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 our working group members as part of the National Cybersecurity Public-Private Partnership.

Comments to US Department of Commerce 

   Cross- Agency Priority Goal:

Leveraging Data as a Strategic Asset

Reducing Burdens for Construction of Infrastructure
Data Interoperability as Innovation Enabler
Impact


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
Impact

Comments to US Department of Transportation 

Reducing Burdens for Construction of Infrastructure
Data Interoperability as Innovation Enabler
Impact

Links
Transportation Infrastructure: Notice of Review of Policy, Guidance and Regulation
Docket No DOT-OST-2017-0057

Posted XBRL-CET Submission of Comments to USDOT

XBRL-CET Submission of Comments
United States Department of Transportation
Transportation Infrastructure: Notice of Review of Policy, Guidance and Regulation
Docket No DOT-OST-2017-0057

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.

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