Research and analysis

Appendix 1. Method for contribution analysis

Published 10 September 2026

1. Approach to contribution analysis

1.1 Rationale for using contribution analysis

Contribution analysis was selected as the primary methodological approach for this work package because it provides a structured way to assess the extent to which the Local Full Fibre Networks (LFFN) programme influenced market outcomes in an environment characterised by multiple interacting factors. In such a context, isolating the specific effects of a single intervention is challenging.

Contribution analysis offers a suitable approach by examining whether the observed changes are consistent with LFFN’s theory of change, assessing the plausibility of the programme’s influence, and weighing this against alternative explanations. Rather than attempting to establish direct attribution, the method focuses on understanding the contribution that LFFN made to market developments and on assessing the strength of evidence for this contribution.

1.2 Contribution claims

To guide the analysis, a set of contribution claims was developed, each linked directly to the programme’s theory of change and representing a specific pathway through which LFFN may have influenced the market. These claims are:

• Claim 1: LFFN funding enabled new suppliers to enter local broadband markets by reducing risks and barriers to entry, and making entry more viable.

• Claim 2: LFFN enabled suppliers to expand their network coverage and investment at a greater scale or speed than they would have otherwise.

• Claim 3: LFFN contributed to the growth and financial stability of alternative network providers (alt-nets) by enabling them to expand their customer base and revenue streams in project areas.

• Claim 4: LFFN acted as a market signal, influencing broadband operators to modify their strategic investment decisions by accelerating, expanding, or reprioritising their network expansion plans.

• Claim 5: LFFN enabled smaller broadband providers to attract private investment for expansion by increasing their market credibility and lowering perceived investment risk.

• Claim 6: LFFN increased competition in local broadband markets, prompting traditional providers (e.g. Openreach and Virgin Media) to respond by accelerating their fibre rollout or upgrading their networks.

• Claim 7: LFFN increased competition and choices of packages in local broadband markets by enabling more Internet Service Providers (ISPs) to offer services over gigabit-capable networks.

• Claim 8: LFFN influenced broadband pricing by increasing competition in local markets, leading to reductions in the cost of broadband subscriptions.

These claims provide the structure for the evaluation, enabling a systematic assessment of the strength and nature of LFFN’s contribution across different aspects of market behaviour and outcomes.

1.3 Contribution categories and evidence tests

A set of contribution categories was first defined and agreed with BDUK to provide a consistent basis for assessing the strength of LFFN’s influence. These categories range from primary contribution, where LFFN was a major driver of the observed change, through substantial, enabling and marginal contributions, to no observable contribution.

Once these categories were established, evidence tests were developed for each claim to specify the types and combinations of evidence required for a claim to be judged as falling within each category. This ensured a transparent and consistent assessment framework, allowing the evaluation to identify where the available evidence strongly supported a contribution, where it was mixed, and where alternative explanations were more plausible. The full set of contribution categories and evidence tests is provided below.

1.4 Sources of evidence

The contribution analysis draws on a wide range of qualitative and quantitative evidence. Key sources included:

• Qualitative interviews with suppliers and other stakeholders, providing insights into commercial decision-making and the role of LFFN in influencing investment, market entry and supplier growth.

• Market data from Point Topic, used to assess changes in full-fibre and gigabit-capable coverage of suppliers, choice of operators and broadband pricing in LFFN project areas.

• Supplier coverage maps from ThinkBroadband

• Company financial data from Companies House, used to examine changes in turnover, profitability and investment patterns among participating suppliers.

• Ofcom’s Connected Nations reports and other published sources, providing nationally consistent data on broadband availability, network build and market trends.

2. Contribution analysis framework

This section sets out the contribution claims, evidence tests, and data sources for assessing the impact of LFFN under work package one. The contribution claims have been developed in alignment with the theory of change, ensuring a structured approach to assessing how LFFN influenced supplier market entry, network expansion, competition, investment confidence, and consumer outcomes.

Each contribution claim is accompanied by:

• Outcome indicators that define measurable changes expected as a result of LFFN.

• Preconditions that must be met for the claim to be tested robustly.

• A framework for assessing attribution, determining the extent to which LFFN played a role.

• Key evidence requirements, specifying what data is needed to validate each claim.

• Potential evidence sources and an assessment of the challenges/limitations in accessing this data.

