Australia’s top mobile carriers have cautiously supported expanding emergency communications beyond voice calls but warned that it will require substantial regulatory change.
TPG Telecom, Optus and Telstra have told the federal government that they support the introduction of alternative ways to contact emergency services, such as SMS, satellite direct-to-device and other data-based means.
However, they said current legislative and regulatory arrangements around triple zero emergency communication is not ready for the change, being primarily geared to fixed line and mobile voice services.
The three mobile network operators were responding to the review of emergency calling legislation that communications minister Anika Wells announced earlier this year in a bid to restore public faith in Australia’s triple zero services.
As part of the review, the government sought views from community stakeholders on the potential for new technologies to provide “multi-modal” access to emergency communications.
TPG Telecom said that introduction of multiple modes of access would require a “fundamental shift” in approach to regulations and warned of “cost and network capacity constraints”.
“The current legislative and regulatory framework for emergency communications is not fit for purpose in a multi‑modal environment,” TPG wrote in a submission.
“It is primarily designed around voice services (delivered via fixed and mobile networks), with limited accommodation for non‑voice channels through the Text Emergency Relay Service (106).
“Integrating new communication methods (such as SMS, MMS, RCS, data services and data enabled over‑the‑top applications) would require more than incremental amendments to existing rules. A fundamental shift in regulatory approach is required.
Non‑voice services should not be viewed as a replacement for voice, but as complementary channels that enhance accessibility, provide redundancy, and support user choice.”
Optus voiced similar concerns about the fundamental design of the current regulatory framework favouring fixed line and “circuit switched” mobile-centric services.
It said that mobile devices “now account for the overwhelming majority of triple zero calls”.
It went on to add that an increasing availability of alternative communications technologies, such as wearables and connected vehicles “were raising important questions” about whether the current regulatory framework was still fit-for-purpose.
However, it said that any action taken to update the framework would need to be considered carefully.
“Optus supports modernising the framework to reflect this reality. However, the public safety function of triple zero means this should be done in a thoughtful and methodical way,” Optus wrote.
“Expanding the framework to incorporate new access modes should only be done after systemic, end-to-end testing across all call delivery aspects … and after detailed consideration of any requirements that should apply to alternate access modes.”
Telstra described the current regulatory frame as “overly rigid” and “anchored in voice-only, carrier-controlled access pathways” limiting the introduction of new access methods and ways for delivering emergency communications.
Telstra called on the government to adopt a technology-neutral, “modular” framework, with core guiding principles to be set in the Emergency Call Services Determination (ECSD).
The carrier argued that this approach would allow for the transition to alternate access to emergency services communications “without reopening or overcomplicating the core ECSD requirements”.
Optus told the government that the framework would need to evolve carefully.
It recommended the review establish “a clear statement of principles” in the Telecommunications (Consumer Protection and Service Standards) Act 1999 and the ECSD to provide a foundation for its ongoing development.
TPG Telecom also sought support for a more flexible regulatory model. It recommended a “layered regulatory model” using the “full range of available legal instruments”.
The carrier said that could include a mix of primary legislation “to establish that emergency communications may be delivered via multiple technologies beyond voice” industry codes for technical and service requirements; and regulatory oversight to support consistent interoperability and consumer outcomes.
