MDS IS UNNECESSARY
City governments must be able to collect information from residents for legitimate planning purposes. But if transportation officials cannot explain the necessity of tracking individual vehicles in real-time using MDS technology, then this practice should be stopped.
After creating MDS over a year ago, the Los Angeles Department of Transportation (LADOT) still has not given a compelling reason for requiring information about individual vehicles in real time to justify the risk that it poses to rider privacy and safety. All of the explanations offered, including parking enforcement, event management, and infrastructure improvement can be addressed without resorting to individual surveillance.
The policy situations cited by LADOT when justifying collecting individual trip information could just as easily be addressed with aggregated data. When trip data is combined, it becomes harder to identify riders and carries a much lower privacy risk. Indeed, aggregate data would satisfy many of the purposes for which cities claim they need real-time tracking: understanding how and where vehicles are being used, as well as planning and budgeting for the future.
LADOT claims that tracking individual trips is necessary because aggregated information cannot be trusted. But there are simple technical solutions available to solve such a lack of trust and ensure that data has not been compromised. Cities could and should be working with transportation providers on building technical auditing solutions to meet their needs.
MDS TAKES AWAY YOUR CONTROL
Remarkably, cities like Los Angeles plan to set the routes for ride-sharing and commercial deliveries using MDS. According to LADOT’s Strategic Implementation Plan, the department will “develop an API to deliver a route for a given set of start/end points.” It goes on to say, “Whether a dockless or docked bike, an autonomous car or package delivery drone … LADOT will explicitly manage the movement of vehicles in the Los Angeles transportation product.”
This approach runs counter to the general principle that regulators will not run the day-to-day (let alone minute-to-minute) operations of private companies. Cities can set requirements that companies are expected to meet. But they should not assume operational control in order to ensure compliance.
LADOT has framed MDS as a debate with companies but really it’s between the city and all of the citizens whose data and lives are being swept up in this fight.
YOU SHOULD HAVE A SAY
Across the country, city officials have not publicly solicited input from citizens or stakeholders about the changing role that local governments intend to play in their transportation data and routing. This is not an acceptable process by which to make such breathtaking policy changes that will impact how cities collect, utilize and control their citizens’ movement. Before moving forward with any MDS tracking programs, cities must adequately and openly answer questions about their process for retaining, deleting, storing, and protecting the data they plan to collect, including:
● Specifically, how will MDS data be used by the city?
● Will cities share MDS data with other government agencies or third parties?
● How will cities secure and protect vehicle location data?
● Does MDS comply with state and local privacy laws?
● Will users be notified if their trip data is breached?
Until then, cities should reject MDS tracking programs and focus on developing data collection policies that improve the transportation landscape while protecting rider privacy and safety.