How exactly would a Triple Zero custodian help prevent a repeat of the fatal Optus outage?

In the wake of last week’s Optus network outage that left multiple people dead after they were unable to call Triple Zero for help, there has been much discussion about the need for a Triple Zero custodian in Australia.

But what exactly would this custodian do? And how might it help prevent a similar tragedy from occurring in the future?

A ‘priority recommendation’

The idea for a Triple Zero custodian emerged following another Optus outage on November 8 2023, which interrupted critical services for 10 million people and half a million businesses in Australia. On November 9 2023, the Australian government announced it would undertake a post-incident review.

Led by Richard Bean, a former Deputy Chair of the Australian Communications and Media Authority (ACMA), the review made 18 recommendations. The second of these was to:

Establish a Triple Zero custodian, with oversight of and overarching responsibility for the efficient functioning of the Triple Zero ecosystem, including monitoring the end-to-end performance of the ecosystem.

In its April 2024 response to the review, the federal government called the Triple Zero custodian a “priority recommendation”.

The role has been established within the communications arm of the Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts, but reportedly isn’t yet operational. In the wake of the most recent Optus outage, Communications Minister Anika Wells told Guardian Australia she is now seeking to “fast track” it.

Monitoring the system, managing a crisis

One way the custodian could operate is as a “near real time” auditor. That is, the custodian would act like a a high-level system architect who continuously monitors the system and manages any crisis that emerges within it.

The custodian could also act as a national watchdog. It would do this by continuously collecting and analysing performance data from carriers (such as Telstra, Optus, TPG/Vodafone) and the nominated carrier responsible for getting calls to emergency service organisations such as the police, ambulance, and fire service (and in some jurisdictions the State Emergency Service and rural fire service). Telstra is currently the nominated carrier.

The aim here would be to identify a gradual decline in performance in one part of the system before it causes a major failure.

All carriers run critical incident response exercises. The custodian could be an observer of these and make recommendations as to how the exercises are conducted in the context of the Triple Zero ecosystem.

If there is a major service disruption, the custodian could establish and lead a national crisis conference response. This could include demanding and receiving status updates from all relevant CEOs. This means the custodian could provide authoritative, centralised information to the government and the public.

There would also be performance scorecards provided to the public on the health of the Triple Zero system, highlighting areas of success and concern. The “name and shame” effect on reputation might well be more important than a fine.

The custodian could also provide a more private mediation and advice service for telecommunications companies. If technology changes at a carrier were affecting calls reaching emergency services, the custodian could bring the technical teams from both organisations together to facilitate a solution.

Some limits

The custodian could not issue penalties, as the power to do so in the Federal Court would remain with the ACMA.

The custodian could also not require carriers – or emergency service organisations, for that matter – to invest in a particular upgrade. It could only provide the data and analysis to make a case for the upgrade through the appropriate channels.

Similarly, the custodian could not prevent a carrier from making a commercial decision, such as decommissioning a particular piece of network infrastructure. However, it could require the carrier to provide a comprehensive risk assessment of that decision’s potential impact on the Triple Zero service.

The custodian could not create regulations. However, it could identify the need for rules based on its systemic analysis and formally recommend that either industry or the ACMA develop and implement it.

The custodian’s focus would be on the system, not individual incidents. It would not get involved in the operational details of how a specific emergency call is handled by an operator – unless that incident revealed a wider, systemic flaw.

No certainty it would stop an outage

There is, of course, no certainty that the custodian would have prevented all of the risks from the Optus outage last week.

But as an example of where it might have helped, all phones will use any available network for a Triple Zero call when the home network is not available. When this happens, phones display “SOS Only” (iPhones) and “Emergency calls only” (Android).

But this feature doesn’t work if the phone can connect to the home network. If the network seems to be operational, there is a chance Triple Zero calls would not complete.

In a critical incident exercise, the custodian would be able to point out this problem.

Also, Optus has mentioned that about 630 calls failed in a 13 hour period in Western Australia, South Australia and the Northern Territory.

This suggests the rate of Triple Zero calls from Optus in those regions is about 50 calls per hour.

One way of determining there is a problem would be to raise an alarm if the number of Triple Zero calls drops below 20 calls per hour. This alarm could trigger a response at the carrier’s network operations centres.

This is just one example of how a Triple Zero custodian might help make emergency service calls more reliable – but telecommunications companies such as Optus must also play their part.