4. Proposed Policy
The steps to installing gigabit-capable broadband in new build homes
The exact process for installing gigabit-capable broadband in new build homes is dependent on which network operator is engaged. However, the overarching steps remain the same for all developments:
Gigabit-capable broadband installation steps
1. A developer (or a contractor working on their behalf) engages with at least two network operators.
2. The network operators provide quotations.
3. Agreement reached with chosen network operator.
4. In-building physical gigabit-ready infrastructure is installed (from a network termination point within each dwelling to an access point, or a common access point within multi-dwelling buildings).
5. Necessary external physical gigabit-ready infrastructure is installed from an access point or common access point to the nearest network distribution point (different methods are used). This work will be done in phases for developments but would typically include on-site ducts, chambers and access points.
6. A gigabit-capable connection from the network distribution point is installed to a dwelling’s network termination point, composed of an optical fibre cable or other equipment by which such a connection will be provided (in some cases this may involve expansion of the network),
A consumer can then contract with a relevant internet service provider who activates the gigabit network connection.
The new requirements are designed to align with current practices and complement existing processes. This will ensure that all developers are taking the necessary steps to equip new build homes with gigabit-ready infrastructure and gigabit-capable connections whilst minimising burdens.
The requirements for developers will ensure new build homes have gigabit-capable connections through the installation of:
- the in-building and onsite physical infrastructure necessary for gigabit-capable connections (consisting of infrastructure including ducts, chambers and termination points) up to an off-site network distribution point where reasonably practicable; and
- subject to a £2,000 cost cap per dwelling, a gigabit-capable connection (composed of equipment such as an optical fibre cable, other cabling or wiring, or wireless connection that will provide gigabit-capable broadband if such a service were to be provided by an Internet Service Provider)
Where a developer is unable to meet the requirement to secure a gigabit-capable connection, for example because the developer costs incurred after any network operator contribution exceed the cost cap or another exemption applies, a developer will be required to install the next best technology connections available unless the quote for that installation also exceeds the cost cap. In the first instance this should be at least a superfast 30 Mbps connection, and failing that a broadband connection in line with the Broadband Universal Service Obligation’s download speed. As set out in the Universal Service Order 2018 (Electronic Communications (Universal Service) (Broadband) Order 2018 – SI 2018/445) this is currently a connection delivering at least 10 Mbps download speed (along with other defined quality parameters). Where future amendments to the Universal Service Obligation are made the standard for new homes will require review.
Where no connection can be secured without exceeding the cost cap, the first requirement to install gigabit-ready physical infrastructure necessary for gigabit-capable connections will ensure that the new build home is future-proofed and ready for gigabit connectivity unless any further exemption based on the remoteness of the property is appropriate. In the absence of a broadband connection in line with a Broadband Universal Service Obligation connection, a consumer will normally be able to make a request for a Universal Service Obligation connection.
The Broadband Universal Service Obligation is a UK-wide measure intended as a ‘safety net’ to deliver broadband to those premises that do not have access to a decent and affordable connection. This is currently defined as a connection delivering at least 10 Mbps download speed and 1 Mbps upload speed (along with other defined quality parameters). Ofcom has defined an affordable connection as one that costs not more than £54 per month. The Broadband Universal Service Obligation provides a legal right to consumers to request a broadband connection, up to a cost threshold of £3,400 providing eligibility criteria are met, and a mechanism to contribute above this threshold to ensure a connection within a specified timeframe.
Gigabit-ready physical infrastructure
The developer’s requirement to install the gigabit-ready physical infrastructure necessary for gigabit-capable connections will require building works to ensure that each dwelling (including each individual dwelling in multi-dwelling buildings) is equipped with the required infrastructure to support at least one gigabit-capable connection. This includes in-building and onsite physical infrastructure. Infrastructure can be located anywhere within the site such as in the footpath, driveway or common area leading from the building.
In-building physical infrastructure
To meet this requirement, in-building physical infrastructure should be provided to extend from a network termination point within a dwelling (a physical point providing access to an electronic communications network) to a building access point (a physical point accessible to a network operator) typically located on the external wall. For domestic buildings containing more than one dwelling, in-building physical infrastructure should be provided to extend from a network termination point within a dwelling to a common access point (typically located in a communal service riser). This mirrors existing requirements of Standard 4.14 of the Building Standards updating the standard to reflect that the physical infrastructure should be capable of enabling a gigabit electronic communications network connection.
