Dear Acting Director Parker and Director Panchanathan:
The U.S. Chamber of Commerce (“Chamber”) appreciates the opportunity to provide comments to the Office of Science and Technology Policy (“OSTP”) and the National Science Foundation (“NSF”) on its “Request for Information (“RFI”) on the Development of an Artificial Intelligence Action Plan.”[1]
The Chamber agrees with the recent Executive Order signed by President Trump which states in part that the purpose of Artificial Intelligence (“AI”) policy should be to “promote human flourishing, economic competitiveness and national security.”[2] AI has the potential to drive growth that will benefit individual Americans by improving their health, giving them greater access to the means of increasing their prosperity and improving the quality of life for their families.
The Chamber has seen this firsthand with the release of a report entitled Small Business Empowered: The Impact of Technology on Small Business.[3] Between 2023 and 2024, the number of small businesses using generative AI almost doubled to 40%. 98% of small businesses are using some form of an AI tool for different functions. U.S. small businesses that are adopting AI are experiencing higher rates of sales and hiring growth than their peers who are not.[4] Recent studies have shown that AI can boost economic growth in the United States by an additional 10-20% over the next ten years.[5] By allow the end-users to experiment and deploy AI, prosperity and productivity will be driven through all parts of the American economy.
The need for rational policymaking is critical for the American people and economy to benefit from continued AI innovation. The Chamber concurs with what Vice President Vance recently said in his speech in Paris: “[n]ow, at this moment, we face the extraordinary prospect of a new industrial revolution, one on par with the invention of the steam engine or Bessemer steel. But it will never come to pass if overregulation deters innovators from taking the risks necessary to advance the ball….”[6]
In 2023, the Chamber’s Commission on Artificial Intelligence, Inclusion and Innovation (“Chamber Commission Report”) released its report outlining the role of AI policymaking.[7] The Chamber Commission Report highlighted the need for continued growth and innovation and proposed a policy framework that called for an inventory of existing laws and regulations that would identify gaps that could be addressed through a risk-based approach. This gap filing risk-based approach recognized that many AI activities are already covered by existing law and that broad based approached could in fact be harmful to the beneficial employment of the technology. As discussed in greater detail in this letter, the Chamber updated its AI principles in 2025[8] to outline how issues may be addressed. Also, in 2023, the Chamber wrote to bi-partisan leaders in the Senate requesting the creation of an office for the Assistant Secretary of Commerce for Emerging Technology to coordinate non-security AI policies throughout the Federal government.
For the United States to continue reaping the benefits of this transformative technology, continued pro-growth action from the federal government is essential. As advocated by Vice President Vance, government must foster an “open regulatory environment” with the business community, and “encourage” American innovators to experiment and make unparalleled research and development investments.”[9] We further appreciate the administration's understanding that “excessive regulations on the AI sector could kill a transformative industry just as it’s taking off” and the need to encourage pro-growth AI policies.[10]
As the first Trump administration declared, the “United States has long been a champion and defender of the core values of freedom, guarantees of human rights, the rule of law, stability in our institutions, right to privacy, respect for intellectual property and opportunities to all to pursue their dreams. The AI technologies we develop must also reflect these fundamental American values and our devotion to helping people.”[11]
We look forward to working with the Administration on these issues and hope to provide better insight as to how AI policies are impacting the end-users of the technology. Accordingly, we offer the following recommendations to achieve the right policy balance that maximizes AI opportunity and economic growth.
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[1] 90 Fed. Reg. 9088 (February 6, 2025) available athttps://www.govinfo.gov/content/pkg/FR-2025-02-06/pdf/2025-02305.pdf.
[2]Removing Barriers to American Leadership in Artificial Intelligence, Exec. Order No. 14179 (Jan. 23, 2025), § 2, https://www.federalregister.gov/documents/2025/01/31/2025-02172/removing-barriers-to-american-leadership-in-artificial-intelligence.
[3] https://www.uschamber.com/technology/artificial-intelligence/the-impact-of-technology-on-u-s-small-business
[4] U.S. Chamber of Commerce, “Empowering Small Business: The Impact of Technology on U.S. Small Business,” (September 15, 2024) available athttps://www.uschamber.com/assets/documents/Impact-of-Technology-on-Small-Business-Report-2024.pdf.
[5] Seydl, J., & Linden, J. (2024, July 16). How AI can boost productivity and jump start growth. J.P. Morgan Private Bank. Retrieved from https://privatebank.jpmorgan.com/nam/en/insights/markets-and-investing/ideas-and-insights/how-ai-can-boost-productivity-and-jump-start-growth.
[6] https://www.presidency.ucsb.edu/documents/remarks-the-vice-president-the-artificial-intelligence-action-summit-paris-france
[7] U.S. Chamber of Commerce. Artificial Intelligence Commission Report. U.S. Chamber of Commerce, 9 Mar. 2023, www.uschamber.com/technology/artificial-intelligence/artificial-intelligence-commission-report.
[8] U.S. Chamber of Commerce. U.S. Chamber Releases Artificial Intelligence Principles. U.S. Chamber of Commerce, 23 Sept. 2019, www.uschamber.com/technology/us-chamber-releases-artificial-intelligence-principles.
[10]Remarks by the Vice President at the Artificial Intelligence Action Summit in Paris, France | The American Presidency Project
[11] Trump Administration; Artificial Intelligence for the American People; Pillar Five “AI with American Values;” available at: Artificial Intelligence for the American People. As President Trump recently stated in connection with the Administration’s Feb. 10, 2025 Executive Order, “[e]very policy must be geared toward that which supports the American worker, the American family, and businesses, both large and small, and allows our country to compete with other nations on a very level playing field.” Fact Sheet: President Donald J. Trump Restores American Competitiveness and Security in FCPA Enforcement (Feb. 10, 2025), https://www.whitehouse.gov/fact-sheets/2025/02/fact-sheet-president-donald-j-trump-restores-american-competitiveness-and-security-in-fcpa-enforcement/.
