Why consequential? To begin with, one could count on one hand the occasions upon which the federal government has undertaken an assessment of the efficacy of the ill-defined public-private partnership that constitutes the U.S. standards development infrastructure. And yet, since the passage of the Technology Transfer and Advancement Act of 1995, the government has by law put almost all of its standards-related eggs in that single basket.
It is also consequential because the decision to issue the RFI reflects the recognition by policy makers that our existing standards development process, both on the public as well as the private side, was never designed to address challenges that involve multiple industry sectors. Indeed, the United States Standards Strategy, developed by representatives of government, industry, standards developing organizations, consortia, consumer groups, and academia, stresses that the development of standards can best be addressed through a “sectoral approach,” and calls upon “Stakeholders in the U.S. standards system[to] seek … to reinforce the sectoral approach to standards development in regional and international forums and highlight the benefits of this approach.”
Finally, it is consequential because the success of many of the current administration’s signature policies, including the deployment of the SmartGrid and Electronic Health Records (EHRs), and urgent defense imperatives, such as ensuring cybersecurity, represent extremely complex cross-sectoral challenges. The achievement of these policy goals must therefore depend on whether our current public-private process can create new standards development methodologies on the fly.
The emergence of challenges such as these should not surprise, given our increasingly total reliance on nationally and globally networked information technology systems. Rather, these are but the first of what will be an ongoing stream of ambitious standards-dependent initiatives that will need to be rapidly and efficiently pursued if our nation is to remain prosperous, competitive and secure.
There are two ways in which the private sector can respond to this RFI. The first, and more predictable of the two, is to once again parrot the oft-repeated virtues of the “bottom up” standards development process that has predominated in this country for more than 100 years, contending that this system is more than adequate to meet the needs of the future without government interference. If this is the sole response, the result will be an enormously regrettable lost opportunity that will work to the great detriment of industry and consumers alike.
The second would be to embrace the formation of the Sub-Committee and the issuance of the RFI as a rare and important chance to work with government to further the national interest. The goal should be to develop the kind of new methodologies, structures and synergies that can enable government to execute policy in the most cost-effective and rapid fashion while ensuring that American industry can innovate as nimbly and competitively as possible.
Far too often in the past, the private sector has presented a united front in opposition to any and every standards-related collaborative overture that government has offered. Indeed, when Congressman Bart Gordon, Chair of the House Committee on Science and Technology, solicited input in October of 2009 on whether “a comprehensive review of our standards-setting process is timely and worthwhile,” the overwhelming industry response was “no.”
While it is true that the current infrastructure serves most needs very well, that does not mean that it is adequate to all of the demands of the future, or even of the cross-sectoral needs of the present. To pretend otherwise suggests a reflexive desire to defend the status quo from greater government involvement than to seek real solutions to important emerging challenges.
Concerns over an augmented government role in standards development would appear in any event to be ill-founded. In the case of the SmartGrid and EHRs, the current administration has acted to catalyze and enable private sector action rather than to compel specific technical approaches or to thrust government bureaucrats into the standards development process. Substantial resources and incentives have been provided to inspire private industry to work with NIST to make rapid progress in both areas – and rapid progress has been made. Absent these supportive efforts, it is difficult to conceive how either initiative could have proceeded past the discussion phase in the same period of time.
In fact, the scope and thrust of both the Charter of the Sub-Committee and the RFI are respectful of the private sector as well as the existing standards development infrastructure. Indeed, if there is a criticism to be leveled at the RFI, it would be that it is more deferential, retrospective, and tentative than forward looking and visionary. Its stated goal is simply to gather information on what to date has worked and what has not, so that these learnings can be reflected in best practices documents intended to guide future government participation in the standards development process.
Private sector companies, as well as the ANSI accredited standards developers and consortia in which they participate, should embrace the RFI and view it as the golden opportunity that it is. If they do, they can recruit the talent, resources and procurement might of the federal government in support of a much-needed optimization of the United States standards development infrastructure.
There is nothing to lose and much to gain from such an effort, from reenergizing U.S. manufacturing and jobs creation to protecting national security from cybersecurity attacks.
Will you be part of the solution, or a champion of the status quo? I hope that you opt for the former, and offer your experiences, your creativity and your support before February 7, the deadline for submissions.
You can learn more about the RFI and submit comments in response here