Onsite physical infrastructure
For the developer to meet the requirement to install gigabit-ready physical infrastructure the new build home will also need to be equipped with infrastructure external to the building. This can vary across developments but typically includes the installation of ducts, chambers, cabinets, towers and poles, connecting a dwelling’s access point to a network distribution point or an access point located in close proximity to a network distribution point.
This gigabit-ready physical infrastructure will need to extend to one of the following points:
- a network operator’s network distribution point for gigabit-capable connections, which could be off-site, or
- where the developer has no right to install gigabit-ready physical infrastructure on intervening land in which it would have to be installed to reach the network distribution point, a point as close as is reasonably practicable to the network distribution point, or
- where the developer has no right to install such infrastructure in land beyond the building, a network termination point’s corresponding access point or common access point.
This stepped approach is designed to ensure that the requirement does not extend to the installation of infrastructure on or over third party land upon which the developer does not have the rights to access.
A network distribution point will vary based on the network in question and may typically include cabinets, boxes mounted on walls or telephone poles. It is the point at which the network operator’s spine or core network ends. In order to facilitate a connection, the network operator’s spine or core network must be met by physical infrastructure leading from the dwelling’s network termination point, via an access point.
Where developers are unable to install gigabit-ready physical infrastructure to a network distribution point because they are unable to access intervening third party land to do so, a network operator may be able to gain access to the intervening third party land, including through engaging Electronic Communications Code (‘the Code’) powers. The Code is the legal framework underpinning network operators’ rights to install and keep electronic communications apparatus on public and private land, and to carry out other activities needed to provide electronic communications networks. The purpose of the Code is to provide a regulatory framework that supports and encourages the efficient and cost-effective installation and maintenance of robust digital communications networks.
As the locations of network operator’s networks and distribution points will vary across developments, we encourage developers to work with network operators as early as possible to ensure that the installed infrastructure is capable of hosting gigabit-capable connection equipment to ultimately establish a live network connection. This work should ensure that planned infrastructure deployment corresponds to a network operators planned or located network distribution point. Proposed guidance under Standard 4.14 of the Building Standards Technical Handbooks provides further information as to how this requirement can be met (see Annex A).
Infrastructure performance and specifications
The installation of the gigabit-ready physical infrastructure necessary for gigabit-capable connections will be defined in a similar way to existing arrangements for high-speed electronic communications networks in the existing Standard 4.14, updated for gigabit connectivity. Namely, it will include any infrastructure or installation which is intended to host elements, or enable delivery, of wired or wireless gigabit-capable public electronic communications networks that are capable of delivering a broadband access service at download speeds of at least 1,000 Mbps.
The requirement will not specify what infrastructure should be used. It will need to be able to host elements or enable delivery of either wired or wireless gigabit-capable public electronic communications networks. A non-exhaustive list of infrastructure types that could be used include: on-site pipes, masts, ducts, chambers, manholes, buildings or entries to buildings, antenna installations, towers, poles and termination points. The physical infrastructure requirement does not include an optical fibre or other cabling or wiring equipment that will provide the broadband connection related to the Standard 4.14(d) requirement and installing a connection.
These physical infrastructure requirements will not be subject to a cost cap given the low costs involved to developers and the need for residents to be able to obtain gigabit connectivity. Within most new build developments, groundworks will be carried out at an early stage to enable connection to other utilities, which should also assist with the inclusion of the physical infrastructure.
Physical infrastructure and next best technology connections
Except for where an exemption is applicable (see Gigabit-ready physical infrastructure exemption in the following section), the gigabit-ready physical infrastructure requirement will apply to all new build homes in scope. We anticipate that in some cases a developer will:
- not be able to fit a gigabit-capable connection within the cost cap, so will be under an obligation to fit a next best technology connection (see Next best technology connections, and
- be required to fit gigabit-ready physical infrastructure, but
- will be unable to use gigabit-ready physical infrastructure capable of supporting both a next best technology connection (for example, a high-speed electronic communications network connection) and a gigabit-capable connection in parallel.
In most cases, we anticipate that the gigabit-ready physical infrastructure to be installed will also support a high-speed electronic communications network connection, if a gigabit-capable connection is not required.
