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ESC is an alliance of European organisations that strives to reduce the
impact of modern communications and electricity use on health and the environment. We are not against technology, but we are pro safe technology and safe connections.

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    Have your say – emergency 112 eCall system

    You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform “Have your say” with the list of all new EU initiatives open for public consultation. You need to register to write your feedback. https://ec.europa.eu/info/law/better-regulation/have-your-say

    There are always 5 stages of each EU initiative, each stage is open for public consultation for a specific time frame:

    1. In preparation
    2. Call for evidence
    3. Public consultation
    4. Draft act
    5. Commission adoption

    Vehicle safety – updated standards for in-vehicle emergency call systems (eCall)

    About this initiative: Currently, eCall works over 2G and 3G networks. Given that these networks are to be switched off in the years to come, this initiative updates standards for the transition of eCall to 4G and 5G networks.

    Feedback period: for stage 4 it is 27 October 2023 – 24 November 2023

    Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13845-Vehicle-safety-updated-standards-for-in-vehicle-emergency-call-systems-eCall-_en

    Automatic emergency 112 eCall by onboard vehicle systems – EU-wide interoperability specifications

    About this initiative: The 112 eCall automatically dials Europe’s single 112 emergency number in the event of a serious road accident and communicates the vehicle’s location and other relevant data to the emergency services. The purpose of the revision is to adapt the specifications of emergency call centres receiving and handling eCalls to 4G/5G telecommunications networks.

    Feedback period: for stage 4 it is 22 September 2023 – 20 October 2023

    Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13191-Automatic-emergency-112-eCall-by-onboard-vehicle-systems-EU-wide-interoperability-specifications_en

    Both Feedbacks from Europeans for Safe Connections

    Since the final aim of this regulation 305/2013 is upgrading public safety,

    and since it is found in scientific research that exposure to radiation influences responsiveness and quality of decisions,

    we “Europeans for Safe Connections” suggest to add more changes to this ammending regulation:

    1) For personal vehicles / private cars, this system must be voluntary and the manufacturer must offer a variant of the vehicle without installed wireless technologies. However, if the user opts for such an additional feature, the option should be provided for an additional shutdown / disassembly to cancel the exposure.

    2) For all vehicles (private, public, trucks…), the driver and the passengers must be informed about the radiation.

    3) The eCall system (IDS) must be located so that it is as far as possible from the interior of the vehicle to irradiate less.

    Explanation:

    Europeans for Safe Connections is an alliance of European organisations that strives to reduces the impact of modern communications and electricity use on health and the environment. We are not against technology, but we are pro safe technology and safe connections.

    The electromagnetic radiation emitted by wireless technologies poses an increased health risk, especially when these technologies are used inside enclosed metallic enclosures such as cars, busses, trains. Vehicles often contain different types of wireless technology and there is cumulative exposure to different sources of RF EMF.

    The metal walls and windows with metal particles create cascade effect of signal reflections but also present significant attenuation for downlink signals, causing the devices inside the vehicle to transmit at significantly higher power.

    Manufacturers should ensure that wireless technologies communicating with the external environment do not expose vehicle passengers unnecessarily. They should place antennas out of reach of passengers – outside of the vehicle, they should also shield radiating components from occupants, and minimize exposure in terms of intensity and timeframe.

    Each passenger should be given informed consent to the fact that vehicle equipment such as sensors, adaptive systems, infotainment systems and communication systems often emit non-negligible radiation and the vehicle creates very specific conditions for exposure as was mentioned before.

    While additional protection is offered through eCall, this and other wireless measures should not be forced, but should be a matter of the person’s free choice as to whether they wish to use it. At the same time, we feel a pressure to incorporate wireless functions into vehicles. Such impositions discriminate against persons with disabilities or persons who have health problems as a result of exposure to RF EMF. According to the UN treaty handicap, EHS people,( people that suffer from current levels of EMFs)  need to be protected and do have the right to participate in society.These rights need to be protected in this eCall Directive.

    We assume that the promotion of the transition to packet switched networks will further increase the growth of wireless infrastructure and densification of the cellular network, which, while contributing to higher coverage of services, will not benefit the health, the environment and the cost of energy consumption and finance.

    Best regards
    Kamil Bartošák and Petra Bertová
    on behalf of the Europeans for Safe Connections
    This feedback was sent from a wired internet connection
    – No use of harmful radiation
    – Less electricity consumption
    – Increased data security

    Link to our second feedback, part a: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13191-Automatic-emergency-112-eCall-by-onboard-vehicle-systems-EU-wide-interoperability-specifications/F3439146_en

    Link to our second feedback, part b: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13191-Automatic-emergency-112-eCall-by-onboard-vehicle-systems-EU-wide-interoperability-specifications/F3440069_en

    Link to our first feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13845-Vehicle-safety-updated-standards-for-in-vehicle-emergency-call-systems-eCall-/F3441867_en

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