Summary/TL;DR:

Starting 1 November 2024, a significant change to Australia’s Emergency Calling rules will require network providers to Block Devices they believe cannot call triple zero (000/112).

The carriers must completely cease providing service to that device.
Even if the device has working calling, SMS and Data!

This is due to an update to the ‘Emergency Call Service Determination’ (ECSD), in the explanatory statement it says.

Subsection 6(2) directs ACMA to include requirements for providers to identify mobile phones unable to access Triple Zero, notify the user, provide assistance if necessary to access an alternative mobile phone, and cease providing service to the affected device. Providers will also be required to not provide service to a prospective customer seeking service with an affected mobile phone. This requirement makes clear the responsibility providers have to ensure mobile networks provide access to the emergency call service.” [..] “The amendments to the Determination to be made under section 6(2) are to be determined and commence in full by 1 November 2024.

ACMA (Emergency Call Service Determination) Direction 2024 — Explanatory Statement
https://www.legislation.gov.au/F2024L01103/asmade/text/explanatory-statement

The providers are not informing people they will be artificially blocked from connecting starting in November, even if they have working calling, emergency calling, data and SMS.

Optus is already doing this for new customers as of 10 September!

My phone stopped working | Optus — As of 3 September 2024
https://www.optus.com.au/support/mobiles-tablets-wearables/important-changes-3g/my-phone-stopped-working

Their updated policy document announcing this was only published on 3 September, 1 day before the new rules were posted on the Government Website (4 Sep 24). This was not on their website a month ago!

The only devices exempt from the block under the determination are those used be travellers/roamers. (Section 2. e.). However there are major issues with making VoLTE Emergency Calls when Roaming which aren’t at all addressed by this determination, see below for more info.

Skip to What you Can Do! Section (including Petition Link)

Why this is a Problem

While the amendments aim to ensure access to emergency services, the changes will have severe consequences for consumers, competition, and the overall accessibility of mobile services. Whilst also not addressing the core technical standardisation failures with VoLTE Calling and Emergency Calling.

This policy essentially penalises customers for using devices that work but were not purchased directly from the telcos or their partners. Once in effect, this would further concentrate profits and market control to the telcos & major handset makers, and severely limit competition & choice in the market.

Under the updated ECSD, telcos must identify and notify users of phones deemed incapable of accessing emergency services, assist them in finding alternative devices, and ultimately cease service to these phones.

This will likely impact devices that have been manually updated to work for VoLTE Calling and Emergency Calling as they aren’t ‘officially’ supported.

Misleading Information from Industry

The SMS Checker does not actually do a test on for calling and emergency calling on the device, it simply looks up that phone model in an established ‘compatibility list’ and reports at aggregate what the telcos believe that device model is capable of on their network.

Devices may not have all the right settings enabled or may be running an out-of-date software version and come switch-off will either lose call service or emergency call service, however the SMS system may say the device is fine.

The telcos and industry somewhat acknowledge this with wording to the effect of “Please remember to keep your device software updated”

3498 SMS Checker — iPhone 6s Plus — Vodafone AU

Additionally Tools like the ‘AMTA 3G Lookup Service’ are not accurate or reliable. AMTA knows this, hence why you need to agree to a long list of terms & conditions before using it.

AMTA 3G Lookup Service Terms & Conditions — Accuracy Disclosure
https://amta.org.au/3g-closure-old/check-my-device/

This new ACMA policy is deeply disturbing because many consumers, including myself, own fully functional devices that can make VoLTE calls and emergency calls, yet are deemed “incompatible” by the telcos.

Xperia XZ1 Running a Telstra Modem Configuration with Working VoLTE Calling — Same Chipset as the Supported XZ Premium — Device has working VoLTE Calling and Emergency Calling

These are devices with the exact same hardware and software as ‘officially supported’ devices, the only difference is the telcos didn’t sell them.

Telstra’s website even says:

“If you didn’t buy your device from Telstra, you’ll need to get technical assistance to see if you can enable VoLTE on your compatible device.”

How do I enable VoLTE on my mobile phone? — Telstra
https://www.telstra.com.au/support/mobiles-devices/enable-volte-mobile-phone

Even though that messaging is not detailed enough, people have done exactly that!

Telstra customers have obtained technical assistance and updated their devices to work on the Telstra network, but Telstra says the device doesn’t work, even when it does, including for emergency calling!

The industry is reliant on established device testing, ‘network compatibility lists’ and VoLTE Registration logs, they are more or less assuming all ‘supported’ devices will work post shutdown.

They have no reliable way to detect if a customer’s individual device can actually make emergency calls. The device would need to first place an emergency call to know for absolute certain.

The SMS ‘3498’ system makes a lot of assumptions about the device, including the software it’s running and the settings enabled.

It doesn’t check anything on the device, for info on how to actually test a device see below.

