Australia’s 3G Switch-off - Failures of Government & Industry to Prepare
A Cautionary Tale of Mismanagement & Consumer Harms
Table of Contents
- Introduction
- Events prior to the Inquiry (‘Events to Date’)
- Background on 3G & 4G Calling
- Why this is a Problem
- Compatibility Problems with 4G Calling
- Issues with 4G Call Roaming
- Problems Using 4G Calling on Optus - International Perspectives
- Emergency Calling & Roaming
- Response from Industry Groups - Lack of Government Oversight
- Questions in Senate Estimates
- Actions by the ACMA - International Counterparts
- Optus Outage Review & Findings
- Blaming the ‘Grey Market’ & Undermining Competition
- Commercial Interests vs Public Interests
- Pricing Increases & 5G Investment Returns - Inadequate Media Coverage
- Increasing Public Awareness of this Issue
- Misleading Messages & Questionable Marketing - Summary & Opinion
- Addendum — My Supplementary Submission
- Application Based Mitigations & Solutions
- Vodafone’s awareness of the 4G Emergency Calling Issue
- Awareness by Optus not all VoLTE Phones Support Emergency Calls
- 4G Calling Compatibility with Different Networks
- 2G/3G Network Shutdowns & Delays - Outcomes of the Inquiry & Findings
- Committee Interim Report
- Changes to the Emergency Call Determination — Device Blocking - Sources & Additional Information
Relevant Articles
Introduction
Australia is on the brink of one of the most significant and poorly managed telecommunications transitions in its history, the shutdown of the 3G mobile network.
As they did with the shutdown of 2G in 2018, the telcos & industry have framed this as an necessary step forward in advancing their 4G and 5G coverage. The reality though is far more complex and dangerous.
It has been fraught with mismanagement, industry self interest and a complete disregard for public safety & human life.
What many Australians still don’t fully realise is that this decision will affect not only those with older 3G devices but also people with new 4G and brand new 5G phones. Many will find themselves unable to make calls or emergency calls.
Since June 2023, I’ve been trying to raise these concerns with the Government, regulators, media and the public.
In March 2024, the Communications Minister finally acknowledged part of the issue, announcing that over 740,000 4G phones could lose the ability to call emergency services once 3G is switched off.
In April that figure sharly increased to over one million, yet the shutdown is still moving forward — driven by the commercial interests of telcos, with little regard for the public interest.
Article Context
This story will cover the issues I outlined in a Submission to a Senate Inquiry on this issue. The information in this article is based on my Submission (#32) to the 3G Shutdown Senate Inquiry (Dated 29 May 2024).
The content contained in this article is based on the information at that time.
You can read the full Original Senate Inquiry Submission at the links below.
The original submissions and the content is protected under Parliamentary Privilege.
Google Drive Versions:
Shutdown of the 3G mobile network — Submission 32
Shutdown of the 3G mobile network — Supplementary Submission 32
Shutdown of the 3G mobile network — Senate Inquiry Home Page
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Rural_and_Regional_Affairs_and_Transport/3GNetworkShutdown
Additionally (or alternatively) you can listen to my Witness Testimony from the 23 July Inquiry Hearing.
Events prior to the Inquiry (‘Events to Date’)
Up until a few months ago the general public was solely under the impression that the 3G switch-off would only impact old ‘3G only’ devices and some very old 3G smartphones (i.e. devices & phones more than 10 years old). This has always been incorrect.
On Sunday 17 March 2024 the Communications Minister stated she became aware that approximately 740,000 4G phones (that support VoLTE/4G Calling) would not be able to call 000/Emergency Services after the 3G switch off.
The Minister announced a ‘working group’ with the providers to try and resolve the issue and additionally Minister Rowland stated she “became aware of this approximately 10 days ago” (i.e ~7 March 2024).
https://www.youtube.com/watch?v=iK98wI6d-W0
Following on from that press conference there was more coverage and scrutiny regarding the issues with shutting down the 3G network, including the establishment of a Senate Inquiry.
In early April the ~740,000 device number was sharply increased to more than 1 Million affected devices.
On 6 May Telstra announced that it will be delaying their shutdown to 31 August from the original date of 30 June. (Optus still set for September 2024, at that time). This is after growing concerns regarding both the impacts to regional coverage and emergency calling.
https://www.abc.net.au/news/2024-05-06/telstra-to-extend-3g-network-shutdown/103808110
All of these issues reported on were entirely foreseeable and I raised many of these issues with both the Minister and my Local Member starting back in June 2023.
There is a lot of important information that has not been compressively reported on and that the Public needs to know. My submission to the Inquiry outlines some of the major issues with switching off 2G/3G networks.
The comments from the Minister in March about possibly delaying the switch-off were encouraging, but I had concerns that pressure from the telcos & industry may of meant the switch-offs proceed regardless, even with the short delay.
The original Telstra delay helped give the Committee time to properly scrutinise this issue.
There is a very strong commercial incentive for the switch-off to go ahead as planned, which based on the 10 News report is what the industry wants to do.
To date I believe the industry has intentionally not communicated the impacts correctly to the Government and the Public. The majority of the media coverage about the switch off from last year has been very poor, and to date this story has not been comprehensively reported on.
Background on 3G & 4G Calling
While some people are aware that both Telstra and Optus are planning to switch-off their 3G networks (Telstra & Optus now 28 October 2024). The vast majority will be unaware the switch-offs may impact their ability to make or receive calls, emergency calls on their existing 4G or 5G Phones.
4G/LTE and 5G network technologies do not natively have any voice calling functionality like 3G & 2G services (‘Circuit Switched Calling’).
4G and 5G are Data only and Calling is enabled through the use of VoLTE (Voice over LTE aka ‘4G Calling’), which is a software/firmware VoIP (Voice over Internet Protocol) calling solution for mobile phones (IMS services).
Learn more about VoLTE Calling and how to test for it below.
Why this is a Problem
Unlike calling on 2G & 3G (GSM) there is no single standard or configuration for 4G calling (VoLTE/IMS). Globally carriers can choose different settings to configure their VoLTE calling networks and devices need to have explicit firmware support in order to have functioning calling.
A device that supports VoLTE with one telco network may not support VoLTE calling when on another network.
Since the Vodafone switch-off in December 2023, the issues around VoLTE Calling and device compatibility have been noticed by more people. Many have lost the ability to make or receive calls on newer and in some cases brand new 4G and 5G devices.
Compatibility Problems with 4G Calling
A significant number of 4G devices sold in previous years in various markets either are not enabled to use VoLTE Calling or ONLY support it with the Telcos/Carriers they were purchased with, regardless of whether the device is network unlocked. (Also affects imported devices, new & used).
This issue primarily impacts Android phones and non-Apple (iOS) devices. This is because Apple has complete control over the firmware on the iPhone. The iPhone 6 (2014) and newer support VoLTE. The iPhone 5 and 5s though 4G/LTE Devices DO NOT support VoLTE Calling.
With 2G or 3G still being in service customers don’t experience any loss in device functionality by switching provider. However, without 2G/3G people may no longer be able to make or receive standard phone calls on their existing 4G device with their preferred provider.
