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MITRE’s Response to the NIST RFI on a National Standards Strategy for Critical and Emerging Technology

MITRE’s data-driven responses to a NIST-led inquiry requesting input into development of an implementation plan for the U.S. Government National Standards Strategy for Critical and Emerging Technology.

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What’s the issue? The National Standards Strategy for Critical and Emerging Technology (NSSCET) outlines how the U.S. Government will strengthen U.S. leadership and competitiveness in international standards development, with a focus on critical and emerging technology(ies) (CET). The U.S. Government, via NIST, sought information to support the development of an implementation plan for the NSSCET.

What did we do? The Center for Data-Driven Policy led a cross-MITRE analysis of the RFI’s posed questions, seeking to uncover data and evidence (from our work in the public interest) that would help the White House understand opportunities and develop plans that are evidence-based, actionable, and effective.

What did we find? MITRE commends the development of the NSSCET and its implementation plan. We do, however, recognize that the current RFI poses questions that are very detailed in nature compared to the high-level scope of the NSSCET. We suggest a stronger focus on the important intermediate space between the overarching strategy and these finer details. Doing so will help ensure a systematic and comprehensive approach to achieving the NSSCET’s goals, rather than merely undertaking a collection of generally supportive activities.

The optimal approach to standards work must account for the unique characteristics, maturity, industry context, and regulatory environment of each critical technology. An NSSCET implementation plan that is too technology agnostic (which the RFI questions imply) could become a hindrance to progress.

Strategically timing standards activities is key to both accelerating the advancement of a technology and ensuring its proper use. By aligning the standardization process with the technology’s maturity and industry readiness, stakeholders can effectively create an environment that fosters innovation, collaboration, and adoption of the technology.

The federal government has developed and collaboratively implemented a standards strategy on a CET before, which provides lessons learned for this NSSCET effort. Key insights from prior work is provided in MITRE's response.