Comments template for Draft SP 800-207 Please respond by November 22, 2019 Submitted by: IDSA Date: 11/21/19 

All comments will be made public as-is, with no edits or redactions. Please be careful to not include confidential business or personal information, otherwise sensitive or protected information, or any information you do not wish to be posted. 

Comment Template for First Public Draft of Four Principles of Submit comments by October 15, 2020 to: 

Explainable Artificial Intelligence (Draft NISTIR 8312) explainable-AI@nist.gov

Comment # Commenter organization Commenter 

name 

Paper Line # (if 

applicable) 

Paper Section (if 

applicable) 

Comment (Include rationale for comment) Suggested change 

1 Ethical AI Consortium, Inc. Sarah Alt 128 1. Introduction There are many instances where people don't have a choice that AI 

is used on them. They don't have a choice to accept or adopt. 

Suggest also acknowledging there are real instances where acceptance and adoption 

aren't even an option. 

2 Ethical AI Consortium, Inc. Sarah Alt 156 2. Four Principles of 

Explainable AI 

I believe the word is "regulator" is supposed to be "regulatory"? Change to "regulatory"? 

3 Ethical AI Consortium, Inc. Sarah Alt 181 2.2 Meaningful I'm sure there was much discussion and debate on whether to use 

"Understandable" instead of "Meaningful". I feel something 

doesn't have to be meaningful (having signficance or purpose) that 

is still understandable (comprehendable). I don't believe we would 

require Explainable AI to be meaningful. In fact, there may be 

many rather frivolous applications of AI, depending upon one's 

viewpoint. But we could still explain them in an understandable 

way. 

Suggest changing this to "Understandable"; and all places where some version of 

meaningful as the root or implied definition is used (e.g. line 199 "meaninfulness"). 

4 Ethical AI Consortium, Inc. Sarah Alt 208-209 2.3 Explanation Accuracy This phrase: "...an explanation that correctly reflects a system's 

process for generating its output" is a great and precise definition 

of what "Accuracy" means. 

Make it really simple and state just that. "We define Explanation Accuracy as an 

explanation that correctly reflects a system's process for generating its output." 

5 Ethical AI Consortium, Inc. Sarah Alt 209-210 2.3 Explanation Accuracy This is a confusing sentence: "The Explanation Accuracy principle 

imposes accuracy on a system's explanation." - It is also a circular 

definition. 

If we succinctly state what I suggest in comment #4, you don't need this sentence at 

all. 

6 Ethical AI Consortium, Inc. Sarah Alt 211-217 2.3 Explanation Accuracy While informative, I don't think you need this paragraph. Suggest dropping this paragraph. 

7 Ethical AI Consortium, Inc. Sarah Alt 225 2.3 Explanation Accuracy Remove "more than one type of of [sic] explanation" Suggest replacing it with "various levels of detail in its explanations tailored and 

relevant for various audiences." 

8 Ethical AI Consortium, Inc. Sarah Alt 228 2.4 Knowledge Limits Generally speaking, do we also mean it is used for its intended 

purpose(s) only? 

If so, suggest we address this someplace in this definition too. 

9 Ethical AI Consortium, Inc. Sarah Alt 231 2.4 Knowledge Limits This is confusing: "...or their answers are not reliable." Do we mean perhaps: "...or cases where their answers are not reliable."? 

10 Ethical AI Consortium, Inc. Sarah Alt 237-239 2.4 Knowledge Limits This set of sentences is confusing..."The system could return an 

answer to indicate that it could not find any birds in the input 

image; therefore, the system cannot provide an answer. This is 

both an answer and an explanation." - We say the system could 

return an answer in the same sentence we say it cannot provide an 

answer, and in the very next sentence we say it is an answer. 

Not sure how to suggest we fix this. 

11 Ethical AI Consortium, Inc. Sarah Alt 235-244 2.4 Knowledge Limits I believe the document should always use human examples, rather 

than a birds example. While it is a "safe" example, it waters down 

why and in what instances we remain most concerned about 

explainability, which is where fundamental human rights, 

discrimination and bias are involved. 

Suggest replacing this with a human example. 

12 Ethical AI Consortium, Inc. Sarah Alt 250 3. Types of Explanations Suggest adding "The categories described below were not designed to be exhaustive, 

nor exclusive, meaning a given individual could be more than one audience member 

in a given AI system situation." 

