Brussels, 6 July 2010

Position paper on the implementation of eCall

Comments submitted by AMICE, 62503501759-81 (Register of interest representatives)
Background information eCall, the Pan-European call service, should be adopted as standard equipment in all vehicles in the years to come. The platform which supports eCall claims to be open and adaptable to eventually allow additional functions and applications principally concerning road safety, personal mobility and logistical support. The system would thereby improve emergency help, but also assistance and vehicle claims management which would benefit the insured. Several stakeholders have rallied around this project which has widespread support, including support from members of AMICE1, the Association of Mutual Insurers and Insurance Cooperatives in Europe. However, there are several points to watch and take into consideration for this projects future development. Standardisation work Standardisation work CEN, within WG15, has allowed us to identify two different processes and procedures for the transmission of location data: Among the technical transmission procedures for location data we find voice link, SMS, GPRS... With regard to process, either the vehicle is directly linked to the emergency response centre, or it is linked to the emergency response centre via an assistance platform operating as a service provider which makes it possible to identify and determine the nature of the request. Two standards have therefore been established: Pan-European eCall standard which sends the voice link and the data directly to the local PSAP using In-band modem technology.

11

AMICE has 120 direct members and 1600 indirect members who represent 1/3 of all insurers in Europe and a market share of 20% of all premiums. For further information, please go to : http://www.amiceeu.org/Default.aspx

TPS (Third Party Service) eCall standard which sends voice link and data to a private service provider using SMS and/or GPRS technologies. In the event of an emergency, the private service provider informs the local PSAP. Identified issues The systems, whether already available as either part of the original equipment of certain European vehicle manufacturers or as aftermarket parts of other/third party operators, operate on the same basis as the TPS eCall. Unlike the Pan-European eCall, this system provides overall flexibility enabling eCall to be accessible to functions which complement the emergency call and is an absolute necessity to introduce additional services, such as insurance. We have specifically identified the following points: The possible use of SMS and GPRS to provide better geographical coverage and secure the transmission of location data. A service provider interface carries out the necessary screening:

o To qualify the emergency call and ascertain the drivers actual need. This is why one of our French members (Inter Mutuelles Assistance, hereafter known as IMA) is the assistance platform for the eCall system installed as Peugeots original equipment and for aftermarket equipment available from MACIF and MAIF, both of whom are French mutual insurers and members of AMICE. IMAs experience has shown that less than 6% of calls actually require emergency service intervention. (Statistical calculation based on a sample of over 60,000 calls from a fleet of over 600,000 vehicles). Ascertaining the motorists need is a way of providing reliable service of high added value: Identification and coordination of stakeholders Emergency service intervention based on the information gathered specifying the accidents circumstances, the type of vehicle and the people involved. o Guaranteeing efficient communication with the driver and passengers in their own language Looking at the vehicle from a technical standpoint, neither standard (Pan-European nor TPS) possesses the criteria to trigger an emergency call. Their automatic treatment is subject to configurations specific to the vehicle manufacturers and/or the country and may cause discrepancies in the triggering mechanism. For example, if we take the same accident in two different countries or with different makes of vehicle, in one case eCall could be triggered and in the other not. Nevertheless, only the TPS standard is able to ensure eCalls overall efficiency with an assistance platform, via design tests and monitoring of its use. The major drawback of the Pan-European standard lies in the risk of incompatibility between the reliability of the eCall system and the heavy demands made on the PSAPs. Indeed,

