BALTIC SUBMARINE CABLE

Feasibility Study Baltic Cable

12 August 2022
Version 0.9
 TABLE OF CONTENTS

CONFIDENTIALITY NOTICE ............................................................................. V

ACRONYMS LIST ........................................................................................... VI

DOCUMENT CONTROL SHEET ....................................................................... IX

1. EXECUTIVE SUMMARY ............................................................................ 1

1.1 Introduction ...................................................................................................... 1
1.2 Business Objectives .......................................................................................... 3
1.3 Technical Overview ........................................................................................... 3
1.4 Operational Overview....................................................................................... 4
1.5 Sustainability .................................................................................................... 5
1.6 Project Delivery and Milestones ....................................................................... 6
1.7 Delivery and Risks ............................................................................................. 7

2. CABLE SYSTEM DESIGN PLAN .................................................................. 9

2.1 Project Objectives ............................................................................................. 9
2.2 Project Design Approach .................................................................................. 9
2.3 Key Design Elements....................................................................................... 10
2.4 Future Decisions and Considerations ............................................................. 12
2.5 System Description ......................................................................................... 14
2.6 Technical Conclusion ...................................................................................... 35

3. OPERATIONS & MAINTENANCE............................................................. 36

3.1 System Management ...................................................................................... 36
3.2 Dry Plant Operations and Maintenance Strategy ........................................... 38
3.3 Wet Plant Maintenance .................................................................................. 42
3.4 Conclusion/Recommendation ........................................................................ 48

4. SUSTAINABILITY .................................................................................... 49
4.1 Industry Sustainability Efforts ......................................................................... 50
4.2 Carbon Footprint Modelling ........................................................................... 53
4.3 Prospective CO2 Mitigators ............................................................................. 55
4.4 RFP Criteria ..................................................................................................... 57

5. PERMITTING & REGULATIONS ............................................................... 61

5.1 Overview ......................................................................................................... 61
5.2 General ........................................................................................................... 61
5.3 Permitting Requirements by Country ............................................................. 61
5.4 Permitting Conclusion .................................................................................... 70

06 April 2023 | Page i of ix | Version 1.0

6. IMPLEMENTATION ................................................................................ 71
6.1 Project Methodology ...................................................................................... 71
6.2 Plan of Work ................................................................................................... 73
6.3 Planning .......................................................................................................... 73
6.4 Procurement ................................................................................................... 74
6.5 Permitting ....................................................................................................... 75
6.6 Land Acquisition and Easements .................................................................... 76
6.7 Marine Survey (Route Design) ........................................................................ 76
6.8 System Design Solution .................................................................................. 77
6.9 Manufacturing ................................................................................................ 78
6.10 Installation & Commissioning ......................................................................... 78
6.11 Operational Readiness .................................................................................... 79
6.12 Ready for Service ............................................................................................ 80

7. PROJECTED COSTS ................................................................................ 81

7.1 Capital Expenditures ....................................................................................... 81
7.2 Operating Expenditures .................................................................................. 82

8. RISK ANALYSIS ...................................................................................... 84

8.1 Overview ......................................................................................................... 84
8.2 Solution Risks Assessment .............................................................................. 84
8.3 Delivery Risks Assessment .............................................................................. 86
8.4 Conclusion ...................................................................................................... 87

9. CONCLUSIONS ...................................................................................... 88

APPENDICES ................................................................................................ 90

A. APPENDIX – Critical Design Elements .................................................... 91

B. APPENDIX - Permitting Matrix .............................................................. 92

C. APPENDIX – Route Position List ............................................................ 93

D. APPENDIX – RPL Illustrations ................................................................ 94

E. APPENDIX – Desktop Study ................................................................... 95

06 April 2023 | Page ii of ix | Version 1.0

 LIST OF FIGURES
Figure 1: BALTIC Technical Overview ..................................................................................................... 3
Figure 2: BALTIC Route Summary ........................................................................................................... 4
Figure 3: Project Gantt Chart ................................................................................................................. 6
Figure 4: Design Plan Development Process .......................................................................................... 9
Figure 5: BALTIC Straight Line Diagram ................................................................................................ 20
Figure 6: Copenhagen Approach .......................................................................................................... 21
Figure 7: ASN ROADM Solutions .......................................................................................................... 22
Figure 8: BALTIC Power Feed ............................................................................................................... 25
Figure 9 : Site Plan Examples ................................................................................................................ 29
Figure 10: Cable Landing Station Layout Example ............................................................................... 31
Figure 11: Electric System Simplified Block Diagram ........................................................................... 33
Figure 12: Global Private Maintenance Agreements ........................................................................... 43
Figure 13: CS Sophie Germain, Orange Marine .................................................................................... 51
Figure 14: Sustainability Model ............................................................................................................ 54
Figure 15: Carbon Footprint of Submarine Cable Production .............................................................. 56

06 April 2023 | Page iii of ix | Version 1.0

 LIST OF TABLES
Table 1: Key Design Decisions .............................................................................................................. 11
Table 2: Open Items ............................................................................................................................. 13
Table 3: Segment Table ........................................................................................................................ 14
Table 4: Latency Estimate .................................................................................................................... 15
Table 5: Failure Modes (Critical) .......................................................................................................... 16
Table 6: BMH Locations........................................................................................................................ 19
Table 7: Cable Lengths by Type ............................................................................................................ 20
Table 8: Burial on Approach ................................................................................................................. 21
Table 9: Typical System Parameters..................................................................................................... 24
Table 10: Cable Landing Station Requirements ................................................................................... 32
Table 11: Technical Operational Disciplines ......................................................................................... 37
Table 12: Wet Plant Spares Quantities (Preliminary) ........................................................................... 44
Table 13: ASN Sustainability Profile .........................................................Error! Bookmark not defined.
Table 14: NEC Sustainability Profile .........................................................Error! Bookmark not defined.
Table 15: SubCom Sustainability Profile ...................................................Error! Bookmark not defined.
Table 16: Xtera Sustainability Profile .......................................................Error! Bookmark not defined.
Table 17: Supplier Comparative Sustainability Profiles ............................Error! Bookmark not defined.
Table 18: Sustainability Model - BALTIC Results .................................................................................. 55
Table 19: RFP Weights Table ................................................................................................................ 58
Table 20: RFP Scoring Table ................................................................................................................. 58
Table 21: Sustainability RFP Recommended Requirements................................................................. 58
Table 22: Delivery Responsibility ......................................................................................................... 71
Table 23: Capital Cost Summary – 24FP ............................................................................................... 82
Table 24: Annual OpEx Budget Estimate .............................................................................................. 83
Table 25: Key Solution Risks ................................................................................................................. 85
Table 26: Key Delivery Risks ................................................................................................................. 86

06 April 2023 | Page iv of ix | Version 1.0

 Confidentiality Notice

This Document contains confidential and proprietary information that must be protected in
accordance with relevant Non-Disclosure Agreements.

06 April 2023 | Page v of ix | Version 1.0

ACRONYMS LIST
ABBREVIATION TERM
AC Alternating Current
AOO Area of Operation
BALTIC Baltic Submarine Cable System
BMH Beach Manhole
BU Branching Unit
CapEx Capital Expenditures
CIF Contract in Force
CLS Cable Landing Station
CRE Cable Route Engineering
CSDP Cable System Design Plan
CTU Cable Termination Unit
DA Double Armor Cable
DC Direct Current
DCN Data Control Network
DGE Directorate General of the Environment
DLS Digital Line Segment
DTS DTS
DWDM Dense Wave Division Multiplexing
EIA Environmental Impact Assessment
EIS Environmental Impact Statement
EMS Element Management System
EPFI Equator Principles Financial Institutions
ESIA Environmental and Social Impact Assessment
ESMP Environmental and Social Management Plan
ESMS Environmental and Social Management System
ETSI European Telecommunications Standards Institute
FDC Fiber Distribution Canisters
FP Fiber Pairs
FTE Full Time Equivalent
HDD Horizontal Directional Drilling
HSE Health, Safety and Environment

06 April 2023 | Page vi of ix | Version 1.0

 ABBREVIATION TERM
HVAC Heating Ventilation Air Conditioning
ICPC International Cable Protection Committee
IEC International Electrotechnical Commission
IEEE Institute for Electrical and Electronics Engineers
IMCA International Marine Contractors Association
IRU Indefeasible Right of Use
ISA International Seabed Authority
ISO International Organization for Standardization
ISP Internet Service Provider
ITU International Telecommunication Union
KDD Key Design Decisions
LME Line Monitoring Equipment
LNG Liquid Natural Gas
LW Lightweight
LWP Light Weight Protected Cable
MAC Move Add Change
MARPOL International Convention for the Prevention of Pollution from Ships
Mbps Megabits per second
MTBF Mean Time Between Failure
MTTR Mean Time to Repair
NMS Network Management System
NOC Network Operation Center
O&M Operations and Maintenance
ODF Optical Distribution Frame
OGB Ocean Ground Bed
OOS Out of Service
OpEx Operating Expenditures
OSNR Optical Signal to Noise Ratio
OSP Outside Plant
OSS Operations Support System
OTT Over the Top
PABX Private Automatic Branch Exchange

06 April 2023 | Page vii of ix | Version 1.0

 ABBREVIATION TERM
PFE Power Feed Equipment
PLSE Pre-laid shore end
POP Point of Presence
POW Plan of Work
PSA Production Sharing Agreements
PSBU Power Switched Branching Units
QC Quality Control
RES Return to Earth System
RFI Request for Information
RFP Request for Proposal
RFPA Ready for Provisional Acceptance
RFS Ready for Service
ROADM Reconfigurable Optical Add-Drop Multiplexer
ROI Return on Investment
RPL Route Position List
RTD Round-Trip Delay
SA Single Armor Cable
SLA Service Level Agreements
SLD Single Line Diagram
SLTE Submarine Line Termination Equipment or Station Line Termination
Equipment
TA Terrestrial Armor Cable
TOR Terms of Reference
UJ Universal Joint
UPS Uninterruptable Power Supply
VDC Volts Direct Current

06 April 2023 | Page viii of ix | Version 1.0

 Document Control Sheet

For Revisions and Proposed Changes Contact:

Eric Handa
[email protected]
[+1] (908) 547 7868

Issue Date Status / Reason

0.1 28 July 2022 First Internal Draft

0.2 8 August 2022 Second Internal Draft

0.3 11 August 2022 Third Internal Draft

0.9 14 August 2022 Preliminary Draft for Issue

06 April 2023 | Page ix of ix | Version 1.0

1. EXECUTIVE SUMMARY

1.1 Introduction
This study integrates the business objectives with technical considerations which are supported
by lessons learned and best practices to develop and assess the technical aspects of BALTIC.
A successful submarine cable project begins with an initial conceptual design, business and
financial model, project definition and risk analysis which becomes the decision package for
moving the project into a more formal development state including engaging potential investors
and initiating a go to market process (e.g., Invitation to Tender or Request for Proposal).
As stated in the opening paragraph, this study’s objectives are to:
1. Provide a conceptual design to support the System which can be built to needs
2. Provide a DTS (DTS) to substantiate the conceptual design
3. Develop an initial investment cost to be used for stakeholder engagement
4. Identify project technical and delivery risks along with considerations for mitigation
5. Provide a delivery approach and supporting high level schedule
This Feasibility Study when integrated with a business and financial analysis, provided by others,
should provide the necessary input or decision pack for governance decisions on the project’s next
steps. These steps may include:
1. Approval to start the next development stages along with identified parallel issue mitigation
2. Recycle to revisit the materials provided and alter them into a new set of options
3. Cancel to stop further consideration and work of the project
As such, this Feasibility Study will provide supporting information for governance, as well as the
core information for the development of a technical specification for an RFP.
The BALTIC concept is to build a 1,214km (estimated) trunk between Rostock and Helsinki with
24FP. Additional fiber branches of 72km and 63km tied to reconfigurable optical add-drop
multiplexer (ROADM) branching units (BU) will be deployed to the Stockholm and Copenhagen
landing sites, respectively. Fiber Pair map design will be agreed at a later state using customer
needs. BALTIC will be of an open architecture system, meaning that no SLTE is provided for
Customer use and users will be sold spectrum and fiber pairs; each Customer will provide their
own SLTE for which the CLS will need to be designed to accommodate.
Technically, no specific issues have been identified and the system uses a standard and proven
architecture. However, it is important to understand that while generating the route, there were
significant discussions on how to mitigate the various hazards as well as the overall shallow water
depth (maximum cable depth 216m) and how to properly protect the cable. A further detailed
review of route including the shore end routing and burial assessment will be required during
cable route engineering and Marine Survey. The DTS provides a preliminary RPL based on
information available and is suitable to solicit for the project and develop Cable Route Engineering
with the Supplier. While a significant analysis was accomplished, the following areas of route
development should benefit from a high-quality Marine Survey and detailed route engineering:
1. Wind farm development – avoid areas due to crossings and O&M constraints

06 April 2023 | Page 1 of 95 | Version 1.0

 2. Windy seasons – considerations for work windows and vessels
3. Icing – confirm no concerns with icing and related damage
4. Crossings – verify and identify undocumented crossings including wind farm power cables
5. Burial Assessment – evaluate the ability to bury the cable from the Marine Survey
6. Burial length – review the areas of burial to determine if more extensive burial is warranted
7. Cable selection – review cable selection to modify armoring to be fit for purpose
8. Verify shore end installation and need for HDD and PLSE.
From a project delivery perspective, it is estimated it will take 36 months to complete the project
should the next stage be approved. The next stage would be to move into a procurement process
with the development of an Invitation to Tender package including Terms & Conditions, Technical
Specifications, and other supporting documents. During this work, the Purchaser would also work
to establish their customers and requirements to ensure the Technical Specifications meet
stakeholders needs. Once there is commitment from all stakeholders and the tender package is
ready, then formal engagement through issuance of the tender package can be done. If issued to
earlier, there is a risk Suppliers may not give full effort due to the lack of confidence in eventual
funding.
The cost for building the system is estimated at $138M including a 25% contingency which is CLS
to CLS including a nominal CLS facility. The cost for building BALTIC is subject to final specifications
as well as the impact of inflation and the risk management by Purchaser and Supplier as it relates
to mitigating 24-36 months of inflation exposure (up and down).
Overall technical risk view on BALTIC is low to medium. The consideration for medium level risk is
driven by the unknowns and risks in managing the complexity of the Baltic Sea and especially the
shore ends. For this reason, a specific $5M UAP has been added to the cost estimate besides the
contingency. Except for the inflationary pressure management and possibly the basin complexity
the risks are typical of a system such as BALTIC and none of them seem of significantly higher
probability or impact which would require more than normal project management practices.
It is anticipated the key risks are:
1. Cost to build system will be adjusted to cover for ongoing inflationary pressures
2. Final cable route engineering will identify additional marine installation effort and amour
3. Securing the land and necessary permits as to coincide with the identified landing points
4. Securing of investment funds so that CIF can be done in accordance with schedule.
In conclusion, BALTIC system should be deployable in a 3-year period using standard practices for
between $100M (-10%) and $138M (+25%). The high investment range is primarily driven by the
unknown impact of inflation over the coming years and marine installation unknowns. Securing
stakeholder commitment to investment funds will be critical to the success of the project. Using
Good Industry Practices to develop and manage the project including Purchaser scope and
preparing for operational readiness will be the most effective way to ensure delivery of BALTIC as
there are no known unique risks.

06 April 2023 | Page 2 of 95 | Version 1.0

1.2 Business Objectives
The potential Purchaser of BALTIC is looking to expand their investment portfolio into
infrastructure. They. Have identified the regional system within BALTIC Sea as potential
investment opportunity. Through this investment, their business model would be to:
A. Diversify their investment portfolio to include telecommunications infrastructure
B. Compete and expand in the market in BALTIC Region
C. Provide international capacity to serve with major data centers
The development will be led by APTelecom and then transferred to a strategic partner venture
(SPV).
Therefore, given BALTIC will have to develop and commit customers for capacity sales, the system
needs to be dependable and cost effective while serving higher demand areas. This includes
selecting the landing sites to coincide with identified data center markets in Denmark, Finland,
Germany, and Sweden, as well as coordinated with the local central business districts or CBD.
BALTIC is designed to:
1. Utilize proper cable protection (e.g., ICPC standards) to maximize reliability and reduce
repairs
2. Avoid geopolitical areas such as the Nordstream Pipelines
A standard submarine cable system using open system architecture and quality construction
methods has been selected for BALTIC and is described through the Design Plan within this study
and supporting DTS.

1.3 Technical Overview

A Design Plan (DP) has been developed using input and analysis using APTelecom Subject Matter
Expertise and other research sources. In general, BALTIC is a standard system with a standard and
concise set of design principles and key design decisions (KDD). The DP presented considers
additional details to provide further insight, basis of analysis and to complete the cost model for
the investment and operations of BALTIC.

Figure 1: BALTIC Technical Overview

The BALTIC design is summarized as follows and illustrated in Figure 1 and Figure 2:
1. Design Life of 25 years.

06 April 2023 | Page 3 of 95 | Version 1.0

 2. 24 Fiber Pairs (FP).
3. 1,214km trunk made of 3 segments with Beach Manhole (BMH) locations in:
a. Rostock, Germany
b. Helsinki, Finland
4. Passive branches to:
a. Copenhagen, Denmark of 63km
b. Stockholm, Sweden of 72km
5. CLS located within 5km of BMH
6. Dual ended PFE for trunk with single end resiliency
7. Wavelength/spectrum selectable BUs to allow for granular routing of capacity
8. Optical plan to capable of supporting 20 Tbps per FP using 50 wavelengths at 400Gbps using
current proven SLTE1.
9. New Network Operations Center (NOC) in [Germany].

Figure 2: BALTIC Route Summary

1.4 Operational Overview

From an O&M perspective, wet plant repair, transmission system operations and maintenance,
system monitoring, onshore facility inspection and maintenance, system engineering, and system
provisioning will be required. It is assumed the SPV will be a new submarine fiber owner and
operator and will have new and dedicated Network Operations Center facility. For BALTIC,
Germany was selected to the country of choice for the NOC as it is well established location at
one end of the trunk.

1 Technical specification will be written in terms of spectrum characteristics such as Width and optical budget.

06 April 2023 | Page 4 of 95 | Version 1.0

 Furthermore, the operator will have to design and implement an organization model including the
use of internal and contract resources along with support services. Key aspects of the organization
will include the following disciplines:
1. Administrative (e.g., corporate, HR, procurement, contracts, finance, facilities, legal)
2. Sales and Marketing (e.g., customer interface, advertising)
3. Operations (e.g., NOC, field technicians, wet plant maintenance, projects)
4. Engineering (e.g., Lifecycle management, upgrades, capacity, provisioning, projects)
Development of this new organization should begin no later than the start of the marine
installation program so that personnel, especially technical, can be part of the system installation,
commissioning, and acceptance. In addition, development of the NOC and integration with the
NMS can occur in parallel to be in a ready to operate state when the system achieves RFS/RFPA.
The Operations and Maintenance model should deliver the following key performance metrics
and targets:
1. Time to detect failure and initiate investigation by NOC of 30 minutes;
2. Total (failure to resolution) target onshore repair time of less than 4 hours;
3. Time to initiate mobilization of repair vessel with 24 hours;
4. Target time to repair cable failure of 7 days;
5. Complete routine inspections and maintenance on a defined schedule.
To accommodate the above metrics, the critical factors of the O&M model are defined as:
1. Defined roles and responsibilities with training requirements using existing model;
2. Utilization of inhouse and contract staff in conjunction with Supplier services;
3. 24x7 NOC located in Germany;
4. Monitoring and alarming of security, facilities, and transmission;
5. Field technicians stationed within an hour travel of each CLS;
6. Deployed spares near each CLS;
7. Defined maintenance and inspection plans;
8. Participation in a vessel repair club with a pre-defined maintenance authority;
9. Wet plant spares held near the cable route at both ends.
As the landing locations are in developed areas with existing submarine cable systems installed,
finding personnel and services suitable to support BALTIC will be reasonably successful. The key
to this will be to ensure candidates and potential support contractors are well vetted, properly
trained (internal and external) and on-boarded to be competent in their roles. And finally,
allowing ample time to bring the organization together to be ready for service.

1.5 Sustainability
The number one area to make a submarine cable system more environmentally friendly is using
green energy sources at the shore ends. Once final landings and surrounding amenities have been
established and identified, respectively, sustainable options for power options can be identified.
Incremental improvements mainly through managing fuel consumption can also be found through

06 April 2023 | Page 5 of 95 | Version 1.0

 route optimization which minimize burial of cable due to the slower speeds and high RPM to pull
the plough (as well as additional armoring of the cable).
If desirable, as project implementation and further development a Sustainability tract can be
added to BALTIC to monitor and optimize during future engineering phases. Such a program would
include:
§ Develop an RFP specification and evaluation process to measure Supplier capability
§ Model the BALTIC system (APTelecom sustainability modelling) to give conceptual view
§ Generate a list of metrics in terms of km or per day to use for decision making.
§ Maintain a log of decisions made to identify engineering contributions to sustainability
§ Research power sources to identify green sources and develop a method to integrate
A significant initial target will be to get the Suppliers engaged in BALTIC’s sustainability initiative
(if elected to do so). This is due to the relatively immature state of sustainable practices in the
submarine cable system. While it can be done easily at the CLS with green energy, the
manufacturing and installation are very much in an incremental approach at this time. BALTIC can
help to further the industry’s sustainability approach and use that as a marketing tool.

1.6 Project Delivery and Milestones

Figure 3 provides a high-level Gantt Chart for the three to three-and-half year BALTIC
implementation starting with the planning face which this study and the attached DTS are the
primary technical deliverables. This is also the period where the business analysis piece is done to
ensure there is an overall business case. The major project execution sans the customer
engagement is shown in the provided chart and highlights a few dependencies such as
procurement drives the Supplier initiating work with the Route Survey and system design
activities.

Figure 3: Project Gantt Chart

As this is a high-level chart, the actual project plan will be developed towards the end of the
procurement phase once Supplier plan of work is provided and integrated. During the integration
of Purchaser and Supplier work plans, there are a couple of critical items to consider and properly
document and place focus:
1. Scope of responsibilities between Purchaser and Supplier along with interdependencies.
2. Third party dependencies such as permits and land acquisition which can impact design.

06 April 2023 | Page 6 of 95 | Version 1.0

 3. Operational readiness to ensure support models are on board and trained on BALTIC.
Care needs to be taken as to not just focus on the System Supplier deliverables but also on the
Purchasers deliverables to deliver a complete and operating system ready for Customer traffic.
This also means getting Customers signed up the investment funds secured early in procurement
is paramount to project success including Supplier commitment such as survey and installation
vessel windows.
Based on the current understanding of the project structure, a full turnkey project is
recommended with the use of third-party project management and Purchaser Representatives.
The full turnkey solution includes construction of the CLS facilities at each landing and all portions
of the System between the CLS including dry plant and submerged plant. There is some possibility
to pull out the facilities especially given the local of the CLS in developed areas, but this will add
to the internal Purchaser team (badged or contract) resource needs.
Again, all the above continues to support the need for management through good industry
practices with competent resources to manage the details. This can be aided by keeping the
technical specification to higher level and allow the proven Suppliers to implement their well-
established solutions versus telling them how to do each step they take (possibly out of their
normal/efficient way).