This also impacts Emergency Calls and Roaming Calls, not all devices with VoLTE Calling support can place Emergency Calls or Roaming Calls over 4G.
For example, in instances where a 4G device was originally obtained through Telstra (with Telstra Software) customers would need to switch back to the Telstra network (from the Optus or Vodafone networks) to restore 4G calling functionality despite the device being fully network unlocked.
In some cases, customers may be able to completely re-flash/reprogram (update) their device with different firmware that supports VoLTE on other networks, however this can be a very technical process and is usually not something that can be done as an automatic Over-the-Air (OTA) update unless it’s provided by the phone manufacturer or telco.
This situation has already created immense confusion and has lead to an outrageous amount of e-waste. Millions upon millions of perfectly functional 4G/5G phones will become essentially useless for making or receiving calls and many will end up in landfill or not properly recycled.
With the lingering effects of the global chip shortage and the extreme ongoing cost of living crisis, a complete switch-off of 3G services in 2024 will pose a major financial challenge for many Australians and Businesses who will have to spend hundreds of dollars for new phones and devices when they can least afford them.
Device Support History & Issues
In general 4G/LTE capable devices started to hit the market with the Galaxy S3 (with Android 4) & iPhone 5 in Late 2012/early 2013.
The Android ecosystem is very fragmented in regards to software support. However it’s fair to say that a majority of Android devices released around or before 2018 are likely to have either no VoLTE calling support or only limited VoLTE support on Australian Networks.
Including all devices from Android 4 to Android 9 (2018) equates to approximately 27% of the Global Android Device Market as per Google’s stats from April 2023.
Older people and people on lower incomes will more than likely have older devices running older versions of Android. This includes the most vulnerable in society and those that can likely least afford to upgrade.
As I mentioned in my Optus Inquiry Submission, I can envision that many Australians with tight budgets and limited incomes may purchase (or have purchased) used 4G Phones from Cash Converters, eBay, Gumtree or Facebook Marketplace and think they are “3G switch-off ready”, when in fact many will have wasted their money on devices that don’t support 4G VoLTE Calling with all AU providers or don’t support the feature at all.
Other Devices
There is also the impact to other 3G devices such as those used for emergency lift phones, Vehicle Emergency Calling (e-Call), facility ‘gate opening’ access control systems that use Calls to operate. Many of these systems use the voice calling component of 3G services and VoLTE compatible replacements aren’t necessarily available for all deployments.
That’s even ignoring the significant costs involved to upgrade. In some instances those systems may have been upgraded to ‘4G’ but the calling component may still be relying on 3G, the ‘4G’ support only provides faster data access.
There is also the major impact on other integrated systems that use 3G Data services such as Smart Energy Meters, Medical Alarms, Security Alarm systems, Car Infotainment and other IoT (Internet of Things or M2M — Machine to Machine) devices.
Millions of those devices will cease functioning once 3G data services are switched off with effects not that dissimilar to the 8th of November Optus Outage.
Issues with 4G Call Roaming
Further to that, the Optus website says VoLTE and VoLTE (International) Roaming should work on all Samsung Phones with Android 12 and above.
Android 12 was only released in late 2021 so people who have Android phones older than 2020/2021 are likely to encounter issues with either switching providers, when travelling overseas or when making calls over 4G.
Devices from Android 4 to 11 make up 69% of the Android Device Market as of April 2023.
Google made major changes to the base Android Operating system for Version 12. Those changes improved how IMS (IP Multimedia Subsystem) Services are activated and by extension VoLTE Calling and RCS Messaging etc. (RCS is modern version of SMS)
However despite that, an imported 2023 model (Android 13) Sony Xperia 1 Mk V (a ~$1,500 5G phone) does not have working VoLTE calling on Telstra in Australia, it does however work on Optus and Vodafone.
This is because Telstra’s VoLTE works in a different non-standard way compared to Optus and Vodafone. Similar issues have also previously been reported from Samsung Galaxy S8-S10 Users.
Problems Using 4G Calling on Optus
Further highlighting the issue is that in late 2019 Optus submitted the following mobile services discussion paper response to the ACCC, within their document they cite VoLTE support and handset compatibility issues.
An extract is below.
“30. Optus’ 3G mobile network covers 98.5% of the population. The 3G network is the network over which voice services are provided for the majority of Optus’ 10 million mobile customers. While voice services can be provided over LTE through Voice over LTE (VOLTE) technologies, VOLTE cannot be the sole technology relied upon to provide voice services. There are several reasons for this including:
(a) Low VOLTE handset penetration, especially in regional areas. As a result, even if VOLTE were available over the whole network, end-users would be unable to use the technology due to incompatible handsets.
[….]”
Though some years have passed since that paper the incompatible 4G Handset and device support issue is still a real and present problem, especially for older 4G devices or new imported/international models. (Including those used by international visitors & tourists)
In the paper Optus did also state that:
“The [ACCC MTAS] discussion paper asserts that the cost to terminate voice traffic is likely to decline over 4G networks and implies this may also extend to future 5G networks. Such a statement, however, does not reflect the reality of how the varying mobile technologies provide voice and data services”
ACCC Acknowledgement
The ACCC acknowledged issues around VoLTE Calling and the importance of 3G for Rural coverage in their November 2020 “Allocation limits advice for 850 MHz expansion band and 900 MHz band spectrum allocation” Consultation paper.
An extract is below.
“Currently, the MNOs provide services predominantly on 3G and 4G networks but have started rolling out 5G networks. The 3G networks have the largest geographic reach, followed by 4G networks while the 5G network footprints are still very limited by comparison. Optus and TPG are currently using the 900 MHz band to provide 3G services. While traffic on 3G networks has declined over the years, the ACCC understand that 3G services remain important, particularly for regional consumers. This is due to the geographic reach of 3G networks, and the fact that voice traffic is still carried over 3G networks if handsets are not compatible with voice-over-LTE (VoLTE) (that is 4G and 5G networks). While Telstra has announced that it plans to shut down its 3G network by June 2024, Optus and TPG have not announced their intentions regarding the shutdown of their 3G networks.”
International Perspectives — The issues are worse than you might think
This year in January whilst researching the issues around VoLTE further, I found additional information from European organisations in regards to the proposed switch offs of 2G/3G Networks.
At the April 2022 European Emergency Number Association (EENA) Conference, Dutch Technical Consultant Rudolf van der Berg made a presentation to the conference outlining serious issues with the current 4G calling standards and protocols.
One of the major issues he raised is that many 4G Phones (both European & International) are completely unable to call (911/112) Emergency services without the presence of 2G/3G (Circuit Switched Calling) Networks.
These issues were noticed following on from the 3G network shutdowns that occurred in the US around that time and he warns this will become a widespread issue as 2G/3G networks are gradually shut down across the globe.
The link to his presentation on the EENA YouTube page can be found below.
Mr van der Berg is from the Dutch Telecommunications Consultancy firm Stratix, he was also an Economist/Policy Analyst at the OECD and has worked for many years in the Telecom Industry.
It’s a very informative video and I would recommend watching the whole presentation (18:10), the video has more information than I can realistically fit into this submission.
