Consultation process on implementation options for location study systems starts

The Ministry of Transport and Communications is requesting opinions on an assessment memorandum regarding regulatory and implementation options for a system to respond to location study requests. Opinions may be submitted until 24 January 2025.

The assessment memorandum presents solutions designed for responding to location study requests, outlines the current state of relevant regulations and identifies associated challenges. The aim of location studies is to facilitate and accelerate the construction of communication networks, prevent faults and disruptions caused by excavation and improve the information security of networks. 

In October 2024, Lulu Ranne, Minister of Transport and Communications, called for the Finnish Transport and Communications Agency (Traficom) to interrupt the process to introduce the location data service prepared by Traficom. Due to the overall security situation, Traficom was tasked with re-evaluating the functionalities and implementation model of the service, as well as exploring alternative solutions in cooperation with security authorities. The location data service was under development for several years. Given the changed security environment, it is essential to place particular emphasis on the data security of the implemented service and ensure the protection of geospatial data.

The location data service, developed by Traficom, was a proposed online platform where network operators would provide the location data of the active components of their communication networks. Private individuals and organisations that need such data could request it from the service. The service was to be opened for production use in October 2024 and for those conducting location surveys in spring 2025. At present, data related to the location survey of cables is scattered in many different sources. Location study responses do not include information about critical infrastructure.

Assessment memorandum compares implementation models

The assessment memorandum compares various implementation models for location studies and evaluates their impact on different user groups of the service. Initially, the location data service was planned to operate as a centralised model. Due to challenges and weaknesses identified with this approach, the memorandum also explores alternative models that better address overall security concerns.

According to the memorandum, all the implementation models examined may require legislative amendments to adjust the public authority’s powers and specify the technical functionalities of the system. The need for legislative amendments will be assessed in greater detail once the implementation approach has been decided.

Centralised model

In the centralised model, network data from all operators would be collected in advance and stored in the service. The supervisory authority would process location study requests and responses and oversee the system. 

Centralising network data in the service would allow for the monitoring of data quality. This model would enable the creation of a composite map of underground infrastructure, simplifying the planning and execution of construction works. Additionally, the authority would gain insights into the nature and origin of location study requests.

In this model, network data, as well as location study requests and responses, would be aggregated within the authority’s system. 

Decentralised model

In the decentralised model, all location study requests would be submitted through the authority’s service. However, the responses would be provided either through the service or directly by the network operator to the initiator of the location study requests. Network data would remain distributed within the operators’ own systems and would not be stored in the authority’s service. The authority would still be informed about the recipients and request initiators.

The assessment memorandum outlines two variations of the decentralised model. Variation A would allow for the creation of a composite map of underground infrastructure. The authority could monitor the quality of network data. However, network operators’ data would not be centralised within the authority’s system. Instead, information about network areas and study responses would be aggregated through the service. Consequently, location study requests and responses would accumulate in the system.

In Variation B, no network data would be submitted to the authority’s service, meaning that a composite map could not be produced. Network operators would independently determine how and where to store their data and how to provide it to requesters. Location study requests would still be centralised within the service.

Hybrid model

In the hybrid model, certain operators, especially smaller ones, would provide their network data to the service in advance, operating as a centralised solution. At the same time, other operators could retain control over their data and respond to requests independently. For these operators, the authority’s service would act merely as an intermediary for transmitting location study requests, with operators responding directly to the request initiator. In this case, the system would only store information about network areas.

The hybrid model would allow the authority to monitor data quality and facilitate the production of a composite map of underground infrastructure. The authority would also have insights into the origin and nature of location study requests.

If implemented as a centralised solution, location study requests and responses would be aggregated in the service. If implemented with decentralised network data storage, only requests would be aggregated within the service.  

Consultation process seeks views on benefits and drawbacks

The consultation process seeks responses to the following questions:

• Which of the presented models do you consider most suitable for your organisation, representative body or industry, and why?
• Which models do you consider particularly challenging to implement, and why?
• How do you assess the cost implications of the various models for your organisation, representative body or industry?
• Are there additional benefits or challenges in the models that are not addressed in the assessment memorandum?

What’s next?

All citizens and organisations may submit opinions on the assessment memorandum at lausuntopalvelu.fi Opinions may be submitted until 24 January 2025. After the consultation process, the preparations will continue by public officials as part of official duties.

Proposals for legislative amendments concerning location studies are intended to be included in the national implementation of the Gigabit Infrastructure Act. The consultation process on the Government proposal on the Gigabit Infrastructure Act is expected to start in February 2025.

Inquiries:

Lauri Mustonen, Senior Specialist, tel. +358 295 342252, [email protected] 

Iida Huhtanen, Senior Ministerial Adviser, tel. +358 295 342 613, [email protected]

Sofia Lindbäck, Senior Specialist, tel. +358 295 342165, [email protected]