

FINANCE & LEGAL
EXORDIUM
FROM THE PUBLISHER
WELCOME TO ISSUE 141 OF SUBTEL FORUM, OUR FINANCE & LEGAL EDITION FEATURING A PREVIEW OF ICPC PLENARY 2025!
Avery long Virginia winter is quickly disappearing, and the snow is now long gone. Technically we are still in winter until next week, but looking around you see people acting and dressing as if the next season has already started. Running in the cold dark after work has often been a trial and sometimes soul crushing, but now with the time change evenings are enjoyable again.
NEW SUBTEL FORUM WEBSITE
Spring is the season of renewal. For this edition’s Exordium, I’m excited to showcase the all-new SubTelForum.com —a completely refreshed platform designed to enhance how we deliver industry news and analysis. This overhaul isn’t just cosmetic; it fundamentally improves how content is organized and accessed. Our What’s Trending section now ranks the most-viewed posts of the day in real-time, giving readers instant insight into the hottest topics, while Popular This Month highlights the most-read articles from the past 30 days. We’ve also introduced Editor’s Pick, a curated selection of must-read stories that offer deeper analysis and industry impact. The new site’s modernized layout and intuitive design make for a smoother, more engaging experience—whether you’re browsing on desktop or mobile. More importantly, this upgrade allows for seamless integration of future enhancements, ensuring we stay at the forefront of submarine cable industry coverage. Click here to check it out!
2025 SUBMARINE CABLE MAP(S)
The 2025 Submarine Cables of the World wall map is
now complete and has already been distributed at PTC in Honolulu and Submarine Networks EMEA in London. Next, an updated version will be available at Submarine Networks World in September, followed by IWCS Forum 2025 in Pittsburgh in October, ensuring continued global visibility for your brand. Want your logo prominently displayed in Singapore and Pittsburgh? [Click here to secure your spot!]
As previously announced, we are preparing the SubOptic ’25 Submarine Cable Map, a bespoke edition created exclusively for the SubOptic 2025 conference in Lisbon this June. This special edition will highlight the latest advancements in subsea cable technology and global connectivity contrasted with our history making past, providing a unique and highly valued resource for attendees. Distributed only at SubOptic ’25, this map offers an exceptional opportunity to showcase your brand at one of the industry’s most anticipated events. Want to make an impact in Lisbon? [Click here!]
CABLE ALMANAC – FEBRUARY EDITION
The 53rd edition of SubTel Forum’s Submarine Cable Almanac was published in February and is now available at SubTelForum.com. This latest edition features the most up-to-date information on global submarine cable systems, including 11 newly added systems and 17 updated systems, ensuring access to the latest industry data. A key focus in this edition is the age distribution of submarine cables, revealing that 52 new systems are planned, while nearly half of existing cables are over 16 years old. By categorizing cables by age, this edition provides valuable insights into development cycles, network longevity, and infrastructure planning.
Looking ahead, the next edition of the Submarine Cable Almanac will be published in May, continuing our commitment to providing the most comprehensive and current data in the industry. Interested in sponsoring May’s almanac? Contact Nicola Tate.
THANK YOU
Thank you as always to our awesome authors who have contributed to this issue of SubTel Forum. Thanks also for their support to this issue’s advertisers: Fígoli Consulting, SubOptic 2025, and WFN Strategies. Of course, our ever popular “where in the world are all those pesky cableships” is included as well.
A Publication of Submarine Telecoms Forum, Inc. www.subtelforum.com | ISSN No. 1948-3031
PRESIDENT & PUBLISHER: Wayne Nielsen | wnielsen@subtelforum.com | [+1] (703) 444-2527
VICE PRESIDENT: Kristian Nielsen | knielsen@subtelforum.com | [+1] (703) 444-0845
ANALYTICS: Kieran Clark | kclark@subtelforum.com | [+1] (540) 533-6965
SALES: Nicola Tate | ntate@associationmediagroup.com | [+1] (804) 469-0324 subtelforum.com/advertise-with-us
DESIGN & PRODUCTION: Weswen Design | wendy@weswendesign.com
DEPARTMENT WRITERS:
Andrés Fígoli, Caroline Crowley, Kieran Clark, Melina Tisopulos, Nicola Tate, Philip Pilgrim, Stephanie Schaupp, Syeda Humera, and Wayne Nielsen
FEATURE WRITERS:
Andrew Lipman, Anjali Sugadev, Christian Keogh, David Kiddoo, Derek Cassidy, Glenn Hovermale, Kristian Nielsen, Lucy Bricheno, Mike Clare, Mike Conradi, Isobel Yeo, and Ulises Pin
NEXT ISSUE: May 2025 – Global Capacity featuring SubOptic 2025 Preview
MAGAZINE ARCHIVE: subtelforum.com/magazine-archive

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BOARD OF DIRECTORS: Margaret Nielsen, Wayne Nielsen, Kristian Nielsen and Kacy Nielsen
Contributions are welcomed and should be forwarded to: pressroom@subtelforum.com.

Good reading – Slava Ukraini STF

Wayne Nielsen, Publisher
Submarine Telecoms Forum magazine is published bimonthly by Submarine Telecoms Forum, Inc., and is an independent commercial publication, serving as a freely accessible forum for professionals in industries connected with submarine optical fiber technologies and techniques. Submarine Telecoms Forum may not be reproduced or transmitted in any form, in whole or in part, without the permission of the publishers.
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Copyright © 2025 Submarine Telecoms Forum, Inc.
SUBMARINE TELECOMS
ISSUE 141 | MARCH 2025


11 QUESTIONS WITH RYAN WOPSCHALL
Talking Submarine Cable Industry with ICPC’s General Manager

FCC PROPOSES SIGNIFICANT EXPANSION OF REGULATION OVER SUBSEA CARRIERS AND RELATED BROADBAND INFRASTRUCTURE
FCC Proposes Stricter
Submarine Cable Regulations By Andrew
Lipman and Ulises Pin
AGENDA OF ICPC PLENARY ‘25
Geopolitics and Spatial Planning in Subsea
HOW CAN WE SECURE OR PROTECT A SUBMARINE CABLE OR IS IT DOWN TO NETWORK AND COMPONENT MONITORING ONLY?
Challenges in Securing Submarine Cable Networks By Derek Cassidy

WHEN NATURE STRIKES: THE HIDDEN THREATS TO THE WORLD’S SUBSEA CABLES
Natural Hazards Threatening
Global Subsea Cables By Lucy Bricheno, Mike Clare and Isobel Yeo

REGULATING AFRICA’S DIGITAL LIFELINES: A BRIEF OVERVIEW OF SUBMARINE CABLE GOVERNANCE IN AFRICA
Regulating Africa’s Submarine Cable Governance Landscape By Anjali Sugadev

By Glenn Hovermale and Kristian Nielsen
Finance and Legal: A Snapshot of Where We Are and Where We Are Headed 32
WORLD ARE ALL THOSE PESKY CABLESHIPS?
the missions of cableships crucial to undersea connectivity.
By Mike Conradi and Christian Keogh



INSIDE THE WORLD OF SUBTEL FORUM: A COMPREHENSIVE GUIDE TO SUBMARINE CABLE RESOURCES
TOP STORIES OF 2019
The most popular articles, Q&As of 2019. Find out what you missed!
NEWS NOW RSS FEED
Welcome to an exclusive feature in our magazine, where we explore the captivating world of SubTelForum.com, a pivotal player in the submarine cable industry. This expedition takes us on a detailed journey through the myriad of resources and innovations that are key to understanding and connecting our world beneath the oceans.
mapping efforts by the analysts at SubTel Forum Analytics, a division of Submarine Telecoms Forum. This reference tool gives details on cable systems including a system map, landing points, system capacity, length, RFS year and other valuable data.
DISCOVER THE FUTURE: THE SUBTEL FORUM APP
CONNECTING THE DEPTHS: YOUR ESSENTIAL GUIDE TO THE SUBTEL FORUM DIRECTORY
Keep on top of our world of coverage with our free News Now daily industry update. News Now is a daily RSS feed of news applicable to the submarine cable industry, highlighting Cable Faults & Maintenance, Conferences & Associations, Current Systems, Data Centers, Future Systems, Offshore Energy, State of the Industry and Technology & Upgrades.
PUBLICATIONS
Submarine Cable Almanac is a free quarterly publication made available through diligent data gathering and
Submarine Telecoms Industry Report is an annual free publication with analysis of data collected by the analysts of SubTel Forum Analytics, including system capacity analy sis, as well as the actual productivity and outlook of current and planned systems and the companies that service them.
CABLE MAP
In our guide to submarine cable resources, the SubTel Forum Directory shines as an essential tool, providing SubTel Forum.com readers with comprehensive access to an array of vetted industry contacts, services, and information. Designed for intuitive navigation, this expansive directory facilitates quick connections with leading vendors, offering detailed profiles and the latest in submarine cable innovations. As a dynamic hub for industry professionals, it fosters community engagement, ensuring our readers stay at the forefront of industry developments, free of charge.
2024 marks a groundbreaking era for SubTel Forum with the launch of its innovative app. This cutting-edge tool is revolutionizing access to submarine telecommunications insights, blending real-time updates, AI-driven analytics,
The online SubTel Cable Map is built with the industry standard Esri ArcGIS platform and linked to the SubTel Forum Submarine Cable Database. It tracks the progress of

and a user-centric interface into an indispensable resource for industry professionals. More than just a technological advancement, this app is a platform fostering community, learning, and industry progression. We encourage you to download the SubTel Forum App and join a community at the forefront of undersea communications innovation.
YOUR DAILY UPDATE: NEWS NOW RSS FEED
Our journey begins with the News Now updates, providing daily insights into the submarine cable sector. Covering everything from the latest technical developments to significant industry milestones, this feed ensures you’re always informed about the latest trends and happenings. It’s an essential tool for professionals who need to stay on top of industry news.
THE KNOWLEDGE HUB: MUST-READS & Q&AS
Dive deeper into the world of submarine communications with our curated collection of articles and Q&As. These insightful pieces offer a comprehensive look at both the history and current state of the industry, enriching your understanding and providing a broader perspective on the challenges and triumphs faced by submarine cable professionals.
IN-DEPTH PUBLICATIONS
• Submarine Cable Almanac: This quarterly treasure trove provides detailed information on global cable systems. You can expect rich content including maps, data on system capacity, length, and other critical details that sketch a vivid picture of the global network.
• Submarine Telecoms Industry Report: Our annual report takes an analytical approach to the industry, covering everything from current trends to capacity analysis and future predictions. It’s an invaluable resource for anyone seeking to understand the market’s trajectory.
VISUALIZING CONNECTIONS: CABLE MAPS
• Online SubTel Cable Map: An interactive tool mapping over 550 cable systems, perfect for digital natives who prefer an online method to explore global connections.
• Printed Cable Map: Our annual printed map caters to those who appreciate a tangible representation of the world’s submarine fiber systems, detailed in a visually appealing and informative format.
EXPLORING OUR PAST: MAGAZINE ARCHIVE
Explore the Submarine Telecoms Forum Magazine Archive, a comprehensive collection of past issues spanning 23+ years of submarine telecommunications. This essential resource offers insights into project updates, market trends, technological advancements, and regulatory changes. Whether researching industry developments or seeking

expert analysis, the archive provides valuable perspectives on the technologies and trends shaping global connectivity.
FIND THE EXPERTS: AUTHORS INDEX
Our Authors Index is a valuable tool for locating specific articles and authors. It simplifies the process of finding the information you need or following the work of your favorite contributors in the field.
TAILORED INSIGHTS: SUBTEL FORUM BESPOKE REPORTS
• Data Center & OTT Providers Report: This report delves into the evolving relationship between cable landing stations and data centers, highlighting trends in efficiency and integration.
• Global Outlook Report: Offering a comprehensive analysis of the submarine telecoms market, this report includes regional overviews and market forecasts, providing a global perspective on the industry.
• Offshore Energy Report: Focusing on the submarine fiber industry’s oil & gas sector, this report examines market trends and technological advancements, offering insights into this specialized area.
• Regional Systems Report: This analysis of regional submarine cable markets discusses capacity demands, development strategies, and market dynamics, providing a detailed look at different global regions.
• Unrepeatered Systems Report: A thorough examination of unrepeatered cable systems, this report covers project timelines, costs, and operational aspects, essential for understanding this segment of the industry.
• Submarine Cable Dataset: An exhaustive resource detailing over 550 fiber optic cable systems, this dataset covers a wide range of operational data, making it a go-to reference for industry specifics.
SubTelForum.com stands as a comprehensive portal to the dynamic and intricate world of submarine cable communications. It brings together a diverse range of tools, insights, and resources, each designed to enhance understanding and engagement within this crucial industry. From the cutting-edge SubTel Forum App to in-depth reports and interactive maps, the platform caters to a wide audience, offering unique perspectives and valuable knowledge. Whether you’re a seasoned professional or new to the field, SubTelForum.com is an indispensable resource for anyone looking to deepen their understanding or stay updated in the field of submarine telecommunications.
SUBTEL CABLE MAP UPDATES
BY KIERAN CLARK
The SubTel Cable Map, built on Esri’s ArcGIS platform, offers a dynamic and interactive way to explore the global network of submarine cable systems. This essential resource provides detailed information on over 440 current and upcoming cable systems, more than 50 cable ships, and over 1,000 landing points. Directly connected to the SubTel Forum Submarine Cable Database and integrated with our News Now Feed, the map gives users real-time insights into the industry, allowing them to view current and archived news related to each cable system.
Submarine cables are the backbone of global communications, carrying over 99% of the world’s international data. These cables connect continents and enable the seamless connectivity we rely on for everything from daily communications to critical business operations. Without this vast network, fast, efficient communication between countries and continents would not be possible.
Our analysts work diligently to keep the SubTel Cable Map up to date with data from the Submarine Cable Almanac, along with valuable feedback from users. This ensures a comprehensive and accurate view of the industry, highlighting both the latest deployments and key updates. As the year draws to a close, updates to the map may slow slightly as we move into the holiday season, but our commitment
Submarine cables are the backbone of global communications, carrying over 99% of the world’s international data. These cables connect continents and enable the seamless connectivity we rely on for everything from daily communications to critical business operations.
to delivering timely, reliable information remains as strong as ever.
We also want to highlight that a sponsor slot is currently available for the SubTel Cable Map. Sponsorship offers an excellent opportunity to showcase your organization to a global audience, with your logo prominently displayed on the map and linked directly to your company’s offerings. This is a unique chance to demonstrate your commitment to global connectivity and support for the submarine cable industry.
We invite you to explore the SubTel Cable Map and gain a deeper understanding of the vital role submarine cable systems play in our interconnected world. As always, if you are a point of contact for a system or company that requires updates, please email kclark@subtelforum.com.

Below is the full list of systems added and updated since the last issue of the magazine:
We hope the SubTel Cable Map proves to be a valuable resource for you, offering insight into the continually evolving submarine cable industry. Dive into the intricate network that powers our global communications today. Happy exploring! STF

