ROGUCCI - THE REPORT ISSUE 1, 2010

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ROGUCCI, The Report, Issue 1, rev. 1

© 2010 IEEE Communications Society, All rights Reserved

This document was prepared by:

Karl Frederick Rauscher

Principal Author, ROGUCCI Study Final Report, and General Chairman, Global Summit
Chief Technology Officer and Distinguished Fellow, EastWest Institute
Bell Labs Fellow
Founder & President, Wireless Emergency Response Team (WERT)
Chair Emeritus, IEEE Communications Quality & Reliability (CQR) Advisory Board

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The ROGUCCI Study and Global Summit Report has been prepared
under the auspices of the IEEE Communications Society . . .

In partnership with the non-profit EastWest Institute

as international policy champion and patron . . .

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And with the Dubai International Financial Centre

as host of the ROGUCCI Global Summit . . .

The ROGUCCI Global Summit was made possible by patronage from:

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Preface

This Report submits twelve bold Recommendations to the private sector, nation-state governments and other
stakeholders for the purpose of promoting the reliability, resilience, robustness and security of the global
interconnectivity that underpins modern society – the world’s undersea communications infrastructure. These
Recommendations are effective, achievable, and urgent.

The urgency is driven by the vital role that global electronic connectivity has in the world’s economy, society and
security. Without reliable international communications services, public welfare is endangered, economic stability is
at risk, other critical sectors are exposed, and nation-state security is threatened. The implementation of The
Report’s Recommendations will significantly reduce these and other risks.

These Recommendations are achievable, yet challenging. Each will require skill, resolve and genuine partnership
among government entities and the private sector. Stakeholders have already demonstrated acceptance of this
challenge with overwhelming support for The Recommendations during the ROGUCCI Global Summit and by a
number of the government and private sector stakeholders volunteering to work on moving the implementation of
several recommendations forward. For each Recommendation, The Report presents a concise background context, a
discussion of alternative approaches and their consequences, next steps to continue the momentum that has been
established during the ROGUCCI process, and measures to gauge progress.

Supporting the twelve recommendations, The Study documents 100 Key Observations. In addition, a major
milestone accomplished during The Study was the confirmation of a comprehensive list of intrinsic vulnerabilities of
undersea communications cable infrastructure using the Eight Ingredient (8i) Framework for Information and
Communications Technology (ICT) Infrastructure. In order to provide more information and updates on follow-up
related to The ROGUCCI Study, the IEEE Communications Society has established a web site (www.ieee-
rogucci.org).

The world’s future communications networks promise to usher in a new world of business and lifestyle-enhancing
capabilities. Many of the benefits have not yet even been imagined. The people of all continents and islands stand
to greatly benefit from the anticipated economic efficiency, citizen connectivity, functional flexibility, and speed. The
Study strongly urges nation-states, the private sector and stakeholders to chart and embark on a new course of
policy and practice that demonstrably supports highly reliable, highly resilient, and highly robust global undersea
communications cable infrastructure.

______________________
KARL FREDERICK RAUSCHER
Principal Author, ROGUCCI Report
General Chairman, ROGUCCI Global Summit
CTO & Distinguished Fellow, EastWest Institute
Bell Labs Fellow

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The Report is dedicated to

the engineers, scientists, entrepreneurs and seamen

who have served as visionaries, pioneers and laborers

to make the world’s undersea cable infrastructure
what it is today.

Modern society is profoundly unaware

of its debt to their service.

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Table of Contents

1. EXECUTIVE SUMMARY 18

2. INTRODUCTION 35

2.1 Objectives 35

2.2 Uniqueness of Approach 38

2.3 Importance of the Subject 38

2.4 Defining Progress 39

2.5 Scope 40
2.5.1 Subject Matter Interest 40
2.5.2 Geography 44
2.5.3 Network Types 45
2.5.4 Infrastructure Boundaries 45
2.5.5 Technology 45

2.6 The Study 45

2.6.1 Research Locations 45
2.6.2 IEEE Online Forum 46

2.7 Global Summit 47

2.7.1 Venue 47
2.7.2 Program 48
2.7.3 Cable Ship Tour 50
2.7.4 Participant Assessment 52
2.7.4 Recognized Historic Event by Porthcurno Telegraph Museum 53

2.8 Contributors 54

3. ANALYSIS OF UNDERSEA COMMUNICATIONS CABLE INFRASTRUCTURE 59

3.1 Environment 60
3.1.1 Function 60
3.1.2 Intrinsic Vulnerabilities 61
3.1.3 Significant Trends 61

3.2 Power 63
3.2.1 Function 63
3.2.2 Intrinsic Vulnerabilities 64
3.2.3 Significant Trends 64

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3.3 Hardware 65
3.3.1 Function 65
3.3.2 Intrinsic Vulnerabilities 66
3.3.3 Significant Trends 66

3.4 Software 70
3.4.1 Function 70
3.4.2 Intrinsic Vulnerabilities 70
3.4.3 Significant Trends 70

3.5 Network 71
3.5.1 Function 71
3.5.2 Intrinsic Vulnerabilities 71
3.5.3 Significant Trends 71

3.6 Payload 73
3.6.1 Function 73
3.6.2 Intrinsic Vulnerabilities 73
3.6.3 Significant Trends 73

3.7 Policy 75
3.7.1 Function 75
3.7.2 Intrinsic Vulnerabilities 75
3.7.3 Significant Trends 76

3.8 Human 78
3.8.1 Function 78
3.8.2 Intrinsic Vulnerabilities 78
3.8.3 Significant Trends 79

4. KEY OBSERVATIONS FOR GUCCI 80

4.1 Stakeholder Oriented Observations 82

4.2 Science & Engineering Oriented Observations 85

4.3 Business & Investment Oriented Observations 92

4.4 Government & Inter-Government Oriented Observations 94

5. RECOMMENDATIONS 98

5.1 Rudimentary Geographic Diversity for Global Infrastructure 102

5.2 Prioritization for Timely Cable Repairs 105

5.3 Preparedness for Hostile Maritime Crises 109

5.4 Best Practices and Trusted Information Sharing 112

5.5 New International Governance 117

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5.6 International Communications Infrastructure Standard for the Financial Sector 120

5.7 Measurements for Stakeholder Due Diligence 124

5.8 Improved Cable Protection Agreements, Standards, Policies and Regulations 127

5.9 Government Inter-Agency Coordination for Undersea Cable Infrastructure 129

5.10 Education and Awareness of GUCCI Critical Role 131

5.11 Mechanisms for Handling Overload Demand 134

5.12 Recognize GUCCI Catastrophic Loss As a Grand Challenge 137

6. SUMMARY 140

7. ACKNOWLEDGEMENTS 141

8. ACRONYMNS 143

9. GLOSSARY OF KEY TERMS 145

10. REFERENCES 148

APPENDIX A. ANALYSIS OF RECENT MAJOR OUTAGE EVENTS 151

A.1 Recent Major Outages 151

A.1.1 Survey of Events 152
A.1.2 Pareto Analysis of Cause Attribution 152

A.2 The Historically Common vs. Very Low Probability Events 153

A.3 Intrinsic Vulnerability Analysis of Select Recent Events 154

A.3.1 Cause-Effect Analysis 154
Hengchun Earthquake (2006) 155
Middle East (2008) 156
Mediterranean Sea (2008) 159
Typhoon Morakot and Taiwan Earthquake (2009) 160
A.3.2 Countermeasure Approaches 162

APPENDIX B. SURVEY OF PUBLICLY AVAILABLE INFORMATION 167

B.1 History 167

B.2 Technology 168

B.3 Suppliers 168

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B.4 Cable Systems 169

B.5 System Owners and Operators 169

B.6 Cable Landing Sites 169

B.7 Cable Routes 169

B.8 Outages 170

B.9 Restoration Procedures 170

B.10 Financial Dependencies 171

APPENDIX C. IMPACT OF HISTORIC OUTAGES 172

C.1 Recent Events 172

CASE #1: Algeria 2003 172
CASE #2: Pakistan 2005 173
CASE #3: Taiwan 2006 173
CASE #4: Bangladesh 2007 175
CASE #5: Middle East 2008 175
CASE #6: Mediterranean 2008 176
CASE #7: U.S. (California) 2009 176
CASE #8: West Africa 2009 176
CASE #9: Taiwan 2009 177

C.2 RECENT CABLE THEFTS 177

CASE #1: Vietnam 2007 177
CASE #2: Jamaica 2008 178
CASE #3: South Africa 178

C.3 Potential Impact 178

APPENDIX D. FINANCIAL STABILITY BOARD CORE STANDARDS 180

APPENDIX E. CABLE-CUTTING IN WAR TIME – REFERENCE 181

APPENDIX F. UNITED NATIONS CONVENTION ON THE LAW OF THE SEAS 182

INDEX 184

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List of Figures

FIGURE 1. PRESENTATION OF RECOMMENDATIONS IN SECTION 5 23

FIGURE 2. EFFECTIVE MARKET FORCES 36
FIGURE 3. CURRENT “S”-CURVE LIMITATION 37
FIGURE 4. NEW “S”-CURVE OPPORTUNITY 37
FIGURE 5. TERMS ON TIME CONTINUUM 41
FIGURE 6. GLOBAL MAP OF SUBMARINE CABLE ROUTES 44
FIGURE 7. INTER-CONTINENTAL CONNECTIVITY VIA UNDERSEA COMMUNICATIONS CABLES 44
FIGURE 8. INFRASTRUCTURE BOUNDARIES 45
FIGURE 9. ROGUCCI ONLINE FORUM 46
FIGURE 10. THE GATE AT THE DIFC 47
FIGURE 11. SUMMIT PROGRAM SNAPSHOTS 49
FIGURE 12. JOHN MROZ AND DR. CURTIS SILLER 50
FIGURE 13. C.S. EITSALAT 51
FIGURE 14. TOUR OF C.S. ETISALAT 51
FIGURE 15. SOME OF THE SUMMIT PARTICIPANTS 52
FIGURE 16. SUMMIT PARTICIPANT ASSESSMENT 53
FIGURE 17. ROGUCCI GLOBAL SUMMIT PARTICIPANTS, THE GATE, DIFC. 58
FIGURE 18. 8I FRAMEWORK 59
FIGURE 19. EXAMPLE OF UNDERSEA COMMUNICATIONS CABLE CONSTRUCTION 65
FIGURE 20. OVERALL CAUSES OF FIBER OPTIC CABLE FAILURES, 2004 67
FIGURE 21. OVERALL CAUSES OF FIBER OPTIC CABLE FAILURE, 2007 68
FIGURE 22. TYPICAL FAILURE'S RATE BEHAVIOR DURING THE LIFE OF A SYSTEM 69
FIGURE 23. PRESENTATION OF KEY OBSERVATIONS. 80
FIGURE 24. 8I FRAMEWORK COLORED INDICATORS FOR INGREDIENT ASSOCIATIONS 80
FIGURE 25. GROWING ‘DEPENDENCE ON RELIABILITY’ GAP 82
FIGURE 26. SHUNT FAULT 87
FIGURE 27. CUT CABLE AND OFFENDING ANCHOR 88
FIGURE 28. EXAMPLE OF UNDERSEA CABLES - MINIMUM TO MAXIMUM PROTECTION 89
FIGURE 29. BASIC NETWORK TOPOLOGIES. 91
FIGURE 30. THE CONTINENTAL SHELF AND WATER ZONES. 95
FIGURE 31. RECOMMENDATION IMPACT ACROSS TIME CONTINUUM 100
FIGURE 32. NESTED INFORMATION EXCHANGE MODEL 115
FIGURE 33. PARETO ANALYSIS OF INGREDIENT ASSOCIATIONS WITH OUTAGE CAUSES (%) 152
FIGURE 34. PORTRAYAL OF THE HIGH PROBABILITY LOW RISK VS. VERY LOW PROBABILITY VERY HIGH RISK EVENTS 153
FIGURE 35. ISHIKAWA DIAGRAM WITH 8I FRAMEWORK. 154
FIGURE 36. HENGCHUN EARTHQUAKE CATASTROPHIC OUTAGE (2006): 155
FIGURE 37. HENGCHUN EARTHQUAKE 8I ISHIKAWA ANALYSIS 156
FIGURE 38. MIDDLE EAST CATASTROPHIC OUTAGE (2008) 157
FIGURE 39. MIDDLE EAST MULTIPLE CUTS 8I ISHIKAWA ANALYSIS 158
FIGURE 40. MEDITERRANEAN SEA CATASTROPHIC OUTAGE (2008) 159
FIGURE 41. MEDITERRANEAN SEA MULTIPLE CABLE CUTS 8I ISHIKAWA ANALYSIS 160
FIGURE 42. TYPHOON MORAKOT AND TAIWAN EARTHQUAKE CATASTROPHIC OUTAGE (2009): 161
FIGURE 43. TYPHOON MORAKOT AND TAIWAN EARTHQUAKE 8I ISHIKAWA ANALYSIS 162
FIGURE 44. EARTHQUAKE BELTS OF THE WORLD 164
FIGURE 45. PRESERVATION OF THE HISTORY OF UNDERSEA CABLES 167
FIGURE 46. MATURITY MODEL OF UNDERSEA COMMUNICATIONS CABLE TECHNOLOGY INFORMATION 168

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List of Tables

TABLE 1. ROGUCCI RECOMMENDATION LIST 23

TABLE 2. RESEARCH LOCATIONS 46
TABLE 3. ROGUCCI GLOBAL SUMMIT PROGRAM 48
TABLE 4. INGREDIENT CHAIRS 50
TABLE 5. ROGUCCI STUDY CONTRIBUTORS 55
TABLE 6. ICPC LOSS PREVENTION BULLETIN 76
TABLE 7. LEADERSHIP POSTURE FOR RECOMMENDATION IMPLEMENTATION 99
TABLE 8. HENGCHUN EARTHQUAKE 8I COUNTERMEASURE ANALYSIS 163
TABLE 9. FREQUENCY OF EARTHQUAKES WORLDWIDE 164
TABLE 10. MIDDLE EAST MULTIPLE CABLE CUTS 8I COUNTERMEASURE ANALYSIS 165
TABLE 11. MEDITERRANEAN SEA MULTIPLE CABLE CUTS 8I COUNTERMEASURE ANALYSIS 165
TABLE 12. 12 CORE STANDARDS OF THE FINANCIAL SECTOR 180

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1. EXECUTIVE SUMMARY
The Reliability of Global Undersea Communications Cable Infrastructure (ROGUCCI) Report
presents twelve Recommendations to the private sector, nation-state governments and other
stakeholders. These Recommendations, if implemented, will significantly enhance the availability,
resilience, reliability and robustness of the world’s international communications infrastructure.
This guidance is based on broad international stakeholder perspectives, international technical
policy development experience, expertise in emerging technologies and the insights captured in
The Study’s 100 Key Observations. Summary statistics of the ROGUCCI Study are as follows:
 
6 Continents represented
12 Recommendations articulated (Section 5)
57 Trends affecting infrastructure reliability (Section 3)
79 Intrinsic vulnerabilities considered (Section 3)
100 Key Observations (Section 4)
300+ Contributing international stakeholder experts (Section 2)
10,000+ Distinct data points researched and analyzed during study
30,000,000,000,000+ Bits per second traversing Global Undersea
Communications Cable Infrastructure (GUCCI)
 

Both developing and established nation-states understand the vital role of modern information
and communications technology (ICT) in providing security and stability, stimulating economic
growth, enhancing education, and fostering the expression and advancement of culture and
society. However, this ICT infrastructure is sharply devalued if it is not connected to the rest of
the world. Nation-states in every part of the globe have a critical need for continuous, reliable
and secure international connectivity. To strive for highly dependable international
communications capabilities is to face enormous technological, economic and political challenges.

To be clear, today’s undersea communications cables have provided a reliable service that is very
dependable. The service is the result of heroic technological breakthroughs and corresponding
diligence in building and operating these vast links that span our planet. Certainly, for the most
part, the countless government agencies, businesses and individuals who rely on the Internet,
global supply chains and modern financial markets everyday have been able to enjoy the luxury of
grossly under appreciating the contributions of this industry to modern society.

However, the insatiable thirst for bandwidth is accompanied by an ever-growing dependence on

inter-continental communications, which are nearly entirely supported by undersea cables.
Given this exploding dependence by seemingly all aspects of society, the question quite naturally
emerges: Is the level of reliability of this critical international infrastructure keeping pace? It was the value
offered by mastery of the answer to this question that first motivated the ROGUCCI Study.

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The consequences of the loss of international communications have proven to be severe. Indeed
several large-scale outages have occurred in recent years that have had an unacceptable impact for
those affected (see Appendix A, Appendix C). It has been observed that never before in human
history has mankind so quickly embraced – and become so completely reliant upon – new
technology, as this current generation. And it must be quickly followed with the observation
1

that it is not clear whether civilization can emerge without irreversible consequences from the
widespread catastrophic failure of such technology. Given the utter dependence, recent history
2

of failure, and the reality of latent failure modes, the imperative for The Study could not be more
urgent.

For a nation-state, or other stakeholder such as the financial sector, to simply keep pace with the
accelerating advances of the information and communications industry it must meet many
challenges. However, for a nation-state or stakeholder to ensure highly available and highly
robust global communications, it must do more – including cooperate with international partners
with the same goals. The twelve Recommendations presented in The Report prescribe critical
areas that should receive priority attention to achieve this objective. Because many of these
issues are common across many stakeholders, international cooperation and private sector-
government cooperation are repeated themes throughout The Report.

Other key messages in The Report are the following:

 
There exists a profound lack of awareness by the general public, businesses and governments
regarding their daily dependence on global undersea communications cable infrastructure.

There appears to be a gap between the growing dependence on international bandwidth and the
reliability of its underpinning infrastructure at a global level. This is not so much that the reliability
of the systems is any less, but that the dependence has grown so great. The industry is keeping
up with the insatiable thirst for bandwidth with heroic advances in technology and deployment of
new systems. However, investment to ensure the resilience at a global level is outside the scope of
those building this increasingly critical international infrastructure.

There is no sufficient alternative back-up in the case of catastrophic loss of regional or global
connectivity. Satellites cannot handle the volume of traffic – the available capacity is not even
close.

Guiding Principles of The Study

Several principles guided the approach taken in The Study. First, the interests of the citizens of
world were at the forefront. For this reason, there is an emphasis on the importance that global
interconnectivity plays on the welfare of societies around the world.

1
Kissinger, Henry, Does America Need a Foreign Policy?, 2002.
2
52% of EWI Worldwide Security Conference 7 – Cybersecurity Consultation participants indicated that “the loss of global
connectivity for an extended period of time (e.g., more than a month) would be catastrophic for global society, with irreversible
consequences.” Brussels, February 2010.

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Second, The Study was to be forward-looking in terms of the future needs of society, businesses
and governments. Therefore, The Study factored in numerous trends, such as regional economic
growth hotbeds, skyrocketing bandwidth demand, the shift of network control from being
“silicon”-based (hardware) to being software-based, the emerging capability to provision
bandwidth dynamically, ocean sprawl, increased piracy activity on the high seas, growing
concerns of terrorist activity worldwide, and the disappearance of national network boundaries as
a result of global interconnectivity.

Another principle was to use a worldwide spotlight. To manage discussions of this novel
perspective, a new term (GUCCI) is introduced to refer to the ‘global undersea communications
cable infrastructure.’ In addition to this focus, an appropriate awareness of nation-state
sovereignty was maintained as a consideration for the private sector operation and ownership of
individual international cable systems.

Including all of the various regional insights that were offered was another principle on which
The Study was based. This was accomplished throughout the methodology described below by
seeking and then carefully considering input received from extensive outreach conducted via
diverse means.

Yet another principle was to ensure rich representation of industry, academic and
government perspectives, with care to include both long-established companies as well as new
entrants. Thus, a wide variety of service providers, network operators and equipment suppliers
were engaged. Government perspectives were gleaned from both regulator and stakeholder
agencies. The Study also obtained input from other critical sectors that depend on the
communications sector.

Finally, the approach utilized world-class proficiency in both the technical subject matter and
broader policy areas to ensure the resulting guidance would be both realistic and achievable. The
Study utilized only individuals of the highest caliber of demonstrated competency. For example,
in the unique technical policy development arena, the small core leadership team included
individuals whose high recommendation implementation rate is a matter of public record.
Further, the subject matter expertise of the technical community included subject areas central to
The Study: network reliability and security, infrastructure protection, nation-state security,
emergency preparedness, disaster recovery, emergency communications, ad hoc emergency
networks, hardware and software quality and government-industry collaboration.

Methodology of Study
The methodology used in The Study was designed to support data gathering, validation and
analysis with the aim of developing meaningful guidance. There are several distinguishing
characteristics of The Study’s methodology. First, The Study employed a framework of the
complete list of ingredients that make up undersea communications cable infrastructure:
power, environment, hardware, software, payload, network, human and policy. The striking
advantage of using this framework is that it readily lends itself to the comprehensive listing of
intrinsic vulnerabilities, which are finite – unlike threats, which, for practical purposes, are

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infinite. Present-day security approaches are for the most part founded on the threat side of the
equation, which is derived from historic experience and gathered intelligence. In contrast, the
intrinsic vulnerability approach, rooted in a detailed knowledge of the ingredients that make up a
communications network, permits profoundly higher degrees of confidence in terms of ensuring
reliability and robustness. This focus on vulnerability analysis does not exclude the use of threat
analysis, which draws extensively on observed trends and the subjective perspectives of
individuals. Rather, it uses that knowledge and supplements it with expert knowledge about the
systems that make up communications networks.

Secondly, The Study was heavily dependent on the expertise and experience of a unique
formula of individuals. Specifically, technical and operational experts, government and
financial sector stakeholders, and international policy change agents were integrated throughout
the ROGUCCI process. Experts from all facets of the communications industry were sought out
and engaged. Thousands of years of experience are represented in the contributions made. It is
worth noting that the dimension of experience that was drawn upon is not solely restricted to
years of experience, but breadth of experience as well. Experts with limited years in the industry
but with new and unique perspectives were included in The Study. Future networks will be a
collection of a diverse set of components – analyzing them requires a diverse set of perspectives.

Next, the findings of The Study were facilitated with a wide range of approaches, including
extensive literature research, face-to-face interviews, Internet forums, conference calls and a
Global Summit.

Finally, the three step process of a Study, Global Summit and then Report development and
dispatch played a key role in maintaining focus on the objective of actual improvement of the
infrastructure’s reliability. This process facilitated the development of twelve Recommendations
that are actionable and effective.

In summary, the methodology used throughout The Study is based on proven approaches for
similar highly consequential advisory undertakings regarding critical infrastructures. The 3

framework, range of experience and expertise, personal interaction and recommendation process
enabled a deep dive into the issues facing the world’s electronic connectivity, drew upon the
knowledge of those most familiar with it, and established a model for future cooperation and
sharing.

The 100 Key Observations

100 Key Observations have been identified relative to the reliability and robustness of global
undersea cable infrastructure. These observations are a combination of information offered by
experts in interviews and derived determinations from analysis of the aggregated information.
With unique analysis points on the order of 10,000, there were certainly more observations that
could be made. Those selected were deemed essential for appreciating The Recommendations
that were formed. In a sense, the Key Observations form a foundation for The Report’s
Recommendations.

3
U.S. President’s National Security Telecommunications Advisory Committee (NSTAC) Next Generation Networks (NGN) Task
Force, 2006.

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The Key Observations are presented in four broad categories: Stakeholder, Science &
Engineering, Business & Investment, and Government & Inter-Government. An example for
each of these areas is provided below. Note that each Observation is accompanied with a color
code that signals which of the eight infrastructure ingredients it is tied to.

Stakeholder.

16. Financial Sector Due Diligence. Insufficient reliability data is available for financial
sector and other stakeholders to support needed risk calculations. In order to do
appropriate diligence, stakeholders should be able make statistical predications
regarding the expected frequency and duration of outages and the range of impairments
(e.g., payload latency) that can affect their operations. However, insufficient data is
available to support such analyses.

Science & Engineering.

21. Rare Glimpse of c’s Limit. Usually the speed of light makes communications appear
instantaneous for humans. However, long haul undersea cable systems provide a rare
human experience with the finite nature of the speed of light on the earth. A trip
encompassing the circumference of the earth requires approximately one tenth of a
second – a delay noticeable to a human. During cable failure alternate routes that
require routing over longer distances is common, resulting in latency that is
unacceptable for some real-time sensitive applications.4

Business & Investment.

74. Specialized Cable Ships. Cable ships and their crews are typically shared resources.
Contention for such limited resources is one of the contributing factors in extended
duration outages, particularly when multiple cuts are involved.

Government & Inter-Government.

78. Geo-politics. Geo-political impediments have limited the implementation of a

fundamental sound principle of reliability engineering – avoiding single points of failure.5

The speed of light is ~3.0 x108 meters/second, which would take 0.13 seconds to travel ~4.0 x 107 meters, the circumference
4

of the earth.
5
Examples include the cable-dense Luzon Strait, Strait of Malacca and Red Sea passages.

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The 12 ROGUCCI Recommendations

Summarized below are the ROGUCCI Study’s Twelve Recommendations for improving the
reliability, robustness, resilience and security of the world’s undersea communications cable
infrastructure. In this executive summary, each Recommendation is presented with an
abbreviated context, consisting of a brief introduction to the issue, a purpose statement and
summary of the commitments required by the private sector and governments and other
stakeholders. An anonymous quote collected from a Study contributor is used to introduce each
recommendation.

Figure 1. Presentation of Recommendations in Section 5

Each Recommendation is supported with a mixture of the Key Observations, knowledge and
experience of the vast expertise engaged, and validation by industry peers and stakeholders. Each
Recommendation is presented in Section 5 with a more complete context – yet in a concise
format (Figure 1).

Table 1. ROGUCCI Recommendation List

ROGUCCI Recommendations
1 Rudimentary Geographic Diversity for Global Infrastructure
2 Prioritization for Timely Cable Repairs
3 Preparedness for Hostile Maritime Crisis
4 Best Practices and Trusted Information Sharing
5 New International Governance
6 International Communications Infrastructure Standard for the Financial Sector
7 Measurements for Stakeholder Due Diligence
8 Improved Cable Protection Agreements, Standards, Policies and Regulations
9 Government Inter-Agency Coordination for Undersea Cable Infrastructure
10 Education and Awareness of Critical Role of Undersea Communications Infrastructure
11 Mechanisms for Handling Overload Demand
12 Recognize GUCCI Catastrophic Loss as a Grand Challenge

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1. Rudimentary Geographic Diversity for Cable Infrastructure
“I’ve been in the industry for almost 30 years and always wondered who is worrying about this . . . in
the early years I remember telling my wife . . . but we all seem to accept it.
But one day our hoping may run out.”

Issue
At a global level, the overall interconnectivity of the continents violates a fundamental reliability
design principle – avoid single points of failure. There are several geopolitical chokepoints that funnel
these critical cable paths together. A single disaster in such an area could cause catastrophic loss
of regional and global connectivity.

Purpose
The Recommendation addresses the issue of how to significantly improve the reliability of GUCCI by
addressing unwanted points of concentration through the deployment of geographically diverse routes.

Recommendation
Stakeholders for highly reliable and resilient international communications should actively
promote the deployment of geographically separate cable paths to avoid current single points of
failure, by serving as advocates to the nation-states controlling the lands and waters for potential
alternative, diverse paths.

Required Commitment
The effective implementation of The Recommendation requires the commitments of
stakeholders, governments, the private sector and an effective international policy change agent.
Stakeholders must commit to a course of advocacy to ensure the appropriate governments
understand the geographic concentration risk. Nation-state governments must provide access to
investors and provide assurances for timely ongoing maintenance. Finally, investors must build
out new fiber cable systems in routes providing new geographic diversity.

 
2. Prioritization for Timely Cable Repairs
“There is no excuse for this . . . and they are hurting the businesses and citizens
of their own country as much as anyone.”
 
Issue
Bureaucracy of nation-states with territorial water sovereignty too often causes extensive delays in
the restoral of service over damaged undersea communications cables. Repair times are already
long. These delays extend the approval portion from days to weeks or even months.

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Purpose
The Recommendation addresses the issue of how to significantly reduce the average time needed to restore
service after cable damage by addressing the lengthy approval process for cable repair vessels to gain access to
sovereign waters.

Recommendation
Nation-state governments should implement policies and procedures to provide timely approval
to authorized cable ships seeking permission to repair damaged undersea communications cables.

Required Commitment
The effective implementation of The Recommendation requires the commitments of
governments and the private sector. Nation-state governments must conduct advance planning
in anticipation of cable damage, and elevate the priority restoration of undersea communications
cables. They must also provide an efficient and appropriately speedy process for granting
authorized repair vessels access to their sovereign waters, and be willing to compare themselves
to best-in-class benchmarks for timely issuing of permits. Cable ship operators and cable
infrastructure owners must cooperate with government requirements for information, onboard
inspections, escorts and other requests, particularly when opportunities for pro-active
engagement are presented.

 
3. Preparedness for Hostile Maritime Crises

“Can you imagine? Pirates in this day and age!”

Issue
Increased hostile activity around the world requires the undersea communications cable industry
to enhance its preparedness for attacks on its specialized cable ships and critical infrastructure.
In addition to the obvious danger to lives and property, such activity could cause long-term
service outages.

Purpose
The Recommendation addresses the issue of how to provide a mechanism for rapid response to hostile
activities against international communications cables or the industry’s specialized cable ships by undertaking
coordination, planning and other emergency preparedness activities.

Recommendation
Nation-state governments should cooperate with each other and private sector undersea
communications cable infrastructure owners and operators to develop maritime crisis
preparedness plans that would protect communications cable vessels that are vital to the
operation of global undersea communications cable infrastructure.

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Required Commitment
The effective implementation of The Recommendation requires the commitments of
governments and the private sector. Nation-state governments must cooperate in establishing
intergovernmental agreements, participating in planning, and being part of periodic simulated
crisis exercises. Owners of cable ships must support effective planning and exercises by making
vessels and critical personnel available. Finally, nation-state governments and cable ship owners
must establish cooperative procedures for maritime crisis response.

 
4. Best Practices and Trusted Information Sharing

“The Summit made it clear there are real opportunities for improved cooperation.”
 
Issue
With the enormous challenge of protecting and advancing the reliability of GUCCI, there are
compelling reasons for ensuring that industry peers are well informed, as better awareness can be
critical in optimizing strategies for protection and reliability assurance. This information sharing
is needed on an international basis, as inter-continental undersea cables are by definition
international critical infrastructure.

Purpose
The Recommendation addresses the need to share sensitive information among industry and
government stakeholders, within a trusted environment, enabling all participants to benefit from
this shared body of knowledge that is essential to optimize network reliability and resilience.

Recommendation
The private sector should establish formal means for sharing information that can improve the
protection and rapid restoration of undersea communications cable infrastructure.

Required Commitment
The effective implementation of The Recommendation requires the commitment of the private
sector and nation-state governments. Private sector companies that own and operate undersea
communications infrastructure must jointly establish a trusted environment for sharing
information to improve the protection and rapid restoration of GUCCI. The private sector must
be willing to share threat and outage information within a trusted environment within the
industry for the common good. Nation-state governments must be willing to share threat and
other sensitive information with owners and operators of GUCCI and safeguard information
provided by the industry. Nation-state governments must be willing to share information that
will improve the protection and rapid restoration of critical infrastructure with other nation-states
as well as the owners and operators of that infrastructure within the other nation-states.

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5. New International Governance

“We still have time for private sector leadership here . . . we can avoid inefficient and costly
government oversight if we better organize ourselves and cooperate better.”
 
Issue
The Report establishes the need for dealing with individual undersea cable systems as an
aggregate, i.e. global level. The need is based on the limited focus of commercial interests that
manage individual systems, the difficulty stakeholders have in performing due diligence in
managing their operational risk and the extremely high level of importance that this infrastructure
plays in the world. Some groups are re-examining their charters to determine how they might
address some of the new or more critical issues of the nature discussed at ROGUCCI Summit.
Observations from financial sector stakeholders were that the undersea communications industry
would benefit from a “system-wide” view, more inclusive participation in industry collaborative
programs, more structured governance, better coordination and a unified voice. Specific mission
areas for new governance would ideally include defining expectations for the industry, engaging
representative stakeholders and articulating agreements, standards, policies and regulations
(ASPR) that would advance GUCCI resilience.

The implementation of Recommendation 4 is complimentary to this Recommendation. Both of these

Recommendations in turn support Recommendation 7.

Purpose
The Recommendation addresses the issue of how the undersea communications cable industry
supports the needs of its stakeholders in providing the information they need to manage their
dependence on GUCCI.

Recommendation
The private sector should establish a new international governance framework for global
undersea communications cable infrastructure to provide optimum support for its resilience
through cross-sector coordination and effectively support stakeholder interests.

Required Commitment
The effective implementation of The Recommendation requires the commitment of the private
sector and stakeholders. Stakeholders must maintain a proactive posture in engaging this critical
international infrastructure partner. Existing industry fora must evaluate their charters,
membership and commitments in light of the stakeholder and internal industry needs. Existing
industry fora must, as appropriate, be either willing to make charter and membership
representation adjustments, or be supportive of sister organizations playing new complimentary
roles. Private sector companies must provide expert and leadership resources to champion new
governance functions.

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6. International Communications Infrastructure Standard for the Financial Sector

“We are completely dependent on this. We don’t have any other way.”
 
Issue
The world’s international undersea communications cable infrastructure continues to operate at
highly reliable levels and continues to provide tremendous service to the financial services sector.
Recommendations 4 and 7 position the communications industry to better share information and
provide needed information to the financial sector, respectively. Correspondingly, this
Recommendation calls on the financial sector to better define its needs and expectations, and to
develop a structure to organize operational risk guidance that allows both providers and users to
manage their growing global dependency on GUCCI.

The implementation of Recommendations 6 and 7 work from the two sides of the same problem.

Purpose
The Recommendation addresses the issue of how the financial sector should manage its
dependence on GUCCI, specifically in the context of an overall improved management program
for its dependence on information and communications technology in general. While one sector
is the focus in The Recommendation, it should be viewed as representative of all international
critical sectors.

Recommendation
The international financial sector should introduce a new core standard for its information and
communications technology dependence that will include guidance on assuring institutional
resilience and managing the operational risk associated with undersea communications cable
infrastructure.

Required Commitment
The effective implementation of The Recommendation requires the commitment of the
international financial sector, international undersea communications cable industry and world’s
economic leaders. The international financial sector must recognize GUCCI reliability as a
strategic priority for the stability of its operations. The international financial institutions must
commit operational risk managers to developing the details of global guidelines. The financial
sector and international communications industry must commit to a partnership to develop a
core standard that both can agree on. The financial sector members must voluntarily implement
the developed core standard. The world’s international financial authorities must utilize these
standards in their determination of ratings and other stability-related decisions.

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7. Measurements for Stakeholder Due Diligence

“We can do better . . . it is clear those counting on us need this.”

 
Issue
As the financial services sector continues to evolve on a global basis, increased reliance on
information and communications technology (ICT) translates directly into increased reliance on
undersea cable infrastructure. Today’s global markets are vitally dependent on resilient
international connectivity. Major gains achieved in reducing market risk through such
mechanisms as automation and compressed settlement intervals are offset by increased
operational risks through increased dependencies on ICT in general, and undersea cable
infrastructure specifically. Those responsible for overseeing their institution’s exposure to
operational risk cannot perform due diligence because there is insufficient information available.
The fundamental information that is needed centers around statistically based expectation of
downtime for international connectivity. There is basic lack of published, or otherwise available,
information on GUCCI reliability for stakeholders that play critical roles in societies around the
world.

The implementation of Recommendations 4 and 5 will create structure and spirit to enable this Recommendation to
succeed. Further, Recommendation 6 will be enabled by the implementation of this Recommendation.

Purpose
The Recommendation addresses the issue of how the undersea communications cable industry
supports the needs of its stakeholders by providing the information they need to manage their
dependence on it.

Recommendation
The private sector should establish a method of providing basic reliability performance statistics
to stakeholders.

Required Commitment
The effective implementation of The Recommendation requires the commitment of the
international undersea communications cable industry. Stakeholders must maintain a proactive
posture in engaging critical international infrastructure partners. Private sector companies must
be willing to share the outage information needed to support overall GUCCI performance
measurements, with appropriate non-disclosure agreement protections. Existing industry fora
must evaluate their charters, membership and commitments in light of the stakeholder and
internal industry needs. Existing industry fora must, as appropriate, be either willing to make
charter and membership representation adjustments, or be supportive of sister organizations
playing new complimentary roles. Private sector companies must provide expert and leadership
resources to champion new governance functions.

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8. Improve Cable Protection Agreements, Standards, Policies and Regulations

“If we could just get all of the best policies from around world packaged together,
we could say, ‘Look! Here is what you can do.’ ”
 
Issue
The protection of undersea cables in international law is well established, dating back to the
1880s. Cable protection laws have been updated with new policy at the international level.
However, too often there is not corresponding nation-state-level policy to match the importance
established at the international level. This is of particular concern because undersea
communications cables are especially vulnerable in the transition from deep water to their landing
site. As a result, avoidable cable damage is routinely experienced.

Purpose
The Recommendation addresses the issue of how to provide better protection of deployed cable
systems using available or new policy instruments.

Recommendation
Nation-state governments should implement best practices for protecting undersea
communications cables within their sovereign waters.

Required Commitment
The effective implementation of The Recommendation requires the commitment primarily of
nation-state governments, but with important support of the private sector. Nation-state
governments must make the protection of undersea communications cable infrastructure a
priority. The private sector must assist the government in understanding the types of damage
experienced. Governments must be able to improve their protection through effective policies
and practices.

 
9. Government Inter-Agency Coordination for Undersea Cable Infrastructure

“I know it seems impossible, but we have to try . . .

There is no law of physics that keeps this from being better.”
 
Issue
The undersea cable industry is too often impacted by weak government policies that impede its
efforts to improve the reliability of its systems and services. One of the primary causes of this is

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poor coordination among government agencies. It is understandable that each agency will have
its own primary interests. However, this often results in inconsistent policy, confusion and delays.
There are no easy solutions. Drawing attention to this problem is a first step, but it must be
followed with commitments and actions for improvements to be realized. Some of the
opportunities for progress may lie in greater education and awareness among key policy makers
and regulators, the quantification of the negative impact of uncoordinated government, the
private sector’s capture and articulation of the best practices for this area, and public recognition
of role model behavior.

Purpose
The Recommendation addresses the issue of how to transform governments’ lack of inter-agency
coordination when it comes to policy for undersea cable protection.

Recommendation
Nation-state governments and the private sector should establish a best practice model for
undersea communications cable inter-agency coordination to ensure consistent policies and
practices.

Required Commitment
The effective implementation of The Recommendation requires the commitment primarily of
nation-state governments, but with important support of the private sector. Nation-state
governments must make oversight of undersea communications cable infrastructure a priority.
The private sector must assist government in understanding observed inconsistencies and impact,
and provide role model references. Governments must be able to improve their inter-agency
coordination to provide consistent policy and speedy implementation.

 
10. Education and Awareness of GUCCI Critical Role

“It is not only the general public . . . this CEO of a high tech company
thought that most international communications were over satellites.”
 
Issue
There is a profound unawareness on the part of the general public, business enterprises, critical
sector stakeholders and government regarding their dependence on undersea communications
cable infrastructure. While the increasing rate of dependence climbs steeply, there is no
corresponding movement in consciousness of the dependence or the risks associated with it

Purpose
The Recommendation addresses the issue of how to close the profound gap between critical
dependence and awareness that stakeholders and the general public have regarding GUCCI.

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Recommendation
The undersea communications cable industry should begin an outreach campaign that provides
appropriate education to government and other stakeholders regarding GUCCI function in the
stability of their operations.

Required Commitment
The effective implementation of The Recommendation requires the commitment primarily of
private sector, but with important support of stakeholders. The undersea communications cable
industry must recognize the unacceptable nature of the existing dependence-unawareness gap,
and commit to action to resolve the under-education of its dependents. Stakeholders must be
diligent in achieving appropriate levels of knowledge regarding their dependence and develop
best management practices regarding their dependence on GUCCI.

 
11. Mechanisms for Handling Overload Demand

“This is the sort of thing that it is better to plan for and control than the alternative.”
 
Issue
There are several reasons for increased vigilance regarding future infrastructure congestion. An
overload condition is a very real scenario, which may present itself intermittently in unexpected
fashion, or as a temporary situation due to a specific event. Terrestrial networks have anticipated
the need for managing overloads with the deployment of various mechanisms. How can
international coordination ensure that the communications most critical for continued
government operation and security be maintained?

Purpose
The Recommendation addresses the issue of how to prepare for traffic overload scenarios for the
global undersea communications cable infrastructure.

