Response to NTIA Request for Comment on AI Accountability

On behalf of The Leadership Conference on Civil and Human Rights (The Leadership Conference) and its Media/Telecommunications Task Force, we write in response to the National Telecommunications and Infrastructure Administration’s (NTIA) Notice of AI Accountability Policy Request for Comment. We appreciate NTIA’s continued commitment to protecting the public in the age of rapidly emerging new technologies. As we wrote in our response to NTIA’s Request for Comments (RFC) on Privacy, Equity, and Civil Rights, we are encouraged by NTIA’s leadership in advancing the Biden administration’s goal of ensuring that the use of AI, and policies regulating the technology, are centered on equity and civil rights, including through the implementation of the AI Bill of Rights.3 These comments build upon those The Leadership Conference submitted in the Privacy, Equity, and Civil Rights RFC. We agree with NTIA’s and the administration’s view that for AI systems to be trustworthy, it is essential to “hold entities accountable for developing, using, and continuously improving the quality” of those systems to realize their benefits and reduce harm.