Safe, Secure, and Trustworthy

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REQUEST FOR INFORMATION

SAFE, SECURE, AND TRUSTWORTHY DEVELOPMENT AND USE OF

The Florida Center for Cybersecurity (Cyber Florida)

The Florida Center for Cybersecurity (also known as Cyber Florida) was established within the University of South Florida in 2014 under Florida statute 1004.444. The goals of the center are to: position Florida as a national leader in cybersecurity and its related workforce through education, research, and community engagement; assist in the creation of jobs in the state’s cybersecurity industry and enhance the existing cybersecurity workforce; act as a cooperative facilitator for state business and higher education communities to share cybersecurity knowledge, resources, and training; seek out partnerships with major military installations to assist, when possible, in homeland cybersecurity defense initiatives; attract cybersecurity companies to the state with an emphasis on defense, finance, health care, transportation, and utility sectors.

Comment

Advancing R&D in artificial intelligence and its deployment for civilian benefit is among America’s most import goals today and should continue to be a priority. Cyber Florida commends the Department of Energy for its intent

to adopt AI technologies for advancing operations of the US energy sectors, while paying attention to safety, responsibility, security, and trustworthiness of AI. The effort is well thought out and is timely. Cyber Florida is very happy to provide a comment.

At the outset, we emphasize that all the topic areas where the DoE intends to use AI can and will benefit if done correctly. AI techniques are no longer restricted to processing images and text, but can be adapted to virtually take any source of data, and derive meaning out of it if trained effectively. DoE focus areas like grid operations and reliability, predictive maintenance, grid resilience, modeling impact of climate hazards on the grid, self-healing energy infrastructures, anomaly detection, and more are actually feasible if careful investments are made in deep neural networks. Energy networks are admittedly complex, and the key challenge in leveraging AI technologies is carefully crafting the key parameters that decide desired outcomes, while filtering out noise.

The most important aspect, even beyond the technicalities of AI R&D is the ethical use of AI in DoE’s mission, while simultaneously ensuring that the rights, responsibilities, and AI risks are effectively managed. Cyber Florida offers the following comments on this aspect.

Strengthening AI Governance. Cyber Florida recommends a Chief AI Officer (CAIO) tasked with the broad oversight of the many ways in which AI is used in DoE. A Governing Board to oversee and advise the CAIO on AI related topics is recommended. This is a trend that is now common in the private sector as AI continues to disrupt operations. We believe that a CAIO at a critical agency like the DoE should be technically adept with AI, but equally important, be someone well versed with the agency’s priorities, understand complex inter-dependencies of the DoE, and be aware of related risks. The CAIO must also be someone with a deep understanding of not only the strengths of AI, but also its limitations. The presence of a formal Governance Board is expected to advise the CAIO on these matters. Cyber Florida recommends that the Governance Board be diverse and include expertise in computing technologies, engineering, material science, neuroscience, physics, mathematics, cybersecurity and much more. A trans-disciplinary Governance Body will advance decisions that are rooted in sound science, ethics, and practicality.

Advancing Responsible AI Innovation. As AI is being used in the DoE, Cyber Florida supports the documentation of AI use-cases and periodically refreshing these as and when AI technologies and intended applications change. We support the creation of well-defined cybersecurity policies to address the needs of AI applications and authorizations to further AI use. The presence of a qualified cybersecurity expert in the AI Governance Board is critical to accomplishing this important goal. Cyber Florida recommends due diligence in safeguarding data that was trained, validated, and tested while developing the AI model, including access and data control policies. Specifically, we recommend a) storing all data within the geographical boundaries of the US; b) multi-layered and fine-grained access control so that impacts of any information leakage are gradual and not catastrophic; c) well defined incident response policies should data compromise be detected. Cyber Florida also recommends a robust program at the DoE to periodically audit all aspects of the AI models, including fidelity of data, security controls, model performance, computing and storage requirements, use-case inventory, test scenarios (in-lab and in the field) and more.

Managing Risks from the use of AI. Cyber Florida believes that there are clear risks to the safety and rights of the public due to misuse of AI. There is documented evidence of certain governments using AI techniques to infringe

upon the rights of their people. There are also reports wherein emergent techniques like Generative AI and LLM models are being utilized to discriminate against people. As such, this aspect may be the most critical of all to consider in a free and fair democracy such as the United States and other like-minded nations and allies. Collaboration across other federal agencies like OMB, NIST and NSA is highly recommended by Cyber Florida as the DoE advances its mission.

Final Remarks: To summarize, Cyber Florida is delighted at the interest within the DoE to utilize AI technologies it is mission. The effort is timely. Cyber Florida is eager to offer comments on the draft report, and hope that they fine-tune the carefully thought out, comprehensive and timely vision of the DoE to practically enable responsible AI use in its critical missions.

Contributing Authors

Dr. Sriram Chellappan

Academic Director of Cybersecurity Research, Cyber Florida: The Florida Center for Cybersecurity Professor, Computer Science and Engineering, University of South Florida

Contact Information

Ernie Ferraresso eferraresso@cyberflorida.org 813 974 1869 Director

Cyber Florida: The Florida Center for Cybersecurity

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