The Office of Parliamentary Counsel, South Australia (OPC) drafts all new Bills introduced into State Parliament, new regulations and maintains all South Australian Acts, regulations and some other instruments. The office has about 14 legal officers who draft new SA legislation and about 5 administrative officers who undertake publishing, consolidation of amendments and related tasks.

OPC is responsible for all production stages before printing SA legislation in hard copy. Printing is undertaken by another SA government agency from PDF files supplied by OPC. SA legislation is currently published on the internet by another SA government agency from word processing files supplied by OPC.

OPC needed to replace its obsolete WordPerfect 5.1 drafting application. It had to decide whether to replace this with another word processing application or use a different approach. OPC wanted to improve the quality of SA legislation available on the world wide web.

Legislation has a life cycle that may extend over many decades. Changes in proprietary word processing formats cause substantial disruption and cost as data has to be converted to new formats. Changes in print styles can require re-formatting of many hundreds of large documents. Historical versions of legislation become inaccessible as their file formats become obsolete.

OPC wished to avoid these recurring problems and adopt a data storage format that would allow it to flexibly and automatically publish SA legislation and related documents in print and electronic form. This called for a highly consistent, machine readable markup of all SA legislation.

To achieve these aims, OPC decided to prepare all new legislation in XML format and convert all current SA legislation from WordPerfect 5.1 format to XML in accordance with its chosen DTDs.

OPC's requirements for legislative drafting

Most, but not all SA legislative drafters typed draft legislation themselves. Draft legislation passes through many review cycles and must be exchanged with instructing departments and the Parliament. Drafters were accustomed to using a macro driven word processing application that aimed to create consistently presented legislation.

OPC does not have its own IT staff but must rely on staff from its parent agency. While always helpful, the IT staff were remote from its day to day problems.

OPC wanted a legislative drafting application that would be easy to use for its drafters and would enable them to reliably produce generic, structured XML markup to meet publishing and long term data management needs. It wanted an application that required little or no system administration and that would let drafters produce draft legislation quickly and without extensive technical review.

After some initial reluctance, OPC was convinced that legislative drafters did not need a full WYSIWYG drafting interface. A slightly simplified approximation of print layouts would be quite sufficient.

Drafters of legislation need the ability to apply automatic numbering to a wide range of components and to enable and disable automatic numbering between drafts. Numbering schemes for legislation can be extremely complex.

OPC wanted a print publishing application that was highly automated and that allowed them to exchange data in editable format (Microsoft Word/RTF) with other agencies.

OPC project management

On OPC's side, the key project champions were Mr John Eyre, Deputy Parliamentary Counsel and Ms Christine Swift, Senior Assistant Parliamentary Counsel. John Eyre and Christine Swift handled all project planning and management within OPC. They conceived of and drove the project from the beginning. Both John Eyre and Christine Swift had to manage much of their normal workload throughout the project. OPC did not have any dedicated technical or project management personnel.

Christine Swift, an IT savvy lawyer, had previously developed OPC's macro driven drafting application in WordPerfect. This gave her a good basis for analysing systems and coming to grips with XML and the new application development.

Elkera engaged as developer

In September 2001 OPC engaged independent software developer, Elkera Pty Limited from Sydney, Australia to develop the DTDs for SA legislation and related documents, manage the conversion of existing legislation to XML format, develop drafting and printing applications and train OPC personnel to use the new systems.

Elkera® specialises in the development of XML based enterprise publishing systems for knowledge management. A major part of Elkera's development work is with Parliamentary Counsel Offices in Australasia. Elkera has extensive experience dealing with authoring and publishing legislation and other legal materials, data conversion and web site development.

The project was managed by Elkera's managing director, Peter Meyer and senior consultant, Andrew Squire. All development work was done in house by Elkera developers.

