April 11, 2016

NTIA Seeks Comment on Policy Issues Related to the Internet of Things

Arnold & Porter Advisory

On April 5, 2016, the National Telecommunications and Information Administration (NTIA), an agency of the US Department of Commerce, issued a Request for Comment (RFC) seeking input from all interested stakeholders on the potential benefits and challenges of the Internet of Things (IoT) and the role, if any, the US government should have in the area.1 NTIA notes that the Department of Commerce has made it a "top priority to encourage growth of the digital economy and ensure that the Internet remains an open platform for innovation." The NTIA plans to analyze the comments and then issue a "green paper" identifying the key issues impacting the deployment of IoT technologies, the potential benefits and challenges, and the possible roles for the federal government, together with the private sector, in fostering the growth of the IoT.

While noting there is no consensus on how to define IoT, NTIA describes it as "the broad umbrella term that seeks to describe the connection of physical objects, infrastructure, and environments to various identifiers, sensors, networks, and/or computing capability. In practice, it also encompasses the applications and analytic capabilities driven by getting data from, and sending instructions to, newly-digitized devices and components." NTIA states that the "number of connected devices is expected to grow exponentially, and the economic impact of those devices will increase dramatically," and that IoT has "the potential to catalyze new user applications and give rise to new industries."

Comments are due on or before 5 p.m. Eastern Time on May 23, 2016.


The NTIA seeks comment on the full range of issues surrounding IoT, but invites specific comment on the following issues:


  • Challenges and opportunities of IoT (including policy, technological, and economic issues);
  • Definition of IoT;
  • Current and planned laws, regulations, and policies that apply to IoT;
  • Ways to divide or classify the IoT landscape (e.g., consumer vs. industrial; public vs. private; device-to-device vs. human interfacing); and
  • Significant research or initiatives that have examined the IoT policy landscape.


  • Technological issues that may hinder the development of IoT (e.g., interoperability; insufficient or contradictory proprietary standards or platforms; spectrum availability; availability of network infrastructure); and
  • Factors the federal government should consider when prioritizing IoT technical activities.


  • IoT demands on existing infrastructure architectures, business models, and stability;
  • Ways to minimize IoT-related infrastructure disruption; and
  • Role of government in bolstering ability of infrastructure to support IoT.


  • Whether, and how, the government should quantify and measure the IoT sector and its economic impact ; and
  • Impact of IoT proliferation on industrial practices (e.g., advanced manufacturing, supply chains, or agriculture) and the US workforce, and the role, if any, of the federal government in addressing any resulting challenges.

Policy Issues

  • The role of government in addressing the main policy issues, cybersecurity and privacy concerns, and consumer protection issues raised by IoT; and
  • Ensuring that the benefits of IoT reach all Americans, and that the harms do not disproportionately impact economically disadvantaged or rural communities.

International Engagement

  • How should the Department of Commerce monitor or engage in various international efforts to develop standards, specifications, and best practices for IoT; and
  • Factors that may impede the growth of IoT outside the US (e.g., data or service localization requirements or other barriers to trade) or otherwise constrain the ability of US companies to provide global IoT services.

Additional Issues

  • Whether a multistakeholder engagement process, similar to the NTIA processes on privacy and cybersecurity, is appropriate for IoT policy issues;
  • Role of the Department of Commerce in helping to address challenges and opportunities of IoT; and
  • Collaboration between government and the private sector to promote IoT growth and development.
  1. Department of Commerce, National Telecommunications and Information Administration, The Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things, 81 Fed. Reg. 19,956, 19,957 (Apr. 6, 2016).

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