KIERAN CLARK is the Lead Analyst for SubTel Forum. He originally joined SubTel Forum in 2013 as a Broadcast Technician to provide support for live event video streaming. He has 6+ years of live production experience and has worked alongside some of the premier organizations in video web streaming. In 2014, Kieran was promoted to Analyst and is currently responsible for the research and maintenance that supports the Submarine Cable Database. In 2016, he was promoted to Lead Analyst and his analysis is featured in almost the entire array of Subtel Forum Publications.
Do you have further questions on this topic?
ASK AN EXPERT
MARCH 17, 2025
Decommissioned/Removed Systems:
BlueMed
Boriken
East Micronesia Cable
Galápagos
Gold Data 1
OEG
SING
TEAS
VCS
WALL-LI
Newly Added Systems: Apollo East and West
Arctic Way Cable Australia Connect Interlink
Bosun
Celia
EMC West-1
EMC West-2
Manta
ORCA
Project Waterworth
PTC’25: NAVIGATING SUSTAINABILITY IN A CHANGING INFRASTRUCTURE LANDSCAPE
BY MELINA TISOPULOS, CAROLINE CROWLEY, AND STEPHANIE SCHAUPP
After PTC’24 last year, our small team of UC Berkeley undergraduates left feeling empowered. At that point, we had spent a semester familiarizing ourselves with critical digital infrastructures. We had also been researching solutions that could mitigate the internet’s environmental impacts. We were already passionate about recording and driving meaningful change in subsea and data center sustainability, but PTC affirmed that the industry was just as eager to engage with us. Panelists recognized our work and called attention to the need for young and motivated minds to shape the future of sustainability efforts.
Returning to PTC a year later, we have embraced the industry’s call to action. The representation of our Berkeley team has more than doubled in size, growing from four students to nine. Two of our veteran attendees returned as speakers and presented a research paper inspired by last year’s conversations on subsea cable recycling.
PTC’25 has again left us motivated to continue our research work and has provided new and intriguing ideas and perspectives for us to consider. In this article, we discuss some of our key takeaways from the conference. This includes the significance of subsea cable resilience for global connectivity and the adoption of green energy sources to meet data center power
demand. We describe the Sustainable Subsea Networks team’s contributions to the conference, including an exploration of the permitting challenges associated with cable recovery and recycling, satellite-driven broadband connectivity in Brazil, developing green metrics for subsea cables, and creating digital infrastructure education at UC Berkeley. Our goal is not only to participate in conversations about sustainable industry practices, but to open this dialogue to a larger audience–especially to our student peers around the world.
RETHINKING MEETING DATA CENTER POWER DEMAND
Similar to last year, power sourcing for data centers remains a signifi-
cant concern for the broader digital infrastructure industry. As AI, 5G, and other emerging technologies are further integrated into major industries and everyday technology use, data center energy needs will only continue to grow. Oftentimes, meeting this demand is perceived as being at odds with using renewable sources. However, given our team’s interest in sustainable infrastructure operations, it was exciting that there was a panel dedicated to green energy for data centers where many of the speakers challenged this notion. Several panelists presented clean energy investment as not only compatible with but the key to meeting increased data center demand. Claudia Masset, Vice President of Global Sales for the
Cloud and Service Provider Segment for Schneider Electric, views the procurement of green energy as integral to the future of data center operations, arguing that “we’re never going to be able to supply the energy we need, the power we need, if we don’t think of sustainable solutions.” Similarly, Jeyakumar Janakaraj, CEO of AdaniConneX, advocates for holistic, strategic, and regionally-variable solutions to address both green and baseload needs.
Last year’s conversations on the “Bring Your Own Power” movement also re-emerged at PTC’25. The deployment of data center microgrids has gained momentum, especially in the United States where reliance on the central grid is becoming increasingly difficult and expensive. Transitioning data centers to on-site power can help decrease reliance on the central grid, potentially reducing costs and improving energy efficiency. Seppo Ihalainen, CEO of Firma-Rise, sees microgrids as the logical next step from a market standpoint. Ihalien emphasizes that beyond cutting energy costs, data centers using microgrids can earn “50% more profits” by selling energy back to the central grid. Microgrids also hold major implications for sustainability. If powered by renewable sources, they can help hyperscale data centers significantly reduce carbon emissions even with increased power usage.
There were also discussions on the variability of natural gas and nuclear energy, both of which have gained traction as potential solutions for meeting energy demand. There was a consensus among the panelists that while these sources have their benefits, neither are definite solutions. Pete DiSanto, Executive Vice President of Enchanted Rock, sees large nuclear plants as taking too long to build. However, he believes

small modular reactors (SMRs) could be a “gamechanger,” although they are still years away from mainstream use. Managing Director of JLL, Kristen Vosamer, sees natural gas, nuclear, and carbon capture as good “interim” sources as we transition to cleaner ones, and an improved alternative for backup power. However, the panel echoed what Janakaraj described as an “all of the above” approach to solving the power problem. With price, accessibility, and sustainability all being critical industry concerns, he says there is no single energy source that can fulfill all these needs. Instead, we need to take into account varying regional needs and resources to strategically meet energy demands. At the core of this strategy is an alignment of policymakers, energy providers, and the industry.
With renewable power for data centers being a key research area for our undergraduate team, these discussions were insightful. It was particularly interesting to see how conversation has evolved since the last PTC, with increased attention towards the “Bring
Your Own Power” movement and its potential benefits. Most importantly, it was reassuring that sustainability remains a significant focus in data center design and construction.
NAVIGATING DISRUPTIONS: THE NEED FOR SUBSEA RESILIENCY
Resiliency was at the forefront of conversations in the subsea cable industry. This past year, a series of cable breaks brought attention to the critical importance of subsea network redundancy and security. In February 2024, three cables were accidentally cut in the Red Sea, which is responsible for carrying 80 to 90% of digital traffic between Asia, Africa, and Europe. This past December, cables in the Baltic responsible for European communications were accidentally severed by shipping boats for a second time, underscoring the importance of addressing network resiliency and security. Additionally, multiple cable outages in Africa had major implications for the continent’s communication, banking services, and internet
The Sustainable Subsea Networks academic research team and students at PTC’25. From bottom left to right: Ziwei Chen, Ella Hebert, Isabelle Cherry, Nicole Starosielski, Melina Tisopulos, Iago Bojczuk, Julia Huggins. From top left to right: Isadora Bratton-Benfield, Caroline Crowley, Stephanie Schuapp, Michael Brand
access. All of these point toward a need for greater diversity in infrastructure–including not only cables, but also cable landing stations and routing technologies. While having the right technology is important, infrastructure alone is not enough to achieve resiliency. Many panelists emphasized the growing significance of collaboration among operators and government, as well as a more strategic approach to regulations.
Robust, efficient subsea systems are essential to cable resiliency. However, permitting for new cable projects and repairs is often a lengthy process, one becoming increasingly challenging in response to federal regulations. Ryan Wopschall, General Manager of the International Cable Protection Committee, notes that over the last few years, governments have grown more aware and interested in subsea cables. As resiliency becomes a concern beyond the “insular” industry environment, governments have become a more prominent presence in the project execution process. Group CEO of Seacom, Alpheus Mangale identifies one of the greatest permitting challenges as navigating the unique regulations established by different countries, as well the need to receive approval from several agencies within a single nation. From our perspective, it is likely that people and governments are in favor of having clear regulatory frameworks to mitigate any potential liability. From our research, we have seen that clarity in regulatory frameworks can likewise increase sustainability.
While they cannot match the performance of cables, several participants at the conference highlighted the capacity of satellites to support
SUBSEA
subsea cable resiliency. This is especially important for regions with limited cable connectivity. For instance, many Pacific Island nations rely on a single cable. Although expanding and diversifying Pacific cable routes is the long-term goal, Tenanoia Simona, CEO of Tuvalu Telecommunications Corporation emphasized that for now,


satellites are essential for redundancy. PTC broadened our perspective on ongoing challenges to achieve cable resiliency. A key takeaway for us is the need to balance the growing role of government oversight with the industry’s need for efficiency. Finding
this balance, many conference participants emphasized, needs to mitigate the growing challenge of geopolitics in diversifying cable routes. We have been left with much to consider, including how the advocacy for streamlining regulations to support new, resilient cable deployment might be applicable for sustainability.
SUSTAINABLE SUBSEA NETWORKS AT PTC
While it was meaningful to listen to emerging issues in the industry, our team also had the opportunity to engage in conversations of our own. Two of our undergraduate researchers, Michael Brand and Isabelle Cherry, presented their paper on the policy and regulatory challenges for the recovery and recycling of subsea cables. Inspired by discussions at PTC’24, the paper examines cable recovery as a sustainable industry practice that reduces the demand for raw materials and prevents seabed clutter. Brand and Cherry, however, showed that other important regulations that support marine sustainability and environmental protection could create barriers to recovery and recycling. The paper highlights three of these relevant policy areas: environmental impact assessments (EIAs) that could complicate the recovery process, marine biodiversity protections that make it unclear if recovery could occur within certain areas, and import and export regulations that could increase cable shipping distance and subsequently carbon emissions.
SSN global policy consultant and PTC Emerging Scholar Iago Bojczuk, a PhD candidate at the University of Cambridge, presented a paper on Brazil’s SGDC-1 satellite
SSN research assistants Isabelle Cherry and Michael Brand presented on the regulatory challenges of subsea cable recovery and recycling.
and its issues of governance and representation in national media. Bojczuk shows that the satellite was intended to expand broadband outreach, particularly for rural schools and communities, but its capabilities and impact on the connectivity gap were often exaggerated by government-issued media—often relying on a narrative of promises without considering longterm changes. For instance, the rural schools highlighted were depicted as having greater technology access than most actually do, which is common in discussions of large-scale infrastructure in Global South contexts. Bojczuk’s research suggests that there is a need for a strategic, long-term satellite connectivity plan in countries with competing priorities and varied challenges for broadband connectivity, including improved and transparent public-private partnership models and community integration.
Our work was also featured in the Submarine Cable Poster Session, where we presented “The Challenges and Possibilities of Green Metrics,” a poster documenting our team’s ongoing effort to establish sustainability metrics for the lifecycle of subsea cables. A key finding of our latest iteration of the carbon footprint model is that the capacity of lifetime total emissions of a new transatlantic system model reduces carbon emissions by about 44% in comparison to systems used in the 1990s. The poster also outlined our approach to establishing cable landing station (CLS) sustainability, with both the insight of CLS owners and existing data center metrics like Power Usage Effectiveness (PUE) being taken into account.
As UC Berkeley students, we were also excited about the final poster,
which introduced UC Berkeley’s new Certificate in Global Digital Infrastructure. Beginning this summer, it will be the first undergraduate certificate program guided by an interdisciplinary approach to digital infrastructure. The program intends to make infrastructure operations accessible to a diverse range of students and

enable the next generation to enter the industry. We look forward to meeting students that come into this program with a similar interest in the infrastructure behind the internet.
WHAT’S NEXT?
Supporting infrastructure sustainability while meeting the demand of AI will be very challenging, with the urgent need for cable resiliency only increasing the complexity of this issue. However, we remain hopeful and energized to strategically collaborate and tackle these issues head-on. While not easy, the discussions at PTC encourage us to continue believing in and striving
towards a pathway to a more resilient and sustainable global internet. We are eager to continue our investigations into infrastructure sustainability concerns and to be active and informed participants in essential industry conversations. Equally important, however, we hope to educate and empower our generation to care about these critical issues.
We have established several initiatives to increase the awareness of these otherwise invisible infrastructures and their implications for sustainability and global equity. A key manifestation of this is our “Building a Sustainable Internet” DeCal course at UC Berkeley. Taught by our undergraduate research team, the course educates an interdisciplinary student audience on the significance of infrastructure like data centers, subsea cables, and cable landing stations, as well as their intersection with the environment, equity, and geopolitics. In its first semester this fall, it was fully enrolled with over 30 students. This semester, it has expanded to over 100. Our key takeaways from PTC’25 on cable resiliency, data center power sourcing, and youth empowerment within the industry will be transformed into course lectures, expanding the conference’s impact from our small research team to a lecture hall of Berkeley students.
We also intend to make infrastructure education more accessible with our upcoming podcast with Data Center Dynamics, “Byte Sized: Insights into Internet Infrastructure.” Hosted and produced by student researchers, each episode aims to answer an essential question about the industry’s approach to building a globally accessible and environmentally responsible internet. Many of PTC’s prominent discussions,
SNN global policy consultant and PTC Emerging Scholar Iago Bojczuk presented on Brazil’s SGDC1 satellite
like strategic cable resiliency, the future of data center power sourcing, and the deployment of satellite technologies, will be featured topics explored through short-form interviews with industry leaders. “Byte-Sized” will not only be used for UC Berkeley’s internet sustainability curriculum, but we hope will help engage students and foster meaningful conversations about infrastructure sustainability, resiliency, and equity around the world.
Our commitment to a sustainable present and future remains the key motivator for our research. While not all of our peers are familiar with the digital infrastructure industry, we know many share our value of the environment. Transforming our work and insights from PTC into educational opportunities will allow us to make the digital infrastructure industry accessible to a broad range of students. We hope to diversify the perspectives involved in solving these critical issues, as well as increase hands-on support. We are ready to not only be a part of, but help cultivate the next generation of leaders in digital infrastructure sustainability.
The Sustainable Subsea Networks is an academic-industry collaboration and research initiative of the SubOptic Foundation to enhance the sustainability of subsea telecommunications cables. This article is an output funded by the Internet Society Foundation. STF
INFORMATION FOR STF

MELINA TISOPULOS is an undergraduate at the University of California, Berkeley studying Society and Environment (B.S.) and Media Studies (B.A). She is a research assistant for the SubOptic Foundation’s
SUBSEA


Sustainable Subsea Networks team, where she investigates the efficiency of data center energy regulations and teaches a course on digital infrastructure sustainability.

CAROLINE CROWLEY is an undergraduate student at the University of California, Berkeley pursuing a B.S. in Environmental Economics and Policy. She works as a research assistant with the SubOptic Foundation’s Sustainable Subsea Networks team. Her work analyzes global, national, and local
policies regulating the environmental sustainability and resilience of digital infrastructure.

STEPHANIE SCHAUPP is an undergraduate researcher at the University of California, Berkeley pursuing a B.S. in Energy Engineering and in Environmental Economics and Policy.She is a research assistant for the SubOptic Foundation’s Sustainable Subsea Networks team, focusing on sustainable project management for subsea cables and exploring renewable energy solutions for cable landing stations.
Video Recap
“Building a Sustainable Internet” students were given maps of global subsea cable routes, donated by Submarine Telecoms Forum.
SNN research assistant Melina Tisopulos and “Media Technologies: Digital Infrastructure” UC Berkeley students.
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ANALYTICS
Click here to view the entire 2024-2025 Industry Report
GLOBAL OVERVIEW: SYSTEM GROWTH
[Reprinted Excerpts from SubTel Forum’s 2024/25 Submarine Industry Report]
SYSTEM GROWTH
The submarine cable industry continues to adapt and evolve in the aftermath of the COVID-19 pandemic, with its long-term impacts becoming more apparent. While initial disruptions were anticipated to manifest in 2020 and 2021, the more substantial effects on project timelines and completions have unfolded in the years following. Projects already in the pipeline before the pandemic generally maintained momentum, but those still in the early stages faced considerable delays, impacting the pace of new installations.
It is important to recognize that the planning and preparation phase for submarine cable systems is often shorter than the subsequent installation and commissioning phases. Consequently, the number of completed systems in recent years has lagged behind pre-pandemic forecasts. However, the past two years have seen steady recovery, culminating in a notable resurgence in 2024, which recorded the highest number of new systems installed over the

last five years.
Since the previous industry report, progress has continued across multiple regions. The year 2024 stands out as a pivotal year with 24 new systems coming online, reversing the downward trend observed since 2020. This surge in activity underscores the industry’s resilience and its continued importance in expanding global connectivity.
Over the last five years, the submarine cable industry has seen considerable growth across several regions, with

EMEA leading in system additions, totaling 34 during this period. The Indian Ocean region, however, has lagged behind, with only three new systems deployed.
2024 marked a significant increase in installations, with 24 new systems, the highest in this timeframe, reversing the general downward trend observed in the preceding years. In contrast, 2023 saw the fewest additions, with just 10 new systems deployed.
Comparing to last year’s report, where EMEA had added 35 systems over five years and the Indian Ocean was projected to add five, this year’s figures show a slight adjustment, particularly in the Indian Ocean region where only three new systems have been confirmed. The upward shift in 2024 indicates renewed momentum in the industry, especially in key regions like AustralAsia and EMEA.


When shifting focus to the total kilometers of cable installed, a different narrative emerges compared to the number of new systems. The correlation between the number of systems added and the total kilometers of cable laid does not always align. For instance, in 2022, 18 new systems were installed, contributing to a total of 140,000 kilometers, while 2020 and 2021 saw similar system counts but much lower totals of 44,000 and 52,000 kilometers, respectively.
In 2023, the trend held steady with a modest 35,000 kilometers of cable installed, in line with its low system count. However, 2024 marks a significant rebound, with
nearly 200,000 kilometers added, driven primarily by major contributions from EMEA and the Transpacific regions.
EMEA continued to lead the industry with 63,000 kilometers of cable installed over the past five years, consistently recording the highest annual increases. Comparatively, the Transpacific region, while adding fewer systems, installed 24,000 kilometers, highlighting
KMS Added by Region, 2020-2024
Planned Systems by Region, 2025-2027
Click here to view the entire 2024-2025 Industry Report
Ownership Financing Analysis
[Reprinted Excerpts from SubTel Forum’s 2024/25 Submarine Industry Report]

HISTORIC FINANCING PERSPECTIVE
In the continually evolving world of submarine cable infrastructure, financing remains a critical factor in shaping the trajectory of global connectivity projects. Analyzing the financing trends from 2014 to 2024 provides key insights into the prevailing strategies used to fund these essential systems.
Self-Finance continues to dominate as the primary method for financing submarine cable projects. The first chart shows a steady and consistent rise in the number of self-financed systems, culminating in a sharp increase to 75 self-financed systems in 2024. This method accounted for nearly two-thirds (63.77%) of the total investment over the past decade, as illustrated by the second chart. Self-finance’s popularity can be attributed to the level of control it offers system owners, allowing them to dictate the direction of their projects without the need for external financial involvement.
Multilateral Development Bank (MDB) financing has remained relatively stable over the same period, with a slow but steady rise in the number of systems funded by MDBs, reaching 15 systems in 2024. While this method represents only 20.15% of total investment, it plays an important role in funding infrastructure projects in regions where financing from traditional sources may not be as accessible. MDBs offer a reliable avenue for financing critical infrastructure in
emerging markets, providing consistent support in areas where the need for connectivity is growing.
Debt/Equity Financing also shows a gradual increase in utilization, particularly from 2020 onward, reflecting a growing interest in collaborative financing approaches for submarine cable systems. By 2024, 33 systems have been funded through debt and equity arrangements, accounting for 16.08% of total investment. While this method remains the smallest of the three, it offers a notable alternative for operators seeking to mitigate financial risks through shared investment.
One notable trend observed is the growing reliance on self-finance as the preferred option for funding. This method not only leads in terms of raw numbers but continues to demonstrate robust growth. It provides system owners with greater flexibility and autonomy in decision-making while also reflecting confidence in the ability of these systems to generate returns without the need for external funding. The dominance of self-financing reflects the maturing of the submarine cable industry, where many operators and consortiums have the financial capability to self-fund largescale projects.
However, despite self-finance’s predominance, both Debt/Equity Finance and Multilateral Development Bank

financing continue to play critical roles in facilitating the expansion of submarine ca ble infrastructure. These financing options, while smaller in scale, provide essential support, particularly in cases where largescale projects require external capital or when projects are in less developed regions that benefit from MDB-backed financing.
The second chart further emphasizes the breakdown of total investment across these financing strategies. Self-financed systems represent the majority, with $10.72 billion invested from 2014 to 2024, followed by $3.39 billion from MDB financing, and $2.70 billion from Debt/Equity financ ing. These figures highlight the diverse approaches that continue to drive submarine cable deployment, ensuring that global connectivity continues to grow to meet the increasing demand for data transmission.

