1. About the Local Government Association

1.1. The Local Government Association (LGA) is the national voice of local government. We are a politically-led, cross party membership organisation, representing councils from England and Wales.

1.2. Our role is to support, promote and improve local government, and raise national awareness of the work of councils. Our ultimate ambition is to support councils to deliver local solutions to national problems

2. Summary

2.1. In the last decade local government has been a key player in the roll-out of improved digital connectivity to the hardest to reach areas. It has partnered with the communications industry to extend coverage to local communities through the Superfast Broadband Programme and has worked closely with mobile network operators (MNOs) and local communities to find the best locations for new mobile infrastructure.

2.2. Councils fully support the Government’s ambition to achieve nationwide gigabit-capable broadband coverage, but the proposal to reach this target by 2025 lies at the upper end of what is likely to be possible. Regardless of how this target is met, it will be paramount to ensure Government does not reduce the offer to rural or more difficult to reach areas to meet the connectivity targets. National gigabit provision must, wherever possible, be a universal service.

2.3. It is important that in striving to become a world leader in 5G coverage the Government does not lose sight of ensuring the Shared Rural Network delivers high quality 4G coverage for rural communities. We have welcomed the deal as a positive step towards securing improved coverage for local communities, but believe more clarity is needed from Ofcom and Government on how it will be implemented and monitored. In particular, more needs to be done by Ofcom to capture the real world experience of mobile phone users in rural areas, as the evidence from some councils suggests that both service speed and availability can fall short of the regulator’s theoretical coverage models.

2.4. There is significant concern amongst councils that the proposal to centralise the roll out of publicly funded gigabit broadband is likely to create additional risks and fail to take advantage of the local expertise of councils, which were instrumental in the successful roll out of the Superfast Broadband Programme. It is important that councils are equal partners in any future programme and that the centralisation of delivery and decision-making does not hamper the overall ability of Government and councils to assure supplier delivery. Councils’ sense checking of deployment and challenge of provider delivery where necessary has had a significant role in mitigating risks that would have otherwise caused delays, cost escalations and local complaints. This has helped secure value for money for the taxpayer. Clarity from the Government regarding the benefits of its proposed approach, the role of councils and the opportunities for AltNet providers, which played a key role in Superfast Programme is now needed as a matter of urgency.

3. How realistic is the Government’s ambition of nationwide gigabit-capable broadband by 2025, and what measures (regulatory, financial, technical, other) will be needed to achieve it?

3.1. Councils support the Government’s ambition to achieve nationwide gigabit-capable broadband coverage, but the proposal to reach this target by 2025 lies at the upper end of what is likely to be achieved. Less than two years ago, the Government’s Future Telecoms Infrastructure Review (FTIR) forecast that only 15 million premises could be reached by 2025.[i] It follows, that covering circa 30 million premises by the same deadline, including 6 million premises in the final 20 per cent, will be exceptionally hard to achieve without significant investment, access to a sufficient and appropriately qualified workforce and strong partnership working between broadband providers, national and local government.

3.2. In 2018, the FTIR estimated that between £3–5 billion of public funding could be required to deliver full-fibre to the final 10 per cent of premises as part of a publicly run initiative, which the Government named the Outside-In Programme. Since then, the Government’s ambition for the programme’s scale has increased to covering the final 20 per cent of premises. Despite a doubling in the number of premises the programme will now aim to reach, the Government’s committed funding remains at £5 billion, which the FTIR forecast would only cover the final 10 per cent of premises. At present, this increase in scale will be covered without any additional public money.[ii] Regardless of how this more ambitious target is met, it will be paramount to ensure Government does not attempt to square the circle of a fixed budget, increased scale and shortened deadline by reducing the offer to rural or more difficult to reach areas, national gigabit provision must, insofar as possible, be a universal service.

3.3. The demands of an infrastructure project of this size will place greater pressure on roads as more streets will need to be dug up to lay the cables. Councils oversee 184,000 miles of local roads in their role as highway authorities.[iii] They play a vital role in balancing the needs of road users and utility companies, whilst protecting the structural integrity of road surfaces that are expected to last an average of 67 years before resurfacing.[iv] Government should therefore consider providing funding to highways authorities, potentially in partnership with broadband providers. This will help deal with increased capacity requirements and ensure a balance is struck between keeping traffic running whilst serving local communities with improved broadband. Councils should be able to schedule, not just issue, work permits. This would ensure that highways authorities have not resurfaced roads within weeks of broadband infrastructure being built.

