The Center for Security and Emerging Technology (CSET) at Georgetown University offers the following comments to Commerce Department in response to the AI and Open Government Data Assets Request for Information.

CSET supports Commerce’s efforts to advance public data accessibility, quality, and transparency. We encourage Commerce to consider existing standards, tools, and best practices for making data usable by humans, as they go hand-in-hand with making data AI-ready. To that end, we encourage Commerce to:

• Leverage existing platforms, forums, and dissemination practices (e.g. GitHub, Zenodo)

• Prioritize clear, understandable, comprehensive data documentation (e.g. data cards)

• Align data assets with existing tools and data sets, including incorporating open organization identifiers and existing occupational codes (e.g. ROR, SOC)

These priorities will help make data usable, ensure accuracy, foster responsible use, and mitigate bias. These priorities also enable consistency and data linkage, two critical data features for human use and AI applications.

CSET has published two Data Snapshots that offer relevant suggestions on the topic of using open Commerce data for analysis. Please see BIS Best Data Practices: Part 1 and BIS Best Data Practices: Part 2.