ETNO RESPONSE TO ECC Report 225

Executive Summary

• ETNO would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on Draft ECC Report 225 “Establishing Criteria for the Accuracy and Reliability of the Caller Location Information in support of Emergency Services” and on its Annex 5 “Accuracy and Reliability of the Caller Location Information for Emergency Services Calls - Summary of Responses to Questionnaire”.

• As a general consideration, the Report should have considered the obligations set out in the European regulatory framework as the baseline rather than focusing on the need to extend it. The obligations set out in the European regulatory framework relate to public networks and telephony services available to the public and do not require operators to provide the best accuracy and reliability possible.

• ETNO is concerned that decisions to mandate new obligations be mandated without statistics on the impact of accuracy/reliability being available, as noted in the ECC draft report. It is crucial in our view that such data are collected and analysed to determine the priorities to be set and the improvement that can reasonably be expected from the new mechanisms to be put in place.

• The Report, as regards Article 26.5 of the Universal Service Directive, should acknowledge that the national implemented solutions already comply with the regulatory obligations to provide access to emergency services for all EU citizens. Improvement activities in relation to mobile location may be appropriate, but this should result from a joint activity of all actors involved in the supply chain of the emergency service. In addition, evaluations will be necessary on the balance between the technologies implemented in the networks, the needs of providers of emergency services, the funding available nationally, total costs, etc.

• As a further consideration, the Report does not give enough consideration to the existing national mechanisms already implemented for emergency calls, and the need for backward compatibility of new solutions for improving accuracy and reliability of caller location information. These national solutions will have an influence on the evolutionary scenarios for an improved accuracy and reliability of location information.

• The Report fails to follow an approach aimed at avoiding costly impacts on public network operators, even when it considers more cost effective solutions based on a combination of GNSS/GPS (terminal-based location information) and Cell ID (network-based location information), especially when recommending that “A-GNSS should be implemented as a caller location technique in addition to the existing network-based methods rather than replacing them”. This conclusion seems to ignore the fast evolution of the market towards over-the-top-like services which are totally independent of the underlying fix and mobile networks.

• ETNO cannot agree with the proposal of new regulation on network operators aimed at better location accuracy and reliability. Imposing further network oriented solutions creates further competitive disadvantages for network operators at the benefit of the over-the-top players. Only a terminal equipment based solution for localisation is future proof in the framework of emergency services to take account of the ever increasing mobility of users using the same service transparently over different network connections: wifi, fixed or mobile access, etc. . Therefore ETNO believes that only a voluntary-based activity of all the involved parties, to improve emergency service provision, allows the determination of a real sustainable solution including manufacturers, OTTs, etc..

Full paper here.