Looking to the future, to effectively address the challenges arising from AI, we must foster a proactive, results-oriented, and cooperative approach with the public. Think tanks and universities can engage the public in conversations about how to work, live, govern, and co-exist with modern technologies that impact society. By involving diverse voices in the decision-making process, we can better address and resolve the complex challenges AI presents on local and national levels.
In addition, we must encourage industry and political leaders to participate in finding non-partisan, multi-sector solutions if civil societies are to remain stable. By working together, we can bridge the gap between technological advancements and their societal implications.
Finally, launching AI pilots across various sectors, such as work, education, health, law, and civil society, is essential. We must learn by doing on how we can create responsible civil environments where AIs can be developed and deployed responsibly. These initiatives can help us better understand and integrate AI into our lives, ensuring its potential is harnessed for the greater good while mitigating risks.
In 2019 and 2020, a group of fifty-two people asked the Administrative Conference of the United States (which helps guide rulemaking procedures for federal agencies), General Accounting Office, and the General Services Administration to call attention to the need to address the challenges of chatbots flooding public commenting procedures and potentially crowding out or denying services to actual humans wanting to leave a comment. We asked:
1. Does identity matter regarding who files a comment or not — and must one be a U.S. person in order to file?
2. Should agencies publish real-time counts of the number of comments received — or is it better to wait until the end of a commenting round to make all comments available, including counts?
3. Should third-party groups be able to file on behalf of someone else or not — and do agencies have the right to remove spam-like comments?
4. Should the public commenting process permit multiple comments per individual for a proceeding — and if so, how many comments from a single individual are too many? 100? 1000? More?
5. Finally, should the U.S. government itself consider, given public perceptions about potential conflicts of interest for any agency performing a public commenting process, whether it would be better to have third-party groups take responsibility for assembling comments and then filing those comments via a validated process with the government?
These same questions need pragmatic pilots that involve the public to co-explore and co-develop how we operate effectively amid these technological shifts.
As the capabilities of LLMs continue to grow, we need positive change
agents willing to tackle the messy issues at the intersection of
technology and society. The challenges are immense, but so too are the
opportunities for positive change. Let’s seize this moment to create a
better tomorrow for all. Working together, we can co-create a future that embraces AI’s potential while mitigating its risks, informed by the hard lessons we have already learned.
Full article: https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an-insiders-perspective/
Hope this helps.
Thanks for all your efforts to keep the "feedback loop" to the rulemakers functioning!_______________________________________________
I'd like to offer a suggestion for a hopefully politically acceptable way to handle the deluge, derived from my own battles with "email" over the years (decades).
Back in the 1970s, I implemented one of the first email systems on the Arpanet, under the mentorship of JCR Licklider, who had been pursuing his vision of a "Galactic Network" at ARPA and MIT. One of the things we discovered was the significance of anonymity. At the time, anonymity was forbidden on the Arpanet; you needed an account on some computer, protected by passwords, in order to legitimately use the network. The mechanisms were crude and easily broken, but the principle applied.
Over the years, that principle has been forgotten, and the right to be anonymous has become entrenched. But many uses of the network, and needs of its users, demand accountability, so all sorts of mechanisms have been pasted on top of the network to provide ways to judge user identity. Banks, medical services, governments, and businesses all demand some way of proving your identity, with passwords, various schemes of 2FA, VPNs, or other such technology, with varying degrees of protection. It is still possible to be anonymous on the net, but many things you do require you to prove, to some extent, who you are.
So, my suggestion for handling the deluge of "comments" is:
1/ create some mechanism for "registering" your intent to submit a comment. Make it hard for bots to register. Perhaps you can leverage the work of various partners, e.g., ISPs, retailers, government agencies, financial institutions, of others who already have some way of identifying their users.
2/ Also make registration optional - anyone can still submit comments anonymously if they choose.
3/ for "registered commenters", provide a way to "edit" your previous comment - i.e., advise that your comment is always the last one you submitted. I.E., whoever you are, you can only submit one comment, which will be the last one you submit.