2.1 Limitations and Evidence Gaps

It is recognised that not all evidence required for testing the contribution claims may be accessible. In cases where data is unavailable or stakeholders are unwilling to engage, we will:

• Assemble the best available evidence from alternative sources.

• Identify gaps and highlight their implications for the robustness of conclusions.

• Consider the strength of causal inference, ensuring that conclusions reflect the certainty of the evidence base.

3. Contribution claims

3.1 Claim 1: LFFN funding enabled new suppliers to enter local broadband markets by reducing risks and barriers to entry, and making entry more viable

Outcome indicator

• LFFN supplier operating in a local market area where it was not previously active

Preconditions for assessing claim

• LFFN contract must have been awarded to a supplier who was not previously active in the local area, or

• LFFN infrastructure is being used by a supplier who was not previously active in the local area

Contribution categories and evidence requirements

Contribution category	Definition	Evidence requirements
Primary contribution	The supplier would not have entered the market without LFFN in the foreseeable future. Securing the LFFN contract made market entry commercially viable	• Supplier had no pre-existing plans to enter the market before securing the LFFN contract • Supplier would not have entered local market without the LFFN contract, or suggests that future entry would have been subject to a substantial change in market conditions • Supplier indicates there were substantial barriers to expansion within the local area (no independent backhaul to internet exchange, physical geography, overall cost, poor ROI for private investment), which LFFN funding helped to overcome. • Alternative factors (e.g. regulatory changes or private investment) influencing their decision may be acknowledged, but would have been insufficient for them to enter the market without LFFN
Substantial contribution	The supplier was considering market entry, but LFFN enabled them to enter earlier or on a larger scale than originally planned.	• Supplier had some prior interest or tentative plans to enter, but securing the LFFN contract made it happen earlier • Supplier states LFFN de-risked the business case, allowing for faster or larger scale deployment • Supplier acknowledges barriers existed, and while these could potentially have been overcome, LFFN accelerated or de-risked the process substantially • Supplier states LFFN was a key driver for entering market when they did, but acknowledges other factors as important
Enabling contribution	The supplier would have entered anyway, but LFFN reduced risk or improved viability	• Supplier states market entry was planned before LFFN • Supplier states that LFFN lowered costs or reduced barriers, but confirms they would have proceeded regardless. • Supplier states that LFFN had small benefits in terms of scale or timing of deployment • Supplier states the decision to enter the market was primarily driven by other factors, but LFFN reinforced this
Marginal contribution	The supplier was already committed to entering, and LFFN played only a minor role.	• Market entry was already fully planned and funded before LFFN. • Supplier indicates LFFN was useful but not influential on their decision making – other factors were of far greater importance • Supplier notes that barriers were low or already being addressed through other means, and LFFN played only a minor role in addressing them. • No major difference in timing, scale, or decision-making due to LFFN
No contribution	The supplier’s market entry was completely independent of LFFN.	• Market entry was fully planned and funded, and supplier states LFFN had no impact on their decision whatsoever

Possible evidence sources and challenges

Evidence source	Purpose	Challenges / limitations
Interviews with LFFN  suppliers	Insights on their factors that influenced their decision to enter local market areas and the relative importance of LFFN and other factors	• Securing interviews with senior decision-makers from suppliers may be challenging • Some senior decision makers may underplay the role of LFFN in their decision making
Open Market Review (OMR)	Exploring whether the supplier had any pre-existing plans to enter the market before LFFN, and the scale/timing of those plans	• Very limited longitudinal data dating back to the start of LFFN, so it is unlikely that we could use this to analyse pre-LFFN plans • Restrictions on access

3.2 Claim 2: LFFN enabled suppliers to expand their network coverage and investment at a greater scale or speed than they would have otherwise

Outcome indicator

• Increased local coverage of gigabit capable networks by the LFFN supplier

Preconditions for assessing claim

• Evidence of suppliers present before LFFN then expanding their fibre coverage after receiving the LFFN contract.