3.4. It will also be vital to ensure that the telecommunications industry has access to a sufficiently skilled workforce. Providers of telecoms services rely heavily on roadworks subcontractors to roll out coverage to communities. We understand from industry representatives that many of these teams are staffed by EU nationals with experience from their own domestic fibre deployment programmes. We therefore echo the calls of the industry that Government must ensure local skills systems can prioritise the training of local labour forces with the appropriate digital and engineering skills to contribute to this ambition and that any future immigration system allows broadband providers fill ever-increasing skills gap with workers, when necessary. [v]

4. What are the challenges to the roll-out of 5G and gigabit-capable networks? To what extent do existing legislative, regulatory and spending plans address them?

4.1. The Government’s commitment to achieve universal gigabit-capable networks and become a world leader in 5G is commendable. Their delivery will be an inherently local endeavour and success will be judged by the extent to which communities and businesses right across the country are able to enjoy the benefits of an increasingly digitalised way of life.

4.2. Councils have the potential to play a crucial role. They have been at the centre of delivering the Superfast Broadband Programme, having committed £740 million to extending connectivity to the hardest to reach areas. Many are also adopting digital infrastructure strategies to support the extension of digital connectivity to all residents and businesses and, in turn, support the delivery of digital public sector transformation. It will be vital that Government’s legislative agenda, spending plans and design of the new ‘outside-in’ programme fully leverage the ability and capacity of councils to contribute to and assure supplier delivery of high-quality connectivity.

4.3. Future proofing the digital connectivity of new housing stock is a key part of achieving the Government’s ambitions. Following our calls to Government, we welcome the recent confirmation it will pass legislation to ensure new homes are built with gigabit-speed broadband.[vi]

4.4. The proposals could of course still be improved and the LGA is working with Government and industry to make the case for positive changes. For example, the Government recently announced that where the cost to connect a premise exceeds the developer and provider combined contribution level, set at £2,000 for developers and between £500-£1400 for broadband providers, then the developer will be obliged to explore connecting new builds to the next best available speed, such as superfast. Considering the Government’s nationwide gigabit broadband ambitions, and suggestions from Openreach that the hardest to reach homes in the final 10 per cent will cost £4,000 to connect to full fibre, this policy seems short sighted.[vii] We have suggested that Government should explore how public funding set aside for the gigabit roll out programme could be used to ‘top up’ new build connection funding, in partnership with councils, to ensure all new builds are provided with gigabit connections as standard. This would provide much better value than creating new housing stock that will very quickly need to be retrofitted.

4.5. With mobile data consumption in the UK forecast to increase sevenfold by 2021 [viii], extending excellent mobile coverage across the country is also key to ensuring all residents have equal access to what is now a necessity of every-day life. At a minimum this means providing every community with access to high quality 4G coverage. This level of connectivity is something that most urban areas take for granted, yet many in rural areas often struggle to make or receive even a simple voice call.

4.6. It is therefore important to ensure that in striving to become a world leader in 5G coverage that the Government does not lose sight of the fact that the significant technical requirements of this technology, not least the necessity to provide cells at a very high density in order to deliver ‘ultrafast’ millimetre wave connectivity, are more likely to be met in urban areas. With this in mind, we believe the Committee should extend the scope of its Inquiry to scrutinising the Shared Rural Network (SRN) commercial proposition agreed by Government and mobile operators. We have welcomed the deal as a positive step towards securing improved coverage for local communities but believe more clarity is needed from Ofcom and Government on how it will be implemented and monitored.

4.7. Ofcom will play a fundamental role in ensuring that mobile network operators meet their new SRN obligations. To do this, the regulator will use its own coverage propagation models as well as modelling data supplied by operators to benchmark performance and ascertain compliance. Councils are also invested in this agenda. Many are exploring how they can use local policy levers to catalyse the improvement of local mobile connectivity, whether through the use of public assets, or even public funding. In order to best inform their approaches, councils are increasingly commissioning drive-by analyses of coverage to independently benchmark Ofcom and mobile operator coverage data. In doing so they are increasingly finding a disconnect between Ofcom’s coverage modelling and real-life mobile experience.

