Hello Jennifer. Many thanks for sharing this draft. This is a really useful note setting out an approach to OGD initiatives. I wonder if it does suffer a bit from being caught between being a summary, and a more in-depth manual. It may be worth exploring splitting into a short 4 - 6 page publication that contains the key models from the How To, and then a more in-depth manual like resource (which could usefully act as the 'policy' and 'organisational' counterpart to the 'legal, social and technical' focus of http://www.opendatahandbook.org) However, assuming the 20 page document evolves as is - some general comments: It would be good to reference the wider literature and guidance on OGD policies, either in-line, or including a section of further resources at the end. For example, consider pointing somewhere to the technical guidance in OpenDataHandbook.org and note that, whilst organisational culture and leadership are as important as technical details, the difference between easy-to-use and well licensed, and poorly-formatted data can be the difference between effective civil society use and none. A 'further resources' section would be valuable to show that this is part of a wider growing literature of practical guidance on developing OGD policy and practice. Consider highlighting that, in many cases, open data is about effectively meeting the Right to Information and that access to documents through RTI can be important alongside OGD in supporting social accountability outcomes. A number of the theories of change developed in the http://www.opendataresearch.org Brasilia workshop boiled down to: 'open data + crowdsourced data / RTI + activism = change' In thinking about users of OGD (p 11), it might be worth highlighting also that actors like Parliamentarians can be key users of OGD, and that there are in fact many cases where individual citizens can benefit from direct, non-intermediated access to data, such as when they zoom in on a particular fact about their local area or about services they use (and where they might be happy to look directly in the government spreadsheets and messy data), and use that fact or claim, plus information they know, to promote accountability at a very local level (for example, the citizen who becomes aware of what was supposed to be spent on their school who confronts teachers directly with that data, rather than going through larger-scale processes). Smaller specific comments: P1: - Open Data licenses do not have to be 'Creative Commons' licenses (and in practice, many Creative Commons licenses do not work for data because they do not handle database rights, and anything other an attribution only places restrictions that create difficulty for integration of different datasets) - Not all of the 55 Countries of the OGP have made commitments relating to OGD. A number of National Action Plans do not reference OGD at all (and there is no obligation for OGP members to do so). P2: - 4 million page views over what period? Box 3: Do all of these route data through Government? Are some not 'targeted transparency' measures which obligate the private providers to publish data, but where that data is not neccesarily held by government? P12: In "C) How will an OGD intervention be implemented?" it would be useful to refer to the background conditions for different theories of change to work. For example, it mentions that consumer choice based theories of change are popular in the US, and may be useful in developing countries. Consider highlighting that this relies on there being meaningful choice between providers for the change mechanism to work effectively. p18: Box 30 - it would be better to focus on feedback loops that are relevant to open data. If we have no evidence of anyone establishing an effective OGD feedback loop then that might be worth highlighting.