As submarine cable systems continue to proliferate, the choice of financing methods will remain a critical factor in determining the success and resilience of these networks. The dominance of self-finance, alongside steady contributions from MDBs and Debt/Equity Finance, illustrates the evolving strategies within the industry as it adapts to new challenges and opportunities in the years ahead. STF
Figure 42: Financing Type of Systems, 2014-2024
Figure 43: Investment Distribution of Systems, 2014-2024
REGIONAL DISTRIBUTION OF FINANCING
MULTILATERAL DEVELOPMENT BANKS
Multilateral Development Banks (MDBs) have continued to play a crucial role in financing submarine cable projects, particularly in regions where infrastructure development is essential for economic growth. Between 2014 and 2024, MDBs have invested $4.69 billion into submarine cable systems worldwide, distributed across various key regions to enhance global connectivity.
The EMEA (Europe, Middle East, and Africa) region remains the largest recipient of MDB investment, accounting for $1.78 billion (37.96%) of the total funds. This is a slight decrease from last year, where EMEA held a 42.5% share of the $2.1 billion total MDB investment. While the region’s share of the total has reduced slightly, EMEA continues to receive significant funding due to the broad demand for connectivity, particularly across its emerging markets and underserved areas.
One of the most notable shifts this year is the Transpacific region, which now accounts for $0.90 billion (19.17%) of MDB funding. In comparison, last year, the Transpacific region had not yet attracted MDB funding, highlighting a major change in investment priorities. This reflects the growing importance of the Asia-Pacific region in the global data network, driven by rapid economic growth and the increasing need for robust infrastructure to support it. MDBs are stepping in to support long-haul, transoceanic cables and large-scale projects that are crucial for connecting Asia-Pacific to other global regions.
The Americas region received $0.55 billion (11.69%) of MDB investment, a significant drop from last year’s 24% share of the $2.1 billion total MDB funding. This decrease suggests that MDBs are shifting their focus away from the Americas as the region’s infrastructure is more mature, and self-financing has become a more viable option for many projects. Nevertheless, MDB funding remains important in select projects where external support is necessary for economic development.
The Transatlantic region accounts for $0.49 billion (10.37%) of the total MDB investment, down from 23% last year. This decrease highlights the shifting focus of MDB investments towards regions with more urgent connectivity needs, although the Transatlantic region remains strategically important, particularly in linking North America to Europe and Africa.
AustralAsia received $0.67 billion (14.17%) of MDB investments, representing steady support for the region compared to last year’s 14% share. This continued investment suggests that while AustralAsia has a relatively mature connectivity landscape, MDBs still recognize opportunities for growth and regional development in certain areas.
Finally, the Indian Ocean region received $0.31 billion (6.64%) of MDB investment, which is notable given its geographic challenges and the region’s reliance on external funding for connectivity projects. This is a small but signifi-




Distribution of Debt/Equity Financed Investment, 2014-2024
cant increase compared to last year when the Indian Ocean region historically saw minimal MDB investment.
DEBT/EQUITY FINANCING
Debt and Equity financing remains an essential strategy for funding submarine cable systems, particularly for larger projects that require significant financial backing. From 2014 to 2024, the distribution of debt and equity-financed investment reflects the varied approaches taken across different regions, each with its own unique financing needs and challenges.
AustralAsia leads in this category, capturing 27.9% of the total Debt/Equity financed investment, amounting to $1.45 billion. This is a significant shift from last year’s data (2013-2023), where the Americas led with 26% Debt/Equity financing. The increased funding for AustralAsia highlights the growing demand for connectivity in the region, driven by the need for both regional and international connectivity, as well as collaborations between governments and local telecom companies.
Transpacific systems account for $0.89 billion (17.09%) of the total investment, reflecting the substantial costs associated with building large transoceanic cables in this region. Although the Transpacific region remains third in terms of system count, the scale and complexity of the systems, which often span vast distances, continue to attract significant Debt/Equity investment. This is consistent with last year’s findings, where the Transpacific region accounted for 16% of Debt/Equity-financed systems.
EMEA (Europe, Middle East, and Africa) follows closely with 17.3% ($0.90 billion) of the total investment. This represents a notable increase from last year, where EMEA accounted for 14% of Debt/Equity financing. The growth in EMEA reflects
continued investment in new systems to meet the region’s growing data demands, particularly in areas with burgeoning economies and the need for improved connectivity.
The Americas, despite leading in Debt/Equity-financed systems last year, now account for 12.29% ($0.64 billion) of the total investment. This marks a shift from last year’s 26%, reflecting the increasing prevalence of self-financing methods in the region. With several mature markets, the Americas are less reliant on Debt/Equity financing than in previous years, although it remains a critical component for larger, more complex systems.
Indian Ocean investments represent $0.62 billion (11.98%) of Debt/Equity-financed systems, a significant increase compared to previous years when this region attracted minimal interest. This growth highlights the emerging opportunities in the Indian Ocean, where improving connectivity has become a priority for both regional governments and international players.
Transatlantic systems represent $0.55 billion (10.57%) of the total Debt/Equity-financed investment. Although this is slightly lower than last year’s 13% share, the Transatlantic region continues to receive notable investments as demand for capacity across the Atlantic remains high. Given the region’s well-established infrastructure, much of the new investment focuses on upgrading existing systems or adding new, high-capacity cables to meet future needs.
Finally, Polar systems have received $0.15 billion (2.88%) in Debt/Equity investment, reflecting the limited but growing interest in developing connectivity in this challenging and remote region. This small percentage remains consistent with last year’s trends, where Polar regions attracted little investment due to logistical and commercial challenges.
These trends emphasize that while AustralAsia and Transpacific have seen increased Debt/Equity financing, more mature markets like the Americas and EMEA are beginning to rely less on this form of financing as self-financing and other funding methods take precedence. Despite these shifts, Debt/ Equity Financing continues to play a vital role in facilitating the expansion of submarine cable systems, particularly in regions that require large-scale, collaborative investments.
SELF-FINANCED
Self-Financing remains the dominant method for funding submarine cable systems, representing a significant portion of total investment over the past decade. The breakdown of Self-Financed investments by region from 2014 to 2024 illustrates how different regions prioritize funding their systems independently, reflecting the unique characteristics and needs of each market.


EMEA continues to lead in Self-Financed investment, capturing 24.08% of the total, which amounts to $3.57 billion. This maintains EMEA’s position as the largest recipient of Self-Financed funds, slightly increasing from last year’s figure of 23%. The region’s extensive geographical reach and established infrastructure support numerous point-topoint systems that are often developed without large consortiums, allowing for more autonomy in financing.
Indian Ocean investments have risen significantly, now making up 20.78% of Self-Financed funding, totaling $3.08 billion. This is a notable increase from the 17% share recorded between 2013 and 2023. The multi-regional systems, like SEA-ME-WE-type cables, involve multiple stakeholders but remain largely self-financed due to their nature as vital utility infrastructure, rather than purely revenue-generating assets.
AustralAsia represents 18.15% ($2.69 billion) of the total Self-Financed investment. While slightly lower than the 22% observed in the previous decade, this region continues to see significant government-backed systems that are less reliant on capacity sales for financial justification. AustralAsia remains a key player in the global self-financed infrastructure landscape.
The Americas account for 15.59% ($2.31 billion) of the total Self-Financed investment, in line with last year’s figure of 15%. Although systems in the Americas often serve as revenue-generating assets, a portion of these systems remain self-financed, particularly for smaller-scale or region-specific projects. The consistent share of self-financing in the Americas underscores its importance in the regional infrastructure development process.
Distribution of Self-Financed Investment, 2014-2024
Transpacific systems have secured 12.41% ($1.84 billion) of Self-Financed investments, reflecting their high costs and strategic importance. This marks a small increase from last year’s 14%, indicating the continued reliance on self-financing for large-scale, long-distance systems across the Pacific, where consortium financing may be less feasible or desirable.
Transatlantic systems represent 7.3% ($1.08 billion) of the total Self-Financed investment, largely driven by the Hyperscalers’ capacity to fund their systems without external financing. Although this percentage is consistent with the previous decade’s share of 7%, the Transatlantic region remains an essential part of global connectivity and continues to attract significant self-financed investment.
Finally, Polar systems account for the smallest share of Self-Financed investment at just 1.69%, amounting to $0.25 billion. This slight decrease from the 2% recorded in last year’s data reflects the ongoing developmental challenges and lower overall demand for connectivity in the Polar regions, where projects tend to be more complex and less commercially viable.
These trends underscore the sustained importance of Self-Financing as the leading method for developing submarine cable systems. While regions like EMEA and the Indian Ocean continue to lead in self-financed investments, AustralAsia and the Americas remain significant contributors to this category. The Transpacific and Transatlantic regions, though smaller in terms of self-financed investment, continue to attract notable attention for their critical role in global data transmission. STF
CURRENT FINANCING
Between 2014 and 2024, submarine cable system investment experienced significant fluctuation. While the industry saw a low point in 2015, with investments of just $0.5 billion, investment levels rebounded by 2016 and beyond, eventually reaching $2.4 billion in 2016 and $2.8 billion in 2018.
These investments align with increased cable deployment in those years. However, between 2019 and 2020, the industry witnessed another dip, with investment levels decreasing to $0.9 billion in 2020. Despite this, 2022 marked a resurgence, with $1.9 billion invested. 2024 is projected to hit a significant peak in system investment at $4.5 billion, representing a dramatic increase over the previous years, signifying an investment boom. This anticipated rise mirrors the global industry’s commitment to meet growing demand and bandwidth requirements, reinforcing the industry’s cyclical investment pattern that occurs approximately every eight to nine years.
The system deployment numbers follow a similar cyclical pattern to financial investments. From 2014 to 2024, an estimated total of 687,000 kilometers of submarine cables were deployed globally, averaging around 68,700 kilometers per
year. The peak years for system deployment correspond with the periods of high investment.
In 2016, a notable increase occurred with 62,000 kilometers of cable deployed. In 2018, deployment levels increased to 75,000 kilometers, following the industry’s cyclical investment rise. Though there was a dip in deployment in 2020, coinciding with the lower investment, deployment surged back to 81,000 kilometers in 2022, emphasizing the resilience of the submarine cable industry. A significant jump in system deployment is forecasted for 2024, with an estimated deployment of 169,000 kilometers, further aligning with the peak investment cycle.
Regionally, the investment landscape from 2020 to 2024 shows that EMEA leads in total investment, securing 32.1% or $5.37 billion of total investment. This is a notable increase from the previous reporting period, where EMEA accounted for 15%. The substantial growth in this region is driven by large-scale projects, including the near completion of key systems such as 2Africa and Equiano. Following EMEA, AustralAsia secures 22.12% or $3.70 billion of total investment. This region continues to play a crucial role in global connectivity, consistently attracting