Some other written resources from the EENA are also below:
EENA Special Focus — 2G/3G Shutdown — 2022–09–22
https://eena.org/our-work/eena-special-focus/2g-3g-shutdown
EENA — The Potential Perils of 2G and 3G Switch Offs — 2022–09–12
https://eena.org/knowledge-hub/press-releases/the-potential-perils-of-2g-and-3g-switch-offs
EENA — Ensuring continuity of access to emergency services/VoLTE Standardisation Problem — 2022–09–22
https://eena.org/blog/webinars/volte-standardisation-problem
Emergency Calling & Roaming
In his presentation he shows a slide from the “Canadian Wireless Telecom Association” warning about this issue for Roaming customers, it states that 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”.
https://drive.google.com/file/d/1WC16k8C1gpeFRJif23yDIuLSRg1OJOnZ/view
As mentioned previously, Optus says Android phones only with Android 12 (2021) and newer have VoLTE Roaming support. Devices from Android version 4 to 11 (2020) make up 69% of the Global Android Device Market as of April 2023.
(Optus says iOS 15 (2021) and newer is required for iPhones to have VoLTE Roaming — iOS 15 is only available on iPhone 6s (2015) and newer — VoLTE is generally better supported on iOS as outlined previously)
https://www.optus.com.au/mobile/plans/international-roaming/volte
Once Australia has completely switched off all 3G networks then many phones used here and from other countries will no longer be able to make calls or emergency calls in Australia either via Roaming or with a local sim card installed. 4G/5G Devices without VoLTE calling support currently rely on the 2G/3G Networks to make and receive calls, this is via a technology called Circuit Switched Fallback (CSFB).
Rudolf van der Berg advises that many phones sold in Europe and in other markets in the world Do Not allow emergency calls to work over 4G but rather default and force calling over the 2G/3G networks.
Without those networks people won’t be able to call 000/112 in Australia unless their device has the right firmware for Australian networks. This issue also extends to imported devices that are used locally, either bought online or being used by international workers, visitors and students etc.
It’s very easy to foresee a scenario (post shutdowns) where tourists (be they from Europe, Asia, Oceania the Americas etc.) come to Australia and find themselves in need of help from Emergency Services but are completely unable to make emergency phone calls.
This problem can still occur if they have a phone that supports VoLTE calling on 4G & 5G in their home country.
I did touch on this potential issue in my Optus Outage Inquiry Submission. But after having watched his presentation and looked at other resources and documentation from the GSMA, EENA and others this issue is far more serious than I initially anticipated and it hasn’t been reported to the public.
Further to that, in January I read an online a post from a Canadian visitor Roaming in Australia, they received a text from their provider warning they wouldn’t be able to call emergency numbers whilst roaming in Australia due to the switch-off, despite the customer having a 5G iPhone 14 Pro (2022).
[…]
These issues aren’t well known to the general public however in his EENA presentation he says these issues are “Common Knowledge” in the industry and that “..there is nobody who feels responsible to fix this”. (16:45)
On a slide in his presentation it says ‘telecom sector will deny [there’s a problem], be angry over 5G investment and bargain for half baked measures..’
https://drive.google.com/file/d/1WC16k8C1gpeFRJif23yDIuLSRg1OJOnZ/view
A further slide goes on to say,
“Sector should be ashamed; Putting lives at stake while wasting shareholder resources” (Slide 16)
Response from Industry Groups
In response to his EENA 2022 presentation, the GSMA (a key industry organisation behind some of the 4G VoLTE Calling Standards and testing) has established a task force to try and address these issues.
The GSMA directly referenced the EENA video in a presentation about this problem to industry last year, a link to the slide deck from that presentation is below.
https://www.itu.int/cities/wp-content/uploads/2023/06/3_Wayne-Cuttler.pdf
The aim of the taskforce is to improve the standards and advocate for device manufacturers, carriers and GSMA member organisations to align their devices and networks with a unified standard.
It’s worth mentioning that Telstra, Optus and TPG/Vodafone are all members of the GSMA, so they have no excuse for not knowing about these issues and the minimal progress made to fix the problem.
GSMA — ‘How we’re addressing VoLTE emergency call issues’ — 2023–05–12:
https://www.gsma.com/services/blog/how-were-addressing-volte-emergency-call-issues/
This work is still ongoing and it’s still very much NOT solved. Major compatibility issues remain with many networks, device chipsets, handset models and different calling systems.
Many existing 4G (& 5G) devices are completely unable to make interoperable calls (across carriers) or emergency calls on 4G and 5G Networks.
I agree with Rudolf that 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 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
Lack of Government Oversight
On the 6th of June 2023 I contacted the Communications Minister Hon Michelle Rowland via email regarding both the switch-off and the numerous issues with VoLTE Calling, and I did not initially receive a response.
(My original 6 June email to the Minster released under FOI, starts page 4)
FOI 24–354 | Correspondence to, and responses from, the Minister for Communications relating to the shutdown of 3G networks between 27 March 2023 and 27 March 2024.
However 4 months later after following up through my local member a few times (in August) I did end up receiving a response late in September. A copy of the letter can be found attached below.
Based on the letter I received and recent events, it’s clear there has been (has continued to be) a lack of oversight from the Government both regarding the 3G Switch-off issue and the telecommunications sector more broadly.
The letter says:
“The Department has been monitoring the transition, and has implemented a quarterly reporting regime with Telstra. The Department is in the process of implementing a similar monitoring regime with Optus.”
I would have expected some sort of monitoring regime would have already been in place for Optus, and I find it concerning that Vodafone was not mentioned as their switch off started in December 2023.
I would have also expected that the issues with 4G Calling and Emergency Calling would have been revealed in the aforementioned quarterly monitoring reports.
An important questions is, how were these issues not known to the Minister until March?
Furthermore the response letter did not acknowledge the significant device/telco firmware support issues I raised, including the competition concerns, consumer confusion and resulting e-waste issues.
The letter also stated:
“The major mobile operators have provided notice to their customers to allow them sufficient time to upgrade any 3G-only devices to 4G compatible devices, and ensure they will not be adversely impacted by the shutdowns. This is similar to when carriers shut down their 2G networks between 2016 and 2018.”
It’s worth noting that the information from the telcos is in many cases wrong or misleading, the info from the telcos and AMTA should be used as a guide only.
The standardisation of 4G Calling has failed and the industry doesn’t want to acknowledge it, take responsibility for it and fix the problem.
For example Telstra, Optus and Vodafone all list ‘compatible’ phones on their websites that aren’t guaranteed to work on their network post shutdown.
You could have an international model or alternative telco model of the exact same phone and it won’t work as the phone will lack the correct Modem Firmware Configuration (Device Software) for each Telco.
New 4G and 5G devices are still affected by this, not just older pre 2018/2019 devices as reported in the media in recent months.
Additionally Optus also lists Samsung Firmware versions that are in some cases 7 years out of date, meaning that end users have no way to actually tell if they have a compatible device based on firmware version alone.