Changes to the Emergency Call Service Determination Rules — ACMA

Below is an extract from the updated Determination Rules. The direction was publically uploaded to the Legislation.gov.au website on 4 September 2024 (despite being written and dated 21 August). The Direction is already “In Force”.

On 9 September the updated determination was tabled in the House and Senate.

ACMA (Emergency Call Service Determination) Direction 2024 — F2024L01103 — 04 September 2024 https://www.legislation.gov.au/F2024L01103/asmade/text
https://www.legislation.gov.au/F2024L01103/asmade/text

The ECSD also has no provisions requiring providers supply customers with replacement devices that are ‘like-for-like’.

The providers have been offering customer’s low-end network locked devices and basic ‘feature phones’, not replacements that are equivalent to the current devices people paid for and own.

Vodafone was offering a free Network Locked ‘Feature Phone’, apparently worth $59. However this device was on sale for $39 in late August 2024.

Vodafone V One 4G Offer 19 August 2024 — $59 ‘Value’ actually on Sale for $39 on 29 August 2024
https://www.vodafone.com.au/prepaid/mobile-phones/v-one-4g

Optus — ‘Keeping our customers safe’

Optus: ‘Our safety policy on Triple Zero impacted devices.’

As of 10 September Optus is already doing this for new customers or customers that re-connect to a ‘non-compatible’ phone.

However, Optus’s policy announcing this change was only published on 3 September 2024, which is 1 day prior to the new determination being published on the Legislation.gov.au Website. (Current Optus Policy PDF metadata shows it was saved 9 Sep)

My phone stopped working | Optus — As of 3 September 2024
https://www.optus.com.au/support/mobiles-tablets-wearables/important-changes-3g/my-phone-stopped-working

Optus Mobile Safety Policy — 3 Sep 2024

Optus — An Important Update on Mobile Handset Safety — 3 September 2024

Note how they are careful to not use the word ‘block’, but instead use ‘no longer support’ or ‘won’t work’. The ECSD is clear that network providers have to cease providing services to ‘affected’ devices.

Optus Website Prior to 3 September

24 Aug 2024 — Archive.org

Prior to the to September Change change to the ECSD, the Optus website made it clear the device may continue to function but:

you may no longer be able to make calls, send or receive texts, make 000 calls or connect to the internet on the Optus network’.

Optus strongly recommended their customers upgrade to ‘compatible’ devices but devices would not be blocked if not upgraded.

There was no indication people would be artificially blocked from connecting starting in November, even if they have working calling, data and SMS!

It seems not even the Industry was planning on doing this.

Important Changes to 3G | Optus Website 24 August 2024 — Archive.org
Important Changes to 3G | Optus Website 24 August 2024 — Archive.org https://web.archive.org/web/20240824112055/https://www.optus.com.au/support/mobiles-tablets-wearables/important-changes-3g

The only previous messaging that comes close is Optus (and their MVNO Amaysim) telling customers that their 4G device would entirely stop working (as if it’s a 3G Only) device, and telling customers their auto-payment renewals would be switched-off until they upgraded!
4G devices that lack VoLTE would continue to have working Data & SMS.

The disabling of ‘Auto-Renew’ alone is in my view extremely harmful behaviour. It puts undue pressure on customers to upgrade, even when that may not be necessary.

Disabling the auto-renew would also result in many people being unnecessarily cut off from working mobile services, even though their device may continue to work post shutdown.

It also has major potential implications for other 4G equipment that does not require calling to function (only 4G data & SMS), some businesses or industry customers may not be aware of this until the payments stop and service is cut-off.

Previous Messaging from Telstra about ‘disconnecting’ Service prior to September

Additionally, on the 14th of May Amaysim sent out a marketing email saying “IT’LL BE MAYHEM” when the switch-off occurs.

This sort of marketing material is extremely unnecessary and only serves to drive people to panic buy new phones.

If the providers, Government and regulators had properly managed this, it would not be “Mayhem”.

The 8 November Optus Outage

The failure by Optus last year during the 8 November Outage is the key factor behind this change and the new Determination Rules.

Blocking handsets is to entirely sweep the compatibility problem under the rug.

By making this change, the industry and regulators are entirely absolved of any responsibility or accountability for failing to properly address the issues with Calling and Emergency Calling over 4G.

We need policy that actually requires the industry to actually fix the problem!

Optus reveals 10 times more people affected by triple-0 failures than previously known https://www.abc.net.au/news/2024-01-23/optus-network-outage-triple-0-emergency-calls-wider-than-thought/103380928

ABC News — Optus Outage Inquiry Report — Sep 2024: https://www.abc.net.au/news/2024-09-27/optus-outage-senate-inquiry-report/104406028

In 2019 Optus even said to the ACCC that “VOLTE cannot be the sole technology relied upon to provide voice services. […]” due to “..incompatible handsets.”

