1. The PSAP-DIR project Report 264: ECC(17)058).
Financial, HR and legal aspects: INFO 04
Input for an ECC response to the ECO council’s letter of 10 May 2017: (ECC(17)059).
The PSAP-DIR project

2. In short A directory of PSAPs long numbers.
Provides PSAPs with means to contact a foreign focal PSAP
Alert foreign PSAPs of an incident in its country
Request assistance with national incidents, translation, ehealth lookup, find next of kin
Border incidents
Voluntary for PSAPs, but in their citizens interest to assist as best as possible
Backdrop of OTT-disruption and level playing field, high policy objective for ECS, mobility, immigration, ever younger and older users

3. Case 1
Lithuanian experience (provided in response to public consultation on ECC Report 264):

4. Case 2
Swedish experience (provided in response to public consultation on ECC Report 264):
At 3 PM a woman calls the emergency number 112. She has just received a call from her daughter who is in Spain. Her daughter calls to say farewell since she wants to end her life. She is lying in a bathtub, has slit her wrists and is bleeding heavily. The call taker at SOS Alarm has no number to connect the desperate mother to since there are no numbers for Spain PSAPs available. The call taker has no other choice than to ask the caller to try calling the international Directory Enquires in hope to get a number for the police or ambulance organization in the area. We have no report on the outcome of this tragic event.”

5. Report 264
Feasibility study investigating numerous sides associated with the ECO taking over the PSAP DIR.
Discussions on
Support from stakeholders (Chapter 3)
Current EENA Directory (Chapter 4)
Remit of CEPT/ECC in Emergency Service Communciations (Chapter 5)
Technical and administrative considerations (Chapter 6)
Legal structure (Chapter 7)
Risk assesment (chapter 8)
Impact Assessment (chapter 9)
Summary (Chapter 10)

6. Increased participation
EENA has asked us to take over
Countries have requested a more formal footing
EENA is a NGO that provides a discussion platform
An ECO hosted PSAP DIR could have more entries than the EENA DB, and provide a better service for European citizens.
ECO has a responsible framework in CEPT, ECC, ECO Council, ECO, WG NaN, PT ES – contacts and deliverables

7. ECC/ECO scope
It is clear from the Strategic Plan and Terms of Reference that emergency services communications is an important activity for the ECC:
From Strategic Plan :
The ECC should study relevant aspects of emergency services communications and provide support and advice to European emergency services stakeholders where appropriate;
From the Preamble:
ECC is a focal point in Europe for providing, maintaining and exchanging information on electronic communication; and endeavours to foster a spirit of cooperation and collaboration with all stakeholders.
From Terms of Reference nr. 7 WG NaN shall:
Study technical and regulatory aspects of emergency services communications and cooperate with European emergency services stakeholders on regulatory matters where appropriate.
The harmonisation of 112 itself was a CEPT initiative originally, and we have PT ES with relevant regulatory interest. It could be argued that the DIR is a natural follow up of our harmonizing activities in a modern Europe with very mobile citizens.

8. Risk assessment Nothing 100% risk free
Report 264 identifies risks and mitigating measures, such as
Risk of legal actions: mitigated by disclaimers, involvement in set-up, option for ADRPs
Risk of physical damage: mitigated by remote stored backup data, small DIR to repopulate
Risk of unauthorised access to online versions: mitigated by ECO experience, procedures and technologies to ensure appropriate levels of security. Firewall and encryption. Notification in case of breach. Deletion of accounts.
Risk of unauthorised access to offline versions: mitigated by audit trail, acceptance of terms and transfer of liability.
Risk of technical failure: mitigated by ECO expertise and experience, existing backup-routines etc.
“Political risk”: mitigated by PSAPs accepting Terms before voluntary participation. EXIT/Termination provisions. Returning DIR to EENA.

9. Economy INFO-04: Those not participating…
PSAP-DIR is a simple directory, appr. 100 entries
Minimal IT developement costs
External IT development cost
2017: 3days (3355 euro).
2018: 3 days (3355 euro).
2019: 0 euro
Human resource commitment
2017: 5 expert person days and 2 person days general staff
2018: 7,5 expert person days and 5 person days general staff
2019: 2 expert person days and 3 person days general staff
Additional legal advice: 2689 euro in 2017
Those not participating…
solidarity, 700MHz repos., future entry?

10. Legal
Aumento:
The PSAPs are responsible for the correctness and updating of its own data
No other risks than those identified in Chapter 8
Contractual descriptions of ECO performance should be described, to limit liability further
Consolidated «terms of reference» for the service
Suggestion for EXIT provision
Reccomends declaration supported by refererence and documentation
Input to Arbitration process (advices not to reuse ECO Convention rules, recommends danish choice of law)

11. Legal structure Contractual and voluntary
Acceptance of terms including ECO-performance and limitations and duty of care
2 contracts:
Between ECO and focal PSAP and Back-up PSAP
Between ECO and the PSAP-DIR user
See chapter 7.2 on elements in contract

12. National considerations
Fragmentet or desentralised PSAP structure
Should not hinder other countries
Capital PSAPs step up to the task?
Choice of law
ECO is in Denmark. Danish law is transparent.

13. EU regulation would be better?
Perhaps, but EC not interested at this time
EECC proposals does not entail it. Neither does IMCO or ITRE inputs
PSAP DIR will include non-EU members
PSAP DIR can be ready soon
ECC, ECO, ECO Council holds great experience in communications in general and PT ES in emergency communications. Good match?

14. End of the road Green OR red light. No yellow.
WG NaN has a lot of other interesting topics to tend to
Thank you!