The looming 3G shutdown timebomb

Oh boy.

I have been working on a few editorials lately. With thanks to one of my friends that I worked with back when I was still knee high to a grasshopper for bringing this to my attention, I have had to drop everything and get onto this one.

 

The TL;DR – Why Triple-0 Calls May Not Work After the 3G Shutdown

As Australia prepares for the shutdown of its 3G network on October 28, 2024, there are growing concerns about the ability to make emergency calls to triple-0. Here’s why these calls may not be successful for some users:

1. Dependence on Network Compatibility: Many mobile phones currently rely on the 3G network to connect calls, including emergency calls. Once 3G is decommissioned, phones that do not fully support 4G or 5G calling, particularly Voice over LTE (VoLTE), may be unable to reach emergency services.

2. VoLTE Limitations: While 4G and 5G networks support VoLTE for voice calls, not all devices or network configurations allow this. If a phone is unable to connect to VoLTE—either due to hardware limitations or configuration issues—it won’t be able to make calls, including to triple-0.

3. Vendor Restrictions: Telecommunications providers, like Telstra, have specific requirements for devices on their network. Phones not purchased directly from the provider may face restrictions that prevent them from making calls, including emergency calls.

4. Emergency Call Standards: Current regulations ensure that any mobile phone sold in Australia since 2002 can access triple-0 as long as it has battery power. However, there are discrepancies in how VoLTE emergency calling is implemented across different networks. Some devices that support VoLTE may not support emergency calls if they don’t meet certain provider criteria.

5. Noncompliance with Legislation: Australian law mandates that all mobile devices sold in the country must provide access to emergency services. The upcoming shutdown raises questions about compliance with this legislation, especially as newer devices may not guarantee triple-0 access without a functioning 3G network. If a device cannot connect to emergency services due to network restrictions or compatibility issues, it may violate existing consumer protection laws.

6. Potential for Service Disruption: With the shift away from 3G, many users, especially those on Mobile Virtual Network Operators (MVNOs), may find themselves unable to make calls due to lack of compatible devices or required settings. This is particularly concerning for individuals who cannot afford to upgrade their phones.

7. Risks in Emergency Situations: If users encounter issues connecting to VoLTE or their devices are deemed incompatible, they may be unable to contact emergency services during critical moments. Past incidents, like the extended outage experienced by Optus that affected triple-0 access, highlight the serious implications of these connectivity issues.

In summary, as the 3G network is phased out, there is a significant risk that many mobile users will not be able to make emergency calls to triple-0, potentially violating existing regulations aimed at ensuring public safety. This situation underscores the urgent need for clarity and solutions from telecommunications providers to protect consumers.

 

 

The Main Event

This year at DRN we have shared a few articles about the Australian 3G shutdown from various telcos, mostly to do with the 3G shutdown deadlines.

The nitty gritty of mobile connectivity is not my forte, and it seems, it is not many people’s forte either. We get our phones, sometimes we have to get a carrier unlock, and then they work right?

Unless you have been living in solitary confinement for the past 25 years or so, you would at least recognise the names that marketing pushes out periodically, namely 2G, 3G, 4G, 5G, LTE.

In Australia the 2G network shutdown was completed on 31 March 2018. This was relatively straightforward with phones that were only 2G capable affected.

The 3G network has progressively been decommissioned across the various Australian telcos since 2023, with Telstra and Optus being the last ones standing. The drop dead date has been pushed back a few times now, with the latest target set to be 28 October 2024.

 

Why is it important to understand these Gees?

Because not all Gees are created equal.

To put it in very simple terms, the 2G/3G mobile communications standards are telecommunications standards for carrying voice calls over mobile networks. It is the modern-day equivalent of the landline.

Beyond that into 4G and 5G, these are data packet standards – like your NBN connection.

Here in Australia our 4G networks are what is called LTE (Long-Term Evolution), which is a particular type of 4G that delivers fast mobile internet experience. For many 4G and later phones, our standard phone calls are made using VoLTE – Voice over LTE. If you think to your Teams meeting through your laptop, that is kind of how 4G and 5G calls work. (Not exactly but the analogy is close enough for this purpose.)

 

What has been happening?

Mobile phones sold in Australia since 2002 recognise triple-0 as the emergency number in Australia. All mobile devices sold in Australia must meet Australian standards which mean that you will be able to call triple-0 as long as your mobile phone has battery power and is within the coverage area of any Australian mobile network.