However, we anticipate that in some cases a developer will:
- not be able to provide a gigabit-capable connection within the cost cap, so will be under an obligation to install the next best technology connection (see next best technology connections); and
- be required to fit gigabit-ready physical infrastructure but will be unable to utilise this to support a next best technology connection and a gigabit-capable connection in parallel.
In such scenarios, the developer may be required to install two sets of physical infrastructure or oversize the physical infrastructure to carry parallel connections.
We are keen to seek views on the likelihood of duplicate infrastructure being required, challenges associated with such a scenario, burdens that this may impose as well as any opportunities to overcome such issues.
Gigabit-ready physical infrastructure exemption
As detailed above, the requirement to install the gigabit-ready physical infrastructure necessary to support gigabit-capable connections exists even where installing the gigabit-capable connection exceeds the cost cap or a next best technology connection will be unable to use gigabit-ready physical infrastructure (see Physical infrastructure and next best technology connections in the section above). This means that when a gigabit-capable broadband connection exceeds the cost cap at the point of construction or an alternative connection is installed, new build homes will still be built with the right infrastructure to support a gigabit-capable connection in the future.
This obligation can be fulfilled in a variety of different ways, although in most cases this would involve the new build home having the necessary physical infrastructure to support a gigabit-capable full fibre connection. This infrastructure can be located anywhere within the site, such as in the footpath, driveway or common area of the site in which the dwelling is located, the outside wall of the dwelling and inside the dwelling.
Where a developer and a network operator are able to identify a network option to support gigabit connectivity, how and where the installation of the infrastructure should be undertaken will be ascertainable. However, there may be a small number of cases where it may not be evident what form of infrastructure should be installed or where this infrastructure should be deployed to meet a network distribution point.
As such we are keen to seek views on any practical difficulties anticipated with a blanket application of this requirement and if any exemption would be appropriate.
1. Are costs of providing the gigabit-ready physical infrastructure element reasonable?
2. Will the proposals help ensure that gigabit-ready physical infrastructure is placed in the best location to connect to a network distribution point? If not, please explain why.
3. How common is it for third party land issues to prevent connectivity to new build homes?
4. How are third party land issues resolved where they do take place?
5. Are there circumstances where it would be difficult to meet the gigabit-ready physical infrastructure requirements?
6. What circumstances may necessitate an exemption from the requirement to provide gigabit-ready physical infrastructure?
7. Do you anticipate any issues with the stepped approach to the gigabit-ready physical infrastructure requirements extending to the network distribution point? Please provide any comments/reasoning on your position.
The proposed Standard 4.14(d) requirement is for the installation of the specific equipment capable of supporting a broadband connection, providing this can be secured without exceeding a £2,000 cost cap per dwelling. Whilst any technology capable of delivering gigabit connections can be considered, in practice, most connections under the requirement are likely to use full-fibre to the premises.
This equipment would include an optical fibre or other cabling, wiring or wireless technology provided by a network operator to facilitate a connection. This should support a broadband connection for service provision from at least one internet service provider through connection with the network operator’s infrastructure. The requirement does not extend to making the connection ‘live’. This will only happen once a consumer contracts with an internet service provider.
The equipment in the first instance should be capable of delivering a broadband service at download speeds of at least 1,000 Mbps. This definition will enable the requirement to be met through any form of existing or future wired or wireless technology including fibre to the premises (FTTP), fixed wireless access (FWA) and other cables (e.g. DOCSIS 3.1) or satellite. This definition and technologically neutral approach will be supported in the guidance supporting the new provisions under The Building (Scotland) Regulations 2004 (as amended) noting forms of existing technology (as referenced in Ofcom’s Connected Nations Reports) that could be suitable for meeting the requirements.
Next best technology connections
Should the cost cap be exceeded, a ‘next best technology connection’ requirement will apply, requiring the developer to seek to obtain a quote for the installation of the fastest possible connection available without exceeding the £2,000 cost cap per dwelling. In the first instance this should be at least a high-speed electronic communications network capable of delivering broadband access services at speeds of at least 30 Mbps (superfast broadband).
If a developer is unable to secure a superfast connection within the cost cap, the developer would then need to secure a broadband connection with a download speed as defined in the Broadband Universal Service Obligation or provide evidence that this could not be secured without exceeding the £2,000 cost cap. A standard connection under the Broadband Universal Service Obligation currently includes a connection that can deliver connectivity download speeds of at least 10 Mbps.