Figure 47: System Investment, 2014-2024


significant investment due to its unique geographic challenges and demand for interconnectivity across vast distances.
The Transpacific region also attracted significant attention, accounting for 18.06% or $3.02 billion of investment. The Americas followed with 12.57% ($2.10 billion) of total investment. This represents a slight decrease in overall investment when compared to previous years. Despite this, connectivity needs between the Americas, East Asia, and Europe continue to drive investment. The Indian Ocean and Transatlantic regions captured 8.16% ($1.36 billion) and 5.49% ($0.92 billion) of total investment, respectively. Finally, the Polar region attracted the smallest amount of
investment at $0.25 billion (1.5%), continuing to be an area of minimal investment due to its relatively low demand.
This section highlights the ongoing financial commitment within the submarine cable industry to ensure that global communications infrastructure continues to grow, evolve, and meet the demands of an increasingly interconnected world. The cyclical nature of investment, correlating with system deployment, illustrates the resilience and adaptability of the industry, particularly in response to emerging technological needs and bandwidth requirements. With key regions such as EMEA and AustralAsia leading investment, it is evident that the global submarine cable industry will continue to play a
Figure 48: System Deployment by Year, 2014-2024
Figure 49: Regional Investment in Submarine Cable Systems, 2020-2024
LEGAL & REGULATORY MATTERS YEAR IN REVIEW
Perspectives of Andrés Fígoli
2024 has been a pivotal year for the launch of several international initiatives in the field of submarine cables. In this report, we look at some of them, explaining their significance for the industry and their impact on national plans.
ITU INVOLVEMENT
Last May, the World Summit on the Information Society (WSIS)+20 Forum High-Level Event 20241 was held in Geneva, Switzerland, co-organized by the International Telecommunication Union (ITU) and other UN agencies such as UNESCO, UNDP and UNCTAD. A special panel of government authorities and cable industry executives was arranged to address submarine cable issues, particularly the need to improve the resilience of the world’s submarine telecommunication networks.
Just a few months later, this has led to the call for nominations towards the creation of an international Advisory Body Group, composed of experts in the field of cable resilience, with an aim to promote dialogue and collaboration on potential ways and means to improve resilience of this critical infrastructure that powers global communications and the digital economy. The following months of this year will consolidate its structure and composition, and lead to a Submarine Cable Resilience Summit in early 2025. The ITU is partnering with ICPC in this effort.
In summary, these new initiatives launched by the ITU open a fresh phase in the telecommunications submarine cable industry, with the direct involvement of an UN body committed to foster multistakeholder dialogue and building consensus on telecommunications issues.
EUROPEAN COMMISSION RECOMMENDATION
In February 2024, the European Commission published a
1 WSIS Action Line C5: Beneath the Waves: Safeguarding Global Connectivity through Secure Submarine Networks. Available at: https://www.itu.int/net4/wsis/ forum/2024/Agenda/RPWeb?live=False&fs=X7674&cb=OR4SC
Recommendation2 setting out a series of actions at national and European Union (EU) level to improve the security and resilience of submarine cables through better coordination across the EU, both in terms of governance and funding.
EU Member States were invited to work with the European Commission to assess the impact of this Recommendation by December 2025 in order to identify appropriate ways forward. Indeed, it is a first step to accurately describe the regional risks to the cyber and physical security of submarine cable infrastructures, not only those related to their supply chains, which will lead to regular stress tests and further obligations for submarine cable owners.
And it is precisely in the context of such initiatives that policymakers should be aware of and not overlook two current realities. First, according to the 2024 ICPC statistics3 , the major risks to submarine cables continue to be negligent acts of fishing and anchoring, rather than intentional misconduct such as sabotage.
It is likely that the geopolitical confrontation in this multipolar world will continue in crescendo, but this does not mean that Brussels should forget to address the major risks by creating an effective deterrent effect with severe penalties for those who most frequently endanger the submarine cables in Europe. Some would argue that it is a matter of national security, when in fact it is logical thinking based on evidence and proven facts to effectively reduce the average of 500 cable failures per year in the world and defend their own digital sovereignty.
Second, the dominance of OTTs in the global capacity market is a fact, leaving less room for telecommunication companies to invest in new undersea infrastructure. Therefore, there should at least be no regulatory barriers
2 See “European Commission Recommendation on the security and resilience of submarine cable infrastructures”, 21 February 2024. Available at: https://digital-strategy.ec.europa.eu/en/library/recommendation-securityand-resilience-submarine-cable-infrastructures
3 Palmer-Felgate, A. “Global Cable Repair Data Analysis”, ICPC Annual Plenary, Singapore, 1 May 2024.
against the latter, otherwise they will gradually disappear with any coups de grâce, considering that such constraints are precisely not a good recipe for promoting a competitive market, or even a wise decision to ensure the diversification of routes.
By 2025, European policymakers will have to decide how to protect their already weakened telecom wholesale sector while attracting the major HYPERSCALER investments. In the midst of geopolitical tensions around the world, it is not an easy dilemma to solve when better conditions for buying and installing cables are evident for the Hyperscalers, using their leverage of dominant positions and economies of scale. How can an incumbent operator with 3 or 4 regional cable systems compete with an HYPERSCALER that has global reach and can regularly launch a new system that is 5 times more powerful than those of the 2000 boom era?
DEFENDING COMPETITION
In every quarter of 2024, there was a public announcement by an HYPERSCALER about new mega projects of subsea systems in different oceans of the planet, adding them to their already rich resources of an immense amount of capacity contracted from suppliers. This is a natural expansion plan in any industry, as we have seen in the past with the invasion of large supermarkets against small grocers, or the dominance of international airlines on major routes. However, the lessons learned in these sectors show that each country ultimately regulated the sector to effectively protect its own national industry from extinction.
ent suppliers and cable routes that make a connectivity network both robust and competitive. Currently, the submarine cable maintenance sector presents its market failures with an inefficient distribution of goods and services. This was demonstrated by the multiple cable failures in West Africa in March 2024, which clearly exposed delays or even unavailability of enough cable maintenance vessels to repair the affected submarine cables. If an HYPERSCALER system had been damaged, would it have been in the same queue waiting for the ambulance?
Government delays in granting maintenance permits in certain countries, an old fleet of cable maintenance vessels with an average age of +20 years, and other excuses to divert public attention may always be around the corner. However, some countries are already taking steps to avoid these market inefficiencies, such as India with its studies to have its own fleet, or the French government’s acquisition of Alcatel Submarine Networks.
In order to defend its own digital sovereignty, it is essential for each country to maintain a variety of different suppliers and cable routes that make a connectivity network both robust and competitive.
Now, a long-term regulatory strategy is urgently needed to protect this ecosystem, otherwise only a few wholesale operators will be left in the arena, forcing local governments to inevitably surrender their digital sovereignty to the agenda interests of foreign private companies.
Moreover, public scrutiny of the usual secret conditions under confidential agreements between some governments and OTTs to receive these investments is still a missing piece. This is crucial if countries are not to fall into false traps for short-term gains, such as sacrificing the sustainability commitments set out in the Paris Agreement in order to speed up environmental approvals for the installation of their usual data centers and/or new submarine cable systems.
Furthermore, in order to defend its own digital sovereignty, it is essential for each country to maintain a variety of differ-
Geopolitics also plays a role in these market constraints, as governments increasingly use their influence to isolate others or ban cable maintenance providers. Under normal circumstances this would be tolerated in a competitive world, but things are approaching a breaking point in the light of global domination, with these market distortions colliding with the universal right of every person to be connected. Indeed, this is a red line if we want no one to be left behind.
SECURITY: FROM HYSTERIA TO PRAGMATISM
Throughout 2023, many security initiatives were launched, and in 2024 these were implemented with further developments. For example, the NATO Maritime Centre for Security of Critical Undersea Infrastructure in Northwood, England, based at NATO’s Allied Maritime Command, with the clear purpose of monitoring the security of submarine energy pipelines and cables against hybrid threats and, as officials further explained, to deny any aggressor the cover of “plausible deniability”.
Less than 10% of cable failures appear in the media out of the 500 per year. It is not uncommon to find that such coverage is biased with propaganda mixed with vague information, turning a simple fishing trawler incident into a massive conspiracy, followed by geopolitical recriminations, inconclusive investigative reports, or even misleading information for an untrained eye in the submarine cable industry.
Accordingly, it would be useful for NATO to publish its own statistics on any sabotage or malicious acts against the submarine telecommunications cable networks, so that the general public is aware and can confirm that these threats are indeed real and not being pushed by researchers with an arms race agenda. It would also ensure that responses are proportional to the actual level of risk. In some cases, without concrete evidence, there is a risk of overreaction, which could lead to unnecessary escalation. This kind of transparency would serve to depoliticize the issue, showing that any responses are based on genuine security concerns rather than being driven by geopolitical competition.
In addition, the Joint Expeditionary Force (JEF), a multinational coalition of ten Northern European nations, has been established and has conducted military exercises to enhance the security of critical submarine infrastructure, while NATO is co-funding a project to find alternative ways to restore communications in the event of an attack on these submarine assets.
Other initiatives continue to forge their own regional paths, such as the Quad Partnership for Cable Connectivity and Resilience to improve security in the Indo-Pacific, and Australia’s new Cable Connectivity and Resilience Centre, launched in mid-2024. Hopefully, all of these and others would contribute globally to improving relations between several nations that have had their submarine cable installation processes severely disrupted, as happened in the South China Sea or the Aegean Sea.
NATIONAL REGULATORY CHANGES
rine cables. Why the difference in criteria between these two countries? It is well known that the maritime industry has its stronghold in the latter country, which has the largest ship registry in the world. Unfortunately, this has led to the erosion of its own telecom authority’s digital agenda to become an international connectivity hub.
In India, the ministerial authorities have yet to implement the “Recommendations on Licensing Framework and Regulatory Mechanism for Submarine Cable Landing in India” issued by the Telecommunication Regulatory Authority of India (TRIA) in the middle of last year. Such guidelines should update their national regulation, and it would be very useful for other countries in the region to follow the same path.
As of July 2024, the new conditions for issuing licenses for the installation of submarine telecommunication cables have come into force in Vietnam. The new Telecommunications Law5 enacted in 2023 also includes other specific regulations on data centers, cloud computing, and HYPERSCALER communications that will come into force on 1 January 2025, allowing the country to receive further investment with clear and updated rules.
Less than 10% of cable failures appear in the media out of the 500 per year. It is not uncommon to find that such coverage is biased with propaganda mixed with vague information, turning a simple fishing trawler incident into a massive conspiracy...
In May 2024 the Cook Islands enacted new legislation4 that imposes fines of up to USD 153,000 on those who negligently damage submarine cables. Other sanctions include mandatory reporting of such incidents with fines of up to USD 12,000, approaching the best international standards adopted by Australia, New Zealand and Uruguay in this area to create a deterrent effect against negligent actors.
On the other hand, earlier this year, Panama also approved a resolution by the Panama Maritime Authority that includes sanctions with a limit of only USD 10,000 for any participation in conduct that may cause damage to subma-
4 Manatua Cable Protection Act Bill 2024 No 5., May 2024. Available at: https:// parliamentci.wpenginepowered.com/wp-content/uploads/2024/06/ManatuaCable-Protection-Bill-2024.pdf
Other countries are actively engaging in a sincere dialogue with the cable industry, such as Qatar with its recent consultation process6, Malaysia with the flexibilization of its cabotage policy to allow foreign vessels to repair submarine cables in its domestic waters, and the Indonesian government, which held a workshop in July 2024 with the assistance of the International Cable Protection Committee. In addition, the UN Office on Drugs and Crime (UNODC) continues its efforts in the Indian Ocean region to improve the regulatory framework, organizing workshops and trying to fill the existing regulatory gaps.
Normally, most countries would follow a discrete consultation process, inviting key national stakeholders to work together to improve their regulations to facilitate the licensing process or remove unnecessary burdens. Most of them are convergent with their national maritime spatial initiatives, or at least designed not to collide with them.
5 Law on Telecommunications 2023 National Assembly, Vietnam, November 24, 2023. Available at: https://dazpro.com/law24-2023-vietnam-on-telecommunications
6 See “CRA Reference Offer for Access to Submarine Cable Landing Station (SCLS) International Connectivity (ROA for SCLS) Services” issued by the Communications Regulatory Authority (CRA), May 2024. Available at: https://www.cra.gov.qa/en/ document/cra-reference-offer-for-access-to-submarine
During these rounds of consultations, it is encouraging to see that many original proposals from different seabed users are on the table, such as the obligation for future cable owners to donate the survey data of submarine cables to coastal states. This could be used by them for further exploration of their continental shelf. In fact, at the last IOC/UNESCO conference for the Ocean Decade 2024, Seabed2030, held in Barcelona, Spain in April 2024, the issue of how to obtain this invaluable data was debated, unfortunately focusing only on existing subsea cables, where consensus in submarine cable consortiums to release such data is difficult to achieve.
JURISDICTIONAL CONCERNS
In July 2023, the new framework agreement for the Maritime Regulatory Authority (MARA) came into force to speed up the approval process for future submarine cables in Ireland. It also has a critical role in the maintenance of this subsea infrastructure, which must be consistent with the national maritime spatial agenda.
Similarly, at the end of last year in Portugal, the government issued a new regulation7 aimed at simplifying the licensing process for submarine cables and data centers, creating corridors to protect submarine assets, among other positive measures for the industry. The country has been very active in attracting new submarine cable systems, competing with its European neighbors as a gateway for African and transatlantic cables, with a pioneering domestic SMART cable project underway. However, some voices have raised concerns about the possibility of using this regulation to impose restrictions on the installation of future cables on its vast extended continental shelf.
to avoid falling under its jurisdiction for the remaining cable system segments that do not land on U.S. soil, changing cable suppliers, and even changing the name of the cable system.
Therefore, there is still a lack of international cooperation efforts that could give certainty and confidence to the states. This is a missing piece that could be filled by the ITU. Otherwise, a regulatory escalation seems to be the inevitable way in the following years, as all nations would be entitled and encouraged to adopt similar jurisdictional rights across borders.
BBNJ AND ISA
Other countries are actively engaging in a sincere dialogue with the cable industry, such as Qatar with its recent consultation process, Malaysia with the flexibilization of its cabotage policy to allow foreign vessels to repair submarine cables in its domestic waters, and the Indonesian government, which held a workshop in July 2024 with the assistance of the International Cable Protection Committee.
Meanwhile, the US Team Telecom continues to exercise its extraterritorial powers whenever a cable system lands in the US. Inspections are conducted at landing stations in other countries, challenging any national sovereignty rights. Accordingly, prospective cable owners are reluctant to use the same cable landing station for a segment connecting to the U.S. and are considering splitting their plans into two systems
7 Dispatch no 11808/2023, 22 November 2024, Portugal. Available at: https://diariodarepublica.pt/dr/detalhe/despacho/11808-2023-224603343
The High Seas Treaty or UN Convention on the Law of the Sea on the Conservation and Sustainable Use of Marine Biological Diversity of Areas beyond National Jurisdiction (BBNJ) continues its ratification process and is expected to reach the 60 required to enter into force. Meanwhile, the submarine cable industry is still debating the requirements for future installation of these assets in the new marine protected areas that will be demarcated and protected.
This treaty requires Environmental Impact Assessments (EIAs) for some proposed activities in areas beyond national jurisdiction, raising the question of whether any submarine cable would trigger this obligation and, subsequently, which states would be involved in such a process. It is likely that SMART Cables will have a safe place to grow and enhance its capabilities here if its regulatory challenges are finally resolved by the stakeholders.
Also, it is worth noting for such EIA processes that the International Tribunal for the Law of the Sea issued an opinion8 in May 2024 ruling that carbon dioxide is a marine pollutant. The case was brought by nine island nations seeking greater protection from climate change, and a similar ruling is expected later this year from both the International Court of Justice and the Inter-American Court of Human Rights.
On the other hand, the International Seabed Authority (ISA) continues to develop new regulations, especially with regard to exploitation activities, which hopefully will always
8 Advisory Opinion in Case No 31, ITLOS, 21 May 2024. Available at: https:// www.itlos.org/fileadmin/itlos/documents/cases/31/Advisory_Opinion/C31_Adv_ Op_21.05.2024_orig.pdf
require a coordination process with submarine cable owners in the affected areas. Other deep-sea mining plans in national jurisdictional waters are underway, so nearby telecom operators should remain vigilant to act proactively to protect their infrastructure.
CABLE LANDING AGREEMENTS
As the industry continues to evolve with open cables, spectrum sharing and other developments, legal frameworks are also evolving, such as cable landing agreements. Originally, these were ancillary agreements to a consortium agreement (Construction and Maintenance Agreement or C&MA) where a co-owner was appointed to be responsible for the landing stations, local permits, ownership of the local portion of the system, and to grant an Indefinite Right of Use (IRU) in favor of the remaining members of the consortium. Depending on the jurisdiction, these arrangements have been reduced in recent years to allow non-members of the cable consortium to offer space in their landing stations without even being co-owners or users of the system.
In addition, in some countries, such as Spain, the regional government of Catalonia grants general authorizations for the simultaneous installation of several future cables in a specific designated area, thereby reserving the area for these subsea infrastructures. This method can also reduce the time and cost associated with obtaining individual permits for each new installation.
LOOKING AHEAD
At the same time, many countries are updating regulatory frameworks to adapt to the new HYPERSCALER dominance of the sector, trying to be competitive and at the same time converge with maritime planning initiatives, a key issue to avoid conflicts with other seabed users in the long term.
The coming year will show whether these and other initiatives are effective in adding value to the submarine cable industry, which urgently needs pragmatic solutions to improve its resilience and market efficiency. STF
The new involvement of the ITU is a positive sign that new winds are blowing in other public forums in support of a sector that is vital for defending people’s connectivity rights, which may lead to further regulatory developments in the coming years.
The legal and regulatory changes in 2024 show that international initiatives to protect submarine cables are now on the agenda of several international organizations. The new involvement of the ITU is a positive sign that new winds are blowing in other public forums in support of a sector that is vital for defending people’s connectivity rights, which may lead to further regulatory developments in the coming years.



The 2024/2025
INDUSTRY REPORT READ IT NOW!
MAIN TOPICS FOR THIS Y EAR’S REPORT INCLUDE:
• Global Overview
• Capacity
• System Ownership
• Supplier Analysis
• System Maintenance

• Cableships
• Market Drivers and Influencers
• Special Markets
• Regional Analysis and Capacity Outlook
WHERE IN THE WORLD ARE THOSE PESKY CABLESHIPS?
BY SYEDA HUMERA
ANALYZING TRENDS AND DATA IN MODERN VESSEL OPERATIONS
INTRODUCTION
The maritime industry, an indispensable pillar of global trade, is witnessing a transformative phase, fueled by rapid technological innovations, heightened environmental regulations, and shifts in the geopolitical landscape affecting global shipping routes. As the lifeblood of international commerce, transporting over 80% of global trade volume, the maritime sector’s adaptability is crucial for the sustenance of worldwide economic stability and growth. This article meticulously examines the age, distribution, and operational characteristics of vessels, providing critical insights that illuminate the sector’s capacity to navigate the complexities of modern trade and environmental stewardship.
In delving into fleet age distribution, ship draught trends, global fleet registration by flag, and the multifaceted ownership landscape, this analysis uncovers the intricate dynamics shaping today’s maritime operations. These elements are pivotal for assessing the industry’s efficiency, regulatory compliance, and its overall environmental impact. As shipping companies strive to meet the International Maritime Organization’s stringent emissions targets, understanding these trends is paramount in strategizing future investments in cleaner, more efficient vessel technologies. Additionally, this exploration sheds light on the strategic decisions behind vessel registration and ownership, which are influenced by regulatory frameworks, economic incentives, and technological capabilities. The diversity in fleet ownership and flag registrations highlights the global nature of maritime operations and the varying strategic interests across different regions.
This comprehensive overview not only offers a snapshot of the current state of global maritime operations but also serves as a barometer for forecasting future trends. It equips industry stakeholders—ranging from policymakers to shipping corporations—with the knowledge needed to make informed decisions that align with evolving economic, environmental, and technological trends. Ultimately, this in-depth analysis aims to foster a more sustainable, efficient, and resilient maritime industry capable of meeting the demands of a rapidly changing global landscape. This article delves into the details of fleet age distribution, ship draught trends, global fleet registration by flag, and the diverse ownership landscape across the global fleet.
FLEET AGE DISTRIBUTION OVERVIEW
The fleet age distribution chart offers a nuanced snap-
shot of the age structure within a maritime fleet, revealing a strategic alignment of vessel ages that impact operational and maintenance strategies. Dominating the chart, the 20–30-year age category with 20 vessels indicates a significant portion of the fleet is mid-aged, suggesting these vessels are either at peak operational efficiency or nearing the phase where significant maintenance or overhaul is necessary. This peak is followed by a gradual decrease in numbers with increasing vessel age, with 13 ships in the 30–40-year range and 12 in the 40–50-year range. This trend highlights a deliberate strategy of phasing out older, potentially less efficient vessels in favor of newer, technologically advanced ships.

The chart also shows a modest number of newer vessels in the 0–10-year category, totaling 5 ships. This indicates ongoing investments in cutting-edge technology and newer ships that are equipped to meet stringent modern environmental and safety standards. These vessels are likely to set the standard for future fleet additions, emphasizing sustainability and efficiency.
Conversely, the presence of 4 vessels in the 50–60-year age category suggests that some older vessels continue to serve specific roles within the fleet, perhaps due to their specialized capabilities or because they have been exceptionally maintained.
This detailed age distribution is critical for fleet management as it directly influences decisions on maintenance schedules, financial allocations for new vessel acquisitions, and the strategic timing of vessel retirements. It also has implications for compliance with international maritime regulations and environmental standards.
Looking to the future, the trends observed in the fleet age distribution indicate a shift towards a younger, more technologically equipped fleet. As environmental regulations become stricter and operational efficiency becomes even more crucial, we can expect continued investment in newer vessels. This will likely lead to a gradual decrease in the average age of the fleet, as older vessels are retired in favor of new builds that can meet the demanding standards of modern maritime operations. This strategic renewal of the fleet is essential not only for maintaining competitive
advantage but also for ensuring the fleet’s operations align with global sustainability goals.
COMPARATIVE ANALYSIS OF SHIP DRAUGHTS
Ship draughts, indicating the depth of water a ship draws, especially when fully loaded, vary significantly. The distribution by draught intervals shows that most ships fall within the 6-9 meters range (40 ships), followed by 3-6 meters (17 ships), with fewer vessels in the 0-3 meters (3 ships) and 9-12 meters (3 ships) ranges. This data suggests operational flexibility, with most ships capable of navigating both deep and relatively shallow waters. The comparative analysis of ship draughts provides a clear illustration of the variation in the depth of water that ships draw, particularly when fully loaded, highlighting different operational capabilities within the fleet. The distribution across draught intervals reveals that most vessels predominantly fall within the 6-9 meters range, with a total of 40 ships, indicating this segment’s substantial capacity to operate in a variety of water depths. This category alone accounts for 63.49% of the total Vessel count observed across the fleet, emphasizing its dominance.
Following this, the 3-6 meters category comprises 17 ships, showcasing a significant number of vessels that are adept at navigating moderately shallow waters, which can be crucial for operations in coastal and inland waterways where deeper draughts may not be feasible. The lesser populated categories, both the 0-3 meters and 9-12 meters ranges, have
CABLESHIPS
3 ships each, indicating that very few ships in the fleet are designed for extremely shallow or particularly deep waters, respectively.
This draught distribution is crucial for understanding the operational flexibility of the fleet, suggesting that most ships are well-suited to a wide range of maritime environments, from deep oceanic routes to more restricted shallow waters. The extensive coverage of the 6-9 meters draught range implies a strategic focus on vessels that can handle a variety of shipping tasks without the limitation of draught restrictions commonly found in ports and harbors around the world.