Yet they have proceeded regardless without first addressing the compatibility issues.

Optus — ‘Optus submission to the MTAS FAD discussion paper’ ACCC — September 2019 — PG5 https://www.accc.gov.au/system/files/Optus%20submission%20to%20the%20MTAS%20FAD%20discussion%20paper.pdf

In late 2019 Telstra announced its plans to switch off 3G in mid 2024.

SMH — The end is nigh for Telstra’s 3G network; termination set for 2024 — October 2019
https://www.smh.com.au/technology/the-end-is-nigh-for-telstra-s-3g-network-termination-set-for-2024-20191009-p52z0n.html

However, only a few months prior (in April) the ACMA said the following in the ‘Reconfiguring the 900 MHz band’ paper. (900Mhz is one of the 3G Bands, it’s currently used by Optus)

“One of the key issues for licensees is the uncertain timeline for the proliferation of Voice Over LTE (VoLTE)-enabled devices among consumers. The ACMA sought information from incumbent licensees on the expected timing and speed of consumer migration towards the use of VOLTE handsets, but still has no clear indication of intended migration paths. In the absence of receiving any further information to support a more detailed assessment, the ACMA considers that the proposed timeline outlined in this option (i.e. a mid-2024 clearance date for existing apparatus licences) provides enough opportunity for carriers to mitigate risks to the continuity of consumer services.”

ACMA — ‘Reconfiguring the 900 MHz band — Options paper’ — April 2019

When the ACMA made that assessment Android and iOS didn’t even have VoLTE Roaming Support. (Android 12–2021, iOS 15–2021)

It does seem the proposed switch-off dates have been chosen not on specific compatibility or standardisation criteria, but rather based on commercial interests.

Note: The other telcos are still bound by the new rules, but at the time of writing are yet to formally announce an ‘incompatible’ device blocking policy. This may occur closer to Nov 1. Watch this space.
Optus was likely the first to formerly announce this policy so they could get in front of the Optus Outage Senate Inquiry Report released 27 September 2024.

Findings from the Government Review into the Outage

In the Bean Review into the 8 November Optus Outage it was noted that there is minimal if any testing between devices across networks and that:

“The carriers do not test with and/or across each other’s networks.” And that “…the testing does not guarantee […] that calls will be picked up when a competitor’s network is unavailable.”

“Current testing regimes do not cover all devices sold by all carriers, and there is no system for addressing the capabilities of the devices of customers who bring their own. The countless variations in handsets, handset and SIM settings, and the alternative configurations between nodes within each of the networks, present a significant risk to the certain operation of the camp on [000] functionality in all (or as many as might reasonably be anticipated) circumstances. This needs to be addressed.”

Department of Infrastructure — ‘Review into the Optus outage of 8 November 2023 — Final Report’ — March 2024 — Pg22

It appears the ACMA, Department and Industry have decided not to properly address the BYOD device issue and will instead now require people to only use ‘supported’ handsets purchased directly from their telcos or associated handset partners.

With this policy change you can now no longer use any device you want from any provider in the world, even if it may work perfectly!

Older ‘incompatible’ devices running 3rd party ROMS and software like LineageOS (and others) would also be unnecessarily blocked. Custom ROM communities are able to fix the VoLTE compatibility issues with certain devices.

Complaints regarding Providers ‘Upselling’

At the Inquiry to the Shutdown of the 3G Mobile Network, Ms Cynthia Gebert, Telecommunications Industry Ombudsman (TIO), confirmed that the TIO had received numerous complaints about ‘upselling’ unnecessary devices and services:

“We have seen some customers coming to us who have approached their telco in order to work out what device they need and have been encouraged to purchase additional devices that may not have been a direct replacement.
[…]
it can mean a more expensive plan than maybe what they were on before. But we’ve also seen instances where there have been additional products put forward by the provider and sold as a broader package.”

Source: Shutdown of the 3g Mobile Network: Interim Report — Affordability

Telcos admit to misleading customers regarding the compatibility of devices — u/l3att Reddit.com

Additionally, customers have been told by the Telcos their device is “incompatible” and they have to upgrade, for only months later to be told, ‘sorry that was a mistake, your device will continue to work’.

How many customers have replaced their devices due to this sort of false and misleading information sent out by the telcos?

Again this goes back to the Blog Article by Aussie Broadband I mentioned in my Senate Inquiry Submission. An extract is below.

Pricing Increases & 5G Investment Returns

Earlier this year (in 2024) Optus rolled-out increases to their wholesale mobile pricing. Following from the pricing changes there was a blog article posted by Jonathan Prosser ‘Chief Strategy Officer’ from Aussie Broadband. (Aussie Broadband use the Optus Network for Mobile Services)

In the article he talks about how “the adoption of 5G has been a much slower crawl than anticipated.” and that “Australians have not embraced the upgrade to 5G with the same fervour as with 3G or 4G in the years prior. Of our mobile customers, those with 5G plans only account for about 2%”. and that “ ‘consumers appear indifferent to 5G’, with nearly 3 in 4 respondents saying they were not actively looking to upgrade.