Contribution categories and evidence tests

Contribution category	Definition	Evidence requirements
Primary contribution	The supplier would not have expanded fibre coverage without LFFN in the foreseeable future. The LFFN contract was necessary to make further expansion viable	• Supplier had no prior fibre network expansion plans in the area prior to award of LFFN contract • Supplier confirms they would not have expanded in this area without LFFN contract, or that future expansion would have been severely delayed or subject to a substantial change in market conditions • Supplier indicates that there were substantial barriers to expansion within the local area (physical geography, distance from existing network raising overall cost/poor ROI for private investment), which LFFN funding helped to directly overcome. • Alternative factors (e.g. regulatory changes or private investment) influencing their decision to expand may be acknowledged, but would have been insufficient on their own for them to expand
Substantial contribution	The supplier was considering expansion, but LFFN allowed for a much larger rollout or a faster deployment than otherwise planned.	• Supplier states they intended to expand in the area but there was no prior evidence before LFFN, or plans were on a smaller scale or for a later date • Supplier confirms LFFN enabled a wider fibre network expansion or earlier timeline than originally planned • Supplier states that while barriers to expansion were not insurmountable, LFFN substantially reduced financial risk or improved ROI • Supplier states LFFN was a key driver for expansion, but acknowledges other factors as important
Enabling contribution	The supplier would have expanded anyway, but LFFN reduced financial risk, made deployment easier, or improved technical viability	• Supplier states network expansion was planned before LFFN • Supplier states that LFFN lowered costs or improved the commercial case, but they would have proceeded regardless • Supplier states there may have been some added benefits from LFFN, in terms of scale or timing of expansion, but these would have been small. • Supplier states the decision to expand was primarily driven by other factors, but LFFN reinforced this
Marginal contribution	The supplier was already committed to expansion, and LFFN played only a minor role in decision-making.	• Network expansion was fully planned and funded before LFFN contract was awarded • Supplier indicates LFFN was useful but not influential on their decision to expand – other factors were of far greater importance • No major difference in timing, scale, or decision-making due to LFFN
No contribution	The supplier’s expansion was already happening and was entirely independent of LFFN.	• Network expansion was either already in progress or at an advanced stage when the LFFN contract was secured • Supplier states LFFN did not influence their investment or rollout decisions in any way
Negative contribution	The supplier was unable or unwilling to expand in the local area as a result of LFFN.	• Red tape made build challenging • Damage to local reputation by slow build/delays/roadworks •Easier to expand in other areas due to greater freedom

Evidence sources and challenges

Evidence source	Purpose	Challenges / limitations
Interviews with LFFN  suppliers	Insights on their factors that influenced their rollout decision and the relative importance of LFFN and other factors	• Securing interviews with senior decision-makers from suppliers may be challenging • Some senior decision makers may underplay the role of LFFN in their decision making
Open Market Review (OMR)	Exploring whether the supplier had any pre-existing plans to expand coverage before LFFN, and the scale/timing of those plans	• Very limited longitudinal data dating back to the start of LFFN, so it is unlikely that we could use this to analyse pre-LFFN plans • Restrictions on access

3.3 Claim 3: LFFN contributed to the growth and financial stability of alternative network providers (alt-nets) by enabling them to expand their customer base and revenue streams in project areas

Outcome indicators

• Increased annual turnover in alt-nets that secured LFFN contracts

• Sustained business operations, with no signs of financial distress

Preconditions for assessing claim

• An alt-net must have secured the LFFN contract and still be operating

• Company accounts must show increased turnover following award, and ideally be profitable

Contribution categories and evidence tests

Contribution category	Definition	Evidence requirements
Primary contribution	The LFFN contract was critical to securing revenues and ensuring the viability of the business	•Supplier states LFFN was necessary for financial survival or long-term stability of the business, or that LFFN resulted in a fundamental shift in their financial trajectory • Supplier confirms that the customers gained as a direct or indirect result of their LFFN contract were the primary driver of revenue growth in the years that followed • Alternative factors (e.g. regulatory changes or private investment) are either not cited as a key factor influencing turnover growth, or are described as secondary in importance
Substantial contribution	LFFN was a key driver of turnover growth, but other market factors also contributed to improved financial performance	• Supplier states LFFN was one of the key factors in their turnover growth, and it would have taken much longer to achieve otherwise • Supplier states LFFN enabled them to expand faster, leading to substantial increases in turnover • Alternative factors are also identified as key factors influencing turnover growth and financial performance
Enabling contribution	LFFN helped improve financial performance/turnover growth, but the supplier would likely have increased turnover even without it.	• Turnover increased after LFFN, some of which may be attributable to LFFN, but the supplier states the majority of growth was due to other factors • Supplier reports that most growth in turnover was due to pre-existing expansion plans which were only marginally affected by the LFFN contract • Supplier may state that LFFN helped de-risk their expansion plans, which supported growth in turnover
Marginal contribution	The supplier’s growth in turnover was primarily driven by other factors, with only a minor influence from LFFN.	• Supplier believes they would have achieved similar growth in turnover without LFFN • Supplier states LFFN was positive, but other factors were of far greater importance in explaining recent financial performance • Supplier may acknowledge small benefits such as minor operational efficiencies as a result of LFFN
No contribution	The supplier’s financial performance/turnover was unaffected by LFFN - growth occurred independently	• Supplier explicitly states that LFFN had no impact on their customer growth or revenues, and this is all explained by other factors

