With the US LBS market tapped out (in terms of Carrier cooperation and on-deck placements) you have four remaining choices as a developer aspiring to set-up business in Europe (the next LBS frontier (again)).

Use existing Carrier Cell-ID systems (these have been in place for about 7 years), reduce yourself in an exhaustive on-deck brownose act, and build your apps around poor accuracy with gross network-inefficiencies
Wait for SUPL (you'd probably run out of operational cash if you did this)
Go off deck, D2C, and couple any bluetooth-enabled handset with clunky GPS-puck aftermarket accessories [it's ugly, but Jentro, Webraska, and others have done well with it]
Use a Blackberry, go off-deck, or convince a Carrier your RIM app is worth an on-deck placement

Number four is the only free (i.e. liberated) option - a testament to RIM's developer-friendly approach and commitment to GPS in an open and accessible device environment independent of Carrier control (except when explicitly told to disable it). Trimble Outdoors recently chose option four to deploy three of their outdoor products. The Blackberry's available in Europe are not exactly the hard gear Trimble would typically use, but with the business freedom offered by RIM to deploy, why not exersize this choice!