From mboxrd@z Thu Jan 1 00:00:00 1970 Return-Path: Received: from mail-ej1-x635.google.com (mail-ej1-x635.google.com [IPv6:2a00:1450:4864:20::635]) (using TLSv1.2 with cipher ECDHE-RSA-AES128-GCM-SHA256 (128/128 bits)) (No client certificate requested) by lists.bufferbloat.net (Postfix) with ESMTPS id 54D553B29D for ; Tue, 12 Mar 2024 10:36:25 -0400 (EDT) Received: by mail-ej1-x635.google.com with SMTP id a640c23a62f3a-a45ecef71deso495916066b.2 for ; Tue, 12 Mar 2024 07:36:25 -0700 (PDT) DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=gmail.com; s=20230601; t=1710254183; x=1710858983; darn=lists.bufferbloat.net; h=cc:to:subject:message-id:date:from:in-reply-to:references :mime-version:from:to:cc:subject:date:message-id:reply-to; bh=OEXI6QdLMfG0HdTDldpcTh7CXmfQmfiKNihL5R1War8=; b=jx1s2dcrBwTMIYn0S3sH1Z1Q3OnU4C5494gc3FRgA5bjwcD/kpHzc0kFCVA25+H9C3 GMNpF5R179c3W3MR0XQybyKXmlZ8XoI8EX15ohJcvJ67v2DBI5qbbzCYzoBB4OIkI5Xa vbNywII6QW1xJ64PpngfVpWisR/NfeNYsJwM6qRtwVai2ILq+n8LAOvB+qNEQoPIobJZ eQd/lMZlFOMQCh1nATeQmjbhAaCY56mLpJof/xEt4rMVdPRfjoh028YYRXKz+OwBERlj ZFGwcPytC4XuPDFMbIpq7LO2m3IoGzNbxDccGCG0WzBjbf8xvtwhVnWBel6fK4kF23WY NhZA== X-Google-DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=1e100.net; s=20230601; t=1710254183; x=1710858983; h=cc:to:subject:message-id:date:from:in-reply-to:references :mime-version:x-gm-message-state:from:to:cc:subject:date:message-id :reply-to; bh=OEXI6QdLMfG0HdTDldpcTh7CXmfQmfiKNihL5R1War8=; b=HMFAI6zkPZtFo2k6kg2Ci6LNk68k0qXPeODIFll2WOO73bOw0y3U+VAmxvNPbzLLyA cA9C4e/5UhnmMxUzw3Nhh5CTtS7XcNrY476FSnGcs4fGzvJVop/u2vj7gFiks0IsCqZ5 En6KvGMiSoJZ13i6cQEZmJ/ynBCGnhdc2On5fMn4hx7C+xwoWIu+2GYqmNGHinJ7ETet WldrplloaxTtZ+wfAVFjndoB1WcGhTnQofJpz2gQVvFhSchpQzVJibssFMnX7TkozXf5 v7Uc8C74tt8O80lQBBCOHcRoV2QhmjigITHCazgRIDmroAEbKyD+6GYrQz+zMGsR2zQg Mv0w== X-Gm-Message-State: AOJu0Ywk8KSGHlI/VVHq6U6GrhZpikw+z9sYwxPzeeZpzI4YTO13TafM SWelfPUprfil5sZrXOAdUL3uY32exJ5duxmkG9kEyXr6MiXIzcAYKA4dZfuidMZho3/kqj+at/z fk3GbL5A1o/DRwzhzT1/5mtjKNYEjf+4FrdU= X-Google-Smtp-Source: AGHT+IEOzrqUCA/p3edDX3T8aSl2joWZcW90gjtbv9/bpSkJEBO8Rtl+XjU/Q87N/wYRXqh8CrtU6WML6OJ+d8xg9Po= X-Received: by 2002:a17:906:b04:b0:a46:4940:9819 with SMTP id u4-20020a1709060b0400b00a4649409819mr1016611ejg.53.1710254182601; Tue, 12 Mar 2024 07:36:22 -0700 (PDT) MIME-Version: 1.0 References: In-Reply-To: From: "David Bray, PhD" Date: Tue, 12 Mar 2024 10:35:43 -0400 Message-ID: To: =?UTF-8?Q?Network_Neutrality_is_back=21_Let=C2=B4s_make_the_technical_asp?= =?UTF-8?Q?ects_heard_this_time=21?= Content-Type: multipart/alternative; boundary="00000000000007987b06137795d4" Subject: Re: [NNagain] new FCC intergovernmental advisory committee X-BeenThere: nnagain@lists.bufferbloat.net X-Mailman-Version: 2.1.20 Precedence: list List-Id: =?utf-8?q?Network_Neutrality_is_back!_Let=C2=B4s_make_the_technical_aspects_heard_this_time!?= List-Unsubscribe: , List-Archive: List-Post: List-Help: List-Subscribe: , X-List-Received-Date: Tue, 12 Mar 2024 14:36:25 -0000 --00000000000007987b06137795d4 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Relating to that quote https://regulatorystudies.columbian.gwu.edu/summary-discussing-applications= -generative-ai-rule-development-and-evaluation [snippet] "... First, agencies use different approaches when addressing AI-generated comments, with consequential results. The Federal Communication Commission=E2=80=99s (FCC) Electronic Comment Filing System and the General Services Administration=E2=80=99s (GSA) eRulemaking program (which is used by dozens of federal agencies as a shared service) represent the two broad strokes of public commenting processes. Participants discussed how back in the mid-2010s different government agencies experienced spikes in what appeared to be a mixture of human- and bot-submitted public comments, although an exceedingly small number of rulemaking efforts saw more than 10,000 comments. A 2021 analysis of a spike in public comments impacting the Environmental Protection Agency observed that =E2=80=9Cthe 2002 E-Government Act did not anticipate the emergence of bots= and thus fails to provide agencies with sufficient guidance on how to identify and treat bots and fake comments.