1.7 Delivery and Risks

Most of the risks for delivery of BALTIC fall within the standard realm of those for submarine cable
systems though there should be a specific emphasis to ensure an acceptable route, cable types
and protection are finalized. BALTIC is designed to use standard and proven technologies which
mitigates those risks, and the system is relatively small versus a trans-oceanic system (25% the
length) which reduces the technical demands on the design and eases any concerns over power
level. In fact, this system has some similar lengths which are consistent with an Oil & Gas system
which has been successfully operating in the Gulf of Mexico for more than fifteen years though it
is a two-pair system, but it is a good validation point that APTelecom is well familiar with
throughout its lifecycle.
From a risk perspective, risks have been examined from an overall project perspective and from a
delivery perspective. The project perspective are those things that impact the overall project and
include items such as:
1. Ensuring funding is available in line with the delivery schedule to allow CIF to take place
2. Purchaser/Owner organization is defined to ensure quality project governance
3. Business case has high enough confidence to support true cost to build and operate
4. Mitigating any political risks that would impede the project from moving forward as planned
5. Finalizing the cable route, cable types and installation methods for acceptable protection
As noted, the delivery risks are the typical ones as they relate to:
§ Controlling changes to design and system with material impact to cost and schedule
§ Full comprehension of roles and responsibilities and inter dependencies to maintain
schedule
§ On time manufacturing and delivering of materials and equipment throughout project
§ Securing land access and permits for system in a timely manner

06 April 2023 | Page 7 of 95 | Version 1.0

 § Timely detailed decision making such as system fiber map and CLS design requirements
§ Quality assurance and quality control to achieve 25-year operational life
The risks are best mitigated through sound project management skills with strong stake holder
commitment and confidence accompanies with competent engineering and surveys. This can be
achieved by assembly of a strong project management team with a trusted governance model.
Having a clean project plan which articulates the interdependencies and maintain it with up to
date and reliable iterations will be quite useful while also diligently tracking issues, decisions, and
related matters to ensure they are addressed effectively.

06 April 2023 | Page 8 of 95 | Version 1.0

2. CABLE SYSTEM DESIGN PLAN

2.1 Project Objectives

BALTIC project has been defined to provide connectivity in Baltic Sea to data centers in the
metropolitan or CBD areas in:
§ Denmark
§ Finland
§ Germany
§ Sweden
While there are other submarine systems in the Baltic Sea, these countries have been selected
due to their development and prospected needs for expanding connectivity. To support a variety
of needs and customers, the intent is to sell spectrum up to full fiber pairs whereby customers
can light their assigned capacity with SLTE of their choice. As the customer base will include OTT
providers and telecommunication capacity, BALTIC is designed to:
§ Maximize capacity based on current technology
§ Optimize investment cost versus capacity and reliability decisions
§ Allow direct connectivity between any two landing sites

2.2 Project Design Approach

In consideration of the above objectives, a Design Plan for BALTIC has been developed as
presented within. The previous supplied objectives have been used as general requirements for
the project which has then fed a set of Key Design Decisions (KDD). The KDDs then feed a detailed
design plan as presented within this study. The final design plan is goes through various iterations
with stakeholders. This process is shown in Figure 4.

Identify
Identify Identify Make Key Design Document Design Subsequent Project
Market and
Assumptions Requirements Decisions (KDD) Plan Phases & Activities
Purpose

Supplier, Project,
Feedback Impact
Customer
Analysis & Reiterate
Feedback

Figure 4: Design Plan Development Process

As part of this Feasibility Study, the design plan is the core behind all other aspects of this study
including:
1. Cost Model development
2. DTS and RPL generation
3. Risks, issues, and opportunities identification
4. Operations and Maintenance strategy
5. Permitting research
6. Schedule and delivery approach

06 April 2023 | Page 9 of 95 | Version 1.0

 In addition, the design plan provides the technical basis for meeting with potential stakeholders
to describe the technical solution.
Once the project proceeds into the next phase, which will be procurement, along with land
acquisition and permitting application, the design plan is critical for:
1. Development of the Invitation to Tender and especially technical specification
2. Stakeholder negotiations including capacity commitments
3. Landing finalization
4. Project plan and budget development
Each of these activities will result in fine tuning of the design plan and subsequent technical
specifications especially when it comes to capacity planning. As such, within the design plan, there
are open items to be addressed as details are agreed amongst parties. However, assuming there
is no change in landings and general architecture, the impacts are normally minimal as the cable
route itself is fixed with tweaks.
Each change to the Design Plan during ongoing system development will need to be evaluated for
technical, financial, commercial, timeline and operational impacts and the consequential impacts
will have to be incorporated into the relevant models and plans. Some changes are primarily a
cost benefit decision such as number of FPs which will be finalized during System Supplier
selection process based on proposed costs.
However, for example, if a location changes to another area, what impacts in length does it have
on the construction and integrity of the OSP between the BMH, CLS and Data Center? Likewise, if
a higher cost technical solution is selected, is the financial model still viable? In the case of BALTIC
with branch legs, does change in a branch length require a change in the optical plan such as
addition of repeaters on the branch legs.
In general, the Design Plan and DTS provide sufficient information for the development of the
technical specifications. Furthermore, most Suppliers can use the design plan to develop a
solution based on their typical system plans to provide an initial cost and technical plan. The
remainder of the technical specifications are put in place to codify additional details in the event
there are future problems and deficiencies. In addition, the technical specification provide clarity
on roles and responsibilities.

2.3 Key Design Elements

As discussed previously, the KDDs for BALTIC were created from an evaluation of the business and
project objectives provided along with other expertise. They are presented Table 1: Key Design
Decisions. The landing coordinates provided are based on the work done within the DTS to identify
a route and are subject to change in future project phases but as provided give reasonable
information to proceed with planning. Additional detail on the landings will be provided in the
DTS.
One of the most important KDD is the selection of a Trunk and Branch solution versus a landing
to landing. This design decision when supplemented with a goal to have passive branches is felt
to be the most optimal cost while also maximizing the integrity of the system. The cost
optimization is a result of:
1. Only two sets versus eight sets of PFE as only required on trunk
2. Four versus six shore ends in a festoon model

06 April 2023 | Page 10 of 95 | Version 1.0

 3. No repeaters on the branch legs
4. Fewer sets of SLTE (customer scope)
The proposed architecture maintains integrity by allowing any single station to go offline (optically or
trunk power) and the remaining landings can continue operate because of:
§ PFE at either end of the trunk can rebalance as to maintain repeater power across the
system
§ The branches create no dependency on other branches or the trunk
Thus, through this architecture and a proper fiber map, the ROADM BUs can redirect traffic to the
desired landings allowing for any to any connectivity while not passing through another landing.
Applicable KDDs used are as follows:
Table 1: Key Design Decisions

Item Decision Basis & Alternative

Telecommunications Capacity
00 § Business Objective
System between identified landings

01 Open Architecture § Each customer will bring their own SLTE and
manage in a way they best see fit.
Maintain proximity to established § Target customer base will OTT and
02
Data Center Telecommunications with Data Center needs.
Rostock, Germany
03 § Based on Desktop Evaluation
54.1772 N / 12.0531 E
Copenhagen, Denmark
04 § Based on Desktop Evaluation
55.5859 N / 12.6716 E
Stockholm, Sweden
05 § Based on Desktop Evaluation
59.2922 N / 18.6952 E
Helsinki, Finland
06 § Based on Desktop Evaluation
60.1461 N / 24.8810 E
Avoid conflict/crossing with
07 § Geopolitical stability
Nordstream
Route should be compatible with
08 § Similar project goals and needs
Sea Lion
09 24FP capable of supporting 20 Tbps § Standard capacity – will also discuss spectrum
10 Selling FP and Spectrum § Stated business objective
Landing sites outages will not impact
11 others (no single landing site can be § Reliability
catastrophic)
§ Optimize cost with a trunk and branch
12 Architecture Trunk & Branch
§ Remove landing interdependency
Trunk Rostock to Helsinki
§ Large sites and most distant
13 12 FP express
§ Evaluate fiber mapping in details
12 FP shared all sights
Branches – Stockholm & § Required for connectivity
14
Copenhagen 12 FP § Evaluate fiber mapping in details
15 Branching Units – ROADM/WSS § Required for connectivity

06 April 2023 | Page 11 of 95 | Version 1.0

 Item Decision Basis & Alternative
§ Evaluate fiber mapping in details
16 Active Trunk with repeaters § Required due to length of system at [1200]km
Passive (no repeaters) branches § Simplicity, resiliency, and cost
17
where possible § Review of Stockholm in engineering
PFE is dual fed with single end § Most reliable
18
capability for resiliency § Resiliency with the two branches
Engineered Availability of 99.99%
§ Best practice for critical telecommunication
19 (excluding external aggression such
systems
as cable damage)
§ SLTE extension beyond will require additional
Cable Landing Station to have PFE
20 engineering to ensure amplification (detailed
and SLTE housing
technical planning)
21 Proven technologies to be used § Minimize technical risk and RFS date variance

System will straight § Lowest cost solution

22 telecommunication cable with no § Smart Cable business case does not exist for
SMART sensor technology Baltic
§ On the trunk
23 Single NOC in Germany § Established area with access
There is no cable redundancy and
24 Customers will by traffic from other § Cost and complexity to build
systems

2.4 Future Decisions and Considerations

During future phases of the project through contract forming with the System Supplier, there are
multiple significant items to be addressed which may have a material impact on the final system
Architecture and Design. The source of these items could be from:
1. Deferred decisions during the feasibility space
2. Changes in philosophy on the KDD basis as the business case evolves
3. Input and deeper clarity from partners and customers on their needs
4. Supplier input
5. Regulatory and permitting learnings
6. Land access and acquisition learnings
7. Other conflicts and learnings warranting change
These open items do not include routine engineering changes such as Cable Route Engineering
which is focused on optimizing what is in place and incorporating learnings from the Marine
Survey and burial assessment studies. Impacts of CRE can impact cost and time through changes
such as:
§ Variance in route and subsequent length
§ Number and methods of cable and pipeline crossings

06 April 2023 | Page 12 of 95 | Version 1.0

 § Variance in length, depth, and methods for burial along route
§ Cable armoring selection
Table 2 highlights the most impactful issues to be addressed and discusses specific sources of
input, impacts, considerations, and decision timing. Most will need to be addressed prior to
completing the contract with the System Supplier to minimize change orders and subsequent time
and cost impacts.

Table 2: Open Items

Open Item Inputs Primary Impact

Final Locations for Land acquisition § Methods of construction (cost
landing sites (BMH and and time)
Permitting
CLS) § System route length and
Stakeholder requirements complexity (cost)
such as integration with Data § Terrestrial and OSP route length
Centers and design (cost and time)
Final termination points Stakeholder requirements § Space agreements (cost)
for BALTIC (data center § Terrestrial network build (cost
Terrestrial network options
or CLS) and time)
Optical design plan limits § CLS design (cost and time)
Finalize Fiber Pair Stakeholder requirements § Fiber pairs in cable and
mapping between repeaters especially if required
Business plan
endpoints on branch legs (Cost)
BU mode selection
Validate mode of Stakeholder requirements § Capacity management options
operation for branching (quality)
Business plan
units (ROADM/WSS, § BU selection (cost)
Switchable Fiber or Fixed Cost and complexity § Fiber pair mapping
Fiber)
CLS Design Customers § Building size (cost and time)
§ Land size required if significant
Business case for building
increase in size (cost and time)
(e.g., Data Center included?)
Internal available Business case for capacity § Quantity of SLTE (cost)
capacity (e.g., Supplier sales and internal capacity
SLTE) needs
PFE in branch legs Final branch leg length and § Need for repeaters and PFE on
optical plan will determine branch leg (Cost)
needs
Final NOC locations Operations model § Dual NOCs require additional
including secondary NOC hardware and support
SPV members
resources but give resiliency
Cost to build and operate (cost)

06 April 2023 | Page 13 of 95 | Version 1.0

 Open Item Inputs Primary Impact
Finalize Burial Plan Burial Assessment § Effort and methods of
construction (cost and time)
Further Risk Review
Final cable armoring Burial Assessment § Effort and methods of
levels construction (cost and time)
Further Risk Review
Shore end construction Cable route engineering § Effort and methods of
method (HDD and PLSE) construction (cost and time)

Table 2 shows that there are limited and typical open issues which will get addressed during
normal engineering and land acquisition processes and finalized during contract forming. The
biggest impacts are related to the final cable route engineering and the associated cable type
selection, burial, and shore end installations. With respect to adding PFE on the branches, the
preliminary RPL appears to be adequate even with future modifications to avoid this need though
continued conversation with the Suppliers will further help to mitigate in case the branch legs
expand more than 20-30km.
However, should the underlying business objectives change such as the system becoming used
for alternate purposes such as long-term sensors and monitoring, then there would be a need to
revisit the entirety of the System KDD and the initial RPL supplied in the attached DTS to ensure it
meets the details of the modified business objectives. For example, if a sensor network were to
be added, the cable system would need to be located where the monitoring needs would be
desired.

2.5 System Description

2.5.1 General

2.5.1.1 System Layout

BALTIC is a planned 24FP submarine system using Open Architecture. It will use a trunk and branch
architecture with a trunk length of 1,214km between Rostock and Helsinki and a pair of branch
legs of 63 and 72km respectively to Copenhagen and Stockholm. The overall system length will be
around 1,347km between the trunk and branches.
The trunk is divided into three segments along with the two branch segments as shown in Figure
1. The lengths and fiber counts are shown in Table 3. The fiber count and length will be adjusted
as open items are closed out and the cable route is engineered per the supply contract. However,
the changes will be limited to approximately 5% of total route length. The fiber pair count will be
driven by evaluation of the capacity needs between endpoints and could be as high as twenty-
four pairs.
Table 3: Segment Table

Segment Endpoints Length Fiber Pairs

1 Rostock & Copenhagen BU (1) 120km 24
2 Copenhagen BU (1) & Stockholm BU (2) 702km 24

06 April 2023 | Page 14 of 95 | Version 1.0

 Segment Endpoints Length Fiber Pairs
3 Stockholm BU (2) & Helsinki 392km 24
1.1 Copenhagen BU (1) & Copenhagen BMH 63km 12
2.1 Stockholm BU (2) & Stockholm BMH 72km 12

With twenty-four fiber pairs in the trunk which are fully terminated in Rostock and Helsinki, initial
capacity would be assumed to be 20 Tbps per FP for 480 Tbps in total capacity across the trunk.
The capacity will increase over time as SLTE becomes more efficient in the use of spectrum.
Repeaters will be located between 70 and 80km apart on the trunk resulting in around sixteen
repeaters. Actual repeater spacing and count will be determined by the Supplier as part of the
optical budget design. No repeaters are expected in the branch legs.
Once onshore, the submarine fiber will terminate in a BMH located near the shoreline. Land cable
will be used to extend to a dedicated CLS facility in at each landing where Customers will install
their own SLTE. In addition, the CLS will support domestic carrier installation of terrestrial fiber to
extend the capacity further inland to data centers, carrier facilities and other end users. As noted
previously, a decision to place SLTE in data centers may be made, however, the CLS will remain to
house the PFE though it will be smaller footprint.

2.5.1.2 System Latency

System Latency or Round-Trip Delay (RTD) depends upon the speed of light in glass (5
microseconds/km), the length of the optical system and the time it takes the SLTE to convert the
signal from electrical to optical and back at the other end. SLTE will add approximately 0.08msec
per end (0.15msec roundtrip). System Latency can be an important consideration for some of
BALTICS customers including financial markets and Hyperscalers. Table 4 provides an estimated
latency which can be stated as about 6ms maximum for BALTIC.
Terrestrial routes will add additional latency at a similar length to time ratio. Final latency will be
measured during the commissioning phase and compared to the expected based on final route
lengths and other impediments such as SLTE and amplifiers to verify it is within design
specifications.
Table 4: Latency Estimate

Endpoint 1 Endpoint 2 Length Maximum Round

Trip Latency (ms)
Rostock Copenhagen 183 2
Rostock Stockholm 894 9
Rostock Helsinki 1,214 13
Copenhagen Stockholm 837 9
Copenhagen Helsinki 1,157 12
Stockholm Helsinki 464 5

06 April 2023 | Page 15 of 95 | Version 1.0

2.5.1.3 System Availability
System Availability is calculated using traffic effecting failures. Non-traffic components failures
such as supervisor or monitoring systems are not part of the availability. In addition, due to the
challenges in calculating onshore and marine cable damage and the extended time to repair, cable
damage is not included.
The key targets for system available are:
§ 99.99% system availability (based on engineering calculations) excluding cable damage;
§ No more than 1 ship repair for failed wet plant repeaters and BU’s during life;
§ 4-hour onshore repair time at CLS and DSL;
§ 14 days to repair a marine cable failure noting the operational plan is to be based on a 7-day
target; and
§ 7 days to repair an onshore cable failure noting the operational plan is to be based on a 4-
day target.
In addition to the exclusion of cable damage being considered in the calculation of the system
availability target, it is critical to note this is not a true operational value. It is an engineering
statistical calculation that considers Mean Time Between Failure (MTBF), Mean Time to Repair
(MTTR) and levels of redundancy. An evaluation of mean time between failures highlights these
times are measured in terms of multiples of years. Thus, an actual outage in any one year is low
probability, but the time to repair may take multiple hours as shown in the above target. Thus,
while four 9’s is about 50-55 minutes per year, it is not realistic for a repair to occur under an hour
if equipment must be replaced and personnel dispatched, which is shown in the four-hour
onshore repair time. Therefore, the use of availability in terms of percent is to assist in design of
the system including redundancy and operating models.
It is more important to understand single points of failure where the system will stop full duplex
transmission and determine mitigation needed and the time to repair. BALTIC does not have any
single points of failure whereby no landing station can talk to at least one other landing station.
However, there are certain failure modes which are worthy of identification and how they have
been mitigated. Many would become catastrophic if secondary conditions such as loss of both
trunk landing stations are realized.
Table 5: Failure Modes (Critical)

Failure Impact w/o Mitigation Mitigation

Unstable utility Loss of specific landing station ability Online battery backup for
power – intermittent to tx/rx traffic. transmission components (PFE,
SLTE, Terrestrial Interface) of at
If at Trunk CLS, then loss of
least 8 hours
redundancy in PFE.
No optical impact elsewhere.
Loss of utility power - Loss of specific landing station ability Online battery backup for initial
persistent to tx/rx traffic. outage for transmission
components but no HVAC
If at Trunk CLS, then loss of
redundancy in PFE.

06 April 2023 | Page 16 of 95 | Version 1.0

 Failure Impact w/o Mitigation Mitigation
No optical impact elsewhere. Generators for full system
powering including HVAC and
extended outages
Loss of 48Vdc Loss of redundancy in PFE. N+1 design for full system power
Rectifier at Trunk CLS rectification
No optical impact
Loss of PFE module Loss of redundancy in PFE N+1 design
No optical impact Dual end fed with load balancing
up to 100% single end fed capacity
Shunt Fault in No optical impact Dual end fed with load balancing
submarine cable
Possible isolation on either side of
shunt fault if CLS loses power
Faulty smoke or fire Non-necessary release of fire Dual positive detections before
detection suppression causing damage to fire suppression and shutdown are
equipment executed.
Failed HVAC Heat damage to equipment Dual systems with lead-lag design
to manage peak load efficiently

Calculations for reliability are further explained below for Dry Plant, Wet Plant and OSP.
For the Dry Plant failure (except OSP), the 99.99% is based upon a MTTR of four hours. Since spares
are expected to be provided on-site for all critical components, the MTTR represents the mean
time required to detect a failure, dispatch a technician, arrive at location, identify, and locate the
faulty element and replace it with a spare. Unavailability is calculated for all elements and the sum
of all the contributions gives the overall unavailability. In the case of a network with protection,
unavailability of the independent paths is multiplied to give the probability of all of them failing
at the same time. From an operational perspective, the focus in on ensuring the four-hour repair
time can be achieved by having the necessary monitoring, trained personnel, available personnel
within reach of the sites and spares on hand. The failure rate or MTBF is driven by manufactures
of equipment and the reliability of their parts over time. MTBF can decrease over time as
equipment ages.
For a Wet Plant failure, the convention is to quote the expected number of repairs requiring a ship
repair during 25 years at the 95% upper confidence level. The time to repair will be measured in
weeks due to the need to mobilize and transit a vessel to the repair site, onboarding the necessary
spares and complete the repair. For example, a repair will require at least two splices each taking
up to 24 hours. This covers failures to cable, repeater, equalizer, or BU which are traffic affecting
and excludes repairs due to damage by external sources (manmade or natural phenomena), which
are impossible to estimate. To minimize the number of estimated ship repairs over the system
life, a certain amount of redundancy is generally included in the repeaters. To ensure the required
amplifier reliability is met, redundant pump laser configurations are employed. Also, the PFE
power rectifiers contain multiple serial-parallel redundant configurations to ensure their reliability
does not affect the operation of the system. The reliability budget is estimated assuming the

06 April 2023 | Page 17 of 95 | Version 1.0

 submarine link is still within its performance when one of the lasers of some amplifiers goes out
of service.
For OSP, it is managed in a similar manner to wet plant. The time to repair is the primary driver as
the OSP is normally passive and not subject to electrical failure so the MTBF outside of external
damage is minimal. Time to repair is managed by having spare cable and components readily
available and having a crew available to quickly mobilize to affect the repair.
As a caveat, System Availability calculations must be evaluated as to business value and end-user
expectations. Decisions may require strategic trade-offs with cost, performance, and security; and
decision makers need to ask questions beyond the system dependability metrics. Careful business
evaluation is needed when establishing Service Level Agreements (SLA).

2.5.2 Wet Plant

2.5.2.1 Landing Points

The landing points presented within the Design Plan represent the pre-survey and pre-land
acquisition locations chosen to support a route selection and DTS as part of completing this
Feasibility Study. A full Marine Survey with a CRE working group should finalize the route to
optimize protection, cost, length, and permissions. Selection of sites was accomplished with direct
consideration for proximity and access to renewable power to align with project goals. Based on
a review of permitting requirements, there does not appear to be any contraindications to the
selected sites. However, this may change once engagement on land acquisition commences.
As the Marine Survey, cable route engineering and land acquisition proceeds, the landing points
will be refined. Consequentially, updates to location of the BMH, RES location, OSP route, CLS site
plan and RPL will be required and ideally stay near the currently prescribed locations. Locking
down these locations and securing the necessary construction permits is critical to project
timeline. Any actions taken to improve confidence and secure these locations including work prior
to issuance of RFP will help reduce overall project risk to cost and time. Many submarine cable
projects have been delayed and taken on additional costs because of delays in landing point
acquisition delays.
For BALTIC there will be four landing sites which in totality will include:
§ Beach Manhole location where the submarine cable will be joined to land cable.
§ Cable landing station where the fiber will terminate, and trunk will have PFE
§ Return to Earth System at the landing sites for the Trunk.
§ Duct bank with land cable between the BMH and CLS.
The four landing points new for the BMH, CLS, and RES. In addition, the Purchaser will need to
work with other organizations to engineer, procure and build a terrestrial network to interface
BALTIC with the domestic environment.
The preliminary locations per the DTS and RPL for the BMH is provided in Table 5. The locations
for CLSs and BMHs will need to be updated as final land and route selection processes are
completed. It is assumed the CLS locations will be within 5km of the BMH. Longer distances are
possible but will need to be determined prior to the issuance of the Invitation to Tender as it may
impact the optical system design and location of repeaters.