For new build homes where the developer has been unable to secure broadband connectivity of at least 10 Mbps download speed without exceeding the cost cap, a consumer moving into the new build home could seek to obtain a broadband connection under the Universal Service Order 2018, subject to the normal eligibility conditions.
Both next best technology connections requirements will be kept under review and should amendments be made to the Broadband Universal Service Obligation the connection requirements may be adjusted or removed as appropriate.
The arrangements for developers obtaining quotes from network operators will not be prescribed. However, it may be practical for a developer to engage with the network operator to determine how much the quote would also be for a high-speed connection and/or a Broadband Universal Service Obligation connection, in the event that a gigabit connection would not be provided because the cost exceeds the cost cap. This may avoid the need for the developer to request repeated quotes from the network operator.
In some instances, but possibly not all, the gigabit-ready physical infrastructure installed for a next best technology connection will also be capable of supporting a gigabit-capable connection. By way of an example, ducting for a high-speed electronic communications network connection that is capable of supporting a gigabit-capable connection would contribute to meeting the gigabit-ready physical infrastructure requirements. However, as set out in Gigabit-ready physical infrastructure exemption, this may not always be the case. In these scenarios, developers will be required to install additional gigabit-ready physical infrastructure alongside the physical infrastructure required for the next best technology connection.
The Scottish Government recognises the additional costs and challenges of deploying in rural areas and that some new build homes in these areas may not obtain a gigabit-capable connection. These proposals have therefore been designed to work in conjunction with other programmes designed to boost rural connectivity. This includes the £5 billion funding for Project Gigabit which will ensure premises in the hardest to reach parts of the UK get gigabit-capable connections.
The Scottish Government recognises that in some cases the costs of installing connections may be prohibitive. As the majority of the costs associated with connectivity relate to connecting a dwelling to an operator’s network (in line with the second requirement), a £2,000 cost cap is to be applied to this requirement. A developer will be exempted from the connectivity requirement, if having engaged two suitable network operators, the developer has not been able to secure the provision of a connection without exceeding a cost cap of £2,000 per dwelling.
Should the costs of a gigabit connection or next best technology connection exceed the cap, a developer will still be required to ensure that the first requirement (i.e. installation of the gigabit-ready physical infrastructure necessary for gigabit-capable connections, is met).
Scope of the new requirements - new build homes
It is proposed that the new requirements under The Building (Scotland) Regulations 2004 will apply to new build homes, that is, the construction of a self-contained building or part of a building to be used as a new residential dwelling. This includes the following forms of buildings:
- domestic buildings (those comprising dwellings and common areas)
- mixed-use (applying to the part of the mixed-use development which is comprised of dwellings)
- dwellings created from a material change of use (conversion) from an existing building
The requirements will apply to new build homes because they will apply to each dwelling or building containing one or more dwellings for which a building warrant application has been submitted, including buildings undergoing conversion to create one or more dwellings.
Any of these forms of new build home developments within conservation areas will also be included within scope of proposals. There is no automatic restriction on installing broadband infrastructure in new or converted buildings in designated conservation areas, and restrictions in such areas are subject to huge variation and considered by local planning authorities on a case-by-case basis. Therefore, to have a blanket exemption on new build homes in conservation areas would needlessly exclude some new build homes from having gigabit-ready physical infrastructure installed.
Buildings occupied by the Ministry of Defence or the armed forces of the Crown, or otherwise occupied for purposes connected to national security are explicitly excluded from the scope of the requirements under The Building (Scotland) Act 2003 (Exemptions for Defence and National Security) Order 2009.
Material change of use or ‘conversions’ resulting in creation of one or more dwellings
In this context, a material change of use or ‘conversion’ as defined under regulation 4 and schedule 2 of the building regulations includes work which forms a new dwelling (type 1 or type 3 conversions). This includes changing non-dwellings into dwellings and where more or fewer dwellings are created within an existing building, such as where a house is converted to multiple flats or a block of flats converted to a single house. We understand these forms of works are undertaken by a range of small and medium enterprises (SMEs) and large development firms.
