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Responses to OMB's Request for Comment on Draft Policy Guidance on Agency Use of AI

HAI Senior Fellows Daniel Ho and Percy Liang, joined by current and former leaders of technology governance and federal agencies, submitted two responses to the Office of Management and Budget’s (OMB) Request for Comment on a draft policy guidance on Advancing Governance, Innovation, and Risk Management for Agency Use of AI, issued in response to President Biden’s Executive Order on AI.


Response from Stanford RegLab

Mariano-Florentino Cuéllar, Daniel E. Ho, Jennifer Pahlka, Amy Perez, Kit Rodolfa, Gerald Ray

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This response urges tailored solutions to AI regulation and offers suggestions for distinguishing between AI risk profiles to avoid further widening the gap between public and private sector capabilities. HAI Senior Fellow Daniel Ho and his co-authors also offer suggestions for adjusting the guidance to reduce the burden while maintaining AI safety, through measures such as securing data for equity assessments and building in public consultation mechanisms that do not lengthen rulemaking proceedings.

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Response from Daniel Ho, Percy Liang, and Technology Governance Leaders

Daniel E. Ho, Percy Liang, Timothy O'Reilly, Jennifer Pahlka, Todd Park, DJ Patil, Kit Rodolfa

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This response highlights the importance of open approaches to innovation for government technology. Writing in their individual capacities, HAI Senior Fellows Daniel Ho and Percy Liang alongside their co-authors argue that the OMB Memo should draw an explicit connection to established federal policy around open source and acknowledge the long-recognized benefits to open source approaches and open research environments. They emphasize that the risks of a limited set of generative AI models should not detract from an overall commitment toward an open approach to AI innovation.

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