Recommendation
Network operators, service providers and stakeholders should develop and implement agreed
upon mechanisms for handling traffic overload conditions for undersea communications cable
infrastructure.

Required Commitment
The effective implementation of The Recommendation requires the commitment of nation-state
government and the private sector. Nation-state governments must agree that some
communications are more important than others and therefore require preferential treatment
during times of infrastructure congestion. Nation-state governments must agree with each other
on mutual preferential treatment of so-designated traffic. Nation-state governments must
provide incentives for private sector development and deployment of priority schemes. Nation-

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state governments, stakeholders, network operators and service providers must securely manage
the administration of authorized priority traffic. Service providers and network operators must
implement agreed-upon overload management mechanisms.

 
12. Recognize GUCCI Catastrophic Loss As a Grand Challenge

“There is no ‘Plan B’.”

 
Issue
Nearly 100% of the world’s inter-continental electronic communications traffic is carried by the
undersea cable infrastructure. Terrestrial based routes alone would leave continents in isolation.
The probability of a global or regional failure is very low; however, it is not zero. The impact of
such a failure on international security and economic stability could be devastating. It is unclear
if civilization can recover to its previous condition from the failure of a technology that has been
so rapidly adopted without a back-up plan. Without GUCCI, the world’s economic financial
market would immediately freeze. But what would happen next? What are the options? What
can be done to best prepare for this possible event?

Purpose
The Recommendation addresses the concern of preparing for a large-scale loss of the world’s
undersea communications cable infrastructure, by directing stakeholders to prepare for the worst
case scenario and by calling on the scientific and engineering community to respond to a new
grand challenge problem.

Recommendation
Subject Matter Experts and Stakeholders should prepare for the worst-case scenario of a
catastrophic loss of global undersea communications infrastructure by identifying best available
alternatives and operational procedures. Preparation should include scientific and engineering
research for long-term solutions.

Required Commitment
The effective implementation of The Recommendation requires the commitment of
governments, stakeholders and the private sector. Governments and other stakeholders must
encourage academic and private sector research to ensure appropriate resources are focused on
this global challenge. Scientists and engineers must be devoted to developing alternatives.
Stakeholders must conduct planning scenarios that consider true worst-case scenarios. The
financial services sector can play a lead role in helping establish the importance of this concern.

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Summary

This Study submits twelve major Recommendations to the private sector, governments and other
stakeholders - especially the financial sector - for the purpose of improving the reliability,
robustness, resilience and security of the world’s undersea communications cable infrastructure.
In practical terms, these twelve Recommendations are offered as challenges to individuals. These
will be the ones who will need to make the difference when a difference is called for. The senior
leaders and subject matter experts of equipment suppliers, network operators and service
providers; the leaders and participants of the industry’s fora; researchers; consultants in small
firms; government policy makers and staff employees; IT specialists in financial firms; and many
others – all are strongly urged to include this Report in their dialogue and to do so speedily, as
the improvement opportunities described have important benefits to many throughout the world.
Likewise, the consequences have many downsides.

It is encouraging that at the time of this Report dispatch, a number of private sector interests
have indicated their willingness to take the next steps suggested for several Recommendations.
Each of The Recommendations should be considered and acted upon with urgency proportional
to the vital role that international communications networks and services will play in the future.
The critical priority for implementation is clear. Without reliable international communications
networks and services, public welfare is endangered, economic stability is at risk, other critical
sectors are exposed, and nation-state security is threatened. The implementation of this Report’s
Recommendations will significantly reduce these and other risks. Each of the twelve
Recommendations is both challenging and achievable. The intent of the ROGUCCI process
from the beginning has been to improve the world’s communications. Successful
implementation of each Recommendation will significantly improve the reliability and robustness
of communications services for the citizens around the world. However, each will require skill,
resolve and genuine partnership among government entities, stakeholders and the private sector.

This Study strongly urges the private sector, governments and other stakeholders to chart and
embark on a new course of policy and practice that forcefully advocates highly available, highly
reliable, highly robust, highly resilient and highly secure international communications
infrastructure.

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2. INTRODUCTION
The ROGUCCI (ro–goo–che) process objectives, scope and methodologies are presented in this section.
This material is essential for understanding the supporting work behind The Report’s guidance. It can be
used as background and reference material for readers who prefer to focus on The Recommendations in
Section 5.

To assist with the discussion of the aggregation of individual undersea cable systems and the concept of a
single infrastructure, the term ‘GUCCI’ (goo–che) is here introduced as an acronym for ‘global undersea
communications cable infrastructure.’

2.1 Objectives

The objectives of The Study were to:

• examine the reliability of undersea communications cable infrastructure at a global level,

• assess the potential impacts of infrastructure failures–with financial sector focus, and
• provide guidance for improved global infrastructure resilience, if needed.

Each of these objectives was achieved as is documented in The Report. The reliability of the
infrastructure is reviewed in Section 3, Analysis of Undersea Communications Infrastructure, with the Intrinsic
Vulnerability approach that not only provides a systematic structure, but also comprehensive coverage.
Additional tutorial-level background as well as advanced information is provided in Section 4, Key
Observations. The impacts of potential failures are discussed throughout and specifically in Appendix C.
Section 5, Recommendations, provides guidance to the private and public sector for improving the reliability,
resilience and robustness of GUCCI.

While The Recommendations cover gaps needing to be addressed at a global infrastructure level, it is
important to recognize that there are many aspects of the industry that are highly effective in delivering
reliable infrastructure and services. To start, the market forces that shape the primary supply chain
interfaces between ‘the equipment supplier and network operator,’ ‘the network operator and the service
provider,’ and ‘the service provider and the end user’ have been effective in achieving the current high
levels of reliability. These market forces include immediate awareness of outages due to their observability
through service impact; competition from alternative service providers, network operators and equipment
suppliers; and an improved return on investment for highly reliable systems, networks and services6
[Figure 2].

6
Exceptions to this are described in Key Observations 71.

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Figure 2. Effective Market Forces

Technology advances as well as healthy commercial relationships have enabled this industry to grow, be
trusted, and ultimately become the underpinning of the global economy. The history of GUCCI has
witnessed its maturing with time and investments along an “S-curve” to produce resilience at a remarkable
level. This achievement is particularly noteworthy given the nature of the challenges faced, such as
extreme dimensions of length and depth, harsh environments and gigantic load. However, forces
preventing further advances are limiting the current performance level [Figure 3]. These forces involve
realms that are outside the industry’s core competencies – i.e. engineering, operations, management, legal
– and are outside the supplier-operator, operator-provider and provider-user relationships. One such
limiting outside force is geopolitical interest. These limiting forces are identified, explored and addressed
in The Study.

The dramatic increasing dependency upon GUCCI makes it imperative that these forces be overcome so
that correspondingly fresh levels of reliability, resilience and robustness can be achieved [Figure 4]. It is in
this way that the ROGUCCI process is complimentary to the many existing activities currently under way
that promote the reliability of this infrastructure. The Recommendations presented in The Report, if
implemented, will provide breakthroughs to improve reliability. Together they offer a new “S-curve”
opportunity that can build upon achievements to date and enable access to higher performance at a global
level.

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Figure 3. Current “S”-Curve Limitation

Figure 4. New “S”-Curve Opportunity

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2.2 Uniqueness of Approach

The character of the ROGUCCI process is unique in four primary ways.

First, the focus is at the global level. The first objective was to look holistically at the undersea
communications cable infrastructure, i.e. at a global level, as distinguished from a focus on individual
undersea communications cable systems, which are often international. The former considers the
aggregation of all international systems. This undertaking was significant because most reliability work in
this arena is done at the individual system level for specific deployed technology. In this way The Report
complements existing mechanisms and forces in play throughout the relationships between equipment
suppliers and network operators, between network operators and service providers, and between service
providers and customers.

Second, consideration is given to “things that can happen, that have not yet.” This is significant
because of the relatively rare frequency of failures within this infrastructure and the ever-increasing
dependence upon it. Diligent exploration was made of failure types and modes that are latent within the
infrastructure. This was accomplished through a disciplined Intrinsic Vulnerability approach and through
comprehensive coverage provided by using the Eight Ingredient (8i) Framework to ensure inclusion of all
possible contributors to downtime (Section 3).

A third distinction of the approach is openness to consider and address areas previously
“untouchable.” This brought The Study into areas beyond the current discussion of improvement areas.
Most notably, The Study addressed constraints imposed by geopolitical perceptions and realities.

A fourth difference in the approach is the ROGUCCI brain trust “formula.” This formula includes
individuals with interests, expertise and experience in three domains:

• technical experts (across 8i for undersea cables, reliability, etc.)

• finance sector and other stakeholders to represent the impact of infrastructure failures
• international policy change agents to affect global policy

The contributions of these “breeds” were authoritative insights into the “what” (i.e. scientific and
engineering limitations and parameters), the “why” (i.e. the practical consequences and impacts), and the
“how” (i.e., convening, reframing and mobilizing for international policy change), respectively. These are
each key elements of the ROGUCCI process.

2.3 Importance of the Subject

The reliability of GUCCI is absolutely essential for the basic functioning of nation-state governments, the
stability of critical stakeholders such as the international financial sector, the continued operation of
business enterprises and the daily lives of countless individual netizens. For these parties, their current high
level of dependence, their rapid rate of increased dependence and their enormous expected future dependence are
self-evident motivations for vigilance in improving the resilience of this infrastructure.

Beyond establishing that the subject matter is important, a compelling need for The Study is the profound
lack of awareness of these dependencies. Only a small minority in each of the parties above is aware of
the nature of their dependence on GUCCI.

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The Study was conducted in close partnership with senior leaders of the international financial community.
This sector continues to evolve on a global basis with increased reliance on information and
communications technology (ICT), and vital dependence on resilient international connectivity. This
global connectivity translates directly into increased reliance on undersea cable infrastructure. “Financial
services executives and managers must recognize the technical complexity, risks and contractual
requirements, ongoing relationships, and recovery challenges associated with the international
telecommunications infrastructure”.7 The major gains achieved in reducing market risk through such
mechanisms as automation and compressed settlement intervals are offset by increased operational risks
through increased dependencies on ICT in general, and undersea cable infrastructure, specifically.

Improvements in the reliability of this global infrastructure will benefit international communications
users around the world – governments, private sector organizations, and individuals.

2.4 Defining Progress

The above subsections answered the three questions about the ROGUCCI activities: What is it about?
Why is it important? and, Who cares if it is successful? This section will continue this line of thought by
answering the question: What are the measures of success?

Success for the ROGUCCI process is defined as follows:

1. Raising the critical stakeholders’ awareness of their vital dependence on GUCCI.

2. Articulating actionable recommendations, that, if implemented, would reduce the likelihood, or ameliorate
the global impact of, a catastrophic undersea communications cable infrastructure failure.

The Study and Global Summit, which are described in later subsections, have begun to elevate awareness.
The engagement of hundreds of experts and stakeholders, the traffic of thousands of ROGUCCI Study
web site visits, and the high profile international Summit event have created impetus for fresh discussions.
The nature of awareness is important and is being appreciated chiefly in two dimensions: by the depth of
understanding and by those who are undertaking the understanding. In the area of depth, greater
understanding is being fostered at all stages of the awareness continuum – from the point of initial
awareness to advanced appreciation for actionable countermeasures. Those engaged in the understanding
are key. Since the private sector is largely the owner of this infrastructure, it is essential that equipment
suppliers, service providers and consortium operators are engaged.8 Owing to the fact that senior level
decisions will eventually be needed to implement The Report’s guidance, the direct participation of senior
government and industry leaders has been welcomed. Inasmuch as this is an international concern, it is
encouraging that experts and stakeholders from six continents are actively engaged. The dispatch of The
Report is expected to continue this momentum. 9 The ultimate measure of success in this area of
awareness is whether enough critical stakeholders develop an accurate sense for their vital dependence on
GUCCI.

Regarding the second measure, it is fulfilled in The Report’s presentation of twelve actionable
recommendations, that, if implemented will improve the reliability of GUCCI (Section 5).

7
Resilient International Telecommunications Guidelines for the Financial Service Sector, Pacine, Wayne and Callahan, Roger,
Financial Service Sector Coordinating Council, www.fsscc.org, 2009.
8
See Section 2.8.
9
Updates will be provided on www.ieee-rogucci.org.

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2.5 Scope
This section describes the scope of The Study in terms of subject matter interests, technology, network
types, and geography.

The Report provides an expert review of the reliability of the global undersea communications cable
infrastructure. Because there exists abundant material in the public domain that covers the components
and architecture of this critical infrastructure, The Report does not attempt to duplicate that excellent body
of knowledge. Rather, the focus of The Report is on the factors promoting or impairing the
infrastructure’s reliability. The Report provides a comprehensive analysis of the intrinsic
vulnerabilities of the infrastructure, significant trends affecting these vulnerabilities and suggested
guidance on addressing latent and emerging reliability challenges. This focus on reliability, in this
context, will include the related aspects of infrastructure availability, resilience, robustness, and security.

2.5.1 Subject Matter Interest

The subject matter of interest is reliability in a broadly defined sense. For the broadly intended audience,
reliability here is used as an umbrella term to include the general expectation of stakeholders that GUCCI
will work for them. As such it includes aspects of the following:

Reliability, in its technical sense, principally that the infrastructure will perform its intended
function, in the context of the environment it was designed for, during the lifetime it was
designed for.

Robustness, principally that the infrastructure will perform its most important functions with a
minimum of variation, in the presence of stresses that are outside of its expected operating
conditions.

Resilience, principally that the infrastructure will return to performing its function after being
overcome.

Related terms that overlap the broad contour of Reliability, and that are appropriately kept in front of
mind in The Study include:

Security, principally that the infrastructure will be protected.

Survivability, principally that the infrastructure will be preserved in some minimum useful state
after being overcome.

The brief glossary found in Section 9 provides more detailed descriptions of terms.10

Therefore, this broadly defined infrastructure reliability includes the stakeholders’ expectations that it will
perform (a) ‘as intended’ during times absent of unusual stress, (b) ‘near as intended’ during times of
unanticipated stress, and (c) ‘returning to as intended’ after being overcome by stress.

The downtime experienced during and after a crisis contributes to the overall downtime for a specified
period of time that a reliability calculation may be desired for.11 Reliability has two chief accounting

10
Additional related terms include availability, dependability and integrity.

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measuring sticks: the frequency of outages and the duration of outages. As it more directly correlated with
end user “pain”, the duration – or “downtime” metric is the single most useful means of describing the
performance of a communications system. The highest reliability is achieved when disruptive events are
recovered from quickly (short duration) and the mean time between disruptive events is very long (low
frequency of events). Conversely, the lowest reliability is experienced when disruptive events have extended
times (long duration) and the mean time between disruptive events is very short (high frequency).

Figure 5. Terms on Time Continuum

The context of use:

• the time period is 24 hours per day, 7 days per week, 365 days per year
• the operating environment includes extremely harsh conditions on the bottom of the ocean floor
• at global level, such events as earthquakes, tsunamis and other catastrophes are expected events

In The Study, the concept of “unanticipated stresses” is different than what may be described in
contractual arrangements involving equipment suppliers, network operators and service providers for
specific, individual international cable systems. For example, earthquakes may be considered a rare event
for an individual system. But at a global level, such rare events are understood to be part of the world we
live in, and, given the dependency on GUCCI, something with which it needs to be prepared to operate.
Therefore the standard commercial legal arrangements made at an individual system level should not be
measured against what is expected by the broad user base, as that is not their intent, nor are they
wellsuited for such purpose. From a global infrastructure perspective, earthquakes are not that unusual;
nor are malicious acts of terrorists on infrastructure; nor is piracy; nor are cyber attacks.

11
Because outages or other crises are rare events for GUCCI, long duration periods are needed in order to develop statistically
meaningful reliability measurements; i.e. on the order of years when multiple systems are involved.

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(on previous pages)

Figure 6. Global Map of Submarine Cable Routes12

2.5.2 Geography
The scope of The Report is the expanse of the earth. Submarine cables connect six continents, and
traverse three oceans and several seas. While there are no currently deployed systems that span the Arctic
Ocean, this route is being studied.13

(a) (b) (c)

Figure 7. Inter-Continental Connectivity via Undersea Communications Cables

(a) Capacity, (b) Existing Cables, (c) Planned14

12
Used with Permission from TeleGeography.
13
Barthold, Jim, Submarine Cable to Find Northwest Passage, Suite101.com, 17 January 2010.
14
Some double counting is included for routes with multiple stops. Middles East included with African Continent in these charts.
Data provided by TeleGeography Research, 2010.

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2.5.3 Network Types

The scope includes long haul network runs. This excludes short runs such as those underwater cables
connecting small islands within a nation and those that cross rivers and lakes within a nation. Though
these smaller networks are excluded, value can still be gleaned from The Report for such applications,
particularly in the systematic review of intrinsic vulnerabilities (Section 3).

2.5.4 Infrastructure Boundaries

In addition to the cables, repeaters and branching units, the undersea communications cable infrastructure
includes the terminations points on land, which consist of some type of building structure, power, and
electronic hardware that provides the interface with the terrestrial networks (Figure 8). The infrastructure
also includes the specialized equipments and human resources needed for their maintenance – in
particular the cable repair ships and their crews.

Figure 8. Infrastructure Boundaries

2.5.5 Technology
The scope of The Report covers optical fiber submarine cables. Earlier metallic conductor cables are
excluded as those deployed are either no longer used or their bandwidth capacity is negligible in modern
networks.

2.6 The Study

The ROGUCCI process was designed with three phases that spanned approximately 2 years. The first
phase was The Study that included research, interviews, small meetings, and virtual forums. The next
phase was the Global Summit, which convened subject matter experts, stakeholders and international
policy change agents. The final phase is The Report preparation and publishing, which includes the
dispatch of twelve bold recommendations to improve the reliability of GUCCI. The objectives, unique
approach and scope are further detailed in this section.

2.6.1 Research Locations

Locations where research activities were conducted include each of the countries shown in Table 2.

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Table 2. Research Locations

Commonwealth of Australia French Republic Kingdom of Saudi Arabia

Kingdom of Belgium Federal Republic of Germany Slovak Republic

Kingdom of Bahrain Greece (Hellenic Republic) United Arab Emirates

Canada Japan United Kingdom

Republic of Estonia People’s Republic of China (incl. Hong Kong) United States of America

2.6.2 IEEE Online Forum

The Study included the use of discussion forums facilitated by the IEEE Communications Society
(ComSoc). A ROGUCCI Study online forum was established to facilitate virtual collaboration among
experts and stakeholders from around the world without the constraints of time zones, business
workweek structure or physical proximity.15 Individuals offering to contribute to The Study could request
membership to the web forum group. The online forum was used to examine the specific intrinsic
vulnerabilities of each of the infrastructure’s eight ingredients (Section 3), observed trends that can affect
the reliability of GUCCI and proposals for recommendations to improve the reliability of GUCCI.

The forum also enabled The forum became an effective

individuals to post documents nerve center for discussion, the
for recommended reading. In posting of information, and
addition, the discussion forums other updates. In fact, the
were used to vet drafts of The discussion group quickly
Report. The online forum was became one of ComSoc’s most
an experiment in that it was new popular in its newly developed
both for many of the individuals online forums space - over 100
who joined it and as a critical individuals from 6 continents
component of a global study have joined the online
and conference (Figure 9). As discussion group, and the IEEE
such, some pioneering was ROGUCCI web site has had
required to navigate through over 10,000 visits.
some of the unfamiliarity. As
with many online forums, for a The ROGUCCI online forum
given thread, there were will continue in order to
typically more observers than support the implementation and
contributors. This demon- other follow-up activities
strated that the forum had gone related to The
some way toward the goal of Recommendations.
achieving better understanding
of GUCCI.
Figure 9. ROGUCCI Online Forum

15
http://community.comsoc.org/groups/rogucci-study .

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2.7 Global Summit

The ROGUCCI Global Summit was convened to bring
together Study contributors and stakeholders as a culmination
of their ongoing collaboration to assess the reliability of the
undersea communications cable infrastructure at a global level,
the potential impacts of infrastructure failures – with financial
sector focus, and proposed recommendations for improved
global infrastructure resilience. This interactive event
culminated an eighteen month-long study among experts who
have been collaborating virtually around the world.

2.7.1 Venue
The Global Summit was hosted by the Dubai International
Financial Centre (DIFC), in the United Arab Emirates
(Figure 10). Dubai was chosen as The Summit venue
because of its prominent role as an emerging financial hub,
its recent experience with GUCCI failure and its strategic
geographic location in regard to GUCCI topology.16

The DIFC is one the world's fastest growing international

financial centers, with an aim to achieving the stature of
New York, London and Hong Kong, and to facilitate
economic development in the UAE and the region. It is
strategically located between the established markets of
Western Europe and the exploding economic growth of
East Asia.17 The DIFC is a 110-acre economic free zone
with special regulations that has been operating since 2004
and has attracted international private sector firms from
both the Middle East region and beyond. It also includes
the NASDAQ Dubai stock exchange, which opened in
2005.18 The DIFC has broad financial sector experience
and interests, with activities spanning banking, brokering,
capital markets, wealth management, reinsurance, captives
and other financial services.

This event convened a unique combination of individuals,

including world-class experts of all aspects of undersea
cable infrastructure, senior financial sector and other
stakeholders, and seasoned champions of international
policy change.
Figure 10. The Gate at the DIFC

16
Dubai and other cities in the Middle East region were affected by multiple undersea communications cable cuts that occurred
during the 12-day period of January 23 through February 3, 2008.
17
Financial institutions may apply for licenses and can be eligible for benefits such as a zero tax rate on profits, 100% foreign
ownership, no restrictions on foreign exchange or repatriation of capital, operational support and business continuity facilities.
Financial services in the DIFC are regulated to international standards by the Dubai Financial Services Authority (DFSA).
18
The stock exchange was formerly known as the Dubai International Financial Exchange or DIFX

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2.7.2 Program
The Summit program progressively advanced through a detailed review of the intrinsic vulnerabilities of
the infrastructure, the stakeholder interests and the proposed recommendations. The Summit format was
highly interactive throughout in order to optimize participants’ ability to offer insights and perspectives, as
well as to influence the consensus development process. The program climax was the final day’s Summit
Council meeting. The Summit Council included senior private and public sector representatives of each
of the 6 participating continents. The Council reviewed each of the proposed recommendations, clarified
key points of articulation and laid out a strategy for implementation.

Table 3. ROGUCCI Global Summit Program

The technical agenda included a review of the eight ingredients of ICT infrastructure. For each of the
eight ingredients, a volunteer session chair had been identified earlier from the online forums. These
chairs helped facilitate discussion on the online forums and then led discussions among subject matter
expert peers in the technical program. For each ingredient, the chairs sequentially walked through a
systematic review of the intrinsic vulnerabilities, a discussion of relevant trends, a prioritization of
concerns and a discussion of proposed recommendations. The purpose of the first part of the discussion
was to be certain that no intrinsic vulnerabilities were missed and that the analysis foundation was
complete in its coverage. The purpose of the second part was to understand the dynamics that could
increase the presence of specific intrinsic vulnerabilities. For example, the increased marine activity
associated with ocean sprawl elevates the concern related to the Hardware ingredient intrinsic vulnerability
of susceptibility to damage. The third step was to call out areas of greatest concern. This was done based
both on the insights gleaned from recent trends, and, more importantly, from the comprehensive intrinsic
vulnerability review. In this way, latent failure modes were exposed and given proper attention. It can be
said that this was a way of identifying “an unprotected cockpit door scenario on September 10th” (to make
reference to September 11, 2001 terrorist attacks). This method contrasts with most reliability and
security work, which is based primarily on reacting to observed historic analogies or to gathered
intelligence. However, such approaches can fail to sufficiently protect critical infrastructure from either
manmade or natural causes, particularly when a latent failure mode is involved. The Ingredient leaders are
listed below in Table 4.

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ROGUCCI - THE REPORT ISSUE 1, 2010

Photography by Libby Buckley

Figure 11. Summit Program Snapshots

The impact agenda included presentations from stakeholders, with special emphasis on the international
financial sector. Dr. Nasser Saidi, Chief Economist of the DIFC and Stephen Malphrus, U.S. Federal
Reserve Board Chief of Staff, presented keynote addresses. In addition, other stakeholder interests were
presented from other stakeholders: regulatory agencies and the international media. The stakeholders
emphasized the devastating impact that the loss of international communications has on their operations,
often rendering them incapable of accomplishing essential services. A special concern for the
international financial sector is the unacceptability of payload latency. Delays in message delivery on the
order of milliseconds can be a harsh competitive disadvantage. Government regulators stressed the
importance of international connectivity for government operations and nation-state security. A television
news reporter described the dependency of the international media on high bandwidth services in order to
transmit news stories.

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Table 4. Ingredient Chairs

Ingredient Chair, Affiliation
19
Environment Dr. Lionel Carter , Victoria University
20
Power Richard Freeman , Telstra

Hardware Dr. Nick Lordi, Telcordia Technologies

Software Goff Hill, GTel Consultancy

Network Peter Cornell, AT&T

Payload Stu Goldman, Bell Labs

Human John Harrison, LanditD

ASPR (Policy) Mick Green, ICPC and BT

The Recommendation agenda consisted of a review of the proposed Recommendations by the

ROGUCCI Global Summit Council. The Council was formed by two representatives of the six
continents and included Dr. Curtis Siller, IEEE Communications Society President Emeritus, and Global
Summit General Chairman, Karl Rauscher. The EastWest Institute Founder and President, John Mroz,
served as the Council Chairman. Discussion included the important
aspects of problem definition and background, required commitments,
benefits if successful, alternatives and their consequences, suggested next
steps and measures of success. As most of The Recommendations
required ‘outside of the industry’ policy influence, the support of proven
international policy change experience was essential to this final part of the
program. For each of the Twelve Recommendations that emerged, a path
forward was planned with the support of the technical and stakeholder Photography by Libby Buckley

communities in the room.

John Mroz and Dr. Curtis Siller

Figure 12.

2.7.3 Cable Ship Tour

In order to provide those less familiar with the industry with the opportunity for first hand experience
with some of its critical equipment, a tour of a special cable vessel was an integral part of the program. A
tour was arranged and hosted by E-marine of the cable ship Etisalat from its cable fleet. Of interest to the
participants were the ship’s special dynamic positioning system, the holding bays for the spare cable and
the equipment and procedures used to lay and retrieve cable.21 Also of interest was the fact that this
particular ship and crew played a critical role in the repair of the cables from the high profile multiple

19
Dr. Carter participated via teleconference, utilizing undersea communications cable infrastructure form New Zealand.
20
While supporting the online forum discussions, Mr. Freeman was represented by Richard Krock (Bell Labs) during the Summit.
21
Cable ships are highly specialized seafaring vessels that can vary widely in their dimensions and performance capabilities.
The CS Etisalat was built to order by M/s. Masa Shipyard, Helsinki in 1990. Classified as a cable layer by the Lloyd’s Register,
the ship has a gross tonnage of 2221 with a cable uplift capacity of 700 tons and a speed of 13 knots with an endurance of 35
days. Its overall length is 74.5 meters and its maximum speed is 13 knots. It can accommodate 32 people.

50
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cable cut crisis that had occurred the previous year.22 The crew and vessel had braved 14-foot waves in
order to act urgently in repairing damaged cables that had left the region with severely degraded
connectivity.23

Figure 13. C.S. Eitsalat

Photography by Libby Buckley

Figure 14. Tour of C.S. Etisalat

22
Etisalat Management Recognizes Bravery of E-Marine Cable Repair Crews - E-Marine Heroes Successfully Restore Internet
Connection to the Gulf, www.etisalat.ae, 9 March 2008.
23
“This was an extremely difficult period for the region’s telecommunications industry. The cuts were extremely serious as
many of the Gulf countries rely on submarine cables to provide access to international markets and Internet content. Accordingly,
telephone and Internet services were seriously degraded.” Omar Bin Kalban, CEO & Managing Director of E-marine PJSC, Ibid.

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2.7.4 Participant Assessment

The Summit succeeded in raising critical stakeholder awareness, formulating actionable Recommendations,
and prompting numerous requests for briefings. The twelve consensus Recommendations, if
implemented, will improve the reliability of the global infrastructure. In addition, the individuals who
took part in it rated The Summit as an overwhelming success (Figure 16).

Figure 15. Some of The Summit Participants

An electronic audience polling system was used to enhance the ability to gauge Summit participant
sentiments in real-time. The polling system was used throughout the event to track perspectives. At the
conclusion of The Summit program, the audience was polled to gauge overall assessment of value,
commitment and interest in the event, process and future steps. As shown the Figure 16, 92% valued
their participation as “time well spent,” 91% expressed commitment to participating in follow-up activities,
90% want to see The Summit repeated, and 97% indicated that The Summit created a desire for more
effort in this area.24

Discreet feedback was also sought and captured. Several points were stressed. These include expressed
appreciation for the leadership provided by the ROGUCCI process in taking on a problem that was
outside of the industry’s ability to solve alone. One benefit that was underscored was the need filled by
the ROGUCCI process in looking at the infrastructure at a global level. Other positive feedback centered
around the value of effectively integrating the diverse disciplines and perspectives of the communications
industry, stakeholders and international policy change agents. Still others expressed gratitude for the
broad span of perspectives, which encompassed technical experts (such as those with manufacturing
functions, or operational responsibilities for networks and cable ships) and senior executive leadership
(e.g., CEOs and other decision makers). Other comments ascribed merit to the venue selection for its
relevance as a financial sector stakeholder and for its historical significance. Finally, the most heartfelt
feedback was directed toward the sense of cooperation that was achieved and the drive to commitment
for breakthroughs in the current barriers to elevate the reliability of the global infrastructure.

Feedback was also provided in areas to strengthen the ROGUCCI process. First, participants recognized
the need for effective engagement between existing, related fora and the ROGUCCI process. The process
had engaged key international groups that deal with some aspects of undersea cable infrastructure.25
However, as breakthroughs are pursued with the implementation of ROGUCCI Recommendations,
effective engagement with these and other fora, as appropriate, will be important. As described in some
of The Recommendations, the best role for these and other groups is still to be determined. They can
either make adjustments to their missions and embrace additional responsibilities, or remain on their
current course. In either case, effective complimentary relationships should be nurtured. Another
opportunity to strengthen the ROGUCCI process is to provide more clarity about the continuity of the
effort going forward. It is understood that as this is a new process there is a need to remain flexible.

24
Note that it was not the intention of the ROGUCCI process to create an ongoing event. The question regarding future annual
events was submitted from participants, who requested that the level of interest be assessed. Since the objectives of the
ROGUCCI process are focused on having a positive impact on the world’s critical infrastructure, flexibility will be maintained and
the most appropriate follow-up activities will be pursued.
25
Engagement or participation included the Financial Services Sector Coordinating Council (FSSCC), International Cable
Protection Committee (ICPC), SubOptic Conference, the IEEE Oceanic Engineering Society as well as several nation-state level
initiatives.

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However, posting next steps and other follow-up materials on the ROGUCCI web site (www.ieee-
rogucci.org) can be very helpful. A third area for improvement was one expressed for the whole industry,
which needs to continue to nurture private sector-led initiatives that are facilitating collaboration with an
aim to improving the reliability of the global infrastructure.

Figure 16. Summit Participant Assessment

2.7.4 Recognized Historic Event by Porthcurno Telegraph Museum

The ROGUCCI Global Summit was recognized as an historic event by the Porthcurno Telegraph
Museum of Cornwall, U.K. The award–winning museum is dedicated to preserving the history of
international undersea communications cables and is located at the site of a landing point of one of the
first international cables.26

An historic note from the Museum that commemorates the ROGUCCI Global Summit is included in the
front matter for The Report. The note reads, in part:

26
In 1870, Porthcurno began its life as an important center of international communications. It was in this year that a chain of
telegraph cables linking Britain with India was completed. Porthcurno was chosen as the landing point for the British end of this
cable link. The company that laid the cable into Porthcurno was the Falmouth Gibraltar and Malta Telegraph Company, founded
by John Pender in 1869 and one of four companies established to lay the cables in the 'chain' linking Britain and India.
www.porthcurno.org.uk

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There are only a few moments in history that capture a key

turning point - Not just a decisive moment for an industry
or technology but a shift to a greater awareness of our
global communities’ dependence on a hidden
infrastructure. The ROGUCCI Global Summit in the
autumn of 2009 will turn out to be such an event.

Porthcurno Telegraph Museum seized the opportunity to

capture this event for future generations, to allow them to
look back and review the details of a time when world
class experts, stakeholders and champions of
international policy change came together to share
research after a yearlong study. We have submitted into
our archives a time capsule of The Summit- including
presentations, photographs and audio recordings which
27
will be closed for 30 years but held for posterity.

Museum Director Libby Buckley, who served as the curator of the ROGUCCI Global Summit, made
extensive photography and audio recordings. She also provided a well-received presentation on the
history of the undersea communications cable industry.

2.8 Contributors 28

The ROGUCCI process relied upon the expertise and experience of world-class experts, and industry and
government leaders from literally around the world. Engagements with these individuals took various
forms, including interviews, small and large meetings, telephone consultations, online forum discussions,
briefings and the Global Summit. Table 5 provides a summary of the many organizations that supported
this effort. The degree of support varied widely - from brief consultations with just one person on a
single important question or participation in the online forum, to efforts that involved a team of people
who took on extensive research, analysis and championing of issues. The number of people engaged
exceeded 300. The individuals and organizations that contributed to The Study have served an important
cause for the benefit of people around the world.29

27
Buckley, Libby, ROGUCCI Global Summit, Dubai 2009 Historical Note, Porthcurno Telegraph Museum, Cornwall, U.K.
February 2010.
28
Additional recognition is provided in Section 6, Acknowledgements.
29
It should not be construed that the contributing organizations or individuals agree with every aspect of The Report.

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Table 5. ROGUCCI Study Contributors

Contributing Organization Country
2Connect Bahrain
ABC News International
Agora Cyber Charter School U.S.
Alcatel-Lucent Egypt, France, Saudi Arabia, U.K.
Alkhorayef Group of Companies Saudi Arabia
ANACOM Portugal
Associated Chambers of Commerce and Industry of India (ASSOCHAM) India
Assured Networks U.S.
AT&T U.S.
Attorney General's Department Australia
Australia-Japan Cable Australia
Batelco Bahrain
Bell Labs ( Alcatel-Lucent) U.S.
BITS Financial Services Roundtable U.S.
Board of Governors, Federal Reserve System U.S.
Booz & Company Italy
BPI TelcoData U.S.
BT U.K.
Cable & Wireless U.K.
Caldwell Marine International U.S.
Central Bank of the U.A.E. U.A.E.
Chairman, Joint Chiefs of Staff, Military (ret.) Pakistan
China Reform Forum China
China Telecom China
China Unicom China
Cisco ME Region
Datawave U.K.
David Ross Group U.S.
Detica U.S.
Digicom U.S.
Dubai Financial Services Authority (DFSA) U.A.E.
Dubai International Financial Centre (DIFC) U.A.E.
Dubai School of Government U.A.E.
E-marine PJSC U.A.E.
EastWest Institute Belgium, Russia, U.S.
Enginnovation U.S.
European Commission, Information Society and Media Directorate
General EU
European Network and Information Security Agency (ENISA) EU
Financial Services Sector Coordinating Council (FSSCC) U.S.
Foreign Secretary (fmr.) India
Furgo Offshore Surveys U.S.
Gateway Gulf Kingdom of Bahrain

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General Cable Company Germany

Go, Ethihad Atheeb Telecom Company Kingdom of Saudi Arabia
Google U.K.
GTel Consultancy U.K.
Harvard Kennedy School of Government U.S.
Hibernia Atlantic Ireland
Huawei Marine Networks China
Huawei Technologies Co., Ltd. China
IABG mbH Germany
IEEE Communications Society International
IEEE Oceanic Engineering Society International
Information Assurance Advisory U.S.
Information Assurance and Cyber Forensics U.A.E.
Institute of Electronics, Information and Communications Engineers
(IEICE) Japan
International Cable Protection Committee (ICPC) U.K., International
International Mulitlateral Partnership Against Cyber Threats (IMPACT) Malaysia
John Tibbles Consulting U.K.
JPMorganChase U.S.
KDDI Japan
Kogakuin University Japan
Korea Communications Commission Republic of Korea
Landitd U.K.
Level3 U.K.
Lucent Government Innovations U.G.
Massachusetts Institute of Technology (MIT) U.S.
Middle East Network Operations Group (MENOG) ME Region
Ministry of Industry and Information Technology China
National Center for Security and Crisis Management Jordan
National Defense University U.S.
National Emergency and Crisis Management Authority U.A.E.
New Jersey Institute of Technology (NJIT) U.S.
Nortel Canada
NTT Communications Japan
NYSE Technologies Ltd U.K.
Office of The Telecommunications Authority Hong Kong
Pennsylvania State University U.S.
Pioneering Consulting U.S.
Porthcurno Telegraph Museum U.K.
Qualitynet Kuwait
Qwest Communications U.S.
REACH Hong Kong
Reliance Globalcom India
Renesys U.S.
Renmin University of China China
Rockbury Media International U.K.

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Russell White Marine Ltd. U.K.

Sahara Net Saudi Arabia
Science Applications International Corporation (SAIC) U.S.
Secure 1st U.A.E.
Southern Cross Cable Networks Australia
Tarasul Telecom Kuwait
TE Data Egypt
Telchemy U.S.
Telcordia Technologies U.S.
TELE Greenland International Denmark
Telecom Italia Sparkle Italy
Telecommunications Regulatory Authority U.A.E.
Telecommunications Regulatory Authority Bahrain
Telefonica Int'l Wholesale Svcs. Uruguay
TeleGeography Research Slovakia
Telenor Norway
Trusted Information Sharing Network Australia
Tyco Telecommunications U.S.
United Arab Emirates University U.A.E.
University of Arkansas at Little Rock U.S.
University of Ottawa Canada
Verizon U.S.
Victoria University of Wellington New Zealand
Vodafone Germany
Westpac Australia

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Figure 17. ROGUCCI Global Summit Participants, The Gate, DIFC.

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3. ANALYSIS of UNDERSEA COMMUNICATIONS CABLE

INFRASTRUCTURE
Undersea cable systems are unique among communications systems fundamentally in that they traverse great
distances and they operate under water. However, the building block ingredients of undersea communications
systems are the same as other communications systems. The Eight Ingredient Framework of Communications
Infrastructure (or 8i Framework) 30 provides a useful way to understand, discuss and manage undersea
communications systems and their intrinsic vulnerabilities (Figure 18).

The 8i Framework is a systematic and comprehensive framework that a) consists of

the ingredients that make up communications infrastructure, b) includes all of these
ingredients, c) specifies the 8 ingredients of environment, power, hardware, software,
network, payload, ASPR (Agreements, Standards Policy and Regulations;
abbreviated as Policy) and human. This framework is used for understanding and
mastering vulnerabilities, identifying disciplines, decomposing attributes, preparing for
new technologies, and other studies that support network, security, and emergency
31
preparedness.

In order for a threat to have an impact, it must exercise an intrinsic vulnerability.32 A key advantage of
using the 8i Framework is that each of the ingredients has a finite set of intrinsic vulnerabilities. Thus,
these intrinsic vulnerabilities can be addressed independently of specific threat knowledge. Further, since
the intrinsic vulnerabilities are finite, using an approach based on them can provide the assurance of
comprehensive coverage that is not achievable by a threat-based approach, where threats tend to be
practically infinite because of countless permutations. Since most government and industry attention,
energy and resources are currently applied to addressing threats, the future use of the 8i approach is very
promising, as it can provide more economical and effective means of promoting high reliability and
security of information and communications infrastructure. In addition, it can bring attention to areas
that otherwise might not receive needed notice, but that can have devastating effects.

Figure 18. 8i Framework

This section reviews each of the ingredients with commentary specific to the undersea communications
systems.

30
Rauscher, Karl. F., Protecting Communications Infrastructure, Bell Labs Technical Journal Homeland Security Special Issue,
Volume 9, Number 2, 2004; Proceedings of 2001 IEEE Communications Society Technical Committee Communications Quality
& Reliability (CQR) International Workshop, www.comsoc.org/~cqr .
31
ATIS Telecom Glossary, www.atis.org .
32
The communications industry has defined a threat as “anything with the potential to damage or compromise the
communications infrastructure or some portion of it.” The industry has defined a vulnerability as “a characteristic of any aspect
of the communications infrastructure that renders it, or some portion of it, susceptible to damage or compromise.” FCC NRIC VI
Homeland Security Physical Security Final Report, December 2003.

