Charlie's analysis is right but he is nicer than I am - I found myself viscerally angry at multiple points reading this bill. There are some good and sensible parts, but overall this legislation is not remotely close to meeting the moment and I overall think passing it would make us less protected against catastrophic risks than we are under existing law. Two parts that stand out as particularly infuriating when taken together: 1. Some of the preemption provisions are remarkably far reaching and consequential, and in addition to preempting legislation like SB 53 would also remove general powers that state courts have to enjoin defendants and protect the public. Most outrageously, it has a provision that looks like its intended to stops states from enforcing laws or judicial decrees that "suspend the development, deployment, or internal use of an AI model" to protect their citizens from imminent catastrophic harms. Such powers to block and suspend model deployments would then only reside with the federal government. 2. The federal governments powers to restrict the development, deployment, or internal use of a frontier model has to meet an absurdly high bar. First, there needs to be an imminent risk of a catastrophic harm (meaning killing more than 50 people or causing more than a billion dollars in damage). But thats not enough! The agency head needs to make a detailed determination with no deference given to show why no alternative would prevent the imminent catastrophe. Next the court is also explicitly told to consider the harms to the developer and other harms from restricting the model, but no considerations in the other direction. This is absurd! For all of its warning about the potential for AI to cause a catastrophe that kills literally everyone on the planet, Anthropic's proposed federal law likely makes it harder than under existing law for a court to get an order blocking or restricting the development of frontier models? WTF?? There are also a bunch of others things that I would like to see improved - the substantive details of the auditing section and the potential for rule-making on substantive safety standards both come to mind - but I think these stand out as particularly indefensible.

This paper shows why I am skeptical of the idea that frontier models can be easily replaced by cheaper ones (and why you should use the best models as orchestrators): Small improvements in accuracy & judgement compound over long-horizon tasks, creating huge gains in outcomes.