Looking ahead, the dominance of the 6–9-meter category suggests that future vessel acquisitions might continue to focus on this draught range to maintain operational flexibility and ensure the fleet can service a broad array of routes and ports. However, as maritime infrastructure evolves and new routes become viable, the fleet may see a shift in draught needs, potentially leading to a diversification in the types of draughts that are prioritized in future ship designs and purchases. The data on ship draughts not only guide current operational strategies but also informs future fleet planning and development to align with anticipated changes in global shipping lanes and port facilities.
SHIP DRAUGHT TRENDS OVER VESSEL AGE

The average ship draught correlates with the vessel’s age, reflecting design evolutions and operational requirements. For instance, vessels aged 0-10 years show varying draughts, with newer models potentially designed for heavier loads and deeper waters, aligning with modern shipping needs. The correlation between ship draught and vessel age is a clear indicator of the evolution in ship design and the operational requirements that have shifted over time. Analyzing draught trends over vessel age offers insights into how new-
er models are adapting to the demands of modern maritime operations. Notably, the younger vessels in the fleet, those aged between 0-10 years, demonstrate a broader range of draughts, which suggests that these ships are built to accommodate heavier loads and navigate deeper waters—a reflection of their design to meet the increasing demands of global shipping and logistics.
In a striking comparison within the data, the highest average draught recorded is 9.14 meters for vessels specifically aged 20 years, which is 194.84% higher than the oldest age group of 47 years, where the average draught significantly drops to 3.10 meters. This vast difference underscores a

period of design transition focused on deeper draught capabilities which are likely aimed at enhancing cargo capacity and broadening operational horizons to include ports that can accommodate deeper-draft ships.
Further data shows that vessels aged 30 and 11 years also follow the trend of higher draughts, indicating periods where ship design strongly favored deeper waters. This pattern points to strategic design choices made during these periods to align with evolving maritime infrastructure and trade routes that demanded more substantial draught capabilities.
Across the entire spectrum of 37 different vessel ages analyzed, the average draught ranges from a minimum of 3.10 meters to a maximum of 9.14 meters. This range not only reflects the technological and operational advancements over the years but also highlights the strategic adjustments in shipbuilding that cater to different shipping needs and environmental considerations.
Looking forward, this trend analysis suggests that as ships continue to evolve, the focus might increasingly shift towards optimizing draught in newer vessels to enhance their operational flexibility and capacity. This would enable them to accommodate a wider range of cargo types and sizes, and access a broader array of ports, thus ensuring they can meet future global shipping challenges efficiently and effectively
GLOBAL FLEET DISTRIBUTION BY REGISTRATION FLAG
The global distribution of the fleet by registration flag significantly impacts the operational strategies and regulatory compliance of shipping companies, reflecting the strategic geopolitical and economic landscapes that define international maritime activities. France, holding a prominent position with 15.87% of the global fleet and the highest count of Vessels, underscores its established maritime infrastructure and a regulatory framework that is conducive to large-scale maritime operations. This leading position is likely to enable France to continue shaping global maritime policies, particularly in areas of environmental sustainability and technological innovation in shipping.
Indonesia and the Bahamas also play critical roles in the global distribution of the fleet due to their strategic geographical locations and favorable regulatory conditions. Indonesia’s role as a key player in Southeast Asian maritime routes positions it well to benefit from the projected increase in regional trade and maritime traffic. The Bahamas, with its favorable fiscal policies and regulatory framework, remains an attractive destination for flags of convenience, offering operational efficiencies and fiscal benefits that are crucial for competitive international shipping operations.
Looking towards the future, the landscape of global fleet registration is poised for significant shifts driven by evolv-
CABLESHIPS
ing international trade agreements, regional economic developments, and stringent global environmental regulations. Countries that can offer robust maritime infrastructure, advanced technological capabilities, and strong regulatory frameworks that support sustainable shipping practices are likely to attract more vessel registrations. This evolution will also be influenced by the maritime industry’s response to global challenges such as climate change, with an increasing emphasis on green shipping technologies and the adoption of alternative fuels.
Moreover, the increasing focus on digitalization and automation in maritime operations could see a reconfiguration of fleet management practices, with flags that support these advancements gaining a competitive edge. As shipping companies look to streamline operations and enhance safety and efficiency, flags that facilitate these technological integrations while maintaining high standards of regulatory compliance will be particularly desirable.
The strategic decisions made today by nations in shaping their maritime policies and infrastructure investments will, therefore, play a crucial role in determining their attractiveness as flag states in the future. This dynamic interplay of economic, environmental, and technological factors will dictate the global maritime fleet distribution, necessitating a proactive and informed approach from all stakeholders to navigate the complexities of the future shipping landscape effectively.


ANALYSIS OF VESSEL LENGTH AND VOLUME DISTRIBUTION IN FLEET MANAGEMENT
The scatter plot titled “Length and Volume Distribution Across the Fleet” offers a detailed examination of the relationship between the average effective length and the average estimated volume of vessels within a fleet. The data highlights two significant outliers: one vessel measures an impressive 176.20
meters in length, making it the longest in the fleet, while another vessel, labeled ‘167’, boasts the highest volume, at 32,728.82 cubic meters, indicating it has the largest cargo capacity.
These findings underscore the diversity within the fleet and suggest potential strategies for fleet management. For example, the fleet managers might consider optimizing vessel deployment based on specific cargo requirements or route efficiencies, which could lead to enhanced operational flexibility and cost-effectiveness. Moving forward, these insights could guide
strategic decisions in fleet expansion or renewal, focusing on increasing high-capacity vessels or enhancing the variety of vessel sizes to meet different logistic demands. This analysis thus not only provides a snapshot of the current fleet capabilities but also serves as a foundational tool for future planning and competitive positioning in the maritime industry.
OWNERSHIP LANDSCAPE OF OUR GLOBAL FLEET
The ownership landscape of the global fleet provides a fascinating glimpse into the market dynamics of maritime operations, where diversity in ownership not only reflects the competitiveness of the market but also its fragmentation. Among the prominent owners, ASN MARINE SASU, ORANGE MARINE, and E-MARINE PJSC stand out as key players, each holding significant portions of the fleet. These entities primarily manage specialized vessels such as cable layers and research vessels, which play crucial roles in various high-stakes industries, from scientific research to the deployment and maintenance of global telecommunications infrastructure.
This varied ownership is instrumental in catering to a wide array of operational needs. ASN MARINE SASU,
for instance, focuses on maintaining robust cable networks that are essential for global data transmission, underscoring the critical nature of these assets in supporting worldwide communication networks. ORANGE MARINE, on the other hand, contributes significantly to oceanographic research and environmental monitoring, leveraging their vessels to support scientific communities and governmental agencies in understanding marine environments. E-MARINE PJSC specializes in the installation and maintenance of submarine communication cables, a fundamental component of the global telecommunications backbone.
The presence of these diverse entities within the maritime sector enhances its capability to meet specific operational requirements across different industries, ensuring the resilience and efficiency of global maritime infrastructure. Moreover, this ownership diversity also fosters a competitive environment where each company strives to innovate and improve their operational capabilities. This not only benefits the specific sectors they serve but also enhances the overall efficiency and technological advancement of the maritime industry.
Looking to the future, the landscape of fleet ownership is likely to see further diversification as new technological

CABLESHIPS

and operational challenges arise. The increasing demand for renewable energy sources, for instance, might spur growth in the number of vessels dedicated to the construction and maintenance of offshore wind farms. Similarly, the ongoing push for digital globalization could lead to an expansion in the fleet of cable-laying vessels as new submarine cables are required to meet the growing demand for high-speed, reliable internet access across remote regions.
Thus, the ownership landscape of the global fleet is a dynamic component of the maritime industry, reflective of both current operational demands and future market trends. It underscores the critical importance of maintaining a diverse and technologically advanced fleet capable of meeting the complex and evolving needs of global industries. This dynamic ownership structure not only fuels competitive practices but also drives innovation, making it a cornerstone of strategic maritime operations worldwide.
SHIP ATTRIBUTES COMPARISON: OLD GUARD VS. NEW WAVE
The comparison between older and newer vessels within the global fleet underscores significant evolutionary changes in ship design and functionality, reflecting the industry’s response to modern logistical demands and environmental challenges. This shift is vividly illustrated in the comparison of ship attributes such as volume, length, beam, and draught between vessels like SEAWAY PHOENIX and NORDKABEL.
SEAWAY PHOENIX, representing newer vessels,
exhibits substantially greater volume and draught, which are indicative of its enhanced capability to handle larger cargoes and operate in deeper waters. The total sum of value for SEAWAY PHOENIX was 13,554.21, significantly higher than 678.71 for NORDKABEL, illustrating the substantial increase in overall capacity and functionality in newer vessel designs. This is further emphasized by the estimated volume in cubic meters for SEAWAY PHOENIX, which constituted 94.07% of the sum of value, a stark contrast to NORDKABEL’s much lower capacity.
Additionally, the average sum of value further highlights the disparity, with SEAWAY PHOENIX averaging 3,388.55 compared to just 169.68 for NORDKABEL. Such comparisons are particularly telling when examining specific attributes like estimated volume, where SEAWAY PHOENIX exceeded NORDKABEL by 12,764.57 cubic meters. This significant difference in volume underscores the capability of newer vessels to meet the increasing demands of global trade, where larger shipment volumes and the ability to access deeper ports are becoming increasingly crucial.
This analysis not only demonstrates the substantial enhancements in ship design over recent years but also serves as a crucial guide for stakeholders in the maritime sector. Understanding these trends helps in making informed decisions about fleet updates, investments in new technologies, and strategic planning to enhance operational efficiency and sustainability.
Looking ahead, as the maritime industry continues to
evolve under the pressure of increased global trade and the imperative for environmental sustainability, newer vessels like SEAWAY PHOENIX are expected to become standard. Stakeholders must consider these evolving trends in their strategic planning, ensuring that their fleets are capable of meeting future demands. This may involve phasing out older vessels that no longer meet efficiency or environmental standards, while simultaneously investing in newer, more capable ships that can perform more effectively in a competitive and environmentally conscious market. STF
Vessel AIS Zone
ANTONIO MEUCCI Aegean Sea
ASEAN EXPLORER South East Asia
ASEAN PROTECTOR South East Asia
ASEAN RESTORER South East Asia
BOLD EXPLORER Arabian Sea
BOLD MAVERICK South America East Coast
C/S RENE DESCARTES North Pacific Ocean
C/S VEGA East Asia
CABLE INNOVATOR North America West Coast
CABLE RETRIEVER China Coast
CABLE VIGILANCE Baltic Sea
CS ETISALAT Indian Coast
CS MARAM Arabian Sea
CS RECORDER Indian Coast
CS SOVEREIGN North East Atlantic Ocean
CS_FUHAI China Coast
DEPENDABLE East Asia
DNEX PACIFIC LINK South East Asia
DURABLE North America West Coast
ENDEAVOUR North Pacific Ocean
FAIRWIND LEGION China Coast
FJORDKABEL North East Atlantic Ocean
FU TAI China Coast
GIULIO VERNE West Mediterranean
HAI YU China Coast
ILE D OUESSANT West Africa
ILE D’AIX South East Asia
ILE DE BATZ Persian Gulf
ILE DE BREHAT South East Asia

SYEDA HUMERA, a graduate from JNTUH and Central Michigan University, holds a Bachelor’s degree in Electronics and Communication Science and a Master’s degree in Computer Science. She has practical experience as a Software Developer at ALM Software Solutions, India, where she honed her skills in MLflow, JavaScript, GCP, Docker, DevOps, and more. Her expertise includes Data Visualization, Scikit-Learn, Databases, Ansible, Data Analytics, AI, and Programming. Having completed her Master’s degree, Humera is now poised to apply her comprehensive skills and knowledge in the field of computer science.
Vessel AIS Zone
ILE DE RE Indonesia
ILE DE SEIN North Sea
IT INTREPID North East Atlantic Ocean
KAIYO MARU NO.3 East Asia
KAIYOMARU NO.1 East Asia
KDDI CABLE INFINITY East Asia
KDDI OCEAN LINK East Asia
LEON THEVENIN East Africa
LODBROG East Australia
NIWA Arabian Sea
NORMAND CLIPPER North Pacific Ocean
PETER FABER China Coast
PIERRE DE FERMAT North East Atlantic Ocean
POLARIS China Coast
PRIMA NUSANTARA X Indonesia
RAYMOND CROZE West Mediterranean
RELIANCE East Asia
RESOLUTE South Pacific Ocean
RESPONDER Indian Coast
SEGERO East Asia
SUBARU East Asia
SWIFT RESPONDER North America West Coast
SYMPHONY North Sea
TELEPAATTI Baltic Sea
TELIRI North East Atlantic Ocean
TENEO South East Asia
WAVE SENTINEL North West Atlantic Ocean
WOLDSTAD North America West Coast
Lisbon, Portugal | 2-5 June 2025
What’s on the horizon?
Future proofing our digital landscape

Organised by: Hosted by:

• Masterclasses on 6 key topics
• Keynotes on the impact of AI and the future of our industry
• Over 100 oral paper presentations
• 100 posters in networking poster session
• Congress on sustainability
• Networking events and Gala Soiree
• By the industry, for the industry

Tickets are selling fast. Get yours now www.SubOptic2025.com
11 QUESTIONS WITH RYAN WOPSCHALL
Talking Submarine Cable Industry With International Cable Protection Committee’s General Manager

1.
CAN YOU INTRODUCE ICPC PLENARY ‘25 AND SHARE THE CORE MISSION OF THE CONFERENCE?
When the ICPC Executive Committee was deciding on the central theme for this year’s Plenary, we were keenly aware that geopolitics and other regional and global issues were increasing around the world. While the ICPC traditionally stays agnostic to geopolitics, as we are a membership body comprised of 242 members across 79 countries, we can’t ignore the trends in the world that are influencing our industry and influencing the ICPC. As a result, we decided on the theme “The Big Squeeze: Geopolitics & Spatial Planning”. In their own rights, both geopolitics and spatial planning with other marine uses, are putting a squeeze on the planning of new undersea critical infrastructure as well as putting a squeeze on our industry, or at least influencing it. These are the concepts we are trying to capture in our Plenary in Montreal.

3.
2. IN WHAT WAYS DOES ICPC PLENARY ‘25 ENGAGE WITH AND INFLUENCE THE SUBMARINE CABLE MARKET?
The ICPC has always been a leading platform to exchange technical, regulatory, and environmental information, data, lessons learned, etc., among our industry members. In the last few years, in particular, we have seen a
continued growth in government engagement – governments wanting to learn from industry in order to protect their critical digital infrastructure. This has been evidenced by the participation in some of our own events including our Law of the Sea Day in 2024, the joint ITU/ICPC Advisory Body on Submarine Cable Resilience, as well as the continued growth of our Government Observer membership category. Government engagement, highlighted be our Plenary theme this year, is a major aspect of how the ICPC engages with and guides the submarine cable industry.
WHAT KEY INNOVATIONS IN SUBMARINE CABLE TECHNOLOGY OR APPLICATIONS WILL BE HIGHLIGHTED AT ICPC PLENARY ‘25?
While the ICPC doesn’t tackle specific technologies per se, we anticipate the Plenary to cover aspects of cable sensing technologies, cable monitoring technologies, as well as trends and developments to support cable resilience such as the planning of diverse routes and landing sites. These last two pertain to the physical layer of infrastructure which the ICPC focuses on from a protection standpoint.
4.
WHAT DO YOU CONSIDER THE PRIMARY FACTORS BEHIND ICPC PLENARY ‘25’S CONTINUED SUCCESS IN THE TELECOM INDUSTRY?
The ICPC has seen a tremendous growth in our membership and Plenary attendance over the last five years. Our event now has over 200 attendees from our member companies and observers. I believe some of this growth is due to the awareness that Covid gave on critical digital infrastructure. I believe we are seeing some diversification and growth in the supply chain of the industry from cable owners down to service providers. Governments are more engaged directly with industry which has also driven growth and attendance. The ICPC has always advocated that cables be treated by governments as critical infrastructure and I believe we are now witnessing this awareness and designation, which puts a lot of focus on how industry operates, organizes itself, and shares information. The ICPC is central to that.
5.
7.
HOW DOES ICPC PLENARY ‘25 FOSTER THE SHARING AND PROMOTION OF NEW DEVELOPMENTS IN SUBMARINE OPTICAL FIBER TECHNOLOGIES?

HOW IS ICPC PLENARY ‘25 DRIVING DIVERSITY AND INCLUSION WITHIN THE SUBMARINE CABLE AND TELECOM SECTORS?
As an organization, we have members from across 79 different countries, with all major regions represented by our member companies. This alone provides diversity among the organization. Beyond just our membership, we promote to our member companies the need for diversity and inclusion, in particular the need for younger generations of people to be brought up into this industry to succeed the tremendous knowledge and experience people have developed over their careers.
6.
WITH SUSTAINABILITY TAKING CENTER STAGE, HOW IS ICPC PLENARY ‘25 SUPPORTING THE SHIFT TOWARDS A CIRCULAR ECONOMY IN THE CABLE INDUSTRY?
The ICPC has supported sustainability efforts in various capacities. We have peer reviewed outputs from Suboptic on the topic of sustainability. We have taken our own look at vessel emissions and other topics related to sustainability to help quantify our understanding of the industry’s impact. Additionally, we have several cable recovery and recycling companies as members of the ICPC and support their efforts in covering the entire lifecycle of a cable.
In general, the ICPC is more focused on the physical layer of submarine cables and not necessarily with optical technology. A relevant recent example of this distinction is that the ICPC formed a Cable Sensing Working Group. The focus of this group is to understand and track the developments of all sensing technologies, to understand their benefits, their drawbacks and limitations, etc. But the focus of this group is to evaluate if the various sensing modalities have an application for cable protection, environmental monitoring, etc. This is also relevant for the ICPC to be conversant in because cable sensing is a very prominent topic with governments right now. However, we focus more on the application of the technology than the technology itself. Another example is tracking the trends in optical transmission technology, fiber count in cables, etc., to the degree that these technology trends drive the need for more cables, more diversified mesh networks, the need for more diverse routing and cable landings, all looked at through the lens of cable resilience, which is looked at as a physical cable protection topic.
8.
AS ICPC PLENARY ‘25 APPROACHES, WHAT EXCITING NEW FEATURES OR CHANGES CAN ATTENDEES EXPECT THIS YEAR?
The ICPC annual Plenary is a pretty tried and true event that has a lot of elements that resonate with our members. Aside from growing attendance, we are seeing growth in our exhibition hall, we always have very interesting and relevant guest and keynote speakers, we are seeing growing government attendance, and we have scheduled events throughout the week to help bring people together to network among our membership. Though the Americas are on our regional rotation when planning a Plenary location, it is rare that we get to Canada despite even the first trans-Atlantic cable being installed from Ireland to Canada. We also have several Canadian members, and in general, I think most people are excited to explore Montreal.
9.
HOW IS ICPC PLENARY ‘25 ADAPTING TO THE RAPID DIGITAL TRANSFORMATION WITHIN THE INFORMATION AND COMMUNICATIONS TECHNOLOGY (ICT) SECTOR, ESPECIALLY WITH THE EVOLVING DEMANDS ON SUBMARINE INFRASTRUCTURE?