The XML DTDs adopted by OPC SA are based on DTDs previously developed by Elkera for New South Wales Parliamentary Counsel's Office in 2000. These DTDs can represent virtually all structures found in Australian legislation. They also provide a framework to facilitate data exchange between Parliamentary Counsel offices and with external publishers of legislation.

The drafting solution

After a review of various applications OPC chose to adopt XMetaL Author (Blast Radius Inc.) for its drafting application plus Elkera XML Print, Elkera's XML to RTF print and workflow application.

The XMetaL Author application was selected because it is a strict, continuously validating XML editor with a flexible set of programming interfaces and scripting capabilities using the Microsoft .NET Visual Studio development environment. It provides a Cascading Style Sheet display for the author and has extensive support for complex tables markup. It provides a cost effective platform for development of an XML authoring application.

Elkera also developed an enhancement layer to XMetaL Author called the Elkera utilities for XMetaL Author. These utilities are an 'off the shelf' package of components suited to authors of complex narrative documents such as technical specifications, legal and business documents. They provide a powerful framework for the configuration of XMetaL Author with any DTD or XML Schema to enhance author convenience and reduce application development effort.

Key features of the utilities for authors include:

• The utilities provide convenient element insertion at the next valid location based on easily configured, full element context rules to provide an intelligent authoring interface that allows 'tags off' authoring in all common situations.
• An automatic numbering engine allows complete flexibility for numbering of document components and the insertion of automatically generated numbers into the markup. Authors can switch between automatic, manual or fixed numbering.
• A cross reference utility makes it easy to create and maintain automatic cross references to other parts of the document.
• The utilities include powerful markup transformation tools to assist authors to edit document content and markup.

For application developers, the Elkera XML drafting utilities for XMetaL include these key features:

• The utilities provide a generic application layer to permit developers to configure rules to define XML contexts for element insertion and transformation actions by authors using a structural markup DTD or Schema, without the need for programming.
• A generic application framework simplifies the configuration and extension of XMetaL Author and allows components to be easily shared among multiple DTDs or XML Schema.
• The utilities include a generic framework to share application resources among multiple XMetaL Author users in networked environments.
• The utilities also include a range of pre-developed components that greatly reduce development effort.

Using XMetaL Author and the Elkera XML drafting utilities for XMetaL, Elkera was able to develop an extremely flexible drafting interface for legislative drafters that allows them to perform virtually all drafting tasks in tags off or Normal view in XMetaL Author.

For example, the application defines helpful context based rules for Enter key behaviour, element splitting, joining elements, wrap containers, unwrap containers, manage complex list structures, select structure and cut, copy and paste structure before or after the current location. All these features allow drafters to perform complex markup actions quickly and easily without concern about the precise location of the insertion point.

The print publishing solution

OPC needed to be able to automatically generate high quality printed output for SA legislation and also produce PDF and RTF electronic versions.

To meet this need, OPC chose the Elkera XML Print application as its print engine. Elkera XML Print is an XML to RTF translator and print workflow engine. It allows the simultaneous production of print, PDF and RTF outputs using Microsoft Word and Adobe Acrobat or equivalent applications. XML Print is a Windows application that can be operated in stand alone mode or as an integrated component in other applications such as XMetaL Author or batch processing applications.

Other key features of the Elkera XML Print application include:

• It provides a powerful, but simple language to specify any XML context for control of print output.
• It can be readily configured to any DTD or XML Schema.
• Print rules use formatting property inheritance to simplify application development and maintenance by avoiding duplication of rules within schema.
• Print rules can be shared across multiple schema with common structures.
• RTF output can include named styles.
• It provides fully configured contents listings, headers (including running headers), footers, cover pages and generated content.
• Users can choose to print with revision marks or print a clean copy with changes incorporated. The application is currently configured for XMetaL Author revision tracking instructions.
• Multiple print projects and rules can be associated with each DTD or schema.
• Processing instructions in the XML document can augment standard print rules.
• The application provides a pre-processing phase for tasks such as combining multiple documents.

