Dame Chi Onwurah
MP for Newcastle upon Tyne Central and West · Labour · United Kingdom
“An extraordinary debate is going on right now inside and outside AI companies about whether the possibility of AI destroying humanity is more or less than 10%. The European Union is moving ahead with a comprehensive AI regulatory framework, but the UK continues to rely on existing regulation.”
“The Pope also highlighted how the billions of online digital twins constitute an unprecedented concentration of power in the hands of a small number of men. Among the many consequences of the 40 years of neoliberalism repeatedly called out by the Prime Minister is a libertarian attitude to technology.”
“But this stealth digital twinning violates the integrity, uniqueness and very personhood of our constituents and of all of us. Digital twins can take many forms, from content creation algorithms and deepfakes to chatbots that reflect aspects of our personalities back at us. It is particularly worrying when children are the target.”
“The automated version of our kids will grow with them, using the power of AI to target advertising and products at them, and worse. The Science, Innovation and Technology Committee has heard about some of the tragic consequences of online grooming by algorithms and chatbots—a vulnerable boy persuaded to kill himself; a vulnerable girl fed…”
“In the arts, entertainment and tech industries, many performers are agreeing to the creation and use of digital replicas as part of their work—think of ABBA Voyage. But performers increasingly encounter unauthorised digital replicas of themselves, which pose a threat to their career, livelihood and reputation.”
“Since then, deepfakes have proliferated. The hon. Member for Mid Norfolk (George Freeman) was shown crossing the Floor in Parliament to join Reform, to his constituents’ consternation and his own—it was a fake. Then there were the horrendous photos of naked women and girls that Elon Musk’s AI created on demand.”
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Every one of 5,139 lines we hold for Dame Chi Onwurah, in date order, each linked to its source. Free to read, in full, without an account. Page 39 of 103.
“Lindsey Fussell: I think this legislation quite clearly does place explicit duties on us to monitor and enforce the compliance of operators on network security requirements. I do not see that there is any risk that we would downplay the importance of that duty in comparison with others. Clearly, it is for the Government to put forward any changes to legislation to change the balance of our duties or to add new ones, but I think the Government—and, indeed, Parliament—are asking us very clearly to take on those responsibilities through this new legislation. To pick up on a point I made earlier, in terms of the interests of citizens and consumers, it is important to say that of course it is in the interest of citizens and consumers to have excellent networks functioning that provide them with great connectivity.”
“Q With regard to asset registry and expectations of having that, having spent a significant amount of time looking in the back offices of operators as to what they have, I know that they are certainly not up to date. We have heard from other witnesses that they do not always have up-to-date and comprehensive asset registers. To rely on an expectation seems a low bar. Can I come on to duties? I have the Communications Act here, which has got a lot thicker since I left Ofcom. The two duties are the “interests of citizens” and the “interests of consumers” with regard to competition, but there is not a duty on security. Does that not suggest that if there is a conflict between competition or communication matters, that will be prioritised over security if there is not an explicit duty to maintain the security of our networks?”
“Although we would expect the largest operators—we would work with them intensively throughout the process—to take part in, for example, penetration testing, it is likely we will be more proportionate with the smaller operators and, for example, respond on an incident-based approach, rather than expect them to carry out the same level of detailed work and interaction with Ofcom. In all of that, we would want to be proportionate in the costs imposed on operators, as we are in all our responsibilities, bearing in mind that these are really important responsibilities, as we have been discussing.”
“We are currently in discussion with the Treasury about the exact technicalities and which of those routes will be used to fund this, but it will be in line with Ofcom’s normal funding arrangements. In relation to company costs, clearly the Government have looked into that, in discussion with operators in relation to the impact assessment for the legislation. I know that there is a plan to do further work on that in relation to telecom security requirements, once companies have had a chance to see the SI and the code of practice. The point here, which is built into the legislation, is the concept of proportionality.”
“Q A word on costs, perhaps. You said in your opening statement that you expected it to cost about £6 million to £7 million for Ofcom. How will those costs be funded or raised? In terms of costs on operators, clearly a requirement to do a complete asset register, for example, could be a very significant cost for an operator. What kind of costs do you see? Do you see limits being placed on the costs that operators could incur in complying with Ofcom demands or requests? Lindsey Fussell: In relation to Ofcom’s costs first, Ofcom is funded in two ways: first, by a levy on the sectors and companies that it regulates and, secondly, through the collection of fees, primarily from our spectrum duties. Our overall funding is obviously agreed by our board but also subject to a cap agreed with Government each year.”
