Comment by Brad Smith

Although developers like Microsoft are addressing these risks through rigorous testing and selfimposed standards, the risks involved are too important, and their scale and potential impacts at present too unknowable, to address them through self-regulation alone. We therefore think it is appropriate for Congress to consider legislation that would impose a licensing regime onto developers of this discrete class of highly capable, frontier AI models, and we are pleased to see that the Blumenthal-Hawley regulatory framework seeks to establish such a regime. Although the details of this licensing regime again would benefit from further thought and discussion, and there are critical consequences and details to deeply consider, such as the impact to open source models and the importance of continuing to foster an innovative open source ecosystem, we think it should seek to serve three key goals: First and foremost, any licensing regime must ensure that the development and deployment of highly capable AI models achieve defined safety and security objectives. In concrete terms, this may require licensees of these models, among other things, to engage in the pre-deployment testing that the Blumenthal-Hawley regulatory framework proposes. We agree that highly capable models may need to undertake extensive prerelease testing by internal and external experts. In addition, a licensing regime may require developers of highly capable models to provide advance notification of large training runs; engage in comprehensive risk assessments focused on identifying dangerous or breakthrough capabilities; and implement multiple other checkpoints along the way. Second, it must establish a framework for close coordination and information sharing between licensees and regulators, to ensure that developments material to the achievement of safety and security objectives are shared and acted on in a timely fashion. The Blumenthal-Hawley framework provides that an independent oversight body not only conducts audits but also monitors technological developments, which may be best accomplished in partnership with licensees. AI Verified source (2023)