Evidence sources and challenges

Evidence source	Purpose	Challenges / limitations
Interviews with alt-nets	Insights on the factors that influenced financial performance and change in turnover, and the relative importance of LFFN	• Securing interviews with senior decision-makers from suppliers may be challenging • Some senior decision makers may underplay the role of LFFN in their decision making
Financial accounts	Assessing change in turnover and other financial indicators in the period before and since LFFN contract	• Not all company accounts show turnover, but this can be estimated using other information available for the business

3.4 Claim 4: LFFN acted as a market signal, influencing broadband operators to modify their strategic investment decisions by accelerating, expanding, or reprioritising their network expansion plans

Outcome indicator

• Changes in strategic expansion plans or new investment announcements by broadband operators (e.g. CityFibre increasing the number of planned cities from 50 to 100)

Preconditions for assessing claim

• Supplier must have announced a larger, accelerated or more ambitious network expansion plan or strategy following LFFN implementation

Contribution categories

Contribution category	Definition	Evidence requirements
Strategic contribution	LFFN funding acted as a clear market signal, which improved investor confidence. This was an important factor influencing suppliers decisions to scale up their investment plans or increase the pace of rollout	• Suppliers confirm that LFFN improved confidence and/or made their investment case more secure, allowing them to scale up or accelerate their plans, or focusing their future plans on fibre vs other >superfast technologies. • Industry analysts believe LFFN played a substantial role in shaping market confidence, leading to increased investment activity or accelerated rollout strategies • Market reports from the time cite LFFN as a key driver influencing market confidence and/or suppliers investment decisions
Supporting contribution	LFFN was not a key reason for increased investment or changes to strategies, but it reinforced confidence and de-risked decisions that were already under consideration.	• Suppliers were planning investment but LFFN did lead to some change to their overall strategy by providing additional reassurance, reducing risk, and may have influenced minor adjustments. • Industry analysts acknowledge LFFN as a positive signal that reinforced supplier confidence, but believe investment decisions were primarily driven by other factors. • Market reports from the time mention LFFN as a positive but not key factor affecting market confidence or suppliers plans
Marginal contribution	Suppliers were aware of LFFN, but it had little impact on their investment plans or strategies	• Suppliers report they were already planning investment, and LFFN played only a minor role in their decision-making. LFFN may have been noted in strategy discussions, but it did not impact the scale, timing, or risk assessment of their investment. • Industry analysts acknowledge LFFN could have affected market confidence, but believe its influence was limited • Market reports from the time mention LFFN in passing or as a minor factor, with little evidence that it had a meaningful impact on market confidence or suppliers' plans.
No contribution	LFFN had no bearing on supplier investment plans, and their decisions were entirely independent of the programme.	• Supplier confirms that LFFN was not a factor in their investment planning. • Industry analysts report no evidence that LFFN influenced supplier investment decisions or market confidence • No mention of LFFN in market reports as a factor influencing market confidence
Negative Contribution	LFFN projects actively discouraged competition in their areas due to the perception that suppliers would gain greater control, thereby reducing ROI/commercial viability for investment	• Supplier discusses how LFFN projects dissuaded them from investing in a certain area/areas they had previously committed to, due to contracts being awarded to other suppliers.

Evidence sources and challenges

Evidence source	Purpose	Challenges / limitations
Interviews with suppliers	Understand if LFFN influenced investment decisions, market confidence, or expansion plans	• Securing interviews with senior decision-makers from suppliers may be challenging • Some senior decision makers may underplay the role of LFFN in their investment strategies
Interviews with industry analysts	Assess market-wide perceptions of LFFN’s impact on investment confidence and supplier strategies.	• Limited pool of experts with the required level of market insight • Analysts may be reluctant to engage or have no incentive to participate • Potentially a risk of bias depending on the industry expert and their role/relationships in the market
Operator investment plans	Identify whether suppliers increased investment, changed rollout timelines, or scaled up due to LFFN.	• Internal documents unlikely to be available, and may lack clear attribution to LFFN
Market reports	Provide independent evidence of LFFN’s role in shaping industry confidence and supplier behaviour.	• May not explicitly reference LFFN, making it difficult to isolate its influence.