o Either the call criteria are too flexible and the vehicle transmits emergency calls in large numbers without there being any real need inappropriate use of PSAPs, o Or the call criteria are too rigid and there is a risk of accidents not triggering the emergency call reliability of eCall. As a result of our experience with emergency calls and vehicle repairs, we wish to draw the European Commissions attention to the potential difficulties in defining the criteria for automatic emergency calls. In our opinion, such criteria may not be those used to trigger the passive security features. On the one hand, as a result of the improved protection provided by the latest generations of automobiles, many accidents involving the triggering of airbags do not require emergency service intervention, and on the other hand, it is true that in the case of many vehicles the passive security features are not released in the event of a rearend collision even though assistance may be necessary. In addition, in accordance with the European Commission, a system to manually trigger the emergency call may be useful in the event of an accident involving a pedestrian or a twowheeled vehicle. With this system however, there is a real risk of jamming the PSAPs. As a result, as IMAs experience described above shows, almost 20% of emergency calls received are due to handling errors. - Vehicle equipment: the eCall directive is aimed at new vehicles. It will take 15 years or so once it has been established to have a substantial number of European cars equipped, and save the anticipated 2500 lives. The design and distribution of products sold as aftermarket parts will help to shorten this length of time. Moreover, the cohabitation of an automatic emergency call with the manual emergency/assistance call is very important for the car driver who will have the choice of the technology and of the operator. Every driver could thereby benefit from this technology including those of used cars. To facilitate aftermarket equipment, it would be ideal if the eCall directive to which these products must conform allowed for a design based on TPS technology and partial sales coverage in Europe. Both conditions are necessary for the economic viability of products sold as aftermarket parts. - Furthermore the Pan-European standard requires costly updates for the PSAPs which are unnecessary with the TPS standard as certain assistance platforms have already incorporated these features (i.e. receiving emergency calls from vehicles and requesting emergency service intervention). - There is also the problem of technological coherence between the system currently recommended for eCall and those of other European projects supported by the European Commission, such as Safetrip, which rely on satellite technology. - Development of eCall towards a range of services: the pan-European eCall system considered by the European Commission is based on a proprietary technology. Even if the standard has been conceived as part of ETSIs Open Standards, nothing can guarantee the free use of on-board technology over time and therefore the possibility for each player involved in telematic technology to be able to distribute added value services necessary for safety and user-satisfaction. The proprietor of the technology concerned has yet to provide guarantees on this subject.

Recommendations AMICE members support the initiative of the Commission to set up an emergency call system in every new car but would like to emphasize that in any case the consumers should be given the choice which operator / service provider they would like to be informed by an emergency call (especially in a TPS eCall system). The consumers should also be given the opportunity to switch the operator / service provider e.g. by keying in another phone number in the eCall systems configuration menu of the car. So what matters most is the choice given to consumers, and not the dependency to one or another system and/or default system configuration. Additionally we ask that the characteristics of the system are known to everyone and interoperable with other systems. Under these circumstances it seems wiser to prefer a system which provides a link to an emergency response centre via an assistance platform according to the principles of the TPS eCall standard. This alternative provides several advantages for all stakeholders involved: It protects future applications and telematic services, including those made possible by communication satellites, such as the European Safetrip Project. It enables the vehicle manufacturer and service provider to perfect the concept ensuring eCalls increased efficiency. It guarantees improved screening and optimum call management thanks to a service provider, and consequently: o Improves the flow of information for claims and gives a clearer idea of the type of emergency resource to be provided ; o Improves the service to drivers and their passengers (greater coverage, improved call processing times, improved handling of emergencies with the emergency services, improved management of European systems interoperability, additional services etc.). It gives car drivers the opportunity to choose the operator / service provider for the emergency call. This would enable more competition, in line with the ambition of the European Commission to improve competition for motor vehicle distribution and repair. In view of the allocated time frame and the decisions which have already been taken, AMICE members recommend that the TPS standard be suggested as an alternative to the PanEuropean standard as both are ultimately compatible. Providing a choice would guarantee the high added value of eCall systems based on TPS in some countries all the while allowing countries which are less involved with this type of system to offer a minimum service eCall such as the one backed by the European Commission as part of the PanEuropean standard. Finally, the eCall directive should allow the commercialization of aftermarket products by authorizing a design based on the TPS standard and partial distribution throughout Europe to speed up the deployment of the eCall system and improve accessibility of this technology to all drivers.

--------------------------------------