openjs-foundation / standards

a repository for documenting and coordinating the foundation's web standards work
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Open Policy Alliance response to CISA's request for comments for CIRCIA #293

Closed tobie closed 2 months ago

tobie commented 3 months ago

This is FYI: the Open Policy Alliance (technically an OSI project) wrote a response (PDF) to CISA's request for comments on the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) (extended to July, 3rd).

Timing made it impossible to bring this up to the group before approving the response, so after checking with @rginn, and because the topic wasn't contentious and inaction more harmful than action, I signed it on behalf of OpenJSF.

Overall the general feeling was that CIRCIA wouldn't impact open source but that it was a good idea to clarify that open source was out of scope, notably because there were explicit questions addressed at the open source community, in particular:

  1. How the proposed IT Sector sector-based criteria might apply to members of the open-source ecosystem, including whether entities that may provide IT hardware, software, systems, or services to the Federal government know or could determine whether they are providing such goods or services to the Federal government, and, if so, the level of effort in making such a determination.