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Written evidence submitted by Three




Three response to the DCMS Select Committee Inquiry – Broadband and the Road to 5G


Three welcomes the opportunity to provide evidence to this inquiry. The current situation with the Covid-19 pandemic has highlighted the importance of connectivity and resilient, high-capacity networks. It brings into sharp relief the need to urgently address some of the barriers that are inhibiting the roll out of 5G.

Three is the UK’s challenger mobile network. Since our launch in 2003, our focus has been on enabling our customers to make the most of their mobile service through the development of innovative propositions, such as Unlimited Data packages and 4G – and now 5G - at no extra cost. As a result, Three carries nearly a third of the UK’s mobile data traffic, with our customers using more than 10.4GB of mobile data per month – roughly 3 times the industry average. We therefore have a unique insight as to the infrastructure needed to support a high-capacity data network.

The rollout of 5G represents a huge opportunity for the UK, bringing with it the faster and reliable connectivity the country’s businesses and citizens now expect. That is why Three has invested over £2bn into the UK to ensure our network is 5G ready. This investment has involved an end-to-end business transformation including a whole new RAN (Radio Access Network) and the world’s first mobile cloud core network. 

Below we have addressed the Committee’s specific questions that are relevant to Three.

Q 2. What are the challenges to the roll-out of 5G.

As detailed above, Three is currently in the midst of our 5G rollout. We therefore have a timely understanding of the legislative and regulatory barriers that are inhibiting an effective rollout. These include:

  1. Inefficiencies in the current Permitted Development Regime for mobile.

Government reforms to permitted development rights in mobile, intended to support 4G rollout, unfortunately came too late. This led to the UK having some of the smallest and least efficient mobile masts in Europe, impacting the quality and coverage UK mobile consumers experienced.

It was the hope of the mobile industry that DCMS and the devolved administrations would learn from this situation and bring forward the reforms needed to support 5G infrastructure in a timelier manner. The mobile industry quickly identified the following areas where the unique challenges of 5G infrastructure would require amendments to the current permitted development rights:

Unfortunately, despite Government’s early intentions, the reforms have been significantly delayed, making it more difficult and expensive for us to build the infrastructure needed to give customers a world-class service.

Government have signalled that they are minded to act in this area; however we are still awaiting their response to their consultation on Proposed reforms to permitted development rights to support the deployment of 5G and extend mobile coverage, which closed in November. We urge the Committee to raise this issue with Ministers, to understand what their current timelines are for progressing these critical reforms.  

2. Prospective High-Risk vendors legislation.

Ensuring network security is of paramount concern for Three and is embedded throughout all our decision-making and procurement process. We always work closely with Government, the National Cyber Security Centre (NCSC) and other relevant bodies to help achieve our common goal of improving the security of the UK. Currently, we are supporting the NCSC on their new Telecoms Security Requirements (TSRs).

Therefore, while it will result in a delay to the rollout of 5G in the UK and significant additional cost as operators procure from a second vendor, we welcomed the clarity of Government’s recent decision to restrict the role of HRVs (High Risk Vendors) such as Huawei in our networks to 35% of our networks. We believe that this is a fact-based decision grounded in evidence from the security community and the telecoms sector.

However, it is important that there is no further uncertainty in this area, to allow mobile networks to plan effectively for the future.

3. Threat to telecoms workers due to misinformation around 5G.

Irresponsible and unfounded social media posts that link 5G to Covid-19 have led to an increase in attacks on our infrastructure – and more importantly, our staff and contractors. The industry has experienced over 50 arson attacks or attempted attacks in the past two weeks. This is an unacceptable situation and we welcome the quick and clear response from Government in condemning these attacks. I was also grateful of your statement on behalf of the Committee, and the intention to look further into the sources of these attacks.

These recent incidents highlight the need for Government leadership in signposting trusted advice in a high-profile manner. Three believes that more could be done – at a national and local level – to combat the general trend of wrongly linking 5G and health issues, not just Covid-19. For example, workshops headed by Government with local authorities in attendance would be an opportunity to share the substantial body of research and advice in this area from the likes of the World Health Organisation and Public Health England.

4. Ineffective reform of the Electronic Communications Code.

For operators to upgrade and repair infrastructure, we must be able to access our sites. Government have recognised the imperative of this during the Covid-19 crisis and released Guidance to landlords and highways authorities stating that they should be continuing to facilitate site access where possible, even at this difficult time.

However, even before the present situation, too often problems with landlords have resulted in delays and inefficiencies in rollout. Three believes that these issues could be effectively addressed by amendments to the Electronic Communications Code.

Government recently updated the Code (in 2017) with the intention to facilitate access for upgrades and create a fairer rental system. While many of the reforms were welcome and effective, unfortunately significant loopholes remain which are now undermining the intention of Government’s reforms.

Three would like to see the following changes to secondary legislation to the recently reformed Electronic Communications Code:

Q4. What will be the impact on individuals and communities whose mobile connectivity fails to keep pace with the rest of the country over the next 10 years?

There is no doubt that individuals and communities need access to high-speed mobile broadband – not just in the future, but now. This need will only become more acute over the next decade. However, as recognised by Government, it is simply not economically sustainable for mobile network providers to build networks in the harder to reach areas of the UK.

That is why industry, Government and Ofcom have worked in partnership to create the Shared Rural Network. This is a world-first, providing a huge boost for people across the country in rural areas by delivering strong 4G coverage irrespective of what network provider people use.

The Shared Rural Network (SRN) is a deal with EE, O2, Three and Vodafone investing in a network of new and existing phone masts, overseen by a jointly owned company called Digital Mobile Spectrum Limited which they will all share. It will provide guaranteed coverage to 280,000 premises and 16,000km of roads.

The deal will lead to increases in coverage in some areas by more than a third, with the biggest coverage improvements in rural parts of Scotland, Northern Ireland and Wales. It means all four mobile network operators will deliver 95% combined coverage across the whole of the UK by the end of 2025 and consumers can rely on their own provider’s network wherever they are.

However, for the benefits from the SRN to be maximised, it is important that the barriers detailed above – especially in relation to planning and site agreements – are addressed.

It is important to note that the impact of the Covid-19 outbreak is yet to be fully understood on the SRN process.

Q5. How effectively do the different stakeholders (UK and devolved governments, local authorities, Ofcom, industry) work together in the mobile sector?

There has undoubtedly been a great improvement in terms of how stakeholders work together, as demonstrated by our ability to work together during the current unprecedented situation in the best interests of consumers and UK PLC.

Three welcomes the continued prioritisation of connectivity issues by DCMS and the relevant departments within the devolved administrations. Government’s recent powers to give Ofcom a Statement of Strategic Priorities should also help foster a more collaborative and consistent approach from Government and regulator. Such certainty is welcomed by business.

However, there is still too often delays of months and years bringing legislation or regulation forward. This is catastrophic in a sector which is characterised by fast-moving technical changes. Recently, this can be demonstrated by the continued delays in bringing forward reforms to Permitted Development Rights for mobile infrastructure. It is perhaps telling that in this situation, the policy is led between government departments – DCMS and DHCLG. Three would like to see a more effective way of handling and scrutinising such joint decision-making processes, to ensure that reforms can still be brought forward in a timely manner. 

Finally, Three apologises that our response to this inquiry is brief due to the current capacity constraints but I hope that the Committee find the above overview useful. We would be please to answer any questions the Committee may have, and to attend any briefing or committee sessions.

Simon Miller

Head of Government and Regulatory Affairs