He goes on to say,

“These innovations don’t add the kind of value shareholders are looking for just yet, but public companies still need to show their shareholders that they are recouping their investment in 5G.” and that “…mobile network operators are struggling to deliver a return-on-invested-capital (ROIC) that is palatable to investors.”

Aussie Broadband — ‘Think like an Aussie: 5G and our mobile plan refresh’ — 2024–02 01:
https://www.aussiebroadband.com.au/blog/think-like-an-aussie-5g-and-our-mobile-plan-refresh/

As I wrote in my Optus Inquiry Submission (16 Nov 2023):

It’s clear the driving forces at the wheel are just chasing ever increasing profits, sales and market control whilst fundamentally failing people when it’s most critical and simultaneously self-absolving themselves of any and all responsibility & accountability.

The Providers Commercial Interests should not be put ahead of the broader Public Interest. The telcos are there to serve their customers, not the other way around.

The providers have been eager to push this issue back onto consumers, getting people to check their own devices, check device manuals & settings, contact phone manufactures or go out and spend hundreds of dollars for new devices.

This shifting of responsibility back onto users and minimising their own responsibility is starkly telling of the industry’s prioritisation of profit over people.

Over many years the providers & industry have been allowed to manufacture the problem and they now get the opportunity to sell customers the solution with new handsets, all whilst harming competition, increasing profits and cutting costs by shutting down the 3G network.

Read More at the Article Below or listen to me speaking to the Inquiry in July:

YouTube — Senate Inquiry — Shutdown of the 3G mobile network | 23/07/2024–2hrs 10m — James Parker

Exemption for International Roamers

Furthermore it appears the ACMA, Department and Industry is not addressing the very serious issues with placing 4G Emergency Calls when Roaming.

Section (2)(e) exempts telcos from blocking ‘affected’ handsets of travellers/roaming customers.

Ensuring they’ve received a text message to say their device won’t work for (000/112) emergency calling is apparently enough?!

As a result of the Vodafone 3G switch-off in January, inbound Roaming customers have been receiving text messages advising they will no longer have access to voice, text or data and emergency calling whilst roaming in Australia.

Even customers with 5G iPhones have received such text messages.
An example is below.

Freedom Mobile Roaming Customer in Australia — Text RE 3G Shutdown and loss of 911 Access — iPhone 14 Pro

There is nothing in the determination about fixing the standardisation issues, providing software updates or app based calling mitigations.

Problems with VoLTE Roaming & Emergency Calling

As I wrote in my Inquiry Submission, ~60–70% of Android Handsets in use Globally do not have VoLTE Roaming Support (2021 or newer/Android 12+).

‘Optus Device Compatibility & VoLTE Roaming Activation’ — May 2024
https://www.optus.com.au/mobile/plans/international-roaming/volte
Android 13 distribution April 2023 — Source: Android Authority & 9to5Google https://www.androidauthority.com/android-13-distribution-2023-3312803 https://9to5google.com/2023/04/13/android-13-market-share-stats/2803

Devices without VoLTE Roaming won’t be able to make calls whilst roaming on 4G, this issue also impacts emergency calls on many devices.

A few years ago the “Canadian Wireless Telecom Association” warned about this issue for Roaming customers.

As shown at EENA 2022, it’s not enough to have a 4G VoLTE Supported phone, but you need a phone that supports VoLTE Roaming. The slide asserts that without VoLTE Roaming:

“Voice services (including emergency calls to 911) will no longer be supported on AT&T and T-Mobile when they discontinue their 3G/HSPA network services”.

‘Should we stop the shutdown of 2G/3G to save lives??’ — Slide 5 — Rudolf van der Berg — Stratix — EENA 2022
https://drive.google.com/file/d/1WC16k8C1gpeFRJif23yDIuLSRg1OJOnZ/view
YouTube — ‘EENA 2022: Access to emergency services is being impacted by the lack of VoLTE interoperability’

In the answers to Telstra’s Questions on Notice from the Inquiry they said that in July there were 2.3 million international roaming devices connected to their network and that Telstra ‘cannot confirm the 4G Voice calling capability of the devices’!

Telstra — Answers to questions taken on notice at a public hearing on 24 July 2024 (received 1 August 2024) https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Rural_and_Regional_Affairs_and_Transport/3GNetworkShutdown/Additional_Documents

We risk seeing hundreds of people per day being in need of help from emergency services but will be unable to call 000!

That includes roamers with 4G & 5G devices that support VoLTE Calling and 4G Emergency Calling!

Device Compatibility Issues

There are devices that are configured for 4G Emergency Calls in other countries, but when you try to make an Emergency Call here on 4G that device just gets stuck on calling and the call will never go through!