06 April 2023 | Page 18 of 95 | Version 1.0

 Table 6: BMH Locations

Landing Coordinates
Rostock, Germany 54.1772 N / 12.0531 E
Copenhagen, Denmark 55.5859 N / 12.6716 E
Stockholm, Sweden 59.2922 N / 18.6952 E
Helsinki, Finland 60.1461 N / 24.8810 E

2.5.2.2 Route Design and Cable Selection

As part of the DTS, a 1,347km route has been identified. The route was developed using general
guidance from APTelecom during a kickoff meeting. This initial information was then used in
conjunction with the KDD to identify a route. It was then optimized based on available data to
optimize. Currently, there are 19 identified cable crossings to be managed in BALTIC.
The Baltic Sea is shallow at less than 500 meters. Normally, this would require 100% burial but
that would most likely not be feasible or cost effective to bury the entire route. Therefore, as
shown in subsequent sections on the shore-ends, there is about 58km of burial recommended.
This will need to be revised during cable route engineering and the Marine Survey along with
burial assessment. As some areas will be more difficult to bury as they are stone and decision will
have to be made on how to handle including rock dumping.
The cable selection is shown in Table 7 and Figure 5. The cable selection was driven by heavier
armoring near the shoreline and where there is burial. In the unburied sections, lighter weight
cable using SA and LWP was selected to optimize system cost. Route engineering may recommend
further up-armoring for protective reasons.
The area in the Baltic Sea provided several challenges to find a valid route. While these are typical,
some of the constraints included:
1. Wrecks
2. Water depths
3. Islands and narrow land mass separations
4. Existing cables for telecommunications and power
5. Other at sea conflicts (buoys)
6. Wind Farms
7. Vessel channels
8. Crossings path constraints
All these together provided some interesting decisions to be made. Many which might be
challenged rightfully during cable engineering and verified during the Marine Survey to finalize
the route. Hopefully, these future processes can bring value to the preliminary work provided
within this report and DTS.

06 April 2023 | Page 19 of 95 | Version 1.0

 Figure 5: BALTIC Straight Line Diagram

Table 7: Cable Lengths by Type

BALTIC
Cable Summary
Segment Cable Type Length (km)
Trunk DA 52.187
Trunk SA 196.074
Trunk LWP 965.569
Copenhagen Branch DA 34.438
Copenhagen Branch SA 28.486
Stockholm Branch DA 34.438
Stockholm Branch SA 28.486
Total Subsea System Length 1,347.57

DA (5% Spare) DA 5.62

SA (5% Spare) SA 13.49
LWP (5% Spare) LWP 48.28
Total Spare 67.38

Contract Length 1,414.95

* All lengths are in km

* Preliminary CRE, subject to complete route engineering based upon cable route survey results, BAS, and
other studies to be performed in future project phases.
DA = Double Armor (Submarine)
SA = Single Armor (Submarine)
LWP = Light Weight Protected (Submarine)

2.5.2.3 Shore Ends

The shore ends will be challenging on BALTIC as they will need to be pre-laid shore ends (PLSE)
where the water depth is shallower than 15meters as marine cable ships are not able to operate

06 April 2023 | Page 20 of 95 | Version 1.0

in these waters. Also, in a look at Figure 6, the complexity of the landings including the items listed
previously on route design constraints highlights the challenges in weaving a cable into the
location shore end.
Current expectations are that PLSE will be required for Copenhagen, Stockholm and Helsinki and
will each be several kilometers in length. The actual length will be determined by the Supplier
based on their selected vessels and other factors. Rostock may require a PLSE which will be
determined during system engineering. Table 8 provides a look at burial on the shore end
approaches and the bottom composition.
Figure 6: Copenhagen Approach

Table 8: Burial on Approach

Landing Burial (km) Bottom Composition

Rostock, Germany 16.3 Gravel
Copenhagen, Denmark 19.64 Gravel & Sand
Stockholm, Sweden 6.3 Cobbles (low burial)

It is important to remember that at the shore ends, the CLS sites will need to be selected and are
currently estimated to be within 5km of the shore landing and BMH. These sites will need to be
identified based on:
§ Land availability
§ Constructability
§ Access to utilities
§ Access to terrestrial network
§ Access for travel and deliveries

06 April 2023 | Page 21 of 95 | Version 1.0

2.5.2.4 Branching Units
BALTIC will have two BUs installed to support each of the branch legs. As previously noted in Table
2, there is a decision to be made on which form of BU should be utilized. From a feasibility analysis,
this is not a significant item to finalize at this point and is better left once stakeholder
requirements are captured and capacity plans and management can be defined.
ROADM is the preferred solution for BALTIC to support any to any landing optionality for capacity
management and allow that to be modified as demand expands and is provisioned. Within this,
there is an option to switch fiber pairs or specific spectrum at each BU down the trunk or to the
branch leg. The exact specifications will be defined during the writing of the technical specification
with confirmation from potential Suppliers on their options. This is an area of development, and
it is important to ensure for competitive reasons to minimize the risk of creating a sole source
solution.
Most likely, a solution like ASN’s 3D Bidirectional ROADM Technology will be selected as illustrated
in Figure 7. One expects it to use WSS where customer might by a Fiber Pair and then manage
capacity across the landings as they see fit.

Figure 7: ASN ROADM Solutions

Installation of the BUs will be accomplished via normal methods and is easily achievable as the
separation between them well exceeds the 2-3 times water depth minimum.

2.5.2.5 Repeaters
Due to length of the trunk, repeaters will be used in BALTIC. The anticipated number of repeaters
is approximately 16, based on a 75km average spacing. One or two additional repeaters may be
utilized near the BUs to ensure adequate optical power on the branch legs. The System Supplier
will determine this in their optical model. Likewise, final placement and quantity of repeaters will
be calculated while ensuring an acceptable OSNR during system planning during the procurement
phase to ensure the correct number of repeaters are manufactured and priced. It is anticipated
that spacing could up to 90km given the roughly 1,200km length of the system as compared to a
longer transoceanic system.
As proposed, the BALTIC is a 24FP system and all repeaters in the trunk will amplify all FPs. If the
number of FP is changed, the repeaters will need additional modules and become more expensive.

06 April 2023 | Page 22 of 95 | Version 1.0

 Installation of the repeaters will be done via normal methods. Resiliency in the repeaters is
accomplished through additional amplifier models which can be applied as needed. It is expected
in general repeaters will not fail during the design life though system design allowances are made
for 1 or 2 failures during the life.

2.5.3 Dry Plant

2.5.3.1 Outside Plant

At each of the landing locations up to 5km of outside plant or land cable is anticipated to extend
the submarine cable (optical and electrical) from the BMH to the CLS. The final length will be
determined once a location for the CLS is made and the location of the BMH is confirmed. Once
these locations are selected, a route for the OSP can be defined accordingly.
Permits and right of way easements will be required to build the route. The ideal route will be
buried conduit with three ducts of at least 110mm in diameter. The route will contain fiber optic
cable, power cable and ground cable. The OSP will be placed in a duct system buried to a depth
based on practices and allowance sin the area (circa 1meter below grade). None of the area are
expected to have permafrost so the depth will below any documented frost line, The power and
ground will be tied into the PFE, RES and the submarine cable system to power the repeaters.

2.5.3.2 Optical Budget

The optical budget is determined based upon a combination of:
§ The optical spectrum (expressed in nm);
§ The optical output power of expected SLTE and repeaters (expressed in dBm);
§ The loss of the optical fibers (expressed in dB/km);
§ The loss through BUs, splices, and equalizers (expressed in dB);
§ Chromatic dispersion of the fiber (expressed in ps/nm/km);
§ The optical receive sensitivity of the SLTE and repeaters (OSNR - expressed in dB/0.1nm);
§ Propagation impairments (expressed in dB);
§ Manufacturing and unallocated margins (expressed in dB);
§ Allowances for repairs (expressed in dB);
§ End of Life margin (expressed in dB); and
§ Purchaser requirement margin (expressed in dB).
The System Supplier will choose the appropriate commercially available fiber to optimize these
parameters to maximize capacity while minimizing system costs. The fiber(s) will meet the ITU-T
recommendations, e.g., G654. The Suppliers use proprietary simulations and testbeds to
maximize the system performance. These parameters will be compatible with the SLTE Suppliers’
equipment. Each Submarine System Supplier will propose different systems with different
parameters, but the Table 9 contains an example of typical values:

06 April 2023 | Page 23 of 95 | Version 1.0

 Table 9: Typical System Parameters

Parameter Typical Value

Optical Spectrum (C band) 1529nm to 1568nm

Fiber Attenuation 0.155 dB/km

Chromatic Dispersion 22 ps/nm/km

Repeater Output 19 dBm

OSNR 17.2 dB/0.1nm

Propagation Impairments 1.0 dB

Repair Margin 0.5 dB

Aging Margin 0.5 dB

Purchaser Margin 0.5 dB

2.5.3.3 SLTE Equipment

No SLTE is provided as currently planned for BALTIC as it is an open cable system.
The System Supplier will need to ensure the proper optical multiplexors are in place to accept
plugging in in of SLTE from Customers. The System Supplier will provide details on this interface
which will be defined during the system design engineering process as generally defined during
the procurement phase.

2.5.3.4 Digital Line Segments

As BALTIC is an open architecture system, there are no DLS at build time. Each customer will
establish these as they design and implement their SLTE. The information provide here is
conceptual to provide an idea of the DLS engineering.
The system will operate in the optical C-band from approximately 1530nm to 1565nm. This
spectrum can be divided into wavelengths that will support the SLTE modulation format. The
number of wavelengths depends upon the modulation and the OSNR of the system. Some typical
numbers of wavelengths and bit rates supported on a single FP currently available are:

§ 100 λ x 100 Gbps = 10.0 Tbps

§ 90 λ x 200 Gbps = 18.0 Tbps
§ 50 λ x 400 Gbps = 20.0 Tbps
From a planning perspective, it could be assumed most SLTE will be use a 50 λ x 400 Gbps solution.
System Suppliers will be asked to confirm transmission and spectrum capacity options as part of
their proposal. Each customer will have to determine their own transmission plan based on the
spectrum or FP as they choose.

06 April 2023 | Page 24 of 95 | Version 1.0

2.5.3.5 Initial System Equipment and Wavelengths
No initial SLTE will be installed by Purchaser unless it is determined that there is a desire to have
capacity for either internal use including network management or bandwidth clients are
identified. This will have to be determine during the technical specification as noted previously.

2.5.3.6 Power Feed Equipment

The standard trunk powering configuration is dual-end powering, allowing for single-end
powering during shunt fault conditions (exposed electrical conductor including full cable cut). This
is so that traffic can be recovered/restored in the event of a single fault scenario. The expected
voltage for the BALTIC is around 10kV for the 24FP system.
Redundancy will be included in PFE designs for high reliability operation. For the Low Voltage (LV)
design, two identical and electrically independent power converters are utilized. The High Voltage
(HV) design uses an N+1 redundancy design. Three or more active converters provide the power
to the undersea system. If one of the converters shuts down, the remaining N converters
automatically adjust their outputs to support the load.
Figure 11 is one of several examples of the possible power configurations proposed by the
Suppliers in response to the RFI. This will be changed during the RFP process when more
information and constraints are known. The power configuration is designed to keep as much as
possible of the system operating if there is a cable fault or break anywhere in the system. The PFE
is sized for the ultimate capacity of the system and will not need to be expanded in the future.
PFE System Block Diagram

CTB BMH
Submarine Cable
Terrestrial Land Cable
System SLTE
Interface
Power Feed Line
Optical Fibers

PFE Sea
Earth

CLS

Sea
Earth

Figure 8: BALTIC Power Feed

2.5.3.7 Network Operations Center

BALTIC will have a primary NOC in Rostock. In the event the NOC fails, operations could be moved
to a CLS or alternate NOC. The Supplier will install their standard NMS tools at each CLS. These
will then be integrated into the NOC tools such as a manager of managers to create complete
alarming, notification, trending, and problem resolution capability. A set of terrestrial circuits
across other systems will be needed to tie the CLS NSM tools to the NOC to be able to interrogate
and configure the system via any landing during a normal and non-normal operational status. The
NOC facility will most likely require about 15-20 square meters to establish a few display screens
and workstations.

06 April 2023 | Page 25 of 95 | Version 1.0

2.5.3.8 Network Management System
BALTIC will have a dedicated NMS that will interface with the new NOC tools to provide element
management as well as general monitoring and alarming. Remote access to the NOC tools will be
provided current solutions. The NMS will use the Supplier’s standard tools as further specified in
the technical specification and provide command line and graphical user interfaces. It will also
have dry contact closure alarms for the CLs environment to enable on alarming across a multitude
of events related to:
1. System status
2. PFE status
3. Temperature
4. Security
5. Power
A critical tool will be the line monitoring equipment will monitor the optical quality of the fiber
pairs and generate reports when there are notable deviations from the accepted baseline. These
could be indicators of:
§ Damaged fiber
§ Degrading fiber
§ Repeater failures
§ Branching unit failures
Any of which will need to be corrected prior to there being a catastrophic unplanned outage.
Ideally, the LME will provide early notice to allow a planned repair with plenty of notification time
to customers so they can manage their traffic.
Furthermore, client systems to record and access surveillance such as CCTV will be in place at the
NOC. All traffic between CLS, Data Center and NOC will traverse the DCN which uses leased
circuits.
Monitoring agents will include software based and dry contact systems as allowed by equipment.
Monitoring will be done on:
§ Transmission and system performance;
§ Security including doors, fences, and surveillance;
§ Electrical and fuel systems;
§ Fire detection and suppression; and
§ Environmental.
The early and proper detection of failures or degradation in the above systems can allow for
prompt response to head off a more disastrous scenario or loss of service and related revenue.
This could include extended power outage, heat damage, fire damage, water intrusion and many
more.
Care should be taken to implement smart monitoring routines to identify and verify failures and
to ensure failures are brought to NOC operator attention promptly. If fault correlation tools exist,
they should be updated to consider the BALTIC.

06 April 2023 | Page 26 of 95 | Version 1.0

2.5.4 Site Facilities

2.5.4.1 Site Facilities Requirements

The CLS are significant component and independently an expensive system component to build.
They must meet space, power, terrestrial capacity access, security, accessibility, and reliability
requirements to meet the needs including:
§ Offshore transmission and power feed system
§ Data Center requirements
§ Secure colocation for telecommunications companies, OTTs and Hyperscalers for SLTE
§ Personnel including short term and overnight stays and workspace
§ Spare’s storage including indoor equipment, cable, electrical, fuel
§ Supporting systems such as HVAC, electrical, generators, toilets, water, kitchen
§ Parking and outdoor space
§ BMH and interconnecting cabling and duct work
§ Security and monitoring systems
All systems critical to operation will have a form of redundancy including:
§ Generators with a utility natural gas fuel supply and automatic transfer switch;
§ Dual HVAC with lead-lag capability to manage extreme conditions;
§ Batteries to carry critical load while generators “spin up” and allow for personnel to respond
if there is a generator or automatic transfer switch failover;
§ Rectifiers in N+1 quantity.
§ Dual fed PFE where PFE is redundant between CLS.
In addition, CLSs will have security and protection features including:
§ Overheat shutdown to protect equipment.
§ Surveillance cameras.
§ Fire alarm systems with multi-detect suppression activation.
§ Monitor points for temperature, water, and power reporting to NOC.
§ Remote access to building systems to monitor and administer.
Design details and implementation on CLS systems and OSP will be developed during detailed
engineering by System Supplier. Agreed standards and practices should specified in within the
Technical Specification to ensure Suppliers propose on an accurate and representable scope.

2.5.4.2 Site Plans

General
Presented is summary guidance on the site plans to aid in completing the study and visualizing
the BALTIC within the CSDP. As land has not been selected, there are many factors which will
influence each site plan. Efforts will be made to keep them as common as possible, but differences

06 April 2023 | Page 27 of 95 | Version 1.0

will occur. These differences should not impact functionality as functionality should be 95% or
more the same based on system design principles. Once land acquisition is complete, a final site
plan will be developed and will consider factors listed below.
§ Land parcel dimensions and shape
§ Location of access roads
§ Location of the BMH (inside the CLS or on the beach)
§ Terrestrial or OSP route to the BMH
§ Local permits
§ Elevation of CLS and nearby lands
§ Neighboring structures and lands
§ Final building sizes and layout
§ Alternate energy solution
§ Total site content including BMH, generators, buildings, parking, security, storage
§ Security requirements including 24x7 dedicated and limited access for Purchasers

Cable Landing Station Site Plans

At each landing, an approximate 0.25 to 0.5 acre space is necessary to house the CLS of ample size
for customer SLTE and needs. A sample high level layout of the space requirement is provided in
Figure 9 : Final design of Data Center site will be subject details previously mentioned. Each site
will be engineered on a site-by-site basis. However, the general layout of internal buildings and
systems will be nearly identical to maximize consistency in operations and functionality. One key
to the site plan is to ensure that delivery of equipment and fuel can happen in safe manner and
minimize driving risks such as tight corners and backing up around corners. Where possible drive
through should be utilized especially for deliveries.

06 April 2023 | Page 28 of 95 | Version 1.0

 30.00

20.00
Figure 9 : Site Plan Examples

2.5.4.3 Buildings
All CLS buildings will meet local building codes and have:
1. Adequate floor space for the initial system capacity with the ability to expand to the ultimate
system capacity in the future;
2. Adequate floor loading for the ultimately system capacity. Land cable entrance facilities, also
known as the cable vault;
3. Access to local telecommunication carrier infrastructure;
4. Heating, Ventilation and Air Conditioning (HVAC) to support the initial installation and the
ability to be expanded to the ultimate configuration;
5. A fire detection and suppression system;
6. Connectivity to local utilities (e.g., power, water, sewer, telephone, internet, cable TV);
7. Adequate DC battery plant that can be expanded in the future;
8. Standby AC power generation with fuel tank(s);
9. A marshalling area with doors sized to receive equipment;
10. Adequate parking for cars and trucks including delivery of bulky items and fuel;
11. Adequate HSSE compliant workspace and furniture for personnel while onsite;
12. Adequate storage space for spare parts and test equipment;

06 April 2023 | Page 29 of 95 | Version 1.0

 13. Physical security features, e.g., door locks, guard stations, mantraps, surveillance cameras,
building alarms, equipment cages, gates, and fencing.
Modular CLSs are proposed at all sites. Additional building can be added for co-locate and non-
operating space to allow for future expansion.
Within the CLS, space will be planned to accommodate initial and future requirements for:
§ PFE;
§ SLTE (segregated and secured areas for customers);
§ Power plant including batteries, rectifiers.
§ Secured and isolated colocation space for Purchaser and carrier equipment;
§ Cable entrances and management;
§ Building systems including Heating Ventilation Air Conditioning (HVAC), fire detection &
suppression, security, and surveillance;
§ Workspace including allowance for temporary NOC operations;
§ General storage;
§ Spare equipment storage; and
§ Staging and testing area.
A key feature within the Data Centers will be to build a segregated or isolated colocation areas or
more likely cabinets for Customer and carrier equipment for security and safety benefits. This area
will be accessible 24x7 using access control systems and other security methods to keep third
party personnel away from the BALTIC infrastructure and CLS systems such as generators, power
systems, SLTE, PFE and other equipment.
Samples of internal building layouts for CLS respectively are provided in Figure 10.
Final details will be completed in detailed engineering subject to local standards and codes and
refined detailed requirements. Early ordering and construction of the buildings will be beneficial
to the project to, so they are ready to accept the cables.

06 April 2023 | Page 30 of 95 | Version 1.0

 15.00

Sea Cable Entrance

Battery
POWER Generator Room

HVAC

0.96
DC/AC

0.60
Rectifiers Rectifiers Rectifiers Accessory Accessory
Inverter

1.04

1.00
Fire Fire Fire

OCI OCI SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE

0.60
HVAC 1.30 OCI OCI SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE

1.00
SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE

12.00
0.60
HVAC SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE

1.00
Storage

SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE

0.60
HVAC SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE

Spares
1.00

SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE HVAC

0.60

Server Server Server SLTE SLTE SLTE SLTE SLTE SLTE SLTE SLTE
1.10

HVAC
Misc. Misc. Misc.
0.90

ODF ODF Spares Spares Spares Spares

HVAC
0.85

Land Cable Entrance

Figure 10: Cable Landing Station Layout Example

2.5.4.4 Electrical

Power
Reliable power will be required at each landing station. At the trunk sites this power is necessary
to power the entire trunk though there is resiliency at both sites. At the two branch legs, like at
the trunk sites, the power will also power the CLS systems, SLTE for the Customers, NMS,
Terrestrial transmission gear and other tools and equipment.
Despite the reliable power, to mitigate potential system outages, the CLS sites will have enough
standby power for continued operations if commercial power is lost. This will be provided through
a natural gas fed generator (assuming natural gas is available – otherwise diesel). Each generator
is to be sized for the full engineered AC power load of the CLS with a spare capacity of 20%. The
generators will use piped in natural gas to save space and simplify fuel management. The
generators will be integrated through automatic transfer switches and auto-start capability.
Alarms will be triggered to notify the NOC whenever there are power issues including low fuel for
the generator.
Batteries will be used to power critical transmission and network equipment while generators
power on and balance their load to maintain constant communications. Due to potential
inconsistencies in power (dirty power), transmission equipment within the CLS will run off the
batteries which are under constant recharging.
The CLS requirements listed in Table 10 were developed for planning purposes. These
requirements are subject to change as the Purchaser works through the procurement phase. CLS
system planning for power shall consider immediate and long-term power requirements such as

06 April 2023 | Page 31 of 95 | Version 1.0

full SLTE buildout and full colocations pace occupation along with a safety factor. For the large
sites in Cabinda and Barra do Dande, an upgrade of the electrical systems to support a future
Hyperscaler expansion building should be planned versus powering from day one.
Table 10: Cable Landing Station Requirements

Floor Space DC Power Heat Dissipation

Requirements (sq. m) (kW) (Mcal/h)

Design Initial Ultimate Initial Ultimate

CLS 200 40 150 59 200

Electrical System for Transmission

The AC power supply will be converted to 48VDC using N+1 rectifiers to feed the BALTIC including
PFE, SLTE, select network gear, carrier equipment and other telecommunications equipment, and
to charge the battery banks. Figure 11 illustrates a typical electrical system schematic. The
batteries will always be online to ensure continued communication in the event AC power is lost
for even momentary periods (e.g., brownouts and while generator is spinning up). Some
components including HVAC, lights and network gear will utilize AC power and not have
continuous backup. Short term interruption of these is acceptable. Rack mount UPS gear can be
used for AC based systems to support momentary brownouts and power loss.
Sufficient battery capacity to operate the system while the automatic transfer switch changes
from one power source to another and the new power source can normalize the voltage,
frequency and current. Furthermore, they will be sized to provide at least four additional hours to
allow for personnel to respond in the event the generators do not properly come online. This extra
battery time will be balanced against the time that the equipment can operate without sufficient
cooling as the HVAC is AC power fed and may not operate if the generators fail and should be less
than eight hours along with high temperature cutoff on electronics.