I think the biggest transformation from an ICPC perspective is the interest and engagement of governments. In today’s geopolitical climate, cables have taken front stage and triggered a variety of concerns that have national or regional security implications. While the ICPC actively engages with media and others to calm what typically can come across as hysteria, we view the interactions with governments as positive, particularly as governments understand further how to protect and maintain cables. Where this is further extrapolated upon is the fact that the ICT sector is rapidly changing with increased development of data centers, increased capacity demands, increased capacity on cables, and the anticipated impacts of AI or other computing methods that trickle down to the need for more fiber.
10. WHAT ARE THE MOST SIGNIFICANT CHALLENGES CURRENTLY FACING ICPC PLENARY ‘25, AND HOW IS THE CONFERENCE ADDRESSING THEM?
Rather than challenges, I like to think of them as opportunities, but these would include: (1) increased importance for industry collaboration with regional cable protection committees and other industry bodies, (2) increased importance to be a voice for the industry particularly related to cable protection issues and issues facing governments, (3) continued importance to be a thought leader on topics of cable protection and marine
maintenance (this has always existed as an important need of the industry and role of ICPC, but the importance of an outward facing voice is ever increasing as people and entities are more aware of cables), (4) continued importance for peer reviewed literature that supports our industry and helps mitigate the impacts of jurisdictional creep whether from a policy or environmental perspective.
11.
LOOKING AHEAD, WHAT’S NEXT FOR INTERNATIONAL CABLE PROTECTION COMMITTEE AS IT CONTINUES TO SHAPE THE FUTURE OF GLOBAL COMMUNICATIONS?
At the moment, we just launched the joint ITU/ICPC Advisory Body on Cable Resilience and held the first in person meeting hosted in Abuja, Nigeria the week of February 24. The feedback I received is that it was a very successful, engaging and well attended event and met the initial intended purpose of bringing governments from around the world together with industry to discuss how the industry operates, the interests and concerns of governments and how we can work together to achieve cable protection. STF
RYAN WOPSCHALL is the General Manager of the International Cable Protection Committee (ICPC) and is the Founder and Principal of Wopschall Consulting, LLC. He has spent the last 18 years working in the submarine cable industry, having worked on over 30 projects at various stages in their planning and implementation lifecycle, and has conducted business in over 20 countries. He has held the position as GM of the ICPC since 2020.

AGENDA
(subject to modification and EC approval)
Pre-Plenary Executive Committee Meeting: Monday, 14th April 2024 (Closed Meeting) 9:00 am – 5:30/6:00 pm
Evening Welcome Cocktail Reception: Monday, 14th April 2025 (Members Only)
Approximately 6:00 pm - 9:00 pm
• For All ICPC Members and their Accompanying Person(s)
• Dress code: ‘Business/Smart Casual’
• Venue & Logistics: TBA
• Guests will receive their delegate badge & lanyard
Day One: Tuesday, 15th April 2025
Approximately 9:00 am to 5:30 pm Venue: DoubleTree by Hilton
Opening of Meeting for ICPC Members Only
• Project Updates
• Working Group *Headline Updates*
• Secretariat Updates
• Legal & Marine Environment Updates
• Onsite Lunch & External Speaker Registration
Open Session Commences & Welcome to External Speakers
• Presentations and/or Panels
• Exhibitor Spotlights
• Guest Speaker Presentation
Day Two: Wednesday, 16th April 2025
Approximately 9:00 am to 5:30 pm Venue: DoubleTree by Hilton
• Welcome Remarks
• Guest Speaker Presentation
• Full day of presentations and/or panels
Evening Gathering of ICPC Members, Invited Speakers, Observers and Guests
Approximately 7:00 pm - 10:00 pm
• For All ICPC Members and their Accompanying Person(s)
• Dress code: ‘Business/Smart Casual’
• Venue & Logistics: TBA
• Guests to bring delegate badge & lanyard for entry
Day Three: Thursday, 17th April 2025
Approximately 9:00 am to 4:30/5:00 pm Venue: DoubleTree by Hilton
• Welcome Remarks
• Full day of presentations and/or panels
• Liaison with other organisations and seabed users.
• Group Photo
• Close of Open Session
ICPC Members Only Wrap-Up
• Request for Members’ Feedback on the 2025 Plenary (to be completed online)
• Arrangements for the 2026 Plenary
• EC Election and Appointments Announcement
• Reflections on the Plenary from ICPC Advisers
• Chair’s Closing Remarks
• Meeting Closure
HOW CAN WE SECURE OR PROTECT A SUBMARINE CABLE
Is It Down To Network and Component Monitoring Only?
BY DEREK CASSIDY
Submarine Cable Security and protection, is it possible? Information in the form of data, communication, and video streaming is the lifeblood of our society, this information uses submarine cable networks to transverse the globe and connect the world’s population to the internet backbone. These submarine cables carry well above 99% of the world’s information usage and cross nearly all the world’s oceans and seas. However, submarine cables are also used for other purposes such as HDVC [high voltage direct current] power interconnectors and carry electrical power between nations, helping them stay connected to the electrical grid and sharing green energy. There are other cables such as research and military owned and deployed cables that follow the same paths as the commercial cables. However, these military cables are not charted and the research cables, if populating territorial waters may not be charted either.
In recent years there seems to be a heightened interest, by third parties and bad state actors, in submarine cables. An example of this interest is the recent appearance of vessels apparently acting in very unconventional ways which have appeared in the Baltic seas and in Atlantic Ocean of the Irish Coast. The first appearance of these “interested parties” was the appearance of approximately 60 Russian vessels in 2022 where Russian Naval Vessels decided to partake in military drill within Irish EEZ waters. It came down to the
fishing industry and the Irish State to intervene and eventually called of the military exercises and leave the Irish EEZ towards international waters. However, there was a confident assumption that they were mapping the commercial cables for future sabotage or aggression, however, it is the industries belief that it is the military cables that they were mapping as these are not charted and their routes are not freely available on the internet like the commercial cables are. But the interest in submarine cables increases all the time and in recent months it has been reported that power and data carrying submarine cables have been damaged in the Baltic Sea area caused by these third parties, who could be bad state actors. However, these incidents could also be accidents, if at all. But it does bring to the fore the nervousness of the western world with regards to the security and protection of submarine cables and the lines of international information connectivity.
To try and put some measure on this issue, there is a new push by the industry, military powers such as NATO and State sponsored bodies to come up with a plan to protect and secure all submarine cables, a perfect example of this is the launch of the AI powered programme to monitor, identify and record any incidents that my affect a submarine cable and its operations. This new programme is being organised and operated by the JEF [Joint Expeditionary Force],
a UK led joint military force which includes the Baltic and Scandinavian states in partnership with NATO. This is in direct response to the damage to the Estlink 2 HDVC cables that were put out of service on December 25th, 2024, due to some accidental or pre-meditated damage caused by a third party or a state actor intent on causing disruption to the power grid and international connectivity. The JEF have applied this AI technology to the Baltic Sea as a first precaution. But as this programme is only using AI or some other intelligence or mapping software to identify risks, it is not actually securing the cables, it is trying to identify and map the risks and also monitor the shipping channels to identify possible risk factors, and vessels that may be of interest. At least some interest is being paid to the issue and the fear of submarine cable damage by third parties, is being taken seriously. In October 2024, an ICPC sponsored conference on submarine cable security was held in Valentia Cable Station, Ireland. This conference focused on areas, ideas and ways to secure a submarine cable, but no definite action point was reached. It was a very fruitful conference with great points of interest raised from great minds. But this area needs a lot of more research, and it needs a much more focused view. A lot more input from the industry and more attention and spotlight needs to be put on the monitoring techniques and their efficiencies that exist today which are employed to indicate aggressive acts and injury to cable assets. By understanding these efficiencies will allow the industry to try and incorporate them into a better secure and cable protective strategy that can be employed by the various state and industry actors to better secure our submarine cable systems. Submarine Cable Security and protection is definitely a new area within the submarine cable world that needs further investigation and research to come up with a proven method that can securely protect a submarine cable from acts of aggression.
However, in my view and the opinion of the cable industry is that it is not technically feasible to secure or protect submarine cables. The only feasible way is to monitor them for component failure or damage, whether it be aggressive or accidental. For well over a hundred years, submarine cable operators have been deploying monitoring techniques that indicate if there is any aggression or outside acts being affected on a submarine cable
Is there a way to protect cables today, yes, by the deployment of guard ships and specifically stationed vessels employing remote operational vehicles [ROV] to continually monitor specific, but not all submarine cables. But again, the question is, is this feasible. The answer is, in my opinion, no as there are not enough vessels or ROVs to carry out the
task, funding and state sponsorship would also be lacking as would the availability of the military, or fishing/merchant [which could be hired] fleet assets to carry out the task.
The specific monitoring tasks that I refer to above which are used for threat detection to indicate aggressive acts of cable failure are as follows, amplifier monitoring, PTFE monitoring, resistive impedance monitoring, optical monitoring and cable protection guard ship [only used on short sections of working cable when the diverse cable is under repair and usually carried out by members of the fishing industry]
DIFFERENT SUBMARINE CABLE ACTIVITY, TRAFFIC AND COMPONENT MONITORING TECHNIQUES AS A SECURITY OR PROTECTION MEASURE
IMPEDANCE AND ELECTRICAL MONITORING AND TESTING MEASURES
James Graves, first superintendent of Valentia Island Cable Station, carried research on the 1865 and 1866 trans-Atlantic Telegraph cables, as they were being laid. He carried out resistive tests, testing the cables and identifying the distance and rough location of each cable after they broke and were recovered, especially the 1865 cable which lay on the seafloor for over a year. During this research and applying the theories of Robert Mallett, he identified undersea earthquakes, and seismic movements buy using impedance to calculate the distance to each event. It must be noted that the ideas, technology and mathematical formulas are the same ones used today to identify a cable break or damage when using electrical power and impedance to identify the drop in impedance and increased current on the cable. Today we use continuity testing referencing the electrical current in milli amps to monitor the cable. When there is damage to the cable and the current increases then we can calculate the distance to the fault through impedance testing. This sort of monitoring is used to calculate the electrical power across the live and earth along a submarine cable. We use a Tinsley continuity system, see figure 1, to apply an electrical current to the cable. On some systems this is usually set at 158mA. When there is a short on the cable, the live conductor has made contact with earth or the outer armouring wires due to a cable shunt, then the impedance drops and so the electrical current will increase. By applying the same formulas used on the original telegraph cable fault finding and normal impedance testing the distance to the fault can be identified. This is one way to identify if anyone or anything has damaged the cable as in figure 2, here we see a trawl door damaging the cable by under tacking the cable and pulling it until it breaks. The trawl door can also roll the cable, damaging the
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optical fibre package. Fishing incidents can also cause shunt faults when the fishing gear causes enough damage that the electrical carrying conductor is exposed to seawater or the outer armouring, which also acts as an earth. However, anchors, beam trawlers and scallop fishing can also damage cables. Other damage can also occur due to underwater landslides, earthquakes, seismic disturbances where seafloor is disturbed etc. To find a submarine cable on the sea floor, we also use the Tinsley to couple up with a tone generator as this type of detection is also used to identify the cable as there are usually more cables not too far away, as an ROV cannot fully identify the submarine cable, as obviously there are no markings and there could be other cables nearby which adds to the confusion about cable identity. This tone generator using the Tinsley and can inject an electrical current with the following values 600ma and 600v at 25Hz. This helps to create a tone which can be detected by an ROV with a detector attached. The ROV usually searches for the cable by trying to locate the electrical tone and then as soon as it has the tone it follows the cable along its path by keeping a tag on the tone until the fault is identified. It must be noted that any repair or cable identification is always done with the original submarine cable route position list [RPL]. This is a detail listing of the co-ordinates, cable crossings, sea-bed obstructions, sea depth, cable burial depth and as laid position on the seafloor. This list helps to quickly aid in the identification of the submarine cable, however, the use of a tone generator to compliment the cable finding exercise is usually the best procedure.
So as can be seen impedance testing is a tried and tested way of calculating distance to a fault by using Ohm’s and Kirchoff’s Voltage Law.
Ohms Law = V = IR [1]



Kirchoff’s Voltage Law = [2]
There are many incidents and faults that can occur on a submarine cable, SLTE, PTFE, Amplifier, shunt-electrical earth, or optical package faults and not all can be identified as intentional damage. For instance, a cable that is rolled by a trawl door my not show actual damage, but the optical package could be severed within the cable. This is where the tone generator along with optical testing, working together can help find the damage. Submarine cables, unlike traditional terrestrial cable does not have 15m coils where there are joints and so the location to fault is easier to locate due to its closeness of real distance and cable distance being relatively close.
RL≈CL [3]
These systems will identify damage and help a cable ship identify the submarine cable on the seabed. Shunt faults are the most common threats that are detected using this system [electrical continuity test] as OTDR or signal loss detection are not picked up with this type of fault and impendence testing is the best threat detection as is amplifier fault localisation [fault between two amplifies as the electrical power is not continued after a shunt fault or amplifier failure].
OPTICAL TESTING AND MONITORING MEASURES
The optical package or optical fibres are the most important part of the submarine as they are the component that carries the information. There is a specific monitoring
Figure 2: An example of a fishing accident with cable being caught by trawl door
Figure 1: Tinsley electrical cable termination unit
mechanism used to detect any anomalies with the optical package, and it can either be coherent [COTDR] or non-coherent [OTDR] testing to capture a real time optical loss test cross section of cable specified in the testing requirements. The COTDR can optically test optical fibres through an optical amplifier but an OTDR can only test fibres, so it is best to decide which test mechanism you deploy, if both and also depends on whether you cable is repeated [with amplification along submarine cable path] or unrepeated [no amplification along submarine cable path]. The testing technique selected is used to monitor the optical fire component of the submarine cable. This optical test is compared to an original optical test that was captured, when the optical fibres were first commissioned, and used as a reference point. The optical testing or OTDR analysis is carried out every 15 minutes and comparisons are done immediately and anything with a loss coefficient of .2dBm is immediately recorded and analysed and reported. This test analysis can be done with the aid of artificial intelligence [AI]. The great thing about these systems is that being an optical test the area of aggressive action is immediately identified and acted upon. However, it must be noted that it is an identifier of threat detection and not a deterrent. This can be reported and identified as reduction in dB [optical loss], a macro bend or optical loss-fibre break. In figure 1 below we can see an example of a long reach OTDR Test result showing the Fresnel reflection at the far end which indicates the end of the fibre. However,



Figure
Figure 4: An example of an optical test and results from an OTDR Viavi ONMSi system with better detail and OTDR
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as the distance is 245Km the OTDR cannot reach 175Km until it reaches a point where noise is introduced and soon the signal to noise ratio increases so much that it has reached a point where good signal cannot be determined [errors] see equation 4. However, as the optical pulse is large enough it still has enough power to record the end reflection. [4]
This type of monitoring or threat detection is common among submarine cable operators and land-based telecom network operators and these systems are provided by Viavi, EXFO and Anritsu. However, the Viavi system is the most common deployed across Europe with Butler Technologies being the main provider and support specialists acting on behalf of Viavi etc.
Another method of optical monitoring is distributed acoustic sensing [DAS]. This is a type of optical testing, just like testing with an Optical Time Domain Reflectometer [OTDR] but this system uses optoelectronic devices that measures the Rayleigh Scattering, just like an OTDR, except a type of Coherent Rayleigh Optical Time Domain Reflectometry [COTDR] is used. It uses single pulses of coherent light that are sent down an optical fibre and then a second one is sent. The COTDR and the optoelectronic devise measures the difference between the two and subsequent pulses of light and determines if there are issues that
could cause strain on the optical fibre. Just like an OTDR the distance to the resultant issue is calculated through the algebraic equation were
A + B = C, where A = Pulse Width, B = Time and C = Distance.
Although the refractive index of the fibre under test must be known to get a true calculation of light speed within the fibre, as its not C [Speed of light] but usually represented as following:
C/[n2/n1] ≈ 82% or 246,000Km/s [5]
An OTDR can give you results somewhere similar to a COTDR, when used in the same format, however when used within a DAS system, the results represented are different as can be seen in figure 5. Most optical system will employ optical testing measures for monitoring and testing but not both as they are very much alike but with slight differences. I won’t go into the functions of an OTDR/COTDR with regards to time, pulse width and distance etc. at this time.
PMD MEASUREMENT AS A MONITORING TOOL.
Another tool we have in the monitoring armament is using phase shifting techniques, which polarisation mode dispersion [PMD] is the best-known phase dispersion anomaly that we know. There are many others, but PMD is the one commonly used. We can use PMD to identify issues and using AI and calculation methods identify the location of the issue by combining the PMD tester/analyser with an OTDR that can complement the testing and give clearer results. Other non-linear optical dispersion and effects can be used alongside PMD testing, if required, but time and monetary budget may curtail employing these techniques.

