Edit: The page mentions that this allows web applications to make their own DNS requests, possibly looking up things other than A/AAAA records that the browser normally requests.
DNS Messages have a two-byte length prefix when transmitted over TCP. Multiple envelopes can and often are sent over a single circuit.
heck you can even do that over udp with dtls, if you don't want to deal with setting up and tearing down tcp connections.
Which is ridiculous, as it literally brings zero advantage to restrict that.
There is, however, https://www.w3.org/TR/tcp-udp-sockets/ - see section 10 for an example.
-- time passes --
"We need to change everything in order to accomplish a task under these restrictons."
(and, to be clear, the answer is yes, namely that a custom protocol has to deliver a lot of value to make up for having to deal with the deployment headaches inherent to anything less supported by firewalls, NAT boxes, etc. than HTTP/HTTPS)
Twilio isn't implemented using AT commands either, and for the same reason.
DNS latency is an entire round trip added to every single fresh domain lookup you make. That's a lot of times, and we want those to be as fast as possible. At that point, the raw sockets vs full blown HTTP over TLS over TCP debate matters.
Twilio, on the other hand, is used in situations with comparably laughable latency requirements. At least two orders of magnitude.
Not saying it's doa, but the question has merit.