The Honorable Laurie E. Locascio
Director, National Institute of Standards and Technology
100 Bureau Drive, Mail Stop 8970
Gaithersburg, MD 20899-8970
Re: Business Roundtable Response to Request for Information (RFI) Related to NIST’s Assignments Under Sections 4.1, 4.5 and 11 of the Executive Order Concerning Artificial Intelligence
Dear Dr. Locascio,
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 Institute of Standards and Technology’s (NIST) Request for Information (RFI) related to its assignments under Sections 4.1, 4.5 and 11 of the Executive Order Concerning Artificial Intelligence.
Introduction
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 to create, deliver, and improve innovative products and services. Rapid innovation and adoption of AI is transforming the nature of work across every industry and reshaping how people interact with and experience the world around them. AI technologies not only help businesses deliver smarter products and services to their customers but also have enormous potential to drive broader positive change for Americans’ health, safety and prosperity.
Our members are among the world’s largest developers and deployers of AI. Accordingly, they have a strong interest in ensuring that AI systems are developed responsibly in a manner that centers on principles of innovation, trustworthiness, transparency, privacy, safety, security, inclusion and respect for community.
Business Roundtable encourages policymakers to account for the complex, context-dependent, and rapidly evolving AI ecosystem when developing legislation, regulations, standards, and frameworks. Regarding this RFI and other work around AI, Business Roundtable encourages NIST to:
- Create effective guidelines that are broadly applicable where possible, but that can be tailored for deployment contexts and use cases, or specific types of AI (e.g., generative AI, Machine Learning, Natural Language Processing, etc.) where appropriate;
- Establish a vision for America’s role in global AI leadership and define clear goals for how to achieve it while ensuring international standards harmonization as appropriate; and
- Clarify how its work under EO 14110 relates, coordinates and overlaps with the existing work related to AI, including generative AI.
Business Roundtable applauds NIST for soliciting stakeholder comments on how to advance the discussion around responsible development and use of AI. As noted in our responses to the National Telecommunications and Information Administration’s (NTIA) Request for Comment on AI Accountability Policies, the Office of Science and Technology Policy’s (OSTP) Request for Information (RFI) on National Priorities for Artificial Intelligence, and NIST’s own RFI on the AI Risk Management Framework (RMF) Concept Paper, we believe that advancing safe and trustworthy AI is a responsibility shared between all stakeholders, including government and the private sector.
We encourage NIST to take additional ongoing input on these matters given their importance, the broad scope of the feedback requested in this RFI and the complexity of the subjects. While we understand that the deadlines in EO 14110 are ambitious and the issues at hand require urgency, we encourage NIST to complete this work carefully and to take the time that is merited.
The full letter provides comments on NIST’s three broad areas of focus in the RFI.