No since enabling this feature connects to a GrapheneOS Proxy (or Apple if someone chooses). Making it local wouldn't though, which is a goal.

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Thanks.

But even if its local, in airplane mode / no WiFi, how would it know which networks are closeby?

Oh, that's what you meant, assumed you meant having no access to the Wi-Fi rather than disabling it.

For WiFi being off, this would depend on if you enable the setting "Wi-Fi Scanning" in Settings -> Location. This is a toggle to scan for nearby WiFi networks even when WiFi is off. Need to enable it.

Very interesting, thanks a lot!

I'm still wondering if it's possible to just remember the last known location, and assume the phone didn't move too far since last use. This should decrease loading time substantially in most cases, even in full offline mode.