3.5 Claim 5: LFFN enabled smaller broadband providers to attract private investment for expansion by increasing their market credibility and lowering perceived investment risk

Outcome indicator

• Alt-nets successfully attract private investment (equity or debt financing) for expansion

Preconditions for assessing claim

• Evidence that smaller broadband providers have attracted investment following the award of LFFN contract (based on supplier testimony, company accounts or statements)

Contribution categories and evidence requirements

Contribution category	Definition	Evidence requirements
Primary contribution	LFFN was the decisive factor in securing private investment - without it, the provider would not have been able to raise funds.	• Supplier indicates LFFN played a decisive role in securing specific investment opportunities investment / without LFFN, it is unlikely these investment opportunities would have been secured • Investor reports that the supplier being awarded the LFFN contract was a key reason for investment • Evidence from other sources (investment documents, industry analysts, market reports) indicating LFFN was a critical factor enabling suppliers to attract investment
Substantial contribution	LFFN was an important factor, but other factors (e.g. general market conditions, prior financial performance) also contributed to raising investment	• Supplier reports LFFN helped strengthen its investment case, reducing concerns of investors / It would have been harder but not impossible to raise finance without LFFN • Investors acknowledge LFFN improved confidence in the supplier but was not the only reason for investment • Evidence from other sources suggest LFFN was an important factor affecting investor confidence
Enabling contribution	LFFN reinforced investor confidence, but the supplier was likely to attract investment anyway	• Supplier believes they would have attracted investment regardless, but LFFN brought some benefits (e.g. faster investment decisions, improved financing terms, enhanced profile) • Investors confirm they would have invested regardless, but LFFN provided additional reassurance. • Evidence from other sources reference LFFN as a supporting but not essential factor in enabling smaller suppliers to raise finance
Marginal contribution	The supplier secured investment primarily due to other factors, with LFFN playing only a minor role	• Supplier believes LFFN had a negligible impact on their success / investment was already in progress before LFFN involvement / no noticeable improvement in investor terms linked to LFFN • Investors may acknowledge LFFN but state that it was not a factor in their decision making • Other evidence sources may mention LFFN, but indicate that increased investment was primarily due to other market trends
No contribution	Investment was secured entirely independently of LFFN, with no link between the programme and investor decisions	• Suppliers state their ability to attract investment was unaffected by LFFN • Investors confirm LFFN played no role in their decision. • Market reports do not mention LFFN • Industry analysts believe LFFN had no effect on suppliers ability to raise investment

Evidence sources and challenges

Evidence source	Purpose	Challenges / limitations
Interviews with suppliers	Understand whether securing an LFFN contract influenced their ability to attract private investment (e.g. improved credibility, reduced risk perception)	• Securing interviews with senior decision-makers from suppliers may be challenging • Some senior decision makers may underplay the role of LFFN in their success
Interviews with investors/lenders	Understand whether suppliers being awarded LFFN contracts affected their investor confidence or their decision making	• Securing interviews with investors would be VERY difficult • Investors may be reluctant to disclose full decision-making rationale or understate the role of LFFN
Interviews with industry analysts	Assess market-wide perceptions of LFFN’s impact on investment confidence and gather anecdotal evidence about specific suppliers ability to raise finance	• Limited pool of experts with the required level of market insight • Analysts may be reluctant to engage or have no incentive to participate • Potentially a risk of bias depending on the industry expert and their role/relationships in the market
Supplier business plans and investment proposals	Check whether LFFN was highlighted as a key asset in plans or proposals	• Internal documents unlikely to be available, and may not explicitly reference LFFN, making it harder to assess its influence
Market reports	Gather independent evidence of the factors affecting investment trends and market confidence, and the role of LFFN	• May not explicitly reference LFFN, making it difficult to isolate its influence. • Reports are likely to focus on industry wide trends and therefore unlikely to provide supplier specific insights

3.6 Claim 6: LFFN increased competition in local broadband markets, prompting traditional providers (e.g. Openreach and Virgin Media) to respond by accelerating their fibre rollout or upgrading their networks.