06 April 2023 | Page 32 of 95 | Version 1.0

 Terrestrial Fiber Carrier User LECS
Commercial Power
Cable Patch Termination Termination Termination
Entrance
Entrance Panel Equipment Equipment Equipment

Carrier User LECS

SLTE SLTE SLTE
Automatic
Transfer
Main Power
Switch Buss

Dual Open Cable

48VDC
Optional DC Cable Termination
Gen-1 Power System
Gen-2 Power Interface Box
N+Y Redundant
BUSS (OCI) (CTB)

Network Element Cable

48VDC Management Management Power Feed
HVAC
Battery Plant System System Equipment
(NMS) (EMS) (PFE)

Figure 11: Electric System Simplified Block Diagram

2.5.4.5 Environmental
The HVAC system will have duplicate systems capable of providing appropriate climate control
(temperature and humidity). They will operate in a lead lag mode to address short term cooling
requirements where one system is unable to manage the necessary load. Systems will be sized to
cover the system operating at full capacity and all equipment racks full (e.g., BALTIC at full
operating capacity with maximum SLTE) in addition, to multiple personnel working. An analysis
for the need for dehumidifiers may be required if the heat load is too small initially and the HVAC
units cool the building too quickly without maintaining the proper humidity.
A temperature monitoring system with high and low point shutdowns as well as humidity levels
will be implemented to give early warning of pending failures and to protect equipment of
extreme environmental conditions.
During building design, air flow and fresh air intake will have to be determined. As part of this,
mitigation for salt laden air which will damage equipment and corrode the CLS buildings will have
to be considered. Care in construction and installation with proper testing will take place to
mitigate leak hazards which is a common risk.

2.5.5 Other Considerations

2.5.5.1 Terrestrial Connectivity

BALTIC will be dependent upon the terrestrial networks in each country to extend BALTIC traffic
to their desired locations or to interface with global services such as Internet. Terrestrial
connections are not within the scope of this study. However as BALTIC locations are near CBD,
establishing access to reliable terrestrial connectivity should be relatively manageable.

06 April 2023 | Page 33 of 95 | Version 1.0

 During the engineering phase, the design of the terrestrial and the BALTIC will have to be reviewed
jointly to ensure the technology, handoffs and physical locations are consistent across the system
or at a minimum do not preclude any technical service offerings to the customer base.

2.5.5.2 Standards
This section identifies the standards that must be met to implement BALTIC. Based on the DTS
and assumptions agreed to for this study, the following system requirements have been defined
for planning purposes only and are subject to change as latest information and opportunities are
discovered.

Standards Compliance (Applicable Standards)

All components of the system must comply with the standards and recommendations recognized
by the submarine fiber optic system industry. System performance, client interfaces, installation
methods and procedures, testing, operational procedures, and definitions will conform to
international and local standards. All system equipment and components must comply with
applicable laws, regulations and requirements of any governmental authority having jurisdiction.
Particular attention must be given to protection of intellectual property and traffic/system
security.
All workmanship will be performed in accordance with good industry standards and all applicable
laws, regulations and requirements of any governmental authority having jurisdiction.
Terms for delivery of goods, including Cost, Insurance and Freight, Delivered Duty Paid and Free
on Board should be used and interpreted in accordance with International Chamber of Commerce
(ICC) Incoterms 2000 or 2010.

International Standards
Standards developed by the following international organizations will impact any submarine cable
system design and implementation:
§ European Telecommunications Standards Institute (ETSI)
§ Institute for Electrical and Electronics Engineers (IEEE) standards
§ International Cable Protection Committee (ICPC) recommendations
§ International Convention for the Prevention of Pollution from Ships (MARPOL)
§ International Electrotechnical Commission (IEC)
§ International Marine Contractors Association (IMCA)
§ International Organization for Standardization (ISO)
§ International Seabed Authority (ISA)
§ International Telecommunication Union – Telecommunications Standardization (ITU-T)
recommendations

Local Standards
Local standards must be adhered to, such as the following:
§ Local and national Health, Safety and Environment (HSE) standards
§ Local electrical codes

06 April 2023 | Page 34 of 95 | Version 1.0

 § Local building codes
§ Local and national safety and security directives
§ Local, national, and international permitting.
While Motorola’s R56, Standards and Guidelines for Communication Sites, is not a required
standard, it contains a good deal of practical information that is beneficial to the BALTIC site
designs.

2.6 Technical Conclusion

BALTIC is technically capable of being built and the technology exists and is proven. The system as
evaluated through this study does not have any major concerns. The Suppliers have confirmed
this through previous conversations as this solution is generally considered to use standard
technical and system concepts. No special technology will be required.
The two major outstanding issues to address are:
1. Finalize the capacity management plan which will drive the fiber capacity map and branching
unit technology selection.
2. Finalize the locations for the sites so that detailed engineering, permitting and site
acquisition can be completed.
The remainder of the issues will be managed in due course as part of the standard submarine
cable engineering and design process. Should requirements be relatively static and not subject to
ongoing change, the design process should flow relatively. Proper surveys and assessments will
be the cornerstone of completing these activities.

06 April 2023 | Page 35 of 95 | Version 1.0

3. OPERATIONS & MAINTENANCE

3.1 System Management

When properly developed, engineered, and constructed, submarine cable systems are extremely
reliable. BALTIC should be no different as it is a standard solution. This along with the high capacity
is why they are a preferred connectivity solution despite their high capital cost. To maintain the
high reliability, submarine cable systems such as the BALTIC need to have a robust O&M model in
place. The goals of the O&M model are to:
1. Know the state of the system to identify problems early to address early through
a. Detect and respond to spontaneous problems quickly;
b. Identify and have a planned response for longer term issues and trends.
2. Prevent problems from occurring through
a. Effective maintenance strategy for onshore
b. Effective liaison, awareness, and monitoring program for offshore
c. Established compliance program
3. Delivery of safe and reliable operations with
a. Redundant systems which are routinely tested
4. Respond to issues with a “pre-defined response plan” including ready access to:
a. Wet Plant and Dry Plant spares
b. Onshore personnel and equipment
c. Cable repair vessels
These goals are further delivered through effective:
1. Organization with defined roles and responsibilities
2. Training and certifications for personnel
3. Network Operation Center and tools
4. Fit for purpose strategies & policies for maintenance, spares, HSSE, incident handling
5. Effective logistics for timely movement of personnel and resources
6. Funding to maintain the necessary activities
7. Contractors for the necessary services
8. Defined maintenance and testing strategies
Based on experience with other systems, O&M incidents and outages are often related to:
§ Power outages at CLS
§ Extended time to repair offshore Wet Plant failures
§ CLS security
§ Purchaser responsiveness and problem resolution capabilities
§ Maintaining adequate spares in the necessary locations

06 April 2023 | Page 36 of 95 | Version 1.0

 § Inter-equipment failures
§ CLS building and building system failures and false activations
§ Increased failure rate as systems age
§ OSP damage from erosion or external aggression
While acknowledging these concepts and in recognition of key challenges, it is assumed Purchaser
must establish a new operations team and resources. To assist in this development, Table 11
provides a breakdown of the necessary disciplines in owning and operating a submarine cable
which can be used as a reference point.
Table 11: Technical Operational Disciplines

Discipline Responsibilities
Operations 1. Keep systems up and running
2. Minor projects and ongoing maintenance
3. Respond to and resolve incidents
4. Support Engineering & Provision with resources and information
5. Support other disciplines with relevant information and field resources
6. Maintain operational records
7. Maintain operational resources including field.
8. Complete Move-Add-Changes (MAC)
9. Maintain compliance with licensing and permits.
10. Maintain field operational sites (e.g., CLS)
11. Purchaser service/help desk
12. Dry Plant Spares management, strategies, and replenishment (including stored
at Warehouse, Depot)
Engineering 1. Plan and execute small scale projects
& Provision 2. Engineering of new and changes to services.
3. Engineering for provisioning MAC (implemented by operations)
4. Monitor usage and performance trends and propose response and upgrades
(e.g., Capacity planning, systemic issues
5. Develop solutions to cyber threats working with HSSE cyber lead and
operations.
6. Wet Plant Spares management, strategies, and replenishment (including
stored at Warehouse, Depot)
7. Manage Wet Plant and major repairs
8. Wet Plant Maintenance authority
9. OSP maintenance and repair program
10. Develops routine maintenance, inspection, and testing programs (executed by
operations with E&P oversight)
Logistics & 1. Coordinate and cause to occur movement of materials and personnel using
Scheduling independent methods (e.g., flights, transporters).
2. Coordinate accommodations for deployed/field personnel.
3. Support import and export of materials.
4. Interface and coordinate with offshore sites for movement of personnel and
materials including any prerequisites and scheduling
5. Warehouse inventory management

06 April 2023 | Page 37 of 95 | Version 1.0

 Discipline Responsibilities
HSE On behalf of disciplines and in close mutual team effort:
1. Safety Policy & Procedures
2. Safety monitoring and enforcement
3. Stand-alone safety program fund owner (most safety in Discipline)
4. Develop security requirements and methods
5. Operate over the top security systems (beyond routine operational NOC
monitoring)
6. Cybersecurity threat management and awareness
7. Coordinate infrastructure security and access management

3.2 Dry Plant Operations and Maintenance Strategy

3.2.1 Overview
As noted in the previous section most of the incidents will be related to the Dry Plant and the CLS
of BALTIC. For this reason, support of this section should be properly staffed using internal and
contract resources. In addition, these resources are deployed near the point of work so they may
respond in a reasonable time. For example, the BALTIC field technicians supporting the CLS, should
be located within one hour time (even in severe weather) to get to the CLS once dispatched so
they can make the necessary repairs within the four-hour performance metric identified.
In addition, the engineering activities are separated from the operational personnel to allow field
personnel to be outsourced and to ensure engineering follows a defined process which minimizes
field engineering. However, engineering and operations must work together closely.
The core components of the dry plant O&M model will be:
§ 24x7 centralized NOC monitoring all aspects of BALTIC and to take Purchaser calls
§ Deployed technicians to complete field inspection, maintenance and repairs as directed
§ Engineering team for escalation of incidents
§ Contractor utilization for non-unique aspects such as building and OSP work
§ Documented strategies for onshore sub systems as summarized below
To calculate the O&M costs, this proposed model has been costed and integrated into the financial
analysis. Current estimates are around [$2.5]M per annum.

3.2.2 Network Operations Center

The NOC as described previously will supervise the network operations and should be equipped
to monitor all technical, facilities and security aspects of the system. The goal of the NOC will be
to identify system issues within 30 minutes of occurring and ideally within fifteen (15) minutes
using technology assisted detection and analysis. The use of automated tools to validate alarms
and routinely interrogate equipment will be critical to the success. This work will most likely need
to be done by a specialist and not necessarily the System Supplier. Upon receiving an alarm, the
NOC should immediately begin to investigate and give the incident a priority which is logged into
the incident tracking system.

06 April 2023 | Page 38 of 95 | Version 1.0

 Where possible, the NOC personnel will resolve the issue. If unable to resolve, the NOC will use a
combination of the following:
§ Dispatch field technicians
§ Escalate to engineering or higher-level support organizations such as System Supplier
§ Notify field security forces, where appropriate
§ Notify third party contractors based on need
§ Notify senior management for priority 1 and 2 incidents
§ Notify Purchasers management per policy
§ Continue to monitor and track incident progress and provide updates per policy
§ Assist with service resolution (steady state) and restoral (temporary) efforts and testing
As the NOC will operate 24x7 and have a fast detection and initial response time, the NOC will be
staffed with multiple personnel. In addition, a supervisor will be onsite during the day and
available after hours. If the primary NOC becomes unavailable, operations will be moved to the
secondary location in Denmark

3.2.3 Field Operations and Maintenance

Activities in the field will typically fall into one of the following categories:
§ Planned and routine maintenance and inspection
§ Incident response
§ MAC
For maintenance and inspection, the field technicians will be given a maintenance program
strategy by the engineering team. These routines will occur typically on a weekly, monthly, bi-
annual, and annual process and could include:
§ Physical site and land inspection from BMH to CLS including the land cable route, return
earth systems and buildings
§ Building system inspection and testing
§ Electrical system inspection and load testing
§ Site cleanup and janitorial
§ System integrity
§ Security system inspection and interrogation
§ Spare’s inventory and testing
§ Material inventory including fuel
§ Contractor testing of equipment such as generators (or green equivalent)
Identified issues which cannot be quickly resolved will be turned into incidents to be managed by
the appropriate teams such as engineering, operations, and contractors. For example, if erosion
is found on the OSP, engineering will be notified, and they will work with the local OSP contractor
to manage repairs.

06 April 2023 | Page 39 of 95 | Version 1.0

 With respect to operational incident response, Field Technicians will be dispatched upon
detection and will work with the NOC to resolve. If the issue is not related to transmission but
instead related to electrical, security and building systems, the technicians will work and
coordinate with the appropriate contractors for resolution.
Field Technicians (full time or contract part time) will be located near each of the CLS and will be
dispatched based on proximity to point of work required. This is to manage the deployment time
to make the designated time to repair target. Field technicians will be rotated through all CLS to
ensure full understanding and awareness of the system as well as the ability to reposition
technicians to address personnel shortages and gaps in coverage such as vacation and sick time.
MAC work will also be completed by the Field Technicians once the work is engineered and
commissioned by the engineering team. They will implement to the defined plan and utilize
components that have been supplied for the work.
The field technicians will work closely with logistics to ensure the timely and pro-active delivery
of spare parts, personnel and supplies as the sites are somewhat remote and isolated.

3.2.4 Outside Plant Maintenance

OSP maintenance will be limited to routine inspection and minor maintenance. Repairs will be
done solely as needed. In general, OSP should not need maintenance as it is not mechanical. The
primary issues for which inspection will focus on are:
§ Security and theft of cable
§ External aggression
§ Water ingression into BMH duct routes, intermediate manholes, CLS vault and inside splices
§ Erosion and loss of cable protection
§ Nearby construction
Annually, there may be a more intrusive inspection such as opening up BMH, intermediate
manholes and handholes to look for hidden damage including rodents. Walking and drive by route
inspections should happen at least once a month and more frequently if the area is active.
Carrier cable routes should also be included in the scope of these inspections although repair is
not within BALTIC scope. Prompt resolution to issues with carrier networks will help the overall
perception and subsequent demand profile for BALTIC.

3.2.5 Site Facilities

CLS buildings and grounds will be focused on routine inspection, landscaping, annual testing,
system testing and minor maintenance. Repairs will be done solely as needed. The primary issues
for which inspection will focus on are:
§ Security and theft of equipment
§ External aggression
§ Corrosion and deterioration
§ Alarm history
§ Nearby construction
§ Leaks

06 April 2023 | Page 40 of 95 | Version 1.0

 § Building systems operations
§ Filters for HVAC, generators
§ Generator testing
As there are active systems within this scope, a more active and investigative approach to
inspection will be required including looking at history logs. In addition, systems such as
generators, battery banks, alarm systems, fire detection and suppression systems and HVAC will
need to be tested on a regular basis in accordance with manufacturer guidelines.
Inspection of these systems will require some additional skillsets and training for the field
technicians such as electrical systems and measurement (including safety). However, any major
work will be contracted out to qualified third parties generally local to the area. Spare parts for
the included systems will need to be maintained on site at each CLS.

3.2.6 Transmission
The primary hands-on work of the field technicians will be to maintain the terminal equipment or
including the PFE. For this reason, the field technicians will need advanced training in this area to
make them competent to investigate, interrogate, configure, remove, and install cards and
subcomponents in accordance with manufacturer guidance. In addition, they will need direct
access to advanced support such as those available from the System Supplier. Note that for the
BALTIC, SLTE under Purchaser management maybe limited however, Purchaser may wish to offer
some level of remote support for customers as part of their operational package and to offset
some of the costs associated with distributed field maintenance technicians. In addition, as part
of operations, there may be the need to help identify spectrum conflicts created by different
customer SLTE systems and coordinate remedy.
As part of the System Supply contract, an extended System Support contract should be put into
place including remote access for the contractor to remotely access systems. Ample spares onsite
will be required, coverage under warranty of failed components and ongoing support system
components, at reasonable prices, plus firmware and software upgrades.

3.2.7 Training
Training will have to be defined for all personnel to ensure they have the right level from
awareness to expert. System Supplier input will be critical. Training will include online, on-site,
and offsite. The Supplier will normally include a training package as an option as part of the supply
contract. This normally includes engineering, technician, and jointer training. However, jointing
may be left to specialist companies and not normal operations personnel.

3.2.8 Security
The NOC will monitor primary security using access controls systems, surveillance cameras, door
monitoring and other forms of intrusion detection. Upon detection of a security event, the field
technicians and the local security company or law enforcement will be notified and asked to
respond at a level consistent with the detected event.

06 April 2023 | Page 41 of 95 | Version 1.0

3.3 Wet Plant Maintenance

3.3.1 Overview
A full analysis and recommendation for wet plant maintenance was not included in the Feasibility
Study. A more comprehensive investigation into talking with potential entities for wet plant
maintenance is needed to complete a comprehensive analysis including cost and response times.
The selection of this solution will also drive the preferred location for a submarine cable depot
System owners must consider how best to cover the risk of faults to the submerged plant over the
design life of the system. There are three standard approaches:
1. Enter the system in to one or more maintenance agreements or maintenance zones that
2. Negotiate a private contract with a single marine service provider such as Baltic Offshore,
but this might be prohibitively expensive compared to the maintenance agreement options;
3. Wait for a cable fault and then go to the spot market to find a repair ship.
It is not recommended for the spot market solution especially on a system that is a single trunk
backbone due to the time to repairs can be extended and the system downtime that would result
in the event of a fault would probably be too great for customers to have confidence in the system
if this was the marine maintenance regimen.
The use of a maintenance agreement or private agreement will most likely be the preferred
solution for BALTIC. While the private agreement with an entity such as Baltic Offshore may not
be as cost effective, the time to respond and repair may be improved and the time and cost to
mobilize might be beneficial of the private solution.
For a maintenance agreement, the oldest of these Club Zones is the Atlantic Cable Maintenance
Agreement (ACMA). ACMA was founded in 1965 and the other Zones, formed later, are modelled
on the ACMA agreement. The Baltic Sea does not immediately shows as being part of this
agreements so it would have to be vetted during a detailed review.
In addition to these Zone agreements, several alternative Private Maintenance Agreements have
been set up to complement and, in some cases, compete with the Zones. The global coverage of
Private Maintenance Agreements is shown in Figure 12.

06 April 2023 | Page 42 of 95 | Version 1.0

 Figure 12: Global Private Maintenance Agreements

As previously stated, most system owners enter their systems into a maintenance agreement. The
annual cost of marine maintenance, known as the “Standing Charge,” the size of which is based
on the length of the system included in the agreement. The calculation being about $200 per km
for the current agreements in the Atlantic. In addition, they build up reserves from income to
cover repair costs, typically based on one repair every two to five years. Subject to the type,
extent, and location of the fault, plus the distance to the ship’s base port, the cost can be
calculated on the daily cost of the repair ship, known as “Running Costs” that are on the order of
$28-30K per day and are typically estimated to be on the order of $1.0-1.5M per repair event.

3.3.2 Proposed Marine Maintenance Solution

Marine Maintenance is in fact a misnomer as extraordinarily little is any preventative maintenance
is conducted on a submarine cable unless this is called for under the cable owners permits to
operate the system. A wet plant maintenance agreement is for a marine repair service.

3.3.2.1 Organization and Maintenance Authority

Wet plant maintenance and repairs will ideally be exceedingly rare. It is proposed that the BALTIC
enters into an agreement to be defined later.
ACMA is organized a little like a golf club, the members and club members run it must accept the
rules of the club. There is no negotiating, rules can only be changed by consensus among the
members. There is a membership hierarchy, members with the greatest length of cable in the
agreement have most influence and take priority over service if two members call for the same
vessel at the same time. However, members do benefit from the experience of other members
and from inter-member loans of spares submerged plant and pooling of such things of UJ jointing
piece parts and consumables.

06 April 2023 | Page 43 of 95 | Version 1.0

 Under APMA each cable owner negotiates a separate contract with the service provider and can,
to a limited extent, within the commercial offering, achieve a made to measure contract.
However, each contract is separate and so there is no synergy, where one cable owner benefits
from the knowledge or experience of another, within the agreement.
Pricing and service offerings are remarkably similar, so the choice between ACMA and APMA
usually comes down to the base port locations of the vessels, relative to the higher risk areas of
the cable owner’s system. The choice being made to keep transit times to a minimum and
therefore reduce running cost in the event of a repair. This will need to be considered in later
phases.
Both these agreements are time limited and are re-negotiated on a regular basis. The new ACMA
agreement has just been completed and will run to 2026. The APMA contracts will be re-negotiate
by the end of the 2021 to cover the same period.
Neither ACMA nor APMA provide a service for the storage of system, submerged plant spares, so
the system owner will have to enter a separate Depot Storage contract. Again, the number and
location of the depos used, will need to be considered at in later phases of the project.
As can be seen, activities require extensive knowledge of the system to identify, isolate and plan
the repair. It is a project with a multi-day or multi-week lifecycle. Therefore, Wet Plant activities
will normally be within the remit of the engineering team with operational support. As such, the
Maintenance Authority will be the Director of Engineering with delegation as appropriate and
support of the entire organization as required. Operational support will include NOC and Field
Technicians to monitor the system, staff the CLS during repairs, test, secure system
power/grounding and return to service the system as required. The engineering team will be
responsible for most other activities and utilize support of legal, procurement, logistics and other
disciplines as required.

3.3.2.2 Suggested Spares Quantities

Spares identified in Table 12: Wet Plant Spares Quantities (Preliminary) have been developed by
the DTS and this Feasibility Study. They are subject to change at final system design and may also
be influenced by the purchaser’s level of concern and/or confidence in the system protection plan.

Table 12: Wet Plant Spares Quantities (Preliminary)

Depot 1 Units Qty

DA - Double Armor (Submarine) Km 1
SA - Single Armor (Submarine) Km 56
LWP - Light Weight Protected (Submarine) Km 71
LW – Light Weight Km 99
Repeater Spares Each 2
Non-Integrated GEJ Spares Each 2
Non-Integrated GEJ-S Spares Each 2
Wet Plant Total Spares Cost $3,220,000

06 April 2023 | Page 44 of 95 | Version 1.0

3.3.2.3 Depot Costs
As stated above, maintenance agreements do not include spare submerged plant storage on the
vessel. Therefore, the owner will need to budget for annual storage of its spare submerged plant
(cable, repeaters, BUs, jointing piece parts, etc.). To reduce mobilization time, wet plant spares
could be held in a facility close to the base port of the vessel(s) of the chosen maintenance
agreement. Cable depots should not be in busy ports since this would require the repair vessel to
compete with commercial vessels for quayside space. This could delay repairs and increase
Running Costs.

3.3.2.4 Cable Awareness and Third-Party Liaison

Given the mission critical nature of traffic that BALTIC will carry and the duration of downtime in
the event of any cable fault, it is essential that the purchasers take every opportunity to reduce
the risk of cable faults. In addition to the appropriate investment in CRE and marine installation,
system owners normally invest in a program of ‘Cable Awareness’ to make sure that all other
seabed users and other relevant commercial marine entities are aware of the submarine system,
its location and purpose. This will involve, but may not be limited to, ensuring the cable route is
published on all the major international charts that are likely to be used in the area, as well as
pilot books published by these organizations coupled with the printing and distributing of charts
and brochure targeted at fishing organizations and regular liaison meetings with bodies
representing commercial marine entities and/or companies developing seabed mineral resources.
The organizations to engage with, under such a program, are likely to be different for each route.
The list of organizations for the Atlantic Ocean are already well established, owners of systems
landing in these locations should be contacted by the BALTIC owner and discussions initiated as
to whether there is any benefit for the BALTIC owners in becoming part of existing Cable
Awareness Programs.

