A version of this comment was submitted to the National Telecommunications and Information Administration on March 26, 2024.
Generative AI models entered widespread public awareness following the release of OpenAI’s first public version of ChatGPT in late 2022. Open-foundation AI models with publicly available weights, a particular category of generative AI model explained below, allow greater or full access to model inputs so that others may use them to customize or create applications.
The National Telecommunications and Information Administration (NTIA) is not a policymaking body but will issue an advisory report to the president on potential policy in this area. In the thus far limited public debate, some have proposed preemptive measures to limit the openness of AI foundation models or their proliferation.
Our comment discusses several of the questions posed by the NTIA. We argue that allowing model developers to freely choose and innovate along dimensions of openness may be indispensable in realizing many of the technology’s benefits, without any evidence of specific risks over and above those of more closed approaches.
The NTIA should not recommend a policy to restrict open-foundation AI models with publicly available weights at this time.
Full Comment to the National Telecommunications and Information Administration