“There are clearly synergies between the security aspects and the diversification aspects: in determining how diverse the supply base is, having a fully populated and up-to-date asset register from the operators for the security needs will also support the requirement to assess the diversity, if that is what we are required to do.”
“Again, although I understand the tiering of the system will be set out in the code of practice, that will also be based on size and scale. Simon, may I turn to you on diversification? Simon Saunders: The diversification strategy that the Government have published has set out a desire to attract new suppliers to the UK and further expand suppliers through open solutions, among other means, and to ensure that that is supported by an appropriate regulatory framework. We are ready to do what comes from that, in terms of any objectives the Government set on the level of diversification and to support measures to enable that.”
“Q Could you therefore confirm that the costs will be in line with the size of the operator, so small start-ups will not be expected to pay the same as Vodafone, for example? We have not talked at all about the diversification strategy, yet there is agreement that we cannot have secure networks without effective diversification of the supply chain. Are you in a position to monitor the diversification of operator supply chains, and is that something you would expect to be doing? Lindsey Fussell: If I may, I will bring Simon in on the question of diversification. In relation to costs, the bulk of Ofcom’s own costs are paid by larger operators rather than smaller ones, and we have talked about proportionality in the way we operate that.”
“I do not view this as an entirely separate area from our existing duties; whether specific duties around this are needed is part of the work we are doing to support the taskforce and the plans that come from that.”
“Q But currently your duties are all to do with the stick, in terms of the enforcement of security requirements, and nothing to do with diversification or the incentives for that? Simon Saunders: Our existing duties around ensuring the health of the communications market for consumers and citizens point in the same direction in many ways, even if diversity is not spelled out explicitly. We see that a functioning, competitive market for network equipment supports the operators’ ability to provide cost-effective networks that perform well, and that supports the needs of citizens to get great services wherever they are and for those services to be reliable and so on.”
“We have quantum encryption expertise funded through Innovate UK’s programmes, we have world-leading providers of optical transceivers for fibre communications, and we have backhaul capability.”
“My question to Dr Johnson: we heard from Mavenir earlier, which said that open RAN could provide 2G, 3G, 4G and 5G networks now. We have also heard of the operational challenges associated with that. What is your view on the maturity of open RAN technology? We will start with Andy. Dr Sellars: The first question was about UK capabilities to exploit the opportunity. Specifically, the UK has a cluster of small-cell base station manufacturers around the Bath and Bristol area. We have satellite communications clusters around the north-east, central Scotland and Surrey. We have a compound semiconductor cluster around south Wales, employing 1,600 highly skilled engineers generating something like £180 million per annum to the Welsh and UK economy.”
“Q It is a pleasure to serve under your chairmanship, Mr McCabe. I will be brief, as we are running out of time, but thank you for your expertise. My question to Andy Sellars and Heba Bevan is about the diversification strategy. In what areas do you think the UK has the capability to exploit the opportunities of this diversification strategy, particularly in hardware versus software? We have been told that hardware is beyond our manufacturing capabilities, yet you seem to be making a success out of it, Heba. What barriers are new entrants and smaller companies likely to experience and what kind of interventions should the Government make that are not fully addressed by the diversification strategy in order to ensure a UK capability in this area?”
“Germany was able to fund €1.2 billion from its money to support these foundries. France put in €0.8 billion, and Holland put in €0.4 billion. In the UK in the last few years, in terms of building these foundries, the UK has not supported that type of manufacturing. In chip manufacturing, we do not. However, on the hardware scale we are able. The way we see it, we build the hardware; we build the software—but the actual components and the chips, today we do not have the capabilities in the UK to manufacture that.”
“Heba Bevan: Thank you for your question. On hardware, as a company—and to be honest in the UK as a nation —we do not have the essential foundries. We can design and prototype the silicon, and we can work on, from the beginning, how actually it would work, but the actual manufacturing of the chip—not the hardware: that one chip which is like the CPU or a piece of DSP—those actually require very high-intensity foundries. If we want to build them in the UK it will cost around £10 billion today—probably over that number. Andy can correct me on that. In the far east, they have unlimited resources with the state aid rule; and Europe, in the last few years, passed something, for the state aid rule, called IPCEI, which is important projects of common European interest.”