4.8. Shropshire Council, working with local parish councils has already found 28 areas where operators’ outdoor coverage claims fail to match the quality of coverage on the ground. In Cambridgeshire & Peterborough Combined Authority, the Connecting Cambridgeshire programme has drawn up a ‘Top 20’ list of priority areas identified by comparing detailed local mobile connectivity surveys commissioned by Cambridgeshire County Council with the latest Ofcom mobile coverage data. The response from both the mobile industry and Ofcom to these concerns has been limited and is an ongoing matter of concern for councils. We have called for the Government to instruct Ofcom to independently verify coverage, with local areas given annual speed and reliability health checks using on the ground testing in real life scenarios. At a local level councils would also benefit enormously from being able access ‘real world’ coverage maps held by mobile operator and we would welcome the industry’s commitment to work with us on this issue.

4.9. In those areas where 5G has begun to be rolled out councils have also had to respond to community concerns and targeted campaigns relating to the perceived safety of the technology. We have seen the cost of this very recently in the damage of 5G equipment across local areas. Government, Public Health England and the mobile industry need to work more effectively with councils in disseminating non-technical and clear guidance that the public can understand to reassert its safety. The sector would also welcome guidance on practical approaches towards dealing with citizen concerns. In terms of roll out, there also remains a common misconception from both Government and industry that some planning authorities are seeking to place a moratorium on 5G infrastructure – which would be illegal. We have seen no evidence of such measures being undertaken by planning authorities but rather by a few town and parish councils who do not have planning powers.

4.10. More generally, the mobile industry often cites the planning regime as a major barrier to mobile connectivity. Councils recognise the important role they must play to ensure local planning policies are streamlined to the needs of mobile roll out. In a recent LGA survey of councils, 80 per cent of respondents outlined they had amended or were looking to amend local plans to ensure a more conducive approach to digital infrastructure deployment.

4.11. West Midlands 5G are working to create a common digital map of mobile and fibre coverage overlaid with local authority infrastructure.[ix] Initiatives such as these can transformative, but often require long-winded negotiation with MNOs around complex non-disclosure agreements. We have called on Government to convene the mobile industry, local government and Ofcom to agree a long-term solution to this issue, including drafting a template non-disclosure agreement to force mobile operators to share their roll out plans.

5. What needs to happen to ensure the Government’s ‘outside in’ approach successfully addresses the digital divide while also delivering value for money?

5.1. Having managed local delivery of the Superfast Broadband Programme since 2011, councils are uniquely positioned to understand how the Government’s ‘outside in’ can most successfully address the digital divide while also delivering value for money.

5.2. As part of the design of the Superfast Broadband Programme in 2011, the then Government stated that “in line with [its] agenda on localism” local bodies would be encouraged to take on the management of local roll outs and lead the development, sourcing and delivery of broadband projects in their areas.[x] Almost 50 councils took up that offer in England alone, and have since managed to successfully pass over 3.7 million premises (not including Scotland, Wales and Northern Ireland).[xi] The Government called the programme one of its greatest successes.[xii]

5.3. Over the last decade, local government has developed significant expertise, and local datasets to help hold broadband providers to account on their delivery, helping achieve value for money for the taxpayer and a considerable number of ‘premises passed [xiii].’

5.4. At present, to deliver its new gigabit-broadband ambitions, the Government will procure and manage the contracts for the local delivery of gigabit-capable broadband infrastructure, rather than councils. In addition, contract deployment will not necessarily be contiguous with council boundaries.

5.5. There is a concern amongst councils as to the potential risks of centralising the roll out of publicly funded gigabit broadband, especially when set against the success of the councils roll out of the Superfast Broadband Programme.

5.6. Whilst the LGA has had positive engagement with Building Digital UK (BDUK) in regard to the possible future design of the programme and welcomes their collaborative approach, we have yet to see articulated how the benefits in terms of value for money and premises passed that a centralised model would provide over a more localised one.

5.7. In contrast the centralisation of delivery and decision-making risks losing the benefits of councils’ local intelligence, insights and knowledge which has enabled the delivery of the superfast programme. Instead, it risks placing much more power in the hands of commercially-minded suppliers. Through proposing the removal of the levers councils use to manage suppliers, BDUK is underestimating the important role councils have played in assuring supplier delivery to date. Sense checking and optimising interventions and deployment plans as well as challenging broadband providers work where necessary has helped mitigate delays, cost escalations and local complaints nationwide. Furthermore, there is a risk that opportunities to accelerate deployments, reduce costs and stop unintentional overbuild will be lost. Most importantly, taken in combination, these actions have been vital in securing value for money for the taxpayer.

5.8. Without a more definitive local role, the level of profile, influence and priority digital has held within the local authorities over other non-statutory may decrease as councils are forced to focus on more pressing needs. The future of council digital connectivity teams will also become more uncertain with the conclusion of the superfast broadband programme approaching. There was been no clarification from Government on whether funding will be provided to councils to maintain local digital connectivity teams. Originally set up to lead on the Superfast Broadband Programme, many could be under threat when the programme ends, and councils are forced to prioritise key statutory services.

