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.