Using Elkera XML Print, OPC was able to fully automate the production of print outputs for all document types and versions required at each stage of the legislative process. Reprinted legislation and the Index to South Australian Legislation share common legislative history information. The print application automatically combines this shared XML resource with the rest of the publication when each output is created. OPC was also able to fully automate the production of Annual Volumes of new legislation.

Application roll out

At the end of June 2003, after completion of DTD and application development, the drafting and printing applications were installed at OPC for acceptance testing. Formal training of OPC personnel was provided over two weeks in July and full production of new SA legislation in XML began at the beginning of August 2003. This ambitious timetable was achieved because of these factors:

• Elkera and OPC carried out extensive planning and requirements gathering to identify and define OPC needs before beginning development.
• The DTDs developed by Elkera define a few basic patterns in complex text documents that can be used to create any kind of structure. This makes the DTDs relatively easy to use for authors and application developers.
• The ease of use of the XMetaL Author drafting application developed by Elkera meant that legislative drafters could be trained quickly to start XML authoring without a full understanding of the DTDs. They quickly gained a general understanding and confidence and could then extend their knowledge of the DTDs to handle more complex markup structures.
• Support by senior personnel within OPC SA has ensured that all personnel are enthusiastic about the project and are receptive to the changes involved with the introduction of a radically new drafting application.

OPC found that many drafters were able to begin using the XML drafting application almost immediately to produce new legislation. It even found that a few drafters who had not previously typed in their own drafts were motivated to take up keyboard drafting with XMetaL Author. The absence of a full WYSIWYG interface turned out to be an advantage since it helped to free drafters from concern about page layouts.

Benefits from the project

OPC is satisfied that the project has lived up to expectations. It was completed by Elkera within OPC's original budget. OPC was able to implement applications to assist in database management and dispatch of legislation data to other agencies which it had not considered in the original project planning. Christine Swift says:

"In undertaking this project we had no doubt that an XML environment would be well suited to legislation since legislation conforms to strict structural rules, but we did have some concerns. Would it be possible to meet the formidable challenge of providing a workable environment for lawyers when its necessary to correctly identify, position and enter markup from a mass of available elements and attributes? Elkera's development of XMetaL met this challenge head on and created an exciting and dynamic solution that far surpassed our expectations and hopes."

Legislative drafters at OPC much prefer using an XML editor to a word processing application. They have fewer tasks to perform and no longer have to worry about how to make sure something will print out correctly. They can concentrate on drafting legislation.

OPC's print publishing processes have been streamlined and automated. Proofs created from XML data are ready to print and rarely require corrections to markup or layouts. The automatic application of style rules to ensure correct page breaks has removed a lot of redundant, manual work. A preview facility that allows quick visual feedback to drafters minimises the need to later adjust column proportions in tables.

OPC is pleased that it now has an automated publishing system and high quality XML data on which it can develop a first class quality web site for SA legislation as soon as a project can be established. It should not have to undertake an expensive and disruptive data conversion program for a very long time.

Conclusions and lessons learned

This is a very complex project to implement for any organisation, particularly one without any dedicated technical or project management personnel. OPC achieved an outstanding result through dedication and careful planning.

OPC learned the importance of requirements analysis and specification before any software development. At the outset, OPC did not realise how much of the project would be devoted to this. Fortunately, Elkera drove this process at each step before it started development. This was an important element in success of the project.

Christine Swift says that the most important element in success of the project was the expertise of the developer. Elkera understands XML technologies. Their consultants understand the processes involved in the production of complex documents such as legislation and they understand the way lawyers work. Elkera relentlessly applied a user focussed approach to development of all the applications.

The verdict is in. Legislative drafting with XMetaL Author is much easier than with a word processor. Legislative drafters can easily work in a native XML authoring environment if care is taken in all aspects of the application design to create a suitable drafting interface.

Contact Elkera

For more information, please contact Peter Meyer, Elkera Pty Limited.

Email: pmeyer@elkera.com