3.3.3 Wet Plant Faults and Repairs

3.3.3.1 Cable Repair Agreements

As can be seen the proposed BALTIC route could be potentially covered by either ACMA or APMA;
APMA supported by ASN and SubCom and the nearest ship based in Praia, Cape Verde. Local
providers can cover BALTIC.
Since 2017, the service providers to ACMA have been Global Marine Systems Limited (GMSL) and
Orange (previously France Telecom Marine). Their contracts, with the ACMA members, will run
until December 2026. The Orange Marine vessels are based in Brest, France and Global Marine
vessels are nominally based in Curacao and Portland. ACMA is supported by the Global Marine
depot facilities in Portland, United Kingdom, and Bermuda; Orange Marine’s facilities in Brest in
Northern France; and SubCom facilities in Curacao in the Dutch Antilles.
Since January 2017 APMA has been covered by ASN and SubCom, with ships based in Calais,
France; Curacao in the Dutch Antilles and Cape Verde.

3.3.3.2 Risk of System Fault

In an upcoming phase in conjunction with the System Supplier, as part of the development formal
route engineering starts using the information from the DTS and is continued through the Marine
Survey into system design and manufacture and finally the installation methodology. The CRE
process will involve investigations into known and potential risks of external aggression faults,

06 April 2023 | Page 45 of 95 | Version 1.0

 both from natural phenomena and manmade intervention. These risks will, as far as is practicable,
be mitigated through route selection, choice of cable type, cable burial and where appropriate,
additional protection, plus the allocation of suitable cable slack allowances throughout the route.
All System Suppliers responding to a system ITT will have extensive experience in identifying risks
to submarine systems and using the CRE process to mitigate them. One of these responders will
become the BALTIC’ System Supplier. Properly conducted, CRE will take into consideration all the
known/identified risks and should result in a system protected, as far as is economically
practicable, from these identified risks. However, it is impossible to guarantee that all the
potential risks to the system that may occur over the 25-year design life of the system will be
identified. Also, there are some types of faults, e.g., random anchor faults, which are
uneconomical to protect against.
As part of the CRE process, the fault history of the overall region and that of similar cable routes
will be considered. Most cable faults are caused by manmade external aggression and occur in
shallow water (<1500m), so landing points and continental shelves will be the most at-risk areas
of the route. If the system passes through oil & gas fields that are subject to severe weather, deep
water risks are also realized when anchors on drilling rigs fail to hold.
In the event of a system fault, a portion of the traffic will be lost BALTIC and with its revenue will
be lost. In addition, there will be a one-time cost to O&M incurred to conduct the repair. It is
important to consider the timescales involved in system outage to get an understanding of the
financial implications and the impact on customer confidence relating to the service provided. To
do this the timescales involved in a repair operation will need to be considered in two separate
parts:
§ Response time to the area of the fault;
§ Time on the cable grounds to reinstate the system.

3.3.3.3 Response to System Faults

When a fault such as shunt fault or optical loss occurs on a submarine system, the first indications
are alarms at the CLSs and the NOC(s). The alarms that go off will depend on the type of system
fault that has occurred, but they should initiate a process of fault location. This could include the
use of the system supervisory, PFE voltages, COTDR (Coherent Optical Time Domain
Reflectometer) techniques, low current DC electrical tests using NOC and Field Technicians
collaboratively. Once a good approximation of the fault location has been determined, Purchaser
can notify the appropriate repair ship to mobilize for the repair, giving the service agreement
representative the fault type and approximate location. Once this notification has been sent,
Purchaser is committed to paying the ‘Running Costs’ of the repair ship. The first process is to
develop a repair plan and agree what spare submersible plant should be used to carry it out. Under
both ACMA and APMA the ship is required to mobilize, load the appropriate spare submerged
plant, if stored in a shore-based depot at the repair vessel’s base port, and then commence
passage within 24 hours of notification. Therefore, by the time the ship is underway to fault area,
the system could already have been down for up to 48 hours.
The next phase of the operation is the transit to the Area of Operation (AOO). This will commence
from the base port/depot directly to the AOO if the fault is in international waters. However, if it
is within territorial waters, the vessel will need to clear into that country before it can commence
operations unless it has special dispensations. The fuel efficient, passage speed of most repair
ships is typically 12 knots in clear weather, but this can be extended by harsh weather and adverse

06 April 2023 | Page 46 of 95 | Version 1.0

 currents. Therefore, the distance, from the base port/depot AOO will be a significant factor in the
response and so will inform the decision as to whether to enter the BALTIC into ACMA of APMA.
After the transit, the clear-in process should take no more than 24 hours and the vessel will then
be able to transit to the AOO. As already stated, the most likely fault areas will be in shallow water
on the continental shelf, between the landing point, i.e., BMH and the transition from LWP to LW
cable on the edge of the continental shelf, as defined by the as laid RPLs.

3.3.3.4 Repair Operations

There are a range of repair operations that could be required:
1. Cable break deep water (unburied)
2. Cable break shallow water (buried)
3. Shunt fault/fiber break deep water (unburied)
4. Shunt fault/fiber break shallow water (buried)
5. Repeater replacement
6. Shore end repair/replacement.
The duration of each repair will depend on several factors, including but not limited to type of
fault, the cable type, the length of cable damaged, water depth, whether the cable is buried or
surfaced laid and the prevailing weather conditions.
BALTIC may be installed using the chosen System Supplier’s proprietary jointing technology;
however, repair operations will be conducted using UJ technology. The current UJ can
accommodate up to 96 fibers and is qualified to a breakdown voltage of 15KV, so is suitable in all
respects for the BALTIC.
A minimum of two cable-to-cable joints will be required to complete any repair. The number of
fibers in the cable to be spliced will be the major factor in the jointing times, with an average of
10 minutes required for splicing and reinstating the protective coating. BALTIC is planned to be a
high fiber count system of up to 24FP or 48 individual fibers. Therefore, to complete the minimum
of two cable joints for any repair, using the current procedures, a minimum of 16 hours, without
rework, on just splicing will be required. Before splicing can take place, the fiber colors will need
to be identified and this requires the use of a software-based identification system. Testing each
splice will be conducted in parallel with splicing and will be followed by wrapping the fibers into
the central housing. When wrapping so many fibers into a small space, testing will again be
required to ensure no high losses from macro bends have been introduced. This will then be
followed by the closing of the central housing and over molding to re-instate the insulation. The
joint can then be completed by completing the armor assembly and fitting the bend limiting
buffers.
The insertion loss of the splices will be checked at each stage of assembly. This testing is relatively
simple for the initial repair splice as the splices can be tested from the end of the stock cable
onboard the repair ship. However, for the final repair splice, the ship will have no access to the
fibers and the insertion loss of the slices must be measured from the appropriate CLSs. This will
require the CLSs to power the system with the cable still onboard the ship. To do this power safety
must be handed back from the ship to the CLSs and ship-to-shore communication will have to be
by satellite phone. This will add significantly to the time required to complete the final splice
compared with the initial splice. As can be seen, the initial and final splices will make up a
significant part of the critical path to completion of the repair.

06 April 2023 | Page 47 of 95 | Version 1.0

 Without working through the details of each type of repair, for the purposes of this analysis, if we
assumed that the fault requires the simplest repair (least time consuming) operation of a single
cable break in shallow water, buried cable and that the complete repair operations will be
completed, up to final splice, assuming no rework or weather delay, in seven days. At which time
the system can be handed back to the system owner to put it back in traffic. Burial of the repaired
cable can be accomplished with the system in traffic.
Obviously more complex repairs will require longer in the AOO before the final splice can be
slipped and the system put back in traffic. Any rework and weather conditions that prevent the
repair ship from working will add to the duration and will increase the overall cost of the repair.
In addition, winter weather conditions are a significant consideration for the BALTIC route.
It should be noted that Purchaser will continue to pay for the Running Costs of the repair vessel
until it has returned to its base port, discharged the unused submerged plant, and recovered scrap
into the depot. This may or may not involve clearing out of the country in which the repair has
taken place.
It can be clearly seen that even for a simple fault on either of the continental shelves, the
downtime for BALTIC could be significant, especially in the winter. Therefore, traffic restoration is
a major consideration.

3.3.3.5 Restoration
The normal PFE configuration for BALTIC is double end feed, one CLS applying negative voltage to
line and the other positive voltage to line with a null point of zero voltage relative to earth in mid
ocean. Depending on the location of a shunt fault in the system, the two PFEs should balance to
the fault allowing revenue earning traffic to continue until the repair ship has reached the AOO,
minimizing system downtime. This would be what is called a ‘Planned Repair.’
In the event of a complete cable break, the system could still be powered, but traffic would be
lost on all DSL(s). Therefore, customers will have to develop their contingency plans in case of an
outage on the BALTIC.

3.4 Conclusion/Recommendation
BALTIC will be maintainable. Significant effort will be required to define and implement the final
support model, and this will evolve as lessons are learned. Development of resources should start
by the start of construction. This will allow the resources to get on the job training and learn the
specifics of their system prior to it becoming operational critical. In addition, during this period,
the engineering team will begin to develop their O&M strategies.
Wet plant maintenance could be a larger challenge to get into place unless existing agreements
are expanded to cover BALTIC. A dedicated effort during system engineering and manufacturing
will need to be undertaken to identify and contract with the ACMA, APMA or a local party that
offers best value for money. As part of this, different repair scenarios will need to be identified
and gaps closed to ensure a timely repair can be made. Finally, a choice of spares depot(s) will
need to be made, based on the best strategic location for the BALTIC submerged plant spares.
Of course, the above implementation is dependent upon having the proper administrative teams
and personnel in place to support these efforts. The growth of these teams and especially
administrative staff can be staged as efforts grow and become better defined. The use of outside
support including legal counsel should be considered to improve delivery efficiency.

06 April 2023 | Page 48 of 95 | Version 1.0

4. SUSTAINABILITY
Despite the interest by the submarine cable industry, little sustainability qualified data presently
or easily exists. As such, APTelecom was compelled to create a purpose-built, completely new
model which relies heavily on scalable sustainability assumptions coupled with pragmatic industry
experience. The resulting development is an imperfect interpretation of a typical submarine
cable’s carbon footprint, estimated in tCO2e, which could then be applied specifically to BALTIC.
However imperfect the model is, it does begin to demonstrate there is significant opportunity
especially with shire end powering with carbon free sourced and in optimized vessel planning and
operations.
The Sustainability Model is heavily dependent on data from System Suppliers and the industry,
and attempts to answer the following basic questions:
1. What is the industry doing or planning to do in the near-term to track and reduce tCO2e?
2. What are System Suppliers doing or planning to do in the near-term to track and/or reduce
tCO2e?
3. What are the System Suppliers’ willingness and commitment to share sustainability data?
4. What are existing opportunities based on current understanding?
The Sustainability Model considered sustainability efforts by the submarine cable industry as a
whole and evaluated and profiled System Suppliers individually to develop and discuss the
following:
§ Industry attitude and commitment to sustainability
§ Carbon footprint modelling to estimate BALTIC life cycle tCO2e
§ Prospective CO2 mitigators that could be applied to further reduce tCO2e
§ Sustainability criteria to be used in adjudicating System Suppliers in an upcoming BALTIC RFP
Going forward, the client will need to answer its own questions, such as:
1. How will the client further validate the Sustainability Model?
2. What cost/benefit risk decisions allow the client to have a cleaner and greener BALTIC, and
what is the client willing to afford?
3. Which actions and areas of effort provide material impact with regards to sustainability.
As such, BALTIC and its application of the Sustainability Model is creating an industry pathway
forward for scrutinizing a project’s life cycle regarding analysis of tCO2e. Continuous improvement
of the model is critical for long term adoption.
The Sustainability Model will need to be validated during the procurement and implementation
of BALTIC, adding quantifiable data and metric revisions as they become available. This should be
accompanied with a log of decisions made and the impacts on the project with respect to
sustainability, cost, time, and risk from which the industry can build future practices. By the end
of project implementation, the client should possess an actualized and quantified analysis of
tCO2e for both manufacture and implementation, as well as life cycle of BALTIC.

06 April 2023 | Page 49 of 95 | Version 1.0

4.1 Industry Sustainability Efforts
Submarine cable industry wide efforts are in their infancy and sustainability is something only
recently being considered.

4.1.1 SubOptic Association

In 2021, the Sustainable Subsea Networks research project was launched. This was one of the first
projects of the newly formed SubOptic Foundation. The foundation is a charitable arm of the
SubOptic Association that is working to advance education and research initiatives for the subsea
cable industry.
The Sustainable Subsea Networks research project grew out of SubOptic's Global Citizen Working
Group, which focuses on developing ways for the subsea cable industry to better itself and the
world. This research project's focus is on the investigation of the cable system's energy use and
impact across various sectors, from supply to recycling. Even though the industry is already
relatively green, industry and academic members of the research project are working to enhance
environmental sustainability as far as possible – a crucial project given the devastating impacts of
climate change.
Over the past decade, many companies have begun to investigate green Data Centers, but
extraordinarily little attention has been paid to subsea cables' role in a greener
telecommunications future. This is possibly because cables clock in at a smaller footprint and the
use of marine vessels. This is something that many in the industry already know, but it needs to
be documented especially as green regulation and legislation is rolled out globally.

4.1.2 Orange Marine

Some companies have begun to consider the environment at nearly every level of their operations
and practices. This is certainly the case with Orange Marine, a subsidiary of the French
telecommunications company Orange. Since 2017, Orange Marine has prioritized sustainability
and made significant strides toward reducing their environmental impact in both technical and
business practices.
Installing and maintaining subsea cables is one of the most fuel-intensive components of the
industry. These tasks often require ships that are often powered by fossil fuels at every stage of
the process. To combat the carbon density of their fleet, Orange Marine powers ships in port using
the onshore electrical grid rather than the fuel stores to reduce overall emissions. In some of their
ports, Orange Marine has installed solar panels to generate and store their own electricity to
power these port stations. Furthermore, they have begun to consider sustainability in designing
the newest ship in their fleet—it will be fuel efficient and have reduced atmospheric pollutants.
In addition to these initiatives, Orange Marine has partnered with several French and European
organizations and initiatives, including act4nature, the Souffleurs d’Ecume association, and Euro
Argo to preserve biodiversity and to minimize local environmental disturbances, as well as to
contribute to ongoing monitoring of the ocean environment for scientific study of climate
change’s impact on the ocean. Some of Orange Marine’s other efforts include powering their
cables with low sulfur fuels to minimize pollution, improving their workplace QSE management
system, and reducing waste in their offices.
Orange Marine’s efforts were propelled by existing and anticipated regulation, but the real
catalyst was a shared commitment of the company and the individuals who work there to improve
the sustainability of their work. Bénédicte Bigot, Orange Marine's Sales & Communication

06 April 2023 | Page 50 of 95 | Version 1.0

 Development Director, took the initiative to pursue many of these opportunities. While these
efforts demonstrate the ways Orange Marine has gone beyond, it also suggests that these kinds
of initiatives are possible in other parts of the cable industry where there is a willingness to make
it happen. In fact, similar efforts are happening in other corners of the subsea cable industry all
around the globe.

Figure 13: CS Sophie Germain, Orange Marine

Orange Marine is constructing a new vessel, the Sophie Germain, which will specialize in cable
repair and replace their oldest vessel in the fleet, the Raymond Croze, launched in 1984.

4.1.3 New Jersey Fiber Exchange

In the United States, the New Jersey Fiber Exchange (NJFX) cable landing station campus recently
chose to go carbon neutral. They signed a multi-year contract to power their station with nuclear
energy generated in nearby Pennsylvania, a decision that moves the broader telecommunications
network toward a more sustainable future. The decision to go carbon-neutral was the culmination
of NJFX’s efforts to increase energy efficiency and a reduced environmental footprint.
A new landing station on the NJFX campus was designed in 2016 with environmental impact and
energy efficiency as a central concern. The campus offers direct access to multiple independent
subsea cable systems interconnecting North America, Europe, South America, and the Caribbean.
The design of the new station was in part a response to the challenges posed by the 2012
devastation of Hurricane Sandy it was equipped with an electrical cooling system that does not
rely on access to water. Rather, the facility is regulated by sustainably designed cooling units
installed on its roof and powered by carbon neutral energy. In addition, the facility uses energy
efficient LED lights that are time set and motion sensitive to reduce energy consumption.
The NJFX station is natural gas free, which allows them to ensure safety while advancing their
commitments to sustainability initiatives – instead of using natural gas for heat, they use the

06 April 2023 | Page 51 of 95 | Version 1.0

 energy from the customer equipment to heat the landing stations. NJFX has plans to install solar
panels this year to expand their sustainable energy resources. In addition to these design and
energy choices, business operations are also calculated into the company's green mindset:
employees of NJFX live on average only seven miles away from the facility and some of them can
bicycle to work. To further incentivize sustainable transportation for employees, NJFX installed
charging stations for electric vehicles in 2020.
Cable landing stations like the ones operated by NJFX are already more efficient and less energy
intensive than other elements of the broader telecommunication’s infrastructure. However,
NJFX’s efforts to increase their overall energy efficiency in their work and their facility, as well as
their choice to power their campus with carbon neutral energy sources, is evidence that the cable
industry can still contribute in many ways. Cable landing stations can play a significant role in the
development of a more sustainable Internet.

4.1.4 Solomon Islands Submarine Cable Company

Access to telecommunications infrastructure is not distributed equally. Many smaller countries,
particularly islands, are highly dependent on a few subsea cables because they are limited by their
geography. Likewise, countries with limited economic resources are often unable to secure
consistent access to the Internet. These obstacles can make sustainable initiatives for
telecommunications companies in these areas difficult. However, the work of Andrew Joel Siru of
the Solomon Islands Submarine Cable Company suggests that, even in situations where
sustainability programs may not be easily realized, small steps are still possible.
The Solomon Islands Submarine Cable Company began operations in 2020 after many years of
planning and development. By 2021 Andrew Joel Siru, an employee at SISCC, started to work on
developing a green agenda for the organization to act responsibly for the environment. This
included increasing efficiency to reduce energy consumption after consulting with people who
developed similar programs at other companies. As a start, Siru helped to launch company
initiatives around turning off lights, air conditioners, and devices in the offices of SISCC when not
in use. He was able to install nozzles on sinks in the facility to reduce water consumption. In
addition to these initiatives, Siru started the process of tracking energy usage for SISCC.
These efforts might not seem to compare to the construction of a cable ship, but it is important
to remember that every little bit counts.

4.1.5 Prysmian
In May 2021, the Prysmian Group announced working for sustainability with its ECO CABLE, a
business strategy consistent with the UN Sustainable Development Goals. ECO CABLE is the first
green label in the cable industry and vouches for the greenness of their cables.
(https://subtelforum.com/prysmian-working-for-sustainability-with-eco-cable/)
In July 2021, the Prysmian Group commented on the importance of energy efficient fiber
solutions, highlighting the need for operators to prioritize green solutions for the post Covid-19
era, with optical fiber significantly outperforming its rivals in terms of consumption. By deploying
optical fiber networks that use eco-friendly materials, Prysmian believe operators will reduce
energy consumption and cut out unnecessary emissions across the supply chain, according to their
official press release. As countries across the continent prepare for the post Covid-19 era, quality
passive optical networks will be essential to enable their digital transformation.
(https://subtelforum.com/prysmian-group-on-the-importance-of-energy-efficient-fiber-solutions/)

06 April 2023 | Page 52 of 95 | Version 1.0

4.2 Carbon Footprint Modelling

4.2.1 Definition of a Green Project

A Green project means a project that makes products or develops technologies that are primarily
aimed at reducing greenhouse gas emissions such as the use of clean energy and reducing other
forms of emissions which impact the environment including water and air quality. Examples of
green sustainable projects are:
§ ICF Construction from Fox Blocks
§ Green Spaces
§ Eco-Friendly Aesthetics
§ Solar Panels
§ Waste-to-Energy Recycling
§ Water Treatment Plants
§ Wind Turbines
§ Hydro power
§ Aquaculture
Similarly, Green project management is a model where APTelecom think green throughout the
BALTIC project and make decisions with strong consideration for the impact to the environment.
Thus, the team is ingraining “green think” into the entire lifecycle of the project and project
management process.

4.2.2 Sustainability Requirements Development

APTelecom created a Sustainability Model specific to submarine cable projects, which was then
applied to the BALTIC. The Model takes into consideration five major categories that impact a
project during its estimated 25-year life cycle shown, namely:
§ Design & Engineering
§ Survey
§ Manufacturing
§ Installation
§ Life-cycle Energy Usage
In looking at the lifecycle shown in Figure 14: Sustainability Model, APTelecom developed
sustainability requirements for throughout the effort, such as:
§ Applicable measurements and Key Performance Indicators (KPI’s) for
§ Renewable to include Biomass, geothermal, hydropower, solar and wind
§ Energy that comes from a source that naturally renews itself
§ Energy that comes from sources that do not impact future generations

06 April 2023 | Page 53 of 95 | Version 1.0

 Survey System Installation
System Design • XXX tCO2e Manufacture Life Cycle
& Engineering • CO2 Mitigators
• XXX tCO2e Cable System
• XXX tCO2e • CO2 Mitigators • XXX tCO2e CO2 Footprint
• XXX tCO2e • Fewer • CO2 Mitigators • Less burial • CO2 Mitigators - tCO2e
• CO2 Mitigators: survey Kms
• Less fiber • Optimal • Green energy
• Fewer flights • Optimal
transiting • Less Armor transiting

Figure 14: Sustainability Model2

The provided model is preliminary. During each phase of the project, the model should be updated
in terms of algorithms, assumptions and unit demands based on input form the various Suppliers.
At all times, APTelecom should look to expand the model to make it more holistic and capture
additional areas based on the materiality of the relevant emissions. The client should identify a
Sustainability Leader for the Project that is responsible for this module and leading discussions
with the engineering teams and Suppliers to complete it. As part of this, any decision which is
deemed to have an impact on the outcome with respect to sustainability should be logged
including calculations on the impact3.

4.2.3 Assumptions of Sustainability Model

To apply the BALTIC variables to the sustainability model, APTelecom made a series of
assumptions to normalize the data. The submarine cable industry is still in its infancy when
considering the indirect environmental impacts of designing, manufacturing, and installing a cable
system.
The Model assumptions made hereafter are utilized with the intention of normalizing the data
and are as follows:
1. Based on 24-hour operations
2. Applicable in-field vessel speeds
o Installation - Burial @ 25km/day, .5 knots/hour
o Installation - Surface Lay @ 150km/day, 3 knots/hour
o Survey – Survey kms factored by 30% for multiple passes
o Survey - Actual Survey kms – 2,135
3. A survey boat creates ~25% of tCO2e of that of a cable vessel
4. Manufacturing Waste estimated at 1%
5. Design and Engineering assumed to be negligible
6. tCO2e footprint does not include repairs to system
7. Four shore ends calculated in CLS Energy Usage
8. Natural Gas used in CLS energy usage figure

4.2.4 Results of Sustainability Model

Rates of tCO2e were applied individually to design & engineering, survey, manufacturing,
installation, and life-cycle energy usage, resulting in the following table:

2tCO2e stands for tonnes (t) of carbon dioxide (CO2) equivalent (e) where "Tonne" is a metric ton, or 2,200 pounds, and
“Carbon dioxide equivalent” is a standard unit for counting greenhouse gas (GHG) emissions, such as carbon dioxide or
methane.
3 Decisions can be combined and detailed as one such as if comparing two routing options with several different gaps.
One could then be labeled – “optimal time and cost” and the other as “optimal sustainability” and the differences
identified along with an impact in tabular form for future reference.