It also brings into question if those devices have been recently re-tested or if the providers are relying on old test results.
https://www.optus.com.au/for-you/support/answer?id=20032
https://sammobile.com/samsung/galaxy-s8/firmware/SM-G950F/OPS/download/G950FXXU1AQC9/129360/
Questions in Senate Estimates
At Senate Estimates on 24 October 2023 Senator Cadell raised concerns regarding the switch-off and asked if there were likely to be any unintended consequences after the 3G shutdown.
Again, at this point in time the general public was of the view that only 3G devices would be affected!
The answers he received from Mr Windeyer (then Deputy Secretary, Communications and Media) demonstrates the very clear lack of awareness about the implications of the switch off from the Department at that time, a small Hansard Extract is below.
Senator Cadell asked Mr Windeyer,
“So there is no formal response by Government or The Department on unintended consequences of the 3G [switch-off].?”
He was told the following by Mr Windeyer:
“No. In a sense, that’s consistent with the approach that was probably taken with the close-down of 2G, for example. […] There will be the need to upgrade. In fact, I got a message from Telstra, helpfully, the other day to tell me that 3G is going to close at some point and that people will need to think about getting a device that is capable of receiving 4G. At this point we’re watching Telstra’s efforts closely, but that is, at the moment, being considered a corporate and commercial matter between Telstra and its customers.”
I note that Senator Cadell also asked:
“Would the Department or Government have powers at hand to delay the shutdown?”
The response from Mr Windeyer was:
“We don’t hold any regulatory role with respect to how they carry out coverage…”
24 October 2023 — Senate Estimates Parlview & Hansard
It’s worth noting that the Estimates meeting occurred one month after I received a response from the Minister’s Office. I contacted the Minister on 6 June, the Response letter I received is dated 25 September 2023.
Actions by the ACMA
In the April 2019 ‘Reconfiguring the 900 MHz band’ paper, the ACMA stated the following in regards to the future reconfiguration of the 900Mhz 3G Bands.
“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
How is it that the ACMA came to such a view with quote,
“no clear indication of intended migration paths”?
Based on the above information it appears that little (if any) consideration was given to ensure handsets were compatible before allowing the providers to announce dates for restructuring any of the 3G Bands.
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.
For reference, Telstra announced its plans to shutdown 3G a few months after the release of that paper in late 2019. Planned for June/Mid 2024. Yet only months prior the ACMA ‘had no clear indication of intended migration paths’ for the transition to VoLTE handsets.
https://www.smh.com.au/technology/the-end-is-nigh-for-telstra-s-3g-network-termination-set-for-2024-20191009-p52z0n.html
International Counterparts
Contrast the above with the information that the UK’s Ofcom has published publically to date regarding this issue. (Ofcom is the equivalent to the ACMA in Australia)
In their “3G and 2G switch-off — Our expectations of mobile providers” document they outline the compatibility issues that exist within the market and the issues that customers may experience with using VoLTE on different networks. A small extract is below.
“2.14 — There are also some customers who are already using 4G or 5G mobile devices that may need to update their settings or software to ensure that any calls they make are using the 4G network (using a standard known as VoLTE).9 There may also be cases where customers who purchased their device indirectly (i.e. not from their mobile provider), or those using devices on a different network from their original network, experience difficulty using VoLTE on those devices (this will only become an issue in future once the 2G networks are switched off). This is because, particularly for less common handset models, there may be some incompatibility in the implementation of the VoLTE standard between the handset and the network.”
Ofcom Website
‘3G and 2G switch-off — Our expectations of mobile providers’ — 2023–02–02
As the UK has not switched-off their 2G network the VoLTE compatibility issues do not impact access to calling, roaming and emergency calling in areas with sufficient 2G coverage. The UK recently started shutting down the 3G network (in 2024) but the 2G network will remain.
Emergency Calling Testing
Further to that, in 2020 regional US mobile provider “OptimERA” published a very detailed paper highlighting various issues with 4G/VoLTE Calling & Emergency Calling.
An important issue they highlighted is a device in an out-of-service or ‘No-Sim’ state may display an “Emergency Calls Only” or “SOS Only” message, however that message does not guarantee a device can actually make emergency calls over 4G/LTE networks.
Additionally they discovered that in some instances emergency call audio will only work one-way.
A table from their Handset & Network Testing is below.
https://optimerainc.com/wp-content/uploads/2021/11/OptimERA_VoLTE_Emergency_Calls_Report.pdf
Optus Outage Review & Findings
In the Bean Review into the 8 November Optus Outage it was noted that there is minimal if any testing between devices across networks.
An extract from the Report is below.
“Regardless of the technical reasons for the outage, it is clear that more testing of network interoperability is needed to ensure problems are identified and anticipated. The complexity of the carriers’ mobile networks and the necessity of interoperability to deliver Triple Zero calls demands a more thorough approach to testing than is currently in place. The carriers do not test with and/or across each other’s networks. While testing the camp on function on their own networks, even if covering all scenarios, the testing does not guarantee (as far as practicable) 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 functionality in all (or as many as might reasonably be anticipated) circumstances. This needs to be addressed.
The establishment of cross-carrier end-to-end network and device testing including under the wide range of known scenarios would provide information and insight into potential issues before major outages occur. Such testing may have gone someway to anticipating the failure of some calls to connect to Triple Zero on the day of the outage.”
The report goes on further to say:
“Australian Standard AS/CA S042.1: Requirements for connection to an air interface of Telecommunications Network. This standard, [..] specifies the requirements for customer equipment (handsets), […]. It includes technical guidance for testing these handsets for various scenarios including accessing the emergency call service. Carriers use this guidance in conducting the testing that they do. There is currently no requirement for universal or cross-industry testing.”
As 2G and 3G calling are well understood and standardised, it hasn’t been necessary to carry out extensive device & network testing. As the standardisation of 4G VoLTE calling is extremely fragmented, testing for devices is necessary to confirm even basic compatibility, this is due to the industry failing to properly standardise VoLTE calling.
There has also been a growing discussion around the need for Domestic Roaming in regional areas, especially in natural disaster scenarios.
However the current firmware and VoLTE Roaming compatibility issues likely make that impossible to fully achieve, especially for older/existing 4G devices. The lack of testing done by the providers exacerbates this issue greatly.
Blaming the ‘Grey Market’ & Undermining Competition
The providers may also attempt to blame these issues on “Grey Market” handsets (i.e BYO Devices or Devices not directly purchased from the telco’s or ‘Brick & Mortar’ Stores).
With 2G/GSM (Global System for Mobile) and 3G there is no such thing as ‘Grey Market’. Grey Market is a term that providers & some handset makers like to use to undermine and delegitimise purchasing phones on the open market (often for much cheaper than the same models are sold for by the telcos).
Part of the reason why this issue exists in the first place is that telcos nationally and internationally have an unreasonable amount of control regarding the roll-out of firmware and updates to Android devices.
The network operators and their partnered handset makers have a strong commercial interest that people purchase phones directly from them at full retail price or on contract. Competition from other brands, stores and vendors is undesirable to the network providers.
As per the findings from the Bean Review “carriers do not test with and/or across each other’s networks”. This lack of proper testing and the fractured standardisation has left us in a very precarious position.
Requiring Optus, Telstra or Vodafone VoLTE firmware on mobile devices provided by those companies will reduce choice for consumers in addition to allowing the major telcos to exert more control over the smartphone and telecommunications space.
