I think AML is certainly a good feature to have. I would probably want to use it if I was making an emergency call.
Using Wi-Fi to determine location is potentially problematic, because that relies upon having a way of querying a regularly-updated dataset mapping Wi-FI SSIDs (or BSSIDS) to geographic locations.
I highly doubt that Purism has the resources to create a database of Wi-Fi network locations, so in practice Wi-Fi geolocation means querying someone else’s database through a web service API. The user’s location and IP address are inherently shared with the web service whenever it is queried.
If we’re using a geolocation web API, then someone probably has to pay for access to the API. Who pays, and how is it funded? Really you need per-device API keys, otherwise users could simply extract the API key from the software and use it for their own purposes, potentially creating high costs for whoever is being billed for usage under that key.
If a suitable Wi-Fi geolocation database, available under a Libre license, can be stored on the phone itself and queried locally, it will take up a lot of storage space. The Mylnikov Geo database is over 600MB, and it’s not even the largest one. Mozilla has a database that it chooses not to distribute, because, it says, doing so could be considered a privacy violation against operators of Wi-Fi networks.
On the other hand, I suppose the regulation C(2018)8383 linked in the edited original post doesn’t appear to specify in what way Wi-Fi should be used for determining location, so perhaps it could be as simple as allowing the user to program in a list of SSIDs which should be associated with specific location coordinates. Or, perhaps, the phone could build its own offline database of WiFi network locations in the locality as it is moved around. (Though, clearly users have the right to disable such data gathering, even if it is only held on the device.)
The regulation says that “Smartphone manufacturers face negligible costs as the solution is software driven,” but it seems to me that this statement can only reasonably be applied to the existing, big players in the market, who already have costly, privacy-violating infrastructure in place that can determine location for other purposes. For Purism, it is clearly going to be disproportionately costly to put in place something equivalent just to facilitate AML for emergency calls.
That is assuming that the Librem 5 isn’t exempt from the regulation on a technicality (e.g. perhaps only the radio modules are classified as radio equipment, and the entire device is simply a portable computer).