MONITORING A SUBMARINE CABLE COMPONENTS VIA NMC/NOC
Now we have seen that there are optical, impedance monitoring systems that can continually monitor the different elements of the submarine cable. However, the normal monitoring of a submarine cable done as part of normal

operations and carried out by the Network Operations Centre or Network Management Centre will continually monitor the cable for normal operation. It will rely on the information/ monitoring feedback received from power feed terminal equipment [PTFE], submarine line terminal equipment [SLTE] etc to make sure that the normal operations of the submarine cable are in keeping with the parameters set by the operator, see figures 6 and 7 for representations of the submarine cable, amplifiers, SLTE and PTFE. Each one being a component that can fail or be affected by a cable incident.
The PTFE system will encompass the power feeding equipment in the cable station and the optical amplifier power feeding scheme. Any issues with the power will need to be identified and the issue isolated. This could be an amplifier issue, power feeding equipment within the cable station, shunt fault or any other electrical continuity issue. The errors or fault on the PTFE system can also
be interrogated by the impedance monitoring equipment, if one is employed. The optical link will be monitored by the operation of the SLTE and any decline in optical power [dBm] will need to be identified as this could be related to the PTFE/Amplifier failure or the failure of the SLTE associated cards that make up the SLTE. Investigations into the issue will need to be carried out as soon as possible to identify the cause of the failure, if it’s related to a system fault of some sort of aggressive or accidental cable damage. However, this fault or increase in errors could also be related to the terminal equipment within the cable stations etc. There are many things that can cause errors and each one need investigation.
USING SMART, ENVIRONMENTAL OR RESEARCH SUBMARINE CABLES AS A MONITORING TOOL.
Science monitoring and reliable telecommunication sub-

Figure 6: A submarine cable with amplifiers, SLTE and PTFE identified: www.viavi.com.
Figure 7: A submarine cable with amplifiers, SLTE, PTFE and branching units identified: courtesy www.viavi.com
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marine cables or [SMART] Cables are now being deployed across submarine cable systems. They are also complimented by research cables, each one being a separate system or a combined component within the SMART cable. The SMART cable systems use the submarine cable optical amplifier to house electronics employed as sensors within the amplifiers to measure strain, temperature and movements etc. These systems are being deployed as seismic and tsunami warning systems and are already in use. They can also be used to monitor submarine cables with respect to security and protection as detections are technically threat detections and can be treated the same way, however with a different specific outturn etc. Research cable systems are specifically designed for research purposes and will combine multiple monitoring systems to record environmental aspects of the surrounding area. They are also used to record and transmit data collected from systems such as wind, wave, seabed and marine buoys etc. With these systems, the recoded data analysis will require the skill and experience needed to understand the difference between normal data recorded results and
threat detection results received back at the cable station or NMC/NOC. An example of a SMART optical amplifier can be seen in figure 8, and a research system such as Smart Bay in Galway Ireland, figure9.
TESTING AND CLEANING OPTICAL COMPONENTS-TO PREVENT SYSTEM FAILURE

However, errors on SLTE equipment can also be due to optical fibres and patchleads used for connectivity. These are responsible for most issues, usually up to 80% of system errors. Therefore, each optical fibre and patchlead needs inspection and cleaning and needs to follow the below flow diagram as can be seen in figure 10. This is the process that needs to be followed to inspect, clean and then test each optical component such as optical fibre patchleads and connectors. As we can see the examples of the optical fibre end faces have areas that need to be cleaned. In figure 11 we see the end face zones of multi-mode and single-mode fibres. The central zone is the optical core which needs to be 100% clean, as the zones move out the percentage of cleanliness needs to be the same but if there are any issues

Figure 9: A representation of SMART BAY deployment in Galway Bay: courtesy www.smartbay.ie
Figure 8: Submarine Cable amplifier incorporating smart electronics: courtesy www.infinera.com.
within any of the zone’s C or D then the connector could still work, but any issue in zone A or B will result in a failure of the optical patchlead, this needs to be cleaned or replaced. In figure 12 below there is an example of an optical fibre patchlead end face with dirt or physical issues with the end face and so this fails as the issues are in zone B. However, we also see an example of the same optical fibre patchlead end face that has been cleaned and tested and past for use. All optical fibres and connectors will need to be tested and cleaned as per specifications. Everything is calibrated before testing using the equation 6 below. Then testing, inspection and cleaning is then carried out. This is very important as the failure of a submarine cable could be down to a single optical fibre patchlead, optical component or a connector. As these are critically important parts of the submarine cable operation and system the need to make sure they work as per specification is very important. In industry dirt on connectors and optical patchlead end-faces account for well over 80% of failures within optical systems etc, as already stated. So, making sure that all patchleads and connectors are dirt free should be part of the network commissioning and network turnup process. The failure of one of these components could be seen as errors on the SLTE and may not be immediately detectable and so a system failure/increase in errors occur. This could be seen as submarine cable damage by accidental or aggressive act. However, investigation always needs to be carried out, better to have a patchlead failure than a submarine cable fault on the seabed.

CONCLUSION-CAN WE REALLY SECURE AND PROTECT SUBMARINE CABLES?
We are seeing at a lot of talk, information and possible evidence of submarine cable damage caused by anchors etc. This is especially evident in the Baltic Sea area. Further examples of this is the recent damage to the Latvian to Swedish Island of Gotland submarine cable, 26th January 2025. There is an ongoing investigation with interest already into a vessel that crossed the cable, it is being treated as sab-
otage. There is also a lot of discussion about how to secure all submarine cables both military and commercial along with research cables. Even going as far as having an international submarine cable conference that was held on Valentia Island in October in 2024. This conference is being held in Valentia again in October 2025. However, there is no actual way to secure or protect a submarine cable from damage. All we can do is to monitor their operation and quickly identify any issues that may arise etc. During Submarine Networks EMEA 2025 there will be a discussion on cable security.
So how does the industry secure and protect a submarine cable. Technically there is no real way other than having an ROV continually on station above the cable, which is not feasible. Deploying NATO or the many national maritime or state agencies is also not feasible. I cannot understand why there is a huge push in getting these agencies involved as they cannot really offer anything other than a show of force. Having NATO or the Maritime Agencies or national state agencies taking an active part in submarine cable security in effect is a good thing however, there is concern about the other submarine cables that are not protected or do not have an active patrol offering security.
So, in effect the best use of NATO or other joint force
Figure 10: Flow diagram of the optical fibre patchlead clean-inspect-clean process.
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like the UK led JEF military partnership, is to monitor the shipping channels and to identify any suspect vessels that may cause an issue, or when a bad-state actor deploys its vessels to an area where there are submarine cables and there is concern about their presence. A perfect example has been seen in the Atlantic in the Irish EEZ where the Irish State had to act and force the movement the offending vessels out of the EEZ, which attributed to the cancellation of the specific naval exercises and the vessels returned to their home port. These vessels were stationed overactive commercial and military submarine cables and were acting is a very suspicious manner. And as already mentioned the incidence in the Baltic and now Tiawan is showing some serious concern about how submarine cables can be properly secured and protected. By combining the efforts of the various submarine bodies such as ACMA. ICPC, ESCA, NASCA, OSCA, this will hopefully deliver benefits and results as these represent all the industry leaders within the submarine cable industry and bring together experience and knowledge. The ICPC and the UN, represented by the ITU-T, have come together to form a new advisory body that will look at ways to protect submarine cables from accidental damage, environmental and aggressive acts of sabotage. This is a new industry body that brings the international community together to devise new ways of working that can be given the authority of the UN and have the backing of the ICPC [International Cable Protection Committee]. This body, The Inter national Advisory Body for Submarine Cable Resilience was set up in November 2024.
and goal of the advisory board. Their other purpose is to help disseminate knowledge and collaborate on this important project and helping and supporting the digital economy.



So, with world attention now on the protection and security of submarine cable systems, especially from bad state actors, and a new drive by the UN and industry to keep this forefront in any discussions etc. within industry and collaboration with national naval agencies etc. There is a need to understand how we can combine industry agreed monitoring systems, as mentioned above, and new measures that will be developed by ICPC, ESCA and/or the UN-ITUT. Allies, NATO, and the countries of the EU now need to work together to understand these issues, come up with a feasible plan that will not tie up any naval or NATO asset that could be required for other needs and programmes. So until there is a definite solution on a security question, monitoring submarine cable connectivity seems to be the best way forward. STF

The International Advisory Body for Submarine Cable Resilience was set up to promote the improvement of submarine cable resilience and diversity. The protection of this vital internation communications infrastructure was seen as a necessity
DEREK CASSIDY is doing a part-time PhD in the field of Optical Engineering which covers Photopolymers, Self-Written Waveguides, and Wavelength manipulation/Opto-Electronics with UCD under Prof. John Healy and Prof. John Sheridan. He is a Chartered Engineer with the IET/UK Engineering Council-Engineers Ireland and Past-Chair and Committee Member of IET Ireland. He is Chair of the Irish Communications Research Group, Advisory Board Member of Submarine Networks EMEA/World and member of numerous standards committees on Optical Engineering under the umbrella of the IEEE and Future Networks. He is also currently researching the Communication History of Ireland. He is a member of SPIE, OPTICA, IET, IEEE, Engineers Ireland, ACMA, ICPC and ESCA. He holds patents in Mechanical and Design Engineering and author of over 30+ papers on Photonics, Submarine Cable Technology, Communications and Optical Engineering. He has been working in the telecommunications industry for over 30 years managing submarine networks and technical lead on optical projects, both nationally and internationally with BT. He is technical Lead for Valentia Transatlantic Cable Foundation and the Valentia Island World Heritage Bid. Derek holds the following Degrees: BSc (Physics/Optical Engineering), BSc (Engineering Design), BEng (Structural/Mechanical Engineering), MEng (Technology & Policy Development and Forensic Engineering), MSc (Optical Engineering) and Higher Diploma in Cybersecurity.
Optical Inspection Fail: Contamination/Dirt Optical Inspection Pass
Figure 12: Example of contaminated optical fibre patchlead and cleaned optical fibre end face now in operation.
Figure 11: The zones of an optical fibre end face and connector that need inspection and cleaning.
















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FCC PROPOSES SIGNIFICANT EXPANSION OF REGULATION OVER SUBSEA CARRIERS AND RELATED BROADBAND INFRASTRUCTURE
BY ANDREW D. LIPMAN AND ULISES R. PIN
In November 2024, the Federal Communications Commission (“FCC”) issued a 150+-page Notice of Proposed Rulemaking (“NPRM”) proposing sweeping changes related to the rules and procedures associated with Submarine Cable Landing Licenses (“SCL”). In the NPRM, the Commission proposes substantial amendments to submarine cable licensing, compliance, reporting and security procedures, overhauling the existing regulatory environment. This will be the first comprehensive review of the rules since 2001 to address advancements in technology, heightened national security considerations, and evolving regulatory requirements for these critical systems.
The NPRM was approved unanimously by all five sitting FCC Commissioners and appears to have full bipartisan support, including from new FCC Chairman, Brandan Carr. At the time of this writing, the NPRM is awaiting publication in the Federal Register. Upon publication, there will be a fulsome comment cycle (with both comments and reply comments opportunities) and parties may seek ex parte meetings with FCC Staff and the Commissioners to discuss issues regarding the NPRM. We note that because this is an NPRM, no changes will take effect until the Commission issues a final Report and Order on the matter.
In this article we seek to provide a high-level review and summary of the FCC’s proposals in this NPRM. We note
that the proposed changes seek to alter the current regulatory paradigm by substantially extending the regulatory burden on current licensees and may sweep currently unregulated parties, such as submarine cable capacity customers or data center providers into FCC regulation.
Among others, the NPRM makes the following proposals regarding the SCL licensing process:
APPLICANT/LICENSEE REQUIREMENTS
The NPRM seeks to modernize the eligibility criteria for entities applying for SCLs by expanding oversight to include those owning or controlling submarine cable systems connected to U.S. networks. Under current FCC rules, only entities owning or controlling U.S. cable landing stations or with at least a 5% ownership interest in a cable system using U.S. points must apply for and hold a license. The FCC now proposes to broaden this requirement to cover entities controlling critical equipment, particularly Submarine Line Terminal Equipment (“SLTE”), which converts submarine signals to terrestrial ones. The FCC also considers mandating landing licenses for entities with Indefeasible Right of Use (“IRU”) agreements, including internet content providers (“ICPs”) using SLTE to connect global data centers.
The FCC is also seeking views as to whether it is appropriate to extend licensing requirements to any entity

with capacity on a submarine cable, even without SLTE or landing station ownership.
REQUIRING LICENSURE FOR DATA CENTER OPERATORS OR PASSIVE INFRASTRUCTURE PROVIDERS
Some of the FCC proposed changes regarding licensure and regulatory compliance may impact currently unregulated providers such as data center owners and operators. The FCC proposes to expand licensure beyond those that control a Cable Landing Station (“CLS”), but also to entities that own or control data centers and other locations where SLTE may be located. Specifically, the FCC seeks comment on the applicability of its rules to data center owners, including the access they have over submarine cables and the site operations, such as physical security, power, backup power, HVAC, and other environmental support essential to proper operations of cable landing systems housed in their facilities. We note that under the current rules, unless a data center is being used as a CLS, there are no reporting requirements about the parties that lease space to SCL holders in non-CLS data centers.
PRESUMPTION OF NOT QUALIFIED ENTITIES
The FCC proposes a presumption that certain entities, especially those associated with so-called and alleged foreign adversaries, are unqualified to obtain new submarine
cable landing licenses due to national security concerns. Entities whose applications were previously denied, or licenses revoked on national security grounds, are specifically named. These companies, along with their current and future subsidiaries and affiliates, must overcome a presumption of ineligibility if they seek licenses. The FCC explains that this proposal aligns with the FCC’s authority to prevent entities with national security risks from accessing critical infrastructure.
Additionally, the FCC considers prohibiting licensees from entering arrangements with “foreign adversary” countries (as defined under Commerce Department Rules) for IRU or leasing capacity on U.S. submarine cables. These restrictions could prevent entities from so called and alleged foreign adversary nations from accessing U.S. communication infrastructure indirectly. Additionally, the FCC is reviewing whether to prevent cables from landing in adversary countries, seeking comments on these proposals to mitigate security risks associated with foreign entities in the cable infrastructure sector.
REDUCING LICENCE TERM AND/OR PERIODIC REVIEWS OF THE LICENSE
Submarine cable landing licenses are currently granted for 25-year terms. This long license term reflects the long life of
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current submarine cable systems, which, if maintained properly, can run strong for decades. Moreover, the long license term provides submarine cable operators with regulatory certainty about the continuous operation of the system.
In the NPRM, the FCC seeks views as to whether a shorter license period is warranted given the Commission’s public interest responsibilities under the Cable Landing License Act regarding national security, particularly in a constantly changing national security environment. The FCC is considering whether “shortening the license term by itself or in combination with periodic reporting, could enable the Commission to assess—earlier than the current 25-year license term—whether a particular cable landing licensee complies with the relevant statutory and rule requirements, whether there are any rule-compliant but unreported changes in ownership or operations, or other factors that present national security, law enforcement, foreign policy and/or trade policy concerns, and whether the license continues to serve the public interest.” The FCC seeks views as to whether a five or 10-year license term may be more appropriate under the current circumstances.
In lieu of shortening the term of the license, the FCC proposes to strengthen its periodic reporting requirements for cable landing licensees by mandating that they submit updated information every three years on ownership, infrastructure, and compliance details. Based on these reports, the Commission may determine to impose additional conditions on a licensee or even revoke a license if circumstances have changed.
Under the proposal, the periodic reports must include substantial information regarding licensee ownership details, contact information, cable infrastructure specifications, current and future service offerings, cybersecurity and regulatory compliance certifications. For existing licensees, there would be a tiered system where each licensee would have to submit a report at a specified 6-month interval based upon certain factors such as foreign ownership and recency of FCC prior review.
These proposed reports to the Commission are substantially more intrusive than any reporting requirements currently applicable to submarine cable licensees. Moreover, in many respects they appear to be a duplication of similar reports that SCL licensees are generally required to file with the U.S. national security agencies affectionately referred to as “Team Telecom,” under the terms of mitigation agreements (e.g., National Security Agreements (“NSA” or Letters of Agreement (“LOA”)) that submarine cable operators generally need to enter with Team Telecom as a condition of obtaining an FCC SCL
ADDITIONAL INFORMATION ABOUT CABLE SYSTEMS
In an expansion from current requirements, the FCC proposes requiring detailed information about the dry portion of a system, including specifying the location of (1) each beach manhole, (2) each cable landing station including locations of each power feed equipment and each SLTE, and (3) each Network Operator Service (“NOC”) providing remote access to the submarine cable system. The FCC also seeks comment on whether it should require SCL applicants and licensees to file with the Commission route position lists containing the geographic coordinates of the wet segment of the submarine cable, including the geographic coordinates of the entire wet segment of the submarine cable. Finally, the Commission proposes that all detailed geo-location and coordinates be considered confidential information not subject to public disclosure, but subject to sharing with other federal agencies.
CURRENT AND FUTURE SERVICE OFFERINGS OVER THE CABLE
Currently, SCL licensees are not required to provide the Commission with details about their service offerings. The FCC now proposes requiring applicants and licensees to provide the following information regarding services that they provide or will provide over the submarine cable system: (1) identification and description of the specific services the applicant(s) and licensee(s) provides or intends to provide; (2) types of customers that are served or will be served, including those with whom the applicant(s) and licensee(s) lease, sell, share, or swap fiber, spectrum, or capacity; (3) whether the applicant(s) and licensee(s) own or control capacity on the U.S. portion of the submarine cable system including the submarine cable landing station(s) through an IRU or leasehold interest; (4) identifying where the applicant expects to market, offer, and/or provide services; and (5) the general terms and conditions applicable to the service provided such as contract term length, minimum capacity/bandwidth requirements, IRU requirements, termination clauses, security requirements, delivery or Service Level Agreements (SLA) requirements, dispute resolution, and other applicable provisions.
COMPLIANCE CERTIFICATIONS
The FCC has proposed new regulatory compliance certifications aimed at protecting submarine cable infrastructure from national security, law enforcement, and cybersecurity risks. The proposed certifications requirements for SCL applicants and licensees include:
• Compliance Certification with FCC Rules, requiring
disclosure of past violations and other relevant legal or regulatory issues;
• Cybersecurity Certifications, mandating the creation and maintenance of cybersecurity risk management plans following established frameworks such as NIST, to protect the confidentiality, integrity, and availability of systems;
• Covered List Certifications, which would prohibit using equipment or services identified as threats under the FCC’s “Covered List” (i.e., the list of telecommunications equipment and services covered by Section 2 of the Secure Networks Act) and other potential sources, such as the Department of Commerce’s Entity List (i.e., a US government compilation of foreign individuals, companies, and organizations deemed a national security concern); and
• Traffic Interruption Capability, ensuring that licensees have the capability to suspend or disconnect traffic on their systems as needed for national security.
Third Party Access, Risk, and Protection. The FCC is exploring measures to address national security and law enforcement risks related to third-party access to U.S.-licensed submarine cable systems, focusing on both physical and logical access vulnerabilities. Specifically, the FCC seeks comment on the oversight of non-licensee individuals and entities, including building owners, co-tenants, contractors, and Managed Network Service Providers (“MNSPs”) who manage network operations, performance, and other critical functions. This includes establishing requirements for license applicants to report the use of foreign-owned MNSPs and the physical security of NOCs as a key safeguard. The FCC also seeks feedback on requiring applicants to provide detailed information on any third-party access arrangements, including data security and operational monitoring, as a precautionary measure against risks posed by unauthorized access.
IMPROVE THE QUALITY OF THE CIRCUIT CAPACITY DATA
The FCC currently collects annual circuit capacity reports on U.S.-international submarine cables, which include available and planned capacity data from cable licensees and capacity holders. These data are crucial for fulfilling the FCC’s national security, law enforcement, and public safety responsibilities, as well as for aiding other federal agencies. The Commission is proposing a new category of reporting regarding SLTE ownership and operation on the system. It is also considering expanding data collection to domestic cables and requiring additional entities to report (i.e., extending obligations to entities
other than SCL licensees or Section 214 holders, which would greatly expand the universe of reporting entities).
OTHER CHANGES
The FCC proposes updates to submarine cable license application requirements to improve clarity and address national security concerns. This includes formalizing existing requirements, specifying conditions for license assignments, transfers, and renewals, and requiring regular updates of licensee contact information and cable system information. Additionally, the FCC seeks to mandate a commencement of service within three years of licensing, or else face potential automatic license cancellation.
CONCLUSION
Many of the FCC proposals are commendable and long overdue, while others appear to be duplicative of national security obligations already imposed on licensees by Team Telecom and other agencies. If adopted, several of the FCC’s proposed changes will substantially elevate the regulatory burden and compliance costs of operating a submarine cable landing in the United States. Moreover, they may expand FCC jurisdiction to entities not currently regulated by the Commission. We would expect that the submarine cable industry, and those not directly operating cables --such as data center operators and passive infrastructure providers-- would actively participate in the rulemaking process and will offer views to the Commission about these proposals. STF

