FIA Region I Briefing on Open Telematics Platforms, including eCall
SAFETY CONSUMER PROTECTION
Executive Summary We strongly support the early mandatory introduction of a European-wide interoperable eCall at no extra cost to the consumer, as this low-cost technology will help save thousands of lives on European roads. Further to the crucial contribution to improving road safety, the introduction of telematics technology in the vehicle could bring about a range of side benefits for motorists and mobile consumers. In order to uphold consumers’ freedom of choice and foster healthy competition in the provision of aftermarket services, the Commission is called upon: • To set up a framework favouring the development of additional services to maximise the benefits of the mandatory fitting of OEM in-vehicle eCall devices for consumers; • To standardise the communication interface to in-vehicle telematics devices to support free consumer choice of services and service providers in order to ensure a high level of quality and nondiscriminatory access; • To guarantee free access to on-board vehicle diagnostics systems for independent operators based on customer preferences. Quality and safety standards have to be fulfilled; • To ensure the correct handling of vehicle-related data and related personal data in connection with EU data protection regulations.
Legislative Background The European Commission foresees the mandatory introduction of a European-wide eCall service in all new passenger cars and light duty vehicles as of 2015. In practice, that means that all new vehicles of these categories will be equipped with an in-vehicle telematics platform allowing localisation via a Global Navigation Satellite System as well as the wireless communication of information from and to the vehicle. The FIA fully supports the mandatory deployment of eCall, as it will speed up the rescue of car accidents victims, thus decreasing road fatalities and mitigating the consequences of injuries mainly in rural areas. The basic technology to be installed in all new vehicles as of 2015 – positioning, communication and central processing units, connected to central vehicle control units – can already support more than the eCall functionality as showcased by the number of additional services provided by Third Party Services providers today (e.g. real-time traffic information, position-enhanced breakdown calls, remote diagnostics). All should be done to ensure that consumers effectively reap the full benefits of the telematics technology they will pay for and to ensure the consumer maintains his/her ability to freely choose their preferred service provider.
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FIA Region I Position The technology mandated by the eCall legislation needs to be based on the concept of an open platform. This will safeguard consumers’ freedom of choice and the integrity of the existing competition framework.
Definition of an open platform The term “platform” refers to an in-vehicle IT environment to execute software applications and its technical arrangements, as well as vehicle data transfer which also includes business architecture, certification regime, and specification. The common Application Programming Interface (API) links the platform (i.e. the hardware) and the programmes to be designed (i.e. the software applications). An open platform means that the platform is able to operate applications in parallel from different domains and multiple service providers. It means that consumers are able to benefit in many ways from the additional technology (i.e. telematics services) mandated into their cars. An open platform also allows independent parties to develop and distribute a wealth of different applications and services to potential customers, who can then choose and install such software in their vehicles. An open platform therefore means: • Consumers can benefit from a wide range of interoperable high quality and certified applications and services that can be installed (and changed over time) in the vehicles; • Suppliers and developers can operate in a framework which can boost product diversity, innovation and competition, creating the conditions for successful business cases; • The vehicle manufacturing industry will need to support the ability to integrate and run third party software that has been independently verified and certificated to meet agreed safety, security and performance requirements.
