The first finding was that “nearly 100% of the world’s inter-continental  electronic communications traffic is carried by the undersea cable  infrastructure”. The second finding was  that “there is no plan B”, meaning  there’s simply no network alternative to the undersea cable network for providing  high-speed broadband connectivity between continents that we’ve come to rely on  each and every day for both business and personal reasons. Now, the actual probability  of a global failure may be quite low, but it’s not zero, especially on a more limited regional  scale.

These two findings together pretty much sum it up – submarine cables are critical infrastructure – albeit with little  public fanfare, until something goes wrong and people can no longer watch cat  videos being served up by some offshore  data center… oh, the humanity!

A global failure of the  submarine network would be utterly catastrophic to international security and the  economic stability of financial markets around the world, given they’re so  intertwined these days. Just think about it, if intra-continental terrestrial  networks were disconnected from the rest of the world resulting in “islands” of connectivity, the entire global  digital economy and associated financial markets would grind to a complete  standstill with devastating consequences for continents, countries, and most  importantly, us!

The ROGUCCI report raised a rather poignant point in that it’s  “unclear if civilization can recover to  its previous condition from the failure of a technology that has been so  rapidly adopted without a backup plan”… kind of makes you think, doesn’t it?

New rules enacted by the US-based Federal Communications Commission  (FCC) reinforce these realities, and very real concerns.

If intra-continental terrestrial networks were disconnected from the rest of the world resulting in 'islands' of connectivity, the entire global digital economy and associated financial markets would grind to a complete standstill. - Brian Lavallée, Director of Portfolio Solutions Marketing

New FCC Rules for Submarine Cable Networks

The new FCC rules are intended  to promote a far more reliable submarine cable communications infrastructure by  requiring “submarine cable licensees to  report significant outages to the FCC to help safeguard this critical  communications infrastructure and promote reliable communications for  businesses and consumers”, which were announced in June earlier this year.  The US has approximately 60 submarine cables that connect the nation to the  rest of the world. These cables are the basis for the global Internet,  especially when you consider that the world’s major Internet Content Providers  (ICPs) are US-based with mammoth local data centers.

The FCC (rightfully) sees the submarine cables  as critical to the American economic and national security. The FCC’s beef is  that in the past, licensees have only reported outages to the FCC on a  voluntary and often inconsistent basis such that when they do receive  notification about outages that have occurred, it was often perceived as too  limited to be of any use.

Although these new rules represent a noble cause with  all the right intentions intended to safeguard the over “US$10 trillion worth of transactional value” carried by the submarine cable network each day,  there are those who have voiced concerns over the FCC’s action. Why? Well,  let’s dive in and review the new FCC rules and their implications, both good  and bad.

According to the FCC news release, “The new  outage reporting rules will enable the FCC to monitor the operational status of  submarine cables and assist the agency in ensuring the reliability of this  communications infrastructure. The rules require submarine cable licensees to  report major outages to the agency’s Network Outage Reporting System (NORS)”,  which I personally think is a good thing, especially since “other communications providers – including  wireline, wireless, and satellite – already report outages to NORS”.

According to the FCC, accurate reporting has allowed them to “analyze outage trends, spot systemic issues,  and work with providers to develop solutions to make communications more  resilient and reliable”, which could be applied to one of the most critical  parts of the global Internet – the submarine  cable network. These rules seem to have their heart in the right place, so  why would anyone disagree with them?

One of the examples cited by the FCC as to why these  new rules are required is when the submarine cable serving the Commonwealth of  the Northern Mariana Islands failed due to a typhoon that swept through the  American territory in July of 2015. The resulting three-week outage led to  significant problems for the tens of thousands of residents related to  Internet, banking, credit card transactions, ATM withdrawals, healthcare, and inbound/outbound  airline flights being delayed or cancelled. Most importantly, especially during  a natural disaster such as a typhoon where emergencies are highly likely,  residents were unable to make calls to 911 for first responder services.

How  did this happen? Because the submarine cable licensee didn’t have a “Plan B” in place, such as a redundant  protection path for the critical communication services mentioned above.

What likely irked the FCC was that they were  apparently not even notified of the complete loss of communications to island  residents. Although the FCC acknowledges that such wide-scale outages are quite  rare, they are precisely the ones that are the intended target of the new  rules, and I’m sure any affected citizens would wholeheartedly agree.

The FCC believes it must  focus on outages affecting consumers by incentivizing network operators to  incorporate redundant protection paths into their networks while also cutting  through regulatory red tape that makes it harder for service providers to  deploy, maintain, and repair submarine cables. This not only helps citizens remain  connected but also promotes economic and national security interests.

A Haystack of Paperwork

However, FCC Commissioner  Ajit Pai believes that “today the FCC does none of this”. His concern is that the FCC mandates that network operators file outage  reports, even when an outage is not actually experienced by end users, such as  during a protection switch that quickly reroutes traffic around a faulted submarine  cable, leading to a “haystack of paperwork that will only make it more difficult for us to  find any needles”.

