education reforming its policy from promoting proprietary works to
one that requires the development of only free works. We know that the
GNU GPL and the FSF's work in free licensing education serves as a
guiding light to policy makers everywhere. But, in order for us to
continue positively influencing public policy, we need your help:
please, become an associate member or make a donation today.
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