Australian consumers should be free to purchase devices from any retailer, online store or international brand and have it work here in Australia, just as they have been able to do for decades with 2G & 3G. The consistent standardisation of 2G & 3G has enabled seamless global connectivity and greatly enhanced competition in the mobile sector.
Currently providers are able to use this Telco Specific VoLTE firmware requirement as a stealth way of network locking their devices and preventing customers from switching to competitors or from using ‘BYO’ devices.
The handsets are largely all made in the same place, with the same type of modems and processors and they all run the same base software. There are little if any physical differences in phones sold in one market or another.
The issues identified with some devices being able to make VoLTE calls but not to Emergency numbers is merely the tip-of the iceberg when it comes to the issues with 4G Calling. This is a ‘canary in the coal mine’ situation and it’s critical that the shutdowns are postponed.
Commercial Interests vs Public Interests
It also appears to me that the providers are using terms like ‘3G is a small percentage of overall network traffic’ to muddy the waters about the scale of the problem.
Even on a 4G or 5G network Calling will be a small amount of the overall data usage on a network. A High Definition ‘4K’ Netflix or YouTube stream uses more data than a 30 second phone call to 000, whether it’s on 3G, 4G or 5G.
Telstra Quote —
“This is reflected by the fact that 3G now accounts for only 1 per cent of our total mobile network traffic.”
https://9news.com.au/national/3g-network-shutdown-how-to-tell-if-your-phone-will-still-work/3b64956d-a0da-42cd-b50e-3f8680f6d001
Note they didn’t say the number of people or calls that still rely on Circuit Switched Calling.
Also 99% of the time affected 4G and 5G devices will use those higher speed data networks and only use 3G (CS Calling) for either calls or emergency calls. It’s a completely flawed metric to use, not all data usage is of equal importance, and I’m sure the providers know this.
Considering that Optus has 10 Million Mobile Customers and that approximately ~60–70% of Android handsets used globally lack full VoLTE support & Roaming (Android 12+), being very generous you could say that at least 10% of Optus customers have devices with some level of compatibility issues with 4G Calling, that’s a minimum of 1 Million Optus Network Customers.
If each customer on average has to spend $300 on a new phone that’s $300 Million Dollars of revenue.
Add on another (minimum) ~10% each for Telstra & Vodafone and collectively you could be looking at over a Billion Dollars in new device sales alone.
Telstra has 22.5 Million retail mobile services — https://www.telstra.com.au/aboutus/our-company
Vodafone has 5.25 Million mobile customers — https://www.vodafone.com.au/about/company
Not to mention the extra millions to be made selling new devices on expensive plans, and all of this during a cost of living crisis.
It’s a certainty that Australians are actively being upsold to new expensive devices and plans when their existing device may just require an update from the Telco or Manufacturer or in some cases just a simple settings change or factory reset.
In recent weeks providers have sent messages to Customers that have done little to ease concerns
During what is by all accounts the worst cost of living crisis this country has seen in decades, we have the network provides pushing people to spend hundreds of dollars to buy new phones right when they can least afford them.
The providers appear to be quite desperate to get people to upgrade, and by any means necessary with no regard as to the impacts. The providers may now be able to boast stronger numbers of compatible devices on their networks, however the means to which much of that has likely been gained is in my view very objectionable.
In any event, the lack of 4G Calling standardisation will continue to negatively impact competition, calling and access to emergency services for the foreseeable future.
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.”
https://www.aussiebroadband.com.au/blog/think-like-an-aussie-5g-and-our-mobile-plan-refresh/
In my view all of this lines up with what Rudolf showed (on Slide 14) in his presentation in regards to trying to prevent any switch-offs, ‘telecom sector will deny [there’s a problem], be angry over 5G investment and bargain for half baked measures..’
These compatibility issues could all largely be fixed with new device firmware/software (or calling apps, see India’s Jio Mobile), though the providers and handset makers would rather sell people new phones instead as it’s easier and more profitable.
The providers and handset makers stand to make hundreds of millions of dollars by selling new phones, not to mention the millions to be saved by switching off 3G.
In my submission I strongly cautioned the Committee to be very sceptical about what the providers have to say in regards to this issue. The inquiry would not have been at all necessary if the industry was actually proactive about this issue and gave any forethought about the implications.
They do not have clean hands in this and there needs to be thorough scrutiny of their actions to date.
As I wrote in my Optus Inquiry Submission, 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 telco’s are there to serve their customers, not the other way around.
The providers are very 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 minimizing their own responsibility is starkly telling of the industry’s prioritization 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.
Inadequate Media Coverage
Over the past year since contacting the Minister I have been monitoring the reports around the switch-off closely. The bulk of the reporting that was in the media last year (primarily that of the commercial TV networks) has been very poor and for months there has been essentially no mention as to the possible impacts to 4G and 5G devices.
On 21 August 2023 both 7 News and 9 News aired stories about the 3G switch-off with their 6PM Bulletins. Both TV Networks included interviews from the providers however the fact that 4G and 5G devices could be affected wasn’t mentioned once.
https://web.archive.org/web/20240124101628/https://www.youtube.com/watch?v=yJZotwC3hjg
https://www.youtube.com/watch?v=JiRdec-E8ps
On 22 August I once again contacted the office of my Local Member Anika Wells regarding the TV news coverage. I asked for any updates from the Minister’s Office regarding the concerns I raised in June.
I said “Last night (21/08) the Brisbane 6PM nightly news bulletins on Channel 7 and Channel 9 covered the switch-off, but both failed to mention the VoLTE support issue and the impact the switch off will have on 4G Devices that lack VoLTE support on Australian networks. It seems like the telco’s aren’t being entirely upfront about this issue to the media and its critical people are properly informed about this.”
On 24 August 2023 I received a response that said:
“We are yet to receive an update, we are liaising with Minister Rowland’s office on the status of the update”
I also raised these concerns with the aforementioned TV networks via email on 22 August. One of networks did respond to my email, and I had an hour long on-camera interview with them in early September 2023, however the network never aired the story.
No explanation was provided. After a number of follow-ups on 15 November they finally advised “At this stage we aren’t running the story sorry.”
Throughout August until November I contacted every major Media outlet trying to raise further awareness of this issue, I did not receive any other responses.
Increasing Public Awareness of this Issue
Frustrated with the response from the Minister’s Office and the lack of accurate Media coverage and reporting last year, in early November I worked with a popular Australian Device Repair and Tech YouTuber ‘Hugh Jeffreys’ to publish a video about this issue. The aim of the video was to increase the broader awareness of this issue both nationally & internationally.
It’s a very good video that explains the issue quite well and it gets the point across in a broadly understandable way for consumers.
A link can be found below.
The video has over 180,000 views at the time of writing and it’s been interesting reading the thousands comments from people who own relatively new 4G and 5G phones that can’t use their devices for calling anymore due to VoLTE compatibility issues.
This includes Vodafone network customers, and in a number of cases they have brand new 5G Devices.
(Vodafone 3G Shutdown started 15 December 2023).