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3.1 Environment

3.1.1 Function
The Environment ingredient of communications infrastructure includes buildings, trenches where cables
are buried, space where satellites orbit, locations of microwave towers and cell sites, and the floor of the
ocean. The Environment is an essential ingredient of undersea cable systems, providing the location for
the physical equipment. Because of the harsh conditions of undersea environments, undersea
communications environments are some of the most challenging across all of the broadly defined
information and communications industry. There are three types of environments for undersea
communications cable systems:

In Air - Landing Stations

The beginning and ending points of submarine cable systems are landing stations. Landing stations are
typically buildings with a controlled environment similar to that of a telephone central office or computer
data center. The two primary functions of the buildings are to serve as a termination point for the
submarine system and to provide a gateway to landline communications networks. Sometimes these
functions are accomplished with two separate buildings at separate locations. In these buildings, air
quality is critical. Thus, temperature, humidity and dust are carefully controlled in order to ensure that the
electronic hardware has the proper environment in which to operate and fire control systems are designed
to avoid damage due to fire extinguishing systems. These facilities also allow personnel to access
hardware to make changes such as system upgrades and repairs.

In Earth - Buried Cable

Between landing stations and the deep sea is a transition environment. In this transition environment, the
communications cable segments are buried either directly or within duct from the landing station to the
beach. Cables are buried under the earth in order to protect them from being damaged. Damage can
occur due to weather, e.g., induced erosion, subsidence, or lightning in the land section. Damage can
occur on the beach due to storm induced cable exposure resulting in cable displacement and abrasion, and
from vehicles, people, animals and debris. In water depths of 1000-1500m, cables are buried underneath
the sea floor, wherever practicable, as the prime protection against fishing activity (including trawlers),
boat anchors, sea creatures such as sharks, and debris being moved across the ocean floor by currents or
by current induced abrasion.

In Water - Undersea
This is the predominant environment for cable systems. It is also the most unique and challenging
because of the oceans’ extent, wide range of current, temperature and pressure conditions and difficult
access. In waters deeper than 1000-1500m, the cables are typically laid on the ocean floor. That depth
range is beyond the present limit of trawl fishing – a major cause of cable faults A unique challenge of
this environment is the high pressure.

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3.1.2 Intrinsic Vulnerabilities

The following is a list of intrinsic vulnerabilities of the Environment ingredient.

 identifiable
 accessible
 exposed to elements
 dependence on other infrastructures
 contaminate-able
 subject to surveillance
 continuously being altered
 remotely managed

The landing station environment is heavily dependent on the people who maintain it and have access to it.
Thus the Human ingredient is one that has many interactions with the Environment. In addition, the
Environment is dependent on Power to operate equipment. When multiple parties share a location there
will be expectations regarding the behavior of other people and systems, and thus the Policy ingredient
plays a key role.

3.1.3 Significant Trends

There are ten significant trends that relate to the Environment ingredient.

 1. The identification of cable route environments is becoming easier with the proliferation of
information on the Internet.

 2. Ocean sprawl is an emerging phenomenon as human activity in the marine environment

increases. This activity includes the rapidly developing renewable energy schemes (wind turbines,
wave power, tidal power), as well as increased exploration and exploitation of hydrocarbon
resources in deeper waters beyond the continental shelf.

 3. Aquaculture development is another trend as offshore fish farming is producing 50% of

consumable fish as of 2009. “Wild” fisheries are also changing in response to over-exploitation
of stocks and varying ocean conditions amongst other factors. This has seen some fisheries
extend into more distant and deeper waters although extended fishing ranges may be curtailed by
the price of fuel. Such trends are significant because as noted above, fishing activities are a major
cause of cable faults.

 4. Interest in deep-sea mining is increasing, with the focus on polymetallic (copper, iron,
manganese, nickel and zinc) nodules, and metallic sulfides around seamounts and hydrothermal
vents. Most of this mining interest is within the Pacific Ocean. The International Seabed
Authority (ISA) organizes and controls activities relating to mineral resources on the seabed and
ocean floor beyond national jurisdiction.

 5. As onshore resources become scarce, there is an increase in coastal mining activity especially
for sand and gravel for aggregates.

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 6. A new type of undersea structure is the cabled ocean observatory, which is a science-based
monitoring and experimental site designed to evaluate many aspects of the ocean and seabed in
order to learn how the marine environment “ticks” and changes with time.33

 7. There is an increase in the number and size of ships. This is significant because anchors have
been identified as the second major cause of cable faults. This trend has been accompanied by
changes in shipping routes to meet the needs of developing economies such as China and India. 34

 8. There is increased use of ship positioning technology, which enables new, remote vessel
surveillance with Internet access.35 36

 9. There is an increased trend in the establishment of marine protected areas in territorial and
international waters.37 38

 10. The oceans’ responses to present and projected changes in climate have the potential to
affect the undersea cable network through intensification of natural hazards relating to [a] rising
sea level, [b] changes in the frequency and intensity of storms that will influence wave and current
effects on cables and [c] rainfall events that can increase floods to the point where river discharge
forms turbidity currents with the potential to damage cables.

In summary, undersea communications cable stakeholders should be aware of the potential impact of the
trends associated with the undersea cable environment and they should actively support existing industry
efforts of continuous innovation and improvement that could help in this area. In addition, an area for
consideration is a proposal for a study that addresses how changes to the ocean chemistry could degrade
the current projected lifespan of cables already in place or about to be laid.

33
The NEPTUNE observatory off Vancouver Island, for example, is based on a 800 km fiber optic cable system that provides
power for submarine equipment and a means to transfer environmental data back to shore in real time.
34
In 2007 there were 43,000 shipping units exceeding 1 billion dead weight tons compared to in 2005 where there were 40,000
shipping units exceeding 880 million tons, Institute of Shipping, Economics and Logistics.
35
Universal Automatic Identification System (AIS) is a short range application used by ships and Vessel Tracking Systems (VTS)
that supports the transfer of information between ships and land-based monitoring stations such as unique identification,
location, speed and course.
36
It is interesting to note that a ship dragging an anchor, which could cause multiple cable cuts, can be detected with this
technology, but if the communication to remote monitoring center relies upon a damaged cable, the transport of the detection
information may be impaired.
37
Australia, for instance, has extended protection of the Coral Sea region to cover an area of almost 1 million square kilometers:
likewise substantial areas of the North Atlantic have been identified for protection.
38
U.S. President George W. Bush established nearly 200,000 square miles (518,000 square kilometers) as a protected marine
environment area. January 2009.

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3.2 Power

3.2.1 Function
The Power ingredient is vital to the operation of any communications infrastructure. Without power,
communications systems fail to operate.

During normal operation, power systems serve in the critical role of

interfacing with commercial electric power to provide high quality
electric energy for highly specialized electronic equipment. During
extreme events, whether they are natural in origin – such as
hurricanes and ice storms, or human in origin – such as power
blackouts and terrorist attacks, power systems are essential. Without
power, communications equipment fails to operate and
39
communications services disappear.

Power includes four basic components: the distribution plant, the battery plant, the generator plant, and
the grounding system.

The designs often implement triplication to achieve adequate redundancy of all components in the power
system and the ability to switch any power sub-system in or out. In addition, there is a need to ensure that
maintenance practices are well designed and fully implemented. These often include practices such as
keeping fuel supplies topped up and test running generators periodically.

In addition to power needed to support the terminating electronics at landing stations, repeater
regenerators and optical amplifiers require power. This is achieved by actually using the environment –
the seawater – as a conductor to complete the circuit.40

Given the great lengths of submarine cables, the power equipment used in these applications has some
special considerations. Cables are typically powered from both ends, with opposite charges at either
termination. The repeaters are powered by the potential across them. The current completes its circuit by
passing through the metallic core of the cable and through the surrounding seawater. When the protective
barrier around the metallic core is damaged such that its insulation properties are compromised, a short
circuit occurs. The location of the short becomes the new virtual earth. However, the system can
continue to operate as long as the power feed equipment from either end can provide enough voltage to
support the required potential across each repeater. Otherwise the communications signals will reach the
repeater and, being too weak because they cannot be amplified at the unpowered repeater, fail to progress
any further. If a second loss of insulation occurs along the cable, the system will fail to operate, as there
will be no potential between the two virtual earth points. For this reason the immediate repair of shunt
faults is imperative.

39
Krock, R., Rauscher, K., Runyon, J., Hayden, P., Intrinsic Vulnerabilities of the Power Systems Supporting Communication
Networks and Expert Strategies for Defense, Bell Labs, 2007.
40
The electrical conductivity of seawater has a significant dependence on temperature, a lesser dependence on salinity, and a
relatively negligible dependence on pressure. Seawater conductivity is generally measured at 4.8 [S/m]. This compares to 63 x
6 -14
10 [S/m] for silver, the best known metallic conductor and ~10 [S/m] for air.

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3.2.2 Intrinsic Vulnerabilities

The following is a list of intrinsic vulnerabilities of the Power ingredient.

 distribution plant - loss of connectivity

 distribution plant - loss of potential41
 battery plant - critical fuel characteristics
 battery plant - load limitations
 battery plant - interface limitations
 battery plant - chemical damage
 battery plant - aging
 battery plant - physical damage
 generator plant- critical fuel characteristics
 generator plant - load limitations
 generator plant - wear
 generator plant - aging
 generator plant - physical damage
 grounding – loss of connectivity

The Power ingredient is also heavily impacted by other infrastructures, such as commercial power and
transportation, and by other ingredients of the communications system, such as humans, environment,
and policy.

3.2.3 Significant Trends

There are four significant trends that relate to the Power ingredient.

 1. Submarine cable infrastructure is being extended into new areas as economies develop.
This brings the risk that, for economic reasons, insufficient redundancy is built into the
power supply system.

 2. More developing regions are able to provide stable commercial power.

 3. In some instances cost savings are driving less redundancy in power design than has
previously been engineered.

 4. The ocean is becoming the source of numerous alternative energy types.

41
Earth potentials can be a serious threat to cable systems in areas of high magnetic-field activity. Root, H.G., Earth-Current
Effects on Communication-Cable Power Subsystems, Electromagnetic Compatibility, IEEE Transactions, Issue 2, May 1979.

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3.3 Hardware

3.3.1 Function
The Hardware ingredient of communications infrastructure includes equipment frames, semiconductor
chips, electronic circuit packs and cards, and metallic and fiber optic transmission cables. While much of
the hardware is similar to landline applications, in undersea communications systems, hardware
components of particular interest are the special purpose fiber cables and inline undersea repeaters.

Undersea fiber cable construction

Modern undersea communications cables are based on fiber optic technology. Depending on the
application, one of several types of cables may be used.42 These include deep-water lightweight cables for
depths beyond 8.5 km, abrasion-protected cables where difficult terrain or sea floor currents are an issue,
deep-water armored cables for difficult terrains or sea floor currents at depths beyond 6km, light single-
armored cable for shallow water applications up to 2km where the cable will be buried, heavy singled-
armored cables for shallow water applications less than 1.5km, light double-armored cables for
applications where the cable typically in depths less than 0.5km that include both buried and unburied
sections, heavy double-armored cables in very shallow water less than 50m where anchors may be present,
and special-purpose shallow-water cables for applications where fishing is done with trawlers and where
burial is not an option. A typical undersea fiber cable construction is shown in Figure 19. The three
primary challenges being addressed in undersea fiber cable construction are (1) keeping sea water out of
the enclosure under very high pressure conditions, (2) corrosion of the enclosure, and (3) combinations of
the two. For this reason, special measures are used in the construction. These include high-density
polyethylene to provide an electrical insulation and to prevent seawater penetration, high tensile steel wires
to provide strength and special metals, and hermetically sealed copper tubing to protect the optical fibers
from the very small hydrogen molecule

Oona
Räisänen

Photography by Oona Räisänen

43
Figure 19. Example of Undersea Communications Cable Construction

42
Chesnoy, Jose, Undersea Fiber Communications Systems, Academic Press, London, 2002. pp. 457-461.
43
diagram from www.wikipedia.com .

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3.3.2 Intrinsic Vulnerabilities

The following is a list of intrinsic vulnerabilities of the Hardware ingredient.

 logical design
 physical damage
 temperature range dependency
 field force influence – electric, electromagnetic
 adverse radiological interaction
 chemical contamination
 aging

The wet plant is more critical than the dry plant in terms of reliability because the MTTR is greater.
Typical MTTR values give around 2 weeks for the wet plant repair instead of 2 hours for the dry plant.
From a reliability point of view, this is why the failure rate for laser pumps used within the repeaters is a
sensitive issue for the system. For example, typical failure rates for amplifiers in terrestrial networks are
within 1000 to 10000 FIT44 compared to submarine amplifiers, which are within 10 to 100 FIT (around 2
orders of magnitude lower).

Designing ultra reliable submarine systems means that the probability of a wear-out failure occurring
during the system life must be near non-existent and the probability of random failure must be minimized
as much as possible.

Repeaters are critical equipment as they contain electronic, optical and opto-electronic components. In
addition to that, one must keep in mind that any internal damage, whatever the cause is, may directly
impact the transmission quality. Consequently, careful precautions must be taken to prevent and reduce
the risk of failure. In particular, an optical failure occurring on a specific fiber must not affect the system
performances of the other fibers. The tests required before and during the cable installation are detailed in
[ITU-T G.976].

Undersea networks require reliable and robust fiber optic systems to avoid costly repairs in the wet plant.
Moreover, considering that technologies may change during the life of the system, a maintenance scheme
should be established at the beginning of system life to ensure timely repairs during the contractual system
lifetime.

Failures occurring during the system life may be due to internal faults (shunt fault, fiber loss increase,
repeater failures, card failures, etc.) or external aggressions (e.g., anchors and fishing activities for wet plant
and mis-operation for dry plant).

3.3.3 Significant Trends

There are eight significant trends that relate to the Hardware ingredient.

 1. Undersea cable systems are typically designed for a 25 year life time.45 However, as new
systems come on-line with much greater capacity, older systems are being retired prior to 25 years.

44
The Failures In Time (FIT) rate of a device is the number of failures that can be expected in one billion device-hours of
operation (once in about 114,155 years).
45
As specified in ITU-T Recommendation G.977. The usual requirement for system reliability is less than three failures
requiring cable ship intervention during the system's designed lifetime.

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Thus, systems are not experiencing the increased failure rate due to aging towards the end of a
system life.

 2. In recent years, it appears that submarine cable faults due to components have been
dramatically decreasing. Available data suggests that they now account for less than 10% of all
faults. 46 47 (Figure 20)

 3. Advances in laser and Dense Wave Division Multiplexing (DWDM) technology have greatly
increased the volume of payload throughput in new, and already deployed, fiber cables. Upgrades
can be made to some existing systems that dramatically increase their potential useful life span.

 4. Hardware components tend to continue to be unique for a given cable system.

 5. There have been advances in introducing standardized equipment used in cable repair activities.

 6. The repair and maintenance of undersea cables continues to rely on very specialized ships.
The availability of these vessels remains limited, the significance being that this limitation affects
the time to repair and the number of simultaneous repairs that can be performed.

 7. A limiting factor for individual undersea cable capacity continues to be the combined weight
of cable and repeaters.48

 8. While the broadly defined information and communications technology industry is

experiencing economic devolution, the undersea communications cable infrastructure remains a
long term investment.

Figure 20. Overall Causes of Fiber Optic Cable Failures, 200449

46
Worldwide Trends in Submarine Cable Systems, http://www.scig.net/Section11a.pdf ; fault data from ICPC, was analyzed for
a period of 15 years.
47
Trends in Submarine Cable System Faults”, Tyco and Alcatel-Lucent, http://www.suboptic.org/Uploads/Files/WeA1.2.pdf
48
More fibers would require more repeater components and thus heavier repeater chassis. The tensile strength of the cables
limits the weight that can be hoisted during repairs.
49
Worldwide Trends in Submarine Cable Systems, http://www.scig.net/Section11a.pdf .

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Figure 21. Overall Causes of Fiber Optic Cable Failure, 2007

Possible reasons for the decrease in component faults include:

Low failure rates are obtained through the use of heavily screened components, close control of raw
materials, robust and simple design, careful manufacturing process and thorough quality control.

Redundant configurations are generally used to achieve the required reliability and to reduce the failure
rate of the subsystems accordingly. For example, redundant pump laser configurations are usually
employed to ensure that the amplifier reliability target is met.

The industry follows specifications developed in the mid-1990s. 50 These standards have also been
updated in the last few years, and include cable parameters (mechanical and electrical), optical repeater
parameters (power, jitter, amplification,), mechanical repeater parameters (housing, corrosion protection,
insulation, etc), cable joint parameters (optical and mechanical parameters such as splice loss, mechanical
and tensile strength) and system design characteristics.

50
ITU-T G.971 to G.978 series of standards; These standards include: [ITU-T G.971] ITU-T Recommendation G.971 (2007),
General features of optical fibre submarine cable systems, [ITU-T G.972] ITU-T Recommendation G.972 (2004), Definition of
terms relevant to optical fibre submarine cable systems, [ITU-T G.973] ITU-T Recommendation G.973 (2007), Characteristics of
repeaterless optical fibre submarine cable systems, [ITU-T G.974] ITU-T Recommendation G.974 (2007), Characteristics of
regenerative optical fibre submarine cable systems, [ITU-T G.975] ITU-T Recommendation G.975 (2000), Forward error
correction for submarine systems, [ITU-T G.975.1] ITU-T Recommendation G.975.1 (2004), Forward error correction for high
bit-rate DWDM submarine systems, [ITU-T G.976] ITU-T Recommendation G.976 (2007), Test methods applicable to optical
fibre submarine cable systems, [ITU-T G.977] ITU-T Recommendation G.977 (2006), Characteristics of optically amplified
optical fibre submarine cable systems, [ITU-T G.978] ITU-T Recommendation G.978 (2006), Characteristics of optical fibre
submarine cables, [ITU-T G.Sup.39] ITU-T G-series Recommendations – Supplement 39 (2006), Optical system design and
engineering considerations.

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Figure 22. Typical failure's rate behavior during the life of a system51

In summary, equipment suppliers of cable and other system components should continue to follow and
adhere to the international standards for submarine cable systems. Industry experts should continue to
support ongoing standards activities to promote continuous improvement in reliability performance of
undersea cable components.52 In addition, undersea cable system procurements should continue to
include reliability and design specifications included in international standards.

Like everything else man-made, a given cable infrastructure has a finite life. Given that many fiber optic
cables are reaching their projected end of life, additional consideration should be given to managing the
end of life period. This can include establishing a range of probable life spans along with identifying the
limiting causes and the end of life failure modes.

51
As specified in ITU T G-series Recommendations – Supplement 41.
52
For example, ITU Study Group 15, (Optical transport networks and access network infrastructures) is currently investigating
the characteristics of optical fiber submarine cable systems. ITU is specifically asking for comments on: Specifications of
terminal equipment and optical fiber submarine cables in optical fiber repeatered submarine cable systems with various optical
amplifiers such as Erbium Doped Fiber Amplifiers (EDFAs) and Raman amplifiers; Specifications of terminal equipment and
optical fiber submarine cables in optical fiber repeaterless submarine cable systems, including systems with remotely pumped
optical amplifiers; Specifications of test methods concerning the terminal equipment, optical fiber submarine cables and other
equipment relevant to the submarine cable systems; Specifications of forward error correction (FEC) for optical fiber submarine
cable systems.

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3.4 Software

3.4.1 Function
The Software ingredient of communications infrastructure includes the programs that provide both the
functionality and the fault management capabilities. Software includes the development and test loads,
version control and management, chain of control deliver, and stored software releases. Relative to the
other ingredients, the function of software in undersea cable systems is not unique.

3.4.2 Intrinsic Vulnerabilities

The following is a list of intrinsic vulnerabilities of the Software ingredient.

 ability to control (render a system in an undesirable state, e.g., confused, busy)

 mutability of deployed code (patches)
 accessibility (during development, distribution, rootkit to control kernal/core)
 logical errors
 complexity of programs
 discoverability of intelligence (reverse engineer, exploitable code disclosure)
 incompatibility (with hardware, with other software)

3.4.3 Significant Trends

There are five significant trends that relate to the Software ingredient.

 1. Software will have more control in future networks (e.g., mesh topologies).

 2. Most other areas of the ICT industry rely increasingly on outsourcing software development.
The undersea cable system software appears to be fighting that trend.

 3. Software is expected to have increased sophistication for handling real-time sensitive

applications in the context of non-real-time sensitive applications that are heavy users of
bandwidth.

 4. Software must increasingly be capable of processing complex combinations of services and co-
mingled data and control messages.

 5. Software will be upgradeable to extend the capabilities and life of systems.

In summary, aggressive testing of software is warranted to ensure not only that it works as expected, but
that it correctly handles conditions at the boundary values and beyond. Exception handling is particularly
important for a system that “can’t” go down. Each node should be able to protect itself from a failure of
the other nodes, and from all possible stimuli regardless of how unlikely or illogical.

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3.5 Network

3.5.1 Function
The Network ingredient of communications infrastructure includes the configuration of nodes and their
interconnection; network topologies and architectures; various types of networks, technology,
synchronization, redundancy, and physical and logical diversity; and network design, operation and
maintenance.

3.5.2 Intrinsic Vulnerabilities

The following is a list of intrinsic vulnerabilities of the Network ingredient.

 capacity limits
 points of concentration (congestion)
 points or modes of failure
 complexity
 dependence on synchronization
 interconnection (interoperability, interdependence, conflict)
 uniqueness of mated pairs
 need for upgrades and new technology
 automated control (*via software)
 accessibility (air, space or metallic or fiber)
 border crossing exposures

3.5.3 Significant Trends

There are five significant trends that relate to the Network ingredient.

 1. There is increasing network capacity being delivered with status quo physical route diversity:
There is substantial growth in capacity being made available, however it is typically not being
deployed with proportionate physical diversity – most notably due to the same landing points
being used or routes tracing the same geographic “choke points”. The significance is that
stakeholder dependency on undersea cables is increasing, which exposes them to greater negative
impact when a system failure occurs.

 2. There is new undersea cable connectivity in global regions of emerging economic growth.

 3. There is a parallel evolution path with generic optical networks advances such that undersea
network software will likely track closely with advances in terrestrial networks.

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 4. There is a move by network operators toward mesh topologies, based on non-ring protected
wavelengths which creates new levels of economic, technical and service complexity and risk. But
the economics are too attractive to the network operators to ignore.

 5. There is a trend for nation-states to establish corridors for cable routes. These corridors
present a trade-off of the disadvantage of concentrating cables into a single point of failure, with
the advantages of a designated protection zone for cables with the potential for more effective
enforcement of restrictions on anchoring and trawling.

In summary, better international cooperation and coordination is needed to create more alternate paths
through sovereign waters without onerous regulatory requirements or costs. In addition, an international
framework for cable system operators, network operators and service providers to cooperate in defining
and implementing best practices would be helpful.

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3.6 Payload

3.6.1 Function
The Payload ingredient of communications infrastructure includes the information transported across the
infrastructure; traffic patterns and statistics; information interception; and, information corruption. It
includes both normal data transport and signaling and network control traffic. There are special latency
considerations for payload delivery due to the long distances of undersea cable systems.

3.6.2 Intrinsic Vulnerabilities

The following is a list of intrinsic vulnerabilities of the Payload ingredient.

 unpredictable variation
 extremes in load
 corruption
 interception
 emulation
 encapsulation of malicious content
 authentication (mis-authentication)
 insufficient inventory of critical components
 encryption (prevents observability)

3.6.3 Significant Trends

There are ten significant trends that relate to the Payload ingredient.

 1. Traffic demand is increasing at its fastest rate.

 2. As a percentage of the total traffic, financial services traffic is decreasing year over year.53

 3. Advances in laser technology have increased the throughput capacity of existing fiber facilities.

 4. Encryption algorithms are evolving and the more robust algorithms may require the most
“extra” bandwidth to carry the encryption.

 5. Compression algorithms may be used more to carry only the unique information and allow
reconstruction of the payload at the far end.

 6. Traffic load variation is increasing at both intra-day and inter-days intervals.

53
High bandwidth applications like video and gaming require orders of magnitude more bandwidth. However, most recognize
that the new applications are less important to critical needs like economic stability.

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 7. The risk of interception is increasing through development of new technologies.

 8. The risk of payload emulation is increasing.

 9. The risk of the encapsulation of malicious content is increasing.

 10. Authentication needs to be more sophisticated today given the increasing sophistication of the
malicious agents.

In summary, the laws of physics do apply here. Increase in distance and retransmission will increase the
delay. Very time sensitive messages will benefit from priority on the most direct routing and perhaps
benefit from forward error correcting schemes to avoid the need to retransmit when an error is detected.
A list of the various applications, their characteristics and their requirements needs to be compiled. Since
corruption at the lowest level is always possible, forward error detection and repair is viable for cable.
Means must be developed to at least detect, if not prevent, interception either directly or indirectly from
the cable. A flip side to interception is emulation of what appears to be valid payload but may be inserted
by a “man in the middle,” a concern that must be detected and blocked. A policy needs to be established
regarding the transport of encapsulated malicious content. Sufficient authentication and authorization
needs to be performed by the access networks prior to entering the cable backbone.

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3.7 Policy

3.7.1 Function
Agreements, Standards, Policies and Regulations (ASPR) is a term used to refer to the complete set of
inter-entity arrangements that are necessary for communications services. These arrangements include
national and international standards; federal, state and local regulations or other legal arrangements; or any
other agreement between entities - including industry cooperation and agreements and other interfaces
between entities.54 ASPR provides the necessary mechanisms used to anticipate, improve and control the
behaviors of entities that design, develop, implement, operate and evolve communications networks.
ASPR is abbreviated here as ‘Policy’.

Several factors make Policy a unique ingredient in undersea communications infrastructure. These factors
include the sharing of cable routes, the international scope, the jurisdiction of maritime law and law of the
sea, the influence of fishing regulations, the need for long term standards and the vital need for
coordinated speedy repairs.

3.7.2 Intrinsic Vulnerabilities

The following is a list of intrinsic vulnerabilities of the Policy ingredient.

 Lack of ASPR (agreements, standards, policies, regulations)

 Conflicting ASPR
 Outdated ASPR
 Unimplemented ASPR (complete or partial)
 Interpretation of ASPR (mis- or multi-)
 Inability to implement ASPR
 Enforcement limitations
 Boundary limitations
 Pace of development
 Information leakage from ASPR processes
 Inflexible regulation
 Excessive regulation
 Predictable behavior due to ASPR
 ASPR dependence on misinformed guidance
 ASPR ability to stress vulnerabilities
 ASPR ability to infuse vulnerabilities
 Inappropriate interest influence in ASPR

54
ATIS Telecom Glossary, www.atis.org .

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3.7.3 Significant Trends

There are eight significant trends that relate to the Policy ingredient.

 1. The use of Automatic Identification System (AIS) has proved invaluable in determining the
cause of some submarine cable faults and has also revealed the extent of faults caused by the
anchors of vessels that are underway. As can be seen in Table 6, the best-understood causal
distribution has changed significantly in recent years.55

Table 6. ICPC Loss Prevention Bulletin

Cause Pre 2007 2007 - 2008

Fishing 67% 33%
Anchors 8% 48%
Dredging 2% 0%
Other 23% 19%

 2. Some nation-states require permits to be issued before cable repair operations are allowed to
commence. This process introduces delay to the repair operation that can be significant and
increases risk of multiple cable failures.56

 3. There is increased concern over the risk of pirate or terrorist attacks on a cable ship on the
high seas. Given the special role of these vessels and crew in regard to global critical
infrastructure, it is unclear as to whether the international community would place the appropriate
priority on the need for quickly resolving such a crisis.

 4. The failure of some coastal nation-states to comply with UNCLOS continues because they
have not enacted domestic legislation to protect submarine cables, have not updated existing
legislation to comply with UNCLOS, or do not enforce existing legislation.57

 5. While there is improved cooperation amongst operators in several areas, there remains a lack
of sufficient information available to stakeholders to make appropriate statistical calculations
related to critical parameters such as expected loss of service, duration of outages and latency
impact.

 6. The commercial interests of private sector equipment suppliers, network operators and service
providers continues to include effective forces for promoting the continued improvement of
undersea communications cable systems. These forces include competition, the return on
investment, drive for efficiency and thus improved quality, and the natural accountability that

55
Since 2006 cable owners have observed 21 submarine cable faults around the UK alone. There were 10 cases of anchor
damage to submarine cables and all involved vessels that had been underway with their anchors deployed. Some of these
vessels also damaged multiple cables during the same event.
56
Conflicting boundary claims compound the delays that can be caused for those states/countries requesting permits before
repair operations commence in circumstances where the estimated location of a fault falls close to or within area of conflicting
boundary claim i.e. multiple permits to repair are require. The cable owner perspective is that there is no legal or practical
reason for requiring permits before repairs are undertaken.
57
Active submarine cable systems were extensively damaged by depredations in 2007. Actions are piratical under UNCLOS
100/101 and violate UNCLOS 113. These incidents were unprecedented in the history of submarine cables and caused
tremendous disruption to the telecommunications network. A cable ship also returned to a buoyed cable, following a return to
port for operational reasons, to discover the buoy, rope and section of cable stolen. There is potential for an exceptionally long
outage if remanufacture of equipment is required to bring any depredated cable system back into service.

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occurs from the observability of service outages or other impairments throughout the
communications services supply chain.

 7. There is a growing number of stakeholders for which highly available and resilient undersea
communications cable infrastructure is vital. Fewer and fewer of these are direct bandwidth
customers of cable network operators. As this ratio of stakeholders-to-customers increases, there
is a growing gap between the commercial focus of the private sector and critical infrastructure
assurance needed at a global level.

 8. Expectations regarding the rights of access and activity on the seafloor is changing as there is
increased interest in exploitation for mining.58

In summary, it is imperative to support existing industry efforts of continuous innovation and

improvement in this area. Specifically, some stakeholders of highly reliable and resilient GUCCI in the
course of due diligence may want to enhance their current understanding to include intrinsic
vulnerabilities and potential for latent modes of failure.

1. The global community of nations can recognize the vital priority of repairing damaged undersea
cables and eliminating the long delays for permits for repair work.59

2. The protections for cables can be strengthened. Consideration can be given to the implementation
and enforcement of minimum precautions to be taken by vessels to secure anchors prior to sea
passage. In addition, consideration should be given to enacting or updating national laws to align with
international cable protection provisions.60

3. Operators of undersea communications systems can be pro-active in cooperating in a trusted

information sharing community to ensure that the assembly, analysis and generation of appropriate
statistics are available to support the needs of the stakeholders of this critical global infrastructure.

4. The undersea cable industry can coordinate with relevant Government agencies to develop a protocol
that will provide a fast and coordinated response in the event of pirate attacks. As part of the protocol,
points of contact can be established for cable owners for such emergencies.

58
International Seabed Authority (ISA).
59
Consideration should be given to a) reinforcing the duty of nations to cooperate in repairs, b) reducing repair
permits/licenses/fees/guard boat requirements for all repairs to international cables beyond territorial seas, c) according cable
repair ships innocent passage status for the purpose of undertaking repairs in territorial seas.
60
e.g., UNCLOS.

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3.8 Human

3.8.1 Function
The Human ingredient includes the human involvement throughout the entire lifecycle of activities related
to the communications infrastructure (design, implementation, operation, maintenance and de-
commissioning); intentional and unintentional behaviors; limitations; education and training; human-
machine interfaces; and, ethics and values.

In addition, it is helpful to consider the human dimension in two roles. The first is when it is actually a
part of the infrastructure; i.e. when humans are part of the complex chains of equipment suppliers,
network operators, and service providers of the systems. In this context the human is an ingredient that is
essential to the infrastructure. Important aspects of this role are that humans have an element of
immediate, direct control of some aspect of the infrastructure, and the infrastructure organization has
some control over the human. The other role is where the human is outside the infrastructure. In this
role the human is not an ingredient of the infrastructure, but rather may be an ingredient of another
infrastructure or may serve as a threat agent.61 In these situations, there is indirect control over the
infrastructure (as when the human is part of the shipping infrastructure), and the communications
infrastructure has considerably less control over the human (as when serving as a threat agent).

People have a vital role in the design, testing, implementation, monitoring, maintenance and repair of
undersea cable systems. Several factors make Human an ingredient deserving of special attention in
undersea communications infrastructure.

These factors include the high stakes potential associated with the payload of cable networks, the human
interface with great natural and engineering challenges, the need for highly specialized knowledge and
skills and the related need for execution of critical tasks, and the concern for sabotage or unintentional
damage.

3.8.2 Intrinsic Vulnerabilities

The following is a list of intrinsic vulnerabilities of the Human ingredient.

 physical (limitations, fatigue)

 cognitive (distractibility, forgetfulness, ability to deceive, confusion)
 ethical (divided loyalties, greed, malicious intent)
 user environment (user interface, job function, corporate culture)
 human-user environment interaction

61
The potential damage that malicious agents could inflict by attacking a relatively few number of cables is considerable, given
that these cables have such huge capacity. This can be thought of as an example relating to the ‘new asymmetric terrorist
threat’ which is causing concern to many nations; It does not take much imagination to extend upon existing published analysis
to see the parallels to undersea cable infrastructure. Maritime Critical Infrastructure Protection: Multi-Agency Command and
Control in an Asymmetric Environment, Watts, Robert B, www.hsaj.org/pages/volume1/issue2/pdfs/1.2.3.pdf;

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Some of these intrinsic vulnerabilities are more present in undersea communications networks than
terrestrial networks. For example, workers on repair ships on the high seas may be away from family for
extended periods of time, exposed to unusual workplace dangers and require highly specialized expertise.
Also, undersea cable consortia are more and more competing on price to deliver large bandwidth with a
resulting focus on reducing costs. If an existing route is known to be acceptably reliable from natural or
man-made damage then there is a great commercial incentive to lay cables along the same route. This
reduction in diversity and resilience has at its root the human intrinsic vulnerability associated with
cognitive decision-making. It is interesting when looking at solutions to this vulnerability, to break this
cognitive aspect down further into the analytical performance of the decision maker and the psychological
factors that could influence the decision maker.

3.8.3 Significant Trends

There are seven significant trends that relate to the Human ingredient.

 1. The Internet has made extensive information available to the public about undersea
communications technology, network deployments and operations.

 2. The workforce involved in undersea communications cable infrastructure tends to be older,

relative to other ICT benchmarks.

 3. Some governments now classify undersea optical fiber cables as “critical infrastructure.”

 4. Over 70% of cable faults are caused by what is termed “external aggression.” Most often these
aggressions involve human activity - fishing, shipping activity. This is an example of influence
from the human ingredient outside this infrastructure.

 5. In recent years, there has been increasing concern over maritime piracy and theft, the later being
motivated by fluctuations in the price of metals.62 These are examples of the human serving as the
threat agent.

 6. Competitive pressures increasing with evidence from dramatically reduced prices for bandwidth
over the past decade.

 7. Economic drivers to reduce cost leads to reduced diversity of cable routes and less collaboration
between consortia because of competition.

In summary, the human vulnerabilities ingredient may be the most “frustrating” one. When we find bugs
in the hardware or software, the mitigation is usually a new release with the bug removed. This is not an
option with people. After a human mistake occurs, warnings are posted on how to avoid making the
same mistake in the future, but people tend to forget and the same error occurs yet again. Therefore
mitigations need to consider preventative measures to be incorporated via avenues of the other
ingredients.63 The undersea communications cable industry and stakeholders should establish a trusted
information sharing community in order to ensure that essential infrastructure security information is
shared with peers in a timely manner.

62
Thieves may not know the difference between legacy metallic cables and fiber cables.
63
i.e. hardware and software features to assist the human in avoiding mistakes.

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4. KEY OBSERVATIONS FOR GUCCI

This section presents information that is related to the current and future reliability of GUCCI. It
includes basic tutorial-level information for the reader previously unfamiliar with this industry, as well as
key insights from peers for those most experienced in it. It contains 100 observations that are key to
understanding the broad range of factors that influence the reliability, resilience and robustness of this
critical international infrastructure. These 100 Key Observations, which provide important support for
the guidance presented in The Report, were drawn from the 10,000+ data points that were part of The
Study. The observations are foundational to the twelve Recommendations, as is evidenced in Section 5
and are referenced there throughout.

To ease the reading of each Observation, care has been taken to present them in a concise fashion as
shown in the figure below.

Figure 23. Presentation of Key Observations.

Each observation is accompanied with an indication as to which of the eight ingredients it is related to.
These indicators are provided as a color key reference in the right hand margin to assist the reader in
quickly identifying Observations of interest for specific ingredients.

Figure 24. 8i Framework Colored Indicators for Ingredient Associations

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The Observations are structured into four main categories, as outlined immediately below, to assist the
reader. The corresponding number of observations for each category is shown.

Stakeholder (20)
Science & Engineering (40)
Business & Investment (17)
Government & Inter-Government (23)

The Observations begin with the Stakeholder perspective. All the effort going into building and
maintaining this vast infrastructure is for their interests. Thus the Stakeholder is the primary driver for
the business and other decisions affecting GUCCI. The Stakeholders includes any user. Consistent with
the design of the ROGUCCI Study, the financial sector is emphasized here as a key stakeholder. A quick
glance at these Observations reveals that they are primarily related to the Payload ingredient, as is
evidenced from the frequent red indicators (). The Stakeholder interests are embodied in the Payload
that traverses the infrastructure. The next category used deals with principles of Science & Engineering
that enable and limit the infrastructure. The laws of the physical world are strict in their rigidity. This is
a good thing when we can harness them for technology. But they can also be constraints when they
bound a possibility. It is not surprising that many of the ingredients are in play as science and engineering
factors directly relate to each of them. The third category utilized covers the Business & Investment
aspects that react to opportunities presented by the Stakeholder drivers and Science and Engineering
enablers and limits. The Final category is the Government & Inter-Government policy, which also
shape what is do-able and not do-able. Each nation-state legitimately seeks to represent its interests in
inter-governmental engagements. There are also issues within a country that affect GUCCI. Because
ASPR are manmade, unlike scientific principles, they are artificial constraints and therefore changeable.
The ROGUCCI process, with its extensive analysis of authoritative source material in each of these
essential four categories, incorporates the nature of each as described above.

Due to rapid developments in technology and business environments, the quantitative information used in
the Observations is presented in orders of magnitude. 64 More specific information would quickly be
outdated.

For additional reading on undersea communications cable infrastructure, the reader is directed to the
material appended to The Report, the many books on the subject or specific technologies utilized, and the
Internet. The industry has maintained a discipline of recording its history and providing ample records of
its underlying science, engineering advances, systems deployed, routes traversed, landing points, regions
served, special techniques developed, maritime fleets and many other details. Much of this information is
readily available in the public domain.

The following sections present the 100 Key Observations in the four categories described above. The
reader is encouraged to make reference to them, as appropriate, when reading The Recommendations in
Section 5.
 

64
‘Order of Magnitude’ is an engineering and scientific method of describing quantities in approximation to emphasize the
intuitive or general meaning of the quantity with deliberately less emphasis on the precision of the measurement. The Report
uses the most common base of 10.

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4.1 Stakeholder Oriented Observations

1. Public Unaware. Members of the general public are largely unaware of the significance
that undersea communications cable infrastructure has in their daily lives and
businesses. This dependence is very real and is evidenced in orders, transactions,
research, technical support, media updates, and many other areas of society and
business operations (Figure 25).

2. More Bandwidth ≠ More Resilience. User demands to date are impressive in

motivating the build out of needed bandwidth, but are incomplete in motivating resilience
investments appropriate for the level of dependence on GUCCI, and the consequences
of its long term loss (Figure 25).

Figure 25. Growing ‘Dependence on Reliability’ Gap

3. Heads in the Clouds. Many consumers and business managers incorrectly believe that
their international communications are carried via satellites links. As such, they may
have a false sense of security regarding their understanding of critical dependencies.

4. Bandwidth Thirst Management. There is unprecedented demand for bandwidth as

growth in traffic over international communications networks races at exponential rates.65
Given the long lead times to deploy new systems, it is conceivable that exponential rates
of demand growth can surpass the industry’s ability to deliver. This concern is offset
presently with technology advancements that enable deployed fiber systems to carry
more information.66

65
For example, the volume of international traffic through Hong Kong is doubling every ~18 months.
66
As insight into the potential steep curve ahead, AT&T reported that 3% of its iPhone users generate 40% of the data traffic on
its wireless network. These are the early adopters of what is available – bandwidth intense applications such as video and
gaming. Los Angeles Times, 10 December 2009.

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5. User Expectations Are High. The nature of communications network traffic is evolving
from voice and messages to images, video, and other sophisticated applications, with
general characteristics of being larger in size and more complex. Users have quickly
extended expectations for high reliability from beyond traditional services to those that
are advanced and emerging.

