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“Yes, but how do I submit a comment on how unintuitive the comment submission process is?”

OSTP RFC

I’m smashblogging on a Saturday because I came across this story on FedScoop: https://fedscoop.com/white-house-launches-public-consultation-on-critical-ai-issues/ which discusses the Biden Administration’s Office of Science and Technology Policy’s launch of a public request for comment on their upcoming AI policy work. I wanted to Say A Few Words.

The story does not contain a link to the actual request itself.

So unnamed senior government sources that I angrytexted (they also noted the complexity of finding this) found this link here: https://www.federalregister.gov/documents/2023/05/26/2023-11346/request-for-information-national-priorities-for-artificial-intelligence. Oh, says I. So intuitive. So clear to all Americans that obviously some place called Federal Register is where that request for public comment would be. So I check it out, and actually, there’s a link in that document that says I have to go to regulations.gov. I hit that link and guess what: it takes me to regulations.gov. No link to the actual thing I’m looking for. But there’s a search bar. Masochistically, I type in “ai” which, obviously, nets me literally-literally 51,704 results.

I take a stab in the dark; I’m a nerd, and perhaps the document I’m looking for has some form of unique identifier. So I try a search instead by the document number on https://www.regulations.gov/search?filter=2023-11346.

Aha. There it is: https://www.regulations.gov/document/OSTP-TECH-2023-0007-0001

Lo, our journey has ended. I’m annoyed, but this is apparently the site you should go to in order to find any public calls for comment on proposed government regulations. Importantly, I did find the call for comment. It was on display in the bottom of a locked filing cabinet stuck in a disused lavatory with a sign on the door saying ‘Beware of the Leopard’.”

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But could I have found it another way? Normal humans might try searching “ai” or “artificial intelligence”; what would their experience be like?

Maybe after searching “ai” the “Only show documents open for comment” checkbox filter will get me somewhere?

Ooo, the top result looks promising; looks like the NTIA wants some AI accountability. https://www.regulations.gov/document/NTIA-2023-0005-0001. Cool, but that’s not what I’m looking for.

Aha, the third one down is what I’m looking for. Obviously these are not ordered in any human logic, as the top result was from April 12th and the one I want is from May 25th. Fine. I’m steeped in Lovecraftian lore and that gives me an automatic Good Result to my “Find Hidden Item On Government Website” roll.

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Well, I certainly have some thoughts NOW. *cracks knuckles.*

Again, here’s the link to tell the OSTP and White House what you think of their upcoming AI policy. https://www.regulations.gov/commenton/OSTP-TECH-2023-0007-0001

post script: I wanted to go tell someone how difficult it was to get from any entry point a normal human would have to try to comment on public policy (usually it would be some kind of news story or a link on a social media site) to actually finding the relevant policy. At minimum, when government agencies post an RFC on their sites, it should link directly to the RFC on regulations.gov. I went down a rabbithole and found that to complain to any government agency, you’re supposed to contact their Inspector General office. Turns out that regulations.gov is run by the General Services Administration, and their site is at https://www.gsaig.gov/hotline. Unfortunately, they only seem to investigate claims of misbehavior or fraud regarding government employees. There’s no place I can find to tell them that the UX on regulations.gov could use some love to get to a place where it’s usable for normal humans. But hey, here’s an email address! I’m going to send them this blog post and also a thank you for all they do regardless. There’s (hopefully) a human on the other end of this email, even if they don’t personally have any power to fix the UX, they might know someone who does. Good luck to you! OIG_PublicAffairs@gsaig.gov.

Turns out the real treasure was the new ways to provide detailed and exhaustive technical comments to the Federal government I found along the way.

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