Wouldn’t these  rules ultimately penalize network operators who already have or will deploy  redundant protection paths by requiring them to file multiple reports every  time they use the protection paths, regardless of whether or not the end user  was affected? Ajit thinks so, stating the FCC has decided “to divert resources away from critical repair and restoration efforts and toward needless paperwork”.

Although the FCC’s heart is in the right place by trying to improve  submarine cable network resilience and service availability, it’s clear that  there’s still some room for improvement according to Ajit, which led to his official dissent.

Although the submarine  cable network that stitches together continental landmasses are viewed as critical  infrastructure, they’re also highly vulnerable to a variety of threats such as  natural disasters (typhoons, earthquakes, tsunamis), naval vessels (fishing  trawlers, anchors), sea life (SHARK! actually no, but that’s a topic for another blog), and of course,  those who purposely harm submarine cables.

Even though the FCC has monitored  submarine cable outages in the past, the voluntary and ad hoc nature of the  system led to non-standardized reporting that wasn’t particularly useful. Some  outages and disruptions went unreported, such as the example mentioned above, leaving  the FCC unable to identify how to prevent such outages in the future through a  variety of recommendations, regulations, and best practices.

I think the new FCC rules are a step in the right direction, particularly related to the reporting of actual outages in a timely, consistent, and standardized manner. - Brian Lavallée, Director of Portfolio Solutions Marketing

Too Big to Fail?

As undersea cables are  upgraded using the latest in Submarine Line Terminating Equipment (SLTE) technologies  that scale to multiple terabits per second capacities, have they become too big  to fail? I definitely think so, but I also think they’ve been too big to fail since  the dawn of the global Internet and digital economy.

Monumental information-carrying  increases have just exacerbated the risk of having them fail. It’s a bad day  when 100 gigabits per second of total traffic is lost; it’s an incredibly miserable day when tens of terabits per second of total traffic is  lost. I haven’t worked out the math, but that’s a boatload of selfies that your  friends cannot enjoy. I mean, how else will they see the new pair of shoes that  you just bought or the meal you’re actually eating? Oh, the horror.

Seriously  though, the impact of a loss of communications due to a submarine cable network  disaster to a country or region can be profound, and is definitely no laughing  matter. Our utter network dependence has ensured that we cannot live with  wide-scale outages for any length of time, ever again.

I think the new FCC rules  are a step in the right direction, particularly related to the reporting of actual outages in a timely, consistent,  and standardized manner. However, mandating network operators to also report on  any and all protection switches, even those that actually avoid outages by rerouting  traffic to alternate available paths, could prove cumbersome unless the  reporting mechanism is tied into the network operating system and automatically  sends required reports to the FCC autonomously.

Time will tell how this ultimately  pans out, but I think discussion to safeguard the global submarine cable  network is a worthy and important endeavor – we all should.

I’d be remiss not to  mention the International Cable  Protection Committee (ICPC) that’s comprised  of more than 150 members in over 60 countries with the stated vision of being  the “premier international submarine  cable authority by providing industry leadership and guidance on issues related  to submarine cable security and reliability”. This is achieved via “the sharing of information for the common  interest of all seabed users” that “represents  all who operate, maintain, and work in every aspect of both the  telecommunication and power cable industry”.

The international committee  was founded in 1958, almost a century after the first trans-Atlantic  telegraph cables were deployed, and has been helping to safeguard the submarine cable industry for  decades via recommendations, videos, publications, as well as liaising with other groups and  governments of similar interest related to submarine cable networks around the  world.

Although the ICPC does an  admirable job in improving the reliability of submarine cables around the  world, the reality is that submarine cable faults and outages will occur  nonetheless. It’s next to impossible to completely avoid natural disasters or  prevent manmade faults, whether accidental (oops, I dropped my anchor and  unknowingly dragged it for 10 kilometers) or (almost) intentional (I know  submarine cables are in these waters, but I’ll trawl for fish anyway).

This is  where intelligent networking technology comes into play where service providers  can hope for the best but plan for the worst. Network outages can be avoided by  implementing automated (not manual!) mesh protection capabilities that autonomously  bypass network faults and switch traffic to alternative submarine and/or  terrestrial network paths. This isn’t actually new and has already been implemented around the world,  especially across Southeast Asia submarine networks that are at a significantly  high risk of earthquakes, typhoons, tsunamis, and naval vessel activity.

For  example, when the massive Japan Tōhoku earthquake of 9.0 magnitude struck on  March 11 of 2011, coupled with a tsunami, several submarine cables were damaged  or outright cut. This could have led to wide-scale loss of communications – at the worst possible time – if it  weren’t for intelligent mesh protection that was in place, spurred on by regional outages in 2006  and 2009 near Taiwan.

What is new however is that as submarine cables are  upgraded to terabit per second capacities, the available protection paths,  overland and undersea, must also be upgraded to similar capacities, including  the switches themselves that reroute the traffic. If not, outages will still  occur.

Are terabit submarine cables too  big to fail? I think so, the FCC  thinks so, and I think most end users would also say so.

Want to learn more about  how to protect these terabit submarine cables today? Check out this GeoMesh paper to see how  submarine cable operators around the world are currently protecting their submerged  jugular veins of international connectivity.