As of: 8/20/21 11 :23 AM 

PUBLIC SUBMISSION Received: August 19, 2021 

Status: Pending_Post 

Tracking No. ksj-e3r5-zgop 

Comments Due: August 19, 2021 

Submission Type: Web 

Docket: NIST-2021-0004 

Artificial Intelligence Risk Management Framework 

Comment On: NIST-2021-0004-0001 

Artificial Intelligence Risk Management Framework 

Document: NIST-2021-0004-DRAFT-0035 

Comment on FR Doc # 2021-1617 6 

Submitter Information 

Email: 

Organization: Rotunda Solutions 

General Comment 

Artificial Intelligence (AI) is not only advancing fast, but it has also been a rapidly accepted technology 

that is currently being utilized throughout various industries to increase effectiveness, understand

processes, provide insight, and alleviate burden from workers in order to allow them to focus on higher 

cognitive loading tasks. However, regulatory and security understanding has not kept up with this 

advance in technology and therefore has not changed to incorporate fairness, security, explainability, or 

proper reporting measures into the development and usage of these tools. Therefore it is with great

pleasure that I respond to this RFI as the Principal Researcher of Rotunda Solutions, Inc, so that we may 

provide our understanding of this field into this very important work. 

Rotunda Solutions is a Systems Engineering and Data Analytics firm with clients throughout the Federal 

Government, as well as the commerical, academic, and non-profit sectors. Rotunda provides consulting 

services to these entities and regularly engages with its academic and industrial colleagues through 

publication, conference presentation and attendance, and assistance in the development of policy related 

to these fields. A key pillar of the Rotunda Analytics and Innovation Lab (RAIL)-the research wing of 

Rotunda Solutions-revolves around AI security and fairness. In addition, Rotunda prides itself on the

usage, research, and development of explainable AI technologies, as well as its ability to explain these 

technologies to both technical and non-technical audiences. Pertaining to this RFI, employees ofRotunda 

Solutions have actively served on various efforts with clientle, research, and policy regarding AI security,

fairness, and ethics. 

The development of a Risk Mitigation Framework (RMF) must consider methodologies which 

incorporate current industrial and academic understanding of security vulernabilites and mitigation 

techniques, inherent bias and fairness concerns, ethical considerations, and the ability to understand how a 

particular tool arrived at its conclusion. This includes not only the development of the algorithms and

models themselves, but also the collection, storage, transfer, and sharing of datasets utilized to develop 

such technologies. Current efforts at Rotunda Solutions are focused on the research and development of 

methodologies within fields of AI Security in order to provide users with the ability to understand not 
only the vulnerability of their assets to various adversarial attacks, but also to understand the origin of 

these vulnerabilities and how to mitigate their affect without degrading the effectiveness of developed AI 

techniques. This is a core area in which effort must be focused: how can AI be made secure, explainable, 

and fair, while remaining effective. These areas can often be seen in competition. Often, the more secure 

an AI tool becomes, the less effective it can be. In addition, fairer tools tend to be more complex whether 

through extensive data collection or extensive model development. The construction of an RMF which 

encorporates such a fast-paced technology can only be done through consensus and the ability for 

evolution of the RMF as the technology advances.