Scottish 4G Infill Programme consultation: information request

This public consultation seeks to expand the intervention area of the S4GI

programme from the initial 16 sites; it also sets out our selection criteria.

Purpose of this Consultation

This public consultation seeks to expand the intervention area of the S4GI programme from the initial 16 sites. To enable this, 100 potential areas of interest have been identified. SG and SFT wish to test these potential locations and their applicability for the programme to enable the £25 million available funding to be maximised, whilst adhering to geographic spend restrictions associated with the ERDF-funded and match-funded elements of the funding.

This consultation also serves to ensure compliance with the European Commission’s Broadband Guidelines. These are EU Guidelines [1] which set out how governments should apply the European Commission’s State Aid rules in relation to the deployment of broadband networks. For these purposes, 4G LTE is classified as a next generation access ( NGA) broadband service. The objective of the S4GI programme is to provide access to mobile NGA infrastructure which is capable of delivering 4G LTE services.

EU regulations are designed to ensure that any use of public funding (‘State Aid’) is targeted at areas of market failure and produces positive market outcomes while minimising any distortion to competition. The State Aid rules require public interventions to be targeted so as to limit the risk of crowding-out or disincentivising existing and/or concrete planned private sector investments that would otherwise meet the desired policy objectives. In the context of broadband, the General Block Exemption Regulations permit the use of public funding only to extend broadband coverage in geographic areas where there is no provision of basic broadband or NGA broadband service or network and it is unlikely to be developed in the near future (within the next three years).

In accordance with this requirement, SG is holding a public consultation through publication of this consultation document on its website.


To ensure the success of the programme, engagement and consultation will help make our overall strategy and performance more effective. We will do this by consulting about our intentions and others’ views. We will gather feedback and analyse the results of the consultation, report on the results, and use this to inform our planning and priority setting.

1. Principles

The following principles will underpin all engagement activity. Engagement activity will:

  • be proportionate both for the group being consulted and to the purpose of the engagement.
  • be open, transparent and focused, being clear how their views will be used and what they may influence.
  • be consistent and joined up ensuring no group has undue influence or access, but that engagement is tailored to the commitments and interests of the audience.
  • support and promote improvement by sharing findings with key stakeholders e.g. partners, colleagues and wider Government departments.
  • be accountable and cost effective, using the necessary resources and time to make a difference, and properly evaluate findings.

2. Levels of Engagement

We will engage with interested parties at the appropriate level, in appropriate ways and at appropriate times. The ways we engage with users, stakeholders and interested parties will depend on what we are trying to achieve. Engagement will operate at a number of levels:

  • information – providing information about the service (including information about how to engage with services locally) and future changes to the way the service operates.
  • consultation – seeking opinions about areas of our work and about the services we provide.
  • involvement – engaging customers and corporate partners in becoming part of the solution by listening to their views and supporting them to bring about improvement.

In all of our engagement with users, stakeholders and interested parties, we will be clear about what we want to achieve and ensure that the means of engagement is designed to achieve that objective. We will tailor our engagement activities and use appropriate methods and will be mindful of the context from the external perspective. Annex A outlines the likely levels and basis of engagement in relation to the programme.

S4GI – Progress to Date

SG and SFT conducted a public consultation on a proposed initial intervention area in August 2017 [2] . This elicited 16 initial locations which formed the basis of a procurement process which ran from March-June 2018, the purpose of which, was to identify an infrastructure provider for the S4GI programme. The procurement has concluded and the contract was awarded to WHP Telecoms Ltd in July 2018. WHP will be responsible for subsequent mast build ownership, operation and maintenance – and will deliver mobile services in partnership with a mobile network operator or operators.

All infrastructure built through the programme will be open access, future-proofed, be connected to backhaul capable of delivering 4G LTE services and be upgradable to 5G. Mast build will also be dependent of the commitment from at least one MNO to provide 4G LTE services at each location. The S4GI programme has now entered its delivery phase.

The S4GI programme will not deliver a service to all mobile notspots in Scotland – for the available funding we estimate that mobile services to around 50-60 locations in total could potentially be delivered by the programme, over the course of the four years until 2021/2022.

Expanding the Intervention Area – Selection of Areas of Interest

To expand the intervention area, SG and SFT needs to understand what complete notspots will remain after commercial rollout by the UK’s four main mobile network operators ( MNOs) is complete.

This programme is solely targeting complete notspots – that is, areas where there is no coverage from any MNO. Any location which has coverage from one, two or three – but not all MNOs – is outwith the programme’s scope.

We have identified 100 areas of interest for potential inclusion in the programme. However not all of these will ultimately be included in the programme as we don’t believe that the available funding will allow us to build more than 50-60 mast locations in total.

These locations have been derived through a process which, in the first instance, sought to identify 4G notspot locations identified from the best information available to SFT and SG; these include datasets from Ofcom and other UK Government programmes. These locations were then analysed against the following criteria:

1. Premises and associated population coverage uplift
2. Transport (road and rail) coverage uplift
3. Key tourism site coverage uplift
4. Geographic coverage uplift

We have selected the top 100 locations from the resulting analysis as our potential areas of interest for the programme. These are shown on the map at Annex B, and in more detail at Annexes E - M. Grid References are presented in the table at Annex D.

For any of these areas of interest to subsequently be incorporated into the programme and progress build phase will require the following items to be achieved and for costs to be within £500,000 per location:

1. Anchor tenancy from at least one MNO (i.e. commitment to provide 4G services from that mast)
2. Landlord agreement
3. Planning permission
4. Power connectivity
5. Network Connectivity

Achievement of items 1-3 are mandatory. Achievement of items 4-5 will be subject to costs and could influence whether an area is viable or not.

If an area of interest meets the requirements above, subject to funding availability, it would be our intention to include it in the programme. It is important to note that through this consultation and engagement with industry and the regulator, the areas of interest may change. The presence of location in the list of 100 sites does not guarantee that it will be included in the programme. Conversely, the absence of an area does not necessarily mean it would be excluded from the programme, if it can be evidenced that it meets the eligibility criteria outlined above.

We now seek views from those who may be able to support the provision of this network infrastructure in the target areas. This could be through ownership of specific telecommunications infrastructure or have plans to build such infrastructure. Also, we seek input from wider stakeholders such as local authorities on the potential intervention area.


This consultation will run for 4 weeks from 10 September 2018 to 8 October 2018.


Email: Gareth Wells

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