 Type: E - Editorial, G - General T - Technical 1 of 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Comments template for Draft SP 800-207 Please respond by November 22, 2019 Submitted by: IDSA Date: 11/21/19 

13 Ethical AI Consortium, Inc. Sarah Alt 251-276 3. Types of Explanations These categories/groups feel confusing. Especially "societal 

acceptance" doesn't feel like a group of people as much as it is a 

concept that all explanations should be aiming to achieve. These 

feel like a combination of groups of professions/people and 

concepts. 

Suggest using the following 5 groups: Builders/Developers, 

Regulatory/Legal/Compliance, Buyers/Subscribers, Users, Beneficiaries 

14 Ethical AI Consortium, Inc. Sarah Alt 256 3. Types of Explanations If you keep this section, change "users" to "people". Some people in 

society aren't actually the users of the AI. It is used on them, which 

means they are intended to be the beneficiaries - whether they had 

a choice or not. 

15 Ethical AI Consortium, Inc. Sarah Alt 259-264 3. Types of Explanations Keep this group, but drop using the word "user". Change this to "a person", "an individual", or "someone". We still need to distinguish 

that there are people who use AI and there are people on whom AI is used. 

16 Ethical AI Consortium, Inc. Sarah Alt 267 3. Types of Explanations Change "includes" to "include" 

17 Ethical AI Consortium, Inc. Sarah Alt 271-276 3. Types of Explanations I don't understand how "operator of a system" is different than 

"user" (line 251). Likewise, if we mean "operator", then why do we 

call it "owner"? There are many instances where an operator of a 

system is not the owner. Similarly, the example provided confuses 

me more. I don't "own" my streaming movie services. I am a 

Subscriber or Beneficiary of the AI system a developer developed or 

that Netflix decides to use with my data. I'm definitely not an 

owner. But I might be an operator? 

See Comment #13 for a suggested nomenclature to clear this up. 

18 Ethical AI Consortium, Inc. Sarah Alt 295-301 3. Types of Explanations This is a good human example! Nice job. 

19 Ethical AI Consortium, Inc. Sarah Alt 322-323 4. Overview of principles in 

the literature 

Change this from a bird example. Follow the human example if you decide to change it. 

20 Ethical AI Consortium, Inc. Sarah Alt 523 5.4 Adversarial Attacks on 

Explainability 

This seems a bit buried in this section and awkwardly placed. It also 

doesn't seem like this would be the only caution or risk we would 

want to point out. 

Does it belong here at all? Is this another paper all together? 

21 Ethical AI Consortium, Inc. Sarah Alt 590 6.2 Meaningful This first sentence should be carefully worded to match the same 

definition used for "Meaningful" (or "Understandable") as used in 

the beginning of the paper. Here we introduce slightly different 

words to describe "Meaningful". If we are making a comparison 

between the capabilities of AI systems to explain "themselves" and 

humans to explain them, we should hold to the same controlled 

definition of the standards. 

22 Ethical AI Consortium, Inc. Sarah Alt 605-609 6.2 Meaningful These same issues exist with AI systems explaining "themselves" 

too. 

23 Ethical AI Consortium, Inc. Sarah Alt 611-612 6.3 Explanation Accuracy Again, we use a different definition here than earlier in the paper. 

Isn't "accuracy" simply: does the explanation factually and 

correctly describe what the AI system does? 

This may be intentional and rational, so disregard if there is a good explanation for it. 

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Comments template for Draft SP 800-207 Please respond by November 22, 2019 Submitted by: IDSA Date: 11/21/19 

24 Ethical AI Consortium, Inc. Sarah Alt 697-707 7. Discussions and 

Conclusions 

The subtitle of the posting for this paper is: "Technical agency 

proposes four fundamental principles for judging how well AI 

decisions can be explained." Most readers would expect to find 

these in the paper. This section contains perhaps the most 

important statements that should not be buried in my opinion. If 

NIST is suggesting that explainability is achieved by both system 

and human involvement, then let's just say that at the beginning. 

Provide the four guiding principles and state the role that both the 

AI system (as designed by humans) and the humans themselves play 

in achieving explainability. Perhaps some of this paper belongs in 

separate rationale papers to explain why or how we arrived there, 

but the core of the guidelines should be ready to use. 

Good start and maybe we need a more consumable piece that results from this for 

lay people to understand. You may already be planning to do so. 

 Type: E - Editorial, G - General T - Technical 3 of