You will be able to call triple-0 regardless of whether your service is prepaid or post-paid. If your service is prepaid, you do not require credit to call triple-0. Even if the mobile account is inactive, disconnected or there is no SIM in the phone you will still be able to call triple-0.

There are special features in place to ensure that even when you are out of your service provider’s coverage but in another carrier’s mobile phone network coverage area your emergency call will be carried on the other carrier’s network.

Reference: Australian Mobile Telecommunications Association (AMTA) "Calling Triple Zero (000)"

 

When your calls are made with VoLTE, it is not so simple. My understanding is that there is no implementation standard for VoLTE.

There is a GSMA (GSM Association) Global / Open VoLTE configuration but it is not mandatory for telcos to implement it. Optus and Vodaphone have implemented this here in Australia, but no prizes for guessing who does not – Telstra.

In a nutshell in order to make a voice call on 4G/5G (VoLTE), you will need the following stars to align:

• 4G or 5G supported handset that fully support VoLTE (and not default back to 3G for calls, that’s cheating)
• phone modem (the bit that figures out how to talk to other devices) that is configured correctly for your specific telco access
• Sim card that allows you access to the telco with the correct VoLTE settings

If you are like me and ever had to fight with MMS settings on a phone, you start to get a sense of the pain of this mess.

As I mentioned earlier, Telstra being Telstra, of course has a different implementation of VoLTE that allows them to easily block non-authorised devices. Read: handsets not sold by Telstra directly. Shades of Telstra NextG network anyone?

To rub salt into the wound, this is just the beginning of hell for all users of the Telstra mobile network, including MVNO (Mobile Virtual Network Operator) such as Aldi, Belong, Boost, Woolworths, Exetel for example.

MVNOs exist to provide competition and alternatives, including those that cannot afford or does not require the kind of plans the bigger telcos offer. As an example my kids are on a MVNO network, because at their age it is simply ridiculous to put them on even the lowest cost plan with say Telstra or Optus.

 

What’s VoLTE Emergency Calling?

Just to confuse the issue some more, VoLTE is not the same as VoLTE Emergency Call.

There is a dearth of information out there about this. Based on my reading and research, you can have devices that support VoLTE but not VoLTE Emergency Call. After all, triple-0 calls to date are routed through 3G networks with priority.

 

Why is it a big deal?

Because phones that are not purchased from the telco you are connecting to, may not actually be able to make calls. That includes triple-0 calls in particular.

Whilst that is annoying and inconvenient at best (and costly), it can be life threatening at worse. Imagine for a minute the 3G shutdown has already happened and the horrible Bondi Junction event in April 2024 happens.

Some people may simply be unable to call for emergency services.

We have already seen the fall-out from the Optus debacle in January 2024 where there was an outage to access triple-0 for a staggering twelve hours.

 

What’s the government doing about it?

Great question from the audience.

Following the great Optus emergency services debacle, a direction was made by the Honourable Michelle Rowland, Minister for Communications. The Australian Communications and Media Authority (Emergency Call Service Determination) Direction 2024, dated 21 August 2024.

In Section 6 Content of the Determination:

(2) The Determination be amended to give effect to the following objectives:

(b) where an end-user’s mobile phone is unable to access the emergency call service using either the provider’s own network or the networks of other carriage service providers who provide carriage services to the public, the carriage service provider is:

(i) to notify the end-user that the mobile phone is not able to access the emergency call service;
(ii) not to supply carriage services to the end-user in connection with that mobile phone;
(iii) to provide the end-user with information about alternative mobile phones available, including low cost or no cost mobile phones, which are able to access the emergency call service.

 

What does that really mean?

It means, like a few of current day Government initiatives is to well, make it someone else’s problem.

The Direction dated 21 August 2024 means that if an Australian telecommunications provider determined that your phone is unable to access the emergency call service, they are obligated to tell you first, and then are prohibited from providing you with a service.

Wonderful.

Yes they also have to provide you about alternative mobile phones available, including low cost or no cost options.

That should nicely corner the market back to telco dictated devices.

And as an afterthought, also screw the tourists who come here with their foreign phones and on a roaming service. I guess we can stimulate the economy by selling them a phone tied to a local telco.

 

Doesn’t that contradict Australian Standards?

Well yes. Because Australian Standards as noted above states every mobile phone sold in Australia since 2002 must be able to call triple-0 as long as there is battery in your phone. There are no other requirements.