“Q What interventions would support them? Dr Sellars: For interventions, I would suggest that the Advanced Propulsion Centre is a really good model to look at. It is in a different sector. It is funded through the Department for Business, Energy and Industrial Strategy, and its remit is to help to transition the automotive industry from petrol and diesel engines to electric drivetrains using batteries. Have a look at that as a model. It is an incredibly good model for transitioning an entire industry from one technology to another. It brings together supply chains and is very effective. That is one of the interventions I would suggest. Other interventions could be cyber-certification and just helping UK companies to access some of the standards bodies. That would be very effective. We have a lot of SMEs.”
“Q It was a question to Dr Johnson with regard to open RAN maturity as an IP. Dr Johnson: So, the 45-second answer: Mavenir is using IP access GSM 3G technology in its open RAN development. Pardeep, I think, said that it would be ready within 12 months, and I agree that that is a true statement.”
“If you can make equipment to test something, you can actually make that equipment, because it is much more complicated to make the test equipment than it is to make the base station or the handset itself. Those companies deserve our support as well. That was a very long question, Chi; I am not sure I covered every aspect you were asking about.”
“We have some very good capability in this country in component and subsystem manufacture based around the chips. We have some good design capability for chips that are then manufactured in the larger foundries elsewhere in the world. Supporting those activities, the design and the manufacture of components and subsystems, would give us a good basis and improve resilience. I also want to mention that we have some capability in this country in the test and measurement sector with Spirent and VIAVI Solutions—although VIAVI is an American-owned company, it manufactures RF and wireless test equipment in the UK. By definition, test is ahead of the curve on development.”
“Helen Duncan: Starting from how we got into this situation, in the 1990s we had three incumbent base station manufacturing companies in the UK, which were Orbitel in Nottinghamshire, and Motorola and Lucent Technologies, both in Swindon. They survived for different lengths of time: Orbitel closed down in 1996 when Ericsson took over, Motorola ceased base station manufacturing in 2002, but stayed open and was then sold to Nokia, and Lucent became Alcatel-Lucent and was closed down. Mergers and acquisitions have clearly played a huge part, as did the dotcom bubble and, as I mentioned, the removal of funding from the defence sector. Heba made the point that to support semiconductor manufacture in the UK, the £250 million would not even start to scratch the surface. We need to concentrate a little bit further up the food chain.”
“Now that we are seeking to reverse that, or to jump ahead of that, what interventions could best guarantee the long-term security and resilience of the UK telecoms network, with UK sovereign capability supporting it? Is the £250 million diversification strategy set to achieve that? Can you give examples—I am looking for quite concrete examples—of what you might add or change? David, you talked about needing to give the right incentives to the mobile operators. The telecoms supply chain review was quite clear that there is not an incentive right now in the supply chain to deliver security in mobile networks. What interventions and what incentives should there be?”
“Q Welcome to all of you, and thank you so much for joining us. May I say, particularly to Helen Duncan—I should also have mentioned this earlier when we had Heba Bevan—that it is great to have two other female electrical engineers giving evidence to the Committee. I hope we have many more such qualified representatives of the technology sector in Committees in the future. We have talked a little about how we got here; Helen, you worked for Marconi, and I worked for Northern Telecom, which bought STC, one of our last UK companies providing telecoms equipment. Without putting words into your mouth, I think the situation could be characterised by a lack of investment in innovation and in British sovereign capability.”
“While we seem to think that that gets delivered by the free market, in reality that is not happening, and I think the Government in particular need to intervene to connect up all these people. Today, I launched the Northern Ireland Engineering Hub for the Royal Academy of Engineering—I am chair of the enterprise committee—and that was specifically picking Northern Ireland because of its deep engineering history in order to start to connect it with a lot of the other things that are happening in the rest of the United Kingdom. I think we need more of that, and I think that out of it will come the same blossoming of innovation and engineering that we have seen previously when people have been connected up together. I am a great optimist on that.”
“I noticed that the Government have spent some money on the 5G networking across the UK, which is being run by Cambridge Wireless, which I am very proud to have helped set up. We talked in the previous session about the cluster of people down in Bristol working on semiconductors and so on, and I think the Government should be putting some money into networking people together across the UK, and between regions in particular, to have ways in which we can be exchanging ideas and getting to understand what each other is doing. We complain about silos in Government and siloes in corporate, but we have siloes across every single component of this industry, and it is no good to sit in a part of the west midlands, Cambridge or Belfast and not talk to other people about the issues, the standards and the technology.”