Outcome indicator

• Changes in rollout scale or speed by traditional providers in areas where LFFN funded networks were introduced

Preconditions for assessing claim

• A new supplier (supported by LFFN funding) must have entered the market (see hypothesis 1) and ideally expanded its coverage (see hypothesis 2)

• Traditional providers (e.g. Openreach, Virgin Media) must have increased their gigabit coverage or implemented technical upgrades within a short time frame following the LFFN-backed alt-net’s entry / expansion

• The geographic area where traditional providers expanded must overlap substantially with the areas targeted by LFFN-supported alt-nets.

Contribution categories and evidence tests

Contribution category	Definition	Evidence requirements
Strategic contribution	LFFN-backed competition was one of the key drivers influencing the timing, scale, or focus of traditional provider investment in LFFN areas.	• Traditional providers confirm competition from LFFN suppliers changed their rollout strategies / they had no pre-existing plans to roll out FTTP coverage to LFFN areas before the programme • Evidence of a clear shift in traditional providers’ planned rollout data • Alt-nets report a clear and immediate competitive response from traditional providers after they entered the market • Other evidence that traditional providers reacted to competition by changing their roll out plans to include LFFN areas (e.g. industry analysts, market reports, press-releases)
Supporting contribution	Traditional providers were already planning investment, but LFFN provided additional justification or urgency for accelerating rollout.	• Traditional providers state there were pre-existing plans for rollout, but these were accelerated or expanded following LFFN competition, or adapted to focus on FTTP vs other technologies. • Rollout data shows some acceleration, but changes are incremental rather than transformational. • Alt-nets report a noticeable competitive response from traditional providers after they entered the market • Other evidence referencing competitive pressure from LFFN-backed alt-nets as a factor influencing the planned rollout activities by traditional providers (e.g. industry analysts, market reports)
Marginal contribution	LFFN was acknowledged, but it had little measurable impact on network rollout decisions.	• Traditional providers confirm LFFN was noted but did not substantially alter their strategy • Rollout data shows no notable differences between traditional providers before-LFFN and after-LFFN rollout plans • Alt-nets report minimal response from traditional providers after they entered the market • Other evidence (market reports, views of industry analysts) referencing LFFN backed suppliers as increasing competition for traditional providers, but suggesting this was a minor factor or has not influenced their plans
No contribution	Traditional providers’ expansion and upgrade plans were completely independent of LFFN.	• Rollout by traditional providers was all planned • Traditional providers explicitly state that LFFN had no impact on their rollout decisions. • Alt-nets report there has been no response from traditional providers since they entered the market • Industry analysts and market reports do not mention LFFN or attribute all network expansion to broader trends

Evidence sources and challenges

Evidence source	Purpose	Challenges / limitations
Interviews with traditional providers	Insights on the factors that influenced their investment decisions	• Highly unlikely that senior decision-makers would be willing to be consulted or disclose the factors affecting their investment decisions
Open Market Review (OMR)	Comparing the rollout by traditional providers to their initial plans prior to LFFN backed competition to assess whether there was a substantial change in their plans	• Very limited longitudinal data dating back to the start of LFFN, so it is unlikely that we could use this to analyse traditional providers rollout plans before and after the LFFN intervention. • Restrictions on access • A change in plans pre- and post LFFN would not be sufficient to establish causality. This would need to be triangulated with other sources
Datasets showing rollout of traditional providers (e.g. Think Broadband)	Assessing changes in network coverage of traditional providers over time, and whether this increased post LFFN (i.e. establishing change in the outcome indicator)	• Think Broadband only provides a snapshot, so we would need to purchase time series data if this was not available through other sources
Interviews with alt-nets	Capture anecdotal evidence of competitive responses from traditional providers in the areas where they have operated	• Anecdotal evidence may be biased, with alt-nets overstating their impact on traditional providers.
Press releases/public announcements	May provide statements from traditional providers indicating factors influencing network expansion	• Statements are likely to be vague and are unlikely to state competitive influences
Industry/market reports	May provide quotes relevant to whether LFFN backed competition influenced market strategies	• May provide general context but unlikely to provide the detail needed about traditional providers response to specific LFFN suppliers
Interviews with industry analysts	Capture insights into competition dynamics beyond what traditional providers may publicly disclose	• Limited pool of experts - unclear who we would speak to • May only be able to provide high-level insights. It may be very difficult for them to provide details relating to specific suppliers or LFFN projects