Need to safeguard the competition framework in place Proprietary telematics have the capacity to transfer a wealth of information (including diagnostics, repair and maintenance data) wirelessly, thus circumventing the competition legislative framework. In the future, more and more diagnostics and small repairs will be done remotely, thanks to telematics systems. Remote diagnostics and remote repairs such as remote door unlock functionality, automatic vehicle status reports, and indications on the degree of wear of spare parts, are a reality today. These functionalities are based on the in-vehicle telematics platform installed in vehicles. They are likely to be extensively developed in the near future, thus creating a privileged access to the repair and maintenance market to the benefit of a single aftermarket player. Recent developments show that competition shortcomings could arise in the entirety of the European internal market if no action is taken at this stage. Proprietary access to in-vehicle telematics systems provides the vehicle manufacturers with a proprietary way of identifying and increasingly solving technical problems by means of remote diagnostics, as well as to use the data transmitted from the immobilised vehicle and make it exclusively available to the vehicle manufacturers’ own network. If implemented without open standardised secure access, the Independent Operators would not be able to provide their services, even if the consumer expressly requested the services of a certain provider since they would be cut from the information chain. Currently, such services would include not only emergency or breakdown calls, but also a range of remote diagnostics services. Examples are automatically transferred indications to change vehicle parts or calls to come to the vehicle inspection service including automatically proposed appointments with the next authorised repairer, even if the consumer expressly requested the services of a specific provider. This privileged access
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would hamper the vehicle owner’s right to choose where to perform his car repair and maintenance. The system put in place should not reserve the sole use of the data processed and wirelessly communicated by the in-vehicle telematics platform to manufacturers and their authorised networks. If the right of first access to the data was to be reserved to manufacturers, free competition would then severely be restricted.
Standardised, open access to aftermarket players An open platform will stimulate consumer demand and enhance the market penetration of in-vehicle services and applications, bringing benefits to both consumers and industry. As an example, the open platform approach, together with a strong user community, is one of the reasons behind the success of today’s smartphones. The ability for users to change service providers over the life-time of the vehicle will increase consumer choice, open competition and ultimately the quality of the service offered. It will additionally ensure that mobility remains affordable for consumers. A wide range of applications could be offered to consumers as a public service (safety, traffic information), as personal services (infotainment, guidance) or as business services (fleet management, pas as you go). A report carried out within the European eCall Implementation Platform highlights a variety of private and public services that could be offered on the basis of existing technology. The survey is based on 26 individual answers, representing 16 industry partners and 10 public bodies. The potential applications to be developed mainly fall under the three main categories: 1. Public services (safety, traffic information); 2. Personal comfort (navigation, guidance, infotainment); 3. Business (remote diagnostics, pay-as-you-go). Among the possible services, the breakdown (or business) call – bCall – was the most featured service. A vehicle immobilised by a breakdown usually is an acute threat to road safety and road users, and for this reason, the offering of breakdown services can have a significant positive impact on road safety.
Consumer expectations The following criteria should be used to ensure the consumer-friendly development of any additional application: • Safety: Current research shows that additional applications could be uploaded to the system without jeopardising eCall primary safety functionality. However, the potential distraction factor of these applications should be fully factored in while defining additional functionalities; • Transparency: Consumers need to be fully informed on the data gathered via their vehicle and remain in full control of who should receive this data. The transfer of information must be based on their informed consent and the sales of a specific vehicle may not be made conditional on subscriptions to specific additional services; • Performance and reliability: Consumers demand applications and services of high quality and will choose them accordingly. To boost consumer confidence, any software application should be verified and certified to ensure the highest level of safety; • Privacy: Users have a right to know which data is gathered and to which purpose it will be used. In this context, the success of ITS applications will depend on their ability to address privacy-related issues. In order to ensure the consumer support, rules governing data protection need to apply the following main principles:
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- Data must be fairly processed; - Data must be processed only to the extent that it is required to fulfil operational needs and must not be kept longer than necessary; - Data must be secured and in principle must not be given to third parties unless explicit consent of the consumer is given. To encourage the deployment of privacy friendly solutions, it is important that in-vehicle platforms are developed on the principle of “privacy-by-design”, meaning that companies should build in consumers’ privacy protections at every stage of product development.
Fédération Internationale de l’Automobile (FIA) Region I FIA Region I represents 106 Touring and Motoring Clubs in Europe, the Middle East and Africa from its Brussels office, which total more than 36 million members. The FIA represents the interest of these members as motorists, public transport users, pedestrians and tourists. The FIA’s primary goal is to secure a mobility that is safe, affordable, sustainable and efficient. With these aims in mind the work focuses on Road Safety, Consumer Protection, Environmental Protection, and the promotion of Sustainable Motoring. See more at www.fiaregion1.com.
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Brussels, December 2012