Box 4: Summary of key terms
Mobile Network Operators (MNOs)
Improving coverage of mobile data services requires mobile base stations (masts) to be built. The roll-out of mobile services and infrastructure is led by private Mobile Network Operators (MNOs), who take commercial decisions about where to build masts and deliver services.
There are four MNOs in the UK: EE, Vodafone, Three and O2. These MNOs deliver mobile services via their own physical network of mobile base stations. Several small providers rent space on one of the MNO’s networks to deliver services to consumers.
The Government has committed to extend geographic mobile coverage to 95 per cent of the UK by the end of 2022. Since 2016, UK Government policy for improving mobile coverage has focused on coverage obligations for operators and reforms making it easier to build mobile infrastructure.
Coverage obligations are legal requirements on mobile operators to provide a minimum level of mobile coverage across a geographic area or certain number of premises. Ofcom imposes coverage obligations via licences for different bands of airwaves (spectrum). Ofcom is consulting on proposals for new coverage obligations on licences for a new band of spectrum set to be auctioned - the 700 megahertz (MHz) band. Due to its specific qualities, this band is currently a key part of the Government and Ofcom’s proposals to improve mobile coverage in rural areas.
Source: House of Commons Library and Ofcom
68.According to the trade body Mobile UK, in 2019 mobile data is now regarded by many as an essential service. With many people using mobile data instead of fixed line telephone and broadband services, access to mobile data services is increasingly important. Given this trend, according to the Local Government Association, mobile data consumption is set to increase sevenfold by 2021. In particular, rural businesses stand set to benefit from improved mobile data services, with the Government in 2017 outlining that the rollout of 4G had delivered more than £75 billion in GDP to the UK economy through innovation and productivity. There are two main issues with coverage of mobile data in rural areas in the UK:
a)“Not-spots” - areas where there is currently no mobile coverage; and
b)“Partial not-spots” - areas that have coverage from some but not all four of the Mobile Network Operators (MNOs).
This chapter examines two issues relating to mobile coverage and the problems with it: first, the accuracy of coverage statistics; and second, the proposals from Ofcom and MNOs for improving national coverage.
69.In response to complaints from numerous councils and rural stakeholders that mobile coverage statistics provided by MNOs were inaccurate (see Chapter 2), Ofcom outlined its methodology to us, explaining that it published data from the four MNOs, each using its own model to give a predicted signal strength across the whole UK. Katie Pettifer, Public Policy Director, Ofcom explained that Ofcom quality assured each of the MNOs’ models, as well as conducted its own physical testing to quality assure the data it gets.
70.The Local Government Association (LGA) criticised Ofcom’s methodology stating that “metrics should be measurable and based on the reality of service and coverage provided to customers, not based on simulated or predicted performance”. The LGA also claimed there was an imbalance in the resource intensive work Ofcom had undertaken to test urban coverage compared to its efforts in rural areas. Shropshire Council recommended that a proportion of the licence funding paid by MNOs should contribute towards a “testing taskforce” which should be “solely focused on detailed and periodic verification of MNO coverage claims in each geography.” In its Statement of Strategic Priorities (SSP), which Ofcom legally must have regard to, DCMS have called on Ofcom to improve the quality and availability of address-level broadband and mobile coverage data.
71.Despite improvements in national statistics for mobile coverage, stakeholder surveys continue to report that actual coverage varies from patchy coverage to complete lack of coverage in rural areas. We welcome the obligation in the Statement of Strategic Priorities that Ofcom must improve the quality and availability of its coverage statistics. Without accurate and detailed local data, it is easy for national policy makers to ignore the specific needs of consumers in rural areas. Ofcom should report coverage at a lower spatial level and include local 4G coverage targets in addition to national targets. Ofcom should also periodically test providers’ datasets against rural consumers actual experience, rather than relying upon simulated or predicted performance.
72.In the Future Telecoms Infrastructure Review the Government set a target for 4G to reach 95 per cent geographic coverage of the UK by 2022. Ofcom told us this ambition could not be achieved solely through regulation. Ofcom’s primary regulatory tool is the inclusion of coverage obligations in its auctions of spectrum bands for mobile services, for example its upcoming auctions of the 700MHz band and the 3.6–3.8GHz band. Ofcom however explained that the level at which obligations are set is constrained by mobile operators’ willingness to purchase them. Beyond its spectrum auctions, Ofcom advised Government in 2018 that a combination of other policies would be required to deliver near universal coverage including public subsidy for roll out, mandating rural wholesale access (known as “roaming”), and increased infrastructure sharing.