4G Emergency Calling - Incompatibility Example

4G Emergency Call — Failure to Attach to 4G Network — Stuck on ‘Calling’ — 4G Fail ❌

Below is a table of tested modem software (configs) for various providers in the world. There is no one configuration for VoLTE calling that all devices and networks universally support.

Some networks (like Optus & Vodafone) & devices support a Generic/’Open Market Device’ VoLTE Profile (e.g GSMA IR.92), however those configurations do not work on Telstra.

The test results noted with ‘NO — Call Fails’ are devices (firmware) that support 4G Emergency calling in their respective home market or network, but Emergency Calls fail to connect on Australian 4G Networks even when 3G is available!

Sony Xperia XZ1 — Qualcomm Snapdragon 835 Chipset — Tested Q2 2024 — Extract from Testing

Learn More Below:

This is not something we have ever seen before!
With 2G & 3G you can make an emergency call with any device on any 2G or 3G network in the world.

T-Mobile in the US still has a 2G network in many areas, it was not shut down in April, (as originally believed by the Department at the Inquiry) and it still has not been completely shut down.

T-Mobile 2G Coverage Map (Pink) — 31 August 2024
https://coverage.lart2150.com/vector/#b=GSM&m=2024-08-31&m2=2024-08-31&b2=R2G

Since 2022 T-Mobile’s 2G network has masked the issues of placing an Emergency call in the US (especially for roamers) and the effects are yet to be fully experienced there.

There are very few countries that have fully switched-off both 2G and 3G, and for these very reasons.

Governments and regulators need to intervene and stop the shutdown of 2G/3G Networks until the 4G Calling Standards and compatibility issues have been fixed.

As I said in my Optus Inquiry Submission (Nov 2023) it’s clear that the shutdown of our 3G networks needs to be delayed to at least the end of 2025.

But realistically it will take longer than that to fix the damage caused by the broken 4G calling standards that have been rolled out to networks and devices across the globe.

Brand new devices are still impacted by network compatibility issues.

By stark contrast France will have 3G until approx 2028/2029 and the UK will be keeping their 2G network around until approx 2030/2033. Both countries have more than 2.5x our population.

Kore Wireless — ‘Global 2G & 3G Network Closures’
https://www.korewireless.com/2g-3g-network-sunset-dates

Mobile UK — ‘2G/3G Switch Off’
https://www.mobileuk.org/2g-3g-switch-off

There needs to be one universal baseline standard on all devices and networks, that allows anyone to use any device, purchased from any provider or brand and use it on any network in the world and make calls, emergency calls and roaming calls.

Just like what we’ve had for 20–30 years with 2G and 3G. None of that currently exists with VoLTE and Calling on 4G.

We really need to wait until Europe and much larger markets actually address the compatibility and standardisation issues with 4G Calling and Emergency Calling, this is a global issue and requires a coordinated effort to fix the problem.

Interim solutions and mitigations for these issues do exist and are possible.

Calling apps, firmware updates and other software mitigations need to be provided to domestic customers and roamers prior to switch-off.

Australia’s 3G switch-off needs to be permanently postponed until this occurs and the compatibility issues are resolved.

Normal 4G Emergency Calling Behaviour (With Active Sim & VoLTE)

4G Emergency Call on 2100Mhz with a Sim Card & Working VoLTE Service — 4G Success ✅

Description: In the above example the device successfully places an Emergency Call over 4G with an active ‘VoLTE’ service. This is the intended Calling behaviour for a device that supports 4G Emergency Calls.

The device (Android 9 — Xperia XZ1C — SD 835) was running a GSMA (‘Open Market’) IR.92 + IR.51 VoLTE Modem Configuration. That configuration has both working 4G VoLTE Calling on Optus and Vodafone AU including Emergency Calling (as shown above), in addition to supporting WiFi Calling. (See here for more info)

However, as Vodafone did not sell this model of device and it was not sold in Australia they do not recognise that it supports both VoLTE Calling and Emergency Calling!

Australia’s 3G Switch-off 3498 ‘SMS’ Device Tester/Checker — SMS Result

Other Examples

The Device shown here is a 4G Device with Working VoLTE Calling yet the SMS says the device needs to be upgraded to continue to make calls, send messages and connect to the internet, when none of that is even remotely true.

Software Mitigations & Solutions

Known affected devices can continue to receive daily text messages and outbound call messages notifying of the possible issues with Emergency Calling over 4G.

To me it’s clear the industry has no real idea what exactly will work post shutdown. The Providers Commercial Interests must not be put ahead of the broader Public Interest.

Service Waivers

There already exist waivers for service guarantees for NBN Phone products, this includes agreeing to terms that state ‘calls may not work during a network outage or power outage’, including to 000!

