June 12, 2023
Acting Chief Counsel
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue NW, Room 4725
Washington, DC 20230
Comments of Business Roundtable RE: “AI Accountability Policy Request for Comment”
Docket No. 230407-0093
Dear Ms. Weiner:
These comments are submitted on behalf of Business Roundtable, an association of more than 200 chief executive officers (CEOs) of America’s leading companies representing every sector of the U.S. economy. Business Roundtable CEOs lead U.S.-based companies that support one in four American jobs and almost a quarter of U.S. GDP. We appreciate the opportunity to comment in response to the National Telecommunications and Information Administration’s (NTIA) Request for Comment (RFC) on Artificial Intelligence (AI) Accountability Policy.
Business Roundtable member companies across sectors—technology, communications, retail, financial services, health, public safety and security, defense, manufacturing, hospitality, insurance and others—rely on data and data-driven processes and solutions every day to create, deliver and improve innovative products and services across the United States and around the world. Rapid innovation and adoption of AI is transforming the nature of work across every industry and reshaping how people interact and experience the world around them. AI technologies not only help businesses deliver smarter products and services to their customers, but they also have enormous potential to drive broader positive change for Americans’ health, safety and prosperity.
Our members are some of the world’s largest developers, deployers and end users of AI, and accordingly they have a strong interest in ensuring that Responsible AI systems are developed and used in a manner that mitigates risks, encourages responsible innovation and earns consumer, government and public trust in order to fully realize AI’s benefits for society and the economy.
Advancing safe and trustworthy AI is a shared responsibility among stakeholders, including between government and the private sector. The Commerce Department is well positioned to advance this important federal objective, building upon and furthering voluntary standards frameworks work such as the National Institute for Standards and Technology (NIST) AI Risk Management Framework (AI RMF). We encourage NTIA to carefully consider the following key principles for AI accountability:
- AI accountability standards and methods should be tailored to the nature and degree of risk and be use case- and context-specific. Policymakers should conduct a thorough gap assessment before developing any new rules and utilize existing legal and regulatory frameworks to the extent possible.
- Some features of Responsible AI may not lend themselves to technical standards due to the speed at which AI systems and tools evolve and the broad diversity of use cases and contexts in which AI is applied.
- Accountability mechanisms should be focused on the application of AI tools rather than imposing technology-specific standards that may be incompatible across various deployment contexts or that can quickly become outdated.
- Any AI accountability approaches should include clear definitions with case study examples informed by continued dialogue with industry stakeholders.
These overarching principles, along with our Responsible AI Roadmap and approach to AI accountability, are underpinned by three foundational tenets we believe apply to all AI accountability efforts: that AI systems are trusted and inclusive; effective, safe and secure; and underpinned by accountable governance.
There is no single approach or simple prescription for how to achieve the objectives of Responsible AI. Rather, each organization should endeavor to implement AI safeguards that are best suited to potential risks within the context of its own industry, use cases and existing regulatory frameworks.