06 April 2023 | Page 54 of 95 | Version 1.0

 Table 13: Sustainability Model - BALTIC Results

No. Components MT Usage

1.0 Design & Engineering -
2.0 Survey 290.10
3.0 Manufacturing
3.1 1. System 4,221.20
3.2 2. Fiber 0.01
3.3 3. SLTE -
3.4 4.Waste Materials 42.21
4.0 Installation 1,908.06
5.0 Lifecycle
5.1 CLS Energy Usage (2 Shore Ends) 57,850.00

Total 64,311.58

The results of the assumptions and inputs to the project sustainability model resulted in a grand
total of 64,311.58 tCO2e emitted during the totality of the project’s life.
The use of carbon credits has been avoided for this project as they do not directly reduce carbon
footprint. Actual reduction of the carbon footprint is the desired objective the BALTIC
sustainability initiative.

4.3 Prospective CO2 Mitigators

4.3.1 Design & Engineering

It was determined that the tCO2e usage during the Design & Engineering phase of the project was
negligible. The CO2 generated can be attributed almost exclusively to project team travel and
supporting office space. Travel is easily mitigated by holding telephonic or remote team meetings
when feasible. Office space and supporting systems, are not considered within scope of this
initiative due to the impact outside this project delivery.

4.3.2 Survey
The Survey calculation was based on both shallow and deep water surveys but not in-shore survey,
and the figure was determined by examining the estimated route length, estimated portion of
route where multiple passes are required, expected active survey days, and applying the tCO2e
produced by a typical survey boat over that period. It was determined that a survey for BALTIC
could expect to produce 290.1 tCO2e over the course of the project.
A mitigating factor for this figure would be to operate the survey boat, or boats, at their optimal
fuel burn rate, rather than their fastest operating speeds. This could potentially add to the overall
duration of the project but would save on fuel and in turn reduce overall emissions.

06 April 2023 | Page 55 of 95 | Version 1.0

4.3.3 Manufacturing
The Manufacturing figure was found by examining the overall estimated system length and
armoring types and applying industry estimates to produce cable. Per Figure 15: Carbon Footprint
of Submarine Cable Production, the industry has begun estimating the tCO2e generated during
submarine cable production.

Carbon Footprint of Submarine Cable Production

14

12

10

0
LW SA DA

tCO2e/Km

Figure 15: Carbon Footprint of Submarine Cable Production

Lightweight protected cable represents 42% of the system and is manufactured with 1,774.23
tCO2e generated, Single Armor represents 25% of the system and is manufactured with 1,062.164
tCO2e generated, and Double Armor represents 33% of the system and is manufactured with
1,384.798 tCO2e generated. The total tCO2e generated during manufacturing is 4,221.2.
The tCO2e cost of manufacturing is a hard figure, the industry has yet to address this aspect of
concern. The real opportunity for mitigation falls to maximizing the cable routing, optimizing the
use of Lightweight cable throughout the system. It was determined that the tCO2e cost of
manufacturing the fiber core was negligible and had minor impact on the total system cost.

4.3.4 Installation
The Installation figure was determined by examining the estimated route length, estimated
crossings, estimated marine operations, expected installation days, and applying the tCO2e
produced by a typical cable vessel over that period. It was determined that an installation for
BALTIC could expect to produce 1,908.06 tCO2e over the course of the project.
There are several mitigations that System Supplier could propose though some may adversely
impact cost mostly through additional ship days. Examples of footprint optimizations for marine
vessels include:
§ Optimization of selected vessels to newer, more fuel-efficient variety;
§ Operating the cable vessel, or vessels, at their optimal fuel burn rate, rather than their
fastest operating speeds;
§ Select cleaner bunker fuels to reduce emissions in consideration of availability;

06 April 2023 | Page 56 of 95 | Version 1.0

 § Use of alternate cleaner shore power when in port;
§ Minimize transit times and distances; and;
§ Optimize cable route to minimize burial, which may add to the overall risk profile of the
BALTIC.

4.3.5 Lifecycle
According to the U.S. Energy Information Administration “emissions from electricity generation
vary by type of fuel/energy source and by type and efficiency of electric power plants. The amount
of CO2 produced per kWh during any period will vary according to the sources of electricity
supplied to the electric power grid during that time. Therefore, electricity-related CO2 emissions
and CO2 emission factors will vary hourly, daily, monthly, and annually.”
As such, APTelecom has performed a rough calculation of the expected energy cost to run a typical
shore end station in a given year.
It is estimated that a typical shore end configuration will require 1.4M kilowatt hours (kWh) in a
year. Assuming that the energy is derived from natural gas, the shore will require 578.5 tCO2e be
generated based on a value of 1.4M kWh per 1.275M pounds tCO2e. There are four shore ends
being considered, the number is multiplied by four and then multiplied by 25 resulting in a total
of 57,850 tCO2e generated over an expected life cycle of 25 years. Further, if the shore ends are
powered by coal fired plants, the tCO2e generated is increased 2.5 times, or 144,625 tCO2e.
The mitigation consideration, or greatest factor to tCO2e savings, is powering the BALTIC by a
sustainable source. By seeking power generated through the sustainable power, roughly 89% of
the tCO2e generated for the project can be saved.
Other lifecycle costs that were not considered at this point due to limited data include:
§ One shop repair during life
§ O&M including NOC office space, systems, and travel
§ Refresh of Dry Plant

4.4 RFP Criteria

APTelecom developed the sustainability criteria that can be utilized as a part of the Supplier
selection and adjudication in the eventual BALTIC RFP. In developing these criteria, APTelecom
considered the infancy of the submarine cable industry in the sustainability space. As the industry
is infant and the sustainability models are initial drafts which need to be populated with “actual
or real data,” the RFP criteria looks to not only measure sustainable practices, but also measure
to what extent the System Suppliers are committed to this space including their willingness to be
transparent with project data. If project data is not obtained, it is impossible to measure their
sustainable practices as only order of magnitude estimates from various sources will be available.
The proprietary APTelecom Project RFP Evaluation Matrix is based upon the Request for Proposal.
The Commercial portion follows the terms identified in the Terms and Conditions with additions
for Financing and Financial Capability and Sustainability. The Technical portion of the matrix
follows the outline of the Scope of Work with additional criteria for Alternative Proposals and
Value Engineering.
The weights assigned to each criterion are meant to reflect the subjective impact of each criterion
on design, cost, and/or schedule. The weights are subjective and based upon:

06 April 2023 | Page 57 of 95 | Version 1.0

 Table 14: RFP Weights Table

Value Weights
0 Item N/A, or not in RFP
1 Unimportant
2 Notable
3 Important
4 Very Important
5 Critical

Each Supplier’s response will be assigned a score based upon his proposal. If a Supplier does not
address a criterion, that criterion will be given a score of zero (except for the additional criteria).
The scoring is based upon a scale of zero to five as follows:

Table 15: RFP Scoring Table

Value Scoring
0 Does not meet requirements; no evidence of ability to meet requirement
1 Low evidence of ability to meet requirement
2 Partially meets requirements
3 Meets requirements - Baseline Scoring
4 Meets requirements with some "nice to have" additions
5 Significantly exceeds requirements

APTelecom will determine a series of questions to be posed to the Suppliers during the RFP
process. These questions will determine the Suppliers’ current long-term plans for sustainability
and willingness to work with the cleint for sustainable solutions for the BALTIC. As evidenced by
the Suppliers’ responses in section Error! Reference source not found., efforts are very disparate
and will need very high-level criteria to find any common factors for comparison.
Table 16: Sustainability RFP Recommended Requirements

Ref. Category Weight Score Weighted Comments

Score
1 Sustainability Requirements
1.1 Does your company possess the ISO 5 - - This question is
14001:2015 Certification? first and most
important of
the list. If a
company
possesses this
certification,
they are
already
considering and
tracking data

06 April 2023 | Page 58 of 95 | Version 1.0

Ref. Category Weight Score Weighted Comments
Score
and sustainable
practices.
1.2 How is your company committing to 4 - - It is understood
real, long-term sustainable practices that
and what are five sustainable APTelecom
changes you have made specific to wishes to select
the submarine cable industry? a Supplier with
a vision for
their
sustainable
practices over
time.
1.3 How much per annum and for how 4 - - The greatest
many years is your company predictor of if a
investing in sustainable practices? company is
taking their
sustainability
goals seriously
is if they are
investing in
discovering,
refining, or
developing new
sustainable
practices.
1.4 What is your level of willingness to 4 - - Tracking the
share data with APTelecom for the carbon
analysis of sustainability data footprint of the
(provide a table of metrics you can project is a key
share) Tenant of the
BALTIC, as
such,Client will
require data
provided by the
Supplier.
1.5 What are you willing to do to reduce 4 - - Client is
emissions on this project (provide a seeking a
table of actions including cost and Supplier who is
time impacts)? willing to work
outside of the
industry’s
current model
for sustainable
practices. This
Supplier will be
a leader for
new practices
and ideas in the

06 April 2023 | Page 59 of 95 | Version 1.0

Ref. Category Weight Score Weighted Comments
Score
submarine
cable space.

06 April 2023 | Page 60 of 95 | Version 1.0

5. PERMITTING & REGULATIONS

5.1 Overview
Applicable data has been gathered and assembled of the BALTIC to provide a high-level review of
the possible permitting process and requirements. Review of the information provided shows an
understanding of the process and requirements for permits and applications. A summary review
of the overall permitting process is below, which is meant as a summary/overview table and
should not be considered complete

5.2 General
The following section generally and then specifically describes the possible permits and regulatory
requirements required as well as, assesses the risk and environmental concerns and processes for
cable installation of BALTIC. As in the case with virtually all submarine cable projects, the
permitting process is likely to be in the critical path for BALTIC and thus, fundamental to its timely
and successful implementation. The importance of permitting cannot be overstated. Sufficient
time must be allowed to consider the complexity of the permitting procedures.

5.3 Permitting Requirements by Country

5.3.1 Rostock, Germany

The following is an assessment of the possible permitting and approval processes needed to install
a cable system in Rostock, Germany. Germany operates as a parliamentary and federal democracy
allowing some independence for the states. Rostock is the largest city in the state of Mecklenburg-
Western Pomerania and lies at the head of the Warnow River estuary, 8 miles (13km) south-
southeast of its Baltic outport at Warnemünde. With German being the dominant language, it is
suggested that a translator or bilingual consultant be obtained to assist with the negotiating and
planning. The anticipated landing location is located on a public sandy beach. It does not appear
to interfere with any protected areas or habitats.
The following is an assessment of the possible permitting and approval processes needed to install
a submarine cable system in this location

5.3.1.1 Federal Mining Act Approval

The laying of submarine cables requires prior official approval from the respective competent
state mining authority. The mining authorities examine whether the project conflicts with mining
law interests. The Stralsund Mining Authority is the specialist authority for mining law in the state
of Mecklenburg-Western Pomerania. According to the Federal Mining Act, it is responsible for
all mining permits and operating plan procedures in the country as well as in the
associated continental shelf and coastal sea . As a hearing and plan approval authority, the Mining
Authority is responsible not only for mining law but also for energy law plan approval
procedures. This includes the extraction of geothermal energy, the construction and operation
of underground storage facilities and the construction of high-pressure gas pipelines in
accordance with the Energy Industry Act.
The project-executing entity must submit a corresponding application. The application must be
accompanied by documents indicating the type and scope of the planned project and any possible
impairment of legal interests (life, health, property, public interests). Further details are regulated
by the legal basis - the Federal Mining Act (BBergG).

06 April 2023 | Page 61 of 95 | Version 1.0

5.3.1.2 Federal Maritime and Hydrographic Agency (BSH) Approval/License
Federal Maritime and Hydrographic Agency is responsible for most aspects related to maritime
spatial planning (shipping, fisheries, sediment extraction, military use etc.), Submarine cable
installation requires approval from the Federal Maritime and Hydrographic Agency (BSH) based
on the Federal Mining Act. The BSH examines whether the project is compatible with the proper
use of the waters above the continental shelf and the airspace above these waters. When
determining the cable route issues of cable routing in conformity with spatial planning, proper
laying techniques and depth as well as species and nature conservation should be considered.
The first step in the approval process is a pre-application meeting with a consultant from the
agency. This will maximize time and minimize cost as the requirements will be outlined. The public
must be involved at least once during the pre-application section. This should include an
explanation of the project and the importance to the community and should be allow for the
public to provide feedback.
The next step it to complete the tasks set out in the pre-application meeting which may include a
form of Environmental Assessment (see below). Once all requirements are complete a decision
will be made by the agency and a license or approval will be granted or rejected.
Once approval has been granted, the project is subject to supervision by the BSH. If necessary,
the BSH may issue orders to ensure the proper implementation of the project.

5.3.1.3 Environmental Approval

Environmental assessments are important environmental protection tools. By involving
authorities and citizens and incorporating environmental reports, the potential environmental
impacts of a planned project can be identified at an early stage and taken into consideration
during the decision-making process. To this end there are various instruments, for example the
environmental impact assessment (EIA) and the strategic environmental assessment (SEA).
An EIA determines and describes in a report what impact a project will have on humans (including
human health), on animals, plants, biodiversity, soil, water, ambient air, the climate, the
landscape, and cultural goods. The public and specialist authorities, as well as citizens and
authorities in neighboring countries that may be affected, may express comments and opinions
on the report. The authority responsible for approving a project is tasked with evaluating the
information and comments and with taking account of the results of the EIA when deciding
whether to approve a project.
The strategic environmental assessment (SEA) complements the EIA. The difference between the
two is that an SEA is conducted at an earlier stage than an EIA. While an EIA is not conducted until
an environmentally relevant project enters the approval process, an SEA is conducted at the
planning stage because important decisions relating to the environment often must be taken in
the context of preparatory plans and programs.
An SEA must be conducted for each important planning procedure that is of relevance to the
environment, for example federal transport infrastructure planning, regional and area
development planning, or planning in the fields of water and waste management, air quality
management and noise protection. The key element in the SEA is the environmental report, which
details and evaluates the anticipated environmental impacts of the plan or program as well as
sensible planning alternatives. Environmental authorities and the public must also be involved.
After concluding the process, the competent authority must describe how it took account of the
environmental report and the comments and opinions submitted when taking its decision, and

06 April 2023 | Page 62 of 95 | Version 1.0

 why a specific plan has been chosen after weighing it up against the other assessed alternatives.
Because of the close connection between SEAs and EIAs, the Act on the Assessment of
Environmental Impacts also contains provisions governing SEAs.
If an environmental assessment is necessary, it is anticipated that it will be in the form of an SEA
as the potential landing location does not appear to have any areas of concern. It is possible that
the public may have concern as the landing location is on a public beach however, this will most
likely be overridden by the authorities due to the benefit of the system.

5.3.2 Copenhagen, Denmark

The anticipated landing location of the Baltic Cable is in Copenhagen, Denmark. Copenhagen is
the capital and largest city of Denmark. It is located on the islands of Zealand (Sjælland) and
Amager, at the southern end of The Sound (Øresund). The system of governance in Denmark is a
parliamentary democracy. The Parliament in Denmark is called the Folketing, and it has a multi-
party structure. Though the dominant language is Danish, many are fluent in English which is the
dominant second language.

5.3.2.1 Seabed Works Permit

The Danish Maritime Authority is consulted in connection with VVM examinations because the
pollution that may arise due to marine accidents can be considerable. Thus, safety of navigation
also concerns the risk of pollution. In this connection, the Danish Maritime Authority focuses on
things that can be done to secure navigation during the construction phase and onwards. A permit
may be required to conduct work. The application and supplemental material must be submitted
to the safety of navigation, national waters sector of the agency. The following information must
be provided:
§ Contact details of the person or company responsible and of any substitute,
§ Description of the activity,
§ Chartlet with a simple outline of the location of the activity in the territorial waters,
§ Geographical longitude/latitude positions of the activity (WGS84 Datum (for example
57°25.86' N 10°42.75' E)),
§ Period of the activity,
§ Unresolved navigational objections from the users of the waters together with a list of the
parties consulted,
§ Assessment of the impact on navigational safety and freedom of navigation in connection
with the various phases of the activity,
§ Overview of the preventive measures planned and
§ List of work vessels intended to be used in connection with the activity.
If a permit is required and granted, during construction, there will be a safety zone around the
cable-lay vessel, within which ship traffic and fishery are prohibited. However, the cable
installation is a moving process, and the safety zone will be of a short duration at any given
location. According to the Executive Order on the protection of cables and submarine pipelines
(BEK no. 939 of 27/11/1992) section 4, a ±200 m protection zone is automatically established on
either side of a subsea cable. Within this zone, anchoring, extraction of materials and any use of
tools that drag on the bottom (including bottom trawling) are prohibited. Upon request by the

06 April 2023 | Page 63 of 95 | Version 1.0

 cable owner, the Danish Maritime Authority may repeal the general ban on fishing in the
protection zone. In accordance with the Fishery Act of 19/06/2017 Chapter 15, Danish fishermen
can make a claim that they should be compensated because of the reduction of the area at the
seabed available for fishery.

5.3.2.2 Permit under the Coastal Protection Act

The competent authority for permitting of an offshore data cable is the Danish Coastal Authority,
which is a division of The Danish Ministry of the Environment. A permission will be granted in
accordance with the Act on Coastal Protection (LBK no. 78 dated 19/01/2017). Guidance on
relevant considerations and requirements are described in the guidance on the laying of
telecommunications cables and certain pipelines in the territorial sea (VEJ no. 163 dated
17/09/2001)1. Once the Danish Coastal Authority has received an application containing all the
necessary information, they will begin processing the case. Before the Danish Coastal Authority
decides, the application will be sent into consultation with other relevant authorities such as (but
not limited too) the Danish Maritime Authority, The Danish Agrifish Agency, Danish Environmental
Protection Agency, The Danish Energy Agency, etc.). They will assist in the assessment of the
potential impact of the project in relation to, inter alia, shipping, fisheries, the environment,
cultural heritage, nature conservation, marine spatial planning, and existing facilities. The internal
authority consultation period usually lasts four to eight weeks. In addition, other relevant
stakeholders will be informed and given the chance to provide comments (the Danish Coastal
Authority decides who they need to inform/consult). The application will also be posted on the
homepage of the Danish Coastal Authority, giving the public an opportunity to comment on it.
Costs involved will be discussed throughout the process.

5.3.2.3 Environmental Assessment

The framework in Denmark regarding SEA and EIA consists of several Acts and regulations and
competent authorities. The application of these depends on the type of plan or project subject to
SEA/EIA and whether these are covered by specific sector laws. Though many authorities may play
a role in the process it is anticipated that the Danish Energy Agency will be the dominant authority.
The permit given based on and in coherence with the Environmental Assessment Act contains all
the environmental conditions connected to the permit, including the characteristics and measures
planned to avoid, prevent, or limit and, if possible, neutralize significant harmful effects on the
environment and any monitoring measures. The competent authority can thereby set out terms
for the permit to meet the objectives of the Act. If the project is found to have harmful effects on
the environment the authority will set out terms for monitoring these effects.
The environmental assessment of plans and programs is sometimes called an SEA, which stands
for Strategic Environmental Assessment. SEA is the term used for environmental assessments of
plans, programs, and political objectives, i.e., an assessment of their impacts on the environment.
The strategic environmental assessment of plans and programs must be considered a regulatory
process superimposed on the provisions relating to EIAs. The strategic environmental assessment
of plans and programs is conducted at the level before the project level, with an assessment being
made of whether an EIA report should be prepared, and therefore also at an earlier stage in the
decision-making process.
The purpose of a strategic environmental assessment of plans and programs is to ensure that an
assessment of environmental consequences and possible alternatives is conducted while the
plans are still under preparation and being considered politically, i.e., before they have been

06 April 2023 | Page 64 of 95 | Version 1.0

 adopted with final effect. This will ensure a high level of environmental protection and that
environmental considerations are integrated in connection with the preparation of plans.
An EIA report must be prepared for a specific project that is subject to an obligation for
preparation of an EIA. This means that detailed surveys must be conducted to assess the
environmental consequences of the 12 projects, both individually and cumulatively with existing
installations and other planned activities. If the project can be expected to impact on an
international nature protection area within or outside Danish territory, an assessment of the
impacts on international nature protection areas must also be conducted. Before a license or
permit can be issued for the project, the impact assessment must demonstrate that the activity
will not damage the international nature protection area. In addition, species that are protected
pursuant to the Habitats Directive must not be intentionally disturbed in their natural habitats,
particularly during periods when the animals are breeding, nurturing their young, overwintering
or migrating, with harmful effects for the species or the population as a result. It is also prohibited
to damage or destroy their breeding or rest areas. Only once a specific project has been prepared
can a delimited survey area, emissions and sound radiation be defined etc., and only then can
field surveys be conducted to supplement knowledge about the existing conditions and status in
the area concerned.
The Environmental Assessment Act include two annexes containing the project categories; a
category listing projects which are mandatory to undertake an EIA (annex 1), and a list of project
categories where it is decided on the basis of a screening whether the project is likely to have
significant effects on the environment and therefore subject to EIA or not (annex 2).
The installation of a submarine cable is considered under annex 2 therefore an EIA is not expected
however, an SEA will most likely be necessary. It is important to note that this will play a significant
role in the other permits necessary for cable installation.

5.3.3 Stockholm, Sweden

The proposed landing of the Baltic cable is Stockholm, the capital and largest city of Sweden,
located at the junction of Lake Mälar (Mälaren) and Salt Bay (Saltsjön). The city is built upon
numerous islands as well as the mainland of Uppland and Södermanland. Sweden is a
constitutional monarchy. The Swedish Constitution (grundlagarna) consists of four fundamental
laws: the Instrument of Government, the Act of Succession, the Freedom of the Press Act, and
the Fundamental Law on Freedom of Expression. The Instrument of Government sets out the
basic principles of Sweden’s form of government: how the Government is to work, the
fundamental freedoms and rights of the Swedish people and how elections to the Parliament
(riksdagen) are to be implemented. It also contains some principles of relevance to
environmental matters. This is important to understanding the permitting structure required.