Customers wanting to use an “unsupported” BYO (Bring your Own) Device could voluntarily opt-in and agree to a waiver that would remove any and all technical restrictions for their service. This waiver could require 6 monthly or annual re-signing.

Mobile services/devices with this waiver active could hear a short pre-recorded reminder message at least once a day when making a call in addition to regular text messages.

The ACMA and Government could require the telcos to ensure customers agree to such a waiver for ‘unsupported’ BYO devices prior to switch-off.

Optus Self Supplied Modems — Calling Limitations

https://www.optus.com.au/broadband-nbn/home-broadband/plans/shop#optusmodem

Internode NBN Phone Agreement Limitations

Internode NBN Phone Waiver Agreement
https://www.internode.on.net/pdf/legal/cra/internode-nbn-phone-service-description.pdf

ACMA — CSG — Customer Service Guarantee
https://www.acma.gov.au/customer-service-guarantee

4G Emergency Call Testing

Post shutdown the telcos could provide a test number for emergency calling or a method that allows customers prove their device will work for emergency calling.

Customers with fully working devices that are ‘unsupported’ must not be blocked from using them and must not be subjected to repeated false & misleading text messages and outbound call recordings, (especially if they can demonstrate the device works).

A Test number for Emergency Calling was suggested earlier this year but not looked into further after Telstra raised concerns.

The Department and Industry was also of the view that user testing was not possible prior to Shutdown.

FOI 24–353- Briefs to the Minister on the 3G network switch offs — 27 Mar 23 and 27 March 2024.
https://www.infrastructure.gov.au/sites/default/files/documents/foi-24-353--documents-for-release--pdf.pdf

However testing can be achieved with some devices prior to shutdown, and ‘post shutdown’ device testing would be far easier as there would be no 3G network to fall back on.

Affected devices can also be fixed with software changes and updates, either by the manufacturer or by the user.

Furthermore the industry also needs to be required to correct their messaging and stop telling customers with perfectly working phones they need to upgrade.

This practice has been occurring for months and there appears to be no accountability for the telcos providing false and misleading information to customers.

The industry should be required to implement real technical fixes that allow all consumers to access the networks, regardless of where they purchased their device.

VoIP Dialler/Calling App

Additionally users with affected devices could be provided with a downloadable VoIP Calling app that provides access to Emergency Calling via 4G Mobile Data or WiFi. A similar Livestreaming facility has already been rolled-out for NSW Police.

Such a mitigation option is entirely feasible and necessary to address the roaming emergency calling issue. As long as someone has working Mobile Data/Coverage or WiFi they could still contact Emergency Services.

ABC News 25 Aug 24 — People who call 000 in NSW, now have the option to live stream their emergency

NSW Police BluLink

As previously mentioned in my original Inquiry submission (#32) and when speaking to the Committee, the issues around VoLTE Calling compatibility and switching between networks could be largely mitigated with the use of (VoIP) Calling Applications that use the 4G/LTE Mobile Data connection of a smartphone.

Despite claims from the providers and regulators at the 24 July hearing, App Based calling such as that used by ‘Jio Mobile’ is a genuine option to mitigate some of the compatibility issues faced by consumers.

New hardware would only be required if users had a 2G/3G enabled device (e.g Jio’s ‘JioFi’ Product). Android Phones with 4G/LTE support can use the Jio Network for calls via the ‘JioCall’ application without the need for the device to have native VoLTE Calling support on Jio.

The ACMA was asked about a downloadable VoIP Calling App being provided to customers (like Jio Mobile did in 2017), the ACMA said new hardware would be required, when that isn’t even remotely true!

24 July Hearing — ACMA RE Calling Apps:
https://www.youtube.com/live/HvDvnfWTou0?si=zcSWtbUvbINrAvPw&t=10237
Read more about this here.

From Late 2016 the JioCall app (originally Jio4GVoice) was made available for download by Jio users. Jio Mobile launched as a 4G Only Network in India in 2016/2017 and most handsets did not have native (VoLTE) 4G Calling firmware support with Jio.

When the service was launched India’s Economic Times noted the following in an article:

“Jio4GVoice allows subscribers to become a Jio customer, without the need to buy a new device. After obtaining their Jio SIM, subscribers are able to download the Jio4GVoice App from the Google Play store. Jio subscribers can make and receive voice and video calls seamlessly on the Jio network, without the requirement of an LTE-enabled device, and benefit from the high call quality that the Jio network brings.

‘Reliance’s Jio4GVoice is world’s largest and fastest growing RCS service’ — ET Telecom — 2017–04–11

Due to the 4G standardisation and compatibility issues there are devices in use that only support regular calls on one network but do support 4G emergency calling on all networks. With an app such as ‘JioCall’ end users could continue to access calling services on different networks without the need for explicit firmware support or firmware updates on the device.