73.Ofcom’s initial proposal for its coverage obligation in its 700 MHz auction was 92 per cent geographic coverage of 4G but this was later reduced to 90 per cent. The LGA criticised Ofcom’s decision, and further argued that there was “no clear guarantee on how progress to reach these goals will be monitored”. Which? commented that Ofcom had been “overly cautious in its approach” to coverage obligations “with only secondary regard given to the consumer perspective”. In its Statement of Strategic Priorities, the Government has stated that the 700 MHz auction presents an important opportunity for improving mobile coverage “particularly in rural areas and on the UK’s major roads” and that this “should, if necessary, be the key priority in the conduct of that auction”.
74.Katie Pettifer, Public Policy Director, Ofcom, explained to us that the initial 92 per cent target was very ambitious and that the decision to reduce the obligation to 90 per cent was made after operators provided more detailed information on the entailed costs. She explained more broadly that Ofcom had “pushed up the boundaries” of the obligations as far as they could in line with its legal duties, and suggested that this approach had helped to prompt the voluntary proposal from the MNOs on infrastructure sharing (see the “Shared Rural Network” proposal below).
75.Shropshire Council commented that the auction did not include any targets for indoor coverage, despite Ofcom data showing that poor coverage inside buildings was a particular rural issue. It argued that “users should not have to step outside every time they want to make a phone call, let alone use an app or go online”. Katie Pettifer, Ofcom, explained the decision to not include indoor targets, stating that the focus of the coverage auction was to focus on “bringing good outdoor 4G coverage to 140,000 premises that do not currently have it”, which in turn would improve indoor coverage due to additional signal strength. Ofcom should set targets for both outdoor and indoor coverage. People living in rural areas shouldn’t have to step outside every time they want to use their phone, either for a phone call or the internet. Ofcom should include indoor coverage targets when setting coverage obligations.
76.In response to coverage obligations included within Ofcom’s 700MHz spectrum auction, the four MNOs have recently come together to propose a partnership with Government to tackle the issue of poor coverage in rural areas. Mobile UK, their trade body, stated that their proposal - called the “Shared Rural Network” (SRN) - goes “beyond what Ofcom is proposing for the 700MHz auction” and does so at less cost to the public purse. The proposal suggests “enhanced mast sharing” to eliminate the issue of partial not spots and bring coverage from all four operators up to 88 per cent (currently 67 per cent). It also calls for Government support to bring commercial services to the Home Office’s Extended Area Service (292 mast sites being built as part of the Emergency Services Network being built by the Home Office to provide coverage for the emergency services).
77.To address “not spots” the proposal also calls for government support to build additional network, “prioritising where there is community led demand”, to bring coverage up to 95 per cent of the UK landmass from at least one operator. Mobile UK has said that the proposal requires measures from government, including reform of permitted development rights, business rates relief, and easier access to public assets under the recently reformed Electronic Communications Code (ECC).
78.Mark Bridgeman, Vice President, CLA, told us that he commended the idea of the SRN but stressed that the arrangement would need to be “legally binding”. The CLA published a letter, with co signatories from the Rural Services Network, National Farmers’ Union, Countryside Alliance and Which?, agreeing in principle to the proposal, but stating their support was subject to:
79.There was a lot of support from rural stakeholders for mandating a “rural roaming” solution to improve coverage in rural areas. MNOs would be required to allow customers of another operator to “roam” onto their network in areas where the customer’s provider did not have coverage, in a similar way to how customers roam onto local networks when abroad. This differs from the SRN proposal in that, rather than MNOs sharing physical infrastructure such as masts to provide coverage from multiple networks in an area, individual MNOs would be required, for a fee, to provide a service to their competitors’ customers through their own infrastructure.
80.The CLA noted that Ofcom’s September 2018 advice to Government stated that coverage could be improved by 10 per cent within 12 months if rural roaming was introduced. More broadly, it argued that rural consumers had been told for too long to just “wait and see” with the unfulfilled promise that coverage would be improved. They argued that “giving too much flexibility to mobile network operators by removing rural roaming” would “take away the level of urgency that is required to solve the 4G coverage crisis”. The Rural Services Network agreed that “network providers would be more incentivised to improve their rural coverage if they knew that failure to do so may result in roaming being imposed at some future date”.