5.3.3.1 Continental Shelf Act Permit

For the laying of a submarine cable or pipeline on the continental shelf outside the territorial limit,
a permit (which may have a validity between 3-5 years) granted by the Government or such
authority as the Government may determine is required. The Geological Survey of Sweden is the
authority appointed by the government to handle these matters though the ministry of
Enterprise, Energy, and Communications will be heavily involved.
In general, a survey prior to the laying of an underwater cable or pipeline is required before
applying for a permit. It is suggested that a local agency be hired for the surveying process. This
should focus, amongst other things, on mapping of sedimentation types to the relevant sediment

06 April 2023 | Page 65 of 95 | Version 1.0

depth, for example to determine where to take an environmental toxicity sample and to establish
which methods (e.g., flushing, ploughing, covering) are best suited to laying the cable or pipeline
in the sediment to the required depth. Normally, surveys should initially be performed using
appropriate hydroacoustic measurement. The measurement data is then interpreted to
determine, for example, where accumulation bottoms are located. Only then is it possible for
environmental sampling at relevant locations to take place to find possible environmental toxins.
For reliable results, environmental sampling requires high precision and therefore needs to be
conducted at a suitable site, with appropriate equipment and by expert and experienced
personnel.
The main content that an application must have been established by the Proclamation concerning
the Application of the Act on the Continental Shelf. However, the requirements for the content of
the application are different depending on the application (for example, surveying the seabed,
sand extraction or laying underwater cables). In general, each application should include:

§ Information on the applicant, address, etc.,

§ Information on the area and the period for which the application is made,
§ Information on the activity, its purpose, which vessel(s), platforms, methods, instruments,
and sampling equipment are being deployed,
§ Information needed to assess compliance with the general review rules laid down in chapter
2 of the environmental code and to assess the possible impact of the activities on the
biological and physical environment;
§ Information on hydrography, for example water depth, exposure to wave effects, currents
and stratification and properties of the water mass;
§ Information on geology, for example, the make-up of the seabed, properties, geotechnical
conditions and the distribution of sediment, bedrock and surface substrates, as well as the
structure of the seabed, properties, geotechnical conditions and make-up (sediment layers)
down to the relevant sediment depth below the seabed surface; in some cases also
information on the existence of natural erosion protection in the form of coarse residuals,
young mud-rich sediments and sulfur-bearing sediments, known as sulphide soil
§ Information on sediment-dynamic conditions, such as the occurrence of erosion, transport
or accumulation bottom at the site, the occurrence of accumulation of fine-grained
sediments with a high organic content, sand transport systems and fine-grained sediments
with natural erosion protection on the erosion or transport bottom);
§ Indication of environmental conditions and loads, for example: content of high levels of
organic pollutants and metals, see Class 5 and higher levels according to the criteria of the
Swedish Environmental Protection Agency; in particular with reference to young mud and
silt sediments;
§ Information on flora and fauna, for example: presence of number of species, number of
individuals, vegetation, marine mammals, bird life, species of animal or plant which are
threatened, rare or require consideration for any other reason;
§ Information on, amongst other things, sand, gravel and mineral resources, pollution
situation in sediments and water, antiquities, aberrant objects, wrecks, unexploded
ordnance, etc. in the area in question,

06 April 2023 | Page 66 of 95 | Version 1.0

 § Information on the measures the applicant considers necessary to prevent water pollution
and encroachment of shipping, fisheries, and other public and private interests;
§ Work program for the activities,
§ Information on the applicant's technical and economic conditions for the activities,
§ Map (prepared in accordance with SGU instructions for the individual case), positions
(preferably in SWEREF 99 TM) and a description of the site in question,
§ Copy of/information on the necessary distribution permits (see paragraph below "Specific
information on hydrographic surveying and distribution permits", and
§ Environmental impact assessment (if required).
If the application relates to exploration of the continental shelf involving blasting or drilling, or if
the application is for the extraction of natural resources from the shelf, the applicant is normally
required to draw up an EIA in accordance with the provisions established in Chapter 6 of the
Environmental Code, if the activity or measure is likely to have significant environmental impacts.
The approval process generally follows the following process:
§ The application and its annexes, as well as any EIA, are checked. If supplements are required,
they are requested from the applicant.
§ The application is referred to the relevant authorities, such as the Swedish Armed Forces,
the Swedish Coast Guard, the Swedish Maritime Administration, the Swedish Environmental
Protection Agency, the Swedish Agency for Marine and Water Management and the Swedish
National Heritage Board In addition, the matter is sent to the relevant county boards and, in
the case of wind power or gas pipelines, also to the Swedish Energy Agency and the Energy
Markets Inspectorate.
§ The applicant is given the opportunity to respond to the comments received.
§ SGU collates the comments received and the applicant's response to them.
§ SGU makes a judgement on the case. SGU's knowledge and experience of the geological
conditions of the site and the possible environmental impact of marine activities are in many
cases of crucial importance to the assessment.
§ SGU decides on the case. If the application must be reviewed by the government, SGU
submits an opinion to the government with a decision-making proposal (including a proposal
for terms and conditions)
In accordance with the Swedish Continental shelf Act, SGU's processing of a case takes an average
of approximately 6-12 months. If the matter is dealt with on behalf of the government, the
government's own time for processing the matter is added to this. However, the duration of the
proceedings may be shorter and longer depending on the circumstances of the individual case.

5.3.3.2 Environmental Impact Assessment

As stated above an EIA may be necessary to obtain the required permits. The purpose of an EIA is
to establish and describe the direct and indirect impact of a planned activity or measure on
people, animals, plants, land, water, air, the climate, the landscape and the cultural environment,
on the management of land, water and the physical environment in general, and on other
management of materials, raw materials and energy. Another purpose is to enable an overall
assessment to be made of this impact on human health and the environment. An EIA shall be part

06 April 2023 | Page 67 of 95 | Version 1.0

 of an application for a permit relating to environmentally hazardous activity and health
protection, water operations, game enclosures and the Government’s consideration of
permissibility.
If the county administrative board decides pursuant to section 4 that the activity or measure is
likely to have a significant environmental impact, an EIA procedure shall be held. In such a
procedure the person who intends to undertake the activity or measure shall consult the other
government agencies, the municipalities, the citizens, and the organizations that are likely to be
affected. The consultation shall relate to the location, scope, design and environmental impact of
the activity or measure and the content and structure of the environmental impact statement.
The Swedish Environmental Protection Agency is the agency responsible for sending and receiving
notifications and for fulfilling the Party’s responsibilities
The production of the EIA is the responsibility of the applicant. The County Administrative Board
has responsibilities in the process and particularly in the early phases such as screening.
The notification is usually sent when the consultation (in the scoping phase) starts with citizens
and organizations that are likely to be affected in Sweden. At a minimum, the following
information should be included.
§ Description of the activity or measure with details of its location, design, and scope;
§ Description of the measures being planned with a view to avoiding, mitigating, or remedying
adverse effects, for example action to prevent the activity or measure leading to an
infringement of an environmental quality standard referred to in chapter 5;
§ Information that is needed to establish and assess the main impact on human health, the
environment and management of land, water, and other resources that the activity or
measure is likely to have;
§ Description of possible alternative sites and alternative designs, together with a statement
of the reasons why a specific alternative was chosen and a description of the consequences
if the activity or measure is not implemented; and
§ Non-technical summary of the information specified in points 1-4.
There are no legal time limits for the consultation in Sweden. The timeframe for answers is
discussed with the developer and with the Point of Contact in the Affected Party. The cost of an
environmental impact statement and an EIA procedure shall be borne by the person applying or
who is otherwise required to prepare an environmental impact statement.

5.3.4 Helsinki, Finland

The following outlines the possible permits required to install a submarine cable in Helsinki, the
capital of Finland and the leading seaport and industrial city of the nation. Helsinki lies in the far
south of the country, on a peninsula that is fringed by natural harbors and that protrudes into
the Gulf of Finland. The Finnish Government is the executive branch and cabinet of Finland,
which directs the politics of Finland and is the main source of legislation proposed to
the Parliament. The Government has collective ministerial responsibility.

5.3.4.1 Permit in accordance with the Water Act

It is recommended that the constructor contact the Finnish Transport Agency already in the
planning stages of cable or pipeline alignment to find as unobstructed alignment with a view to
waterborne traffic as possible. At the same time, it is also possible to conduct a preliminary survey

06 April 2023 | Page 68 of 95 | Version 1.0

 of how to mark the cable or pipeline at sea, if needed. At the Finnish Transport Agency, the
contacts in matters relating to cables and pipelines are the agency's units for sea channels and
inland waterway
Pursuant to Chapter 3 of the Water Act, construction of a water, sewer, power, or other line under
a general or main channel is always subject to a permit in accordance with the Water Act. A permit
is also regarded necessary if the cable or line runs in the channel area, even if it did not cross the
channel. A permit may be needed also even if there was no general or main channel in the area if
the case is a situation referred to in Chapter 3, Section 2 of the Water Act, in which the project
“may cause changes in the state, depth, water level or flow, shore, or aquatic environment of a
water body or the quality or quantity of groundwater”, and this change causes damage, harm or
loss of benefit referred to in Section 2. It is highly suggested that the applicant contacts the
regional Centre for Economic Development, Transport and the Environment (ELY Centre), which
acts as supervising authority in these matters, for a statement on whether a permit is needed in
order to reduce unnecessary time and cost.
It is worth noting that it is necessary to mark submarine cables and pipelines to avoid any
unintentional damage to them and any accidents they might cause to others. From the
perspective of waterborne traffic, the need to mark them is decided in accordance with the
following principles:
§ As a rule, any submarine cables or pipelines crossing a channel or otherwise running in the
channel area are always marked.
§ In other navigable water areas, submarine cables and pipelines are marked according to
circumstances and necessity.
§ If directional drilling is used for implementing the submarine passage across the whole width
of the channel, no cable or pipeline signs are needed to mark the cable or pipeline.
An advance notification shall be made to the Finnish Transport Agency on any construction or
installation work of overhead cables or submarine cables and pipelines in channel areas or other
watercourses used by waterborne traffic for the purpose of issuing notifications and warnings for
seafarers. At the same time, potential special arrangements concerning waterborne traffic during
construction can be preliminarily agreed upon, such as notifications and temporary markings at
sea. These procedures will be specified further as needed during construction. Information on
completed overhead cables or submarine cables and pipelines is submitted to the Finnish
Transport Agency for having them marked on the nautical charts and included in the publication
“Notices to Mariners.” A notification on overhead cables is made every time a cable crosses a
public channel marked on nautical charts. It is also advised that a notification is made on any other
overhead cables of significance for waterborne traffic. A notification on submarine cables and
pipelines shall be submitted if they are in navigable water areas.

5.3.4.2 Environmental Impact Assessment

The environmental impact assessment (EIA) is a regulatory procedure (overseen by the ELY
Centre) for determining the environmental impacts of a project. It is also designed to promote
opportunities for citizens to participate in and influence the planning process.
The submission is made to the responsible ELY Centre by the project coordinator, i.e., operator.
The procedure consists of the following stages:

§ Launch negotiations (optional)

06 April 2023 | Page 69 of 95 | Version 1.0

 § Advice and guidance (throughout the process)
§ Expert consulting in meetings of the steering/monitoring group (optional)
§ Public notification of the assessment program and report
§ Requests for comments on the assessment program and report
§ Public events (program and report)
§ A procedure in accordance with the Espoo agreement (projects with cross-boundary
impacts, the Ministry of the Environment coordinates the procedure)
§ The responsible authority’s statement on the assessment program
§ The responsible authority’s decision and grounds
§ Notification and communication of the decision
§ Meetings to discuss the program statement and decision (the project coordinator and the
responsible authority) (optional)
The procedure is considered to have been started when the authority receives the assessment
program. Launch negotiations etc. are common but not mandatory. The procedure concludes
when the responsible authority issues its statement on the assessment program to the project
coordinator. Authorities that are responsible for oversight in later project stages are notified of
the statement. The procedure may also include additional meetings to discuss the statement and
the updating of the project website.

The project coordinator must have a sufficiently detailed project plan so that the impacts can be
assessed and the ability to implement the EIA can be verified. There is a fee associated for the
service which is discussed on a case-by-case basis. The project coordinator pays the ELY Centre a
fee for the EIA program and report. The fee is based on the government decree on the Centre for
Economic Development, Transport and the Environment’s services subject to a fee. The amount
of the fee is adjusted annually.

5.4 Permitting Conclusion

The permitting process involved for BALTIC installation is expected to be straight forward. Careful
consultation with the appropriate government agencies is paramount to obtaining the required
information and to ensure unnecessary steps are not taken. This will also reduce time and cost.
Each location has a unique legislative structure however, some form of cable license/approval and
some form of environmental permit/approval is universal.

06 April 2023 | Page 70 of 95 | Version 1.0

6. IMPLEMENTATION

6.1 Project Methodology

Development of a project methodology starts with trying to identify the scope of responsibilities
between the primary System Supplier and the Purchaser directly or through supplementary
contracts. For BALTIC, the high level scope of responsibilities is summarized in Table 17 where it
is recommended BALTIC be delivered through a single System Supplier and limited responsibilities
fall within the Purchaser’s direct scope. The System Supplier is responsible to deliver the entire
scope as a Turnkey Project from CLS to CLS including the CLS itself at all four landings.
The Purchaser is responsible for their internal needs around the permits in principles (e.g., licenses
to operate and land a submarine cable), program management and representation and
operational readiness including the NOC systems and personnel.
The model provided in Table 17 is driven by the nature of the BALTIC ownership including it being
a first system for the ownership group and not having the internal skills to engineer and build the
system. This model will help reduce the risks. For the program management role, it is
recommended the Purchaser enlist the assistance of experienced resources to provide activities
such as:
§ Quality control including acceptance testing
§ Field and marine work monitoring representatives
§ System Supplier recommendations review and guidance prior to approval
§ Aggregated program/project reporting including financial and progress reporting
Project delivery will follow a typical role out starting with a procurement phase for the System
Supplier following the initial project planning which includes this Feasibility Study and the DTS.
Once System Supplier is selected and awarded, engineering will begin including the Marine Survey
to finalize route and initiate manufacturing followed by installation and commissioning. Once
commissioning is completed, the acceptance process will allow the system to start carrying
commercial traffic in early 2026.
Table 17: Delivery Responsibility

Activity Description Responsibility

Permits for work associated with the installation
of the system, including Marine and Terrestrial
Operational Permits System Supplier
installation work, including shore ends, BMH, OSP
facilities and the CLSs.
Studies to demonstrate proper care will be taken
Environmental
to preserve and minimize impact to the Purchaser
Study
environment, marine life, and people.
Operating licenses and other permits specific to
Principle Permits
the ownership and operation of the submarine Purchaser
and Licenses
cable system
Marine Route Marine Survey using vessels and divers to
Survey & Burial investigate the proposed route and provide System Supplier
Assessment Survey guidance on the ability to burial and propose

06 April 2023 | Page 71 of 95 | Version 1.0

 Activity Description Responsibility
alternatives to improve system installation and
reliability.
Wet or Submerged Submarine Cable, Repeaters, Branching Units,
System Supplier
Plant Splicing Kits, Spares, Crossings
Installation of submarine cable including burial
Marine Installation
less the shore ends. This also includes route System Supplier
– Main Lay
clearance using grapple runs (PLGR)
Marine Installation Installation of the last few kilometers of cable into
System Supplier
– Shore Ends each landing and might include HDD
Post Lay Inspection Remote Operated Vehicles (ROVs) to visually
System Supplier
and Burial inspect and jet bury portions of the cable
Electrical and fiber cabling between BMH and CLS
OSP or Land Cable System Supplier
including the ducts and BMH, RES
Includes electrical, sewage and water service-
Civil Works related work necessary to supply the CLS and System Supplier
system.
Buildings, building systems, generators, electrical
Cable Landing
systems including 48vdc, battery plant, internal System Supplier
Station
racks
Onshore Land
Land for BMH, CLS and Land Cable duct routes Purchaser
Acquisition
Terminal Power systems to operate submarine cable
System Supplier
Equipment – PFE repeaters
Purchaser via
Transmission Optical transmission equipment
Customers
NMS System specific monitoring and alerting system System Supplier
Network management system and facilities used
NOC Purchaser
by system operator which interface with NMS
Test Equipment OTDR and other tools and meters as recommend System Supplier
Engineering and Engineering and project management services are
Project standard cost elements included in every System Supplier
Management Supplier’s proposal
Program Oversight, representation, governance, and
Purchaser
Management general coordination
Training Technical training for operations and engineering: System Supplier
System specifications, as built, route survey data
and user manuals that the System Owner will need
Documentation System Supplier
to properly operate the system and especially for
the event of a system failure

06 April 2023 | Page 72 of 95 | Version 1.0

6.2 Plan of Work
The initial schedule provides a framework for BALTIC was previously provided in Figure 3. It will
be updated as Purchaser continues to seek potential partnerships and investors, which will
undoubtedly influence decisions as the project draws nearer to the procurement phase. A final
plan will be built during the procurement phase using input from the selected Suppliers and
accounting for other factors including permitting and seasonal allowances. This plan outlines each
phase of the implementation process and serves as a guide to help Purchaser as they implement
BALTIC.
The process of implementing a submarine cable system includes the following workstreams
though there is strong interdependence between outcomes which can cause adjustment:
1. Planning
2. Permitting
3. Land Acquisition
4. Procurement
5. Route Survey & Route Design
6. System Design
7. Manufacture
8. Installation & Commissioning
9. Operational Readiness
10. Ready For Service
These work streams illustrate the primary or key elements of an implementation plan at a high-
level and are not intended to be detailed at this stage as detailed schedules require Supplier input
and are dependent upon Purchaser readiness.
Purchaser will need to expand this plan to be very detailed as it begins work to implement the
system, working with stakeholders and Suppliers. A key component of this will be to integrate the
Plan of Work (PoW) provided by the System Supplier and identify the interdependencies between
each parties’ plans (for example, installation of Dry Plant is dependent upon CLS construction
which is dependent upon land acquisition and permitting). The final implementation plan should
also consider other elements of the system deployment, not in the scope of this study, such as
any terrestrial work required from the CLS to the third party data centers or domestic carrier
points of presence.

6.3 Planning
Typical Duration: 3-6 Months
Objectives:
§ Develop Design Plan
§ Complete DTS
§ Develop Implementation Approach

06 April 2023 | Page 73 of 95 | Version 1.0

 § Identify external points of integration for BALTIC
§ Develop Procurement Strategy
§ Establish Program Management core team
This study along with the DTS provides three of the above four objectives in a preliminary level to
lead discussions. Further work will be required to finalize the content these based on further input
from others. Such work which will be dependent heavily upon the stakeholders to identify
external points of integration and resulting work. For example, this might include determining
additional terrestrial capacity will need to be constructed and where that responsibility will reside.
Furthermore, to close out this phase, the stakeholders will need to “sign off” on the Design Plan
once any adjustments are identified and made. A potential adjustment might be if it is determined
to extend BALTIC to a data center or to integrate the CLS into an existing CLS.
Furthermore, during this phase, additional details, and issues on how to optimize schedule and
how these may impact future phases such as requirements within the ITT will be documented. A
key component will be to determine the Purchaser project organization including:
1. Types and levels of resources;
2. Internal and external use of resources;
3. Timing of resource needs; and
4. Overall organization.
Due to the need to on board a program manager for this work, any contracts for the core program
management should be issued during this phase. Core management would be program manager,
quality manager, technical manager, and procurement/contract manager. It is possible these roles
may be combined to fewer than 1:1 ratio.
Likewise, during this phase the go to market strategy will be defined including determining how
work will be presented to Suppliers for proposals and quotations and ensuring the points of
interface between work scopes are aligned.
Finally, during this phase, initial engagement with landowners, regulators and other critical path
entities will begin and their input will be used to further formulate the implementation plan and
approach.
The planning durations may be as short as several months or as long as a couple of years or more.
It will also most likely include travel to areas of interest for direct engagement and awareness and
to obtain higher quality project intelligence. For this study, it is assumed a 6-month duration that
considers this work as having started in July of 2022.

6.4 Procurement
Typical Duration: 3-4 Months
Work Streams:
§ Develop Technical Requirements
§ Define Terms & Conditions
§ Determine Initiation to Tender Process
§ Complete Tender Package

06 April 2023 | Page 74 of 95 | Version 1.0

 § Release Tender and Manage Responses (Administration)
§ Assess Supplier Responses
§ Propose Adjudication and Award
This phase includes the preparation and management of the tender packages (ITTs) for BALTIC
including Wet Plant, Dry Plant and CLS per the proposed responsibilities presented in Table 17.
The ITT process includes the administration of the process itself, including development of the ITT
package, assessment of the responses from each Supplier, adjudication, and award of the
contracts. The ITTs will be the instruments used to convey technical requirements and other goals
from which the participating Suppliers will develop and propose a design solution. This process
will also allow the Purchaser an opportunity to negotiate final terms and cost for the proposed
design solution.
As a turnkey solution using a primary System Supplier from CLS to CLS is proposed, third party
contracts for other services will be very limited. During this phase, if different scopes of work are
identified, procurement processes might be executed during this phase based on the necessary
timeline. Specifically, these might include:
1. Extended terrestrial network
2. Permitting support resources
3. NOC development
Purchaser and its partners may initiate a tender process at any time but must ensure funding is
available at the time of procurement or have a high degree of confidence that funding will be
available to execute a system supply contract. Attempting to procure a system without
establishing funds will be counterproductive and dilute the system’s credibility, which may
undermine Purchaser’s resolve to implement this system. This will not doom a system but will
make efforts to procure the system more difficult and could risk the project with respect to timing.
Procurement is typically a three-to-four-month process, this study considers a four-month
duration. The procurement phase can start shortly after the completion of this Feasibility Study
and once some of the up-front planning phase is complete to ensure the direction taken in
procurement is aligned.

6.5 Permitting
Typical Duration: 8-12 Months
Work Streams:
§ Develop All Inclusive Permitting Plan
§ Prepare, Submit and Manage Permit Applications & Compliance Requirements
§ Identify Permit Compliance Requirements (Environmental Studies, Mitigation Plans,
Observation)
§ Complete required environmental studies
Permitting represents one of the larger aggregated risks to the project and will consume
significant time and effort. The risk on permits include time to acquire or changes in design driven
by permit approvals and allowances. It is important for Purchaser to seek support in developing
and executing a sound permitting plan. This plan should take all permits into consideration,
including operation of BALTIC, operating permits for the installation of the submarine cable, as

06 April 2023 | Page 75 of 95 | Version 1.0

 well as permits required for landing the cable and for installation of the OSP and CLS. It should
also be noted that as part of the permitting, there are numerous compliance requirements
associated with each permit type.
These compliance requirements vary by permit and may include requirements to develop
environmental studies, develop mitigation plans and/or provide additional resources for such
things as animal conservation, historical artifacts, and environmental protection measures. In
addition to permitting, there may be needs to acquire land for the BMH and the Cable Landing
Station, as well as easements for the terrestrial cable installation.
While permitting is a great concern, a good permitting team anchored with using local expertise
at each landing local will develop a sound permitting plan and execute the plan with minimal
issues.
Typically, durations for permitting range from eight to twelve months and sometimes longer
depending on region specific complications and delays, this Study considers a twelve-month
effort. Permitting will start during the later phases of the planning work stream and coincide with
the site visits mentioned under planning. They will also overlap with the Route Design and Survey
portions of the work plan as they are interdependent.

6.6 Land Acquisition and Easements

Typical Duration: 8-12 Months
Work Streams:
§ Define requirements for land and easements based on CLS requirements and the preferred
cable route
§ Determine budget and negotiation strategy to acquire
§ Negotiate and acquire land and easements
Land acquisition and easements are typically not included in turnkey procurements but should be
included in the implementation plan as this work stream will consume time and money and must
be done for the BMH, OSP and CLS. Also, if determined later, terrestrial network routes. This effort
requires a great deal of consideration to ensure sites and routes selected provide opportunities
to acquire land in a cost-effective manor, while ensuring each site and easement meets all
requirements and considers future impact by new development and surrounding growth. It is
recommended the permitting team and the land team work closely if not in a combined manner
due to the inter dependency.
This study considers a 12-month duration to be done in parallel with permitting effort.

