Submarine Cable Resiliency Report Update - September 2016
Working Group 4A:
Submarine Cable Resiliency
Final Update
September 14, 2016
Kent Bressie, Co-Chair (Harris, Wiltshire & Grannis for the North American
Submarine Cable Association
Catherine Creese, Co-Chair (Naval Seafloor Cable Protection Office)
2
WG4A Objectives
•
WG4A’s work builds on that of CSRIC IV’s WG8, which analyzed
the physical risks to submarine cable infrastructure and
recommended spatial separation distances.
•
WG4A examined how lack of coordination across federal, state,
and local agencies and clustering of cable routes and landings
can increase the risk of cable damage and harm U.S. network
resilience.
•
Cable protection remains critical, as submarine cables carry
approximately 99 percent of U.S. traffic with the rest of the
world, not to mention Alaska, Hawaii, and U.S. territories.
3
WG4A Deliverables
•
Regulatory Coordination Report
: examined gaps, conflicts,
and sources of delay in existing federal, state, and local
interagency coordination for submarine cable and other
marine activity and infrastructure permitting and recommend
mechanism for enhancing coordination without increasing
regulatory burdens.
•
Geographic Diversity (Clustering) Report
: addresses industry
best practices and government policies for promoting
geographic diversity of submarine cable routes and landings.
4
WG4A Members
Steve Balk (Sprint)
Stephen Bowler (FERC)
Allan Creamer (FERC)
Seth Davis (SRD Associates)
Jennifer Golladay (BOEM)
Kurt Johnson (Pacific Crossing)
Amy Marks (Xsite Modular)
Jennifer Miller (BOEM)
Mikal Modisette (Verizon)
Wayne Pacine (Board of Governors, Federal Reserve System)
Ron Rapp (TE SubCom)
Neil Rondorf (International Cable Protection Committee)
Nikki Shone (Southern Cross Cables)
Rick Spencer (CenturyLink)
Takahiro Sumimoto (Pacific Crossing)
Bob Wargo (AT&T)
Al Wissman (NOAA)
5
•
Report builds on:
•
CSRIC IV Report on Spatial Separation, which highlighted the risks to submarine cables
and the use of geographic diversity, and
•
CSRIC V Report on Intergovernmental and Interjurisdictional Coordination, which
highlighted the need for better coordination to enhance cable protection in the course of
regulating other marine activities.
•
Report addresses:
•
Key concepts
•
Factors influencing routing and landing
•
Recommendations for further FCC action
Diversity of routes and landings
report
6
•
Economic opportunities and differing costs of routes and landing points
•
Seafloor topology
•
Regulatory factors
•
Prohibitions on cables or required locations
•
Ease of permitting and fees
•
Variation between regulations or application in different jurisdictions
•
Proximity to other marine infrastructure
•
Access to terrestrial networks
Factors influencing routes and
landings
7
1.
Encourage Interagency and Interjurisdictional Cooperation
•
Cooperating agencies should seek to streamline permitting; adopt more transparent and
consistent permitting processes, conditions, and timelines; and reduce permitting times.
•
With lengthy permitting timeframes, any location that offers a slightly shorter permitting
timeframe becomes a much more attractive option in order to satisfy “time to market”
concerns that confront new submarine cable developers—even the resulting location
reduces geographic diversity of submarine cables.
•
Streamlining across multiple jurisdictions would serve to reduce regional disparities,
while reductions in overall permitting timeframes would render less critical any small
variations in permit timing and burdens.
Recommendations
8
1.
Encourage Interagency and Interjurisdictional Cooperation (continued)
•
As part of this process, the FCC should consult with the Army Corps of Engineers
regarding variations in the processes and permit conditions employed by its various
districts.
•
The FCC should consider adoption of a submarine cable permitting shot-clock
for state
and local permitting for submarine cables as a means of highlighting the significant
disparities in timing that submarine cable operators experience, and as a basis of
potential future interjurisdictional discussions, including through the regional planning
bodies.
Recommendations
9
2.
