EC Consultation Opening Up Education

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Submitted 5 November, 2012.

IPM Reference Number: 863801634322031012

The answers below are supported by the following CC Europe affiliates:

  • CC Luxembourg, host institution Luxcommons ASBL
  • CC Denmark
  • CC Greece
  • CC Germany
  • CC Belgium
  • CC United Kingdom
  • CC Sweden
  • CC Czech Republic
  • CC France
  • CC Portugal
  • CC Serbia
  • CC Poland
  • CC Netherlands
  • CC Finland
  • CC Bulgaria
  • CC Ireland


Public consultation on "Opening Up Education - a proposal for a European Initiative to enhance education and skills development through new technologies"

Before responding the present questionnaire, please read carefully the consultation document where the initiative is presented together with its priority areas and activities. You can find this document in the "useful links" above. Questions marked with an asterisk * require an answer to be given.

Identification of the respondent

The contributions received will be published online together with the identification of the respondent, unless you oppose. In the end of the questionnaire you will be asked whether you authorise or not such publication.

Are you responding as an individual or as organisation?

  • Organisation


Name of the organisation (maximum 50 characters)

  • Creative Commons


Country where the organisation is based (maximum 50 characters)

  • United States


Is your organisation registered in the "EU Transparency Register for organisations and self-employed individuals engaged in EU policy-making and policy implementation"

  • Yes


Please indicate the number of registration of your organisation (maximum 50 characters)

  • 15262256432-95


Please indicate one contact person regarding this answer (maximum 50 characters)

  • Timothy Vollmer


Please indicate one contact (email or telephone) where this person could be reached (maximum 50 characters)

  • tvol [at] creativecommons [dot] org


PART I - Rationale and scope of the initiative

To what extent do you agree with the following statements

A more systematic use of ICT in education, together with extended availability and use of Open Educational Resources, could have a significant and positive impact on the quality of education and on learning outcomes;

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


There is a clear rationale for public intervention in order to promote and facilitate the provision of and access to OER;

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


An initiative at European level to support and complement initiatives at Member State level would allow for significant synergies and increase overall results for society;

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Ensuring wider availability and use of OER and ICT in education should be a top priority for the EU and its Member States in the coming years;

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


How much benefit do you consider each educational sector will gain from opening up education?

Pre schooling

  • None
  • Little
  • Some
  • A lot


School education

  • None
  • Little
  • Some
  • A lot


Higher Education

  • None
  • Little
  • Some
  • A lot


Initial Vocational Training

  • None
  • Little
  • Some
  • A lot


Adult Education (including continuous VET)

  • None
  • Little
  • Some
  • A lot


Informal and non-formal learning

  • None
  • Little
  • Some
  • A lot


Problems to be addressed


Policy intervention is appropriate when there are clear and specific problems that requires intervention from public authorities. Would you agree that this is the case? Namely in the following:


The use of Open Educational Resources, and more generally the use of ICT, in education in Europe is still too fragmented and unsustained; therefore, there is a need for action to promote more and better use of OER.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


A deeper exploitation of Open Educational Resources and its potential would increase access to education, namely by attracting individuals who would otherwise not be involved in formal education (adult learners, individuals who are geographically remote from educational institutions, individuals interested in only very specific subjects, individuals with special educational needs, etc.)

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


The potential of Open Educational Resources is not being fully exploited at least in part because of the lack of a clear legal framework applicable within the European Union addressing issues like Intellectual Property Rights, copyrights, licensing and publishing rights.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


The use of Open Education Resources is not being fully exploited, at least in part because the variety of resources, their types and sources, make it too complicated for users (learners or educators) to find and select the right resources for their specific needs.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


For the user, identifying quality resources and/or sources may be difficult due to the variable quality and fragmented nature of Open Educational Resources. This could be resolved by the development of quality standards and quality assurance tools.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


The potential of ICT in education and OER is not being fully exploited, at least in part because it is yet not clear how different actors (e.g. content providers, publishers) can adapt their strategies and business models.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


The nature of Open Educational Resources has the potential to generate higher levels of innovative practice in education and training institutions who embrace this approach.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Wider use of ICT in education could increase the motivation of born-digital learners, thus reducing early school leaving.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


While maintaining the freedom of choice for schools to choose their own educational textbooks, the availability of free digitised school books could lead to a significant reduction in the cost of education for the learner and thus reduce levels of dropout from education.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


The availability of high quality Open Educational Resources, clearly identifiable as European, would have a positive effect on the attractiveness of the European education and research system, contributing to the recruitment and retention of high quality students and researchers in the EU.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


ICT didactics on the use of OER and new pedagogical practices are not made sufficiently available to teachers and other educators, particularly during initial teacher training.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Stronger cooperation between traditional higher education institutions and Open Universities could contribute to a better use and uptake of OER and should be encouraged.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


The availability of hardware and ICT infrastructure in/for education in many learning environments is still insufficient, thus creating imbalances in learner access to education generally.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Do you think that other issues/difficulties should be addressed? Please explain further. (maximum 5000 characters)

