Consumer Protection and
Technical Regulatory Authority,
Endla 10A,
10122 Tallinn,
Estonia.
14 July 2022
Lack of Voice over LTE (VoLTE) interoperability preventing people from calling
emergency services
To whom it may concern,
The European Emergency Number Association (EENA) would like to draw your attention to
a problem which may prevent people from making or receiving voice calls, including calls
to emergency services, once 2G and 3G networks are phased out.
This problem is currently being experienced by some European citizens roaming on mobile
networks in the USA and it is now attracting some media attention. The problem may also
exist for European customers roaming in other parts of the world where 2G/3G has been
phased out. The pace of 2G/3G phaseout is slower in Europe which means that the issue
is not as evident here yet.
In August 2021, telecoms expert, Rudolf Van Der Berg, had already warned that the current
implementation of 4G standards does not ensure compatibility and interoperability between
all devices and networks for VoLTE services. Consequently, users of these devices and
networks are unable to make or receive voice calls based on VoLTE, including voice calls
to emergency services. This becomes particularly problematic when 2G and 3G networks
are phased out and there is no fallback solution to provide a legacy voice service. It should
be noted that even though VoLTE is already widely available in Europe, the vast majority
of mobile originated voice calls to emergency services rely on circuit-switched fallback
(CSFB). This approach ensures continuity of access to emergency services for citizens
travelling throughout Europe.
As the national regulatory authority for electronic communications in your country, we
would kindly ask you to:
1) Circulate this letter to your leadership team and the wholesale and retail
departments within your organisation.
2) Raise the issue in any relevant international coordination bodies in which you
participate (e.g. BEREC, CEPT, ITU etc.)
3) Inform all Mobile Network Operators (MNOs) and Mobile Virtual Network Operators
(MVNOs) in your country of the problem and request that they assess the potential
impact on their customers. If risks are identified, steps should be taken to mitigate
these including:
Avenue de la Toison d'Or, 79
[email protected] +32 (0)2 534 97 89
1060 Brussels, Belgium
a. Informing customers of any limitations of service they may experience while
travelling in the US (and potentially other countries) and advising them of
any steps they could take to deal with these limitations, including on how to
contact emergency services.
b. Raising the issue with roaming partners, network equipment vendors and
handset providers with whom they have established commercial
relationships.
This problem could seriously harm the electronic communications market and put at risk
the safety of its customers. It is therefore necessary that MNOs, MVNOs, handset and
chipsets manufacturers, standardisation bodies, national governments and competent
public authorities work together to address this problem and ensure compatibility and
interoperability of VoLTE services between all networks and VoLTE-capable devices.
Until this problem is addressed and resolved, EENA strongly believes that any plans for
phasing out of 2G and 3G networks in European countries should be reviewed to take
account of the impact on continuity of access to emergency services. Otherwise lives will
unnecessarily be put at risk.
EENA appreciates your cooperation on this matter and should you require any further
information or clarification please contact us.
Yours sincerely,
Gary MACHADO
Executive Director, EENA
Avenue de la Toison d'Or, 79
[email protected] +32 (0)2 534 97 89
1060 Brussels, Belgium
Saatja: <
[email protected]>
Saadetud: 15.07.2022 11:31
Adressaat: Mariko Männa <
[email protected]>; Krista Kask <
[email protected]>
Teema: FW: Lack of Voice over LTE (VoLTE) interoperability preventing people from calling
emergency services
Tähtsus: Kõrgeim
Manused: image001.png; image002.png; image003.png; image004.png;
2022_07_07_Lack_of_VoLTE_Interoperability - CPTRA - Estonia.pdf
Dear Mariko and Krista,
I send you this important information in Anu’s absence. Let me know if you have any questions.
Kind regards,
Freddie
Freddie McBride
Director – Digital Communications Policy & Regulation
European Emergency Number Association - EENA112
EU Transparency Register – Privacy Policy
Tel: +353 86 3874334
Avenue de la Toison d'Or, 79 - 1060 Brussels – Belgium
Email :
[email protected]
Find out more about us! Read about our work in the press:
Bloomberg - Forbes - EUObserver - Engadget - El País - The Next Web
From:
[email protected] <
[email protected]>
Sent: Friday 15 July 2022 09:29
To:
[email protected]
Subject: Lack of Voice over LTE (VoLTE) interoperability preventing people from calling emergency
services
Importance: High
Dear Anu,
I hope this e-mail finds you well.
Please find attached a letter from EENA’s executive director, Gary Machado, providing information on
an issue that could affect citizens’ access to emergency services because of a lack of VoLTE
interoperability between some mobile networks and some handsets.
There are short term and long-term consequences of this issue. In the short term, citizens are put at risk
while roaming in the USA and potentially other countries. In the longer term, we need to seriously
consider the impact of 2G/3G switch-off on continuity of access to emergency services in Europe.
As advocates for public safety, EENA is trying to mobilise all stakeholders to play their part in resolving
the issue. We would be very grateful if you could consider the contents of this letter and circulate it to
your leadership and the relevant departments within your organisation.
Thank you in advance for your kind cooperation.
Best regards,
Freddie
Freddie McBride
Director – Digital Communications Policy & Regulation
European Emergency Number Association - EENA112
EU Transparency Register – Privacy Policy
Tel: +353 86 3874334
Avenue de la Toison d'Or, 79 - 1060 Brussels – Belgium
Email :
[email protected]
Find out more about us! Read about our work in the press:
Bloomberg - Forbes - EUObserver - Engadget - El País - The Next Web