As mentioned, such an application could also provide access to emergency services (000) via Mobile Data or WiFi. Most modern NBN ‘landline’ phone services are ‘VoIP’ (Voice over Internet Protocol) based solutions that connect to the provider network via the internet, access to 000 is also provided this way. Mobile Customers using an app could expect a similar level of service to an NBN based VoIP Phone solution.

JioCall — Reliance Jio Website
https://www.jio.com/jcms/apps/jiocall

In addition to Jio there are other Application based (VoIP) services that can provide users with access to calling and messaging with a real phone number, there is no requirement for both users to have an app installed to communicate.

The Telcos denied that device software updates or VoIP Calling Apps could be provided to fix or even mitigate the issues. Saying that other users would also need to have the app, when that is absolute nonsense.

24 July Hearing — Telcos RE Device Updates:
https://www.youtube.com/live/HvDvnfWTou0?si=8hiVpPfSlVI4IZnf&t=4949

As Jio is a Network Provider they are able to offer a solution directly and their customers don’t have to sign-up to a third party VoIP Calling application or platform and people can continue to use their Jio Number.

SmartVoLTE’ is another App based solution that was provided by the Indonesian Provider Smartfren. Customers without native VoLTE support on Smartfren can use the SmartVoLTE VoIP Dialer App.

What you can do!

If you are an Australian Citizen please contact to your local Federal Member of Parliament, Senators, the Communications Minister, the ACCC and your Telco.

Either via email, phone or old fashion snail mail.
The more messages sent the better.

You can find out your electorate at the link below.

When contacting your politicians please remember to include your electorate or suburb, as well as a name and basic contact details. If you don’t provide where you are from you won’t get a response.

AEC Electorate:
https://electorate.aec.gov.au/

ACCC — Report a Consumer Issue:
https://www.accc.gov.au/about-us/contact-us-or-report-an-issue/report-a-consumer-issue

Communications Minister Contact
https://minister.infrastructure.gov.au/rowland/contact

Sign this Change.org Petition
Short Link: https://www.change.org/StopTelcoDeviceBlocking
Full Link:
https://www.change.org/p/stop-telco-4g-5g-device-blocking-volte-restrictions-australia-s-3g-shutdown

I will try and establish a APH Website e-Petition if there is strong interest, they can take some time to set up. So contacting your local member, Senators and the Minister is priority #1.

Raise the Alarm and Share this Story and the Petition!

Please share this with various media, Tech Youtuber’s, online communities and others. More more people who know, the better.

Unless people are properly informed and are armed with the facts this will start happening elsewhere in the world as 2G and 3G are shutdown in the next 1–2 years. Much of Europe is looking at late 2025/2026.

Contact information & other info can be found below.

https://twitter.com/JamesDwho
https://youtube.com/JamesDwho/about

Example Template Letter: (Adapt as Required)
https://docs.google.com/document/d/1ZyFiQ7SvLwizhoY-0t_x2cWvSlmXAr4eod29x0f0xKw/edit?usp=sharing

To the Hon [YOUR MEMBER HERE] MP,

I am writing to you to raise urgent and very serious concerns regarding the recent changes made by the ACMA to the Emergency Call Service Determination (ECSD), set to take effect on 1 Nov 2024.

While the amendments aim to ensure access to emergency services, they will have severe consequences for consumers, competition, and the overall accessibility of mobile services. Whilst also not addressing the core technical standardisation failures with VoLTE Calling and Emergency Calling.

[…]

Sources & References

3G Switch-Off Could Stop Triple-Zero Calls | 10 News First — 17 March 2024
https://www.youtube.com/watch?v=iK98wI6d-W0

ABC — ‘Millions of Devices Caught out by 3G Shutdown’ — Jane Norman — 8 April 2024
https://www.abc.net.au/news/2024-04-08/million-iphone-android-devices-caught-out-3g-shutdown/103673864

ABC — ‘Telstra to Extend 3G Shutdown’ — Jane Norman — 6 May 2024
https://www.abc.net.au/news/2024-05-06/telstra-to-extend-3g-network-shutdown/103808110

Senate Estimates 30 May 2024 Video Stream — Department of Infrastructure
https://www.aph.gov.au/News_and_Events/Watch_Read_Listen/ParlView/video/2488638?startTime=04480 (Start 10:04)
https://www.aph.gov.au/News_and_Events/Watch_Read_Listen/ParlView/video/2488638?startTime=08118 (Start 11:05)

Shutdown of the 3G mobile network — Australian Parliament Senate Inquiry
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Rural_and_Regional_Affairs_and_Transport/3GNetworkShutdown

Senate Inquiry — Shutdown of the 3G mobile network — Submission 32 — James Parker
https://drive.google.com/file/d/1wrwLDogtUCUn70GWY8yCsqbZvzZEvj2q/view?usp=sharing