6. Traffic Growth Is Part of Development. Developing countries are experiencing

disproportionately larger growth in traffic.67

7. Everybody Wants It. There are both new and more stakeholders for reliable GUCCI.

8. Pacific Rim Leadership. The steepest traffic growth area for undersea
communications is trans-Pacific connectivity.68

9. Bank on It. The financial sector’s evolution to a largely electronic infrastructure has
been accomplished through reliance on international communications.

10. “Snap to a Halt!”69 The loss of communications services has an immediate impact on
international financial services sector, which have become almost completely electronic.

11. Financial Sector Sensitivity. Due to the recent economic downturn, global leaders
have a heightened sense of appreciation for the cascading impacts of financial sector
degradation. However, they may not have a sufficient appreciation for the rapidity at
which it can occur. Degradation is conceivable through a technological failure of
international electronic connectivity that would instantaneously freeze assets and
prevent transactions.

12. The Technologically Blind. Stakeholders are typically not technically oriented and do
not focus on the technology that they are using, but rather only its ability to meet their
needs. Even if they were so inclined, because of the complexity of networks, it would be
very difficult for them to know which cable systems they are actually depending on for
specific types of communications.

13. You Get What You Pay For - Maybe. Sophisticated customers tend to distribute their
dependence across multiple cable systems. However, due to common physical paths,
this does not guarantee them of geographic diversity.

14. Two Modes of Awareness. There is wide variation of awareness within the financial
sector and among other key stakeholders regarding their dependence on undersea
cable infrastructure. The vast majority is largely unaware of the dependence and a very
small minority has an advanced appreciation.

67
The international Internet traffic growth has exceeded 100% for three regions: Middles East (160+%), Eastern Europe
(140+%) and South Asia (110+%), TeleGeography Research, 2009.
68
TeleGeography Research, 2009.
69
U.S. Federal Reserve Board chief of staff Stephen Malphrus has coined this phrase to describe the instantaneous transfer of
impact from the loss of communications services to the financial sector. Keynote Speeches, IEEE CQR International Workshop,
London, June 2006, and IEEE ROGUCCI Global Summit, October, 2009.

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15. Emerging Role of Operational Risk. The Bank for International Settlements Basil II
Accord establishes operational risk as one of the three fundamental components of risk
that a bank manages. This operational risk includes losses that could stem from internal
processes, people and systems, and external events. Given the tight integration of the
financial sector with international electronic communications networks, intensified
cooperation between the financial and communications sectors is imperative.

16. Financial Sector Due Diligence. Insufficient reliability data is available for financial
sector and other stakeholders to support needed risk calculations. In order to do
appropriate diligence, stakeholders should be able make statistical predications
regarding the expected frequency and duration of outages and the range of impairments
(e.g., payload latency) that can affect their operations. However, insufficient data is
available to support such analyses.

17. Waiting. Financial sector stakeholders have expressed an eagerness for more
complete statistical information about the reliability of GUCCI.

18. Waiting for My Ship to Come In. The limited number of specialized cable repair ships
is a top concern for stakeholders in some regions. Many undersea cable systems have
a zone maintenance agreement (ZMA), in which the risks, costs and repair vessels are
managed across multiple systems.70

19. Nation-State Stakeholders. The protection and integrity of GUCCI remains a focus of
nation-states for both security and economic protection interests.71

20. Resigned to Learn the Hard Way. Those stakeholders aware of the latent
vulnerabilities of global undersea communications cable infrastructure are generally
resigned to work within the current paradigm of incremental improvement based on
lessons learned from historical outages. The expectation is that a widespread
catastrophe has to be experienced before the political will can be established to take
necessary actions to address latent vulnerabilities.72 73

70
The Atlantic Cable Maintenance Agreement (ACMA) covers the North Atlantic and South Atlantic Oceans (and also the South
Pacific on the west coast of South America; the Mediterranean Cable Maintenance Agreement (MECMA) covers the
Mediterranean Sea; and the Mutual Assistance Agreement for Pacific and Indian Ocean Cable Maintenance (PIOCMA) supports
cable systems in the Pacific and Indian Oceans (www.piocma.com).
71
The U.S. President’s National Security Telecommunications Advisory Committee (NSTAC), a Federal Advisory Committee
Act (FACA) body has included undersea cable infrastructure in its studies and guidance to the White House. NSTAC Chair
Letter to President Barak Obama and NSTAC Response to the Sixty-Day Cyber Study Group, March 2009, Pages 10-11.
(www.whitehouse.gov/files/documents/cyber/NSTAC%20Response%20to%20the%20Sixty-
Day%20Cyber%20Study%20Group%203-12-09.pdf), NSTAC Report to the President on International Communications, August
12007, page 6., An Overview of the Use of Submarine Cable Technology by UK PLC, Centre for the Protection of National
Infrastructure (CPNI), March 2006.
72
The concern with this scenario is that given the profound dependence on communications infrastructure that has developed
so rapidly, it is uncertain as to whether societies will be able to absorb the impact of catastrophic critical global infrastructure
failure with its cascading effects.
73
This mindset appears to carry across the human condition, as physician Scott Stoll notes: “Prevention is the wisest, but
hardest medicine.” www.drscottstoll.com/ .

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4.2 Science & Engineering Oriented Observations

21. Rare Glimpse of c’s Limit. Usually the speed of light makes communications appear
instantaneous for humans. However, long haul undersea cable systems provide a rare
human experience with the finite nature of the speed of light on the earth. A trip
encompassing the circumference of the earth requires approximately one tenth of a
second – a delay noticeable to a human. During cable failure alternate routes that
require routing over longer distances than normal is common, resulting in latency that is
unacceptable for some real-time sensitive applications.74

22. 99+%. Nearly all long haul inter-continental communications traffic is carried through
undersea communications cables. Less than 1% of inter-continental traffic is carried via
satellites.

23. Alternatives Are Not Up in the Air. Satellite back-up alternatives to undersea
communications cable infrastructure introduce latency that is unacceptable to real-time
sensitive modes of communications and do not have sufficient bandwidth to meet
current demands.75

24. Payload Volume. The payload traversing undersea communications cable

infrastructure is on the order 30 terabits per second (30,000,000,000,000), and
increasing at a rapid rate.

25. Repeaterless Range. Recent advances in fiber optic technology support propagation
over distances of up to 500 km (~300 miles) without a repeater.

26. Digital to Analog to Digital. The historic progression of undersea communications

began with the use of Morse code, which is a form of digital communications.76 The
bandwidth of these 1850s systems was about two words per minute. One hundred
years later, in the 1950s, undersea cable analog telephony was introduced with a
bandwidth of 36 simultaneous 4 kHz phone calls. Modern systems are digital once
again, transmitting hundreds of millions of simultaneous telephone calls.

27. DWDM. A key technology for concentrating so many distinct signals in fiber optic
communications is wavelength-division multiplexing (WDM). This is a method of using
different frequencies of light to carry individual signals. This multiplexing can be

The speed of light is ~3.0 x108 meters/second, which would take 0.13 seconds to travel ~4.0 x 107 meters, the circumference
74

of the earth.
75
There are three main reasons for this. First there is a finite frequency domain within any medium. For earth-space-earth
transmissions the same “free space” is utilized; whereas each fiber optic strand provides a new complete frequency domain.
12
Second, undersea fiber optic cables are capable of much greater traffic loads - on the order of terabits (10 , or
6
1,000,000,000,000); whereas satellites offer bandwidth on the order of megabits (10 , or 1,000,000). Third, satellite
transmission paths are considerably longer and the latency introduced with this longer path (recognizable for many from news
interviews with subjects in isolated regions) is unacceptable for some critical applications, such as those associated with
financial markets.
76
However, Morse code is not binary, but rather quinary, as five elements are needed to represent all alphanumeric characters.

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bidirectional over a single fiber strand. Dense WDM (DWDM) uses optical multiplexing
techniques to further increase carrying capacity.

28. Protocol Soup. Synchronous Optical Networking (SONET) and Synchronous Digital
Hierarchy (SDH) are protocols for multiplexing. They are standards that define the transfer
of multiple digital bit streams. Synchronized networking ensures precise coordination rates
across networks by the use of atomic clocks.77 Future networks will likely increasingly rely
upon Multiprotocol Label Switching (MPLS) or something similar, which is able to assign
labels to data packets independent of their protocol and forward them based solely on the
label content. MPLS can handle SONET, Ethernet and other data link layer technologies.

29. Dynamic Rerouting. Capabilities are being developed to automatically reroute traffic
with software controls when a failure is detected. This capability is based on the
availability of alternate routes and spare capacity to complete such rerouting, however.

30. Fiber Pair Count. The number of fiber pairs in a system is typically on the order of 10.78
While systems can physically contain on the order of 100 pairs, there are limiting factors.
These limitations include the maximum repeater weight that can be handled by the cable
as it is lowered into and lifted from the water. In addition, the amount of time required to
repair such a system relative to acceptable weather conditions has been cited as a
consideration.

31. Heavy Light Technology. In addition to the foundation of light amplification by

stimulated emission of radiation (laser) technology, there are numerous advanced
photonic physics applications in a modern fiber optic transmission system. These
include both linear and nonlinear all-optical amplifiers. An example of a linear amplifier is
Erbium-Doped Fiber Amplification (EDFA), which uses an erbium-doped segment of a
fiber to increase the intensity of the optical signal by exciting the erbium atoms to higher
orbits. Raman amplification, on the other hand is nonlinear, and utilizes a lower
frequency signal photon to induce inelastic scattering of a higher frequency pump photon
that produce yet another signal photon.79

32. High Voltage. Given the great lengths of submarine cables, the power equipment used
in these applications has some special considerations. Cables are typically powered
from both ends, with opposite charges at either termination. The electric potential
generated is in the range of 1,000 to 15,000+ Volts. Current flows are typically on the
order of 1 Ampere, with variations of no more than an order of magnitude.

33. Ground Water. The signal repeaters are powered by the potential across them. The
current completes its circuit by passing through the metallic core of the cable and
returning by way of the surrounding seawater. The ocean completes the circuit.

34. Out on Two Strikes. When the protective barrier around a cable’s metallic core is
damaged such that its insulation properties are compromised, a short circuit occurs. The

77
Prior to synchronized networks, Plesiochronous Digital Hierarchy (PDH) was used. This scheme coordinated networks to run
at nearly the same rate.
78
4 to 8 pairs are common.
79
Named after Sir Chandrasekhara Venkata Raman, who discovered the inelastic scattering of a photon in liquids, for which he
received the Nobel Prize in Physics in 1930.

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location of the short becomes the new virtual earth. However, the system can continue
to operate as long as the power feed equipment from either end can produce enough
voltage to provide the minimum needed potential across each repeater. If a second loss
of insulation occurs along the cable, the system will fail to operate, as there will be no
potential between the two virtual earth points.80

Figure 26. Shunt Fault

35. As Thin As Your Hair. Optical fibers have a diameter on the order of 10 microns.81
The fiber is glass - typically made from silica (silicon dioxide, SiO2), which is found in
sand and quartz, and is one of the most abundant minerals on the Earth.82 The long,
thin, cylindrical strands form a waveguide that keeps light within its core as the refraction
index of the material and geometry cause the light to be reflected internally as it passes
along its length.

36. Fiber Splicing. The repair of a broken fiber strand so that it can again serve as a
continuous optical waveguide, was once thought to be impossible. It is now performed
routinely, however with a process that requires great care and precision. Fusion welding
uses heat to join two fibers end to end. The result is a joint in which light passing
through does not scatter or reflect backwards.

37. Cause Analysis. Because of limitations to monitor the vast spans of the seafloor that
host GUCCI, the root cause analysis of many outages results in imprecise conclusions.
The most frequently exercised intrinsic vulnerability is hardware’s susceptibility to
physical damage. This can be confirmed. However, the exact source of external
aggression that acted as the threat agent is often not determined. Attribution for most
outages is categorized generally as damage caused by anchors and fishing.83

80
For this reason the immediate repair of shunt faults is imperative, in order to avoid an outage.
81
Single mode; multi-mode fibers tend to be an order of magnitude larger in diameter.
82
Doping is used to achieve attenuation levels suitable for long haul distances.
83
www.iscpc.org

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Figure 27. Cut Cable and Offending Anchor

38. Statistical Analysis. Modern communications networks are designed to be highly

reliable. Therefore, outages are rare events. This means that specialized approaches
are needed for understanding the likelihood of outage events and expected future
downtime. For example, the frequency distribution of outages can often be well
represented with a Poisson distribution.

39. Not a Role Model Yet. The current level of industry cooperation demonstrates
significant progress, but comes short of supporting trusted sharing of outage data so that
a global reliability performance level can be calculated.84

40. Heroic Technology Breakthroughs. Developments in Dense Wave Division

Multiplexing (DWDM) have enabled existing fibers to be utilized to support greater
throughput – on the order of 100 times more. “Butler’s Law” predicts the amount of data
coming out of an optical fiber is doubling every nine months.85 86 Fiber Optic technology
is able to support transmission speeds of 40G across long haul distances, and 100G
across shorter distances. Continued advances are expected.

41. Silver Anniversaries. Undersea cables have design lives of 25 years.

42. Highly Reliable Components. Undersea communications software and hardware are
designed with ultra-high reliable requirements – typically some of the highest standards
in the broad ICT industry.87

43. Seeing the Light. Transmission medium switched from metallic (copper) to optical fiber
in the 1980s.

44. The Gravity of It All. The early undersea cables, which relied on an outer protective
cover of gutta-percha as an insulator, were buoyant.88

84
A role model example of private sector cooperation – including among competitors – to measure and improve infrastructure-
wide reliability performance can be seen in the nearly two decade cooperation of the ATIS Network Reliability Steering
Committee. www.atis.org/nrsc. Under non-disclosure agreement and with the use of a trusted third party, industry members
share outage data, conduct joint expert analyses on causes and produce statistical descriptions and reports.
85
Bishop, David, Architects of the Internet: Speeding Net Traffic with Tiny Mirrors, EETimes, September 2000.
86
This is keeping pace with “Nielsen’s Law”, which predicts a 50% annual increase in connection speed from a usability
perspective. Nielsen's Law of Internet Bandwidth, Nielsen, Jakob, www.useit.com/alertbox/980405.html, April, 1998.
87
Ultra-high reliability expectations were established throughout the industry’s history. For example, the first transatlantic
telephone system (TAT-1), was built in the mid-1950s by AT&T (what is now Tyco Telecommunications), along with the British
Post Office and the with the Canadian Overseas Telephone Corporation. It supported 36 analog telephone circuits
simultaneously. TAT-1 performed flawlessly for more than two decades. When it was retired in 1978, the system had not
experienced a single component failure. www.tycotelecom.com/pdfs/tyco_history.pdf

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45. Varying Degrees of Protection. Undersea communications cables can be deployed at

depths on the order of 10km (~ 6 miles).89

46. Like a Garden Hose. Undersea cables vary in diameter based on the manufacturer and
the extent of protection. Cables in environments with more activity (i.e. near shore lines)
call for more protection. Cables in deeper oceans require less protection.

Figure 28. Example of Undersea Cables - Minimum to Maximum Protection90

47. Recipe for Success. The materials used in the manufacturing of undersea
communications cables are carefully selected based on many factors. These include
weight, electrical conductivity, contribution to tensile and other strength considerations,
contribution to bending radius, chemical interactions with other materials used, affects of
high pressure on them, contraction and expansion, longevity and cost.

48. Information Smorgasbord. There is a proliferation of information in the public domain,

and especially on the Internet, on all aspects of undersea communications cable
infrastructure.91

49. Visibility Means Accessibility. Undersea cable systems, landing points and shipping
vessels are identifiable and therefore accessible.92

88
The first undersea cable, deployed in 1850, required weights to sink to the sea floor.
89
The deepest part of the ocean known to man is found in the Mariana Trench located in the Western Pacific east of the
Mariana Islands. The recorded depth extends to 11,033 meters. Water column pressures at this depth are on the order of 100
megapascals (over 15,000 psi), which is 1,000 times the standard atmospheric pressure at sea level.
en.wikipedia.org/wiki/Mariana_Trench.
90
Example shown at Alcatel-Lucent OALC4 family. Depicted are the Lightweight (LW) [17 mm], Lightweight Protected (LP) [23
mm], Single Armored (SA) [31 mm], and Double Armored (DA) [46 mm].
91
Appendix A provides examples of the range and details of information available on the Internet.
92
This is an intrinsic vulnerability of the Environment Ingredient, discussed in Section 3.

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50. Looking Backwards. Most risk analysis and preparations are limited to previously
experienced failure modes. However, senior experts recognize latent modes of failure.
The consequences of a long-term outage from some of these failures could be
catastrophic.

51. Intrinsic Vulnerability Approach. Stakeholders for highly reliable and resilient global
undersea communications infrastructure would enhance their current understanding by
including systematic coverage of intrinsic vulnerabilities and actively anticipating the
potential impact of latent modes of failure.93

52. SPOFs. GUCCI has several geographic aggregation points that present latent single
points of failure. The probability of a failure to occur at one place is much higher than for
at multiple places simultaneously. Points of concentration are an intrinsic vulnerability of
the Network ingredient.94

53. Landing Sites. The landing stations and their approaches from the sea are avenues
that concentrate multiple cables and therefore present a particular concern from a
physical diversity perspective.

54. Back on Land. Terrestrial routes are being deployed as alternatives to undersea
routes.95

55. Basic Topologies. There are several geometric arrangements used for connectivity.
Factors used to determine the topology include economic, number of connection points,
and the distance. Branching is used when connectivity is needed along the way
between two points. A ring architecture provides two simultaneous transmissions and
can recover automatically when one path is cut. A collapsed ring trades reliability for
capacity. A mesh network provides more alternate pathways but has less reserve
capacity assurance. (See Figure 29.)

93
Section 3.
94
Section 3.5.2.
95
Reliance Takes Silk Road to China, Lightreading.com, 26 August 2009.

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Figure 29. Basic Network Topologies.

(a) repeaterless, (b) repeater, (c) branching, (d) ring, (e) collapsed ring, and (f) mesh

56. Collapsed Rings. Many undersea systems that were originally deployed as
Synchronized Optical Network (SONET) Rings, have been collapsed, or otherwise
opened, which results in networks without the protection of a ring topology. This is done
to increase capacity, however, it has exacted a cost on redundancy.

57. Mesh Topology. There is increased use of mesh network topologies. If designed with
spare capacity, these geometric arrangements can offer increased resilience by offering
multiple paths to maintain connectivity. If reserve capacity is not managed, then a single
failure could result in substantial impairment of service.

58. No “Plan B”. There is currently no alternative to GUCCI for providing high-speed
broadband connectivity among the continents.

59. Hurray Up - and Wait. Damaged undersea cable outages have extended durations for
three primary reasons: weather, contention for limited resources and government
permitting processes for access to sovereign waters.

60. Swelling Marine Activity. There is currently an unprecedented level of human activity
in the oceans. This includes the combined ocean sprawl in the form of wind turbines,
wave power, tidal power, hydrocarbon access, deep sea and coastal mining, deployment
of cabled ocean observatories, and an increase in the number and size of ships. An
example of a displaced activity is aquaculture development in the form of fish farms,
which are reducing deep-sea fishing activities. The reliability concern here is that
environments can be altered by human activity in a way that can be harmful to the
integrity of cables.

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4.3 Business & Investment Oriented Observations

61. Investing Billions. Investment in new cable infrastructure for the next 3 years is
expected to exceed that of the past six. The current investment level is on the order of
$2 billion annually. This investment peaked in 2001 when investment exceeded $13
billion.96

62. Build Cost. The total initial cost to construct a long haul undersea cable system is on
the order of $100M to $1B.

63. Maintenance Cost. The annual cost to maintain an undersea cable varies across
regions. It is generally on the order of $100 to $1000 per km.97

64. Price Variation. The price for monthly bandwidth lease can vary widely depending on
the points being connected. For example, a 10 Gbps wavelength can range from the
order of $10,000 to $100,000.

65. Nothing But Time. It takes several years to plan and build a new undersea
communications cable system.

66. Competitive Differentiation. Cable system operators are very sensitive to outage data
that may reflect negatively on the perception of their system’s performance.

67. Small Community. Relative to other communications networks, the number of undersea
communications cable equipment manufacturers and system operators is small.

68. Better than the Alternative. Undersea communications cables are more economical
and generally less susceptible to damage than are terrestrial cables.98

69. Internet Underpinning. The dramatically increased intercontinental connectivity

capacity achieved in the 1980s was an essential aspect of the growth of the Internet.

70. Game Change. The undersea communications cable industry has shifted from one
where competition was primarily between service providers exclusive ownership of
systems to one where competition is based on bandwidth cost.

71. Business Impact Disconnect. Contracts between cable system operators and service
providers typically include Force Majeure clauses that exclude operators of any
obligation for the downtime associated with a damaged cable. This legal insulation is
understandable because the cause of cable damage is seldom attributable to cable
system operators. However, the resulting limited awareness of financial and other

96
TeleGeography Research, 2009.
97
Costs for the Pacific tend to be nearly double those for the Atlantic.
98
The NRSC has observed that cable cuts are historically the most frequent cause of widespread outages in the United States
public communications networks. www.atis.org/nrsc.

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impacts of outages, isolates cable system operators from the feedback loop common to
many commercial interfaces. This isolation makes operators less aware of the growing
impact of downtime on end users.

72. The Road More Travelled. The re-use of existing cable routes is common practice for
new system deployments. The motivations are at an individual system level, being
primarily financial for the business and safety for the cable. 99 However, global
infrastructure reliability considerations are not a primary consideration.

73. Business Appetite. Business investors tend to prefer the relative low risk option of
placing cables along certain existing routes (whose safety is known) to meet new
demands, as opposed to pioneering new routes with more uncertainties. The result is
that there is less physical diversity than if more investment was made in new, alternative
routes.

74. Specialized Cable Ships. Cable ships and their crews are typically shared resources.
Contention for such limited resources is one of the contributing factors in extended
duration outages, particularly when multiple cuts are involved.

75. Paying Tolls. Many undersea cable routes involve tariffs, rights of passage fees and
similar expenses levied by nation-states.

76. Spare Capacity. With the exception of Asia-Europe routes, most routes have
considerable “unlit” capacity, though at current traffic growth rates this existing capacity
will be exhausted within a few years.100

77. Maintenance Access. Even if cable system operators were given advance permission
to enter sovereign waters, there could be new requirements placed on them at any time.

99
Planners first define the markets they want to serve, and landing points flow from this. Then they seek the shortest and safest
routes, in order to minimize cost of cable and maintenance. The shortest path to deep water is usually taken, where risks are
less, so the cable can be unarmored. In depths greater than 2,000 m cable is normally much safer and can be manufactured
without armor, thus reducing risk, maintenance, manufacturing and installation cost. Planners of early undersea cables
generally chose the shortest, safest routes between communications hubs. Consequently, distance and safety are the major
motivators in re-using routes. This leads to concentration in some areas, since alternate routes may be longer, more expensive
or more dangerous. In addition, costs to explore new routes can be avoided. Other factors include unknown risks, relationships
with new nation-states, securing rights and the extent of research associated with a new area.
100
TeleGeography Research, 2009.

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4.4 Government & Inter-Government Oriented Observations

78. Geo-politics. Geo-political impediments have limited the implementation of a

fundamental sound principle of reliability engineering – avoiding single points of failure.
While certainly very serious, these limitations are artificial in the sense that they are
manmade and unlike the rigid limitations of physics and other scientific parameters being
managed in the pursuit of high reliability.

79. Paperwork. The procedure for a repair vessel to obtain approval for entering waters to
restore service in some countries is very complex and can introduce significant delay in
to the repair procedure.101 It appears that for some countries the process can vary and
suggests gross lack of planning and coordination on the part of the government.

80. Confusing Boundaries. There is wide variation among countries’ claims on their
territorial rights relative to its adjacent waters.

81. Need to Go the “Extra Mile”. Several nation-states require repair vessels to obtain a
permit for the repair of communications cables, including activity that takes place beyond
a nation-state’s territorial sea, normally 12 nautical miles (NM) from the coastal baseline
(Figure 30).102 103

82. UNCLOS. The United Nations Convention on the Law of the Seas (UNCLOS) provides
special status for undersea communications cables, including special provisions for their
protection.104 105

83. EEZ. The UNCLOS establishes Exclusive Economic Zones that grant nation-states
special rights for the exploration and use of marine resources. The EEZ extends out to
200 nautical miles from its coast (Figure 30).

84. Continental Shelf Access. Nation-states are entitled to lay undersea communications
cables on the continental shelf, with conditions related to natural resources, the course
taken, navigation channels and regard for cables or pipelines already laid (Figure 30).106
107

101
Equipment supplier-provided data showed two modes of repair for faults and outages. One mode had a dramatically much
longer duration, which was due to extended permitting procedures.
102
Cable owners tend to view this as inconsistent with their rights and responsibilities under the United Nations Convention on
the Law of the Sea (1982) ("UNCLOS").
103
This is a reliability concern because this practice often increases the duration of repair times, increases maintenance costs,
and destabilizes the investment environment for this critical infrastructure: if nation-states can impose such mandates at will,
the rights of cable owners are uncertain.
104
October 1982, www.un.org/Depts/los/convention_agreements/convention_overview_convention.htm.
105
Appendix E.
106
A continental shelf is the undersea extension of a continent, which can extend out for many miles into sea.
107
UNCLOS Article 57, Submarine cables and pipelines on the continental shelf. See Appendix E.

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85. Freedom of the High Seas. Freedoms spelled out for all nation-states on the high seas
specifically include one to lay undersea cables, in addition to those for navigation, over
flight, constructing artificial islands, fishing and scientific research.108

Figure 30. The Continental Shelf and Water Zones.

86. Intelligence Eavesdropping. The switch from metallic to fiber optic cable made the
interception of traffic over undersea cables much more difficult.

87. A Shot Across the Bows. Hostilities on the High Seas are an increasing concern for
undersea cable repair ship operators, their crews and other stakeholders.

88. International Infrastructure. Many nation-states classify their international undersea

communications cable assets as “critical national infrastructure.” However, these cable
systems are really international.109

89. A History of Importance. Undersea communications cables have been protected with
international law since the International Convention for the Protection of Submarine
Cables of 1884.

108
UNCLOS Article 87, Freedom of the high seas, Article 112, Right to lay submarine cable and pipelines. See Appendix E.
109
Burnett, Douglas, International Telecommunication Cable Repair Under UNCLOS.

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90. It Needs Some Teeth. Willing or negligence-caused damage to undersea cable is a

punishable offense, though few nation-states have effective legislation to support the
international law.110

91. Keep Your Hands to Yourself. Parties that damage a neighboring undersea cable
when deploying or maintaining their own cable are responsible for the cost of the
damages they cause.111

92. Anchors Away! Nation-states are to recognize when a ship has sacrificed an anchor or
fishing equipment in order to avoid damaging an undersea cable.112

93. Seabed Ownership. Part XI of the UNCLOS provides for the assignment of mineral
rights outside of the EEZs. UNCLOS set up the International Seabed Authority, an
intergovernmental organization that controls mineral activities in international seabed
areas.113

94. U.S. Not On Board. The United States has signed, but not ratified, the United Nations
Convention on the Law of the Sea. Objections to the role of the ISA have been cited as
impeding ratification. The United States is the only major maritime power to not ratify
the treaty.

95. Mining the Floor. The International Seabed Authority is experiencing a dramatically
heightened interest in the mining of seafloor minerals. 114 This is significant from a
reliability perspective as activity on the sea floor can have harmful repercussions on
cable integrity.

96. Controlled Approaches. Some nation-states have established special zones for
communications cables. Advocates emphasize the benefits that the clarity of designated
locations provides for protecting cables through restricted access. Critics raise concerns
of tighter physical concentration and of heightened awareness of the critical
infrastructure locations.

97. Good Housekeeping? Policies within nation-state governments are not coordinated.
Examples include the domains of security, regulation, commerce, environment,
transportation and windmill and mining and fishing activities.
 
98. Battened Down the Hatches. Those who may be most aware of the concerns from
their nation-state’s security perspective are also those whose responsibilities are highly
aligned with specific nation-state security interests. These individuals are seldom
enabled to engage international parties to discuss their concerns and propose

110
UNCLOS Article 113, Breaking or injury of a submarine cable or pipeline. See Appendix E.
111
UNCLOS Article 114, Breaking or injury by owners of a submarine cable or pipeline of another submarine cable or pipeline.
See Appendix E.
112
UNCLOS Article 115, Indemnity for loss incurred in avoiding injury to a submarine cable or pipeline. See Appendix E.
113
The ISA is based in Kingston, Jamaica. www.isa.org.jm.
114
The International Seabed Authority is an autonomous international organization established under the 1982 United Nations
Convention on the Law of the Sea and the 1994 Agreement relating to the Implementation of Part XI of the United Nations
Convention on the Law of the Sea. www.isa.org.jm

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cooperative measures to protect GUCCI. Track II discussions are a possible avenue for
international critical infrastructure protection.

99. A Sea Change. The deployment of new alternative cable routes to avoid several
GUCCI geographic chokepoints would require international ASPR breakthroughs.

100. Eating Dust. Relative to the growth in stakeholder needs and the advances in
technology, progress in essential complimentary international ASPR is not keeping
pace.115

115
81% of the participants of the EWI Worldwide Security Conference 7, Multilateral Cybersecurity Consultation indicated that
“the current level of international cooperation in cyber space is far, far behind where it needs to be.” Brussels, February 2010.

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5. RECOMMENDATIONS
The ROGUCCI process led to the development of twelve Recommendations. Each of these
Recommendations is actionable and, if implemented, would improve the reliability of global
communications infrastructure. These Recommendations were developed based on international
stakeholder perspectives from six continents, the insights captured from the 100 Key Observations and
expertise from across the eight ingredients of communications infrastructure. In addition, each
Recommendation was reviewed and supported by stakeholders who are vitally dependent on GUCCI.

This section presents each of the twelve Recommendations along with supporting material, which
includes a concise statement of purpose, brief background, review of benefits achieved with The
Recommendation’s implementation, required commitments, alternatives and their consequences,
suggested next steps and measures of success. Because these recommendations are intended to mobilize
individuals and organizations in effective and coordinated action, the articulation of this surrounding
guidance is considered indispensible in realizing the sought after reliability improvements.

Leadership Posture for Recommendation Implementation

These Recommendations require the active support of the stakeholders, governments and the private
sector. Table 7 provides an overview of the primary leadership role(s) for each Recommendation. Each
Recommendation was fashioned with diligent attention to many important interests and factors, such as
respecting nation-state sovereignty and security interests, recognizing the long-term planning required to
deploy an international long-haul cable system, dealing with the harsh and isolated environment that hosts
undersea cables, acknowledging the public’s profound unawareness of its dependence on this
infrastructure, and many others. Primary leadership roles were identified based on these factors, interests
and competencies. A noteworthy observation here is that primary and supporting leadership roles are
shared among stakeholders, governments and the private sector. This is important because upholding the
reliability of the world’s communications infrastructure is a shared responsibility, and the critical principals
need to respect and support the distinct roles of each other, as well as fulfill their own.

Another noteworthy observation from Table 7 is that the private sector is more often the primary leader
than are stakeholders or governments. To be clear, given the relative constraints for governments to forge
agreements, the leadership of the private sector is imperative.

The Recommendations are deliberately written at the level of specificity presented. For example, while it
is apparent that there are organizations possibly well suited for implementing certain aspects of a given
recommendation, restraint has been used to avoid naming specific organizations as candidates. This is
done in order to preserve an open opportunity for others to take initiative and serve as leaders. There is a
lot of work to be done. All available, qualified resources are needed. Thus, other than by broad role (i.e.
private sector, stakeholder, government), the potential sources of support are quite open. Other examples
of targeted specificity are seen by the focus on the heart of required commitments, analysis of alternative
approaches and the brevity of the measures of success.

The ROGUCCI web site has been designated as a place to track ongoing progress of recommendation
implementation.

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Table 7. Leadership Posture for Recommendation Implementation

Private
ROGUCCI Recommendations Stakeholders Governments
Sector
Rudimentary Geographic Diversity for
1 1 1 1
Global Infrastructure

2 Prioritization for Timely Cable Repairs 1 2 1

Preparedness for Hostile Maritime

3 2 0 1
Crisis

Best Practices and Trusted

4 1 2 2
Information Sharing

5 New International Governance 1 2 2

International Communications
6 Infrastructure Standard for the 2 1 2
Financial Sector
Measurements for Stakeholder Due
7 1 2 0
Diligence
Improved Cable Protection
8 Agreements, Standards, Policies and 2 0 1*
Regulations (ASPR)
Government Inter-Agency
9 Coordination for Undersea Cable 2 0 1*
Infrastructure
Education and Awareness of GUCCI
10 1 2 2
Critical Role

Mechanisms for Handling Overload

11 1 2 1
Demand

12 Recognize Catastrophic GUCCI Loss 1 2 2

*includes nation-state and state or provincial levels

KEY
Primary Leadership Role 1
Active Supporting Leadership Role 2
Not Applicable 0

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Recommendation Impact
The Recommendations deal with the full range of challenges: the normal non-crisis state, the crisis state,
and the crisis response state. Figure 31 provides a high level overview of the relationships of The
Recommendations to these three states. Here a timeline is used to show the progressive situations of
normal operation, crisis, recovery and return to normal operation. The reliability of GUCCI concerns
each of these situations, and therefore The Recommendations span the continuum.

Figure 31. Recommendation Impact Across Time Continuum

Continuing with reference to Figure 31, the following is a brief summary of the impact of each
Recommendation’s implementation.

 Recommendation 1, Rudimentary Geographic Diversity for Global Infrastructure, decisively reduces the
impact of the most severe multiple cable cuts that could be experienced.

 Recommendation 2, Prioritization for Timely Cable Repairs, reduces the time associated with restoring
service after individual disruptive events, and would have very strong overall improvement on
combined GUCCI downtime.

 Recommendation 3, Preparedness for Hostile Maritime Crisis, can help avoid a disruptive attack event
and also provide critical management during a crisis that may occur.

 Recommendation 4, Best Practices and Trusted Information Sharing, enables higher levels of reliability
in normal conditions and also provides support for crisis and crisis recovery situations.

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 Recommendation 5, New International Governance, enables higher levels of reliability in normal

conditions.

 Recommendation 6, International Communications Infrastructure Standard for the Financial Sector,

provides the financial sector with enhanced capabilities to manage its critical interests during
normal conditions.

 Recommendation 7, Measurements for Stakeholder Due Diligence, will provide much needed advances
in understanding GUCCI performance during normal, crisis and crisis recovery periods.

 Recommendation 8, Improved Cable Protection Agreements, Standards, Policies and Regulations (ASPR),
will keep GUCCI in normal conditions by providing countermeasures to prevent some of the
most common forms of crises.

 Recommendation 9, Government Inter-Agency Coordination for Undersea Cable Infrastructure, will assist in
optimizing the conditions that support normal conditions.

 Recommendation 10, Education and Awareness of GUCCI Critical Role, will elevate the level of
understanding of how important the normal conditions are to the health of governments,
commerce and society.

 Recommendation 11, Mechanisms for Handling Overload Demand, will provide robustness by enabling
the most critical traffic to be carried to its destination during periods of crisis.

 Recommendation 12, Recognize GUCCI Catastrophic Loss as a Grand Challenge, will commence what
is expected to be a long journey toward solutions that will enable a more acceptable crisis
recovery from a catastrophic worldwide, or wide regional, loss of GUCCI.

Relationship Between the Key Observations and Recommendations

The 100 Key Observations played a key role in the formulation of The Recommendations. After analyzing
over 10,000 data points, most of these Key Observation were selected for their supportive role in the
formation of The Recommendations.116 Insights gleaned were prioritized based on their potential for
addressing the reliability, robustness, resilience and security of GUCCI. Specific Key Observations
references are integrated throughout the presentation of each Recommendation.

116
Some Observations were included for their purely tutorial value.

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5.1 Rudimentary Geographic Diversity for Global Infrastructure

Purpose
This Recommendation addresses the issue of how to significantly improve the reliability of GUCCI by addressing
unwanted points of concentration through the use of geographically diverse routes.

Background
The world’s undersea communications cable infrastructure performs at a level of reliability such that its
availability and operation are taken for granted by countless users.117 However, the dramatically increasing
dependence upon this infrastructure evokes a sense that ever-increasing diligence is needed to ensure its
reliability performance is commensurate with this dependence.118 When designing and implementing
highly reliable systems, a fundamental principle of reliability engineering is to avoid single points or modes
of failure.119 Redundancy and diversity are design techniques used to prevent any single failure causing a
system-wide failure. This is because the statistical likelihood of one failure is typically several orders of
magnitude higher than for two or more failures occurring simultaneously.120 121 The fundamental principle
of avoiding single points of failure is compromised in the world’s global undersea communications cable
infrastructure due to the aggregation of cables at certain geographic “choke points”. 122 These locations
include the Luzon Strait, 123 the ‘Suez Canal-Red Sea-Mandab Strait’ passage, 124 and the Strait of
Malacca,125 among others.126 Single points of failure are latent design weaknesses, whether or not they are
ever exposed.127 128 Recent history provides instances where this susceptibility has been exploited.129

The ideal GUCCI topology would be a mesh network with deliberate geographic diversity that wraps a
highly interconnected web around the planet. Contributing factors to the current situation include real
and perceived geographic and nation-state political barriers to preventing private sector investment in
alternate routes to avoid existing choke points.130 Hindrances include initial resistance to explore and
invest in these locations, and then uncertainty regarding access to these cables for maintenance. In
addition, economic incentives motivate undersea network installations to re-use existing paths. 131 132

117
Key Observation 42, Highly Reliable Components, Section 4.2.
118
Key Observation 2, More Bandwidth ≠ More Resilience, Section 4.1.
119
Can be abbreviated as SPOF, SMOF.
120
Context is for a system built for high reliability applications.
121
Key Observation 52, SPOFs, Section 4.2.
122
Even if redundant systems are deployed in such a way that a common aspect is aggregated in a common area, then a single
point of failure is created.
123
The body of water that connects the Philippine Sea of the western Pacific Ocean to the South China Sea, between Taiwan
and Luzon in the Philippines. The strait is about 250 km (155 miles) wide.
124
The Mandab Strait, also, Bab-el-Mandeb, Bab el Mandab, Bab al Mandab, or Bab al Mandeb meaning "Gate of Tears" in
Arabic (‫)ﺍاﻝلﻡمﻥنﺩدﺏب ﺏبﺍاﺏب‬, is the strait separating the continents of Asia (at Yemen on the Arabian Peninsula) and Africa (at Djibouti,
north of Somalia on the Horn of Africa), and connecting the Red Sea to the Indian Ocean (Gulf of Aden). The width of the Strait
is about 30 km (18 miles).
125
The Strait of Malacca is a narrow, 805 km (500 mile) stretch of water between Peninsular Malaysia (West Malaysia) and the
Indonesian island of Sumatra; the Strait is 64 km (40 miles) wide at its narrowest point.
126
Key Observation 8, Pacific Rim Leadership, Section 4.1.
127
Key Observation 50, Looking Backwards, Section 4.2.
128
Key Observation 51, Intrinsic Vulnerability Approach, Section 4.2.
129
Recent instances of multiple cables being damaged in geographically concentrated cable pathways include the Hengchun
Earthquake (December 2006), Middle East (January-February 2008), Alexandria, Egypt (December 2008) and the Typhoon
Morakat (August, 2009). See Appendix A for a description of these events.
130
Key Observation 78, Geo-politics, Section 4.4.
131
Key Observation 72, The Road More Travelled, Section 4.3.

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Overland alternatives have always been a possible solution, however, such routes also have challenges
such as accessibility for initial deployment and ongoing maintenance.133

Recommendation 1
Stakeholders for highly reliable and resilient international communications should
actively promote the deployment of geographically separate cable paths to avoid
current single points of failure, by serving as advocates to the nation-states
controlling the lands and waters for potential alternative, diverse paths.

Required Commitment
To sustain the viability of The Recommendation, stakeholders, governments and the private sector must
be committed to defined courses. Specifically,

 Stakeholders must commit to a course of advocacy to ensure that effective articulation of the
geographic concentration risk is understood by the appropriate governments.134
 International policy change agents must effectively frame the interests for decision makers and
mobilize resources.135
 Nation-state governments must provide access to investors and provide assurances for timely
ongoing maintenance.
 Investors must build out new fiber cable systems in routes providing new geographic diversity.

Benefits of Rudimentary Geographic Diversity for Global Infrastructure

When implemented, The Recommendation will provide more reliable global connectivity. This improved
reliability will benefit both far separated continents whose connectivity depends on existing choke point
passage, as well as the regions with the choke points. The international financial services sector will
benefit from improved economic stability. Countless private enterprises of all sizes will benefit from
enhanced business continuity. Governments will benefit from enhanced continuity of operations for
essential services. International media outlets will be served with improved resilience when covering crises.
Individuals will benefit by the improved availability of global connectivity.