=E2=80=9D Participants observed that the FCC had legally interpreted the Administrative Procedure Act (APA) of 1946 and related policies in a manner that effectively gave senior management less discretion to address the risk of comment surges =E2=80=93 and precluded the FCC from being able to adopt = the GSA=E2=80=99s eRulemaking program. During the mid-2010s, the then-CIO had a= ttempted to make the case for the FCC to adopt the eRulemaking program and not succeeded. This stemmed from the FCC=E2=80=99s interpretations of the APA t= hat prioritized real-time viewing of comments rather than waiting to post submissions until they are processed, acceptance of all comments even if they were perceived as potential spam, allowance of anonymous comments or comments with no identification checks, a reluctance to use CAPTCHA, and a strong push by external parties for the ability to submit comments in bulk. While the FCC=E2=80=99s legacy Electronic Comment Filing System eventually moved = to a cloud-based service that included API rate limits for comment submissions, it employed a GSA service that before 2017 did not monitor API key requests for multiple registrations. After 2017, GSA=E2=80=99s public-facing platform, located at regulations.gov , successfully implemented techniques such as CAPTCHA and API rate limits to mitigate the risk of being overwhelmed by automated submissions. The FCC since 2017 has made some adjustments too. Participants also discussed how the 2017 net neutrality rulemaking demonstrated that the FCC=E2=80=99s interpretations of the APA made it tech= nically at risk of astroturfing =E2=80=93 defined as organized activity that falsely attempts to pass itself off as a grassroots movement. The Commission=E2=80= =99s proposal received nearly 23 million comments in 2017, requiring the FCC to scale its cloud-based systems more than 3,000 percent to address the flood of comments. In 2021, the New York Attorney General identified at least 18 million of these comments as not authentic. Since 2017, regulations.gov has not experienced the same issues, although some rulemakings routinely receive large volumes of mass submissions (though none that approach the scale of 23 million comments). Comparing different legal interpretations of the APA and the downstream impact on technical implementations highlighted how policy decisions may prevent the commenting process from being overwhelmed by bots or generative AI submissions. ..." On Tue, Mar 12, 2024 at 10:27=E2=80=AFAM Frantisek Borsik via Nnagain < nnagain@lists.bufferbloat.net> wrote: > Paul Baran 1994: "The FCC has a few very good technical people, but > they're totally outnumbered by the lawyers." > https://www.eff.org/pages/false-scarcity-baran-cngn-94 > > All the best, > > Frank > > Frantisek (Frank) Borsik > > > > https://www.linkedin.com/in/frantisekborsik > > Signal, Telegram, WhatsApp: +421919416714 > > iMessage, mobile: +420775230885 > > Skype: casioa5302ca > > frantisek.borsik@gmail.com > > > On Tue, Mar 12, 2024 at 3:06=E2=80=AFPM Dave Taht via Nnagain < > nnagain@lists.bufferbloat.net> wrote: > >> not an obvious technologist to be seen... >> >> >> https://www.fcc.gov/general/intergovernmental-advisory-committee-current= -members >> >> -- >> https://www.youtube.com/watch?v=3DN0Tmvv5jJKs Epik Mellon Podcast >> Dave T=C3=A4ht CSO, LibreQos >> _______________________________________________ >> Nnagain mailing list >> Nnagain@lists.bufferbloat.net >> https://lists.bufferbloat.net/listinfo/nnagain >> > _______________________________________________ > Nnagain mailing list > Nnagain@lists.bufferbloat.net > https://lists.bufferbloat.net/listinfo/nnagain > --00000000000007987b06137795d4 Content-Type: text/html; charset="UTF-8" Content-Transfer-Encoding: quoted-printable