Some of the Video Comments are below:
The release of the also video sparked a number of other discussion threads and some other reporting.
https://hackaday.com/2023/11/27/voice-over-lte-the-reason-why-your-phone-may-soon-stop-working/
Whirlpool Forums
3G shutdown: no more calls on many 4G devices — 2023–11–26
https://forums.whirlpool.net.au/thread/3l10nzwy
For the video description I also wrote an 18 page Google doc that people can use to find out if their Android device actually supports VoLTE Calling (IMS Registration) with their carrier.
(Though some handset makers make that more difficult than it needs to be).
2G/3G Switch-Off & 4G VoLTE Calling Device Information https://docs.google.com/document/d/1QaVDYnZCdI2jKk0-DEZmlKTP33rt1vARd5cKKDA1ObI
In early September I purchased Telstra and Vodafone prepaid Sims in order to test different devices and phone firmwares for VoLTE Support.
(I personally use the Optus network).
I am still paying for those extra Sims in order to carry out testing with different handsets and device firmware.
Even with the video and recent media coverage it’s very clear there is still a lack of awareness about this issue globally and nationally. Most people are completely unaware that 4G and 5G devices can be affected by 2G and 3G Network switch-offs.
The global interoperability that people expect and have become accustomed to for the last 20+ years is quickly disappearing and the vast majority have no knowledge that it is happening.
Misleading Messages & Questionable Marketing
Following on from the announcement by the Minister in March and the subsequent establishment of the working group, in April Telstra rolled-out an SMS Device Testing Service that customers could use to ‘check their device for compatibility’.
However, the SMS ‘Testing’ system that Telstra rolled out Does NOT actually test your device for compatibility or report accurate information for customers.
Based on my testing with multiple handsets the SMS ‘3498’ system only appears to look up your phone Model (IMEI) in an established Telstra ‘compatibility’ list.
Telstra VoLTE Compatibility List: https://www.telstra.com.au/support/mobiles-devices/enable-volte-mobile-phone
It does not report back if your device has working VoLTE calling on the network.
For example I have a (2015) 4G Sony Xperia Z5 Compact, and with Telstra Firmware installed the phone has both working VoLTE calling on Telstra and working 4G Emergency Calls.
However if I use the Telstra SMS Checker service it will say:
“[…] this mobile phonewont [sic] connect to our 4G network […] Please upgrade to a 4G/5G device that is capable of making VoLTE calls and VoLTE emergency calls.[…]”
This means there are customers with compatible phones that are wrongly being told to upgrade. Additionally people with incompatible phones may be getting told their device is fully compatible when it is in fact not.
(For example if a customer has an Optus, Vodafone or other Telco version of a ‘supported’ device model)
Additionally the SMS system says:
“if you have changed phones recently, please check again soon”.
However results seem to only update once per month and it can take up to two weeks for the new results to appear.
I have also received similar misleading information & text messages from both Vodafone and Amaysim. (Amaysim is an MVNO owned by Optus)
Amaysim Marketing
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”.
Summary & Opinion
It is clear that the 3G network switch-offs must be permanently postponed. Failing to do so prioritises commercial interests over the public interest, risks lives, harms competition, and undermines essential communication.
It’s clear that to date there has been insufficient oversight of the switch-off from Government, Minister, the ACCC, ACMA and Media.
In my view the industry has not been open or transparent around this issue and communication about the impacts has neglected to provide key information to customers. The industry is entirely aware of the problem but as shown in the EENA presentation, nobody wants to take responsibility for it and fix it.
The planned switch-offs are entirely set to serve the commercial and business interests of the network providers, partnered handset makers and associated industry.
The broader community and public impacts have been disregarded, and recent sector outages and service disruptions underscore the industry’s inability to ensure systems actually function as intended.
Prior to Contacting the Minister in June of last year I have been generally aware of issues around VoLTE compatibility with devices for at least 4–5 years.
The near last minute call from the Minister to investigate the issues around Emergency Calling shows a complete and utter failure to properly monitor the switch-offs. Even more so given the provided warnings. Additionally I have read about others who have attempted to bring these issues to the attention of the ACMA and regulators in years past but have been largely ignored.
Handset makers, network operators and the broader industry are all aware of these issues but have consistently failed to address the root causes. Interests around preserving market control and reducing costs has meant the standardisation of 4G calling has failed.
It seems the industry has been saying whatever it wants in order to ensure the switch-offs go ahead as planned. Another item that likely warrants further investigation is how the regulators allowed all of this to happen in the first place.
Australia should not proceed with switching off 3G networks until Europe and the rest of the world have resolved the compatibility issues.
We should be looking to France and keep 3G services until around 2028, or at the very least 2025–2026 like other European countries.
Australians are essentially being used as guinea pigs and by all accounts the industry wants to proceed as planned. They have little regard to the implications as to what WILL go wrong and how it will affect people. There is a reason why a number of major developed markets within Europe are not switching off 2G or 3G until towards the end of the decade and a number are considering delays or have announced delays.
There are very serious compatibility issues due to the failure of the industry to properly standardise calling and emergency calling over 4G.
Industry groups like the GSMA do have specification documents that providers and handset makers can use to configure their networks and devices however none of these specifications are mandatory and providers can go about configuring their networks in alternative ways that are anti-competitive and prevent certain devices from working on their network.
Handset makers & network operators have also engaged in behaviour that restricts the use of devices on different networks and behaviour that otherwise undermines competition.
Based on my testing with a number of Android Handsets Telstra does not support what’s known as the (Global) ‘Open Market Device’ VoLTE Configuration designed by the GSMA.
To use a device on the Telstra network the phone needs specific Telstra Modem Software loaded. Devices running the (IR.92) ‘Open Market’ Configuration can work on Optus and Vodafone.
Newer Android Devices support the GSMA ‘TS.43’ standard which should enable automatic 4G calling activation, however according to Google’s documentation only a few networks have implemented this feature and none of the AU providers are on that list.
Android Open Source Project Documentation —
IMS Service Entitlement/TS.43 Service Entitlement Configuration
https://source.android.com/docs/core/connect/ims-service-entitlement#integrate
Essentially all Smartphone Processors and Modems sold since about 2013/2014 support VoLTE and 700Mhz or 850Mhz 4G/LTE (sub 1Ghz LTE). There is no reason why existing devices could not be configured to work, the handset makers and telcos have simply decided not to.
It’s more commercially beneficial to sell people new phones rather than ensure updates are provided to existing devices. This is clear forced obsolescence and is another example of how the industry will consistently put profit and commercial interests above the needs and concerns of their customers, regional communities or the environment.
In recent years we have seen the providers such as Telstra post massive profits. In 2023 they posted a $2.2 Billion Net Profit, up 13 percent to the previous year.
https://www.smh.com.au/business/companies/telstra-profits-pass-2b-on-mobile-growth-20230816-p5dx29.html
https://www.afr.com/companies/telecommunications/telstra-posts-2b-profit-shelves-option-for-infrastructure-sale-20230815-p5dwpi
The industry has demonstrated it lacks the necessary commitment to fix these standardisation issues and ensure consumer safety.