3.7 Claim 7: LFFN increased competition and choices of packages in local broadband markets by enabling more ISPs to offer services over gigabit-capable networks

Outcome indicators

• Increase in the number of ISPs offering services over gigabit-capable networks in LFFN-supported areas (compared to pre-LFFN levels)

• Increase in variety of broadband packages available (e.g. different speed tiers, contract options)

Framework for assessing the claim

• We do not believe a contribution analysis framework is appropriate for assessing this claim because ISP competition in the retail market is directly dependent on the availability of LFFN-funded infrastructure.
• If ISPs are using LFFN-backed networks, LFFN was a necessary condition for their market entry.
• Instead, the key attribution question is: “Did ISPs enter the market as a direct result of LFFN-funded infrastructure?” (Yes/No)

To test this, the following conditions must be met:

1. LFFN-funded supplier expanded network coverage in the local area as a result of LFFN. This depends on the evaluation findings for Claim 2 (supplier expansion). LFFN must have made a primary, substantial or enabling contribution to expanding coverage in the area. If LFFN had no impact on network expansion, it cannot have influenced ISP outcomes

2. LFFN-funded infrastructure is available for wholesale access, and multiple ISPs are using it. If the network is not available on a wholesale basis, or if there is only one ISP, there has been no change in competition or consumer choice besides the LFFN supplier

If both conditions are met, LFFN was a necessary condition for increased retail competition, and its contribution is the same as in Claim 2. If either condition is not met, LFFN did not contribute to increased ISP competition or consumer choice.

Evidence source	Purpose	Challenges / limitations
Supplier interviews	Understanding whether the infrastructure was made available for wholesale access, and which ISPs are using the network	• Securing participation of supplier
Consumer broadband comparison websites	Identifies the number of ISPs and broadband packages available in areas served by LFFN-backed networks.	• Websites may not differentiate between networks (e.g. whether an ISP is using Openreach or LFFN infrastructure) • Does not provide longitudinal data to assess change over time
Specialist data providers showing broadband package availability over time	Tracks whether ISP and package availability increased after LFFN infrastructure was deployed, showing competition growth.	• Unclear at this stage whether this is available or which data providers can provide longitudinal data • There would be a cost to accessing this data (currently unknown)

3.8 Claim 8: LFFN influenced broadband pricing by increasing competition in local markets, leading to changes in the cost of broadband subscriptions

Outcome indicators

• Monthly cost per Megabit per second (Mbps)

• Package costs at different speed thresholds (e.g. 10 Mbps, 50 Mbps, 100 Mbps etc)

Preconditions for assessing claim

• Evidence that LFFN has led to increased local competition – either because of supplier entry, expansion, or ISPs using infrastructure of LFFN suppliers

Framework for assessing impact of LFFN on broadband pricing

Scenario	Attribution to LFFN
Broadband prices dropped in LFFN areas but remained stable or higher in non LFFN areas or UK as a whole OR broadband prices fell nationwide but at a faster rate in LFFN areas	Strong evidence that LFFN drove price reductions by increasing competition
Broadband prices increased but at a lower rate than in non LFFN areas or national average	LFFN mitigated price increases, even if it did not directly lower prices.
No substantial price changes for most speed levels, but gigabit-capable packages introduced in LFFN areas are cheaper than in non-LFFN areas or UK average	LFFN influenced affordability of high-speed broadband, even if overall pricing did not change
No substantial price changes, but gigabit-capable packages became available.	LFFN expanded consumer choice, but did not lower costs.
Broadband prices changed at the same rate in LFFN and non-LFFN areas (whether increasing, decreasing, or stable).	No evidence that LFFN influenced pricing.
Broadband prices in LFFN areas were higher than in non-LFFN areas	LFFN created localised monopolies for suppliers, leading to a less competitive local market, and higher prices for consumers.

Evidence sources and challenges

Evidence source	Purpose	Challenges / limitations
Consumer broadband comparison websites	Identifying the best deals available in areas served by LFFN-backed networks.	• Websites may not differentiate between networks (e.g. whether an ISP is using Openreach or LFFN infrastructure) • Does not provide longitudinal data to assess change over time
Specialist data providers showing change in cost of broadband over time (e.g. Point Topic)	Tracking changes in the lowest available broadband subscription in LFFN areas	• There would be a cost to accessing this data (currently unknown), but Point Topic website indicates this should be available.