The Center for Democracy & Technology (CDT) has submitted comments to the National Telecommunications and Information Administration (NTIA) in response to a Request for Comment regarding the risks and benefits of "open foundation models." This submission is part of a proceeding mandated by section 4.6 of the U.S. Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence.
In their submission, the CDT emphasized the importance of considering the potential policy approaches to these models and how they should be regulated. The CDT's perspective aims to guide the NTIA in advising the President on the appropriate steps to take concerning open foundation models.
The CDT's comments are based on a joint letter sent to the Commerce Department, which included input from various civil society organizations and academic scholars. The letter highlighted the significant benefits that open foundation models can offer, drawing parallels to the history of open source software and recent advancements in AI technology.
Furthermore, the CDT's submission delves into the risks associated with open foundation models compared to closed models and other technologies. It underscores the need for more in-depth research to understand specific risks and develop effective solutions.
In addressing policy approaches to open foundation models, the CDT suggests that the government should support activities that establish best practices in the field and norms around the associated risks. Additionally, the CDT mentions the importance of aligning policy interventions with the constraints of the First Amendment.
The CDT's comprehensive comments shed light on the complexities surrounding open foundation models and the considerations that need to be taken into account when regulating them.