By contrast the 2G mobile services switch off in 2016/2017 had relatively minimal impact as the majority of 2G Only devices around were pre-smartphone era devices that did not support the modern features we use today, those devices also were already in declining usage. Furthermore all devices and networks were equally affected. The same absolutely cannot be said for a 3G switch off.
With the analogue TV switch off that happened between 2010 and 2013 the public was given clear messaging and labelling about the shutdown, the impact of the shutdown and the various solutions.
In stores country wide people could purchase Digital TV set-top-boxes that would allow them to continue to use their existing analogue Television sets, this stopped millions of otherwise functional TV’s from going to landfill in addition to preventing people from being upsold on new expensive TVs they didn’t need.
Prior to being allowed to switch-off their networks the providers should be held to a Government specified standard for the number of compatible devices and minimum levels of coverage for those in remote and regional areas.
All networks need to support the ‘Open Market’ Standards and allow any phone to work for calling, emergency calling and roaming. Telcos and Device Manufacturers should also be required to roll-out updates to existing devices or otherwise provide customers free devices that are network unlocked.
The switch-off of 3G networks in Australia should be postponed until these issues are comprehensively addressed, this will ensure public safety, fair competition, and protect essential mobile communications.
It’s now incumbent on the Government, regulators and telcos to provide answers and stop these shutdowns.
(Additionally I provided Questions in my Submission for the Committee to ask the Carriers at the Hearing, a number of these were asked at the hearing on 24 July)
Shutdown of the 3G mobile network — Senate Inquiry — July 2024
Shutdown of the 3G mobile network: Interim report — August 2024
Addendum - My Supplementary Submission (1 Aug )
On 1 August 2024 I provided the Committee some additional information to supplement the content of my primary submission.
The Telcos denied that device software updates or VoIP Calling Apps could be provided to fix or even mitigate the issues.
24 July Hearing — Telcos RE Device Updates:
https://www.youtube.com/live/HvDvnfWTou0?si=8hiVpPfSlVI4IZnf&t=4949
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
This additional submission corrects some incorrect and misleading information that was provided to the Committee by the Telcos, ACMA and Department.
Application Based Mitigations & Solutions
As previously mentioned in my original submission 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.
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
https://telecom.economictimes.indiatimes.com/news/reliances-jio4gvoice-is-worlds-largest-and-fastest-growing-rcs-service/58121152
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 without the need for explicit firmware support or firmware updates on the device.
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.
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.
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. Other Apps that provide this sort of VoIP Calling functionality and service include:
- Google Voice
- TextNow
- Line2
- FreeTone
TPG/Vodafone’s awareness of the 4G Emergency Calling Issue
Sometime between late July and August 2023 Vodafone removed a number devices from the ‘Supported VoLTE Devices’ page on the Vodafone Website. Many of these devices are able to make calls on 4G (with VoLTE) on Vodafone but not to Emergency numbers.
I first noticed a number of devices were missing from the website on 31 August 2023 when registering the sim card I purchased for device testing. (The removed devices were still listed on 10 July 2023).
Considering that Vodafone was not required to provide any formal quarterly reporting to the Department and Government it does bring into question their awareness of the scale of the compatibility issues last year, and the reasons why these devices were removed at the time without any alarms being raised for customers.
Additionally a number of the devices they removed from their list are still in some cases on Telstra’s and Optus’s Support List, which means many of these potentially affected devices are likely still in use and circulation.
In some instances the Telstra and Optus Firmware versions of those devices support Emergency Calling over 4G but not necessarily VoLTE Calling on all networks.
A summary of the removed devices are below.
Archived copies of the Vodafone website can be found on The Internet Archive ‘Wayback Machine’.
Devices Removed from Vodafone’s Website between July-August 2023
Further note, some of the above devices will have working calling and emergency calling when used with either Telstra or Optus Network Sim Cards but when a Vodafone Sim Card is inserted the phone may continue to make calls but will lose the ability to make 4G Emergency Calls.
This is due to 4G Emergency Calling not being enabled within the Vodafone (AU) Qualcomm Modem Configurations on some devices, despite emergency calling being configured for the Telstra and Optus modem configurations, refer to the testing information & tables below.
Vodafone AU VoLTE Device Support List — Before Device Removal
2023–06–06
The Samsung devices in yellow were removed and are missing from the current version of the page.
Awareness by Optus that not all VoLTE enabled Phones Support Emergency Calling to 000
As early as 2018 the Optus Website had information regarding devices that support VoLTE calls on Optus but not to Emergency Services. It does bring into further Question how Optus (and by extension the Department) was not aware of the scale of this “fourth category” of device until late 2023/early 2024.
I note that in the reporting documents obtained under FOI and tabled at the Inquiry it states the following:
“Devices impacted by the 3G shutdowns
There are four broad categories of mobile devices that will be impacted:”
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Rural_and_Regional_Affairs_and_Transport/3GNetworkShutdown/Additional_Documents
I originally read this information from the Optus website a number of years ago and assumed this issue was well known by industry & regulators. It does raise the question how this issue was not thoroughly looked into until early 2024.
4G Calling Compatibility with Different Networks
On the below pages are tables of Qualcomm Network Configurations (i.e. Firmware) for various network providers all over the world.
Qualcomm is the world’s largest Mobile Device Chipset Vendor and they provide chipsets, device platforms and modem firmware to handset makers & the telecom sector. See the Medium article below for more information.
The tests were performed on two Android devices, a Sony Xperia X Performance with a Qualcomm Snapdragon 820 Chipset and a Sony Xperia XZ1 with a Qualcomm Snapdragon 835 Chipset.
For reference, the Snapdragon 820 Chipset (2016) was also used in some of the following devices:
- Samsung Galaxy S7 & S7 Edge (USA)
- Sony Xperia XZ
- OnePlus 3
- LG G5
- Google Pixel 1 (Snapdragon 821)
- HTC 10
- HTC U Ultra (Snapdragon 821)
GSM Arena — Phone Finder — Snapdragon 820 + 821 Devices https://www.gsmarena.com/results.php3?sChipset=2,3
The Snapdragon 835 Chipset (2017) was used in some of the following devices:
- Samsung Galaxy S8 (USA & China)
- Samsung Galaxy Note 8 (USA & China)
- Sony Xperia XZ Premium
- Sony Xperia XZ1 & XZ1 Compact
- OnePlus 5 & 5T
- LG V30
- Google Pixel 2
- HTC U11 & U11+
GSMArena — Phone Finder — Snapdragon 835 Devices
https://www.gsmarena.com/results.php3?sChipset=1
Both devices were running the latest Firmware available, for the X Performance this is Android 8.0 (June 2018 Patch) and for the XZ1 Android 9.0 (September 2019 Patch).
I used Sony devices for this testing as Sony has an ‘Open Devices’ development program which allows experienced users and software developers to make changes to the firmware on their Qualcomm based Sony smartphones.
With very minor changes I can configure the devices to use any VoLTE network configuration including the Open Market Standards (GSMA IR.92). With the ‘Open Market’ Standard the devices can make VoLTE Calls on Optus and Vodafone as well as calls to 000 on every network.