Senate Inquiry — Shutdown of the 3G mobile network — Supplementary Submission 32 — James Parker
https://drive.google.com/file/d/1SNsWzH5rOWl62Wxe0I0dQbyDMvLQQcPm/view?usp=sharing

Rural & Regional Affairs & Transport — 3G Shutdown Senate Inquiry — 23/07/2024 — Public Hearing
https://www.youtube.com/live/Tlofv0UfoI0?t=7833s

Rural & Regional Affairs & Transport — 3G Shutdown Senate Inquiry — 24/07/2024 — Public Hearing
https://www.youtube.com/live/HvDvnfWTou0?t=355s

Rural and Regional Affairs and Transport References Committee — 23/07/2024 — Shutdown of the 3G mobile network — Hansard
https://www.aph.gov.au/Parliamentary_Business/Hansard/Hansard_Display?bid=committees/commsen/28167/&sid=0004

Quarterly reports from Telstra & Optus regarding 3G switch offs from 27 Mar 2023 to 27 Mar 2024
https://www.infrastructure.gov.au/sites/default/files/documents/foi-24-352--documents-for-release--pdf.pdf
https://www.infrastructure.gov.au/about-us/freedom-information/freedom-information-disclosure-log

Correspondence to, and responses from, the Minister for Communications relating to the shutdown of 3G networks between 27 March 2023 and 27 March 2024
https://www.infrastructure.gov.au/sites/default/files/documents/foi-24-354--documents-for-release--pdf.pdf

Australian Parliament Senate Inquiry into the 8 Nov 2023 Optus Outage:
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/OptusNetworkOutage

Additional References

What is a Circuit Switched Fallback (CSFB)?
https://ribboncommunications.com/company/get-help/glossary/csfb

Siretta — Circuit Switched vs Packet Switched Networks
https://web.archive.org/web/20231206141205/https://media.digikey.com/resources/siretta/siretta-circuit-switched-vs-packet-switched-networks.pdf

Doug Makishima, GSMA — ITU Workshop on “Voice and Video over LTE”
https://www.itu.int/en/ITU-T/Workshops-and-Seminars/conformity-interoperability/20150112/Documents/Abstracts%20and%20Presentations/S3P5_Doug_Makishima.pdf

GSMA New VoLTE Specification to remove Market Fragmentation (07/2016):
https://www.gsma.com/futurenetworks/digest/new-gsma-volte-specification-removes-market-fragmentation/

Annoyed that your phone won’t work on VoLTE or VoWIFI on other carriers? GSMA is working it:
https://ausdroid.net/news/2017/11/18/annoyed-phone-wont-work-volte-vowifi-carriers-gsma-theyre-working-answer/

GCF GSMA IR92 VoLTE Spec Presentation: https://www.globalcertificationforum.org/static/uploaded/c1683a68-b94c-4c75-a6470136dfed73a9.pdf

OptimERA- ‘VoLTE Emergency Calls — Testing of 3GPPCompliance in OEM Handsets’ — January 2020
https://optimerainc.com/wp-content/uploads/2021/11/OptimERA_VoLTE_Emergency_Calls_Report.pdf

EENA — Ensuring continuity of access to emergency services/VoLTE Standardisation Problem
https://eena.org/blog/webinars/volte-standardisation-problem/

The Potential Perils of 2G and 3G Switch Offs
https://eena.org/knowledge-hub/press-releases/the-potential-perils-of-2g-and-3g-switch-offs/

‘Should we stop the shutdown of 2G/3G to save lives??’ Rudolf van der Berg — Stratix — EENA 2022
https://drive.google.com/file/d/1WC16k8C1gpeFRJif23yDIuLSRg1OJOnZ/view

Operators expect ‘blood on the highway’ as US visitors lose 911 Access
https://www.capacitymedia.com/article/2a8jhlzsoucvynqade3up/news/operators-expect-blood-on-the-highway-as-us-visitors-lose-9-1-1-emergency-access

Additional Test Cases for IMS Emergency Calling — Wayne Cutler, GSMA
https://www.itu.int/cities/wp-content/uploads/2023/06/3_Wayne-Cuttler.pdf

Ofcom — ‘3G and 2G switch-off — Our expectations of mobile providers’ — 02/23 https://www.ofcom.org.uk/__data/assets/pdf_file/0025/252592/3G-and-2G-switch-off.pdf

The Little Known Problems with VoLTE Emergency Calling -
How to Test for 4G Emergency Calling Support on Android

https://medium.com/@jamesdwho/the-little-known-problems-with-volte-emergency-calling-3d4cdaf0e042

How to Check for Working 4G VoLTE Calling on Android Handsets -
The Problems with VoLTE Interoperability & Standardisation

https://medium.com/@jamesdwho/how-to-check-for-working-volte-calling-on-android-8c343362ecfe

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James Parker
0 Followers

I have a Background in IT & Networking with an interest in PC Hardware, Android Handsets, Custom Roms and device re-use & repair.