81.Hamish MacLeod, Mobile UK, outlined to us the operators’ resistance to roaming, arguing that “by mandating national roaming you could create a situation where you actually incentivise a reduction in investment”. He stressed that coverage was a key selling point for MNOs and that rural roaming removed the potential for competition, reducing the incentive for investment. Mobile UK further asserted that a roaming solution did not have the full support of industry, whereas the SRN proposal did, meaning it had “the greatest chance of success”. BT argued that roaming would “not be an effective solution to delivering a high-quality experience for customers”, stating that it would not address total not spots and would “significantly dilute the incentive for operators to invest in extending coverage”. BT further argued it would degrade the customer experience with increased dropped or blocked calls, less reliable access to data, poorer service and decreased battery life.
82.Ofcom told us that it believed the SRN proposal was a “potentially very positive development” and informed us that they were providing technical support and input into the discussions between the operators and Government. On roaming, Ofcom concluded in advice to the Government published last year that roaming introduced investment risks and consumer experience issues, but that these could be mitigated to a degree. It also concluded that the most effective way to introduce a roaming arrangement was with the cooperation of the MNOs. Ofcom said it would continue to keep the question of rural roaming under review, but that it had no plans to conduct a specific review given the advice to Government last year and the ongoing SRN discussions. DCMS stated that the terms of the SRN proposal were still being developed, and that it looked forward to hearing the industry’s potential solution. In its Statement of Strategic Priorities, DCMS have stated that “Ofcom should consider the costs and benefits of [roaming in rural areas] and maintain the option of requiring roaming by including appropriate provisions when granting rights of use for spectrum”.
83.Rural communities have been told for too long to just wait and see with the unfulfilled promise that mobile coverage will be improved. On the eve of the roll out of 5G, rural communities will only feel more marginalised if they continue to be denied access to 4G, or even 3G. With many now regarding mobile data as an essential service, the Government and Ofcom has to be ambitious in setting coverage targets and obligations.
84.Relying on competition between the Mobile Network Operators to tackle not spots and partial not spots in coverage has not worked. The Committee therefore supports a rural roaming solution to tackling poor mobile coverage in rural areas if the industry cannot find a comparable or better solution quickly. We await the detail of the Shared Rural Network proposal with interest, as we recognise it could have significant benefits for rural communities. Any arrangement must include legal guarantees on Mobile Network Operators (MNOs) to ensure they meet coverage targets. Parallel to the talks over the Shared Rural Network, Ofcom should urgently conduct a specific review on the costs and benefits of roaming. Should a voluntary agreement between Government and MNOs not be reached by the end of 2019, the Government should instruct Ofcom to impose a rural roaming solution to tackle partial “not-spots”.
200 Mobile coverage in the UK, Briefing Paper , House of Commons Library, 22 February 2019; see also Ofcom, , (May 2018), last accessed 6 September 2019
201 Mobile UK (), para 14
202 Local Government Association (LGA) (), para 3.9
203 Local Government Association (LGA) (), para 3.9
204 DCMS, (March 2017), p 19
207 Local Government Association (LGA) (), para 3.12
208 Local Government Association (LGA) (), para 3.12
209 Shropshire Council (), para 3
210 DCMS, , July 2019, para 54
211 DCMS, (July 2018), p 10
212 Ofcom (), para 3
213 Ofcom, (March 2019), para 1.2; Ofcom, Improving mobile coverage (March 2019), para 1.7–1.8
214 Ofcom (), para 3
215 Ofcom, (September 2018), p1–2
216 Local Government Association (LGA) (), para 4.4
217 Which? (), para 11
218 DCMS, (July 2019), para 30
221 Shropshire Council (), para 3.10
222 Shropshire Council (), para 3.10
224 Mobile UK (), para 26
225 Mobile UK (), para 28
226 Mobile UK (), para 30
227 Mobile UK (), para 30
228 Mobile UK (), para 31
230 CLA, (June 2019), last accessed 30 August 2019
231 North Yorkshire County Council (), para 6.1.8; Action with Communities in Rural England (), para 11; Leicestershire County Council (), para 3.1.6; Hampshire Rural Forum (), para 2.5; Rural Services Network (), para 10; CLA (), para 6; Local Government Association (LGA) (), para 2.4.3
232 CLA (), para 8
233 CLA (), para 9
234 CLA (), para 11
235 Rural Services Network (), para 10
238 Mobile UK (), para 36
239 BT Group (), para 45
240 BT Group (), para 46
241 Ofcom (), para 5
242 Ofcom (), para 6
243 Ofcom (), para 6
244 Ofcom (), para 7
245 Department for Digital, Culture, Media and Sport (), para 13
246 DCMS, (July 2019), para 31
Published: 18 September 2019