Comment Letter

COGR Submits Comments in Response to NSF NITRD NCO’s “RFI—Development of an Artificial Intelligence Action Plan”

The Council on Governmental Relations (COGR) submitted comments in response to the National Science Foundation’s Request for Information concerning the development of a national Artificial Intelligence (AI) Action Plan, as mandated by Executive Order 14179. Representing over 225 research universities and affiliated institutions, COGR emphasized the importance of empowering U.S. academic research organizations to advance AI research across technical, social, and ethical domains. While not addressing specific technical issues, COGR’s recommendations focused on the need for clear, consistent, and harmonized AI-related regulations and policies across all relevant federal agencies. Such alignment, they argue, would enable institutions to more efficiently comply with federal requirements by fostering unified institutional systems, training, and processes.

Furthermore, COGR advocated for the adoption of a risk-based regulatory approach within the AI Action Plan, suggesting that requirements should be specifically tailored to address well-identified risks. This calibration, they contend, would circumvent the imposition of unnecessarily burdensome regulations that could impede both the use and study of AI technologies. COGR concluded by expressing their willingness to engage further on this topic and encouraged continued dialogue to ensure effective and efficient AI policy development at the federal level.

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