If implemented correctly, the new routes will be of a distance similar to - or shorter than - existing routes,
so as to preserve the low latency transport required by time-sensitive users, such as the financial services
sector. Shorter routes would provide the added benefit of reduced latency and be thus more competitive
for financial markets.

132
Key Observation 73, Business Appetite, Section 4.3.
133
The most common cause of terrestrial network outages in the U.S. has traditionally been cable cuts per ATIS Network
Reliability Steering Committee (NRSC), www.atis.org.
134
Key Observation 20, Resigned to Learn the Hard Way, Section 4.1.
135
Key Observation 99, A Sea Change, Section 4.4.

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Alternative Approaches and Their Consequences

Alternatives to this approach include the following:

o Keep the issue quiet . . . resulting in eventual exposure through natural or man-made forces, but with the
impact being greater due to increased dependence on GUCCI as time goes by.136 137
o Discourage use and dependence on global connectivity . . . would be cause for profound disadvantage to a
nation-state in terms of technological and economic development.138
o Maintain the current course . . . passively promoting increased global dependence on global infrastructure with
latent design deficiencies, the anticipated ramifications being higher likelihood of catastrophic loss of global or
regional connectivity.139

Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:
1-1. Private and public sector stakeholders should establish a guiding coalition to actively raise
awareness of existing SPOF concerns and advocate deployment of geographic diversity for cable
routes at existing choke points. A proven global policy change agent should champion this
initiative.

1-2. Financial sector and other stakeholders should articulate their need for reduced operational
risk through geographic diversity around existing infrastructure choke points.

1-3. Governments with sovereignty in regions with existing GUCCI SPOF concerns should
attract investors by providing assurances regarding access for deployment and ongoing
maintenance as well as clarity around private sector ownership rights of deployed infrastructure.

1-4. Rudimentary geographic diversity is provided at existing GUCCI choke points with the
deployment of additional communications cables taking alternative routes.
   
Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Geographic diversity provided: Existing undersea cable infrastructure choke points are
avoided through the deployment of cables in physically diverse routes.

Latency-competitive routes provided: The routes designated as alternatives for the existing
choke points are of similar or shorter distance so that they avoid unacceptable payload latency.

Improved availability of global communications infrastructure: The availability of the

world’s communications infrastructure is improved as calculated from appropriate models.

136
One approach to addressing this infrastructure design concern is to reduce awareness in order to limit its exposure to
malicious agents. The desired benefits of this approach would be minimal, as information regarding cable path routes and
points of concentration are already in the public domain. In addition, the consequences of reducing awareness of this concern
will compete with the need for broad global awareness and the need for cooperative action.
137
Gambetta, Diego, and Hertog, Steffen, Engineers of Jihad, Sociology Working Papers, Department of Sociology, University
of Oxford, 2007. This paper documents that a significant number of terrorists have advanced technical training. Thus they are
capable of accessing the existing public domain information and understanding the infrastructure implications.
138
In 2007, the total transaction volume of e-commerce in China exceeded 2 T Yuan, a 90% growth over the previous year. E-
commerce is forecast to be the main medium of commerce and about 70% of trade in 10 years. China Economic Net, November
2008.
139
Key Observation 100, Eating Dust, Section 4.4.

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5.2 Prioritization for Timely Cable Repairs

Purpose
The Recommendation addresses the issue of how to significantly reduce the average time needed to restore service after
cable damage. This can be done by addressing the lengthy approval process for cable repair vessels to gain access to sovereign
waters.

Background
Damaged undersea cable repairs have extended durations for three primary reasons: weather, contention
for limited resources and government permitting processes for access to sovereign waters.140 141 142 The
first is outside of human control and the second is discussed elsewhere in The Report. The third reason is
addressed here. Unlike other challenges for improving the reliability of GUCCI that deal with hard
limitations in physics and geography, very long distances, and outdoor and undersea environments,
improving the time needed to complete a process is very much a soft and controllable parameter.

The repair of a damaged undersea communications cable is a process that involves coordination between
the cable system owner, a specialized repair vessel operator and the nation-state government in whose
waters the repair operation needs to be performed. 143 144 Because of variations across nation-state
governments’ policies and procedures that grant access for repair operations, there is wide variation in
permitting approval times – from 24 hours to well over 2 months. Despite the greatly increasing
dependence on this infrastructure and resulting negative impact associated with any downtime, there has
been no meaningful change in years. On one hand, there are governments whose process is proactive and
streamlined. In these cases, speedy restoration of service has been prioritized and coordination planning
for responses to anticipated outages includes pre-approval for repair operations in designated waters.
Such coordination and planning keeps the approval process on the order of only days.145 On the other
hand, there are governments whose approval approach is reactive, uncoordinated among divisions, or
otherwise ineffective in prioritizing the restoration of service over damaged cables.146 These cases are
typified by information being requested during the approval process that could have been provided in
advance of an outage, slow and bureaucratic interactions between government agencies or ministries, and
a general unawareness of how the approval for access into waters is a priority – even though the
government may at that very time be experiencing severe negative affects from the outage.147 148 In these
cases, outage durations are unnecessarily extended by additional weeks.149

140
Key Observation 74, Specialized Cable Ships, Section 4.3.
141
Key Observation 80, Confusing Boundaries, Section 4.4.
142
Key Observation 81, Need to Go the “Extra Mile”, Section 4.4.
143
There are three possible situations: no permit required, permit required in territorial waters (typically 12 nautical miles),
permit required in disputed territorial waters.
144
If different from the government of the territorial sea, the government of the coastal area hosting the landing station is an
additional entity needing to be engaged.
145
Key Observation 77, Maintenance Access, Section 4.3.
146
Key Observation 79, Paperwork, Section 4.3.
147
Repair vessel owners have been required to provide annual reports on their companies’ business as part of one lengthy
approval process; this is information that could have been requested and provided well ahead of an outage.
148
Even in situations where all agencies of a government agree with approval for access, the carrying out of routine
administrative protocols introduce weeks of delays.
149
It is recognized that a nation-state government may need time to perform forensic analysis of a cable’s damage for its
security interests; though the time required for this activity is not as long as the delay durations here referenced. Additional
security concerns include cable repair ships performing espionage or surveying missions.

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Regarding the special case of disputed territorial waters, the undersea cable industry continues to expend
considerable effort to promote ratification of the UNCLOS as a means of establishing international laws
protecting the rights of cable owners in international waters.150 The industry is encouraged that the
UNCLOS provides special status to undersea communications cables, but also recognizes that confusion
is caused by the differences between legal regimes under the UNCLOS territorial seas, Exclusive
Economic Zone (EEZs) and Continental Shelves with regard to submarine cables.151 152 153

Very long duration outages are a major concern regarding the reliability of GUCCI because they
contribute significantly to overall widespread downtime or impairment. In addition, these long duration
outages should be a major concern for the economic stability of an established or emerging nation-state,
as its business, financial transactions and many other international connectivity-dependent functions are
lost or severely impaired.154

 
 
Recommendation 2
Nation-state governments should implement policies and procedures to provide timely
approval to authorized cable ships seeking permission to repair damaged undersea
communications cables.
 
 
 

Required Commitment
To sustain the viability of The Recommendation, stakeholders, governments and the private sector must
be committed to defined courses. Specifically,

 Nation-state governments must conduct advance planning in anticipation of cable damage.

 Nation-state governments must prioritize the restoration of undersea communications cables by
committing to providing an efficient and appropriately-speedy process for granting authorized
repair vessels access to their sovereign waters.155
 Cable ship operators and cable infrastructure owners must cooperate with government
requirements for information, onboard inspections, escorts and other requests, particularly when
opportunities for pro-active engagement are presented.
 Nation-state governments must be willing to compare themselves to best-in-class benchmarks for
efficient permitting time durations.
 
 
 

150
As of October 2009 there are 157 signatures.
151
Key Observations 82, UNCLOS, and 83, EEZ, Section 4.4.
152
China Institute for Marine Affairs (CIMA) and Center for Ocean Laws and Policy (COLP) Regional Workshop on Submarine
Cables Workshop Report, Beijing, PR China, May 2009.
153
The EEZ is a seazone where a nation-state has rights regarding exploration and use of marine resources (UNCLOS Part V
Article 55). The EEZ is 200 nautical miles (370 km) from the coastline. Rights associated with the continental shelf extend to
350 nautical miles (650 km) from the coastline (Article 76).
154
Since the infrastructure may cross many borders, government guarantees supporting infrastructure reliability are required,
including policies ensuring that providers will always have timely access to restore a failed part of a system. Resilient
International Telecommunications Guidelines for the Financial Service Sector, Pacine, Wayne and Callahan, Roger, Financial
Service Sector Coordinating Council www.fsscc.org, 2009.
155
Key Observation 100, Eating Dust, Section 4.4.

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Benefits of Prioritization for Timely Cable Repairs

When implemented, The Recommendation will provide more reliable global connectivity by reducing
both the frequency of outages and the average amount of time damaged cables are out of service while
awaiting repair. The frequency is reduced as repairs can be performed more quickly for system faults that
have the system utilizing its back-up facilities, but that have not yet resulted in an outage. The longer the
delay in repairing the primary facilities, the more likely a service outage will occur.156 The implementation
of The Recommendation will also reduce the duration by similarly reducing the repair interval time of
outages.

Another benefit of the implementation of The Recommendation is that it will increase awareness within
governments regarding the critical role of GUCCI. In addition, the carrying out of The Recommendation
will foster cooperation between governments and private sector partners.

Alternatives Approaches and Their Consequences

Alternatives to this approach include the following:

o Focus all efforts solely on endorsing ratification of the Law of the Sea . . . forfeiting achievable progress
with less demanding instruments.
o Cable ships enter waters to begin repairs prior to permits being issued . . . placing crews and the vessels
at risk, potentially creating an incident that is interpreted as challenging nation-state sovereignty.
o Maintain status quo . . . continuing to accept critical international infrastructure outages of longer durations than
are necessary, with intensifying impact given the increasing global dependence.
 
 
 
 
Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

2-1. Nation-state governments with best-in-class performance in facilitating speedy repair of damaged
cables should be identified and encouraged to provide their best practices to serve as references
for other governments to consider.157

2-2. Nation-state governments lacking the ability to facilitate timely authorized access to their
sovereign waters should develop policies and procedures that will enable them to achieve
performance comparable to international best-in-class benchmarks.

2-3. Cable owners and repair vessel operators should engage governments where there are new
opportunities to build pro-active permitting procedures.

156
Key Observation 34, Out on Two Strikes, Section 4.2.
157
e.g., At the time of cable system installation, the cable system operator should work with the authorizing government on
permitting procedures for future access for repairing anticipated cable damage. Ideally, the agreed procedure would include
some type of advance permitting arrangements. This Best Practice was shared at the ROGUCCI Global Summit, Dubai,
October 2009.

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Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Improved cooperation: Pro-active planning between private sector and governments regarding
expectations of each critical party and associated estimated time intervals for completion.158

Reduced outage durations: The duration of damaged cable-caused outages is reduced in areas
where there are currently protracted durations due to slow permitting procedures.

Benchmark performance awareness: Governments measure their permitting approval

procedures against internationally recognized best-in-class performance benchmarks.

158
e.g., some sort of pre-approval arrangement for cable ships operating within certain regions.

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5.3 Preparedness for Hostile Maritime Crises

 
 
Purpose
The Recommendation addresses the issue of how to provide a mechanism for rapid response to hostile
activities against international communications cables or the industry’s specialized cable ships by
undertaking coordination, planning, and other emergency preparedness activities.

Background
A basic exposure of undersea cables and cable ships is simply that they can be identified and located.159 160
There are a number of concerns that arise from this ever-present susceptibility.

For example, one of the major causes of outages in Southeast Asia during the past decade has been the
theft of cables for interest in their metallic content for scrap resale.161 A corresponding outage trend was
observed with terrestrial networks during this time frame.162 This trend seems to have passed its peak for
now, being correlated to the previous market highs for certain metals. Another concern is the new wave
of high seas piracy. Undersea communications cable repair ships are highly specialized vessels that have a
vital role in the resilience of GUCCI.163 Pirate attacks are on the order of hundreds worldwide, and
increasing at an annual rate of about 200%.164 165 These vessels represent a limited resource and their loss
or damage could contribute to significantly longer outage repair times.166 Unfortunately both undersea
cable routes and pirate activities seem to be common at geographic chokepoints. As an example of this,
the hottest bed for pirate attacks in the world is the water off the Somali coast in the Gulf of Aden
region.167 This is the same stretch of water that hosts undersea cable routes that connect Europe to Asia.
The typical motivation of pirates is different than that of terrorists. Pirates are motivated to gain a ransom
and so their harm is limited to the threats they pose to the personnel, the vessel and the infrastructure
through extended outage durations, should the vessel be unavailable. Conversely, other malicious actors -
such as terrorists - could target and misuse these specialized vessels for harm against undersea
infrastructure.

While most vessels will have some sort of security program, today’s sophisticated pirates can likely
outmatch such defenses, leaving crews, vessels and the infrastructure in danger. In light of the industry’s
inherent exposure to malicious activity, enhanced preparedness is needed.

159
Appendix A outlines the extensive information readily available in the public domain.
160
Key Observation 49, Visibility Means Accessibility, Section 4.2.
161
Thieves may be searching for metallic cables, not able to distinguish fiber optic cables.
162
The Network Reliability Steering Committee (NRSC) special study on malicious activities is documented in the NRSC 2006-
2007 Bienniel Report, pp 24-25, ATIS, August 2008, pages 24-25. The Report documents industry consensus expert guidance
that was developed to deter theft of cables.
163
Key Observation 74, Specialized Cable Ships, Section 4.3.
164
International Maritime Bureau, July, 2009.
165
Key Observation 87, A Shot Across the Bows, Section 4.4.
166
Key Observation 18, Waiting for My Ship to Come In, Section 4.1.
167
“Somali pirates carried out a record number of attacks and hijackings in 2009, despite the deployment of international
warships to thwart them and a United Nations Security Council resolution to bring the fight against them to shore.” The Piracy
Reporting Center of the International Maritime Bureau reported counted that pirates operating across the Gulf of Aden and
along the coast of Somalia had attacked 214 vessels so far this year, resulting in 47 hijackings, a 200% increase from 2007.
Record Number of Pirate Attacks in 2009, New York Times, December 29, 2009.

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Recommendation 3
Nation-state governments should cooperate with each other and private sector
undersea communications cable infrastructure owners and operators to develop
maritime crisis preparedness plans that would protect communications cable vessels
that are vital to the operation of global undersea communications cable infrastructure.
 

Required Commitment
To sustain the viability of The Recommendation, nation-state governments and the private sector must be
committed to defined courses. Specifically,

 Nation-state governments must cooperate in establishing intergovernmental agreements,

participating in planning, and being part of periodic simulated crisis exercises.
 Owners of cable ships must support effective planning and exercises by making vessels and
critical personnel available.
 Nation-state governments and cable ship owners must establish agreements on cooperation
procedures for maritime crisis response.

Benefits of Preparedness for International Crises

The benefits of implementation of The Recommendation will include improved crisis readiness. Effective
crisis response will translate into avoided downtime, thus strengthening GUCCI reliability. In addition,
another advantage will be better awareness of the role of undersea cable infrastructure and cable ships
among nation-state security stakeholders. Regional cooperation in crisis preparedness will build a
foundation for more advanced discussions in related areas such as general cable protection.

Alternative Approaches and Their Consequences

Alternatives to this approach include the following:

o Decide to leave private sector to defend itself alone . . . increasing likelihood of harm to crew, vessels, and
cable infrastructure.
o Do nothing, waiting for an event to occur and then react during this time . . . forfeiting advantages
that could have been achieved with advance planning and coordination.

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Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

3-1. Nation-states and cable system operators should convene regionally to conduct a joint threat
assessment and develop plans for responding to a hostile attack against cable infrastructure or
cable ships.

3-2. Nation-state governments and cable system operators should implement the crisis
preparedness plans developed, including 24x7 points of contact.168

3-3. Nation-state governments and cable system operators should design and conduct crisis
response exercises to evaluate the effectiveness of their plans and to provide practice for the
organizations involved.

Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Government-private sector coordination: Jointly developed plans are implemented.

Emergency contact points: Government and private sector interfaces are established and
operational.

Crisis response: Maritime crises are handled safely and effectively.

168
An important consideration is the need for modes of communications that are non-undersea cable-based, given the scenari
os that are being addressed. Thus satellite phones should be considered for international communications.

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5.4 Best Practices and Trusted Information Sharing

 
 
Purpose
The Recommendation addresses the need to share sensitive information among industry and government
stakeholders, within a trusted environment, enabling all participants to benefit from this shared body of
knowledge that is essential to optimize network reliability and resilience.

Background
The scope of undersea cable infrastructure reliability is vast. Whether viewed as protecting the integrity of
hundreds of thousands of kilometers of cable, or from the meticulous diligence required for the
exhaustive extent of the eight ingredients, it is a very big job. However, it can also be a subtle and delicate
topic. The transmission of terabits is done in complete silence through fiber strands as thin as a human
hair.169 Another of the more quiet sides of GUCCI is the sensitive nature of some of its business.
Outages are a delicate topic because they can reflect negatively on a business reputation resulting in
disadvantageous marketplace differentiation and reduced revenues.170 Other international infrastructure
protection information can be nation-state security, where topics may include security compromises that
have happened or concerns that are insufficiently prepared for.171 While the needs for protecting sensitive
information are quite clear, there are equally compelling reasons for ensuring that industry peers are well
informed, as better awareness can be critical in strategies for protection and reliability assurance. This
information sharing is needed on an international basis – particularly for GUCCI, as inter-continental
undersea cables are by definition international critical infrastructure.

Precedents for effective information sharing in trusted environments are well established within the
communications industry. 172 In today’s world of many suppliers, owners and operators, optimum
infrastructure protection cannot be provided without effective information sharing.173

A number of organizations have agendas and active memberships that seek to develop common best
practices and address issues impeding the business of planning, installation and maintenance of undersea
cables. 174 The memberships of these communities have developed a commendable level of trust.
However their remits do not facilitate the resolution of the broader concerns of global resilience voiced by
industry peers and stakeholder participants of the ROGUCCI study group. Information exchanges are
specifically designed to encourage and facilitate this kind of debate and to develop consensus solutions,
which transcend barriers presented by commercial or political interests. With such a huge scope however,

169
Key Observation 35, As Thin As Your Hair, Section 4.2.
170
Key Observation 66, Competitive Differentiation, Section 4.3.
171
A useful point of guidance posted in the ROGUCCI web forum. An example in the cyber security space is consider when a
government agency has information about ‘the Who’, ‘the Why’, ‘the What’, ‘the When’ and ‘the How’ for a specific cyber attack.
Naturally this information is very sensitive. However the technical practitioner may be only interested in ‘the How’. By
negotiating a limited exchange of information about ‘the How’ a compromise can be found to provide more timely and accurate
exchange of information whilst still protecting sensitivities. Peter Brouggy, January 2010.
172
The ATIS Network Reliability Steering Committee (NRSC) has fostered industry cooperation that has improved the reliability
of the U.S. public networks. The NRSC has operated as a trusted information sharing environment to share analysis insights on
outages and develop voluntary, expert best practices for over 15 years (www.atis.org/nrsc). Other references include the
WARP (www.warp.gov.uk/TrustedSharing.htm ) approach that has been deployed in numerous sectors. The European Network
and Information Security Agency (ENISA) is a recently re-invented approach (www.enisa.europa.eu ).
173
Rauscher, Karl, European Commission Availability and Robustness of Electronic Communications Infrastructure (ARECI)
Report, March 2007, page 102.
174
These include the International Cable Protection Committee, the Submarine Cable Improvement Group, and the International
Jointing Consortium.

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some means of partitioning information exchange is needed to bound discussions in order to ensure
relevance to all participants, yet remain sufficiently flexible to allow broad ranging and interdisciplinary
solutions. For example, those who are concerned with the mechanisms for protecting the physical
undersea cable sections will, in general, deal with different people and policies than those who are
concerned with peering arrangements. Yet both aspects have been shown to influence traffic behavior in
the event of a major failure.

With the enormous challenge of protecting and advancing the reliability of GUCCI, the private sector
needs every advantage it can get. Given the choice between the status quo, or a trusted information
sharing environment where industry and nation-state stakeholders could have the combined intelligence of
the industry, the clear choice is the later.175

 
Recommendation 4
The private sector should establish formal means for sharing information that can
improve the protection and rapid restoration of undersea communications cable
infrastructure.
 
 
 
Required Commitment
To sustain the viability of The Recommendation, the private sector and nation-state governments must be
committed to defined courses. Specifically,

 Private sector companies that own and operate undersea communications infrastructure must
jointly establish a trusted environment for sharing information to improve the protection and
rapid restoration of GUCCI.
 The private sector must be willing to share threat and outage information in a trusted
environment within the industry for the common good.
 Nation-state governments must be willing to share threat and other sensitive information with
owners and operators of GUCCI and safeguard information provided by the industry.
 Nation-state governments must be willing to share information that will improve the protection
and rapid restoration of critical infrastructure with other nation-states as well as the owners and
operators of that infrastructure within the other nation-states.
 
 
Benefits of New International Governance
Knowledge is power. Sharing information among owners, operators and the governments whose
constituencies depend on that critical infrastructure, provides decision makers with additional knowledge
and insights to help them prepare for, and react to, trends or threats. The sharing of sensitive information
will only occur and flourish in an environment characterized by openness, concern for the common good,
and most of all, trust.

The perceived benefits of establishing information exchanges include the comprehensive capture of
customer requirements, a coherent service provision to customers worldwide, the preservation of
commercial confidentiality, the development of ‘common good’ consensus outside of commercial and
political arenas and the reduction of human barriers to progress.

175
Key Observation 39, Not a Role Model Yet, Section 4.2.

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Alternative Approaches and Their Consequences

Alternatives to this approach include the following:

o Industry stakeholders sharing only with selected partners . . . resulting in fragmented sharing and
response to attacks, and various providers of critical international infrastructure being left uninformed.
o Critical government information kept within government . . . reduces industry’s ability to prepare and
respond to concerns.
o Industry threat and outage information shared only within industry . . . leaves government interests
under-protected and eliminates potential benefits of government assistance during a crisis.
o Information sharing kept within a nation-state government . . . weakens the ability of other governments
to prepare and respond, and negatively impacts the reliability and security of all networks connected to those of the
uninformed nation-states.
o A mandated environment for information sharing not built on mutual trust . . . results in sharing only
to the extent of the mandate, potential unintended consequences, and lost opportunity to benefit from a common body
of knowledge.

 
Next Steps
Relative to the other Recommendations in The Report, this one takes a considerably longer time to
develop to its full potential. This is because it is based on trust and the development of trust requires time
– years. This is all the more reason for the initial steps to be taken without delay. Following are suggested
next steps that can facilitate The Recommendation’s implementation and the building of that precious
trust.

4-1. The private sector and nation-state governments should investigate, and where appropriate,
join some of the excellent information sharing organizations that already exist, learning their
methods and creating an even larger pool of knowledge, mutually benefiting all organizations.

4-2. The private sector and nation-state governments should convene to establish a trusted
environment for information exchanges centered around functional roles, such as, customer
stakeholders, government regulators, equipment suppliers, and operators.176 Existing fora should
be used as appropriate. A gap analysis should be completed to help identify where other
communities could be created. The following activities should support this step:

• Identify those areas in which cooperation is not effective through existing mechanisms and
where the establishment of information sharing and best practice development could improve
GUCCI resilience and reliability.

• Map identified gaps onto the categories that enable the appropriate expertise to be readily
identified and engaged.177

176
Those most experienced with effective information sharing emphasize the importance of getting the architectural model that
best aligns with the interests of the parties invited to participate. An additional architectural element is the flexibility to selectively
share and unshared with members of a given community. A “star” or centralized arrangement is a topology where all sensitive
information passes through an entity, which then shares with community members. An alternative is the mesh network, which
encourages information sharing directly between parties willing to share. By enabling sharing to thrive where trust exists, the
end result will be substantially more information being shared.
177
The 8i framework can serve this purpose.

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4-3. Participants should agree on a model to be implemented. In so doing, consideration should

be given to the following insights:

• The scope and remit of the information exchange should be clearly defined.

• Trusted information sharing can only be achieved if the communities are small enough to
allow personal trust to develop. Multiple trusted sharing communities will likely be
needed.

• Participants must recognize that there are barriers to trusted information sharing and
ensure the proposals address these to ensure they are pragmatic and achievable. Typical
barriers include: lack of trust, competition law, lack of awareness, commercial pressures,
and lack of an independent facilitator or trusted third party.

• Some types of information will be more sensitive than others and some will have more
value than others. Many trusted information sharing communities start by sharing low
value, less sensitive information and as trust develops the community can move up the
value chain. This can sometimes take years to mature and therefore it is really important
to identify existing communities who already have a certain level of trust.

4-4. Participants should begin to share information with peers, as appropriate.

 
 

 
 
Figure 32. Nested Information Exchange Model178  
 

178
Harrison, John; Hill, G, Todd, M., ROGUCCI White Paper on Best Practices and Trusted Information Sharing, Landitd, U.K.
2010.

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Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Scope clarified. The industry defines the Global Undersea Communications Cable Infrastructure.

Deep awareness. Nation-state governments are appropriately aware of sensitive information of

importance to the security and prosperity of their nation-state and at regional, international and global
levels.

Financial services sector. The industry engages special challenges and concerns of the international
financial sector with the aim of improving the resilience schemes for systems supporting financial
services.

Best Practices developed and shared. Industry experts share best practices for promoting the
reliability, resilience and robustness of GUCCI. Information sharing is viewed as a means to an end.
The process ultimately underpins a top-level analysis of the issues that currently undermine the
resilience of the global information infrastructure.179

Smarter chain. The reliability of GUCCI is strengthened through enhanced stakeholder awareness,
and the concomitant more complete contracted services and infrastructure investment.

179
Achievement of this measure implies the establishment of effective international fora, as well as fora within nation-states (to
include private sector) that will be able to benefit from the information flowing.

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5.5 New International Governance

 
Purpose
The Recommendation addresses the issue of how the undersea communications cable industry supports the needs of
its stakeholders in providing the information they need to manage their dependence on it.

Background
The Report establishes the need for dealing with individual undersea cable systems as an aggregate, i.e.
global level. The need is based on the limited focus of commercial interests that manage individual
systems, the difficulty stakeholders have in performing due diligence in managing their operational risk
and the extremely high level of importance that this infrastructure plays in the world.180

The industry has historically recognized value in coming together for discussing various aspects of its
operation. There are a number of existing organizations that represent and address some of the concerns
of interested affinity groups involved in various aspects of the undersea cable infrastructure. 181 Reliability
is within the scope of some undersea cable industry cooperative efforts. These fora have brought together
equipment suppliers, network builders and operators and other special industry players such as surveyors
and repair ship fleets. Some of them have facilitated joint studies and have provided guidance that is
made available to the industry or public, as appropriate.182 These include analyses of specific outages,
trends in outage causes, best practices for addressing them, and advocacy for international policy agendas.
Some groups are re-examining their charters to determine how they might address some of the new or
more critical issues of the nature discussed at the ROGUCCI Summit.183

However, as stakeholders better comprehend the degree of their dependence on GUCCI, they require
more from their interface with it. For example, stakeholder participants of the ROGUCCI Global
Summit emphasized that the global view provided by the ROGUCCI process needs to continue to be
championed. They identified a number of issues that would benefit from an ongoing process and efforts
to systematically and comprehensively address several cross-industry and inter-government related
problems at a global level. The increasing dependencies and criticality of this undersea infrastructure to a
broad range of stakeholders further appeared to be evidence of interest and the need for some governance
structure to better permit providers and stakeholders to address key issues in a comprehensive and
strategic manner.184 Financial sector stakeholders described this as the “system-wide” view.185 Other
observations from financial sector stakeholders were that the undersea communications industry would
benefit from more inclusive participation in industry collaborative programs, more structured governance,
better coordination and a unified voice. Specific mission areas for new governance would ideally include
defining expectations for the industry, engaging representative stakeholders and articulating ASPR that
would advance GUCCI resilience.186

180
See Introduction, Sections 2.1, to 2.3.
181
These include the Atlantic Cable Repair and Maintenance Agreement www.acmaweb.ne), International Cable Protection
Committee (www.iscpc.org), Submarine Cable Improvement Group (www.scig.net), Submarine Telecoms Forum
(www.subtelforum.com), SubOptic (www.suboptic.org) and the Universal Jointing Consortium www.ujconsortium.com.
182
Key Observation 66, Competitive Differentiation, Section 4.3.
183
Key Observation 39, Not a Role Model Yet, Section 4.2.
184
Summit participants suggested collaborative efforts to identify problems, develop alternative solutions and provide expert
guidance and leadership. Also, such work would be of distinct benefit to decision makers, who are dealing with these complex
issues, both from an educational and awareness perspective and a source of expert information.
185
The financial services sector stakeholders established the fact that it has an international view that is complete in terms of
capturing all the necessary elements that make up its system.
186
Key Observations 71, Business Impact Disconnect, Section 4.3.

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Recommendation 5
The private sector should establish a new international governance framework for
global undersea communications cable infrastructure to provide optimum support for
its resilience through cross-sector coordination and effectively support stakeholder
interests.
 
 
 
Required Commitment
To sustain the viability of The Recommendation, the private sector and stakeholders must be committed
to defined courses. Specifically,

 Stakeholders must maintain a proactive posture in engaging this critical international

infrastructure partner.
 Existing industry fora must evaluate their charters, membership and commitments, in light of the
stakeholder and internal industry needs.
 Existing industry fora must, as appropriate, be either willing to make charter and membership
representation adjustments, or be supportive of sister organizations playing new complimentary
roles.
 Private sector companies must provide expert and leadership resources to champion new
governance functions.
 
 
 
Benefits of New International Governance
Stakeholders will have the opportunity to bring their concerns to the industry in a more organized fashion,
and encourage the availability of information regarding benchmark performance levels for GUCCI,
supporting the objectives of Recommendation 7. Industry members will have improved effectiveness in
cooperation, and have a unified voice when appropriate. Existing industry fora can be more effective at
fulfilling their current missions by channeling out-of-scope issues (outside of their mission or realm of
influence) to complimentary partners. The industry will attain an augmented capability to respond with
flexibility and speed on issues that may arise, like those identified in The Report.
 
 
 
Alternative Approaches and Their Consequences
Alternatives  to  this  approach  include  the  following:  
 
o Defer to government sector for oversight of industry cooperation . . . dulling the value of the industry’s
expertise, introducing delays in actions, and inviting unwanted regulation.
o Existing fora remain on current course and no new governance is established . . . accepting
suboptimum industry coordination and proactive engagement with stakeholders.
 
 
 
 
 
 

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Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

5-1. Existing industry fora should re-evaluate their charters and membership and make adjustments,
as appropriate.

5-2. New governance structure should be established, complimenting the existing effective functions.

5-3. Participation is expanded to be sector-wide.

5-4. Representative stakeholders are invited to be part of the new governance structure.

Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

New governance structure. New governance structure and process are established that provide
effective sector-wide coordination and addresses interests of stakeholders, fostering and
facilitating the coordination of cross-sector activities and initiatives designed to improve the
resiliency of the undersea cable infrastructure and services at a global level.

Finance sector participation. The finance sector is actively engaged as a stakeholder

representative in the new structure.

Unified voice. The undersea communications cable industry has a process for discussing issues,
developing consensus and representing itself with a unified voice at a global level.

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5.6 International Communications Infrastructure Standard for the

Financial Sector
 
Purpose
The Recommendation addresses the issue of how the financial sector should manage its dependence of
GUCCI specifically in the context of an overall improved management program for its dependence on
information and communications technology in general. While one sector is the focus in The
Recommendation, it should be viewed as a representative of all international critical sectors.

Background
The world’s international undersea communications cable infrastructure continues to operate at highly
reliable levels and continues to provide tremendous service to the financial services sector. Indeed, the
reliability of financial sector operations owes much to its ability to place extremely high confidence in its
communications service providers and their networks.

The financial services sector continues to evolve globally with increasing dependence on international
communications every step of the way.187 The sector is achieving much by reducing market risk through
such mechanisms as automation and compressed settlement intervals. On the other hand, it is raising its
operational risks in the process, by such things as increased dependency on GUCCI.188 189 The Bank of
International Settlements, Basel Committee on Banking Supervision has elevated operational risk as a
critical component of its supervisory framework.190 As with anything new, managing operational risk has
not yet been fully mastered. Indeed re-thinking is needed around business processes, resiliency planning
and continuity of operations. 191 Ideally, the information could be limited to focusing on expected
downtime for international connectivity. 192 However, depending on the thoroughness behind such
analyses, additional information may be needed, such as geographic route information for purchased
circuits and bandwidth, and equipment and service supplier information that can contribute to common
failure modes.193 194 The financial sector would benefit much from the systematic and comprehensive
perspective offered by an intrinsic vulnerability approach utilizing the Eight Ingredient (8i) Framework.

Recommendations 4 and 7 position the communications industry to better share information and provide
needed information to the financial sector, respectively. Correspondingly, this Recommendation calls on
the financial services sector to better define its needs and expectations, and to develop a structure to
organize operational risk guidance that allows users to manage their growing global dependency on
GUCCI.195 The need to manage international communications services as a priority is not new to the
financial sector. Recent activities include the development of the U.S. Financial Service Sector
Coordinating Council Resilient International Telecommunications Guidelines for the Financial Service Sector, which
underscored the imperative for improved management of the operational risk in resiliency planning.196 197

187
Key Observation 9, Bank on It, Section 4.1.
188
Key Observation 10, “Snap to a Halt!”, Section 4.1.
189
Key Observation 11, Financial Sector Sensitivity, Section 4.1.
190
Bank of International Settlement, www.bis.org .
191
Key Observation 15, Emerging Role of Operational Risk, Section 4.1.
192
Key Observation 38, Statistical Analysis, Section 4.2.
193
Key Observation 13, You Get What You Pay For – Maybe, Section 4.1.
194
Key Observation 12, The Technologically Blind, Section 4.1.
195
Key Observation 16, Financial Sector Due Diligence, Section 4.1.
196
Pacine, Wayne and Callahan, Roger, www.fsscc.org, FSSCC, 2009. Included in the document are: a description of the
undersea cable infrastructure and commonly used configurations, a description of general risks to the undersea cable
infrastructure, suggestions for analyzing requirements and risks, a description of practices that need to be considered for basic

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As the global economy continues to expand, reliable connectivity and highly

resilient international telecommunications systems are essential. Revenue-
generating and revenue-supporting financial services operations translate to
a need for near 100 percent global network availability coupled with
application-friendly round-trip latency, low jitter, and near-zero packet loss.
Thus, for any global application deployment, end-to-end cable path resiliency
becomes an important aspect of the initial planning, procurement, and
provisioning process and must be considered when engaging any global
carriers and service providers. 198

However, such progress stops short of calling for international cooperation around a core standard and
for its voluntary utilization, which will enable the more precise management of resilience and operational
risk on a global basis. 199 A standard should appropriately incorporate the financial services sector
sensitivity to latency.200 201 Therefore, The Recommendation builds on the progress achieved to date and
defines a course that will do much to close the gap between common practices and optimum due diligence.

Recommendation 6
The international financial sector should introduce a new core standard for its
information and communications technology dependence that will include guidance
on assuring institutional resilience and managing the operational risk associated with
undersea communications cable infrastructure.

 
 
Required Commitment
To sustain the viability of The Recommendation, the private sector must be committed to defined
courses. Specifically,

 The international financial sector must recognize GUCCI reliability as a strategic priority for the
stability of its operations.
 The international financial institutions must commit operational risk managers to developing the
details of global guidelines.202
 The financial sector and international communications industry must commit to a partnership to
develop a core standard that both can agree on.
 The financial sector members must voluntarily implement the developed core standard.
 The world’s international financial authorities must utilize these standards in their determination
of ratings and other stability-related decisions.203
 
 

types of service, suggestions for engaging service providers as partners in a trusted relationship at the beginning and
throughout the life cycle of operations, a discussion of contract considerations and important aspects of managing the ongoing
relationship with international telecommunications service providers.
197
Key Observation 14, Two Modes of Awareness, Section 4.1.
198
Ibid. pages 18, 20.
199
Key Observation 12, The Technologically Blind, Section 4.1.
200
Key Observation 21, Rare Glimpse of c’s Limit, Section 4.2.
201
Key Observation 23, Alternatives Are Not Up in the Air, Section 4.2.
202
central banks, markets, institutions, bank supervisors, investment firms, etc.
203
i.e. Individual financial sector regulators and the Financial Sector Assessment Program (FSAP) of the IMF and World Bank.

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Benefits of an International Communications Infrastructure Standard for the Financial Sector

The implementation of The Recommendation will bring key benefits to the international financial sector,
other stakeholders and the international communications industry. An international benchmark for due
diligence in managing GUCCI will be established. In addition, the sector will more fully understand the
risks associated with its current and evolving dependencies in this vital area. Also, other sectors will
benefit by the financial sector’s championing role, which simultaneously represents the vital interests of
many other stakeholders. Finally, the development of a global standard will strengthen the necessary
partnerships with the communications industry that are imperative for ensuring appropriate long-term
technology evolution that will accompany the world’s growing dependence on this infrastructure.

Alternative Approaches and Their Consequences

Alternatives to this approach include the following:

o Assimilate default standards and practices . . . mission critical interests will be under-represented
o Develop multiple standards . . . the financial sector will manage its operational risk inconsistently, and the
clarity of its interface with the undersea communications industry will suffer.204
o Continue status quo of attention . . . the financial sector will be unable to manage its operational risk
effectively.205

Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

6-1. A neutral party that is a well recognized international organization should convene operational
risk managers from the international financial sector, along with other critical stakeholders and
international undersea communications cable experts to define a process for developing a global
standard for operational risk management in this area.206 The core standard development initiative
should utilize the 8i framework to ensure coverage of the full scope of what needs to be considered.207
208 209

6-2. The financial sector and communications industry should implement this process to jointly
produce a new global core standard for international communications infrastructure resilience
assurance.

6-3. The world’s senior economic leaders should promote voluntary adoption of the core standard,
and should utilize nation-state institutional implementation as decision support for its policy and
practices, as appropriate.210
 
 

204
i.e. the critical international user communities will manage their operational risk inconsistently, and the lack of consistency will
not provide clarity to potentially valuable investments by the undersea communications industry and users.
205
i.e. the critical users will manage their operational risk based on limited knowledge and information with the likely potential
that unknown risks impact their operations, and the opportunity for more clarity for potential investments will be missed.
206
Key Observation 71, Business Impact Disconnect, Section 4.3.
207
Use of the 8i Framework recommended by Dr. Nasser Saidi, DIFC Chief Economist, in his keynote address to the ROGUCCI
Global Summit, October 2009.
208
Section 3.
209
Key Observation 51, Intrinsic Vulnerability Approach, Section 4.2.
210
e.g., the G8, G20, World Bank, IMF.

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Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Global Core standard. A core standard for international communications reliability is established
for the international financial sector. This standard is recognized with the similar stature of existing
core standards for the international financial sector (Appendix D).211 212

Voluntary implementation. Financial sector institutions, firms, markets and others voluntarily
implement the core standard to enhance the reliability of their international connectivity.

Decision support. The core standard is used to guide private sector investment, international
supervisory bodies and nation-state priorities.

211
e.g., the twelve core standards for Sound Financial Systems of the Financial Stability Board (Appendix X).
212
More specifically, the standard is recognized by the international financial sector supervisory bodies as best practices for
those that provide important international systemic functions that would affect global or significant institutional financial stability;
and by other critical global user communities and international service providers.

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5.7 Measurements for Stakeholder Due Diligence

Purpose
The Recommendation addresses the issue of how the undersea communications cable industry supports the needs of
its stakeholders by providing the information they need to manage their dependence on it.

Background
Throughout the world, many stakeholders are depending on the reliability of GUCCI. But the
dependence of some stakeholders stands out for its extremely high import. One such stakeholder is the
financial sector.213 In similarity to vital dependence of the transportation sector on fuel, and agriculture on
rain, the modern financial sector cannot operate without GUCCI.