Encourage Other Agencies to Consider Impacts On Submarine Cable
Diversity During Permitting Processes
•
FCC should encourage other federal, state, and local government agencies to consider
impacts on cable diversity during permitting for other marine activities.
•
As demonstrated in the CSRIC IV Report on Spatial Separation, there already exists a
problem in protecting existing submarine cable infrastructure from damage by other
marine activities as authorized by other federal, state, and local government agencies.
•
Similarly, there is a lack of awareness and/or focus on foreclosure of particular
submarine cable routes and landings, and on reductions in geographic diversity of cables
through authorization of other marine activities.
Recommendations
10
3. Evaluate the Role of NEPA and CZMA as a Coordination Mechanism
•
FCC should decline to rely on the National Environmental Policy Act (“NEPA”) or the
Coastal Zone Management Act (“CZMA”) as the principal means of coordinating with
other federal, state, and local government agencies.
•
NEPA exists to identify and evaluate potential environmental impacts of activities
authorized by federal agencies.
•
CZMA exists to coordinate environmental protection efforts between federal and
state agencies, permitting the adoption of state coastal zone management plans
approved by the Secretary of Commerce and consistency reviews by states
regarding potential effects within state territorial seas.
•
Neither of these laws is a marine spatial planning law designed to optimize the use of
marine and coastal areas for particular activities of national importance, whether for
telecommunications and Internet connectivity or renewable energy development.
•
Neither tasks government agencies with assessing the impact of proposed
activities on telecommunications network resilience.
Recommendations
11
4.
Promote Further Industry-to-Industry Cooperation
•
FCC should promote further direct industry-to-industry coordination to enhance
diversity of submarine cable routes and landings.
•
The submarine cable industry has long engaged in direct consultations with other
marine industries, particularly the commercial fishing industry and offshore oil and gas
industries, to mitigate harmful impacts to their respective activities, equipment, and
infrastructure.
•
While such industry efforts are sometimes insufficient, they should not be supplanted
entirely by governmental solutions.
•
In coordinating with other federal, state, and local government agencies, the FCC should
recommend processes that encourage other marine industries to coordinate with
submarine cable operators at the earliest stages of project planning, and vice versa.
Recommendations
This update presents the final findings of Working Group 4A on Submarine Cable Resiliency, focusing on the importance of coordinating federal, state, and local agencies to mitigate risks to submarine cable infrastructure. The report highlights the critical role of regulatory coordination and geographic diversity in enhancing U.S. network resilience and protecting submarine cables that handle a significant portion of U.S. traffic. Key deliverables include reports on regulatory coordination and promoting geographic diversity in cable routes and landings.
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Presentation Transcript
Working Group 4A: Submarine Cable Resiliency Final Update September 14, 2016 Kent Bressie, Co-Chair (Harris, Wiltshire & Grannis for the North American Submarine Cable Association Catherine Creese, Co-Chair (Naval Seafloor Cable Protection Office)
WG4A Objectives WG4A s work builds on that of CSRIC IV s WG8, which analyzed the physical risks to submarine cable infrastructure and recommended spatial separation distances. WG4A examined how lack of coordination across federal, state, and local agencies and clustering of cable routes and landings can increase the risk of cable damage and harm U.S. network resilience. Cable protection remains critical, as submarine cables carry approximately 99 percent of U.S. traffic with the rest of the world, not to mention Alaska, Hawaii, and U.S. territories. 2
WG4A Deliverables Regulatory Coordination Report: examined gaps, conflicts, and sources of delay in existing federal, state, and local interagency coordination for submarine cable and other marine activity and infrastructure permitting and recommend mechanism for enhancing coordination without increasing regulatory burdens. Geographic Diversity (Clustering) Report: addresses industry best practices and government policies for promoting geographic diversity of submarine cable routes and landings. 3
WG4A Members Steve Balk (Sprint) Stephen Bowler (FERC) Allan Creamer (FERC) Seth Davis (SRD Associates) Jennifer Golladay (BOEM) Kurt Johnson (Pacific Crossing) Amy Marks (Xsite Modular) Jennifer Miller (BOEM) Mikal Modisette (Verizon) Wayne Pacine (Board of Governors, Federal Reserve System) Ron Rapp (TE SubCom) Neil Rondorf (International Cable Protection Committee) Nikki Shone (Southern Cross Cables) Rick Spencer (CenturyLink) Takahiro Sumimoto (Pacific Crossing) Bob Wargo (AT&T) Al Wissman (NOAA) 4