“You are right to say that, until relatively recently, the penalties on security and so on—the consequences—have been very small, but in terms of behaviour, you need both carrot and stick on things like this. You need to have something that will give the telecom operators a real reason to do something, which might be as simple as a kitemark that says, “The telecoms network you are using has been certified as secure.” That may or may not be the kind of thing that would engender the behaviour change, but it is noticeable that with a number of things like Telegram and WhatsApp, that is seen to be quite an important thing. Finally, the networks of people are important in all of this.”
“Q That’s great. David? Dr Cleevely: Thanks, Chi—nice to see you. One of the things that was mentioned in the session a little bit earlier was standards, and I think one of the things that changed telecommunications between the 1970s and the dotcom revolution was the emergence of some of these more open standards, such as TCP/IP for running the internet and so on, and HTML for doing the web browsers. I think we could be putting a lot more money and effort into defining some of those standards, because if you define the interfaces for pieces of equipment correctly, you can allow people to come in and provide bits of equipment that can conform to those interfaces. That is one very concrete thing.”
“Q Helen, you were absolutely right to emphasise, in terms of how we got here, with no UK telecommunications network capability, that as well as being about under-investment, which I mentioned, it was about acquisitions—many acquisitions of UK capability and capacity. We have the National Security and Investment Bill going through the House; in fact, that is coming back for Report tomorrow. It will make national security—although not economic security—a ground for intervening in acquisitions and investments, but it will not make investment in companies any easier. We are talking about concrete measures—what measures could Government take, or could be taken, to make significant additional investment available or easier? Helen Duncan: That is an interesting question.”
“As I have mentioned before, if you have a client or two who is prepared to buy kit from you, you not only get money but you get experience and expertise and you develop your company. We need more incentives for procuring from those kind of middle-sized companies, because out of those will come the giants of tomorrow. My experience in Cambridge and elsewhere is that quite often, many of those companies say they are entirely private sector driven, but actually they have been the subject of lots of Government procurement and interventions along the way. That is particularly true in the United States where the SBIR scheme is very important.”
“Dr Cleevely: There was a thing called the Macmillan gap, which led to the emergence of the Industrial and Commercial Finance Corporation in the late 1940s. Translated into modern terms, that gap is investments required of around about half a million to £5 million or £10 million. We are still living with that, and that gap was identified in the 1920s. We have a structural problem in the United Kingdom about the way in which we invest in some of what would in Germany be called Mittelstand—those smaller companies. I think you are quite right, Chi, to draw attention to that as a particular risk profile. People do not want to put money necessarily past the seed stage into what I would call late series A and into series B. The other point is procurement.”
“We could perhaps have a telecoms business bank? Helen Duncan: You cannot stop mergers and acquisitions happening, but if you can put in some sort of criteria that companies that buy British companies need to give a commitment to continue to invest in this country for a set period of time—whether or not that is practicable—that would help. The most important thing is to make the companies themselves strong enough so they are not targets for asset stripping, as has happened in the past. All the measures that we are talking about to oil the wheels, as David says, will make our companies stronger and able to compete in what is still a global market. I think making our companies competitive is the key to this.”
“It also had a long-term focus and an interest in broad technological change, which many R&D efforts in industry do not see. It had steady revenue from telecom rates. There is a complicated story there. It is hard to tell what concentration is good for innovation and where competition is really the order of the day, but it seems clear that the decline of Bell Labs was a real loss.”
“They were focused on growing quarter after quarter and meeting their financial targets, which made it very difficult to focus on long-term growth. You can contrast that with Ericsson in Sweden, where the Wallenberg family control a lot of the voting shares. Ericsson was able to focus on much longer-term value creation, and they did not cut staff or R&D by nearly as much as Lucent did. Before that, I think there are a lot of lessons to be learned from the aggressive anti-trust action that broke up Bell Labs and restructured the entire industry. Up until the restructuring of the US telecom market in 1984, Bell Labs had a fantastic situation in order to generate innovation. It had the commercial drive, focus and flexibility that is often lacking in a Government research lab.”
