Request for Information on the Development of an Artificial Intelligence (AI) Action Plan

Summary (from OSTP)

"On January 23, 2025, President Trump signed Executive Order 14179 (Removing Barriers to American Leadership in Artificial Intelligence) to establish U.S. policy for sustaining and enhancing America's AI dominance in order to promote human flourishing, economic competitiveness, and national security. This Order directs the development of an AI Action Plan to advance America's AI leadership, in a process led by the Assistant to the President for Science and Technology, the White House AI and Crypto Czar, and the National Security Advisor.

 

"This Order follows the President's January 20, 2025, Executive Order 14148, revocation of the Biden-Harris AI Executive Order 14110 of October 30, 2023 (Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence), which hampered the private sector's ability to innovate in AI by imposing burdensome government requirements restricting private sector AI development and deployment. The Trump Administration recognizes that with the right government policies, the United States can solidify its position as the leader in AI and secure a brighter future for all Americans.

 

"OSTP seeks input on the highest priority policy actions that should be in the new AI Action Plan. Responses can address any relevant AI policy topic, including but not limited to: hardware and chips, data centers, energy consumption and efficiency, model development, open source development, application and use (either in the private sector or by government), explainability and assurance of AI model outputs, cybersecurity, data privacy and security throughout the lifecycle of AI system development and deployment (to include security against AI model attacks), risks, regulation and governance, technical and safety standards, national security and defense, research and development, education and workforce, innovation and competition, intellectual property, procurement, international collaboration, and export controls. Respondents are encouraged to suggest concrete AI policy actions needed to address the topics raised.

 

"Comments received will be taken into consideration in the development of the AI Action Plan."

Relevant Executive Orders and Memos

CAIDP encourages commentators to learn about the Executive Orders and OMB Memos issued by prior administrations.

  • The White House, EO - Maintaining American Leadership in AI (2019)
  • The White House, EO - Promoting the Use of Trustworthy AI in  the Federal Government (2020) (Section 3)
  • OMB Memo, Guidance for Regulation of AI Systems (2021)
  • The White House, EO - Safe, Secure, and Trustworthy Development and Use of AI (2023)
  • OMB Memo, Advancing Governance, Innovation, and Risk Management for  
  • Agency Use of AI (2024)
  • OMB Memo, Advancing the Responsible Acquisition of AI in Government (2024)
  • The White House, EO – Removing Barriers to American Leadership in AI (2025)

CAIDP's View

 

The Center for AI and Digital Policy supports the Request for Information concerning Development of an Artificial Intelligence (AI) Action Plan, announced by the Office of Science and Technology Policy on February 6, 2025. CAIDP has outlined 10 Key Recommendations, and intends to submit comments. In advance of the deadline, we offer several recommendations to commentators.

 

Advice to Commentators

  • Read carefully the Request for Information. Understand the context and the type of information that the OSTP is seeking from the public. 
  • Learn about the prior work on AI policy. Both the Trump and Biden administrations have issued important Executive Orders on AI and OMB guidance for the use of AI systems in the federal government as well as policies for the procurement of AI systems.
  • Follow the instructions. Provide only one response. 15 pages max. Include the name/organization of the person filing the comment. Note that all comments will be publicly acessible. Do not provide any informatin in the comment you do not want to be made public.
  • Write clearly and directly. Short, simple statements are often the most effective.
  • Provide evidence. If you make a factual claim, include a citation to a report, article, or study to support your point.
  • Make concrete recommendations. If you have a specific recommendation for the AI Action Plan, state it.
  • Keep a copy of your comments. Managing the federal portal for agency comments is not easy. The best strategy is often to prepare your comments in advance and then cut and past the sections into the form.
  • Meet the Deadline. Comments must be received by March 15, 2025.
  • Evaluate the outcome. You were asked by a public agency for your views. You took time to prepare a response. You should expect the agency to consider your comments. The agency may not agree with you, but you are entitled to a "reasoned response" to your recommendations.

Good luck!

 

(If you need assistance with comments, please reach out to CAIDP (info@caidp.org). Put "Help with RFI" in subject line).

 

CAIDP's Recommendations

Here are the key points the Center for AI and Digital Policy set out for the AI Action Plan.

  1. AI innovation. Encourage the development of innovative AI systems that are less energy dependent and less data intensive.
  2. American Leadership. Maintain American leadership in global AI Policy and ratify the US-sponsored AI Convention for freedom, human rights, and the rule of law.
  3. AI Safety Standards. Fully fund the AI Safety Institute and ensure US leadership in international standards for the safe deployment of AI systems that promote human flourishing.
  4. Procurement. Carry forward the OMB Memo on AI acquisition and ensure accountability, managing risk and assessing performance.
  5. Human-centric AI. Ensure that human roles and responsibilities are clearly defined, and appropriately assigned for the design, development, acquisition, and use of AI.
  6. Public Safety. Protect the safety of Americans and ensure that dangerous AI systems are not deployed by the federal government or the private sector.
  7. Rights Protections. Protect the rights of Americans and ensure that AI systems that violate the American values of privacy, civil liberties, and civil rights, are not deployed by the federal government or the private sector.
  8. Understandable AI. Ensure that the operations and outcomes of AI systems are sufficiently understandable by subject matter experts and users.
  9. Traceable AI. Ensure that AI systems are well documented and that inputs and outputs of particular AI systems are traceable.
  10. Algorithmic Fairness. Promote AI transparency in content-moderation and AI systems impacting the lives of Americans.