Such conversions are required to meet current building regulations, including the mandatory standards, either in full or as far as is ‘reasonably practicable’. Current provisions under standard 4.14 for in-building physical infrastructure are to be met as far as is ‘reasonably practicable’. To ensure this proportion of new housing stock is furnished with gigabit-ready infrastructure and gigabit-capable connectivity, allowing consumers to take advantage of the benefits, we propose to apply the requirements of the new provisions being added within Schedule 2 to the Building (Scotland) Regulations 2004 to new build homes developed through building conversion. We are keen to ensure that the proposals are workable for these developments.
8. Is the Universal Service Obligation an appropriate reference point for lower speed services?
9. The proposals provide no exemptions for developments within conservation areas. Do you agree with this?
10. Are there any other exemptions that should be considered?
11. Do you agree that a material change of use or ‘conversions’ should be included in the scope of the proposals?
Suitable network operators
The cost cap exclusion will only be applicable where the developer having approached two suitable network operators for quotes is declined a connection without exceeding the cap. What constitutes a suitable network operator will vary depending on the development circumstances, but a developer will need to consider which network operators appear to be among those more likely to be able to provide a connection. Examples of factors to take into account include:
- the development location
- the ability of a network operator to provide a suitable connection in the location
- existing network operators in the location
- network operator development plans
- other network operators who could deploy in the area
Where a network operator is not currently operating in or near the location and does not have plans to deploy in the location, they are less likely to be able to provide a connection. Should a suitable network operator not respond to a developer within a reasonable time period, this will amount to being refused a connection. Further information as to what constitutes an appropriate network operator is set out in the Technical Handbook. Further support will be provided to stakeholders, to assist them on what constitutes a suitable network operator.
Network operator commitments
To ensure that the costs for developers are minimal and do not exceed the cost cap, the UK Government have secured commitments from network operators who are to contribute towards the costs incurred under the cap. These commitments (Correspondence: New Build Developments: Delivering gigabit-capable connections) include, subject to certain requirements:
- a Virgin Media contribution of at least £500, rising in the case of some larger sites to £1,000
- an Openreach and Developer combined Contribution of £3,400, with a maximum developer contribution per plot of £2,000
- additionally, Openreach has committed that when new build homes cannot be provided with a gigabit-capable connection within the cost cap and contribution, it will fall back on offering to provide the next best alternative, depending on available infrastructure
- Openreach has published a price structure that reduces the costs developers pay for connecting two premise developments from £3,100 to £2,000 per premise, bringing all developments of two premises or more within our proposed cost cap
- Openreach also committed to connect full fibre infrastructure free from developer contributions for all new build development sites of 20 or more premises, reducing this from its previous offer of 30 or more premises
- a Gigaclear contribution of up to £1,000 per new build property (providing Gigaclear can carry out infrastructure work at the appropriate stage)
While these commitments were made to the UK Government and as telecommunications is a non-devolved policy area, we would expect the commitments to apply equally in Scotland.
Cost cap calculation
In assessing if the cost cap is to be exceeded, a developer will take account of the costs quoted by a network operator minus any financial contribution from the network operator. The calculation of the cost to the developer is to include value added tax but will exclude:
- the cost of installing gigabit-ready physical infrastructure
- administrative expenditure incurred by the developer
- the cost to consumers for the provision of a service
12. Do you envisage any problems with the requirement to approach two suitable network operators for a quote?
13. Please give your views on the criteria for defining a suitable network operator.
14. Is £2,000 the right amount for the cost cap given the higher costs of delivering gigabit-capable broadband in Scotland?
15. Do you agree with the criteria for calculating the cost cap?
Process and procedure
The aim of the new policy is to ensure the process for installing gigabit-capable broadband is as simple as possible for developers, mirroring as it does the process to evidence compliance with other Building (Scotland) Regulations 2004 requirements.
To ensure that the requirements can be met, developers are encouraged to engage with network operators at the earliest point to ensure a new build home development can be furnished with connectivity efficiently. This early engagement with appropriate network operators will also enable confirmation of the particulars related to connectivity and compliance for building control.
For building control purposes, a developer will be required to submit a ‘connectivity plan’ with full plan applications, initial notices or amendment notices provided to a local authority (either directly or through an AI). To ensure that connectivity is considered for all new build homes, the legislation will extend connectivity plan requirements to initial notices and amendment notices.
