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Please accept these comments on behalf of the American Council of Engineering Companies (ACEC) – the business association of the nation’s engineering industry. Founded in 1906, ACEC is a national federation of 51 state and regional organizations representing nearly 5,500 engineering firms and nearly 600,000 engineers, surveyors, architects, and other specialists nationwide. ACEC member firms drive the design of America’s infrastructure and built environment.
ACEC appreciates the desire to protect information our government has and shares with private sector partners. We recognize the nearly fifteen-year administrative history of this proposed rule going back to Executive Order 13556, “Controlled Unclassified Information” and the National Archives and Records Administration (NARA) final rule in 2016 that established policies for agencies on designating, marking, safeguarding, disseminating, and disposing of CUI, which was codified at 32 CFR Part 2002.
Government agencies struggle following their own procedures on CUI. Many examples exist in recent years of documents or presentations marked CUI or “For Official Use Only” (FOUO) posted to public government websites. Much work remains to educate government and industry personnel about existing procedures beyond the procedures contemplated in this proposed rule….Continue Reading