Our consultation response on the Mobility Data Infrastructure Act

On 2 February 2022, the Federal Council decided to open the consultation procedure on the “Federal Act on the Mobility Data Infrastructure (MODIG)”. The act is intended to create the basis for improving the use of mobility data and making the transport system more efficient.

We welcome the fact that a concentrated improvement of mobility data is being sought, but we would like to raise two fundamental points of criticism. Mobility data must be made available to all interested parties as open data for free use, as set out in the OGD Strategy 2019 – 2023. Unfortunately, this is not the case in the present draft. Linked to this is the fact that, although some data silos are to be broken up, this is only in favour of a larger silo. That is no longer an effective approach today. This is not about mobility problems alone; mobility has to be analysed in a wider context. The current draft prevents the potential of mobility data from being used fully and innovatively. That requires open data and, with it, the linking of data from other sectors. No new bureaucracy is needed for this either; Open Government Data can be implemented within the existing structures. A specialised bureaucracy and an opaque data infrastructure, on the other hand, inevitably lead to black-box solutions and prevent any democratic search for solutions. We therefore recommend a thorough revision of this draft.