Comments to US Department of Transportation 
Transportation Infrastructure:

Notice of Review of Policy, Guidance and Regulation

Reducing Burdens for Construction of Infrastructure
Data Interoperability as Innovation Enabler

XBRL-CET Memo to Homeland Security
Modernizing Energy and Transportation Infrastructure
Emergency Response for Puerto Rico

Comments to California Department of Transportation 
Caltrans SB1 / SB103 Small Business
Reducing Burdens for Construction of Infrastructure
Data Interoperability as Innovation Enabler

Comments Submitted - Recommended Action Plans

Action Plan - Data Interoperability
Promote the use of XBRL, FIBO and other federally recognized machine readable data standards to stimulate innovation and competition.

Prohibit the use of proprietary data standards for data exchange that constrains innovation and stifles competition for compliance with public laws.

Promote the use of industry trade group published data sets to be synergized with federally recognized machine readable data standards like XBRL and FIBO, and to have the respective trade associations maintain and update their data sets as warranted and under their control, and  for the benefit of their constituency.

Prohibit any industry trade group from imposing any constraints, licensing requirements, or fees of any kind on the use of the trade association data set if that data set is contributed to, and incorporated into, machine open data standards like XBRL and FIBO.

Action Plan – Digital Commerce
Promote the use of secure electronic bonds.  There are a number of competitive companies that already provide the service now and are in place ready to serve.

Prohibit the continued use of expensive and burdensome paper bonds that are subject to fraud.

Promote the use of competitive industry standardized surety bond delivery and administration systems on all public works.

Prohibit public agencies from imposing proprietary bond delivery and administration systems.  Examples are PennDOT and Nationwide Multistate Licensing System and Registry (NMLS)

Action Plan – Multi-agency data interoperability
Require all federal, state and local agencies to adopt federally recognized machine readable data standards like XBRL and FIBO as part of any funding provided by the government under MGT Act, the Federal Information Technology Acquisition Reform Act and others that provide funding for system upgrades.

Prohibit all federal, state and local agencies that receive funding from adopting or implementing a data standard or reporting requirement that does not utilize federally recognized machine readable data standards like XBRL and FIBO, or any requirement that is a “silo approach” to a single industry, trade association, or government entity.​

Action Plan – Cyber
Promote the engagement of stakeholders in best practices for cyber risk mitigation by the federal government providing clear policies and procedures as part of the Cybersecurity Information Sharing Act that when followed provide legal liability cover for all entities and stakeholders.

Provide a national defense posture for providing private entities and stakeholders with a national cyber protection resource, including real time monitoring and threat detection, to establish an offensive approach to mitigating cyber risk.

Provide a clear demarcation of liability resulting from a cyber-attack, where the government assumes liability for consequential liabilities and the entity attacked is only responsible for their internal costs and recovery expenses with the objective of providing the insurance market with a quantified risk and limited exposure to make cyber insurance more affordable and responsive.

Engage with working groups as part of the National Cybersecurity Public-Private Partnership.

Comments to US Department of Commerce 

Reducing Burdens for Construction of Infrastructure
Data Interoperability as Innovation Enabler

Alfred R. Berkeley
Former Vice Chairman and Acting Chairman of

     the President's National Infrastructure Advisory Council
Former Chairman of XBRL US
Former Director of XBRL International
Former Director of The World Economic Forum USA.

Executive Summary

The barrier to leveraging data as a strategic asset is the ability to aggregate and administer data from multiple sources confident the data elements are consistent and reliable with respect to each individual data element having the same usage, definition and application, and for data interoperability between multiple unrelated systems to enable efficient and cost effective data exchange. This was resolved in large part when the SEC developed the XBRL taxonomy as a free resource for public traded companies to report their US GAAP XBRL financial data to the SEC as a data exchange.

In response to the DOE contest Open Data by Design we demonstrated how construction of the nation’s energy infrastructure could follow the best practice of Caltrans and VDOT for building transportation infrastructure, where Caltrans and VDOT monthly progress reports are posted online for transparency to enable data analytics, most importantly predictive analytics for risk management utilizing XBRL.

Under the Smart Grid Interoperability Panel (SGIP) we developed Priority Action Plan 25 to harmonize energy related construction and operational data with the financial markets utilizing XBRL, which led to the DOE Orange Button RFP where respondents and collaborators advocated leveraging XBRL to enable stakeholder data interoperability to reduce the soft costs of developing energy related projects, and reduce burdens on stakeholders.

The emphasis of the collaboration effort is to contribute to the publicly available XBRL taxonomy, and federally recognized machine-readable data standards like FIBO and others, as public resources that can serve multiple purposes for multiple industries and multiple governmental agencies.

The ongoing expansion of the XBRL taxonomy funded by the DOE Orange Button to incorporate all the various data requirements of multiple stakeholders for building infrastructure projects is a public resource available now that can be utilized for cross-agency data interoperability and for data interoperability between government agencies and private industry.

If non-standard, agency specific or proprietary data exchange structures are imposed, the negative impact will be inefficiency, high costs and unreliable data consistency that would undermine the strategic asset.

By utilizing public resources like XBRL and FIBO all stakeholders can concentrate their attention towards developing innovative ways to leverage data interoperability to create strategic assets that make a positive impact through greater efficiency, along with new products and services that create multiple strategic assets.

Not only across government agencies, but across all stakeholders that rely on data to perform their functions.

The “cross-agency” priority goal should appropriately be a “cross-stakeholder” priority goal,
where making an Impact is made possible by leveraging data.

K. Dixon Wright
Surety Resource Connection, Inc.
Chief Cat Herder XBRL-CET Working Group

XBRL-CET Submission of Comments
United States Department of Commerce

     Cross- Agency Priority Goal: Leveraging Data as a Strategic Asset
     Docket ID USBC–2018–0011