“Throughout the ’90s, it was the largest telecoms equipment company and was still growing dramatically overseas, but due to a number of strategic decisions within the company and decisions within the US Government, it ended up really suffering as a result of the dot.com bubble. Setting aside all the competitiveness questions, particularly with regards to Chinese companies, a hands-off, free market globalised system reigned in the US and UK throughout the ’90s. It was finance-focused capitalism that saw Lucent and Nortel cut their R&D budgets and staff dramatically, particularly as a result of the 2001 crash—much more so than some of their international competitors. With that financial system, it was harder for those companies, which were designed to be growth companies—much more so than a valued company.”
“I would say that it is fair to characterise the failures and decline of Lucent as a complicated story, but it stems from a combination of unique challenges imposed by the Anglo-American economic system, systemic failures of US Government policy—particularly with regards to anti-trust and some of the regulatory policy throughout the 1990s—and very strong and aggressive foreign industrial policies, particularly with regards to China, to acquire market share. I am happy to go through that in some detail, but feel free to cut me off if I go on too long. You are absolutely right to say that we had Lucent and Nortel. Lucent was absolutely massive—it was three times larger than Nortel—and originally spun off from AT&T’s equipment arm, Western Electric. It had the famous Bell Labs.”
“What might you say to the Minister about how the UK Government should be working with the US, and about what sorts of vehicles there might be to work together and with other allies to achieve that? Doug Brake: That is a great question. We talk now about needing diversification and seeking entry of a US-UK equipment supplier, but the question and lessons from history are about why we need this in the first place. In the past, we had quite successful telecommunications supply companies, especially in the US. The president of our organisation, Rob Atkinson, set out to answer that question. You may have seen an article in the American Affairs journal, titled, “Who Lost Lucent?” It is a long and interesting article—I will not go into all the details of history.”
“Q Thank you very much for joining us, Doug. It is particularly interesting to have your American perspective. As you may have heard, my first job as a hardware engineer was with Nortel, a Canadian-American company that had just bought one of the last UK companies in this area. Nortel ended up seeking chapter 11 and having most of its IP bought by Huawei. What are your views on how we got ourselves into this position of not having a single UK or US supplier that can supply to our UK networks? How do you think we can work together to rebuild our telecoms sectors? You talked about pursuing transformational change and an industrial strategy to do that.”
“Q Perhaps you could contribute the article you mentioned and the key points made as written evidence. Doug Brake: Absolutely. We would be happy to do that.”
“I think that is a potential opportunity for real co-operation: identifying companies that are interested in focusing purely on radio. There is still hardware that needs to be provided that historically was integrated with the broader system, when you only have relatively small providers that are interested in scaling up manufacturing.”
“First, there is a real risk of bandwagoning, where this is seen as a silver bullet and even companies that might not be interested in pursuing this area, such as Nokia and Ericsson, are willing to join in these efforts, even if it is just for the sake of defence. So, there is a real risk of bandwagoning. There is real complexity with transitioning to this sort of system. It is not immediately clear how well open RAN will scale. Actual implementation at scale in urban areas is adding a tremendous amount of complexity. There is a much larger attack surface. It is worth keeping in mind SolarWinds, a US company trusted by many within the Government, which saw this massive damaging breach. I think there is a real challenge that remains to be addressed in the manufacturing of stand-alone radios.”
“Q The second part of my question was about how we can work together. Doug Brake: Absolutely. I think the diversification strategy is a very strong document. I would say, when it comes to open RAN generally, there are clear benefits that you have heard a lot about, I am sure, including diversification and faster innovation when software is decoupled from hardware. Generally, lower margins on generic components eliminate the risk of the entire sector tipping to a single vendor or a gradual narrowing of trusted suppliers, but there are real challenges with this process. Again, this is going to be a gradual effort. There is not a need to transition immediately.”
“Q It is a pleasure to serve under your chairship, Mr Hollobone. I want to start by thanking, as well as the witnesses, the members of the Committee, the officials and the staff of the House, who in coming into Parliament during a pandemic are also taking risks, which we very much regret. I should have mentioned, as an interest, that I spent 20 years working in the telecoms industry within four network operators and vendors, as well as Ofcom, the regulator. I also may know personally some of the witnesses.”
“We need the stability and the time, as Derek rightly points out, to allow industry and Government to develop a diverse supply chain and allow the technology to mature, both in its functionality and its capability, as well as the possibility of scaling industrially. The legacy vendors have had a lot of time in the market to develop their competence. We need to support any new entrants in the open RAN space with appropriate investment incentives and a policy framework that attracts and supports new entrants in the open RAN space.”
