[governance] NTIA RFC on IoT - deadline 5/23

[Joly MacFie]

[You may have heard this mentioned in
https://livestream.com/internetsociety/sotnw/videos/120095892]

https://www.ntia.doc.gov/files/ntia/publications/fr_rfc_iot_04062016.pdf

DEPARTMENT OF COMMERCE National Telecommunications and Information
Administration [Docket No. 160331306–6306–01] RIN 0660–XC024

The Benefits, Challenges, and Potential Roles for the Government in
Fostering the Advancement of the Internet of Things

AGENCY: National Telecommunications and Information Administration, U.S.
Department of Commerce.

ACTION: Notice, request for public comment.

SUMMARY: Recognizing the vital importance of the Internet to U.S.
innovation, prosperity, education, and civic and cultural life, the
Department of Commerce has made it a top priority to encourage growth of
the digital economy and ensure that the Internet remains an open platform
for innovation. Thus, as part of the Department’s Digital Economy Agenda,
the National Telecommunications and Information Administration (NTIA) is
initiating an inquiry regarding the Internet of Things (IoT) to review the
current technological and policy landscape. Through this Notice, NTIA seeks
broad input from all interested stakeholders—including the private
industry, researchers, academia, and civil society—on the potential
benefits and challenges of these technologies and what role, if any, the
U.S. Government should play in this area. After analyzing the comments, the
Department intends to issue a ‘‘green paper’’ that identifies key issues
impacting deployment of these technologies, highlights potential benefits
and challenges, and identifies possible roles for the federal government in
fostering the advancement of IoT technologies in partnership with the
private sector.

DATES: Comments are due on or before 5 p.m. Eastern Time on May 23, 2016.

ADDRESSES: Written comments may be submitted by email to iotrfc2016@
ntia.doc.gov. Comments submitted by email should be machine-readable and
should not be copy-protected. Written comments also may be submitted by
mail to the National Telecommunications and Information Administration,
U.S. Department of Commerce, 1401 Constitution Avenue NW., Room 4725, Attn:
IOT RFC 2016, Washington, DC 20230. Responders should include the name of
the person or organization filing the comment, as well as a page number on
each page of their submissions. All comments received are a part of the
public record and will generally be posted to http://
www.ntia.doc.gov/category/internetpolicy-task-force without change. All
personal identifying information (for example, name, address) voluntarily
submitted by the commenter may be publicly accessible. Do not submit
confidential business information or otherwise sensitive or protected
information. NTIA will accept anonymous comments.

FOR FURTHER INFORMATION CONTACT: Travis Hall, National Telecommunications
and Information Administration, U.S. Department of Commerce, 1401
Constitution Avenue, NW., Room 4725, Washington, DC 20230; telephone (202)
482–3522; email thall at ntia.doc.gov. Please direct media inquiries to NTIA’s
Office of Public Affairs, (202) 482–7002.

SUPPLEMENTARY INFORMATION: Background: As part of the Department of
Commerce’s Digital Economy Agenda, the National Telecommunications and
Information Administration (NTIA) is requesting comment on the benefits,
challenges, and potential roles for the government in fostering the
advancement of the Internet of Things (IoT). Description of IoT and its
Impact on the Economy: IoT is the broad umbrella term that seeks to
describe the connection of physical objects, infrastructure, and
environments to various identifiers, sensors, networks, and/or computing
capability.[1]

In practice, it also encompasses the applications and analytic capabilities
driven by getting data from, and sending instructions to, newly-digitized
devices and components. Although a number of architectures describing
different aspects or various applications of the IoT are being developed,
there is no broad consensus on exactly how the concept should be defined or
scoped. Consensus has emerged, however, that the number of connected
devices is expected to grow exponentially, and the economic impact of those
devices will increase dramatically.[2]

While some types of devices will fall into readily identifiable commercial
or public sectors in their own right—for example, implantable health
devices—most will serve the function of enabling existing industries to
better track, manage, and automate their core functions. The potential
health, safety, environmental, commercial, and other benefits of IoT are
enormous, from reducing the risk of automobile-related injuries and
fatalities to enabling micro-cell weather forecasting. IoT has the
potential to catalyze new user applications and give rise to new
industries. For example, IoT is the foundation for ‘‘Smart Cities’’
efforts, which use pervasive connectivity and data-driven technologies to
better manage resources, meet local challenges, and improve quality of
life. However, the IoT also presents challenges,[3] which in turn have
begun to generate initial thinking and policy responses both inside and
outside of government. A number of Federal agencies—for example, the
National Highway Traffic Safety Administration (NHTSA) and the Food and
Drug Administration (FDA)—have already begun grappling with potential
health, safety, and security issues arising from the connection of cars and
medical devices to the Internet.[4] The Federal Trade Commission (FTC) has
identified privacy and cybersecurity aspects of IoT, and proposed some
possible best practices.[5]