In fact, digging a bit deeper, this is enshrined in the Telecommunications (Consumer Protection and Service Standards) Act 1999. Under Section 147 “Provision of emergency call services”.

Provision of emergency call services

(2) In making a determination under this section, the ACMA must have regard to the following:

(a) the objective that a carriage service provider who supplies a standard telephone service should provide each end-user of that standard telephone service with access, free of charge, to an emergency call service, unless the ACMA considers that it would be unreasonable for such access to be provided.

With 2G/3G phones you will be able to call triple-0 “even if the mobile account is inactive, disconnected or there is no SIM in the phone”, thanks to the 2G/3G mobile communications global standards.

The answer does not appear to be so simple for 4G/5G phones. No amount of Google-fu by me yielded a proper, up to date answer on how VoLTE Emergency Calling really works.

I had a really burning question that Google could not answer, so I resorted to ChatGPT. Look I don’t trust ChatGPT without being able to cross reference the answers, but this is the best I can do.

I asked ChatGPT if VoLTE emergency calling require a SIM card. The answer was “Yes, VoLTE emergency calling typically requires a SIM card. The SIM card is essential for authentication on the mobile network and to access services like VoLTE. Without a SIM card, your device won’t be able to connect to the network to make calls, including emergency calls.

However, some devices may allow emergency calling without a SIM card, depending on local regulations and network configurations. In such cases, the device can still dial emergency numbers, but functionalities may be limited.”

Sat on the fence much? Truth is, I don’t think even the telcos know how it works, hence all the conflicting information on whether certain phones will still be supported going forward.

I am not a lawyer, but seems there is a noncompliance of legislation and Australian Standards somewhere.

 

What other implications are there?

We have enjoyed a period of almost two decades of choice and freedom, where handset offerings have been broken out of the telco’s tyrannical fists (thanks Steve Jobs for this one).

Is anyone else old enough to remember having to choose from Nokia, Motorola, Sony Ericsson phones at a telco shop, and locked into a plan with repayments? No such thing as BYOD?

Aside from a carte blanche for telco to kick any phone they don’t like off their service – be it a from a competitor telco and overseas import, it also means custom firmware phones are in the crosshair. Porting between telcos just got a lot harder. It is legislated reduction in free market choices.

I used to run custom ROM on my android phones. It works great, takes out all the bloatware and gives me the ability to really make a phone mine.

Although I have stopped doing it personally, there are still great reasons to run custom ROMs. Plenty of phones still have capable hardware but without official support. Or if you are privacy and security minded, you can look to GrapheneOS to meet your needs as an example.

The Australian move to turn off 3G puts all of this on the chopping block because the powers have been invested into the telco where they are permitted “not to supply carriage service“.

Am I fearmongering? No because I had a Pixel 2XL with 4G and VoLTE support but was kicked off the Kogan network regardless. I didn’t bother checking at the time because the broken screen and failing battery made it uneconomic to repair, and I replaced it with a low cost Aspera Mobile.

Here is the kicker, there are many people like me where we have a perfectly capable handset that has been or will be arbitrarily disconnected because it is the simple solution.

I have said this many times before in relation to this topic, in the midst of a cost-of-living crisis those who could least afford to replace their handsets are those hardest hit.

It is fair to point out that the numerous delays in the final shut down of 3G in Australia is related to the unknown number of devices out there that will be actually affected. I have not even had a chance to dig in and find out whether smart meters will still work post 3G shutdown!

 

Further information

As I said at the start, this is not my area of expertise.

I have done a whole bunch of research quickly and absorbed a lot of material, but that is no replacement for genuine knowledge and experience. So instead, I am going to direct you to Hugh Jeffreys’s video on YouTube for a much better and detailed look at this very important topic.

There are a couple of change.org petitions of relevance. Please take the time to read them and understand what the flow on impact of our headlong rush to shut down 3G has.

1. Remove restrictions for 4G Calling from the Telstra mobile network before the 3G shut-down
2. Stop Telco 4G/5G Device Blocking & VoLTE Restrictions – Australia’s 3G Shutdown

It is madness that there is no guarantee that an emergency call to triple-0 will work once 3G is finally killed off for good in Australia. Will it take another tragedy before we go, oops, mea culpa?

Bonus fact. TIL (Today I learned) that 112 is a globally recognised emergency number and Australia’s secondary emergency number that can also be dialled from mobile phones in Australia.