6.7 Marine Survey (Route Design)

Typical Duration: 4-6 Months
Work Streams:
§ Finalize Marine Survey route
§ Complete Marine Survey
§ Complete Burial Assessment Study
§ Complete cable route engineering

06 April 2023 | Page 76 of 95 | Version 1.0

 § Issue Cable route engineering design including installation plan
As proposed by Purchaser, the route design will include development of the CRE working group.
The CRE will use the DTS, Marine Survey results, Burial Assessment, Permitting, land acquisition
results and other sources to generate a final route which is turned into an installation plan for
BALTIC.
Prior to completion of the cable route of BALTIC a Marine Survey with Burial Assessment Study is
necessary to gain information not available in the “charts” including confirming cable and pipeline
crossings. Marine Surveys are used to confirm the proposed route identified in the DTS, identify
obstacles (i.e., geophysical, manmade, environmental, etc.) to be avoided and provide data
necessary to determine what portion of the cable will be laid versus buried, as well as what type
of cable armoring will be required for each portion of the route. The Supplier will mobilize vessel(s)
to conduct the route survey, which is typically done at least a year in advance of the installation.
The data collected during the route survey will determine installation methods and type of cable
and will allow the Supplier to estimate more precisely how much cable and type will be needed
and ultimately allow for the final design of the system. This information is then fed into the
manufacturing process.
Marine Surveys are negotiated as part of the procurement of BALTIC and can be costly if not
carefully negotiated, as they include high costs for mobilization and delays attributed to weather.
The route survey is a key step of the implementation process and necessary to finalize the route
and system design.
Marine Survey durations are dependent on the length of the route and weather conditions that
define workable windows of time. Typically route survey durations are anywhere from three to
six months and may carry over to an additional work season if there are complications and delays.
This study considers a four-month duration noting there will be time prior to the actual survey to
finalize the survey route using a review of the DTS. To make this timeline, the survey needs to be
scheduled well in advance to ensure vessel availability and should be agreed and scheduled within
the procurement process to reserve vessel time.

6.8 System Design Solution

Typical Duration: 2-3 Months
Work Streams:
§ Finalize System Design
§ Define System architecture and performance Specifications
§ Validate Contractual Compliance and Purchaser Acceptance
The Design effort begins once the contract is awarded to a Supplier, but the work turns to finalizing
as Marine Survey is being concluded. Data gathered from the route survey defines the final
technical specifications for submerged cable length and type, and installation methods. Once
these parameters are defined, the final system design calculations may be calculated, and final
system design solution developed for the system.
System design defines the final capacity, fiber pair plan, repeater plan, BU specifications, power
feed specifications, and so forth. This work is tightly integrated with the system installation plan
such that at times it cannot be uniquely identified. It also includes network monitoring and
management equipment, as well as ancillary equipment necessary to support the system and

06 April 2023 | Page 77 of 95 | Version 1.0

 services drops. This information feeds into the OSP and Site Facility designs to ensure they can
handle the demands of the system.
System design is performed by the System Supplier and the duration for this work ranges from
two to three months from the conclusion of the Marine Survey. This study considers a three-
month duration, which will be derived from the Supplier’s POW

6.9 Manufacturing
Typical Duration: 4-15 Months
Work Streams:
§ Manufacture Wet Plant
§ Manufacture Dry Plant
§ Manufacture Site Facilities
§ Conduct Test & Acceptance for Purchaser
As the system design is being developed, the Supplier will begin manufacturing Wet Plant and Dry
Plant. This manufacturing including system assembly, testing, and loading at the Supplier’s site
prior to cable loading.
While this plan shows manufacturing taking 6-9 months beyond the Marine Survey and System
Design manufacturing will start prior to this date. For example, systems like line monitoring
equipment, PFE, CLS buildings and systems will be minimally impacted by the results of these
processes and the adjustments can be easily made. As such, the manufacturing of these will begin
shortly after System Supplier is onboarded and necessary engineering is completed in
consideration of lead times. Cable manufacturing will also start early and final quantities, system
assembly and testing are completed in the last months of the manufacturing process based on
the final results. Furthermore, acquisition of feedstock (e.g., steel for armoring) will start with
contract award to mitigate delays in manufacturing. Fortunately, most items are common across
system so working in advance has little holistic risk to the Supplier.

6.10 Installation & Commissioning

Typical Duration: 4-12 Months
Work Streams:
§ Mobilization
§ Cable Load
§ Main Cable Installation
§ Shore End Installations
§ CLS construction
§ OSP Installation
§ System Commissioning
Submarine cable system installations are broken down into three types of work, Wet Plant Dry
Plant and CLS. CLS and OSP installation and construction is started first. Installation work may
begin earlier as allowed by weather for CLS and OSP as these materials and labor resources are

06 April 2023 | Page 78 of 95 | Version 1.0

 separate from those provide through the system Supplier. Ideally, that work is completed and
lying in wait for the cable system delivery. CLS construction may begin once land acquisition is
completed and based on schedule for supply of buildings and related systems.
Wet Plant or marine installation includes burial of some segments in shallow water where the
threat to the cable is high and laying cable on the seabed in deep water installation where the
threat is low, installation of shore ends including HDD and the deep water installation. As the Wet
Plant is being installed and tested and the OSP and CLS are complete, the Dry Plant is installed and
tested to complete the system.
Upon completion of the Wet Plant, Dry Plant and CLS, final integration will be completed and
commissioned. This process means the system will be tested end-to-end to ensure connectivity,
measure transmission rates, and confirm the system operates and performs as designed.
The Client or purchaser typically works with the Supplier to determine an agreeable test and
acceptance plan for commissioning.
This study considers a turnkey procurement approach, which means the Supplier will be
responsible for Wet and Dry Plant and CLS. An eight-month duration is considered for installation,
including commissioning and burn-in period. This work will have to be schedule in consideration
of local and seasonal limitations and in some cases may occur over multiple years depending upon
workload. Otherwise, efforts to parallelize the work and utilize multiple crews and vessels may be
required.

6.11 Operational Readiness

Typical Duration: 12-18 Months (completed by RFS)
Work Streams:
§ Define Operational Requirements, Structure, and governance model
§ Develop Operating Strategies and Policies
§ Implement Operational Support and Organizational Structure
§ Build NOC
§ Integrate network management systems with NOC
§ Confirm management systems are functional as part of commissioning
§ Recruit, Train and onboard
§ Declare Operational Readiness
One of the most important considerations for developing a Submarine Cable System, is the
purchaser’s ability, capacity, and experience to operate the system.
Planning and executing the operations plan is most critical to the success of the system
development, this work should be in parallel with the installation of the system and should be
started no later than a year before the system is declared ready for service. This study considers
a 12-month duration for the development and execution Operations. Work should start as Marine
Survey; system design and manufacturing are under way and in a stable condition. For BALTIC,
this work will be significant as all development will be new and require additional education and
awareness prior to making and executing decisions.

06 April 2023 | Page 79 of 95 | Version 1.0

6.12 Ready for Service
Milestone achieved with Installation and Commissioning
Once the system is commissioned, the system is declared RFS. Keep in mind that there are
situations where the system is conditionally accepted and placed into service with a hand full of
minor issues remaining. Once the system reaches RFS, it is considered formally accepted by the
System Owner and represents the point at which the Supplier’s obligations for the installation of
the system are concluded except to those items which are identified in the RFS exceptions list.
There may be scenarios where the purchaser may choose to conditionally accept the system while
efforts to complete installation punch list items is concluded and most Supplier’s offer two to five-
year warranty.
At this point as part of commissioning it is recommended that Purchaser conduct a burn-in period
to continue testing and ensuring the organization is ready to operate and manage the system.
Commissioning is typically a one-to-two-month duration with a three-month burn-in period.

06 April 2023 | Page 80 of 95 | Version 1.0

7. PROJECTED COSTS

7.1 Capital Expenditures

This section documents the estimated capital costs for BALTIC, which are based on the supplied
Design Plan. These estimates were developed by APTelecom using historical pricing data with
additional considerations. The impacts of the recent extraordinary levels of inflation have been
considered but cannot be validated at this time. In addition, there are certain unknown at this
time in the Baltic Sea and landings for which an UAP of $5M has been included in the estimate.
Ultimately, pricing will be the result of the Invitation to Tender Process.
As such, these estimated costs are provided for financial modeling, partner engagement and
ultimately to serve as a budgetary target for the implementation of BALTIC. Changes to the Design
Plan can have a material impact on the capital cost as the scale of the changes grow (e.g., adding
a landing, significant change in route, significant change in cable protection, additional crossings).
In developing the project cost of $138M, the following should be noted:
§ The recommended budget amount includes a 25% contingency over the $110M calculation.
§ All costs and prices are stated in current present value.
§ All pricing is 2022 US Dollars
§ System Costs does not include consideration for financing costs.
§ Costs do not include other Purchaser costs such as land acquisition and internal costs
§ Costs are exclusive of import fees and taxes
As a general note, normally the System Supplier will offer a five-year warrantee on the submerged
plant (excluding external damage) and a two-year warrantee on the Dry Plant. Other timeframes
can be negotiated. Other elements of the system, e.g., CLS, OSP, BMH, backup generator, will have
their own warrantees.

7.1.1 Capital Cost Summary

Cost elements as described throughout the Design Plan were reviewed and estimated using
APTelecom knowledge and experience with various assumptions considered. These are
summarized in Table 18. In reviewing the costs, it is worth noting the following which resulted in
a general $5M UAP being applied:
§ Extra effort may be required to achieve burial due to bottom compensation.
§ The shallow waters through the Baltic Sea may require additional small vessel work.
§ The complexity and conflicts near the shore ends may require additional survey work.
§ Horizontal drilling (HDD) may be required on shore ends subject to further survey.
The above and other assumptions along with allowances have been made and these will be
further assessed during the procurement phase as additional information has been garnered.
Supplier tenders will ultimately decide the price.

06 April 2023 | Page 81 of 95 | Version 1.0

 Table 18: Capital Cost Summary – 24FP

No. Components Cost

1.0 Permitting $ 1,200,000

2.0 Owner's Engineering and Project Management $ 1,100,000
3.0 System Supply Contract
3.1 Marine Survey $ 7,550,000
3.2 Submerged Plant $ 34,315,867
3.3 Spare Submerged Plant $ 1,926,943
3.4 Marine Operations $ 28,852,644
3.5 Civil Works $ 5,700,000
3.6 Land Cable Installation $ 580,000
3.7 Terminal Equipment $ 5,500,000
3.8 Power Feed Equipment $ 4,400,000
3.9 Test Equipment $ 175,000
3.10 Supplier's Engineering and Project Management $ 4,180,023
3.11 Site Facilities $ 10,000,000
4.0 UAP for Basin Complexity $ 5,000,000
Subtotal $ 110,480,478
Contingency 25% $ 27,620,119

Budgeting Estimate $ 138,100,597

7.2 Operating Expenditures

7.2.1 Overview
Based on the proposed O&M methodology provided In Section 4, an operating cost model has
been developed. Table 19 provides a preliminary OpEx budget which is the annual costs for
BALTIC. It has been assumed operating costs year on year will be flat (exclusive of inflation)
through organizational optimization. APTelecom believes figures provided are reasonable for
initial project budgeting but will need to be refined as the BALTIC project moves forward. Repairs
have been assumed to occur once per 3-4 years on the submerged plant and a prorated amount
has been used to estimate annual operating cost.

06 April 2023 | Page 82 of 95 | Version 1.0

 Table 19: Annual OpEx Budget Estimate

Ref. Item Total Cost

1.0 Marine Maintenance $400,000
2.0 Prorated Marine Repair (1 per 3 years) $350,000
3.0 Staff $1,000,000
4.0 Other Costs $500,000
Annual Recurring Costs, 2022 Dollars $2,250,000

06 April 2023 | Page 83 of 95 | Version 1.0

8. RISK ANALYSIS

8.1 Overview
Risks for BALTIC can be broken into two categories. The first category are the solution risks which
are about the long-term sustainability and ability to meet the business case objectives. The second
area with respect to the risks related to the immediate project delivery. Separating the risks into
this category is critical as the solution risks need to have more involvement from the stakeholders
through governance whereas the delivery risks are managed by the project delivery team and are
“reported” as appropriate and only escalated when they become significant and need further
support.
As such, from a sustainability approach, the solution risks focus on:
§ Design & Quality
§ Operations and Maintenance
§ Permits in Principle
§ Major cost variances
Whereas the delivery risks focus on the project workstreams and items like:
§ Delays in acquiring land, permits, materials, personnel, installation
§ Cost management within allocation including contingency
§ Minor quality management concerns
This report does not address commercial risks associated with meeting capacity sales targets
assumed in the business plan as that is being handled outside the scope of this Feasibility Study.
Such commercial risks are inherent to a submarine cable project and may be mitigated by
promptly launching an effective strategy to gage private interest in equity investments in BALTIC
and to close pre-sale capacity IRU purchase agreements (i.e., sales that take place pre-CIF and pre-
RFS dates).

8.2 Solution Risks Assessment

Based on the analysis undertaken, Table 20 summarizes the key solutions risks identified for the
BALTIC project. All risks identified in the matrix below apply to BALTIC as described in this study
and accompanying DTS. The information is intended to assist project stakeholders in further
developing the project such as incorporating risk mitigations into stakeholder and customer
agreements and into the system supply contracts or assigning resources to certain risk mitigation.
In general, there are no high solution probability risks to the extent they should cause concern. Of
the most concern are the risks around cost management and in particular inflation given the
current global economic environment. Being creative in risk sharing and ensuring adequate funds
are included in the investment profile is required to mitigate this properly. In other words, do not
expect to be able to squeeze to much cost out of the investment and instead allow for adequate
contingency and unallocated provision (UAP) to deal with unknowns and estimating challenges.

06 April 2023 | Page 84 of 95 | Version 1.0

 Table 20: Key Solution Risks
Risk Prob Impact Mitigation

Design
Route is determined (e.g., Low § Unacceptable route is § Follow standard project
Marine Survey) to be too found for geopolitical or processes and complete quality
difficult or expensive reliability reasons Marine Survey
Unable to secure land rights in Low § Unable to deliver capacity § Initiate early programs for
desired markets where required permitting and land acquisition
§ Delays in revenue per proposed project
methodology
§ Identify alternate viable landing
sites within business objectives
Unable to secure permitting in Medium § Unable to deliver capacity § Assign dedicated resources to
planned time where required manage.
§ Delays in revenue § Initiate land acquisition
immediately
§ Defined confidence level prior to
RFP execution
§ Purchaser to have funding
available to backup permit plans
System unable to meet optical Low § Extra cost § Additional repeaters or other
spectrum requirements for solutions to adapt system
capacity § Utilize standard assumption –
nothing special
Operating and Maintenance
Wet Plant failure rate is too Low § Extra cost and time § Follow standard project
frequent and too long to repair § Lost revenue during processes and complete quality
(e.g., lack of sufficient burial) outages Marine Survey
§ Stakeholder terminates for § Ensure proper maintenance in
cause – revenue loss place
§ Ensure property warranty in
place for Supplier equipment.
Time to repair wet plant failures Medium § Lost revenue during § Cable awareness program
is too long outages § Strong NOC operations
§ Stakeholder terminates for §
cause – revenue loss
Unable to maintain good NOC Medium § Poor availability and lost § Strong team leadership
operations including personnel revenue during outages § Strong onboarding and training
and tools § Stakeholder terminates for § Competitive compensation
cause – revenue loss § Corporate oversight of
performance
Cost Management
Cost comes in higher than Medium § Cost outside business case § Utilize Supplier’s standard
expected (excluding inflation) tolerance solutions (do not customize/over
specify)
§ Competitive tender
Cost comes in higher than High § Cost outside business case § Utilize a shared risk pricing
expected due to inflation tolerance schedule.
§ Increase cost in financial
modelling.

06 April 2023 | Page 85 of 95 | Version 1.0

 Cost comes in higher due to Medium § Cost outside business case § Review changes for alternative
change orders tolerance options were driven by
§ Loss of investment to date conditions.
if stopped § Strong governance on change
orders were driven by change in
requirements.
Delays in funding Medium § Unable to secure Supplier § Secure funding early
resources § Identify contingency funding
§ Suppliers do not give full § Ensure business case is agreed
effort with stakeholders

8.3 Delivery Risks Assessment

Based on the analysis undertaken, Table 21 provides the key delivery project risks identified for
the BALTIC project. All risks identified in the matrix below apply to BALTIC as presented in this
study and the accompanying DTS. The information is intended to assist project stakeholders in
further developing the project such as incorporating risk mitigations into system supply contracts
or assigning resources to certain risk mitigation. It also should be considered when developing the
financial model used for project governance decisions.
Overall, the project delivery risks are typical of those for a system of this nature though there
should be extra emphasis on sufficient burial and the impacts along with mitigations. The route
has limited burial despite water depth being shallow. By being aware of where the issues are and
properly planning lead time and design approach, these can be managed especially given that
BALTIC is a three-year project. Of note, there currently is an ongoing supply chain issue and items
may take 1 if not 2 years to receive. For example, Line Monitoring Equipment is almost 2 years
out which while long if properly managed does not impact BALTIC if it is ordered at the front end
of the project.

Table 21: Key Delivery Risks

Risk Prob Impact Mitigation

Project Delivery & Construction

Scheduled vessel times are not Medium § Extra year prior to RFS & project § Build plan with contingencies
met and revised dates are not overhead costs for time.
in line with business objectives § Accelerate work where
possible
Project interdependencies not Medium § Extra year prior to RFS & project § Experienced program
properly managed overhead costs management team focused on
holistic project and not just
System Supplier
Delays in materials especially High § Extra year prior to RFS & project § Realistic lead times accounted
long lead items overhead costs for in project plan (by line
item)
§ Order early wherever possible
and adjust later
Permitting work is more Medium § Extra year prior to RFS & project § Utilize qualified permitting
extensive than planned or there overhead costs team with local
are changes in process representation to lead
program efficiently.
Excessive change orders to Medium § Extra cost and time § Strong contract language
supply contracts § Increase contingency/UAP

06 April 2023 | Page 86 of 95 | Version 1.0

Risk Prob Impact Mitigation
Unexpected delays and impacts Medium § Extra time and overhead costs § Include unallocated time and
to project cost allowances in Purchaser
project plan
§ Routine combined project
delivery and technical reviews
with focus on risks and issues
Inability to achieve burial depth High § Extra cost and time § Burial Assessment and adjust
§ Reduced cable protection § Additional cable armor
§ More aggressive burial tools
§ Accept risk
Technical
HDD is more complex especially Medium § Extra cost and time. § Confirm requirements of HDD
for deviation tolerance § Properly engineer including
management (if needed) tolerance requirements
More expensive installation Medium § Extra cost and a little time § Proper Marine Survey to
program (crossings, burial) capture early
§ Include unallocated time and
cost allowances in Purchaser
project plan
Extended cable lengths from Low § Change to system design § Include unallocated time and
route engineering modifications including PFE and amplification cost allowances in Purchaser
exceed technical capabilities project plan
§ Include a small variance
allowance (e.g., 3-5% in
contract) for general variances
in route
Cybersecurity Events Low § Loss of customer support and § SLTE provided by customer
revenue § Secure NOC and NMS
§ CLS site security
§ Utilize trusted vendors
Operational
Component reliability lower Medium § System outages, Loss of § Proper maintenance programs
than expected reputation, revenue, and legal
ramifications
External aggression Medium § System outages, Loss of § cable awareness program
reputation, revenue, and legal § proper design and cable
ramifications protection
Dry Plant Repairs take too long Medium § System outages, Loss of § Sparing program
reputation, revenue, and legal § Competent personnel
ramifications § Strong NOC capability to
detect and isolate

8.4 Conclusion
Based on the information available at this time, APTelecom has accomplished a risk analysis for
BALTIC. This assessment considered cybersecurity, system design, technology, construction
contract, geotechnical, operations and maintenance, environmental, permitting, project plan of
work and schedule. The likelihood of occurrence of these risks is considered low and in worst case
in most cases.

06 April 2023 | Page 87 of 95 | Version 1.0

 Risks management and mitigation should be a continuous process during each phase using quality
resources and program management. During each phase and activity, a reduction in risk profile
should take place. This should be through planned actions and interventions and defined as part
of the success or completion criteria for each activity and phase. For example, during procurement
phase risks on CapEx should be heavily reduced with more clarity including those around external
fees and taxes. Also, by the time the project is entering into execution, selection of land should
be in a mature state with high probability of the desired outcome.

9. CONCLUSIONS
The proposed BALTIC cable system is found to be technically feasible with special considerations
given the complex and shallow water of the Baltic Sea. Over the 25-year life of the system, there
will be sufficient capacity to support OTT, internet services providers, telecommunications
companies and Hyperscalers. The BALTIC will require close to three years to implement, (i.e., RFS
in 2025 or 2026) subject to System Supplier’s project capacity which will be confirmed during RFP.
The system technical solution is like other successful systems and Suppliers have had limited
concerns.
While in the procurement phase which is next phase, the project should focus on securing landing
sites and adjusting the cable route or RPL in accordance with the final coordinates of the
associated BMH and CLS.
The BALTIC design has been based on using proven solutions and there is confidence a 24FP
solution can be implemented if requested and financially viable. Therefore, the technical risk is
average to the extent noted previously especially around the near shore approach conflicts and
burial. Overall system protection is somewhat at risk but can be mitigated through other choices
including armoring and cable placement for avoidance. Deploying submarine fiber system in Baltic
Sea has been proven though there are opportunities for an improved solution including landing
sites selection and cable protection. As this is a basic point-to-point trunk system with two
branching units, the probability of changes outside RPL optimization and final onshore locations
is minimal.
It is APTelecom’s experience that most submarine system developments encounter some level of
constraint concerning funding and timing for the implementation of the system. This cost will have
an impact on securing stakeholders, customers, and funding. In addition, there are risks as it
relates to permitting and land acquisition which need to be addressed early.
It is these activities and their respective timing that pose the greatest risk to this project.
Developing BALTIC in a fashion that is economically feasible will depend greatly on how effectively
Purchaser manages these activities and their subsequent timing for completion.
APTelecom recommends BALTIC is built using a turnkey Supplier and that Purchaser solicit support
for the above identified critical activities and recommends the following next steps for the project:
1. Seek support resources to help with these critical activities and especially permitting -
resources should have extensive experience as it relates to submarine cable system
development
2. Establish a POW that considers these activities and sets a realistic schedule for the
implementation of the system
3. Accelerate the procurement, permitting and land acquisition phases, where possible
4. Execute the plan with great attention, care, and resolve

06 April 2023 | Page 88 of 95 | Version 1.0

 5. Engage with stakeholders to secure capacity commitments and funding
APTelecom’s experience in managing turnkey supply contracts for submarine systems end-to-end
is second to none, either directly or in a support role to the owner, and APTelecom could assist
Purchaser in the next phase of the BALTIC project, if requested.

06 April 2023 | Page 89 of 95 | Version 1.0

APPENDICES

06 April 2023 | Page 90 of 95 | Version 1.0

A. APPENDIX – Critical Design Elements

06 April 2023 | Page 91 of 95 | Version 1.0

B. APPENDIX - Permitting Matrix

06 April 2023 | Page 92 of 95 | Version 1.0

C. APPENDIX – Route Position List

06 April 2023 | Page 93 of 95 | Version 1.0

D. APPENDIX – RPL Illustrations

06 April 2023 | Page 94 of 95 | Version 1.0

E. APPENDIX – Desktop Study

06 April 2023 | Page 95 of 95 | Version 1.0