As noted in the 2022 EENA Presentation in many countries phones have been specifically configured via software/firmware to block access to Emergency Services over 4G and entirely rely on 2G/3G. It’s also worth noting that devices running the Singtel Modem Configuration Do Not work on the Optus network despite Singtel being the parent company, 4G Emergency calls also do not work with the tested Singtel Modem Configurations.
For this tested generation of devices the various network (modem) configurations are preloaded onto the device firmware by the manufacturer. This is still true with new devices, not all devices sold or in use will have the configuration files for every network and not all devices will be configured to detect every type of network sim card and enable VoLTE Calling.
This is another layer to the compatibility and standardisation problem, many devices have the necessary modem files on board but aren’t configured to load them on the insertion of the relevant sim card.
(Depending on brand, device, software version & network).
As noted in the above tables there are major inconsistencies when making VoLTE calls between various networks (both nationally & globally).
Only about ~33% of the various tested network configurations support emergency calling over 4G. Many configurations work with both the Optus and Vodafone networks as they are (GSMA IR.92) ‘Open Market’ Compatible.
The configuration results noted with ‘NO — Call Fails’ are devices that support 4G Emergency calling in their respective home market or network, but Emergency Calls fail to connect on Australian Networks even when 3G is available. When the device is running those configurations the device gets stuck on ‘Calling’ 000/112 indefinitely.
This is the type of Emergency Calling compatibility issue that was pointed out in the 2022 EENA presentation and in subsequent information from the GSMA.
The other configurations that failed to make Emergency Calls over 4G (‘Result: No’) will fail to make emergency calls when there no 2G/3G (Circuit Switched) network available.
2G/3G Network Shutdowns & Delays
(Context: At the Inquiry the Department of Infrastructure was asked if there are any countries that have fully switched off both 2G and 3G networks. The Department cited the US, noting that none of the major US Carriers still provided 2G services, however a Senator on the Committee asked if T-Mobile did actually switch it’s network off in April 2024 or if it was delayed (it was), the Department had to take that question on notice —
3G Shutdown Inquiry — 24 July — Questions to the Department RE 2G & 3G)
Though most US providers have switched-off both their 2G and 3G Networks, T-Mobile’s 2G Network is still in service across most of the continental US (as of 1 Aug 24).
Inbound roamers without VoLTE support on US Networks can use the 2G Network for Emergency Calling in areas with sufficient T-Mobile 2G Coverage.
Informa Tech — ‘2G’s death sentence gets a reprieve in the US’ — 2024–02–10
https://www.cellmapper.net/map?MCC=310&MNC=260&type=GSM&latitude=39&longitude=-95.2&zoom=5.5
As recently as July 2024 T-Mobile users with 2G devices were posting on forums & online discussion boards that their 2G devices were still working for calls, SMS and data.
The network was supposed to be switched-off in April 2024 but switch-off was once again delayed.
Posts on Reddit.com/r/tmobile
‘Thank you for keeping our 2G phones going, T-Mobile!’ — 2024–04–03
‘2G is suddenly starting to work perfectly in my area?’ — 2024–07–14
In late June 2024 European Industry Association ‘Euralarm’ published a paper calling for a unified approach to shutting down European 2G and 3G networks.
Euralarm represents the fire and security industry in Europe and provides expertise for industry, policymakers and standards bodies.
In their paper they state that:
“To prevent unintended consequences, a gradual and coordinated shutdown should be implemented, with at least one carrier in each Member State maintaining 2G or 3G until at least 2029–2030” and that “The EU should strongly encourage Member States to implement a delayed and harmonized shutdown of 2G and 3G networks “
Outcomes of the Inquiry & Findings
In emails released under FOI in advance of the inquiry, it was revealed that I was the only person in the entire country prior to February this year to warn the Minister and Government about the unintended consequences of switching off 3G and 4G devices being unable to make calls and Emergency Calls.
(My original 6 June email to the Minster released under FOI, starts page 4)
FOI 24–354 | Correspondence to, and responses from, the Minister for Communications relating to the shutdown of 3G networks between 27 March 2023 and 27 March 2024.
Within the some of the documents released under FOI it shows the Department of Infrastructure was talking to Optus regarding my ‘Optus Inquiry Submission’ on 9 February 2024 which is the same day the Optus hearing was set to sit again.
The Optus Senate Inquiry first met on Friday 17 November 2023 with the next hearing originally scheduled for 9 February 2024.
The Department, ACCC, ACMA and other entities were due to speak at that hearing on the 9th, in addition to Telstra and TPG/Vodafone.
Late January/Early February Vodafone customers also started writing to the Minister complaining they lost call service on VoLTE enabled 4G/5G Phones. Initially these people were told their device may be defective in some way and to contact the manufacturer or retailer.
FOI 24–354 | Pages 54 of 147 [PDF Page 42] & 66 of 147 [PDF Page 54]
Those emails may have raised concerns with the Department, hence the email between the Department & Optus discussing my November Inquiry Submission on 9 February.
The 9 February hearing was cancelled last minute Thursday Evening (8 Feb) due to a reported illness with the Committee Chair and has yet to meet again.
The Committee issued it’s final report on 27 September 2024.
https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/OptusNetworkOutage/Report
Emails & Documents Released under FOI
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
Committee Interim Report
On 1 August 2024 the Committee Released an Interim Report recommending a delay and an audit be conducted to better identify what devices will not work post shutdown.
Shutdown of the 3G mobile network: Interim report — August 2024
The industry was planning to proceed in opposition of that recommendation, however on 14 August exactly 14 days later the Telcos (Optus & Telstra) announced they would jointly delay their shutdown until 28 October 2024.
Changes to the Emergency Call Determination — Device Blocking
In relation to the switch-off, there has been an extremely alarming recent finding. Telcos will be forced to block any device they don’t have in their official ‘support lists’ even if the device might work perfectly!
From 1 November any handsets the telcos believe can’t call 000 will be totally blocked from connecting at all! Even if you have working calling, SMS and Data!
This is due to an update to the ‘Emergency Call Service Determination’, in the explanatory statement it says.
Australian Communications and Media Authority (Emergency Call Service Determination) Direction 2024 — Explanatory Statement https://www.legislation.gov.au/F2024L01103/asmade/text/explanatory-statement
“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.”
Australian Communications and Media Authority (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!
Their updated policy document announcing this was only published on 3 September, 1 day before the new rules were posted on the Government Website. This was not on their website a month ago!
Optus Website — Blocking phones from 10 Sep 24:
https://www.optus.com.au/support/mobiles-tablets-wearables/important-changes-3g/my-phone-stopped-working
Optus Mobile Safety Policy — 3 Sep 24:
https://www.optus.com.au/content/dam/optus/documents/for-you/support/mobiles-tablets-wearables/important-changes-3g/0830_an_important_update_on_mobile_handset_safety_legalv1_03.09.24.pdf
Optus Website 3G Closure — 24 August 2024:
https://web.archive.org/web/20240824112055/https://www.optus.com.au/support/mobiles-tablets-wearables/important-changes-3g
I’m working on raising the alarm with the ACCC, Senators and other Members of Parliament.
Learn More Below!
If you got this far and read of this in entire post, thank you.
James
Sources & Additional Information
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