Pursuant to the White House Smart Cities Initiative, the U.S. Government is
providing $35 million in new grants and nearly $70 million in new spending
on Smart Cities across several departments.6 Additional activities at the
federal level seek to take advantage of the potential opportunities as well
as address any possible issues raised by the deployment of IoT in relation
to agency missions. IoT has also garnered interest by other national
governments, standards organizations, and intergovernmental organizations
that are interested in understanding how to engage in the IoT ecosystem to
encourage economic growth and innovation.[7] Unfortunately, country
specific strategies threaten the possibility of a global patchwork of
approaches to IoT, which would increase costs and delay the launch of new
products and services, dampening investment. The U.S. government will need
to work with stakeholders to develop industry-driven solutions; however,
thus far no U.S. government agency is taking a holistic, ecosystemwide view
that identifies opportunities and assesses risks across the digital economy.

 The Department’s Digital Economy Initiatives: More than six years ago, the
Department created the Internet Policy Task Force (IPTF) to identify and
address leading public policy and operational challenges in the Internet
ecosystem. The IPTF collaborates across bureaus at the Department, seeks
public comment, and has produced policy papers on a variety of important
topics. In recognition of the broad impact that the Internet and
digitization are having across the economy, in 2015 the Department created
the Digital Economy Leadership Team (DELT). Comprised of senior officials
from across the Department, the DELT provides highlevel guidance and
coordination, leveraging the substantial expertise within the agency to
promote initiatives that have a positive impact on the digital economy and
society. The DELT currently focuses on the four pillars of the Department’s
2015–16 Digital Economy Agenda: promoting a free and open Internet
worldwide; promoting trust and confidence online; ensuring Internet access
for workers, families, and companies; and promoting innovation in the
digital economy. Working closely together, the DELT and IPTF ensure that
the Department is helping businesses and consumers realize the potential of
the digital economy to advance growth and opportunity. Given the
cross-cutting nature of the IoT landscape, the Department of
Commerce—through the DELT and IPTF—is able to provide important perspective
and expertise on IoT. The mission of the Department is to help establish
conditions that will enable the private sector to grow the economy,
innovate, and create jobs.

The Department also has statutory authority, expertise, and ongoing work
streams in numerous areas that are critical to the development of IoT,
including: cybersecurity, privacy, cross-border data flows, spectrum,
international trade, advanced manufacturing, protection of intellectual
property, standards policy, Internet governance, big data,
entrepreneurship, and worker skills. For example:
• The Department has long standing technological and policy expertise and
experience that it is applying to IoT. The Department’s National Institute
of Standards and Technology (NIST) has coordinated the development of a
draft reference architecture for CyberPhysical Systems and is conducting a
Global City Teams Challenge to foster the development of Smart Cities and
promote interoperability. NTIA’s spectrum planning and management
activities contemplate the growth of IoT and its Institute for
Telecommunications Sciences (ITS) has begun testing the possible effects of
IoT on spectrum usage. Both NIST and NTIA have been actively engaged with
international standards bodies and international organizations on aspects
of IoT and other related areas (e.g., cybersecurity), and have been further
engaged with other Federal agencies.
• The Economic Development Administration (EDA) provides grants to
communities around the country to build up their technology-focused
innovation ecosystems in order to grow their local economies and create
jobs.
 • The U.S. Patent and Trademark Office (USPTO) continues to improve its
patent quality, especially in new technological domains, including IoT.
USPTO also plays a key role in the alignment of intellectual property
policies around the world, so that U.S. inventors of IoT technology can
have access to the protections they need to continue innovating and sell
their products and services everywhere.
 • The International Trade Administration (ITA) is an active promoter of
IoT and Smart Cities on the international stage, including participation in
the CS Europe Smart Cities Initiative and working with the other Federal
agencies to consider innovative financing mechanisms for Smart City
projects. ITA hosts roundtables on an ad hoc basis with the private sector
and federal partners to discuss Smart Cities and infrastructure financing.
In addition, ITA’s Office of Textiles and Apparel is holding a Smart
Fabrics Summit (http:// smartfabricssummit.com/) on April 11, 2016. The
Department, through this RFC and subsequent green paper, will capitalize on
the Department’s experience and holistic economic perspective to craft an
approach to IoT and its potential impacts that will best foster IoT
innovation and growth. Where relevant, comments received may also inform
the work of other federal initiatives, such as the recently created
Commission on Enhancing National Cybersecurity.

