EDF has provided feedback to a European Commission consultation on a draft delegated Regulation to ensure effective access to emergency services through the single European emergency number ‘112’. This delegated Regulation provides more details about the application of the European Electronic Communications Code.
Context
The European Electronic Communications Code (EECC) sets a legal framework to coordinate national legislation on electronic communications networks and services – including, among others, the European emergency number 112. One of its aims is to ensure that persons with disabilities enjoy access and choice to these services on an equal basis with others.
In this context, the European Commission can adopt delegated acts, such as the one EDF has reacted to, to supplement specific provisions of the Code. This draft Delegated Act, which should be adopted soon, will provide further guidance on technical solutions to ensure high-quality emergency communications.
EDF position and recommendations
EDF has welcomed specific provisions of the draft, such as:
- The uptake of packet-switch technology that can enable an accessible communication of persons with disabilities with the Public Safety Access Points (PSAPs) which are the “call centres” that answer emergency communications initiated by people, and if necessary coordinate with the emergency services.
- The requirement of ensuring emergency communication without pre-registration when travelling across the EU, free of charge and guaranteeing equivalent levels of accuracy and reliability.
Nevertheless, we have proposed several improvements:
- The need to make a clearer link between the Delegated Act and the functional accessibility requirements laid down in the European Accessibility Act (EAA).
- The Commission must specify that the development of mobile applications is a complementary and interim tool until the Accessibility Act is implemented in this regard (by 2027). We note that such interim solutions should be pre-installed in all capable handsets (as this would avoid the need for downloading and registering).
- Regarding the upgrade of packet-switched technologies (which will enable to send caller location and communicate in an accessible manner), we have proposed to aim for the core network instead of just the mobile application.
- The need for more clarification on the awareness-raising measures among end-users with disabilities and better reporting mechanisms
See our detailed response and recommendations below:
EDF feedback to European Commission draft Delegated Regulation to the European emergency number ‘112
Contact
Daniel Casas, EDF Accessibility Officer: daniel.casas@edf-feph.org