April 1, 2011 Comments of GTW Associates on

  Strategy for American Innovation

76 FR 6395

Securing our Economic Growth

National Economic Council, Council  of Economic Advisers,

And Office of Science and Technology Policy

GTW Associates  submitted  recommendations and substantive comments  in an April 1 submission to the  Department of Commerce    


GTW Associates observed NIST Director Gallagher's remarks in the preface to the third edition of the United States Standards Strategy that Standards are the building blocks for innovation and competitiveness  and GTW found numerous examples of the term "standards" in the innovation strategy.  


However GTW was unable to discern an overarching standards theme  or standards strategy within the innovation strategy.  GTW remarked that such a government oriented standards theme or strategy  may be the outcome of  work of the National Science and Technology Council’s Technology Committee Sub-Committee on Standards.

GTW remarked that one of the references to standards in  the Strategy above merits examination:  

Standard setting, which the government can enable through its role as convener and support through research and development, often involves facilitating coordination within the private sector to create a larger market, thus enhancing the demand for innovative products.  p 13

The U.S. Federal government participates as one of many stakeholders in the standards development process, not as the driver of the process. By comparison, governments in other nations play a more active role; and the process is more centralized. Many principles  in    the third edition of the United States   Standards Strategy  at     www.us-standards-strategy.org  are worthy of consideration in this regard.

For example  even whether the government or private sector serves as a convener  can send signals to the participants.  NIST or  the White House OSTP  serving  as a convener of an activity sends one signal  and  ANSI or one of many standards developing organizations serving as a neutral body convenor sends a different signal.  Funding by  a government convener compared by private sector convener differs. A private sector convener may need help government support getting jump started but must carry forward  through  self funding rather than with tax payer  funds.

The matter of neutral convener    relates directly to the 12th goal of the United States  Standards Strategy Address the need for standards in support of emerging national priorities

In response to the  Entrepreneurship  question of what obstacles limit entrepreneurship in America, and which of these obstacles can be reduced through public policy? GTW Associates stated:  Maximizing the role of the private sector and voluntary solutions to regulatory matters reduces the burden on entrepreneurs and encourages innovation and private sector investments. 


GTW identified existing  policy documents applicable to the role of voluntary standards to contribute to private sector solutions.  These include: OMB Circular A-119 Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities  ; Circular A-4  September 17, 2003  TO THE HEADS OF EXECUTIVE AGENCIES AND ESTABLISHMENTS Subject: Regulatory Analysis The Presumption Against Economic Regulation; Executive Order 12866,  Regulatory Planning and Review   January   18, 2011 Executive Order 13563, Improving Regulation and Regulatory Review;  February 1, 2011  MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES, AND OF INDEPENDENT REGULATORY AGENCIES M-11-10 MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES, AND OF INDEPENDENT REGULATORY AGENCIES  FROM: Cass R. Sunstein  Administrator  SUBJECT: Executive Order 13563, “Improving Regulation and Regulatory Review” ;  January  18th 2011  Executive Order 13563, Improving Regulation and Regulatory Review


In response to the Intellectual Property question of what are the key elements of any legal reform effort that would ensure that our intellectual property system provides timely, high-quality property rights? GTW  recommended that the US government should  assist owners of  intellectual property resist and overturn  foreign governments procurement or regulatory policies  relating to incorporation of patents  in standards  that unfairly compromise  the abilities of the US owners of patents  to obtain a  fair return on their investments.


In response to the question  How important is catalyzing greater interest and training in science, technology, engineering and mathematics (STEM) fields?  GTW  referred to the United States Standards Strategy Goal number 10 – Establish standards education as a high priority within the United States private, public, and academic sectors


In response to the Exports question How could the government better assist small and medium-sized domestic firms sell their products abroad? What policies can be pursued that would help all U.S. businesses increase their exportsGTW Associates observed increasing evidence of the use of  standards, regulations and legal systems to impede the acceptance of both US Goods and services in many markets. 




Today  standards are  the new   “Wolf in Sheep’s clothing.





The US government is in a  powerfully strong position to assist US businesses  address and resolve the increasing threats of existing and potentially new non tariff barriers to trade in US products and services.


The US government should continue international efforts to help prevent  use of  standards, regulations and legal systems to impede the acceptance of both US Goods and services in many markets.  The US government should prepare an interagency plan how it will translate the goals from the   February 3 2011  the third edition of the United States   Standards Strategy     into specific projects and dedication of government resources to help achieve the goals.




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