Request for Comment: Instructions for Commenters:
The Department invites comment on the full range of issues that may be
presented by this inquiry, including issues that are not specifically
raised in the following questions. Commenters are encouraged to address any
or all of the following questions. To the extent commenters choose to
respond to the specific questions asked, responses should generally follow
the below structure and note the number corresponding to the question.
Comments that contain references to studies, research, and other empirical
data that are not widely published should include copies of the referenced
materials with the submitted comments. For any response, commenters may
wish to consider describing specific goals or actions that the Department
of Commerce, or the U.S. Government in general, might take (on its own or
in conjunction with the private sector) to achieve those goals; the
benefits and costs associated with the action; whether the proposal is
agency-specific or interagency; the rationale and evidence to support it;
and the roles of other stakeholders.

General:
1. Are the challenges and opportunities arising from IoT similar to those
that governments and societies have previously addressed with existing
technologies, or are they different, and if so, how? a. What are the novel
technological challenges presented by IoT relative to existing
technological infrastructure and devices, if any? What makes them novel? b.
What are the novel policy challenges presented by IoT relative to existing
technology policy issues, if any? Why are they novel? Can existing policies
and policy approaches address these new challenges, and if not, why? c.
What are the most significant new opportunities and/or benefits created by
IoT, be they technological, policy, or economic?
2. The term ‘‘Internet of Things’’ and related concepts have been defined
by multiple organizations, including parts of the U.S. Government such as
NIST and the FTC, through policy briefs and reference architectures.8 What
definition(s) should we use in examining the IoT landscape and why? What is
at stake in the differences between definitions of IoT? What are the
strengths and limitations, if any, associated with these definitions?
3. With respect to current or planned laws, regulations, and/or policies
that apply to IoT:
   a. Are there examples that, in your view, foster IoT development and
deployment, while also providing an appropriate level of protection to
workers, consumers, patients, and/or other users of IoT technologies?
   b. Are there examples that, in your view, unnecessarily inhibit IoT
development and deployment?
4. Are there ways to divide or classify the IoT landscape to improve the
precision with which public policy issues are discussed? If so, what are
they, and what are the benefits or limitations of using such
classifications? Examples of possible classifications of IoT could include:
Consumer vs. industrial; public vs. private; device-to-device vs. human
interfacing.
5. Please provide information on any current (or concluded) initiatives or
research of significance that have examined or made important strides in
understanding the IoT policy landscape. Why do you find this work to be
significant? Technology: Technology is at the heart of IoT and its
applications. IoT development is being driven by a very diverse set of
stakeholders whose expertise in science, research, development, deployment,
measurements and standards are enabling rapid advances in technologies for
IoT. It is important to understand what technological hurdles still exist,
or may arise, in the development and deployment of IoT, and if the
government can play a role in mitigating these hurdles.
6. What technological issues may hinder the development of IoT, if any? a.
Examples of possible technical issues could include: i. Interoperability
ii. Insufficient/contradictory/proprietary standards/platforms iii.
Spectrum availability and potential congestion/interference iv.
Availability of network infrastructure v. Other b. What can the government
do, if anything, to help mitigate these technical issues? Where may
government/private sector partnership be beneficial?
7. NIST and NTIA are actively working to develop and understand many of the
technical underpinnings for IoT technologies and their applications. What
factors should the Department of Commerce and, more generally, the federal
government consider when prioritizing their technical activities with
regard to IoT and its applications, and why? Infrastructure: Infrastructure
investment, innovation, and resiliency (such as across the information
technology, communications, and energy sectors) will provide a foundation
for the rapid growth of IoT services.
8. How will IoT place demands on existing infrastructure architectures,
business models, or stability?
9. Are there ways to prepare for or minimize IoT disruptions in these
infrastructures? How are these infrastructures planning and evolving to
meet the demands of IoT?
10. What role might the government play in bolstering and protecting the
availability and resiliency of these infrastructures to support IoT?
Economy: IoT has already begun to alter the U.S. economy by enabling the
development of innovative consumer products and entirely new economic
sectors, enhancing a variety of existing products and services, and
facilitating new manufacturing and delivery systems. In light of this, how
should we think of and assess IoT and its effects? The questions below are
an effort to understand both the potential economic implications of IoT for
the U.S. economy, as well as how to quantify and analyze the economic
impact of IoT in the future. The Department is interested in both the
likely implications of IoT on the U.S. economy and society, as well as the