Diversity of routes and landings report Report builds on: CSRIC IV Report on Spatial Separation, which highlighted the risks to submarine cables and the use of geographic diversity, and CSRIC V Report on Intergovernmental and Interjurisdictional Coordination, which highlighted the need for better coordination to enhance cable protection in the course of regulating other marine activities. Report addresses: Key concepts Factors influencing routing and landing Recommendations for further FCC action 5
Factors influencing routes and landings Economic opportunities and differing costs of routes and landing points Seafloor topology Regulatory factors Prohibitions on cables or required locations Ease of permitting and fees Variation between regulations or application in different jurisdictions Proximity to other marine infrastructure Access to terrestrial networks 6
Recommendations 1. Encourage Interagency and Interjurisdictional Cooperation Cooperating agencies should seek to streamline permitting; adopt more transparent and consistent permitting processes, conditions, and timelines; and reduce permitting times. With lengthy permitting timeframes, any location that offers a slightly shorter permitting timeframe becomes a much more attractive option in order to satisfy time to market concerns that confront new submarine cable developers even the resulting location reduces geographic diversity of submarine cables. Streamlining across multiple jurisdictions would serve to reduce regional disparities, while reductions in overall permitting timeframes would render less critical any small variations in permit timing and burdens. 7
Recommendations 1. Encourage Interagency and Interjurisdictional Cooperation (continued) As part of this process, the FCC should consult with the Army Corps of Engineers regarding variations in the processes and permit conditions employed by its various districts. The FCC should consider adoption of a submarine cable permitting shot-clockfor state and local permitting for submarine cables as a means of highlighting the significant disparities in timing that submarine cable operators experience, and as a basis of potential future interjurisdictional discussions, including through the regional planning bodies. 8
Recommendations 2. Encourage Other Agencies to Consider Impacts On Submarine Cable Diversity During Permitting Processes FCC should encourage other federal, state, and local government agencies to consider impacts on cable diversity during permitting for other marine activities. As demonstrated in the CSRIC IV Report on Spatial Separation, there already exists a problem in protecting existing submarine cable infrastructure from damage by other marine activities as authorized by other federal, state, and local government agencies. Similarly, there is a lack of awareness and/or focus on foreclosure of particular submarine cable routes and landings, and on reductions in geographic diversity of cables through authorization of other marine activities. 9
Recommendations 3. Evaluate the Role of NEPA and CZMA as a Coordination Mechanism FCC should decline to rely on the National Environmental Policy Act ( NEPA ) or the Coastal Zone Management Act ( CZMA ) as the principal means of coordinating with other federal, state, and local government agencies. NEPA exists to identify and evaluate potential environmental impacts of activities authorized by federal agencies. CZMA exists to coordinate environmental protection efforts between federal and state agencies, permitting the adoption of state coastal zone management plans approved by the Secretary of Commerce and consistency reviews by states regarding potential effects within state territorial seas. Neither of these laws is a marine spatial planning law designed to optimize the use of marine and coastal areas for particular activities of national importance, whether for telecommunications and Internet connectivity or renewable energy development. Neither tasks government agencies with assessing the impact of proposed activities on telecommunications network resilience. 10
Recommendations 4. Promote Further Industry-to-Industry Cooperation FCC should promote further direct industry-to-industry coordination to enhance diversity of submarine cable routes and landings. The submarine cable industry has long engaged in direct consultations with other marine industries, particularly the commercial fishing industry and offshore oil and gas industries, to mitigate harmful impacts to their respective activities, equipment, and infrastructure. While such industry efforts are sometimes insufficient, they should not be supplanted entirely by governmental solutions. In coordinating with other federal, state, and local government agencies, the FCC should recommend processes that encourage other marine industries to coordinate with submarine cable operators at the earliest stages of project planning, and vice versa. 11