The Commission should support the recommendations in the 2012 Paris OER Declaration (PDF), which was ratified by UNESCO member nations at the World Open Educational Resources Congress on 20-22 June 2012. As described in the consultation document, “the EU will use the tools at its disposal (policy guidance, EU regulation whenever relevant, funding mechanisms, exchange of good practices and innovative pilots).” By leveraging these various tools in alignment with the suggestions laid out in the Paris Declaration, the EC can be very effective in promoting the development and use of OER. Those recommendations urge UNESCO member nations to:

  1. Foster awareness and use of OER.
  2. Facilitate enabling environments for use of Information and Communications Technologies (ICT).
  3. Reinforce the development of strategies and policies on OER.
  4. Promote the understanding and use of open licensing frameworks.
  5. Support capacity building for the sustainable development of quality learning materials.
  6. Foster strategic alliances for OER.
  7. Encourage the development and adaptation of OER in a variety of languages and cultural contexts.
  8. Encourage research on OER.
  9. Facilitate finding, retrieving and sharing of OER.
  10. Encourage the open licensing of educational materials produced with public funds.


The European Commission is in a position to help coordinate, promote, and support most--if not all--of these recommendations. In addition, these recommendations align with the Europe 2020 priorities, especially in increasing effective investments in education by encouraging free open access to publicly funded educational content.

In addition, the Paris Declaration reaffirms OER as “teaching, learning and research materials in any medium, digital or otherwise, that reside in the public domain or have been released under an open license that permits no-cost access, use, adaptation and redistribution by others with no or limited restrictions.” The EC should support this definition of OER so that users of OER know the rights available to them and so that producers of OER get the credit they deserve. Also, since we agree that the potential of OER is not being fully exploited at least in part because of the lack of a clear legal framework applicable within the European Union, we strongly suggest that the EC should consider promoting the use of Creative Commons licenses and public domain tools like the CC0 Public Domain Dedication. CC licenses are globally applicable and are seen as the gold standard for content licensing. It would be beneficial for the EC to adopt CC licenses because they are already established and understood, instead of creating customized licenses that may not interoperate with existing solutions.


PART II - Actions at EU level

The proposed actions are grouped into four priority areas (please refer to the main text). Do you agree that the priority areas are adequately addressed by these proposed actions? Please respond considering each of these areas:


Access, inclusion and equity;

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Quality, efficiency and internationalisation;

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Teaching, educational practices and assessment;

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Policy development.

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


For each of the four priorities aforementioned, please highlight which action you consider to be the most important and whether it requires intervention at the European level.


Area 1 - Access, inclusion and equity (maximum 200 characters)

  • Establish an open licensing requirement for educational resources developed with public funding, in line with UNESCO's Paris Declaration on OER.


Area 2 - Quality, efficiency and internationalisation; (maximum 200 characters)

  • Explore possible ways of exchanging high quality OER with other parts of the world.


Area 3 - Teaching, educational practices and assessment (maximum 200 characters)

  • Support teacher education and professional development on ICT didactics and use of OER, and increase access to communities of practice to develop transnational collaborative models.


Area 4 - Policy development (maximum 200 characters)

  • Policy discussions on adapting funding and quality frameworks to incentivize engagement in open education.


Do you consider that any of the proposed actions are not appropriate for inclusion in this initiative? (maximum 500 characters)

  • No


Is there any other action that you consider essential? (maximum 500 characters)

  • Education, guidelines and/or sharing of best practices on open licensing and public domain tools for policymakers and educators.


Considering the need for intervention at European level (as opposed to intervention at Member State level) please rate how much you agree with the following statements:

Jointly agreed actions are needed to maximise the benefits from opening up education;

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


There would be clear synergies from an EU initiative because it would complement existing or future actions by Member States

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Although a European initiative would create synergies, some actions would require a closer cooperation with Member States because there may be a need to contextualise to different geographical areas

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


As education is the responsibility of Member States, cooperation in the field of Open Educational Resources is not appropriate at EU level and should be left exclusively to each Member-State

  • Strongly disagree
  • Disagree
  • Agree
  • Strongly agree


Final general question

Do you have any further comments on the proposed initiative? Please feel free to give your opinion on the proposed initiative and/or to address any specific elements not mentioned previously. You can also upload a file with the official position from the Member State/organisation/authority you are responding on behalf of.

  • As members of the Creative Commons affiliate teams in Europe, we are primarily focused on the development and adoption of Open Educational Resources and policies supportive of OER. While ICT is an important related component to the support structure for teaching and learning, it is not necessarily our main area of expertise and we hope that other parties have provided useful feedback on the necessity for addressing ICT needs.


PART III - Confidentiality

The contributions received and the identity of the contributor will be published on the Internet, unless the contributor is opposed to the publication of personal data for fear that this would damage his/her legitimate interests, in which case the contribution may be published in anonymous form. Do you authorise the European Commission to publish your contribution?

  • Yes