tools that could be used to quantify that impact. 11. Should the government
quantify and measure the IoT sector? If so, how? a. As devices manufactured
or sold (in value or volume)? b. As industrial/manufacturing components? c.
As part of the digital economy? i. In providing services ii. In the
commerce of digital goods d. In enabling more advanced manufacturing and
supply chains? e. What other metrics would be useful, if any? What new data
collection tools might be necessary, if any? f. How might IoT fit within
the existing industry classification systems? What new sector codes are
necessary, if any?
12. Should the government measure the economic impact of IoT? If so, how?
a. Are there novel analytical tools that should be applied? b. Does IoT
create unique challenges for impact measurement?
13. What impact will the proliferation of IoT have on industrial practices,
for example, advanced manufacturing, supply chains, or agriculture? a. What
will be the benefits, if any? b. What will be the challenges, if any? c.
What role or actions should the Department of Commerce and, more generally,
the federal government take in response to these challenges, if any?
14. What impact (positive or negative) might the growth of IoT have on the
U.S. workforce? What are the potential benefits of IoT for employees and/or
employers? What role or actions should the government take in response to
workforce challenges raised by IoT, if any? Policy Issues: A growing
dependence on embedded devices in all aspects of life raises questions
about the confidentiality of personal data, the integrity of operations,
and the availability and resiliency of critical services.
15. What are the main policy issues that affect or are affected by IoT? How
should the government address or respond to these issues?
16. How should the government address or respond to cybersecurity concerns
about IoT? a. What are the cybersecurity concerns raised specifically by
IoT? How are they different from other cybersecurity concerns? b. How do
these concerns change based on the categorization of IoT applications
(e.g., based on categories for Question 4, or consumer vs. industrial)? c.
What role or actions should the Department of Commerce and, more generally,
the federal government take regarding policies, rules, and/or standards
with regards to IoT cybersecurity, if any?
17. How should the government address or respond to privacy concerns about
IoT?
   a. What are the privacy concerns raised specifically by IoT? How are
they different from other privacy concerns?
   b. Do these concerns change based on the categorization of IoT
applications (e.g., based on categories for Question 4, or consumer vs.
industrial)? c. What role or actions should the Department of Commerce and,
more generally, the federal government take regarding policies, rules,
and/or standards with regards to privacy and the IoT?
18. Are there other consumer protection issues that are raised specifically
by IoT? If so, what are they and how should the government respond to the
concerns?
19. In what ways could IoT affect and be affected by questions of economic
equity? a. In what ways could IoT potentially help disadvantaged
communities or groups? Rural communities? b. In what ways might IoT create
obstacles for these communities or groups? c. What effects, if any, will
Internet access have on IoT, and what effects, if any, will IoT have on
Internet access? d. What role, if any, should the government play in
ensuring that the positive impacts of IoT reach all Americans and keep the
negatives from disproportionately impacting disadvantaged communities or
groups? International Engagement: As mentioned earlier, efforts have begun
in foreign jurisdictions, standards organizations, and intergovernmental
bodies to explore the potential of, and develop standards, specifications,
and best practices for IoT. The Department is seeking input on how to best
monitor and/or engage in various international fora as part of the
government’s ongoing efforts to encourage innovation and growth of the
digital economy.
20. What factors should the Department consider in its international
engagement in: a. Standards and specification organizations? b. Bilateral
and multilateral engagement? c. Industry alliances? d. Other?
21. What issues, if any, regarding IoT should the Department focus on
through international engagement?
22. Are there Internet governance issues now or in the foreseeable future
specific to IoT?
23. Are there policies that the government should seek to promote with
international partners that would be helpful in the IoT context?
24. What factors can impede the growth of the IoT outside the U. S. (e.g.,
data or service localization requirements or other barriers to trade), or
otherwise constrain the ability of U.S. companies to provide those services
on a global basis? How can the government help to alleviate these factors?
Additional Issues:
25. Are there IoT policy areas that could be appropriate for
multistakeholder engagement, similar to the NTIA-run processes on privacy
and cybersecurity?
26. What role should the Department of Commerce play within the federal
government in helping to address the challenges and opportunities of IoT?
How can the Department of Commerce best collaborate with stakeholders on
IoT matters?
27. How should government and the private sector collaborate to ensure that
infrastructure, policy, technology, and investment are working together to
best fuel IoT growth and development? Would an overarching strategy, such
as those deployed in other countries, be useful in this space? If the
answer is yes, what should that strategy entail? 28. What are any
additional relevant issues not raised above, and what role, if any, should
the Department of Commerce and, more generally, the federal government play
in addressing them?