5.9. BDUK should establish a partnership agreement with councils so that local teams have clear contracted responsibilities. Government must also contribute to the resourcing of local teams to ensure that this expertise and capacity is not lost and expensive and long-winded re-recruitment has to take place to re-build teams. Talented and knowledgeable council officers are already in place in local areas and BDUK must make use of them.

6. What does take-up of broadband and mobile services indicate about consumer and business attitudes to digital connectivity? What needs to be learnt from this for the roll-out of, and switchover to, gigabit-capable networks?

6.1. With the majority of the population currently working from home owing to the Covid-19 public health crisis, the importance of digital networks that are widespread, fast and have the required capacity to deal with peak demand has been made clear. Many councils are reporting increases in dropped calls and outages, especially in rural areas. Whilst initiatives like the Shared Rural Network, place front and centre commitments to increase coverage across the country, a look at the fine print shows much more limited ambitions. Ofcom’s recent 700Mhz spectrum auction outlined the regulator views ‘good quality” 4G coverage as “single-user download speed of 2 Mbps with a better than 90% probability.’[xiv] Its recently published Shared Rural Network coverage methodology sets required coverage at a minimum of -105dbm of signal strength. This would register as a single bar of coverage on an iPhone 7 plus, something which is already out of step with consumer expectation today, let alone in five years’ time.[xv]

6.2. The Superfast Broadband Programme has shown that take up of faster services takes time and requires pump priming. There is evidence that when the Government has funded local demand stimulation programmes our members have seen a marked improvement in the take-up of broadband services from both residents and businesses.[xvi] Ofcom’s own analysis shows that when providers roll out full fibre in areas that haven’t shown a pre-registered interest, take up also tends to be low.[xvii] Councils also used their own funding to offer new premises passed with digital skills sessions to ensure residents had the ability and knowledge to utilise improved speeds. It will therefore be important that the Government streamlines digital skills initiatives to complement the expansion of gigabit services for communities ensuring join up at a Departmental level across BDUK, digital and skills policy teams and also empowers councils to undertake more targeted measures that can often be more effectual than one size fits all campaigns.

6.3. Finally, there remains a high level of confusion amongst the public and in the communication provided by broadband providers and Government on broadband speeds and infrastructure. References to both in public policy and Government announcements must be clearer, more accurate and consistent. An example of how complicated the broadband market is for consumers was highlighted across the 2019 party manifestos which had initiatives related to funding broadband which was hyper-fast, superfast, ultrafast, full-fibre, fibre-optic, gigabit-capable, highspeed and base-level.

7. What will be the impact on individuals and communities whose broadband and mobile connectivity fails to keep pace with the rest of the country over the next 10 years? What is the link with other DCMS policy concerns, such as changing patterns in the consumption of digital media?

7.1. Despite the ‘digital revolution’ many in rural areas are still deeply dissatisfied with the level of connectivity services available to them. Ofcom analysis has found that a third of rural firms believe poor connectivity is hampering their growth.[xviii] If local areas fail to keep pace with the rest of the country, they are unlikely to attract and sustain the high value industries of the future. There is already evidence showing that non-metropolitan economies are lagging behind the rest of England in these sectors, such as information and communications, finance and insurance.[xix] To build a prosperous economy, non-metropolitan England will require digital infrastructure capable of supplying upload and download speeds not just to meet the present demand, but which will be capable of meeting the needs of the industries of the future.

8. How effectively do the different stakeholders (UK and devolved governments, local authorities, Ofcom, industry) work together in both the mobile and broadband sectors? How might these relationships be improved to support gigabit-capable roll-out?

8.1. Wider collaboration and engagement at a strategic level between councils, national Government and telecommunications stakeholders will be vital if digital connectivity is to be successfully expanded across the country. We have outlined in this submission why BDUK’s outside-in programme must be designed with councils as equal partners to government in their own local areas. More broadly we believe that Ofcom must also work much more closely with local areas to hold mobile network operators to account on the coverage they are providing to local communities. At present, we have heard the regulator is hard to engage and does not accept the local evidence provided by councils outlining the disconnect between mobile operator coverage data and reality.

[xiii] Premises passed refers to the number of premises that could connect to faster speeds should they wish as a result of the programme’s roll out.

[xviii] The SME experience of communications services: research report, Ofcom, 2016