“Andrea Donà: Very much like my colleagues, I am more than happy to write to the Committee in the future, once we have completed our procurement process, with the details on the cost for replacing our high-risk vendor. More specifically, when it comes to the diversification strategy and the role that open RAN has, we at Vodafone believe that the UK should seek to be a leader in open RAN. We are, indeed, leading the way, and have committed to swapping out 2,600 of our base stations to an open RAN technology. In order to fulfil that ambition, the current timescales for removing the high-risk vendor equipment must remain unchanged.”
“You are absolutely right that we tend to buy end-to-end service in the current mobile environment. ORAN today is set up with a quite separate and different supply chain, with different companies specialising in software, different companies specialising in hardware and specialists doing the integration. It is likely to change the nature and relationship that we will have with supplies. ORAN is relatively immature in its development. As it is technically and commercially ready for scale deployment, that may well change. But we see today that the leaders in ORAN tend to be smaller companies specialising in the hardware or, more specifically, the software.”
“In terms of the diversification of the market, there are really only two players in the UK market now. As you rightly point out, there are service as well as equipment capabilities within those suppliers. As we look for diversification, we need to diversify across all those aspects of the market. We are working with the Government, NCSC and DCMS in terms of how to approach that and how to build that. We will continue to support that as we go forward. Derek McManus: We have similar commercial sensitivities on cost. You may or may not be aware that we are not indebted to Huawei. For our network, the cost of removing from the radio network is relatively small compared to some of our competitors. So, I will focus more on your second question, if that is okay.”
“How best can the Government work with partners around the world to achieve their goals? That is quite a lot in two questions. Patrick Binchy: There was quite a lot in those questions. I guess the first thing is that the costs are obviously commercially sensitive, and we cannot disclose them in a public environment, but we would be very happy to respond to any of the Members or the Committee in private to give the detail behind that. At a more generic level, there will, of course, be cost to the industry and to Three. We had selected Huawei to build our 5G network, and we have now selected a second vendor, Ericsson. We have to go through the process of mobilising Ericsson and removing the Huawei equipment, which has a cost to it and will have an impact.”
“How can we minimise the economic impact, in your view? Are there other significant costs associated with the Bill and the implementation of a new security framework? Secondly, your mobile network procurement is currently made through what I will call full-service providers, such as Huawei, Ericsson and Nokia. They basically design and make a network, and provide it to you—I know it is not quite as simple as that. Do you think the removal of Huawei or the develop of open RAN will change that? Critically, is the Government’s diversification strategy likely to lead to the emergence of significant full-service suppliers that will compete head on with the remaining suppliers, Ericsson and Nokia? If not, what other measures should the Government consider taking?”
“You make a very good point, Mr Hollobone. I am going to try to keep my engineering and technical interest as much to the back as possible. I am the shadow Minister for digital, and I am leading for Labour on this Bill. I will focus on the costs of removing Huawei and the diversification strategy, and Opposition colleagues will be focusing on different areas. I thank you for your presence and expertise. I want to ask two somewhat related questions. First, some have given estimates of the costs of removing Huawei from your networks, and I want to verify whether those are the most up-to-date estimates. I also want to know whether they include opportunity costs, and the time and resources from your boards and others in your organisations. Are they the full costs, if you like, of the removal of Huawei?”
“We hold a lot of expertise, from a Telefónica group point of view, that the UK team is able to rely on and work with to ensure that we are at the very edge of developing the right standard. Andrea Donà: As the Government plan to take a lead in enhancing the minimum security requirements, and in diversifying their telecoms strategy, we as a global company are happy to support the standard setting, and to advise on the practical implementation of the additional security requirements. Patrick Binchy: I refer to Derek’s answer. We have a very similar position with regard to the UK legislation: we have not seen quite the same in the other countries. On standards, we play an active role, and we have a number of UK staff who act actively in standards setting.”
“Q I ask these questions on behalf of Catherine West. Vodafone runs networks across Europe, and so does Three, whose owner is headquartered in Hong Kong, and O2, which is owned by Telefónica. Does the Bill duplicate or reflect legislation that you have seen elsewhere in your operations? What international comparisons are you aware of? Also, we have talked about standards being a key part of international collaboration. How many people, or what presence, do you have on international standards bodies? Derek McManus: Basically, we have not seen anything directly like the UK legislation, although various forms of it can be seen internationally. The second question was on standards. We operate in 23 countries, and as you can imagine, their standards are key to us.”