As the financial services sector continues to evolve on a global basis, increased reliance on information
and communications technology (ICT) translates directly into increased reliance on undersea cable
infrastructure. Traditionally, the focus of resilient communications has been within a continent,
specifically, the “last mile” from the institution to the first node of a robust terrestrial network. Today’s
global markets are vitally dependent on resilient international connectivity. Major gains achieved in
reducing market risk through such mechanisms as automation and compressed settlement intervals are
offset by increased operational risks through increased dependencies on ICT in general, and undersea
cable infrastructure, specifically.214

Those responsible for overseeing their institution’s exposure to operational risk cannot perform due
diligence because there is insufficient information available.215 The fundamental information that is
needed centers around a statistically based expectation of downtime for international connectivity.216

There is basic lack of published, or otherwise available, information on GUCCI reliability for stakeholders
that play critical roles in societies around the world.217 This in turn prevents advanced analysis of outages
and trend information and the formulation of a coordinated response to resilience issues.

The time is right for a multi-national, cross-industry forum comprised of the

undersea cable infrastructure community, major enterprise customers, ISPs,
and data hosting centers that monitor their global infrastructure to develop
218
models for global infrastructure resiliency.

The implementation of Recommendations 4 and 5, Best Practices and Trusted Information Sharing, and New
International Governance, respectively, will create structure and spirit to enable this Recommendation to
succeed.219 Further, Recommendation 6, International Communications Infrastructure Standard for the Financial
Sector will be enabled by the implementation of this Recommendation.

213
Key Observation 9, Bank on It, Section 4.1.
214
Key Observation 10, “Snap to a Halt!”, Section 4.1.
215
Key Observation 16, Financial Sector Due Diligence, Section 4.1.
216
Key Observation 38, Statistical Analysis, Section 4.2.
217
Key Observation 17, Waiting, Section 4.1.
218
Makris, Spilios and Lordi, Nick, Undersea Cable System Outages and Global Infrastructure Resilience: A Discussion of
Issues in Managing Third-Party Expectations, Proceedings of the IEEE CQR International Workshop, 2009.
219
Key Observation 66, Competitive Differentiation, Section 4.3.

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Recommendation 7
The private sector should establish a method of providing basic reliability
performance statistics to stakeholders.

Required Commitment
To sustain the viability of The Recommendation, the private sector and stakeholders must be committed
to defined courses. Specifically,

 Stakeholders must maintain a proactive posture in engaging critical international infrastructure

partners.
 Private sector companies must be willing to share the outage information needed to support
overall GUCCI performance measurements, with appropriate non-disclosure agreement
protections.
 Existing industry fora must evaluate their charters, membership and commitments, in light of the
stakeholder and internal industry needs.
 Existing industry fora must, as appropriate, be either willing to make charter and membership
representation adjustments, or be supportive of sister organizations playing new complimentary
roles.
 Private sector companies must provide expert and leadership resources to champion new
governance functions.

Benefits of New International Governance

Stakeholders will have sufficient - and sufficiently clear - information regarding benchmark performance
levels for GUCCI, enabling them to perform due diligence in managing their operational risk. Industry
members will have improved effectiveness in cooperation, and have a unified voice when appropriate.
Existing industry fora can be more effective at fulfilling their current missions by channeling out-of-scope
issues (outside of their mission or realm of influence) to complimentary partners.

Alternative Approaches and Their Consequences

Alternatives to this approach include the following:

o Governments or stakeholders force the industry to report outages . . . resulting in unwanted regulation
and cost, inefficient use of expert resources as they are needed to support compliance fulfillment, and increased
defensive posturing by the industry.
o Outage analysis continues at the current limited practice . . . accepting suboptimum industry coordination
and limiting stakeholders’ ability to manage risks.

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Next Steps
Next steps to generate momentum toward the implementation of The Recommendation are suggested
below. This process should hold strict standards for the protection of commercial interests by
ensuring that no competitive disadvantage results from any part of it.220

7-1. The undersea communications industry should establish a trusted environment in which to
submit outage and other critical infrastructure reliability data. 221

7-2. The collected information should be aggregated at an industry level, where subject matter experts
from across the industry conduct joint analyses to determine statistically significant trends based on
historical events, and systematically assess intrinsic vulnerabilities that may pose latent reliability
challenges.222

7-3. The industry should provide a report on the “Health of Global Undersea Communications Cable
Infrastructure” to support its stakeholders. The Report should provide stakeholders with the essential
information that stakeholders need to perform risk management.223

7-4. Continuous improvement should be made for the steps above, increasing industry participation,
“peeling the onion” to study the next layer of problems, and confirming with stakeholders that their
need for basic information is being met.

Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Outage database. The industry sets up a database to collect outage information, ensuring that no
competitive disadvantage is gained from the process.

Joint analysis. Subject matter experts are lending expertise in collaborative efforts to understand
reliability influencers and suggest countermeasures.

Unified voice. The undersea communications cable industry produces an authoritative description
of its performance at a global level, satisfying stakeholder needs.

220
The existing trusted environment models referenced throughout the Report can be used to build confidence in the viability of
this approach.
221
Recommendation 4, Best Practices and Trust Information Sharing.
222
Section 3 provides a reference for these systematic intrinsic vulnerability analyses using the 8i framework.
223
Recommendation 6, International Communications Infrastructure Standard for the Financial Sector.

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5.8 Improved Cable Protection Agreements, Standards, Policies

and Regulations

Purpose
The Recommendation addresses the issue of how to provide better protection of deployed cable systems using available
or new policy instruments.

Background
The protection of undersea cables in international law is well established dating back to the 1880s.224
Cable protection laws have been updated with new policy at the international level.225 However, too often
there is not corresponding nation-state-level policy to match the priority established at the international
level. As a result, avoidable cable damage is routinely experienced.

Undersea communications cables are especially vulnerable in the transition from deep water to their
landing site.226 This is due to the shallow water and increased activity in these areas.227 It is therefore
imperative that these cables be supported with special protection in these particular areas.

Nation-states for the most part understand the importance of GUCCI to their economy and security.228
Much of the world’s most robust economic growth is taking place in regions where there is traditionally
less attention paid to critical infrastructure protection, though this is not a problem confined to emerging
market regions.229 Some countries are moving forward with an approach to define special areas for
undersea communications cable passage.230

Since the cable infrastructure may cross many borders, government guarantees that support infrastructure
reliability are needed. Ideally, these provisions would include policies ensuring that providers will have
timely access to restore a failed part of a system.231 232

Recommendation 8
Nation-state governments should implement best practices for protecting undersea
communications cables within their sovereign waters.

224
Key Observation 89, A History of Importance, Section 4.4.
225
Key Observation 82, UNCLOS, Section 4.4.
226
Key Observation 53, Landing Sites, Section 4.2.
227
Key Observation 60, Swelling Marine Activity, Section 4.2.
228
Key Observation 19, Nation-State Stakeholders, Section 4.1.
229
Key Observation 6, Traffic Growth Is Part of Development, Section 4.1.
230
Key Observation 96, Controlled Approaches, Section 4.4.
231
Resilient International Telecommunications Guidelines for the Financial Service Sector, Pacine, Wayne and Callahan, Roger,
Financial Service Sector Coordinating Council www.fsscc.org, 2009.
232
Key Observation, 90, It Needs Some Teeth, Section 4.4.

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Required Commitment
To sustain the viability of The Recommendation, nation-state governments and the private sector must be
committed to defined courses. Specifically,

 Nation-state governments must make the protection of undersea communications cable

infrastructure a priority.
 The private sector must assist the government in understanding the types of damage experienced.
 Governments must be able to improve their protection through effective policies and practices.233

Benefits of Improved Cable Protection ASPR

Benefits of the implementation of The Recommendation will include improved reliability due to better
cable protection and due to shorter time intervals when dealing with approvals for maintenance.

Alternative Approach and Consequences

Alternatives to this approach include the following:

o Do nothing, waiting for an event to occur and then reacting . . . forfeiting advantages that could have
been achieved with efficient government policy and practice.

Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

8-1. Nation-states and cable system operators should convene for the purpose of identifying best
practices among the represented governments. The private sector should articulate its needs and
explain the impacts when these needs are not met.

8-2. Agreement should be sought around the articulation of the best practices shared.

8-3. The best practices should be implemented by the governments participating in the process, then
also shared with governments not participating in the process.

Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Prioritized mission: Government agencies are aligned on the priority, policies and practices for
protecting undersea communications cable infrastructure.

Best practices: Governments have best practices guidelines to reference.

Practice speed. The government conducts its business in an efficient manner.

233
Key Observation 100, Eating Dust, Section 4.4.

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5.9 Government Inter-Agency Coordination for Undersea Cable

Infrastructure

Purpose
The Recommendation addresses the issue of how to transform the governments’ lack of inter-agency coordination
when it comes to policy for undersea cable protection.

Background
Effective and efficient government agency coordination is a challenge that has been around since
governments were first established. There are a number of challenges to overcome, including different
responsibilities, different – and sometimes conflicting – priorities and varying types of available resources.

While the inter-governmental coordination is also an area for concern, this Recommendation focuses on
the coordination within a single nation-state. The undersea cable industry is too often impacted by
government policies that impede its efforts to improve the reliability of its systems and services.234 One of
the primary causes of this is poor coordination among government agencies.235 It is understandable that
each organization will have its own primary interests, however, this often results in inconsistent policy,
confusion and delays.

There are no easy solutions. Drawing attention to this problem is a first step, but it must be followed with
commitments and actions for improvements to be realized. Some of the opportunities for progress may
lie in greater education and awareness among key policy makers and regulators, the quantification of the
negative impact of uncoordinated government and the private sector’s capture of the best practices for
this area, and public recognition of role model behavior.

The undersea cable industry’s frustration with the lack of intra-governmental coordination has in the past
been an accepted annoyance. However, as the importance of this international infrastructure becomes
more apparent, this avoidable barrier to reliability is increasingly unacceptable to the private sector as it
strives to improve the reliability of undersea communications cable systems.

Recommendation 9
Nation-state governments and the private sector should establish a best practice
model for undersea communications cable inter-agency coordination to ensure
consistent policies and practices.

234
Key Observation 97, Good Housekeeping?, Section 4.4.
235
Key Observation 79, Paperwork, Section 4.3.

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Required Commitment
To sustain the viability of The Recommendation, nation-state governments and the private sector must be
committed to defined courses. Specifically,

 Nation-state governments must make its oversight of undersea communications cable

infrastructure a priority.
 The private sector must assist the government in understanding its observed inconsistencies and
impact, and provide role model references.
 Governments must be able to improve their inter-agency coordination to provide consistent
policy and speedy implementation.

Benefits of Improved Cable Protection ASPR

Benefits of the implementation of The Recommendation will include improved reliability due to better
cable protection and shorter time intervals when dealing with approvals for maintenance.

Alternative Approach and Consequences

Alternatives to this approach include the following:

o Maintain status quo . . . GUCCI remains sub optimally managed as a critical nation-state asset.

Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

9-1. Nation-states and cable system operators should convene for the purpose of identifying best
practices among the represented governments. The private sector should articulate its needs and
explain the impacts when these needs are not met.236

9-2. Participants should seek agreements around the articulation of the best practices shared.

9-3. The best practices should be implemented, shared with governments not participating in the
process.

Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Inter-agency coordination: Government agencies are aligned on the priority, policies and
practices for supporting undersea communications cable infrastructure. 237

Policy clarity. The government and the private sector understand what the policies that affect
undersea communications cable industry are.

Authority exercised. Nation-states exercise their authority to ensure policies that will promote
undersea communications cable resilience.

Practice speed. The government conducts its business in an efficient manner.

236
Quantification of the affects of lack of government coordination may be a useful vehicle for conveying the importance of this
issue.
237
It is understandable that some practices may not be suitable for every situation.

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5.10 Education and Awareness of GUCCI Critical Role

Purpose
The Recommendation addresses the issue of how to address the profound gap between critical dependence and
awareness that stakeholders and the general public have regarding GUCCI.

Background
The world’s undersea communications cable infrastructure continues to operate at highly reliable levels
and continues to provide tremendous service to the daily operation and long-term growth of both
established and emerging economies in all parts of the world. GUCCI is an essential part of the modern
world.

However, there is a profound unawareness on the part of the general public, business enterprises, critical
sector stakeholders and government regarding their dependence on undersea communications cable
infrastructure.238 239 While the increasing rate of dependence climbs steeply, there is no corresponding
movement in consciousness of the dependence or the risks associated with it.240 It being imperfect, like
any other critical infrastructure, due consideration needs to be given to its priority in decisions affecting it,
ramifications of its failure and opportunities to promote its resilience.

There are times when the public is temporarily conscious of the importance of these cables.241 This is
during times when there are cable cuts that affect Internet service. Major or multiple cuts in one part of
the world can affect all parts of the world. The initial impact is typically during the first hours, until
manual re-routing can be engineered. Then the impaired throughput (slow Internet speed) is experienced
for days or weeks, depending on the event. In fact at least four incidents have had this effect in recent
years.242

Those most ‘in-the-know’ about how important this infrastructure is can be in a very difficult position.243
The traditional approach of ‘security through obscurity’ has been soundly outdated with the emergence of
the Internet. Broad and detailed information such as cable technologies, equipment manufacturers, cable
routes, repair ships, landing station sites, and more, are available for anyone with Internet access.244 What
has traditionally been a nation-state security issue has spilled far over into the laps of a much broader
community of stakeholders.245 246 247 The circumstances are compelling.248 New approaches are needed

238
Key Observation 1, Public Unaware, Section 4.1.
239
Key Observation 14, Two Modes of Awareness, Section 4.1.
240
Key Observations 5, User Expectations Are High, Section 4.1.
241
Some events even have unique Wikipedia entries for them, e.g., “2008 Submarine Cable Disruption.”
242
In order from most recent: August 2009 Typhoon Morakot, December – multiple cuts, 2008 Mediterranean Sea, January–
February Middle East, December 2006 Hengchun Earthquake, . . . each of these involved multiple simultaneous cable cuts.
243
Key Observation 98, Batten Down the Hatches, Section 4.4.
244
Key Observation 48, Information Smorgasbord, Section 4.2.
245
Key Observation 19, Nation-State Stakeholders, Section 4.1.
246
Key Observation 88, International Infrastructure, Section 4.4.
247
The author’s father worked on submarine cable system repeater systems at Bell Labs during the 1960s. The ability for these
repeater systems to identify the location of a cable cut from an adversary during the Cold War was of significant national
security interests.
248
Key Observation 22, 99+%, Section 4.2.

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that properly educate stakeholders to enlist them as allies, and that are also keen to protect their and
nation-state security interests.

Recommendation 10
The undersea communications cable industry should begin an outreach campaign
that provides appropriate education to government and other stakeholders regarding
GUCCI function in the stability of their operations.

Required Commitment
To sustain the viability of The Recommendation, the private sector and stakeholders must be committed
to defined courses. Specifically,

 The undersea communications cable industry must recognize the unacceptable nature of the
existing dependence-unawareness gap.
 The undersea communications cable industry must commit to action to resolve the under-
education of those dependent on it.
 Stakeholders must be diligent in achieving appropriate levels of knowledge regarding their
dependence and developing management best practices regarding their dependence on GUCCI.

Benefits of Education and Awareness of CUCCI Critical Role

Stakeholders will have the necessary awareness of their vital dependence on GUCCI. The needed context
will be provided for proper decision support for many waxing ASPR needs, such as improved cable
protection, regional negotiation and investment in physically diverse cable routes, emergency preparedness
for hostile maritime crises, and need of a back up plan for catastrophic loss of GUCCI.

Alternative Approaches and Their Consequences

Alternatives to this approach include the following:

o Incomplete or otherwise ineffective education campaign . . . will provide a different, inappropriate

perception.
o Security through obscurity . . . will fail as extensive information is already in the public domain and potential
adversaries to GUCCI stability tend to be highly technical.249 250 251

249
Appendix B.
250
Gambetta, Diego, and Hertog, Steffen, Engineers of Jihad, Sociology Working Papers, Paper Number 2007-10, University of
Oxford, 2007.
251
Key Observation 100, Eating Dust, Section 4.4.

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Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

10-1. The private sector should assess the education gap and develop a countermeasure strategy,
which includes the main messages.

10-2. Existing industry fora should agree on what role each can play in implementing the strategy.

10-3. Stakeholders should develop a metric to measure progress in achieving critical awareness
objectives.

10-4. The private sector should work together to update the educational strategy, program and
messages, as appropriate.

Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Education strategy. The private sector develops an educational outreach program.

Stakeholder commitment. The stakeholder community establishes objectives for achieving

awareness of dependence and identifies best practices for managing its dependence.

Gap removed. The dependence-unawareness gap regarding dependence on undersea

communications cable infrastructure is removed.252

252
Key Observation 1, Public Unaware, Section 4.1.

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5.11 Mechanisms for Handling Overload Demand

Purpose
The Recommendation addresses the issue of how to prepare for traffic overload scenarios for the global undersea
communications cable infrastructure.

Background
The current situation is one in which there is considerable “unlit” spare capacity on fibers within the
GUCCI.253 In addition, technological advances have enabled deployed systems to be used to deliver much
greater bandwidth than they were originally designed, and ongoing research promises continued advances
in this area.254 255 256 257 There is no immediate alarm regarding existing capacity availability.

However, there are several reasons for increased vigilance regarding future infrastructure congestion.258
First, an ever-present, intrinsic vulnerability of any communications system, network or infrastructure is its
finite capacity limitation for payload throughput. Second, the world is currently experiencing an explosive
rate of increasing demand for bandwidth, consuming spare capacity at an aggressive pace.259 Third, the
nature of the traffic is very different today. What used to be primarily voice or message content of fixed
size, is more and more becoming image and video content of nondeterministic (but very large) size.
Fourth, with the viral phenomenon of some new applications and global connectivity, there is no
guarantee that the rise in user demand based on these types of services will allow the spare capacity buffer
levels we are used to.260 For example, a major disaster or other scenario may trigger end user activity (e.g.,
sharing videos) that presents an aggregate payload above maximum capacity limits over an extended
period of time. Fifth, a cyber attack could unleash volumes of traffic or affect network control channels,
resulting in overload conditions. Finally, a loss of satellite or a significant portion of terrestrial
infrastructure could place significant expectations on GUCCI. In light of these factors, an overload
condition is a very real scenario, which may present itself intermittently in unexpected fashion, or as a
temporary situation due to a specific event.

Terrestrial networks have anticipated the need for managing overloads with the deployment of various
mechanisms. Prioritization schemes are one such mechanism.261 The International Telecommunications
Union - Telecommunications Standardization Sector (ITU-T) supports an international standard with a
five-tiered prioritization scheme.262 These mechanisms enable governments to authorize users for priority
treatment. While initially developed for basic voice calls, they currently extend to data and video
applications. Service providers can provide another type of prioritization in the form of a service level
agreement (SLA), whereby an end-user subscribes to a special premium service that ensures a specified

253
Key Observation 76, Spare Capacity, Section 4.3.
254
Key Observation 27, DWDM, Section 4.2.
255
Key Observation 28, Protocol Soup, Section 4.2.
256
Key Observation 31, Heavy Light Technology, Section 4.2.
257
Key Observation 40, Heroic Technology Breakthroughs, Section 4.2.
258
Key Observation 65, Nothing But Time, 4.3.
259
Key Observation 4, Bandwidth Thirst Management, Section 4.1.
260
Key Observation 7, Everybody Wants It, Section 4.1.
261
Government Emergency Telecommunications Service (GETS) is deployed in the U.S. to provide government-authorized
users priority treatment between access points; whereas Wireless Priority Service (WPS) provides similar treatment over the air
loop between a mobile subscriber and the cell tower.
262
Emergency Telecommunications Service (ETS) and International Emergency Preference Scheme (IEPS).

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level of performance. Both of these are examples of how limited capacity is allocated along
predetermined arrangements.

In summary, GUCCI has limited capacity and it is conceivable that, like its terrestrial cousin, it may be
impaired by overload conditions. How should limited capacity be managed? How can international
coordination ensure that the communications most critical for continued government operation and
security be maintained?

Recommendation 11
Network operators, service providers and stakeholders should develop and implement
agreed upon mechanisms for handling traffic overload conditions for undersea
communications cable infrastructure.

Required Commitment
To sustain the viability of The Recommendation, nation-state governments and the private sector must be
committed to defined courses. Specifically,

 Nation-state governments must agree that some communications are more important than others
and therefore require preferential treatment during times of infrastructure congestion.
 Nation-state governments must agree with each other on mutual preferential treatment of so
designated traffic.
 Nation-state governments must provide incentives for private sector development and
deployment of priority schemes.
 Nation-state governments, stakeholders, network operators and service providers must securely
manage the administration of authorized priority traffic.
 Service providers and network operators must implement agreed-upon overload management
mechanisms.

 
Benefits of Mechanisms for Handling Overload
When implemented, The Recommendation will provide a mechanism to ensure that the most important
traffic is carried over undersea communications cable infrastructure that is congested.

Alternatives Approaches and Their Consequences

Alternatives to this approach include the following:

o Rely upon ability to maintain a sufficient buffer of spare capacity . . . will result in indiscriminate
blocking of traffic when overload conditions occur, as the statistical variability is ever more difficult to engineer for.
o Discourage use and dependence on global connectivity . . . would be cause for profound disadvantage to a
nation-state in terms of technological and economic development.
o Maintain the current course . . . requires accepting indiscriminate loss of traffic when overload conditions are
presented, acknowledging loss of critical communications.

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Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

11-1. The international financial community should determine the sufficiency of existing congestion
management options, including SLAs, in order to determine whether due diligence for operational risk
can be achieved, or new mechanisms are needed.

11-2. Nation-state governments should establish international agreements around GUCCI congestion
management policies and practices.

11-3. Governments should provide appropriate incentives for the development and deployment of
agreed upon mechanisms to manage overload conditions in GUCCI.

11-4. Standards development organizations (SDOs) should include GUCCI considerations in their
ongoing deliberations.

Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Overload Strategy: Stakeholders have an established strategy for effectively handling GUCCI
congestion scenarios.

International Cooperation: Nation-state governments establish agreements on the

coordination of priorities when overload conditions are present in GUCCI.

Priority Communications: GUCCI is robust in ensuring that the most important

communications are carried during the stresses of congestion.

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5.12 Recognize GUCCI Catastrophic Loss As a Grand Challenge

Purpose
The Recommendation addresses the concern of preparing for a large-scale loss of the world’s undersea
communications cable infrastructure, by directing stakeholders to prepare for the worst case scenario and by
calling on the scientific and engineering community to respond to a new grand challenge problem.263

Background
Nearly 100% of the world’s inter-continental electronic communications traffic is carried by the undersea
cable infrastructure.264 265 There is no back-up capability should it be lost.266 Satellite capacity, if not
carrying its existing traffic, would have carrying capacity two orders of magnitude too small. 267 268
Terrestrial based routes would leave continents in isolation.269

The probability of such a failure is very low, however, it is not zero.270 271 The impact of such a failure on
international security and economic stability could be devastating. The pace at which technology has been
adopted and then depended upon is unprecedented in history. It is unclear if civilization can recover to its
previous condition from the failure of a technology that has been so rapidly adopted without a back-up
plan.272 Without GUCCI, the world’s economic financial market would immediately freeze.273 But what
would happen next? What are the options? What can be done to best prepare for this unlikely, but
possible event?

Recommendation 12
Subject Matter Experts and Stakeholders should prepare for the worst-case scenario
of a catastrophic loss of global undersea communications infrastructure by identifying
best available alternatives and operational procedures. Preparation should include
scientific and engineering research for long-term solutions.
 

263
A grand challenge is a fundamental problem in science or engineering, with broad applications. The fundamental physical
sciences, engineering, and mathematical underpinnings are similar for many of these problems. Examples of grand challenges
are: more efficient automobiles and airplanes, improved environmental modeling, understanding the structure of biological
molecules. A Research and Development Strategy for High Performance Computing, Executive Office of the President, Office
of Science and Technology Policy, November 20, 1987.
264
Key Observation 3, Heads in the Clouds, Section 4.1.
265
Key Observation 22, 99+%, Section 4.2.
266
Key Observation 58, No “Plan B”, Section 4.2.
267
Key Observation 23, Alternatives Are Not Up in the Air, Section 4.2.
268
Key Observation 24, Payload Volume, Section 4.2.
269
Australia; North America from Europe and Asia, etc.
270
Key Observation 50, Looking Backwards, Section 4.2.
271
Key Observation 51, Intrinsic Vulnerability Approach, Section 4.2.
272 st
Kissinger, Henry, Does America Need a Foreign Policy? Toward a Diplomacy for the 21 Century, September 2002.
273
Key Observation 10, “Snap to a Halt!”, Section 4.1.

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Required Commitment
To sustain the viability of The Recommendation, governments and the private sector must be committed
to defined courses. Specifically,

 Governments and other stakeholders must encourage academic and private sector research to
ensure appropriate resources are focused on this global challenge.
 Scientists and engineers must be devoted to developing alternatives.
 Stakeholders must conduct planning scenarios that consider true worst-case scenarios.
 The financial services sector must play a lead role in establishing the importance of this concern.

Benefits of a Recognizing GUCCI Catastrophic Loss As a Grand Challenge

When followed, The Recommendation will provide a benchmark understanding of the impact of
catastrophic GUCCI failure and guidance on best alternatives and procedures in such a situation. It
should spark new long-term research for alternatives to the current dependence. In addition, critical
stakeholders will be more informed of the very low probability - yet possible – risk of GUCCI failure.
Consequently, stakeholders can be prepared for the worst-case scenario.

Alternatives Approaches and Their Consequences

Alternatives to this approach include the following:

o Minimize public awareness of the issue by limiting research and discussion of issue to closed
forums . . . resulting in a less rigorous effort and limited stakeholder planning.
o Discourage use and dependence on global connectivity . . . would be cause for profound disadvantage to a
nation-state in terms of technological and economic development.274
o Maintain the current course . . . passively promoting increased global dependence on global infrastructure, with
the anticipated ramifications being higher likelihood of catastrophic loss of global or regional connectivity.

Next Steps
Suggested next steps to generate momentum toward the implementation of The Recommendation
include:

12-1. Governments, industry associations and academic and other research institutions should initiate
strategic programs to address the current preparedness gap.

12-2. The international financial community should coordinate its plans for the case of a catastrophic
loss of GUCCI.

12-3. The scientific and engineering community should publish analyses of near and long-term
alternatives, highlighting promising, emerging technologies.

274
There is an abundance of studies that correlate economic growth with ICT as an essential enabler.

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Measures of Success
The successful implementation of The Recommendation can be gauged by the following measures:

Stakeholder preparedness: Stakeholders coordinate planning with international counterparts

and establish procedures for catastrophic GUCCI failure. Such planning includes agreed to
expectations for roles, activities and associated time intervals of each critical party.

Scholarly publications: Technically authoritative guidance is made available to the general

public, government and other stakeholders regarding limitations and emerging possibilities.

Long term alternative: An acceptable back up solution is developed that offsets the existing
complete dependence on GUCCI for intercontinental electronic communications.

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6. SUMMARY
The ROGUCCI process introduced a fresh perspective on undersea cable infrastructure. What was new
was taking a global view of all the intercontinental connectivity and treating it as an aggregate critical
international infrastructure. It also charted a new course for conducting systematic research of the
infrastructure’s eight ingredients using the 8i Framework. This, coupled with the intrinsic vulnerability
approach, enabled a comprehensive analysis of what could go wrong with GUCCI – looking beyond what
had has been experienced to date. The process also went beyond the norms of association in convening
the industry’s technical, business and legal expertise with stakeholders and international policy change
agents. This ROGUCCI “formula” played a critical role in the development of the guidance outlined in
this report.

The next steps of the ROGUCCI process are the dispatch of this report and the call to the private sector,
academia, nation-states and other stakeholders, to initiate the implementation of The Recommendations.
The Study, Summit and Report are not designed to be limited to discussion. Rather, their intent is to have
a significant impact on the reliability of GUCCI. To this end, each of the Twelve Recommendations is
carefully prepared to present in concise executive fashion, the problem, recommendation, required
commitment, alternatives and their consequences, benefits, next steps, and measures of success.

Both the IEEE and EastWest Institute intend to continue to serve as catalysts for mobilizing resources to
implement The Recommendations. However, the challenge is for individuals, organizations and industry
associations to take up and forge ahead. Early briefings of the ROGUCCI Recommendations are very
encouraging, as enthusiastic responses from the private and public sector have been witnessed from six
continents.275

The IEEE will maintain a ROGUCCI web site to provide updates on progress being made for each of
The Recommendations and for members of the community to sustain online forum discussions.276

On behalf of the countless individuals and organizations that depend upon highly reliable, robust, resilient
and secure global communications, the author wishes to express appreciation one more time to the many
who have brought GUCCI to the performance level that has been so attained to date . . . and to thank in
advance, the many who will step up to the challenges laid out herein to ensure that GUCCI breaks
through the current limitations to achieve the new benchmark performance levels that are needed.

275
One such briefing included a presentation to the EastWest Institute “Cyber 40”, hosted at the Canadian Embassy in
Washington, D.C. on the 19th of April, 2010.
276
www.ieee-rogucci.org

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7. ACKNOWLEDGEMENTS
The ROGUCCI project would not have been possible without the contributions of the many individuals and
organizations that have lent expertise, offered insights, shared concerns and offered tangible support. While the
contributing organizations are listed in Table 5 of Section 2.8, the author recognizes contributions here at an
individual level.

IEEE Leadership and Staff

Communications Society presidents: Dr. Curtis Siller (emeritus) for counsel and networking, Dr. Byeong
Gi Lee (2010) for encouragement and support, and Dr. Doug Zuckerman (2009) for openness and
flexibility; executive director Jack Howell for availability of society resources and coaching, Deborah
Kingston for Summit planning support, Carole Swaim for filling in where needed, David Alvarez, Matt
Sielski and Max Losk for web design and support; IEEE CQR Chair Dr. Chi-Ming Chen (AT&T), (“The
Chief”) for long term coaching and support. IEEE local chapter president Dr. Eesa Bastaki for his warm
welcome

EastWest Institute Leadership and Staff

Founder and president John Edwin Mroz for vision for improving cyber space, openness to bold ideas
and challenges, and for serving as Global Summit Council Chairman; chairman Francis Finlay for his
support during the Global Summit and for serving as a force in follow-up activities, Dr. Greg Austin for
continuous enthusiasm and encouragement, Vartan Sarkissian for senior business experience and
friendship, board members Jim Lash, Henrik Torgersen and General (ret.) Ehsan Ul Haq for their interest
and perspectives, Andy Nagorski and Sarosh Syed for assistance in communications and outreach, and
Anneleen Roggeman for flexibility to join Summit program team on last minute notice.

U.S. Federal Reserve Board of Governors

Chairman’s Chief of Staff Stephen Malphrus and senior interagency advisor Wayne Pacine for their
partnership throughout this project and their commitments promoting optimally reliable international
communications critical infrastructure, Eric Hainzer for this steadfast support of the project and
innovation in seeking new approaches, and Debra Orock for her willingness to support in whatever ways
possible.

Dubai International Financial Centre

Chief economist Dr. Nasser Saidi for his thought leadership and hosting of the Summit, ICT
infrastructure director Mohammed Sabunchi for his presentation of the DIFC as an world class venue to
host the Summit, Natalie Baydenko, Dalia Lahham, Brendan Ryan, Souheir Misto and Azza Al Sajdi for
their support, and Shaima Omar Al Zarouni for her high standards of excellence in hospitality and event
management for the Global Summit.

Dubai Financial Service Authority

Managing director of supervision Mike Zamorski for his relentless support of the Summit and for lending
his vast knowledge of the inter-workings of the complex international financial services sector, Paul
Koster and Tony De Cristofano for their support.

International Cable Protection Committee

Chairman Mick Green and secretary Graham Marle for their support throughout the process.

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U.A.E. Telecommunications Regulatory Authority

U.A.E. Ambassador to the U.S. Al Otaiba for his support of the Global Summit, Khalid Belhoul for his
support of the Summit as U.A.E. host, and Abdulrahman Y. Al Naser for providing special post-event
outreach of the ROGUCCI Summit in the region.

E-Marine
CEO Omar Jassim Bin Kalban for his hospitality, Mohamed Shameer for his logistics support for a
wonderful cable ship tour and for his photography. . . . and Tyco’s Jim Herron for supporting planning
for the cable ship tour.

For the subject matter experts who served as ingredient leaders

Dr. Lionel Carter of Victoria University, Richard Freeman of Telstra, Richard Krock of Bell Labs (Alcatel-
Lucent), Dr. Nick Lordi of Telcordia Technologies, Goff Hill of GTel Consultancy, Peter Cornell of
AT&T, Stu Goldman of Bell Labs, John Harrison of LanditD, and Mick Green of ICPC and BT.

TeleGeography
Alan Mauldin for his research support, Tim Stronge and Mike Owings for their sponsorship support.

Alcatel-Lucent Submarine Networks

Nigel Weaver, Pierre Aussant, Michel Bouvard and Jose Chesnoy for their insights and technical
excellence.

Researchers
BPI TelcoData president Art Menko, Rutgers professor Dr. Mike Tortorella and Telcordia Technologies
Dr. Spilios Makris, Dr. Nick Lordi and Dr. Gail Linnell, and Harvard graduate student Steve Secrhist.

Summit program operations team

Rick Krock, Stuart Goldman and Dr. Anil Macwan

Global Summit Participants not elsewhere mentioned

Ibrahim Alshamsi, Elijah Bass, Nigel Bayliff, Tim Bie, Peter Brouggy, Roger Callahan, Stephen Drew, Eric
Dunand, Andres Figoli, Peter Howard, Kwong Cheung Lau, John Mariano, Dr. Maneck Master, Robert
Schellman Jr., Susan Shen, Paul Stoddart, Giuseppe Valentino, Andy Yates, Siu Keung Yiu and Junke
Zhang.

Report Proof Reading

Rick Krock and Bridget Erlikh.

Porthcurno Telegraph Museum

Director Libby Buckley for insight into the significance of the ROGUCCI undertaking, for serving as
ROGUCCI Global Summit curator and for her excellent photography

Family
Finally, my father, Joseph Rauscher Sr. (ret. Bell Labs submarine cable engineer and researcher) who made
science and engineering interesting to the sons he raised; and for my son, Konrad who prepared the
Acronym section of this Report and for making a memorable trip to Dubai; daughter Mercy for her
assistance with special photography, and daughter Grace and niece Kimberly for editing; and my wife
Laura, for her incredible patience with her husband’s intense pursuits.

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8. ACRONYMNS
8i Eight Ingredient Framework for Information and Communications Technology
Infrastructure
ARECI Availability and Robustness of Electronic Communications Infrastructure Study
ASPR Agreements, Standards, Policies and Regulations
BU Branching Unit
BUTEC British Underwater Test and Evaluation Centre
C The speed of light, a constant
CQR IEEE Technical Committee on Communications Quality & Reliability
CNI: Critical National Infrastructure
CCTV Closed Circuit Television
CS Cable Ship
DCN Digital International Switching Centre
EC European Commission
EDFA Erbium Doped Fiber Amplifier
EEZ Exclusive Economic Zone
EMP Electromagnetic Protection
ETS Emergency Telecommunications Service
EWI EastWest Institute
DIFC Dubai International Financial Centre
FCC Federal Communications Commission (U.S.)
FRB Federal Reserve Board (U.S.)
FSSCC Financial Services Sector Coordinating Council
FEC Forward Error Correction
G.652 ITU recommendation number for standard single mode fiber
GETS Government Emergency Telecommunications Service (GETS)
GUCCI Global Undersea Communications Cable Infrastructure277
HF High Frequency
ICT Information and Communications Technology
ICPC International Cable Protection Committee
IEPS International Emergency Preference Service
277
This term was introduced by the ROGUCCI process, which introduced the global aggregate perspective of the infrastructure.

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IEEE Institute of Electrical and Electronics Engineers

IP Internet Protocol
ISR International Simple Resale
IRU Indefeasible Right to Use
ITU International Telecommunications Union
ITU-T International Telecommunications Union – Telecommunications
LASER Light Amplification by Emission of Radiation
MENOG Middle East Network Operators Group
NOC Network Operations Centre
NRIC Network Reliability and Interoperability Council
NRSC Network Reliability Steering Committee
NSTAC The U.S. President’s National Security Telecommunications Advisory Committee
NPE Network Protection Equipment
PC Personal Computer
PDH Plesiochronous Digital Hierarchy
PFE Power Feed Equipment
Psi Pounds per square inch
RFS Ready For Service
ROGUCCI Reliability of Global Undersea Communications Cable Infrastructure
SDH Synchronous Distribution Hierarchy
SLTE Sub-sea Line Terminating Equipment
SMP Significant Market Player
SONET Synchronous Optical Network
STM Synchronous Transport Module
TMN Telecommunications Management Network
UAV Unmanned Aerial Vehicle
UNCLOS (The) United Nations Convention on the Law of the Seas
VoIP Voice over Internet Protocol
VPN Virtual Private Network
WDM Wavelength Division Multiplexing
WPS Wireless Priority Service

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9. Glossary of Key Terms

Availability
Availability is simply the extent to which a system is ready to be called into use for its designated purpose, without
advance knowledge of when it is needed. In The Study, the system is the global undersea communications cable
infrastructure, which is the aggregation of individual long haul fiber optic undersea cable systems. A more formal
definition of availability is offered as follows:
 
The degree to which a system, subsystem, or equipment is operable and in a
committable state at the start of a mission, when the mission is called for at an
278
unknown, i.e., a random, time.
 
Infrastructure, network or service availability characterizes the infrastructure, network or service being operable for
use, as intended, at any given instant. It is a function of the underlying system(s) reliability, robustness of technology
and design and reparability or restorability. Network design includes appropriate redundancy, alternate routes and
sufficient or additional capacity. Availability is expressed in multiple ways, such as, the duration of time, the
probability, and the percent of time, that the network is operable. Conversely, the time per interval during which the
network is inoperable (i.e., unavailability) sometimes is the indirect measure of availability. The duration of (operable
or inoperable) time may be continuous or non-continuous.
 
Total  Time  Available    =    TA      =    ∑TOperable(i)  i  
 
Total  Time  Unavailable      =    TU      =    ∑TInoperable(  j  )  j  
 
Availability    =      TA          /    (TA  +TU  )  
 
Unavailability    =    TU    
where  
 
TA    +  TU    =    Total  Time  Interval  =  TI  
 
 

For example, current system platforms are commonly described as ‘highly available’ if they are operable at least “five-
nines” (e.g., 99.999% or better). This corresponds to 5.2 minutes of cumulative inoperable or downtime, per year.

Backhaul
Connection from the landing station back to the terrestrial network.

Critical Communications Infrastructure

There are specialized Best Practices for reliability when dealing with high and ultra-high reliability systems, such as
critical communications infrastructure. Because of the complex, sensitive and proprietary nature of this subject,
critical communications infrastructure is generally best defined by its owners and operators. Generally, such
distinction applies to points of concentration, facilities supporting high traffic, and network control and operations
centers, and equipment supplier technical support centers. The first two of these criteria apply for GUCCI.

Dark fiber
Fiber that is deployed but not yet being used.

278
ATIS Telecom Dictionary. www.atis.org

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Dominant Technology Issues

Those technology issues that have the most impact on GUCCI.

Outage
A condition in which a user is completely deprived of service by the system. For a particular system or a given
situation, an outage may be a service condition that is below a defined system operational threshold, i.e., below a
threshold of acceptable performance.279

Private Circuits or Leased Lines

A point-to-point private line subscribed to by an organization to provide communications services between sites.

Reliability
Reliability is simply the likelihood that a system will perform its intended function within the context it was designed
to operate within.280

A measure that refers to a particular “mission.” It represents the ability of the system, subsystem, equipment,
network, or service to operate for the intended purpose, during the intended period of time. It is the probability that
given operability now, it sustains operation for a period of time. For example, the reliability of the space shuttle
would refer to it’s operability during the period of time that includes its launch, time in space and return to Earth.
Thus, reliability is often characterized as a probability or percent or may also be characterized as the Mean Time
Between Failure (MTBF).

The ability to achieve high availability is also a factor of how quickly a system, subsystem, equipment, network, or
service can be repaired or service restored when a failure occurs. Reparability or Restorability are respectively
characterized by the Mean Time To Repair or Mean Time To Restore (MTTR). First and foremost is the return to
operability of the intended function. This may occur through an equipment repair, or more likely an equipment
substitution, redundancy or alternate means for the intended use. Hence, in communications infrastructure, Mean
Time to Restore (service) is most often the key measure.