Dated: April 1, 2016. Lawrence E. Strickling, Assistant Secretary for
Communications and Information.

 [FR Doc. 2016–07892 Filed 4–5–16; 8:45 am] BILLING CODE 3510–60–P

Notes:

1] The term was initially coined by Kevin Ashton in 1999 in a presentation
at Proctor and Gamble in reference to radio-frequency identification tags
(RFIDs). See Kevin Ashton, That ‘Internet of Things’ Thing, RFID Journal
(June 22, 2009), http:// www.rfidjournal.com/articles/view?4986.

2] In 2003, there were only around 500 million connected devices, but by
2015 there were around 25 billion connected devices. Devices now outnumber
people by 3.5 to 1. (Intel, A Guide to the Internet of Things Infographic,
available at http://
www.intel.com/content/www/us/en/internet-ofthings/infographics/guide-to-iot.html).
It is expected by 2020 that there will be up to 200 billion connected
devices and these devices will outnumber people by 26 to 1. The McKinsey
Global Institute estimates that the cross-sector impact of IoT technologies
will be between $3.9 trillion and $11 trillion by 2025. See James Manyika
et al, Unlocking the Potential of the Internet of Things, McKinsey & Co.
(June 2015), http:// www.mckinsey.com/insights/business_technology/
the_internet_of_things_the_value_of_digitizing_the_ physical_world.

3] See, for example, the concerns laid out by the National Security
Telecommunications Advisory Committee (NSTAC) in NSTAC Report to the
President on the Internet of Things (Nov. 2014), pg. 21–22.
https://www.dhs.gov/sites/default/files/
publications/NSTAC%20Report%20to%20the
%20President%20on%20the%20Internet%20of %20Things%20Nov%202014%20%28updat
%20%20%20.pdf.

4] See U.S. Dept. of Health and Human Services, Radio Frequency Wireless
Technology in Medical Devices: Guidance for Industry and Food and Drug
Administration Staff (Aug. 14, 2013), http://
www.fda.gov/downloads/MedicalDevices/Device
RegulationandGuidance/GuidanceDocuments/ ucm077272.pdf; see also NHTSA,
Vehicle-toVehicle Communications (last accessed March 9, 2016),
http://www.safercar.gov/v2v/index.html.

5] Federal Trade Comm’n, FTC Report on Internet of Things Urges Companies
to Adopt Best Practices to Address Consumer Privacy and Security Risks, FTC
(Jan. 27, 2015),
https://www.ftc.gov/newsevents/press-releases/2015/01/ftc-report-internetthings-urges-companies-adopt-best-practices.


 6] The White House, FACT SHEET: Administration Announces New ‘‘Smart
Cities’’ Initiative to Help communities Tackle Local Challenges and Improve
City Services, The White House Office of the Press Secretary (Sept. 14,
2015), https:// www.whitehouse.gov/the-press-office/2015/09/14/
fact-sheet-administration-announces-new-smartcities-initiative-help.

 7] For example, the Internet Engineering Task Force (IETF), International
Organization for Standardization (ISO), the International Electrotechnical
Commission (IEC), and ISO and IEC’s Joint Technical Committee 1 (ISO/IEC
JTC1) and the International Telecommunications Union’s Standardization
Sector (ITU–T) have initiated discussion and work related to IoT.


8] Federal Trade Comm’n, Internet of Things: Privacy and Security in a
Connected World, FTC (Jan. 2015), https://www.ftc.gov/system/files/
documents/reports/federal-trade-commission-staffreport-november-2013-workshop-entitled-internetthings-privacy/150127iotrpt.pdf;
Abdella Battou, CPS PWG: Reference Architecture, National Institute of
Standards and Technology (accessed March 9, 2016),
http://www.nist.gov/cps/cpspwg_ refarch.cfm







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Joly MacFie  218 565 9365 Skype:punkcast
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