4/ In the thousands of pages of comments, somehow flag the ones that are from registered commenters, visible to the people who read the comments. Even better, provide those "information consumers" with ways to sort, filter, and search through the body of comments.
This may not reduce the deluge of comments, but I'd expect it to help the lawyers and politicians keep their heads above the water.
Anonymity is an important issue for Net Neutrality too, but I'll opine about that separately.....
Jack Haverty
On 10/2/23 12:38, David Bray, PhD via Nnagain wrote:
Which gets me to my biggest concern as a non-partisan in 2023-2024, namely how LLMs might misuse and abuse the commenting process further.In some respects this is not new. The whole "notice and comment" process is a legacy process that goes back decades. And the FCC (and others) have had postcard floods of comments, mimeographed letters of comments, faxed floods of comments, and now this - which, when combined with generative AI, will be yet another flood.Second, I'll share that in what happened in 2017 (which itself was 10x what we saw in 2014) my biggest concern was and remains that a few actors attempted to flood the system with less-than-authentic comments.Greetings all and thank you Dave Taht for that very kind intro...First, I'll open with I'm a gosh-darn non-partisan, which means I swore an oath to uphold the Constitution first and serve the United States - not a specific party, tribe, or ideology. This often means, especially in today's era of 24/7 news and social media, non-partisans have to "top cover".
Both in 2014 and 2017, I asked FCC General Counsel if I could use CAPTChA to try to reduce the volume of web scrapers or bots both filing and pulling info from the Electronic Comment Filing System.
Both times I was told *no* out of concerns that they might prevent someone from filing. I asked if I could block obvious spam, defined as someone filing a comment >100 times a minute, and was similarly told no because one of those possible comments might be genuine and/or it could be an ex party filing en masse for others.
For 2017 we had to spin up 30x the number of AWS cloud instances to handle the load - and this was a flood of comments at 4am, 5am, and 6am ET at night which normally shouldn’t see such volumes. When I said there was a combination of actual humans wanting to leave comments and others who were effectively denying service to others (especially because if anyone wanted to do a batch upload of 100,000 comments or more they could submit a CSV file or a comment with 100,000 signatories) - both parties said no, that couldn’t be happening.
Until 2021 when the NY Attorney General proved that was exactly what was happening with 18m of the 23m apparently from non-authentic origin with ~9m from one side of the political aisle (and six companies) and ~9m from the other side of the political aisle (and one or more teenagers).
So with Net Neutrality back on the agenda - here’s a simple prediction, even if the volume of comments is somehow controlled, 10,000+ pages of comments produced by ChatGPT or a different LLM is both possible and probably will be done. The question is if someone includes a legitimate legal argument on page 6,517 - will FCC’s lawyers spot it and respond to it as part of the NPRM?
Hope this helps and with highest regards,
On Mon, Oct 2, 2023 at 2:15 PM Dave Taht via Nnagain <nnagain@lists.bufferbloat.net> wrote:
All:
I have spent the last several days reaching out to as many people I
know with a deep understanding of the policy and technical issues
surrounding the internet, to participate on this list. I encourage you
all to reach out on your own, especially to those that you can
constructively and civilly disagree with, and hopefully work with, to
establish technical steps forward. Quite a few have joined silently!
So far, 168 people have joined!
Please welcome Dr David Bray[1], a self-described "human flack jacket"
who, in the last NN debate, stood up for the non -partisan FCC IT team
that successfully kept the system up 99.4% of the time despite the
comment floods and network abuses from all sides. He has shared with
me privately many sad (and some hilarious!) stories of that era, and I
do kind of hope now, that some of that history surfaces, and we can
learn from it.
Thank you very much, David, for putting down your painful memories[2],
and agreeing to join here. There is a lot to tackle here, going
forward.
[1] https://www.stimson.org/ppl/david-bray/
[2] "Pain shared is reduced. Joy shared, increased." - Spider Robinson
--
Oct 30: https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html
Dave Täht CSO, LibreQos
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