Robustness
Robustness is the property of being strong and healthy in constitution.281 It is further defined as a condition of a
system design “that remains relatively stable, with a minimum of variation, even though factors that influence
operations or usage, such as environment and wear, are constantly changing.”282 Robustness is the degree to which a
system or component can function correctly in the presence of invalid inputs or stressful environment conditions.283

Other definitions vary in (a) the emphasis they place on where the challenges come from - internal (e.g., component
failure) or external (e.g., environmental), (b) the degree to which such challenges are anticipated - ranging from
conditions slightly beyond what is expected to anything unexpected, and (c) the level of stability of functionality
maintained during the period of stress. For the purpose of The Study, the robustness of undersea communications
cable infrastructure includes:
• the ability to maintain critical functions, but not all functions
• in the context of both internal and external challenges
• when the challenges are of any degree of variability from expected conditions, but that expectations should
diminish with increased stress (e.g., a more robust system can handle more extreme forms of stress)

279
ATIS Telecom Glossary 2000, T1.523-2001, www.atis.org/tg2k/
280
A more formal definition from the ATIS Telecom Glossary. reliability: 1. The ability of an item to perform a required function
under stated conditions for a specified period of time. 2. The probability that a functional unit will perform its required function for
a specified interval under stated conditions. 3. The continuous availability of communication services to the general public, and
emergency response activities in particular, during normal operating conditions and under emergency circumstances with
minimal disruption.
281
wordnet.princeton.edu/perl/webwn.
282
www.onesixsigma.com/tools_resources/glossary/glossary_r.php
283
Institute of Electrical and Electronics Engineers. IEEE Standard Computer Dictionary: A Compilation of IEEE Standard
Computer Glossaries. New York, NY: 1990.

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Sector
A group of industries or infrastructures that perform a similar function. In general, critical sectors are sectors whose
incapacitation or destruction would have a debilitating impact on the national security and the economic and social
well-being of a nation.284

Shared Ownership
Cable consortia share the ownership of cable systems and have agreements about how capacity usage will be shared.

Shunt Fault
A condition where the cable system has sustained damage to its protection insulating sheath, but is still able to
maintain potential to continue operating. The virtual earth position is established at the damaged location. Repairs
need to be conducted rapidly, because a second damaged location would mean a loss of potential, resulting in an
outage.

Threat
A threat is an attempt to exploit one or more vulnerabilities that may result in damage to, or compromise of, a
system (e.g., GUCCI), or some portion of it.285

Vulnerability
A vulnerability is an intrinsic characteristic of an infrastructure or system (e.g., GUCCI or its components) that make
it susceptible to damage or compromise if exploited by a threat.

284
International Critical Information Infrastructure Protection (CIIP) Handbook 2004, , An Inventory and Analysis of Protection
Policies in Fourteen Countries, Swiss Federal Institute of Technology, p. 227. Network Reliability and Interoperability Council VI,
Homeland Security – Physical Security (Focus Group 1A) – Prevention and Restoration Report, Issue 2, Mar. 2003, pp.27, 41,
www.nric.org/fg/nricvifg.html; Network Reliability and Interoperability Council VI, Homeland Security – Physical Security (Focus
Group 1A) – Final Report, Issue 3, Dec. 2003, www.nric.org/fg/nricvifg.html; Network Reliability and Interoperability Council VII,
Focus Group 3A – Wireless Network Reliability – Final Report, Issue 3, Sept. 2005, www.nric.org/fg/index.html; Network
Reliability and Interoperability Council VII, Focus Group 3B – Public Data Network Reliability – Final Report, Issue 3, Sept.
2005, www.nric.org/fg/index
285
Network Reliability and Interoperability Council VI, Homeland Security – Physical Security (Focus Group 1A) – Prevention
Report, Issue 1, Dec. 2002, p. 27, www.nric.org/fg/nricvifg.html;

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10. REFERENCES

12 Key Standards for Sound Financial Systems, Financial Stability Board,

www.financialstabilityboard.org/cos/key_standards.

Alliance for Telecommunications Solutions (ATIS) Network Reliability Steering Committee, www.atis.org.

Asia Communications Hit by Quake, BBC News, December 27, 2006.

Asma Ali Zain, Cable damage hits 1.7m Internet users in UAE, Khaleej Times, February 5, 2008.

ATIS Telecom Dictionary, www.atis.org .

Ayadi, A. et. al., Strong Algerian Earthquake Strikes Near Capital City, Eos, Vol. 84, No. 50, December 16,
2003.

Bad Weather Obstructs Pakistan's Fiber Optic Cable Repair Work, Pakistan Times Staff Report, July 5, 2005.

Barthold, Jim, Submarine Cable to Find Northwest Passage, Suite101.com, January 17, 2010.

Bishop, David, Architects of the Internet: Speeding Net Traffic with Tiny Mirrors, EETimes, September 2000.

Borland, John, Analyzing the Internet Collapse: Multiple Fiber Cuts To Undersea Cables Show The Fragility Of The
Internet At Its Choke Points, Technology Review (MIT), February 5, 2008.

Burnett, Douglas R. and Mick P. Green, Security of International Submarine Cable Infrastructure: Time to Rethink?.

Burton, Kevin; McGee, Angela; Dibeler, Jack, Who Turned Out the Light? Burton Asset Management, 2009.

Cable-Cutting in War Time , The Pall Mall Gazette, May 11, 1898.

Cable Fault Cuts off West Africa, BBC News, July 30, 2009.

Cheng, Jacqui, Phishing Plumbs New Depths: Vietnamese Fishermen Sever Fiber Optic Lines,
www.Arstechnica.com, June 8, 2007.

Chesnoy, Jose, Undersea Fiber Communications Systems, Academic Press, London, 2002.

China Institute for Marine Affairs (CIMA) and Center for Ocean Laws and Policy (COLP) Regional
Workshop on Submarine Cables Workshop Report, Beijing, PR China, May 2009.

Choe Sang-Hun; Arnold, Wayne, Asian Quake Disrupts Data Traffic, The New York Times, December 28,
2006.

Etisalat Management Recognizes Bravery of E-Marine Cable Repair Crews - E-Marine Heroes Successfully Restore
Internet Connection to the Gulf, www.etisalat.ae, 9 March 2008.

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Fried, Malcolm; Klemming, Lars, Severed Cables in Mediterranean Disrupt Communication (Update4),
www.Bloomberg.com, December 19, 2008.

Gambetta, Diego; Hertog, Steffen, Engineers of Jihad, Sociology Working Papers, Paper Number 2007-10,
University of Oxford, 2007.

Green, Green, ICPC Presentation to the ROGUCCI Global Summit, October 19, 2009.

Harrison, John; Hill, G, Todd, M., ROGUCCI White Paper on Best Practices and Trusted Information Sharing,
Landitd, U.K. 2010.

Hayyan, Faisal, Task to Detect Major Fault in Pakistan's Internet Cable Set Off, Pakistan Times, July 2005.

Heng, Ek, Typhoon Morakot Damages Several Subsea Cable Systems, www.Telecomengine.com, August 19, 2009.

Ho, Victoria, Typhoon Knocks Out Asia Telecom Cable, CNet News, August 13, 2009.

Holding, Cathy, A Global Cable Network of Fragile Links, The Independent (UK), March 10, 2009.

Hong Kong Rebounding from Recent Natural Disasters Typhoon Morakot and Earthquake, HKCOLO, October
2009.

Kissinger, Henry, Does America Need a Foreign Policy?, Touchstone, 2002.

Krangel, Eric, Egypt Goes Dark: Mediterranean Data Cables Toast, www.BusinessInsider.com, December 19,
2008.

Long, Ronán,; Moore, John Norton Moore; Nordquist, Myron H. and Wolfrum, Rüdiger; Legal Challenges
in Maritime Security. Martinus Nijhoff Publishers, 2008.

Makris, Spilios and Lordi, Nick, Undersea Cable System Outages and Global Infrastructure Resilience: A Discussion
of Issues in Managing Third-Party Expectations, Proceedings of the IEEE CQR International Workshop, 2009.

Malphrus, Stpehen, Keynote Address at ROGUCCI Global Summit, Dubai, U.A.E., October 19, 2009.

Mydans, Seth, The Day the Pixels Froze: When a Digital World Was Stopped by a Natural Disaster, The New
York Times, December 28, 2006.

NRSC 2006-2007 Biennial Report, Alliance for Telecommunications Industry Solutions (ATIS) Network
Reliability Steering Committee (NRSC), Washington, D.C., 2008.

Next Generation Networks (NGN) Task Force Report, The President’s National Security Telecommunications
Advisory Committee (NSTAC) 2006.

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(CQR) International Workshop, www.comsoc.org/~cqr.

Proceedings of Worldwide Security Conference 7, EastWest Institute, Brussels, February 2010.

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Rasheed, Omair, Standby Net Arrangements Terminated in Pakistan,

Pakistan Times, July 6, 2005.

Rahmna, Sayeed, Bangladesh Submarine Cable Link Sabotaged Sgain, www.Groundreport.com, November 13,
2007.

Rauscher, Karl F., European Commission Availability and Robustness of Electronic Communications Infrastructure
(ARECI) Report, March 2007.

Rauscher, Karl. F., Protecting Communications Infrastructure, Bell Labs Technical Journal Homeland Security
Special Issue, Volume 9, Number 2, 2004.

Reardon, Margeurite, How Secure is the U.S. Communications Network?, CNet News, April 13, 2009.

Reliance Takes Silk Road to China, www.Lightreading.com, August 26, 2009.

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of Science and Technology Policy, November 20, 1987.

Saidi, Nasser, Keynote Address at ROGUCCI Global Summit, October 2009.

Singel, Ryan, Fiber Optic Cable Cuts Isolate Millions From Internet, Future Cuts Likely, Wired Magazine, January
31, 2008.

Steinglass, Matt, Undersea Cable Thieves Slow Vietnam's Internet Access, VOA News.com, June 1, 2007.

Submarine Cable: IT Ministry Preparing Load-Sharing Plan, Pak Tribune, February 14, 2006.

Taiwan Quake Causes Net Blackout, Reuters. December 28, 2006.

TeleGeopraghy Submarine Cable Maps, 2008, 2009, 2010.

Zain, Asma Ali, Cable Damage Hits 1.7m Internet Users in UAE, Khaleej Times, February 5, 2008.

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APPENDIX A. Analysis of Recent Major Outage Events

Undersea communications cable systems are designed to be highly reliable, their permitted downtime
measured in terms of seconds per system-year. These ultra-high levels of reliability engineering for such
communications systems are attempted in only a few human endeavors; other examples being the nuclear,
aviation and outer space disciplines.286 For this reason, the advanced skills and methodologies used are
uncommon.

Even so, network outages occur. When system failures occur, traversing payload is impaired. When
alternate paths are available, the payload may be re-routed automatically, or through manual means, but
because there are limited routes available, re-routed traffic may take longer paths, which introduces latency.

Because of vast distances and limited routes available, re-routed traffic may take paths with noticeable
delays for applications with extreme sensitivity, such as competitive real-time financial transactions. Such
delays may be unacceptable.

Outage detection happens instantly, as signals travel at the speed of light. On the other hand, repair times
can be quite lengthy. Some repairs – such as those associated with hardware replacement to landing
station endpoints, power distribution equipment on shore, or software changes - can be routinely handled
in durations similar to what is involved in terrestrial network maintenance, typically measured on the order
of hours. However, repairs and maintenance on the open seas are not so easy and are measured on the
order of weeks. Here, repair times involve many critical steps – missing any one of them can jeopardize
the entire repair operation. Thus the objective is to accomplish the mission in as little time as necessary,
but to also execute in a way that ensures the highest probability of getting the job done right the first time.
The process begins with a pre-repair meeting where planning and resource estimation is performed with
all of the parties involved. As the most time in the process can be lost in the grapnel attempts for the
cable, assembling all possible data that can support an accurate location is essential to avoid lengthy
location searches. Grapnelling close to fault location is key to reducing time. Experienced crews know
that it is also worth conducting research to determine which methods have been successful in past repair
activities in the area. Selective use of remotely operated unmanned vehicles can optimize repair time. If
possible, simultaneously recovering the stray end while testing the system cable end can save time. It is
also important to have competent staff available on a 24-hour by 7-days per week basis.

A.1 Recent Major Outages

Most undersea communications cable outage events are not reported to the public. The reasons for
protecting this information include protecting competitive interests (i.e. disclosing a system failure is
viewed as having a net downside affect on business) and for protecting the security interests of the nation-
state and private sector stakeholders associated with the cable system.287 For these reasons outage data
can be hard to come by. Most outages that are reported within the public domain have had a public
impact such that some industry reporting becomes necessary. But that is the exception. Analysis was

286
Communications systems that are deployed in public networks are routinely designed for 5 9’s (99.999% availability); in the
mid-1990’s the 5 9’s barrier was broken when the 5ESS Switch achieved the first sustained 6 9’s performance in public
networks; this same system went on to break the 7 9’s barrier. Analysis of FCC ARMIS 43-05 data, BPI TelcoData.
287
These reasons for outage data protection are similar to those in the terrestrial-based networks. Discussion around these
points can be found in the proceedings of the ATIS Network Reliability Steering Committee (NRSC) and the FCC’s Network
Reliability and Interoperability Council (NRIC).

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conducted of publicly available information on communications cable outages. In addition, insights were
gleaned from proprietary outage databases through discussions with experts. These discussions were
conducted in a way that protects the sensitive aspects of the data, yet supports the research objectives of
The Study. For example, outage analysis conclusions drawn from the research are able to confirm that
both data sources found similar relative proportions among the identified causes (e.g., fishing, anchors).

A.1.1 Survey of Events

The analysis described above covered over 600 outage events. The time period was limited to the last
decade, keeping the types of systems relatively similar technology-wise. Further summary of the outage
data can be outlined as:
• Outages were included from each region where cable systems are deployed
• Outages were included from all cause types – man-made and natural
• Outages were included from any system or network operator
• Outages were included from any equipment supplier

A.1.2 Pareto Analysis of Cause Attribution

Outages can be caused by the failure of any of the eight ingredients, which can happen when a threat is
able to exercise one or more intrinsic vulnerabilities. Thus, cable systems can experience outages due to
causes associated with Power, Environment, Hardware, Software, Network, Payload, Human or Policy.
Most major cable system outages have occurred due to causes associated with the Environment and
Hardware ingredients. This can be expected given the special challenges for these two areas. The
Environment consists of thousands of kilometers of distance in harsh, untamed undersea terrain. The
destruction of a cable system’s Environment is typically associated with undersea earthquakes or landslides,
though marine life and abrasion are also contributors. Similarly, the Hardware deployed for these vast
distances consists of continuous, highly purified strands of fibers wrapped in a protection package on the
order of the size of a household garden hose. Physical destruction of cables, or cable cuts, occurs most
frequently as the result of being hooked by fishing equipment or a ship’s anchor.

Figure 33. Pareto Analysis of Ingredient Associations with Outage Causes (%)

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A Pareto analysis is presented in Figure 33. The methodology applied defines an ingredient category as a
contributor if a threat exercised one of its intrinsic vulnerabilities. Thus for a single outage event, there
may be more than one ingredient involved. Examples of this include an earthquake altering the
Environment and damaging the Hardware; or a fishing crew being unmotivated by Policy enforcement
limitations regarding restricted zones and damaging Hardware with their trawling equipment. It is readily
apparent from the chart that a few ingredients are involved to a large extent and the remaining ingredients
to a minimal extent. An encouraging observation of the Pareto analysis is that nearly half of the events
could potentially be prevented because of the association with something within human control:
agreements, standards, policies and regulations - i.e. the “Policy” ingredient.

A.2 The Historically Common vs. Very Low Probability Events

The Pareto analysis just presented depicts a situation where a few categories have been associated with
nearly all of the problems. However, it is vital to realize that each of the ingredients has intrinsic
vulnerabilities that are always there. While the diligence and vigor that the industry has applied to learning
from the historical events is highly commendable and needs to continue with ever increasing fervor,
something must be said for the very low probability - yet possible - types of events that have very high impact.
Figure 34 provides a simple depiction of the situation.

Given the ever-increasing global dependence on undersea communications cable infrastructure, the effects
of a widespread (i.e. global or regional) outage would be history-altering. The profound reality that such
events can occur needs to be effectively communicated to stakeholders and decision makers so that
effective countermeasures can be developed and deployed to mitigate the impacts of such events. The
Countermeasure Approaches section below outlines some insights into such opportunities.

Figure 34. Portrayal of the High Probability Low Risk vs. Very Low Probability Very High Risk Events

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A.3 Intrinsic Vulnerability Analysis of Select Recent Events

This section will provide further analysis of the four most significant outage events in recent history.
These outages are:

o 2006 (December 26) Luzon Strait [Hengchun Earthquake] – multiple cuts

o 2008 (January 23 – February 4) Middle East – multiple cuts
o 2008 (December 19) Mediterranean Sea – multiple cuts
o 2009 (August 12 and 17) Luzon Strait [Typhoon Morakot and Taiwan Earthquake] – multiple
cuts

Various reports are available in the public domain for each of these events. The focus of these reports is
on the threats involved. For the first and fourth events listed above, there is consensus on the threats that
caused the outages; for the middle two events, there is less certainty regarding the threats that caused the
outages.

In contrast to the spotlight of these public reports being on the effective threats, this analysis focuses on
the intrinsic vulnerabilities of the critical infrastructure – the susceptibility that was acted upon. The value
proposition for this approach is that it provides insights and guidance that are based on the foundational
scientific and engineering principles that are the basis of the infrastructure, and in which there can be very
high confidence relative to some of the threat-based analyses.

A.3.1 Cause-Effect Analysis

A Cause-Effect, or Ishikawa, diagram is shown in Figure 35.

Figure 35. Ishikawa Diagram with 8i Framework.

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Hengchun Earthquake (2006)

The Hengchun earthquake occurred on Tuesday, December 26 at 12:25 UTC, having an epicenter in the
Luzon Strait (21.89°N 120.56°E).288 Particular aspects of the island of Taiwan contributed to a unique
situation. These factors include the landslides near two tectonic plates (Eurasian and Philippine), river
systems that deposit exceptional debris near their entry into the sea, and the resulting turbidity current
flows.289 The Hengchun turbidity current flowed a distance of over 300 km and reached speeds on the
order of 20 km/hr.

The earthquake resulted in catastrophic, global outages of historic proportions in the communications
industry. This exceptional impact was due to multiple undersea cables being damaged, including:

• December 26+: 2 systems290

• December 27+: 2 additional systems

Figure 36. Hengchun Earthquake Catastrophic Outage (2006):

(X) Hypocenter, and
(Y) Region of Undersea Landslides and Turbidity Current Flows

The affected regions include Taiwan, China, Hong Kong, Vietnam, Japan, Philippines and Singapore and
many other regions around the world (e.g., United States and Europe). The affected services include
substantially reduced international connectivity for telephone voice traffic, Internet access including email
and search capabilities, financial sector and other commerce traffic, and other critical services.

288
The magnitude of the earthquake has been rated as 6.7, 7.1 and 7.2 by the Central Weather Bureau (Taiwan), United States
Geological Survey, and the Japan Meteorological Agency, respectively.
289
Turbidity currents are forces of sediment-dense water that moves within another fluid of lower density. Because the speed of
the turbidity current increases with its density, these currents can increase their speed as they create erosion and pick up more
debris.
290
While the identifies of these systems is readily available in the public domain, it is not necessary to mention specific system
names in this Report.

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The duration of the impact extended to approximately 2 months. Numerous specialized undersea
communications cable vessels were deployed in the repair operation to restore the damaged cables to
service.

As shown in Figure 37, the Hengchun earthquake threat exercised the intrinsic vulnerability of the
undersea environment by violently altering it. This dramatic altering of the previously safe Environment,
became a threat that exercised the intrinsic vulnerability of Hardware to be physically damaged. From a
global infrastructure perspective, the aggregated routing of different cables through the Luzon Strait
exposed the intrinsic vulnerabilities of Networks to be accessible and to have points of physical failure.
The reasons for lack of physical diversity appear to be, in part, geopolitical restrictions on the use of other
routes, exposing the intrinsic vulnerability of Policy to be lacking sufficient agreements.

Figure 37. Hengchun Earthquake 8i Ishikawa Analysis

Middle East (2008)

Multiple undersea communications cable cuts occurred in the Middle East region during the 12-day period
of January 23 through February 3. There is not consensus as to the actual threats that damaged the
cables.291 This uncertainty has fostered intrigue, which, coupled with the ongoing political conflict of the
region and the widespread impact of these cuts, resulted in unprecedented traditional news media
coverage and Internet forum discussion activity for a communications outage. Several official government
and industry expert views have attributed some of the cable cuts to anchors. Participants of the
ROGUCCI Global Summit were able to tour one of the repair vessels used in the restoration process.
Further, these participants were able to learn from the crew of this ship what they observed. Insights were
provided that substantiated the cause as anchor damage from ships that were drifting due to unusually
high winds in the region at the time.

291
The causes of these outages have been ascribed by different sources to: dragging ship anchors, non-anchor maritime
activity, bad weather, an earthquake, a coordinated non-government organization attack (NGO), a government-sponsored
activity using explosives, as well as others.

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The cables damaged include:

• January 23+: one system

• January 30+: two additional systems affected (one was an additional segment of the initial system)
• February 1+: an additional segment of one of the above systems
• February 3+: one more system affected

In addition, on February 4, it was discovered that one of the systems had been damaged again, this time
farther East near Penang, Malaysia.

Figure 38. Middle East Catastrophic Outage (2008)

The countries most impacted include Afghanistan, Bahrain, Bangladesh, Egypt, Kuwait, India, Pakistan,
Qatar, Saudi Arabia, and the United Arab Emirates, and effects were felt throughout the rest of the world
(including the United States and Europe). Impaired services include substantial reduced international
connectivity for telephone voice dialing and Internet access including email and search capabilities,
financial sector and other commerce traffic, and other critical services.

In addition to the reliability impacts described above, if the events were a coordinated malicious activity
there could be security issues that arise from the rerouting of traffic. The practice of cutting
communications cables to achieve a strategic advantage has been a practice for more than 100 years.292

292
Cable Cutting in War Time, The Pall Mall Gazette, May 11, 1898

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Numerous specialized undersea communications cable vessels were deployed in the repair operation to
restore the damaged cables to service.

As shown in Figure 38, the multiple locations of the cable damage were focused in two primary areas:
Alexandria, Egypt and the perimeter of the U.A.E. Unlike the Henchung earthquake, these damages
occurred in geographically separated areas, though they were within the same region.

Figure 39. Middle East Multiple Cuts 8i Ishikawa Analysis

If the triggering threat was a natural phenomenon (i.e. an earthquake) for any of these damage areas then
the intrinsic vulnerability of alterability of the undersea Environment was exercised. In this scenario, the
dramatic altering of the previously safe Environment became a threat that exercised the intrinsic
vulnerability of Hardware to be physically damaged. If the threat was a ship anchor, then the same
intrinsic vulnerability of Hardware was exercised. Though ship anchors are a known threat to undersea
communications cables, and various Policies are in place to avoid anchor damage, the ASPR intrinsic
vulnerability of enforcement limitations permits continuous exposure of cables. A more complicated
scenario involves directed action by Human actors. This scenario could involve Human agents within the
infrastructure, who are susceptible to the intrinsic vulnerability of ethical compromise. This could be
associated with coercion, greed, malicious intent or other motivations. The Human agents could have
compromised privileged information regarding the cable infrastructure. However, as shown elsewhere in
The Report, with the abundance of critical communications cable infrastructure information available on
the Internet, privileged information would not be necessary. Such information exists in the public domain
due to the intrinsic vulnerability of information leakage that is part of ASPR processes. This information
leakage is itself propagated by the intrinsic vulnerability of ASPR to infuse vulnerabilities (i.e. requirements
for information to be part of an open proceeding).

From a global infrastructure perspective, the predominant aggregated routing of Europe-Asia through the
Red Sea passage exposed the intrinsic vulnerabilities of Networks to have points of physical failure and to

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be accessible. Analysis of the reasons for the lack of physical diversity appear in part to geopolitical
restrictions, exposing the intrinsic vulnerability of Policy to be lacking sufficient agreements.

Mediterranean Sea (2008)

Multiple undersea communications cable cuts occurred in the Mediterranean Sea on December 19. The
cable damage has been attributed to fishing trawler activity, ship anchors, an earthquake or a combination
of these. The cables damaged were:

• January 19+: four systems affected

Figure 40. Mediterranean Sea Catastrophic Outage (2008)

The regions most affected include northern Africa, the Middle East and the Indian subcontinent, and
Europe, while the rest of the world (including the United States and Asia) was also affected. The most
seriously affected countries were (in order) Egypt, Saudi Arabia, Maldives, Bangladesh, Sri Lanka, Sudan,
U.A.E., Lebanon, Pakistan and India.293 Impaired services included substantially reduced international
connectivity for telephone voice dialing and Internet access including email and search capabilities,
financial sector and other commerce traffic, and other critical services. Most business-to-business traffic
between Europe and Asia was rerouted through the U.S.

Specialized undersea communications cable vessels were deployed in the repair operation to restore the
damaged cables to service.

293
Based on the percentage of total routed prefixes per country. Deju Vu all Over Again: Cables Cut in the Mediterranean, Alin
Popescu, December 2008.

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As shown in Figure 40, the multiple incidents of cable damage were contained within a single geographic
area: between Sicily and Tunisia. Like the Henchung earthquake, these damages occurred in a
geographically concentrated area, though the attribution to an earthquake is not clear.

If the triggering threat was a natural phenomenon (i.e. an earthquake), then the intrinsic vulnerability of
alterability of the undersea Environment was exercised. As before, the dramatic altering of the previously
safe Environment became a threat that exercised the intrinsic vulnerability of hardware to be physically
damaged. If the threat was a ship anchor, then the same intrinsic vulnerability of Hardware was exercised.
Though ship anchors are a known threat to undersea communications cables, and various Policies are in
place to avoid anchor damage, the ASPR intrinsic vulnerability of enforcement limitations permits
continuous exposure of cables. This holds similar for fishing practices that may have damaged the cables.

Figure 41. Mediterranean Sea Multiple Cable Cuts 8i Ishikawa Analysis

Typhoon Morakot and Taiwan Earthquake (2009)

Deep sea landslides caused by the approach of Typhoon Morakot severed undersea cables and disrupted
telecommunications and Internet traffic to China and various areas of Southeast Asia. This impact was
due to multiple undersea cables being damaged, including:294
• August 9: 3 systems
• August 12: 5 additional systems
• August 17: 1 additional system

The affected regions include China, Singapore, the Philippines and Hong Kong. Traffic was rerouted to
back-up cables, however there was concern that the back-up cables would not be able to handle all of the
traffic.295
294
Hong Kong Rebounding from Recent Natural Disasters Typhoon Morakot and Earthquake in August, 2009, HKCOLO,
October, 2009.

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Figure 42. Typhoon Morakot and Taiwan Earthquake Catastrophic Outage (2009):
(9)(12) progression of typhoon, and
(17) Earthquake

On August 17th, an earthquake off the east coast of Taiwan, amidst the Southwestern Ryukyu Islands
(Japan), damaged the cables being used as back-up. In all, nine undersea cables were damaged by the
typhoon and the earthquake, affecting service between the Chinese mainland and Taiwan, Japan, the
Republic of Korea, Singapore, the United States, and Europe.296

As shown in Figure 43, Typhoon Morakot and the Taiwan earthquake threat exercised the intrinsic
vulnerability of the undersea environment by violently altering it. This dramatic altering of the previously
safe Environment, became a threat that exercised the intrinsic vulnerability of Hardware to be physically
damaged. From a global infrastructure perspective, the aggregated routing of different cables through the
Luzon Strait exposed the intrinsic vulnerabilities of Networks to be accessible and to have points of
physical failure. The reasons for lack of physical diversity appear to be, in part, due to geopolitical
restrictions on the use of other routes, exposing the intrinsic vulnerability of Policy to be lacking sufficient
agreements.

295
http://www.computerworld.com/s/article/9136622/Typhoon_Morakot_severs_three_undersea_Internet_cables
296
http://english.peopledaily.com.cn/90001/90781/90877/6731967.html

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Figure 43. Typhoon Morakot and Taiwan Earthquake 8i Ishikawa Analysis

A.3.2 Countermeasure Approaches

Given that intrinsic vulnerabilities are ever present in the undersea communications cable infrastructure, it
can be helpful to explore methods that can address their exposure and ability to be exercised by a threat in
order to prevent future similar occurrences or ameliorate the impact of future similar occurrences.
Amelioration of impact can be accomplished by reducing the breadth of the impact in terms of impaired
users, by reducing the duration of the outage event, or by reducing the criticality or types of services
affected.

Tables 8, 10 and 11 provide a countermeasure analysis for each of the four outages presented above. This
countermeasure analysis is not complete, but is offered to demonstrate the challenges faced in raising the
overall resilience of the undersea communications cable infrastructure and the cross-disciplinary nature of
countermeasures (e.g., a Hardware limitation may be addressed by a Policy countermeasure). Note that
for those cases where this analysis was conducted for events with an unconfirmed threat, the analysis was
completed as if any of the suggested countermeasures were applicable.

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Table 8. Hengchun Earthquake 8i Countermeasure Analysis

CM Potential CM Potential
Exercised to Prevent to Ameliorate
Infrastructure Intrinsic Countermeasure Considerations Future Impact of
Ingredient Vulnerability Similar Similar
Occurrences Occurrences
Alterable
Environment Luzon Strait is known tectonic risk X X

Power
Damageable Physical protection against these
Hardware
forces not feasible
Software Automatic reroutes X
Accessible
Network Provide physical diversity X X
SPoF
Payload

Human

Policy (APSR) Lack of ASPR Remove geopolitical restrictions X X

Hengchun Earthquake
Regional geopolitical forces funnel all of the cable routes that connect North America to the regional
financial hubs of Hong Kong and Singapore through the Luzon Strait. This situation stresses the intrinsic
vulnerability of networks having single points of physical failure. To address this, progress in the ASPR
arena can help tremendously. Specifically, if agreements could be made to permit the laying of undersea
communications cables in the North-South direction in between mainland China and Taiwan, then a
geographical separation can be achieved and thus reduce the exposure of the aggregate global
infrastructure to this seismically active area. Other enhancements can be accomplished via software
capabilities and pre-arranged contractual agreements that would enable more speedy and high capacity
reroutes.

Given the reality of geographic regions of frequent high magnitude earthquakes (Figure 44), a global
review of infrastructure single points of geographic failure is highly relevant. Surely individual system
planners and designers appreciate this concern. However, the exposure of aggregated worldwide
communications resources is a problem at another level. The increasing dependence of the world’s
economic stability, as well as other interests, require that geopolitical limitations be revisited with the
mutual interests of affected parties in mind.

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Table 9. Frequency of Earthquakes Worldwide297

Magnitude Annual Frequency
2 to 2.9 ~1,300,000*
3 to 3.9 ~130,000*
4 to 4.9 ~13,00*0
5 to 5.9 1319**
6 to 6.9 134**
7 to 7.9 17***
8 and higher 1***
* estimates
** based on observations from 1990 onward
***based on observations from 1900 onward

Reproduced with the permission of the British Geological Survey © NERC. All rights Reserved.

298
Figure 44. Earthquake Belts of the World

Middle East and Mediterranean Multiple Cable Cuts

It is unclear as to whether a sufficient post-mortem analysis has been completed, particularly for the
Middle East events. Due to the uncertainty of the actual threats that caused these cuts, available analyses
are somewhat limited. The analysis below, while remaining flexible for this uncertainty, provides guidance
in key areas that can prevent similar occurrences and ameliorate the impact of similar events.

297
Data from the United States Geological Survey (www.usgs.gov ).
298
Data from the British Geological Survey, National Environment Research Council, www.bgs.ac.uk

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Table 10. Middle East Multiple Cable Cuts 8i Countermeasure Analysis

CM Potential CM Potential
Exercised to Prevent to Ameliorate
Countermeasure
Infrastructure Intrinsic Future Impact of
Considerations
Ingredient Vulnerability Similar Similar
Occurrences Occurrences
Alterable Few undersea cable path
Environment
options in this area
Power
Damageable Physical protection against
Hardware
these forces not feasible
Automatic reroutes X
Software
Accessible
Network
SPoF Provide physical diversity X X
Payload
Ethical Address motivation; raise security X
Human
Lack of ASPR Remove geopolitical restrictions; X
Back-up routing; X
Policy
Information leakage Anticipate utilization; X X
(APSR)
Enforcement limitations Strengthen ASPR; X X
Vulnerabilities infusion Educate policy makers; X

Table 11. Mediterranean Sea Multiple Cable Cuts 8i Countermeasure Analysis

CM Potential CM Potential
Exercised to Prevent to Ameliorate
Countermeasure
Infrastructure Intrinsic Future Impact of
Considerations
Ingredient Vulnerability Similar Similar
Occurrences Occurrences
Alterable Few undersea cable path
Environment
options in this area
Power
Damageable Physical protection against
Hardware
these forces not feasible
Automatic reroutes X
Software
Accessible
Network
SPoF Provide physical diversity X X
Payload
Ethical Address motivation; raise security X
Human
Lack of ASPR Remove geopolitical restrictions; X
Policy Back-up routing; X
(APSR) Unimplemented ASPR Strengthen ASPR X X
Enforcement limitations Strengthen ASPR X X

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In summary, countermeasures can be asymmetrical to the failure domain associated with the outage cause.
Given that subject matter experts and responsible parties have limitations with regard to their expertise
and responsibilities respectively, effective cross-discipline countermeasure proposal and development is
often insufficiently practiced in many fields. For example, a network design expert well aware of the
limitations of the geopolitical status quo, is not likely effective at having influence in that arena, despite the
fact that he may be well armed with a profound economic and commercial value proposition. A key
distinction of the ROGUCCI process was to integrate technical expertise, business leaders, stakeholders
and international policy change agents in order to be able to aggregate the maximally useful core
competencies to develop and deploy countermeasures.

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APPENDIX B. Survey of Publicly Available Information

While undersea communications cable infrastructure is a highly specialized field, there exists a significant
amount of information available to the public. This appendix summarizes the types of information
available to the public – with examples - in 10 key areas:

1. History
2. Technology
3. Suppliers
4. Cable Systems
5. System Owners and Operators
6. Cable Landing Sites
7. Cable Routes
8. Outage Events
9. Restoration Procedures
10. Financial Dependencies

The information described below is available from published documents and the Internet.

B.1 History
The history of the world’s undersea (or submarine) communications cable infrastructure is well
documented. The industry has done an excellent job in documenting the trials and outcomes, events and
dates, discoveries and improvements, and business risks and successes. For example, the inaugural
message sent across the first trans-Atlantic cable from Queen Victoria to U.S. President Buchanan:
“England and America are united. Glory to God in the highest and on Earth, peace, good will to men.” The message
was sent as a telegraph that took over 30 hours to transmit.

Figure 45. Preservation of the History of Undersea Cables

(a) A Map of the First Trans-Atlantic Telegraph Cable Route (1858)
(b) “Eighth Wonder of the World” painting commemorating the cable crossing of the Atlantic Ocean (1866)

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The Smithsonian Institute in Washington, D.C. has previously displayed an exhibit featuring the history
and advances of undersea communications cable technology. The exhibit now takes on the form of an
online library. The advances of undersea communications cable progress continues to be documented
and includes the latest information sharing approaches - web blogs and interactive videos.

B.2 Technology
Very complete information is available to the public on the underlying science of undersea
communications cables systems. The engineering design principles and many operational practices are
likewise readily available, some even in the form of instructional videos. Figure 46 outlines the types of
information available. Note that this spans the development lifecycle from research through
manufacturing to operation.

Figure 46. Maturity Model of Undersea Communications Cable Technology Information

Literally thousands of pages of information are available on these subjects. Specific examples of
technology information include the principles of light and wave theory from physics that form the basis of
optical fiber transmission, the trade-offs made in cable design construction, the reason for selecting
particular materials for specific applications, the method of manufacturing long haul cables, techniques for
field experiments to validate the predicted longevity of undersea components, the machinery and manner
of digging trenches for buried cable segments, and steady state operation.

B.3 Suppliers
The suppliers of the world’s undersea communications cable infrastructure are easily identified in publicly
available information. To varying degrees, information is available on such areas as their:

• Technology
• Manufacturing methods
• Manufacturing locations
• Customers
• Contract wins that identify the system to be built

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B.4 Cable Systems

A list can be compiled from the Internet that contains over 300 international undersea cable systems. The
information available includes the system name and the systems landing points.

B.5 System Owners and Operators

Undersea cable systems have several ownership structures. In some cases, the owner is also a
communications company and also an operator. In other cases, the cable system owner leases the
transmission facilities to multiple communications companies that are service providers. Public domain
information includes owners of currently operational undersea cable systems and their respective
nationality.

B.6 Cable Landing Sites

Significant information is available to the public on undersea cable landing stations. This information
includes various tutorials on the function of a landing station facility, diagrams of facility locations relative
to the adjacent body of water, criteria for site selection, and geographical coordinates. An instance was
found where the type of security being employed at a site is discussed. Photographs can be found on the
Internet of cable landing sites that include aerial views, topographical maps, and building exteriors. In
some countries, the process for designating an area for use as a cable landing site involves a regulatory or
other governmental approval process that is in part open to the public.

Approximately 1,000 cable landing sites can be found on the Internet. The information provided for
these sites includes the cable system termination at the site, the equipment supplier of the system, the date
of deployment, and the cable route length.

B.7 Cable Routes

Substantial information is available to the public on the routes of undersea communications cable systems.
Details include origination and termination points, segment end points, and paths. In addition,
information is provided by the installers of new systems on the updates of progress being made and
schedules. In some areas, cable route information is provided for use by the fishing industry. The data
available include:

• Name of cable system (at segment level)

• Geographic region of location
• Date deployed
• Route length in kilometers
• Equipment suppliers providing component to build the system

In addition, detailed maps of cable systems can be found in the public domain. Images include:

• Global view of cable routes

• Landing points
• New reports of damaged cable locations
• Awareness maps for navigators

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B.8 Outages
Long haul undersea communications cable systems are designed to perform at a level described as ultra-
high reliability. However, despite all of the best planning and execution, failures of these systems still
occur. The systems are also designed to be fault tolerant, meaning that a failure can be detected and dealt
with gracefully such that there is minimal impact to the traffic being carried. This is often accomplished
by the use of the system’s spare capacity available in its paired redundant path. Increasingly, undersea
cable systems are also rerouting their traffic to other systems – either undersea or land-based.

As the frequency, duration and cause of network failures is potentially sensitive information, it is
understandable that much of this information is not available to the public. The information may be
sensitive for reasons related to direct competitive business interests (i.e. comparison among systems),
stakeholder subscriber interests (i.e. a carrier leasing space may be represented as having sub-optimum
performance through association), or nation-state security.

However, outages that have a major impact tend to be reported in public news outlets. A detailed analysis
of information publicly available on the Internet supported the following observations:
• on the order of 100 outages can be identified for the period from 2000 through 2009
• the outage locations are distributed across the globe
• outage events were found in each of the 12 months
• outage durations range from several hours to several months
• the primary causes (from the 8i Framework) of the events are associated with
o Environment
o Hardware
o Power

In addition, there are suggestions that some events could have been caused by malicious activity, thus
potentially involving the Human ingredient.

B.9 Restoration Procedures

Because system outages result in complete or partial service impairment, noncompliance with contracted
service level agreement obligations, and expensive reroutes over alternate undersea or landline paths, the
restoration of the system to its full functioning is urgent business. Outage detection, analysis and repair
procedures are types of information available to the public.

Restoration of land-based equipment is obviously likely to be less involved. This type of restoration will
most typically involve replacement of electronic hardware at the termination point or repair or
replacement of power feed equipment. The restoration for buried or submerged equipment is more
involved. When submerged equipment must be accessed, dedicated ships with specialized crew and
equipment aboard are needed.

Given the vital dependence of undersea communications cable infrastructures on specialized cable ships,
these vessels are appropriately considered a critical international asset. Public information on these ships
is available and includes information such as:

• vessel name
• country of registration
• base port

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• owner
• specific function regarding cable repair
• weight capacity
• photographs

B.10 Financial Dependencies

By and large, the undersea communications cable infrastructure is owned and operated by the private
sector. A such, there are key business drivers throughout this process that motivate private sector
stakeholders to make the investments, take the risks, and fund the research that has created the
infrastructure we have today. For a complete perspective, we must take into account the financial factors
affecting this industry. Below are some types of information available in the public domain regarding the
financial impacts of GUCCI outages.

• The cost for a normalized (by distance and capacity) unit of undersea cable transmission has
dropped by 93% from 1998 to 2008.299

• The number of people affected per country for specific undersea cable cuts.

• The cost per minute, hour or day for financial trading firms, call centers communications service
providers, and other businesses.

• Estimates of the number of businesses that fail from specific undersea cable outages. 300

• Specific details describing the amount of backlog created when three are outages (medical
subscriptions, airline reservations, stock trades, orders, etc.).