[snippet] "...=20

First, agencies use different approaches when addressing AI-generated comments, with consequential results. The Federal Communication=20 Commission=E2=80=99s (FCC) Electronic Comment Filing Sys= tem and the General Services Administration=E2=80=99s (GSA) eRulemaking program (which is used by dozens of federal agencies as a shared service)=20 represent the two broad strokes of public commenting processes.=20 Participants discussed how back in the mid-2010s different government=20 agencies experienced spikes in what appeared to be a mixture of human-=20 and bot-submitted public comments, although an exceedingly small number=20 of rulemaking efforts saw more than 10,000 comments. A 2021 analysis of a spike in public comments impacting the Environmental Protection Agency observed that =E2=80=9Cthe 2002 E-Government Act did not anticipate the emergence o= f=20 bots and thus fails to provide agencies with sufficient guidance on how=20 to identify and treat bots and fake comments.=E2=80=9D

Participants observed th= at the FCC had legally interpreted the=20 Administrative Procedure Act (APA) of 1946 and related policies in a=20 manner that effectively gave senior management less discretion to=20 address the risk of comment surges =E2=80=93 and precluded the FCC from bei= ng=20 able to adopt the GSA=E2=80=99s eRulemaking program. During the mid-= 2010s, the=20 then-CIO had attempted to make the case for the FCC to adopt the=20 eRulemaking program and not succeeded. This stemmed from the FCC=E2=80=99s=20 interpretations of the APA that prioritized real-time viewing of=20 comments rather than waiting to post submissions until they are=20 processed, acceptance of all comments even if they were perceived as=20 potential spam, allowance of anonymous comments or comments with no=20 identification checks, a reluctance to use CAPTCHA, and a strong push by external parties for the ability to submit comments in bulk. While = the=20 FCC=E2=80=99s legacy Electronic Comment Filing System eventually moved to a= cloud-based service that included API rate limits for comment submissions, it employed a=20 GSA service that before 2017 did not monitor API key requests for=20 multiple registrations. After 2017, GSA=E2=80=99s public-facing platform,= =20 located at regulations.gov, successfully implemented techniques such as= CAPTCHA and API rate limits to mitigate= the risk of being overwhelmed by automated submissions. The FCC since 2017= has made some adjustments too.

Participants also discussed how the 2017 net neutrality rulemaking=20 demonstrated that the FCC= =E2=80=99s interpretations of the APA made it=20 technically at risk of astroturfing <= /span>=E2=80=93 defined as organized activity that falsely attempts to pass itself off as a grassroots movement. The=20 Commission=E2=80=99s proposal received nearly 23 million comments in 2017,= =20 requiring the FCC to scale its cloud-based systems more than 3,000=20 percent to address the flood of comments. In 2021, the New York Attorney General identified at least 18 million of these comments= as not authentic. Since 2017, regulatio= ns.gov has not experienced the same issues, although some rulemakings routinely receive large volumes of mass submissions (though none that=20 approach the scale of 23 million comments). Comparing different legal=20 interpretations of the APA and the downstream impact on technical=20 implementations highlighted how policy decisions may prevent the=20 commenting process from being overwhelmed by bots or generative AI=20 submissions.


..."

On Tue, Mar 12, 2024 at 10:27=E2=80=AFAM Frantisek B= orsik via Nnagain <nnag= ain@lists.bufferbloat.net> wrote:
Paul Baran 1994: "The FCC has a few very= good technical people, but they're totally outnumbered by the lawyers.= "

All the best,

Frank

Frantisek (Frank) Borsik

=C2=A0<= /u>

https://www.linkedin.com/in/frantisekborsik

Signal, Telegram,= WhatsApp: +421919416714=C2=A0

iMessage, mobile: +420775230885

=

Skype: casioa5302ca=

frantisek.borsik@gmail.com



On Tue, Mar 12,= 2024 at 3:06=E2=80=AFPM Dave Taht via Nnagain <nnagain@lists.bufferbloat.net> wrote:
not= an obvious technologist to be seen...

https://www.fcc.gov/= general/intergovernmental-advisory-committee-current-members

--
https://www.youtube.com/watch?v=3DN0Tmvv5jJKs Epik = Mellon Podcast
Dave T=C3=A4ht CSO, LibreQos
_______________________________________________
Nnagain mailing list
Nnagain@= lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain
_______________________________________________
Nnagain mailing list
Nnagain@= lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain
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