A proposed model connectivity plan is included in the guidance supporting the new provisions of the Building (Scotland) Regulations 2004. The information that will need to be provided includes:
- the quotes received from network operators to provide connections, and evidence of a network operator being contracted to provide connections to the dwellings in question,
- that the gigabit-ready physical infrastructure necessary for gigabit-capable connections is to be installed,
- that the suitable installation of a gigabit-capable connection has been arranged with a network operator and the nature of the network to be deployed,
- in the absence of a gigabit-capable connection, any exemption or exclusion being relied upon, providing evidence towards applicability,
- in the absence of a gigabit-capable connection, the form of the next best technology connection being installed within the cost cap.
The building warrant and construction process and connectivity plans
In line with existing practice, a building warrant is issued by the local authority verifier once they are satisfied that the construction work set out in the application for building warrant will meet building regulations. It is then the responsibility of the applicant to ensure that the construction work undertaken is in accordance with the issued building warrant and The Building (Scotland) Regulations 2004. A statement on compliance (the completion certificate) provided by the applicant on completion of building works will confirm the works comply with the Building (Scotland) Regulations 2004, including the new gigabit requirements.
The new requirements do not impinge on the arrangements between developers and network operators. However, should a network operator not meet the terms of an arrangement with a developer, this will be recorded in the connectivity plan as a relevant consideration for the applicant and the building standards verifiers in determining the works required to comply with the regulations prior to the issue of a building warrant..
The proposals extend the provisions of standard 4.14 to include on-site physical infrastructure and a means of connection to a network. Once the extents of these elements are confirmed and included in the issued building warrant, it is the responsibility of the applicant to complete the works in accordance with the agreed provisions.
The new requirements for developers will be enforced using the existing Building Standards verification and enforcement regime. This system is well established and sufficient for the new requirements, with key information on proposals recorded in the connectivity plan.
16. Do you have any concerns about extending the requirement for a connectivity plan to initial notices and amendment notices?
17. Do you have views on how inspection of the new physical infrastructure elements beyond in-building infrastructure to a network distribution point should be undertaken?
Guidance (Technical Standard 4.14)
The Building (Scotland) Regulations 2004 include, under schedule 5 to regulation 9, a schedule of functional requirements that must be complied with when building work is carried out. The government publishes Technical Handbooks, under powers contained in the Building (Scotland) Act 2003 (section 4). More information on the regulations and guidance can be found at www.gov.scot/policies/building-standards.
To accompany our proposed amendments to the Building (Scotland) Regulations 2004, we plan to updated the related guidance to Standard 4.14 of Technical Handbook. The Technical Handbook will also aid monitoring and enforcement by local authority building standards verifiers.
New provisions and statutory guidance
It is proposed that the new provisions within the Building (Scotland) Regulations 2004 will be further broken down into requirements for gigabit-ready physical infrastructure, common access points for buildings containing multiple dwellings and connection to a gigabit-capable electronic communications network, and this will be reflected in the updated Technical Handbook Standard 4.14.
It should be noted that the requirements of the Building (Scotland) Regulations 2004 and guidance the Technical Handbooks is performance-based and technology neutral. There is no single industry standard and it would not be appropriate to cite any particular network operator’s specifications for gigabit-capable infrastructure. Advice is offered on the design and specification of passive infrastructure and the recommendation that the specification is agreed with the successful network operator. This approach ensures that potential future developments in technology are not excluded.
Practical guidance for developers
A draft of the proposed updated Standard 4.14 can be seen attached to the consultation. The proposed amended Standard 4.14 is drafted in the context of the guidance contained within the Domestic Technical Handbook, however it is helpful to note the non-domestic handbook would also be updated to reflect relevant changes to the functional standard and any revision of terminology relating to in-building physical infrastructure. Within the equivalent non-domestic text, which would exclude clauses 4.14.2 to 4.14.4, reference would be made to ‘building units’ instead of ‘dwellings.
18. Do you have any specific comments on the content of the updated edition of Standard 4.14, for example references to external guidance?
19. Do you agree with proposals to refer to Scottish Road Works Commissioner’s and Streetworks UK guidance for external gigabit-ready physical infrastructure in the Technical Handbook?
20. Do you agree with proposals and guidance for network termination points and the inclusion of best practice advice to improve connectivity within the individual dwelling?
21. Do you agree with proposals to include a two-part model form for the connectivity plan with the revised Standard 4.14?
22. If you have any further comments to make regarding the proposals please set them out here.
23. Please provide any feedback you have on the impact assessment here.
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