299
Unit Cost of Submarine Cable Systems, TeleGeography, 2008.
300
National Archive & Records Administration.

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APPENDIX C. Impact of Historic Outages

This section was prepared for the ROGUCCI Report by Michael Sechrist, fellow - U.S. Department of Homeland Security,
graduate student - Harvard Kennedy School of Government, Cambridge, Massachusetts, and participant - ROGUCCI
Global Summit.301

C.1 Recent Events

This section will briefly analyze recent cable breaks in Algeria 2003, Pakistan 2005, Taiwan 2006, Pakistan
2007, Vietnam 2007, Bangladesh 2007, Mediterranean 2008, Middle East 2008, West Africa 2009 and
Taiwan again in 2009. The impact of these events on related societies is also discussed. The potential
impact of a future multi-cable event is then analyzed.

CASE #1: Algeria 2003

 
EVENT: On May 21, 2003, a 6.8 magnitude earthquake affected the Bourmerdes region, outside the
coast of Algeria.302 The earthquake occurred 7 km offshore at a boundary between the European and
Asian tectonic plates. As a tsunami 2 meters high traveled across the Mediterranean Sea, turbidity currents
generated extensive submarine landslides.

DAMAGE: The earthquake killed 2,266, injured 10,261 and caused extensive structural damage to the
city of Bourmerdes and elsewhere in the country. The undersea landslides generated from the earthquake
cut undersea cables approximately “45 km offshore from the epicentral area and disturbed the
communications link between Europe and several other countries in Asia and the Middle East.”303 Overall,
undersea landslides damaged five communications cables.304

IMPACT: It took four cable ships six weeks to fix all the cables.305 One repair involved replacing a 120
km section of cable. All things considered, the earthquake caused an estimated $100 million in damage.306

301
ORISE Acknowledgement: This research was performed under an appointment to the U.S. Department of Homeland
Security (DHS) Scholarship and Fellowship Program, administered by the Oak Ridge Institute for Science and Education
(ORISE) through an interagency agreement between the U.S. Department of Energy (DOE) and DHS. ORISE is managed by
Oak Ridge Associated Universities (ORAU) under DOE contract number DE-AC05-06OR23100. All opinions expressed in this
paper are the author’s and do not necessarily reflect the policies and views of DHS, DOE, or ORAU/ORISE.
302
A. Ayadi, et. al., “Strong Algerian Earthquake Strikes Near Capital City,” Eos, Vol. 84, No. 50, 16 December 2003. Accessed
at http://atlas.cc.itu.edu.tr/~cakirz/papers/ayadi_etal_2003_EOS.pdf
303
Ibid.
304
ICPC, “Critical Infrastructure: Submarine Telecommunication Cables,” Accessed at
www.iscpc.org/publications/Critical_Infastructure_2009_V2.pps
305
Ibid.
306
Ibid.

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CASE #2: Pakistan 2005

EVENT: On June 27, 2005, the only undersea communications cable connecting Pakistan with the rest
of the world was disrupted. According to the repair company, the possible cause “was the fishing activity
around the affected area," and “that an anchor of a fishing trawler had got entangled which ruptured the
cable."307 The disruption occurred 11-12 km from the port of Karachi.

DAMAGE: The breaks were significant. At the time, “Pakistan was the only country in the region that
relies on a single cable. There were no backup cable, no disaster recovery strategy and no business
continuity plan in place.”308

Despite this plan, business suffered from the lost connection. As one airline director noted, "all our
business including reservations, ticketing, check-ins and 500 agents all around the world are web-based
and it was all affected badly. We had to switch to manual work and that was very difficult for us. Besides,
we suffered severe damage to our market credibility."309

IMPACT: It took two cable repair ships over eleven days to fix the fault. According to an official from
the Pakistani Internet service providers union, 10 million online subscribers in Pakistan went without
Internet service for more than a week because of the fault.310 All e-services were affected, particularly the
burgeoning Pakistani call center industry. As the President of the Call Centres Association of Pakistan
stated, "It has definitely caused millions of dollars in potential losses and a lot of intangible damage you
cannot quantify."311

The loss of communications in a country of size and scope of Pakistan reverberated with its trading
partners. Several multinational information and communication technology contracts were cancelled,
most notably a $10-$20 million investment by Indian call centers. The Indian companies “withdrew the
offer as the lingering Internet blackout caused mistrust in India about Pakistan’s Telecom
infrastructure.”312 India could not outsource their work to Pakistan, fearing that their U.S.-based contracts
would be unfulfilled.

RECOVERY: During that outage, 50% of Internet subscribers and 20% of international phone callers
received a connection via a back-up satellite plan provided by the Pakistani Communications Cable
Limited company. The PTCL implemented an ad-hoc tiered restoration structure, providing data access
first to banks, airlines and the Pakistani stock exchange access first before all others.

CASE #3: Taiwan 2006

EVENT: On December 26, 2006, a seminal event occurred in the undersea cable industry. An
earthquake of at least 6.7 magnitude triggered a submarine landslide near the junction of the Eurasian and
Philippine tectonic plates. Termed the Hengchun earthquake, the epicenter of the event landed directly in

307
“Submarine cable: IT ministry preparing load-sharing plan,” Pak Tribune, February 14, 2006. Accessed at
http://www.paktribune.com/news/index.shtml?134126
308
Hayyan Faisal, “Task to detect major Fault in Pakistan's Internet cable Set Off,” Pakistan Times, July 2005. Accessed at
http://pakistantimes.net/2005/07/04/top1.htm
309
“Bad weather obstructs Pakistan's Fiber Optic cable repair Work” Pakistan Times Staff Report, July 5, 2005. Accessed at
http://pakistantimes.net/2005/07/05/top6.htm
310
Faisal, Pakistan Times.
311
Ibid.
312
Omair Rasheed, “Standby Net arrangements terminated in Pakistan,”
Pakistan Times, July 6, 2005. Accessed at http://pakistantimes.net/2005/07/06/top5.htm

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the middle of the heavily cabled Luzon Strait, off the coast of Taiwan. Ten aftershocks greater than 4.7
magnitude also hit the region.313 From the timing of the breaks, a turbidity current averaging a speed of
approximately 20 km/hour traveled over 330 km.314

DAMAGE: Undersea landslides severed nine out of eleven cables in the area, moving cables far away
from their original routes. A total of twenty-one faults were discovered in the nine damaged cable
systems.315 The damage extended to water depths of 4000 meters and covered many in tons of mud.316 It
took eleven cable ships (over 40% of the world’s entire fleet) until February 15th – a total of forty-nine
days or seven weeks to complete the cable repair work.317

IMPACT: The day after the earthquake, most people in Hong Kong were “just twiddling their
thumbs.”318 Taiwan’s international calling capacity to the U.S. was down to 40% its normal capacity.319
98% of Taiwan's communications with Malaysia, Singapore, Thailand and Hong Kong was also
disrupted. 320 Internet access to China, Hong Kong, Vietnam, Taiwan, Singapore, Japan and the
Philippines was seriously impaired. Banking, airline bookings, email & other services in many of these
countries, particularly Taiwan and Singapore, were either stopped or delayed.321

Financial markets and general commerce were disrupted. A South Korean domestic bank reported that
“trading of the Korean won has mostly halted due to the communication problem."322 Other “securities
traders in Hong Kong and Singapore were unable to obtain prices and complete orders… [and] dealers in
the region said they have had difficulties accessing international news providers for information.” 323
Customers also had trouble looking up various “stock prices online.”324

RECOVERY: Some traffic that couldn’t be carried on the two remaining undersea cable systems needed
to find a different route in order to reach North and South America. One solution was to re-route traffic
over terrestrial cables across Asia and through Europe. Despite these ad-hoc arrangements, some delay in
internet traffic was still apparent even two months after the earthquake.

AFTERMATH: This event forced communications carriers to avoid cable-laying in seismically active
areas when possible.

313
2006 Hengchun earthquake, Wikipedia entry, accessed at http://en.wikipedia.org/wiki/2006_Hengchun_earthquake
314
ICPC, “Critical Infrastructure: Submarine Telecommunication Cables,” Accessed at
www.iscpc.org/publications/Critical_Infastructure_2009_V2.pps
315
Ryan Singel, “Fiber Optic Cable Cuts Isolate Millions From Internet, Future Cuts Likely,” Wired Magazine, January 31, 2008.
Accessed at http://www.wired.com/threatlevel/2008/01/fiber-optic
316
Ibid.
317
Ibid.
318
Seth Mydans, “The Day the Pixels Froze: When a Digital World Was Stopped by a Natural Disaster,” The New York Times,
December 28, 2006. Accessed at http://www.nytimes.com/2006/12/28/business/28connect.html
319
Sumner Lemon, “Earthquake disrupts Internet access in Asia,” Computer World Magazine, December 27, 2006. Accessed at
http://www.computerworld.com/s/article/9006819/Earthquake_disrupts_Internet_access_in_Asia?intsrc=news_ts_head
320
Ibid.
321
“Taiwan quake causes net blackout,” Reuters. December 28, 2006. Accessed at http://www.smh.com.au/news/wireless--
broadband/taiwan-quake-causes-net-blackout/2006/12/28/1166895395104.html
322
“Asia communications hit by quake,” BBC News, December 27, 2006. Accessed at http://news.bbc.co.uk/2/hi/asia-
pacific/6211451.stm
323
Choe Sang-Hun and Wayne Arnold, “Asian Quake Disrupts Data Traffic,” The New York Times, December 28, 2006.
Accessed at http://www.nytimes.com/2006/12/28/business/worldbusiness/28quake.html?pagewanted=all
324
Ibid.

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CASE #4: Bangladesh 2007

Since connecting its first international undersea communications cable on May 21, 2006, Bangladesh has
suffered numerous faults. In little over a year, twenty-two different faults were reported, either due to
accidents, sabotage or thefts.

EVENTS: In November 2007, the Dhaka-Chittagong–Cox's Bazar portion of a submarine cable “was
snapped at two points near Cox's Bazar and Feni” twice in one week.325

DAMAGE: All international communications to Bangladesh were disrupted for fifteen hours during the
second outage.

IMPACT: Due to the cuts, the Bangladesh Telegraph and Telephone Board lost revenue on the order of
$70,000 per hour.326
 

CASE #5: Middle East 2008

EVENT: Between January 23 and February 4, 2008, “a total of five cables being operated by two
submarine cable operators” were damaged in two locations each. 327 A cable system segment that
connected South East Asia-Middle East-Western Europe near Penang, Malaysia, another cable system that
connected Europe-Asia near Alexandria, a cable system that connected Dubai, a cable system that served
Bandar Abbas in Iran and a cable system that served Alexandria, were all disrupted. Reports would
describe two ships, the MV Hounslow and the MT Ann, as having improperly dragged their anchors five
miles north of Alexandria, Egypt, severing multiple cables.328

DAMAGE: The anchors “severed the cables outside Alexandria after bad weather conditions forced
ships to moor off the coast.”329 Two of the cut cables “have a capacity close to 620 gigabits per second,” 330
leaving only one cable connecting Europe with Egypt and the Middle East in operation. The sole
remaining cable “has a capacity of 70 gigabits per second,” and could not handle the large influx in traffic.
331

IMPACT: The cuts “affected at least 60 million users in India, 12 million in Pakistan, 6 million in Egypt
and 4.7 million in Saudi Arabia.”332

In Egypt and Pakistan, “70 percent of its connection to the outside Internet and 30 percent of service to
its call-center industry, which depended less on the lines,” were lost.333 Also, “50 and 60 percent of India's
Net outbound connectivity was similarly lost on the westbound route critical to the nation's burgeoning

325
Sayeed Rahmna, “Bangladesh Submarine Cable link sabotaged again,” Groundreport.com, November 13, 2007. Accessed
at http://www.groundreport.com/Media_and_Tech/Bangladesh-Submarine-cable-link-sabotaged-again/2837950
326
Ibid.
327
Asma Ali Zain, “Cable damage hits 1.7m Internet users in UAE,” Khaleej Times, February 5, 2008. Accessed at
http://www.khaleejtimes.com/DisplayArticle.asp?xfile=data/theuae/2008/February/theuae_February155.xml&section=theuae
328
Lewis Page, “Dubai impounds cable slicing ships: Satellite images used to ID Gulf cable miscreants,” The Register (UK),
April 14, 2008. Accessed at http://www.theregister.co.uk/2008/04/14/undersea_cable_cut_ships_nabbed/
329
Malcolm Fried and Lars Klemming, “Severed Cables in Mediterranean Disrupt Communication (Update4),” Bloomberg.com,
December 19, 2008. Accessed at http://www.bloomberg.com/apps/news?pid=20601085&sid=aBa0lTN.dcoQ
330
John Borland, “Analyzing the Internet Collapse: Multiple fiber cuts to undersea cables show the fragility of the Internet at its
choke points,” Technology Review (MIT), February 5, 2008. Accessed at http://www.technologyreview.com/web/20152/?a=f
331
Ibid.
332
Ali Zain, Khaleej Times, 2008.
333
Borland, Technology Review, 2008.

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outsourcing industry.”334 Between those three countries, 2,500 networks went down during the outage
period.

CASE #6: Mediterranean 2008

EVENT: Ten months later, it happened again. On December 19, 2008, three cable systems in the region
“carrying more than 75% of traffic between the Middle East, Europe and America were damaged.”335 The
cables run from Alexandria in northern Egypt to Sicily in southern Italy, connecting the Middle East and
South Asia with Europe. The cuts were caused along the Italy to Egypt route and a ship anchor or bad
weather was likely to blame.

IMPACT: At one point as much as 55% of voice traffic in Saudi Arabia, 52% in Egypt and 82% in India
was out of service, according to Orange.336

Again, these cuts caused massive outages; one article reported these significant outages:337 Saudi Arabia:
55% out of service; Djibouti: 71% out of service; Egypt: 52% out of service; United Arab Emirates: 68%
out of service; India: 82% out of service; Lebanon: 16% out of service; Malaysia: 42% out of service;
Maldives: 100% out of service; Pakistan: 51% out of service; Qatar: 73% out of service; Syria: 36% out of
service; Taiwan: 39% out of service; Yemen: 38% out of service; Zambia: 62% out of service.
 

CASE #7: U.S. (California) 2009

EVENT: On April 4, 2009: “a total of ten fiber optic cables…were deliberately cut in three different
locations in Southern California” within two hours.338 One article notes that “a few vandals, equipped
with pliers...cut fiber-optic cables in the San Francisco Bay area, paralyzing wireless, Internet, phone, and
emergency communications for more than twelve hours.”339 The operation was easy; “whoever cut the
fibers simply lifted the manhole cover, went down the ladder, and cut two cables.”340

IMPACT: 1.5 million services were interrupted, including all ATM and credit card processing; 52,000
Verizon landlines lost service.341 Although the case deals with a terrestrial cut, the situation makes the
point that such a cut can happen on land.

CASE #8: West Africa 2009

EVENT: On July 30, 2009, the only cable connecting West Africa to other continents was severed.

334
Ibid.
335
Eric Krangel, “Egypt Goes Dark: Mediterranean Data Cables Toast,” Business Insider.com, December 19, 2008. Accessed
at http://www.businessinsider.com/2008/12/egypt-goes-dark-mediterranean-data-cables-toast
336
Ibid.
337
Arsalan Tariq Mir, “Three Undersea Cables Slashed,” AMMAR-3SIXTY! Blog, Accessed at
http://ammar360.com/2008/12/20/three-major-undersea-cables-slashed/
338
Kevin Burton, Angela McGee, Jack Dibeler, “Who Turned Out the Light?” Burton Asset Management, 2009. Accessed at
http://www.thinkbam.com/thinking/WebArticles/WhoTurnedOutTheLight.pdf
339
Ibid.
340
Margeurite Reardon, “How secure is the U.S. communications network?,” CNet News, April 13, 2009. Accessed at
http://news.cnet.com/8301-1035_3-10217550-94.html?part=rss&subj=news&tag=2547-1_3-0-20
341
Burton, et al., Burton Asset Management report, 2009.

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IMPACT: Internet traffic was significantly disrupted to Benin, Togo, Niger and Nigeria. Nigeria
appeared to be worst hit, as close to “70% of Nigeria's bandwidth was cut, causing severe problems for its
banking sector, government and mobile phone networks.”342

CASE #9: Taiwan 2009

EVENT: On August 12, 2009, Typhoon Morakot, which triggered massive flooding in Taiwan, knocked
out multiple cable systems in the area.343 A week after the Typhoon, a 6.5 magnitude earthquake struck
the region.344 According to Verizon, “10 submarine cable systems in the Asia-Pacific region were damaged
in more than 20 locations.”345

IMPACT: Qatar and Singapore suffered the greatest communications failures. In addition, cable
operators in Indonesia, the Philippines, South Korea and Japan all suffered disruptions to their
networks.346

C.2 RECENT CABLE THEFTS

Acts of theft and sabotage are not new. The Vietnam case in 2007 can be considered both theft and
sabotage as it was designed to earn a profit by severing optical cable systems.

CASE #1: Vietnam 2007

In March 2007, a large undersea cable disruption in Vietnam occurred due to man-made activity, not
natural disasters. In August 2006, the Vietnamese province of Ba Ria-Vung contracted “several
companies to salvage undersea copper cable left over by the former government of South Vietnam...”347

Instead of recovering old cable, the companies and other fisherman started to pull up new ones. In the
end, over 500km of cables was recovered from five illegal cable ring networks, with “roughly 43 km of
fiber optic cable…belonging to a company in Singapore.”348

342
“Cable fault cuts off West Africa,” BBC News, July 30, 2009. Accessed at http://news.bbc.co.uk/2/hi/technology
343
Victoria Ho, “Typhoon knocks out Asia telecom cable,” CNet News, August 13, 2009. Accessed at
http://news.cnet.com/8301-1035_3-10308348-94.html
344
Robert Clark, “After the typhoon, quake slows net access to a crawl,” Telecomasia.net, August 19, 2009. Accessed at
http://www.telecomasia.net/content/after-typhoon-quake-slows-net-access-crawl
345
Verizon Business press release, “Verizon Business Global Mesh Network Investment Pays Big Dividends for Enterprise
Customers During Multiple Submarine Cable System Disruptions in Asia-Pacific Region; All Restorable Customer Traffic Moved
to New Routes Within Milliseconds,” M2 Newswire.com, September 18, 2009. Accessed at http://www.highbeam.com/doc/1G1-
208059844.html
346
Ek Heng, “Typhoon Morakot damages several subsea cable systems,” Telecomengine.com, August 19, 2009. Accessed at
http://www.telecomengine.com/article.asp?HH_ID=AR_5575
347
Matt Steinglass, “Undersea Cable Thieves Slow Vietnam's Internet Access,” VOA News.com, June 1, 2007. Accessed at
http://www1.voanews.com/english/news/a-13-2007-06-01-voa14-66777382.html

348
Jacqui Cheng, “Phishing plumbs new depths: Vietnamese fishermen sever fiber optic lines,” Arstechnica.com, June 8, 2007.
Accessed at http://arstechnica.com/old/content/2007/06/phishing-plumbs-new-depths-vietnamese-fishermen-sever-fiber-optic-
lines.ars

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The cable thefts forced Vietnam to rely on one submarine cable for 82% of voice and data traffic.349
Other traffic was pushed to terrestrial lines and satellite, creating Internet delays for up to three months
after the thefts.350 To replace an eleven km section, Vietnam paid $5.8 million. More than the money,
Vietnam’s credibility suffered as it sought to restore itself with the rest of the world.351 The Prime Minister
of Vietnam said the theft “directly affects Vietnam’s socio-economic development, national security and
the country’s prestige in the region as well as in the world.”352

So far, press reports of criminal prosecutions are available, but no official report has been published.
Claims for compensation remain ongoing. The Prime Minister embarked on a campaign to educate the
public on the significance of submarine cables so as to avoid anymore unwarranted cable theft.

CASE #2: Jamaica 2008

In Jamaica, “theft of copper cable was reported to have reached epidemic proportions, costing one
company over J$100m ($1.2 million) in losses and forcing them to offer J$1m ($12,000) for information
leading to the arrest of the cable thieves.”353 The problem was out of control with reports stating thieves
were stealing cable “at one end of a route while it was being replaced at the other.”354

CASE #3: South Africa

One South African cable company “recently reported losses due to copper cable theft totaling almost 1bn
rand – over [$100 million] – each year.”355

C.3 Potential Impact

In many of the cases, an undersea cable disruption caused severe problems to one or more countries.
Corporations lost millions, militaries lost missions, publics lost connections, and countries lost national
prestige. Since major banks can operate in upwards of 100 countries around the world, large multi-
national corporations are increasingly vulnerable to outages around the world. The problem has become
less localized and more globalized than it ever has been.

It is clear that undersea fiber-optic communications cables profoundly impact in the age of information.
For instance, nearly all international data and communications flow over undersea cables. The vast
majority of U.S. government international data traffic, at least at the unclassified level, is sent on
commercially owned and operated undersea cables. This situation is similar in almost all countries.

349
“Critical Infrastructure: Submarine Telecommunication Cables,” ICPC, Accessed at
www.iscpc.org/publications/Critical_Infastructure_2009_V2.pps
350
Ibid.
351
See Burnett, Douglas R. and Mick P. Green. "Security of International Submarine Cable Infrastructure: Time to Rethink?."
Legal Challenges in Maritime Security. Eds. Ronán Long, John Norton Moore, Myron H. Nordquist and Rüdiger Wolfrum.
Martinus Nijhoff Publishers, 2008.
352
Ibid.
353
Cathy Holding, “A global cable network of fragile links,” The Independent (UK), March 10, 2009. Accessed at
http://www.independent.co.uk/news/business/sustainit/a-global-cable-network-of-fragile-links-1640448.html
354
Ibid.
355
Ibid.

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The profound importance of cables is also noted in regards to international commerce. The Chief of Staff
for the Chairman of the U.S. Federal Reserve recently stated that “when communications networks go
down, the financial services sector does not grind to a halt, rather it snaps to a halt.”356 Based on the sheer
numbers, it is easy to see why this is true. The Society for Worldwide Interbank Financial
Telecommunication (SWIFT), which describes itself as “the global provider of secure financial messaging
services,” 357 uses undersea fiber-optic communications cables to transmit financial data between 208
countries. In 2004 alone, 9 million messages and approximately $7.4 trillion a day were traded on this
network.358 Today, nearly 15 million messages a day are sent over it. The CLS Bank, which “operates the
largest multi-currency cash settlement system,” trades over 1 million transactions and over $4.7 trillion
dollars a day over the same undersea cables.359 With trillions traded daily, a multi-cable outage, especially
in a regional financial hub, like Taiwan/China/Hong Kong, has enormous ramifications on the trust and
soundness of the global financial order.

Moreover, in the 2006 Hengchun earthquake case, it took ships seven weeks to repair all disrupted cables.
When millisecond delays can lose millions in real-time trading companies, seven weeks is an eternity.
Without a fool-proof back-up plan, communications carriers and end-users can jeopardize profit and
investor confidence. Even with a sound back-up plan, the cost differential in service restoration can be
huge. In the case of Taiwan 2006, the cost of going over land was thirty times the cost of going over
water in the back-up plan.360 Additional latency is typically another problem companies’ face in these
situations too. Satellite back-up is usually not a feasible option.

Secondary effects with cable outages are also significant. A simulation in an advanced industrial country
proved just how important cables are to ancillary industries. The official involved in the simulation noted
that his government soon realized that if one or more cables went down, air traffic controllers “wouldn’t
be able to land planes because you couldn’t check who is on them.”361 In the global age of terrorism,
planes can land only after all passengers are background checked. This example is one of many proving
that cable outages have large first, second and third-order effects that can reverberate within a country,
within a region and within the international community. Governments and companies worldwide need to
do much more to protect against a future multi-cable disruption in order to avoid such effects.
 

356
Stephen Malphrus, “Keynote Address,” ROGUCCI Summit, Dubai, U.A.E., October 19, 2009.
357
Ibid.
358
Ibid.
359
Ibid.
360
Mick Green, ICPC Presentation to the ROGUCCI Summit, October 19, 2009.
361
Comments made by Australian official to ROGUCCI Summit members, October 22, 2009.

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APPENDIX D. Financial Stability Board Core Standards

362
Table 12. 12 Core Standards of the Financial Sector
12 Core Standards
Macroeconomic Policy and Data Transparency
Monetary and financial policy transparency
Fiscal policy transparency
Data dissemination
Institutional and Market Infrastructure
Insolvency
Corporate governance
Accounting
Auditing
Payment and settlement
Market integrity
Financial Regulation and Supervision
Banking supervision
Securities regulation
Insurance supervision
 

362
Financial Stability Board, 12 Key Standards for Sound Financial Systems, www.financialstabilityboard.org/cos/key_standards

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APPENDIX E. Cable-Cutting in War Time – Reference

The Pall Mall Gazette, May 11, 1898

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APPENDIX F. United Nations Convention on the Law of the Seas  

(UNCLOS) – Highlights

The United Nations Convention on the Law of the Seas (UNCLOS) provides special status for undersea
communications cables, including special provisions for their protection.363

Article 21. Laws and regulations of the coastal State relating to innocent passage:
1. The coastal State may adopt laws and regulations, in conformity with the provisions of this Convention
and other rules of international law, relating to innocent passage through the territorial sea, in respect of
all or any of the following: . . . (c) the protection of cables and pipelines;

Article 58. Rights and duties of other States in the exclusive economic zone
1. In the exclusive economic zone, all States, whether coastal or land-­‐locked, enjoy, subject to the relevant
provisions of this Convention, the freedoms referred to in article 87 of navigation and over flight and of
the laying of submarine cables and pipelines, and other internationally lawful uses of the sea related to
these freedoms, such as those associated with the operation of ships, aircraft and submarine cables and
pipelines, and compatible with the other provisions;

Article 79. Submarine cables and pipelines on the continental shelf

1. All States are entitled to lay submarine cables and pipelines on the continental shelf, in accordance with
the provisions of this article.
2. Subject to its right to take reasonable measures for the exploration of the continental shelf, the
exploitation of its natural resources and the prevention, reduction and control of pollution from pipelines,
the coastal State may not impede the laying or maintenance of such cables or pipelines.
3. The delineation of the course for the laying of such pipelines on the continental shelf is subject to the
consent of the coastal State.
4. Nothing in this Part affects the right of the coastal State to establish conditions for cables or pipelines
entering its territory or territorial sea, or its jurisdiction over cables and pipelines constructed or used in
connection with the exploration of its continental shelf or exploitation of its resources or the operations
of artificial islands, installations and structures under its jurisdiction.
5. When laying submarine cables or pipelines, States shall have due regard to cables or pipelines already
in position. In particular, possibilities of repairing existing cables or pipelines shall not be prejudiced.

Article 87. Freedom of the high seas

1. The high seas are open to all States, whether coastal or land-­‐locked. Freedom of the high seas is
exercised under the conditions laid down by this Convention and by other rules of international law. It
comprises, inter alia, both for coastal and land-­‐locked States:
(a) freedom of navigation;
(b) freedom of over flight;
(c) freedom to lay submarine cables and pipelines, subject to Part VI;
(d) freedom to construct artificial islands and other installations permitted under international law, subject
to Part VI;
(e) freedom of fishing, subject to the conditions laid down in section 2;
(f) freedom of scientific research, subject to Parts VI and XIII.
2. These freedoms shall be exercised by all States with due regard for the interests of other States in their
exercise of the freedom of the high seas, and also with due regard for the rights under this Convention
363
October, 1982, www.un.org/Depts/los/convention_agreements/convention_overview_convention.htm.

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with respect to activities in the Area.

Article 112. Right to lay submarine cables and pipelines

1. All States are entitled to lay submarine cables and pipelines on the bed of the high seas beyond the
continental shelf.
2. Article 79, paragraph 5, applies to such cables and pipelines.

Article 113. Breaking or injury of a submarine cable or pipeline

Every State shall adopt the laws and regulations necessary to provide that the breaking or injury by a
ship flying its flag or by a person subject to its jurisdiction of a submarine cable beneath the high
seas done wilfully or through culpable negligence, in such a manner as to be liable to interrupt or obstruct
telegraphic or telephonic communications, and similarly the breaking or injury of a submarine
pipeline or high-­‐voltage power cable, shall be a punishable offence. This provision shall apply also to
conduct calculated or likely to result in such breaking or injury. However, it shall not apply to any break or
injury caused by persons who acted merely with the legitimate object of saving their lives or their ships,
after having taken all necessary precautions to avoid such break or injury.

Article 114. Breaking or injury by owners of a submarine cable or pipeline of another

submarine cable or pipeline
Every State shall adopt the laws and regulations necessary to provide that, if persons subject to its
jurisdiction who are the owners of a submarine cable or pipeline beneath the high seas, in laying of
repairing that cable or pipeline, cause a break in or injury to another cable or pipeline, they shall bear the
cost of the repairs.

Article 115. Indemnity for loss incurred in avoiding injury to a submarine cable or
pipeline
Every State shall adopt the laws and regulations necessary to ensure that the owners of ships who
can prove that they have sacrificed an anchor, a net or any other fishing gear, in order to avoid injuring a
submarine cable or pipeline, shall be indemnified by the owner of the cable or pipeline, provided that the
owner of the ship has taken all reasonable precautionary measures beforehand.

Article 297. Limitations on applicability of section 2

1. Disputes concerning the interpretation or application of this Convention with regard to the exercise by
a coastal State of its sovereign rights or jurisdiction provided for in this Convention shall be subject to the
procedures provided for in section 2 in the following cases:
(a) when it is alleged that a coastal State has acted in contravention of the provisions of this Convention in
regard to the freedoms and rights of navigation, overflight or the laying of submarine cables and pipelines,
or in regard to other internationally lawful uses of the sea specified in article 58;

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INDEX

8   E  
8i  Framework,  16,  59,  80,  122,  140,  154,  170   economic,  7,  18,  20,  28,  33,  34,  47,  64,  67,  71,  72,  73,  
83,  84,  90,  102,  103,  104,  106,  122,  127,  135,  137,  
138,  147,  163,  166,  182  
A   engineering,  22,  52,  56,  81,  85  
academic,  20,  33,  138   environment,  20,  26,  40,  41,  59,  60,  61,  62,  63,  64,  78,  
agreements,  23,  30,  59,  75,  99,  101,  127   94,  96,  98,  112,  113,  114,  126,  146,  156,  161  
assessment,  12,  16,  52,  53,  121   events,  41,  52,  62,  63,  84,  88,  100,  102,  126,  131,  151,  
awareness,  19   152,  153,  154,  157,  162,  164,  167,  170  
EWI,  19,  97  
exercises,  26,  110,  111  
B  
back-­‐up,  19,  85,  107,  137   F  
bandwidth,  18,  19,  20,  45,  49,  70,  73,  77,  79,  82,  85,  92,  
120,  134,  177   failure,  19,  22,  33,  38,  39,  47,  48,  66,  67,  68,  69,  70,  71,  
best  practices,  23,  26,  99,  100,  112,  115,  116,  124,  126,   72,  76,  77,  83,  84,  85,  86,  88,  90,  91,  102,  113,  120,  
145,  149   131,  137,  138,  139,  146,  151,  152,  156,  158,  161,  
bureaucracy,  24   163,  166,  170  
business,  22,  81,  92,  93,  103,  117,  122   failure  modes,  19  
financial  sector,  19,  22,  83,  84  
financial  sector  stakeholders,  21,  27,  117  
C   forum,  46,  50,  54,  112,  124,  156  
cable  ships,  25,  26,  52,  106,  108,  109,  110,  111,  170   framework,  20,  21,  27,  59,  72,  114,  118,  120,  122,  
capacity,  19,  45,  50,  66,  67,  71,  73,  78,  86,  90,  91,  92,   126  
93,  134,  135,  137,  145,  147,  163,  170,  171   future,  7,  20,  21,  32,  34,  38,  52,  54,  59,  70,  79,  80,  88,  
catastrophic  loss,  23,  33,  101,  137,  138   107,  134,  162  
cause,  76,  87,  152,  154  
commitment,  26,  27,  28,  29,  30,  31,  32,  33,  52,  133   G  
congestion,  32,  71,  134,  135,  136  
coordination,  23,  25,  27,  30,  31,  32,  72,  86,  94,  99,  101,   global  level,  19,  24,  27,  35,  36,  38,  41,  47,  52,  77,  117,  
105,  109,  110,  111,  117,  118,  119,  125,  129,  130,   119,  126  
135,  136,  142   Global  Summit,  4,  5,  6,  7,  21,  39,  45,  47,  48,  50,  53,  54,  
core  standard,  28,  121,  122,  123   58,  83,  107,  117,  122,  141,  142,  150,  156  
countermeasure,  153,  162,  163,  165   government,  7,  18,  19,  20,  21,  25,  26,  27,  30,  31,  32,  
crisis,  23,  56,  99,  100,  111   34,  39,  49,  54,  59,  91,  94,  98,  105,  106,  107,  112,  
114,  117,  118,  127,  128,  129,  130,  131,  132,  134,  
135,  139,  156  
D   Guiding  Principles,  19  
damage,  25,  30,  48,  59,  60,  62,  64,  66,  76,  78,  79,  87,  
92,  96,  105,  106,  107,  109,  127,  128,  147,  156,  158,   H  
159,  160  
delay,  22,  74,  76,  85,  94,  105,  107,  114   human,  19,  20,  22,  45,  59,  61,  63,  78,  79,  84,  85,  91,  
distance,  74,  90,  93,  103,  104,  152,  155,  171   105,  112,  113,  151,  153  
due  diligence,  22,  23,  29,  84,  99,  101,  120,  124  
I  
IEEE,  141  
Information,  7,  23,  26,  55,  56,  57,  75,  89,  99,  100,  112,  
114,  115,  116,  124,  126,  131,  147,  149,  165,  168  

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information  sharing,  26,  77,  79,  112,  113,  114,  115,   oversight,  27,  31,  118,  130  
168   owners,  26,  110,  167,  169  
international  cooperation,  19   ownership,  20,  47,  92,  104,  147,  169  
Internet,  92  
intrinsic  vulnerabilities,  7,  20,  40,  45,  46,  48,  59,  61,  
64,  66,  70,  71,  73,  75,  77,  78,  79,  90,  126,  152,  153,  
P  
154,  156,  158,  161,  162   participant,  12,  16,  52,  53  
Investment,  22,  81,  92   payload,  20,  22,  49,  59,  67,  73,  74,  78,  84,  85,  104,  134,  
Ishikawa,  154,  156,  158,  160,  162   151  
isolation,  33,  93,  137   personnel,  26,  60,  109,  110  
piracy,  20,  41,  79,  109  
K   pirates,  25,  109  
planning,  25,  26,  33,  94,  98,  105,  106,  108,  109,  110,  
key  observations,  7,  18,  21,  22,  23,  35,  80,  81,  98,  101,   112,  120,  121,  138,  139,  141,  151,  170  
106,  117,  131   policy,  5,  7,  18,  20,  21,  24,  30,  31,  34,  38,  45,  47,  50,  52,  
Kissinger,  Henry,  19,  137   54,  64,  74,  81,  103,  104,  117,  122,  127,  128,  129,  
130,  165,  166,  180  
Porthcurno  Telegraph  Museum,  12,  53,  54,  56,  142  
L   practices,  30,  31,  32,  63,  72,  107,  112,  116,  117,  120,  
landing,  60,  90,  127,  167,  169   121,  122,  123,  127,  128,  129,  130,  132,  133,  136,  
latency,  22,  49,  73,  76,  84,  85,  103,  104,  121,  151   160,  168  
law,  30,  75,  95,  96,  115,  127,  182   price,  92  
leader,  98   priority,  19,  25,  28,  30,  31,  32,  34,  74,  76,  77,  105,  120,  
leadership,  20,  27,  29,  52,  98,  117,  118,  125,  141   121,  127,  128,  130,  131,  134,  135  
limitation,  67,  134,  162   private  sector,  7,  18,  19,  20,  23,  24,  25,  26,  27,  29,  30,  
31,  32,  33,  34,  39,  47,  53,  76,  77,  88,  98,  102,  103,  
104,  106,  107,  108,  110,  111,  113,  114,  116,  118,  
M   121,  123,  125,  128,  129,  130,  132,  133,  135,  138,  
maintenance,  24,  45,  63,  66,  67,  71,  78,  84,  93,  94,  102,   151,  171  
103,  104,  112,  128,  130,  151,  182   probability,  33,  66,  90,  137,  138,  145,  146,  151,  153  
marine  activity,  91,  127   public,  7,  19,  20,  31,  34,  35,  40,  48,  79,  81,  82,  89,  92,  
measurements,  23,  29,  99,  101,  124   98,  104,  109,  112,  117,  129,  131,  132,  138,  139,  146,  
151,  154,  155,  158,  167,  168,  169,  170,  171  
publicly  available  information,  167  
N  
nation-­‐state,  24,  25,  26,  30,  31,  32,  103,  106,  107,  110,   R  
111,  113,  116,  127,  128,  129,  130,  135,  136  
network,  20,  26,  33,  34,  35,  38,  40,  41,  45,  59,  62,  69,   regional,  19,  20,  24,  33,  101,  104,  116,  132,  138,  153,  
71,  72,  73,  76,  77,  78,  79,  82,  83,  90,  91,  102,  103,   163  
112,  114,  117,  121,  124,  134,  135,  145,  146,  151,   regulations,  23,  30,  59,  75,  99,  101,  127  
152,  166,  170   repairs,  23,  24,  99,  100,  105,  107  
network  operators,  20,  33,  34,  35,  38,  41,  72,  76,  77,   restoration,  25,  26,  105,  106,  113,  156,  170  
78,  135   risk,  7,  22,  24,  27,  28,  29,  34,  39,  64,  66,  72,  74,  76,  84,  
non-­‐disclosure  agreement,  29,  88,  125   90,  93,  103,  104,  107,  117,  120,  121,  122,  124,  125,  
126,  136,  138,  163  
robustness.,  21  
O   role  model,  31,  88,  129,  130  
routes,  22,  24,  33,  44,  62,  71,  72,  75,  79,  81,  85,  86,  90,  
operation,  20,  25,  32,  38,  63,  66,  71,  76,  78,  100,  102,  
93,  97,  102,  103,  104,  109,  131,  132,  137,  145,  151,  
105,  110,  117,  131,  135,  146,  151,  156,  158,  159,  
156,  161,  163,  169  
168,  182  
operational  risk,  29,  84,  120,  122  
optic,  62,  65,  66,  69,  85,  86,  95,  109,  145,  174,  176,   S  
177,  178,  179  
optical,  68,  69,  86,  87,  91,  144   satellites,  19  
outage,  125,  126,  146,  151,  152,  155,  157,  159,  161,   science,  22,  57,  81,  85,  137,  150  
167,  170   scope,  19,  35,  40,  44,  45,  75,  112,  115,  117,  118,  122,  
overload,  23,  32,  99,  101,  134,  135,  136   125,  173  

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security,  7,  18,  19,  20,  21,  23,  32,  33,  34,  40,  48,  49,  55,   terrorist,  20,  48,  63,  76,  78  
56,  59,  79,  82,  84,  96,  97,  98,  101,  105,  109,  110,   topology,  47,  90,  91,  102,  114  
112,  114,  116,  127,  131,  132,  135,  137,  144,  147,   trusted  information  sharing,  23,  26,  57,  99,  100,  112,  
148,  149,  150,  151,  157,  165,  169,  170,  172,  178   115,  124,  149  
sensitive,  22,  26,  66,  70,  74,  85,  92,  103,  112,  113,  114,  
115,  116,  145,  152,  170  
service  providers,  20,  32,  33,  34,  35,  38,  39,  41,  72,  76,  
U  
78,  92,  120,  121,  123,  135,  169   UNCLOS,  94,  144  
single  points  of  failure,  22,  24,  90,  94,  102,  103   United  Nations,  15,  94,  96,  109,  144,  182  
software,  20,  59,  70,  71,  79,  86,  88,  151,  163  
sovereignty,  20,  24,  98,  104,  107  
stakeholder,  18,  19,  20,  27,  29,  48,  49,  50,  52,  71,  81,   V  
97,  98,  112,  116,  117,  118,  119,  124,  125,  126,  133,   virtual  earth,  63,  87,  147  
138,  170   vulnerabilities,  12,  13,  61,  63,  64,  66,  70,  71,  73,  75,  78,  
standard,  23,  28,  99,  101,  120,  122,  124,  126,  146   165  
statistics,  18  
survivability,  40  
W  
T   water  zones,  16,  95  

technology,  18,  19,  28,  29,  33,  38,  39,  40,  54,  62,  65,  67,  
71,  73,  79,  81,  82,  83,  85,  86,  88,  97,  120,  121,  122,   Z  
124,  137,  145,  146,  152,  168,  177  
zone,  47,  72,  84,  182  
terrestrial,  32,  33,  90,  134,  137  
territorial  water,  24  

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