ANDREW D. LIPMAN is Partner at Morgan, Lewis & Bockius LLP, and practices in most aspects of communications law and related fields, including regulatory, transactional, litigation, legislative, and land use. Andy’s clients in the private and public sectors include those in the areas of local, long distance, and international telephone common carriage; Internet services and technologies; conventional and emerging wireless services; satellite services; broadcasting; competitive video services; telecommunications equipment manufacturing; and other high-technology applications. Additionally, he manages privatizations of telecommunications carriers in Europe, Asia, and Latin America.

ULISES R. PIN is Partner at Morgan, Lewis & Bockius LLP, and deputy leader of the firm’s telecommunications, media, and technology (TMT) practice, represents US and foreign communications and technology companies on corporate, financial, and regulatory matters. He also advises private equity firms, venture capital funds, and financial institutions on investments in the TMT sector, specializing in digital infrastructure and data centers. Ulises represents clients before the Federal Communications Commission and government agencies in Mexico, Latin America, Europe, and Asia. He has experience in cross-border transactions with particular emphasis on foreign investment and national security issues, including securing approvals by the Committee on Foreign Investment in the United States (CFIUS).

IWCS SEEKS TECHNICAL PAPERS FOR THE ANNUAL CABLE & CONNECTIVITY INDUSTRY FORUM
By David Kiddoo
Burke, Virginia, USA [January 21, 2025] – IWCS calls industry professionals and academic researchers to submit a brief 300–500 word abstract summarizing research or emerging technologies affecting the global cable and connectivity industry. Abstracts will be reviewed by the IWCS 2025 Technical Symposium Committee and authors of accepted abstracts will gain international exposure for their work.
Technical Papers will be presented during the Technical Symposium component of the 2025 IWCS Cable & Connectivity Industry Forum. Participants have the option to present their Technical Paper as a presentation or as a poster display during the 74th annual IWCS Forum. This year’s Forum is scheduled to take place October 27–30, 2025 at the David L. Lawrence Convention Center in Pittsburgh, Pennsylvania, USA.
Papers will be published in the IWCS research archives and select papers may be featured in relevant industry magazines, providing par-
ticipants additional recognition for their work and their company. Additionally, presenters have the opportunity to receive prestigious awards for their research and presentation. The IWCS Technical Symposium Committee recently announced the following awards for papers presented

Mabud Choudhury, Standards Manager at OFS, presents a Technical Presentation on fiber optic links for artificial intelligence computing and networking during the IWCS 2024 Technical Symposium
during last year’s Forum. The Jack Spergel Memorial Award for Outstanding Technical Paper will be announced soon.
• Kitts-Kingsley Award for Best Presentation: Mr. Bernard Lee, SENKO Advanced Components, “Connectivity Advancement Trends for Quantum Technology & Its Applications”
• Award for Outstanding Poster Paper: Ms. Alison Shapiro, University of Delaware, “Crosslinked Polyolefins: Opportunities for Fostering Circularity Throughout the Materials Lifecycle”
SUGGESTED TECHNICAL TOPICS –SEE MORE ON THE IWCS WEBSITE

Examples of paper topics range from manufacturing processes of copper and optical fiber cables, innovative cable design, codes and standards, connectivity and assemblies, installation techniques, materials and extrusion processing, sustainability and recycling, energy smart grid, broadband connectivity, and more. A complete list of suggested topics is available on the IWCS website. Additional topics are also welcome.
IWCS accepts submissions from all industry professionals, with no limitation of job title or level of experience. Examples of past authors’ roles include, but are not limited to: Engineering, Research & Development, Product Management, and Academia in a variety of market and industry segments relevant to cable products, materials, processes, and applications.
REFER YOUR COLLEAGUES – OPPORTUNITY FOR COMPLIMENTARY EVENT REGISTRATION
A referral program is available for those who wish to refer their colleagues to submit a paper. When a colleague submits their abstract, they will be asked to enter your name as the referral source. The person who refers the most authors of accepted Technical Papers will receive complimentary full-access registration to the 2025 Cable & Connectivity Industry Forum.
HOW TO PARTICIPATE
A complete list of suggested topics, submission criteria,
and resources to refer colleagues can be found at on the IWCS website. The deadline to submit a Technical Paper abstract is April 11, 2025. Visit iwcs.org/present for details.
ABOUT IWCS
IWCS is a not-for-profit organization that has hosted the premier event for new technologies in cable and connectivity products, processes, and applications for the past 73 years. The Cable & Connectivity Industry Forum is the leading worldwide event to explore topical issues, learn about new technologies, and network with colleagues from the communications, data, electronics, power, industrial, automotive, and aerospace industries. In addition to the Forum, IWCS is committed to the development of industry professionals and scholars by hosting educational webinars, publishing research, and awarding scholarships.
The IWCS Technical Symposium Committee generates an extremely high-caliber program for each year’s Forum. Peer-reviewed papers presented during the Technical Symposium and recordings from the IWCS Webinar series remain archived for ongoing research and education. STF

DAVID KIDDOO is the CEO / Director of IWCS, Inc. Prior to his current role, David spent over 20 years as the Global Business Manager for Wire and Cable insulation and sheathing products at AlphaGary Corporation. He also had 11 years of wire & cable experience with the Du Pont Company.
Ms. Alison Shapiro, PhD Candidate in Chemical and Biomolecular Engineering at University of Delaware presents a technical poster paper related to crosslinked polyolefins during the IWCS 2024 Poster Session
WHEN NATURE STRIKES
The Hidden Threats To The World’s Subsea Cables
BY DR LUCY BRICHENO, DR MIKE CLARE AND DR ISOBEL YEO

Subsea telecommunication cables, the unsung heroes of our hyper-connected age, carry over 99% of all digital data traffic worldwide. They silently facilitate everything from simple emails to trillions of dollars in daily financial transactions. Spanning over 1.6 million kilometres around the globe, it’s a resilient network that’s been designed to withstand the unforgiving conditions of the deep sea.
Subsea cables are built to be robust, through cable armouring and diverse routing providing redundancy that allows rerouting of data traffic in the blink of an eye. Yet, these vital connections are still vulnerable to damage by humans, as highlighted throughout history.
They are also vulnerable to another problem, natural hazards, as a collaborative research project led by scientists at the UK’s National Oceanography Centre (NOC) recently found.
It analysed data on instances where cables were damaged, leading to a loss in data transmission or the need for a major repair. While most of the damage was caused accidentally by human activities, such as fishing and anchoring, the data from 1965 to 2019 found 1,473 faults (25% of those recorded) could be attributed to natural hazards.
Natural hazards comprise a wide spectrum, from infrequent, high-magnitude events that make headlines, to persistent, low-level forces that work continuously beneath the waves.
Geological hazards, such as earthquakes, volcanic eruptions and submarine landslides, represent the dramatic end of this spectrum. Earthquakes, capable of displacing the seafloor and triggering tsunamis that can span entire ocean basins, pose a significant, but often unavoidable, threat to cable integrity.
Volcanic eruptions, though less frequent, unleash a cascade of destructive forces that can sever cables, bury them under mountains of debris or render them inoperable.
NOC is dedicated to understanding and mitigating these risks, mapping geological events like earthquakes and landslides and analysing cable fault data to understand the causes and damage mechanisms.
CATASTROPHIC HAZARDS
The 2022 eruption of Hunga Volcano in Tonga is a stark example of not only what can happen to vital infrastructure in the event of a major geological hazard, but also the com-
NATURE

plexities of what actually causes the damage. The Hunga eruption, exceeding VEI 5 (a measure of volcanic explosivity), generated tsunami waves over 15 metres high and an eruption plume reaching 57 kilometres into the atmosphere. The resulting damage to Tonga’s sole international cable led to communication blackouts, severely hampering aid efforts.
Post-eruption surveys revealed that the culprit was not the eruption itself, but the fast-moving, underwater density currents triggered by the collapsing eruption column. These currents, reaching speeds of up to 122 km/h, eroded the seafloor, carving gullies up to 100 metres deep and burying sections of the cable under more than 20 metres of volcanic sediment.
The remoteness of the region and the extent of the damage further complicated repairs, requiring the manufacture of over 100 kilometres of new cable and taking five weeks to restore the international cable and 18 months for the domestic cable.”
Submarine landslides, often triggered by earthquakes or sediment accumulation, can also displace or bury cables over large areas. The 2006 Pingtung earthquake offshore Taiwan, for instance, triggered a fast-moving underwater sediment flow known as a turbidity current that severed
multiple cables. It took 11 cable ships seven weeks to complete hundreds of millions of US dollars of repairs.
HYDROLOGICAL HAZARDS
Further down the spectrum lie hydrological hazards, such as river floods. These floods, especially in regions with heavy sediment loads, can give rise to powerful underwater turbidity currents that carve their way through submarine canyons, eroding the seafloor and threatening the cables that lie in their path. The Congo Canyon (off the coast of West Africa), for example, has seen repeated cable breaks following major floods of the Congo River, highlighting the persistent threat posed by this hydrological phenomenon.
This canyon, extending over 1,200 kilometres into the deep sea, acts as a conduit for powerful, sediment-laden flows originating from the Congo River. Multiple cables, routed across this canyon, have historically experienced frequent faults, particularly following periods of elevated river discharge.
In 2020, two branches of the West Africa Cable System (WACS) and the South Atlantic 3 (SAT-3) cable, laid across the Congo Canyon at around 2,000 and 4,000 metres depth and previously undamaged for 18 years, were severed by powerful turbidity currents. These currents, triggered by a record-breaking Congo River flood, travelled over 1,100 kilometres at speeds of 5-8 m/s, disrupting internet connections across western and southern Africa during the crucial early stages of the COVID-19 pandemic lockdown.
The damage occurred two weeks and 10 weeks after a major flood, highlighting the delayed and cascading nature of this type of hazard. Repairs took 15-20 days. Similar turbidity currents in the Congo Canyon have continued to damage cables in subsequent years, including incidents in April 2021, January 2022 and August 2023. In the most recent case of damage, data traffic could be rerouted through an unaffected cable that was laid away from the canyon, in much deeper water.
In 2023, a new cable system was routed into deeper waters away from the canyon, and remained operational during a turbidity current event, allowing for swift data rerouting and minimizing disruption; demonstrating the value of diverse route options.
MORE PREDICTABLE HAZARDS
Meteorological and oceanographic hazards, such as storms and wave action, are often overlooked, but pose a slow but persistent threat.
While seemingly distant from the seabed, they can generate substantial stress, mobilizing sediment, and moving a cable around, which can lead to cable suspension and abrasion over time.
FEATURE
A COMPLEX WEB OF CONSEQUENCES
More broadly, cascading hazards are the norm rather than the exception, making it difficult to pinpoint a single root cause.
The Hunga Volcano eruption, for example, didn’t sever the cable directly, it was the powerful underwater density currents generated by the collapsing eruption column that delivered the fatal blow. Similarly, in the Congo Canyon, the initial river flood was not the culprit, it was the delayed triggering of turbidity currents by extreme Spring tides that caused the cable breaks weeks later.
Similarly, the gradual accumulation of damage from abrasion caused by persistent currents often makes it difficult to assign blame to a specific event. This lack of a clear trigger leads to many such cases being classified as “unknown” in industry databases, obscuring the true nature and pervasiveness of the threat.
UNEQUAL IMPACTS
Another challenge is that while some regions, like Europe and North America, have numerous interconnections and benefit from a robust and interconnected infrastructure, others, particularly Small Island Developing States (SIDS), face heightened vulnerabilities due to a combination of factors.
Oceania, and SIDS in particular, often have limited cable connections, sometimes even just one, and bandwidth capacity, making them susceptible to disruptions.
These regions are also often located in areas prone to geological hazards, such as earthquakes and volcanic activity, compounding their vulnerability. Oceania is particularly vulnerable, with fewer connections and lower bandwidth than other areas of the globe.
Furthermore, the intensity and frequency of these hazards are projected to increase due to climate change, further amplifying the risks for Oceania. For SIDS, the reliance on internet connectivity extends beyond convenience. It’s a lifeline for essential services like education, healthcare and economic activities. Prolonged outages in these regions can severely disrupt daily life, hamper development, and isolate communities at critical moments.
Addressing this vulnerability gap requires a multipronged approach. Diversifying cable routes and landing stations is crucial, but the economic realities of these regions often make this challenging. Improving access to cable repair vessels and maintaining sufficient stocks of spare cable can minimize downtime in the event of a break.
A STRONGLY CONNECTED FUTURE
Despite all of the threats that global subsea cables face, they have proven remarkably resilient. “The industry is
constantly learning from past incidents and adopting proactive measures to safeguard this critical infrastructure,” says John Wrottesley of the International Cable Protection Committee. “Key strategies to bolster subsea cable resilience include planned redundancy, and strategic route planning for new subsea cable systems that considers geological activity, submarine canyons and turbidity currents.”
It’s an ongoing learning curve. The quest for a truly resilient subsea cable network requires a continuous commitment to research and innovation. Especially an improved understanding of the more predictable natural hazards from storms and waves – which are becoming more common under ongoing climate change.
Detailed seafloor mapping and repeat surveys are essential in identifying potential hazards, understanding the dynamic nature of seabed features and guiding optimal cable routing. Initiatives like Seabed 2030, with its goal of mapping the entire ocean floor by 2030, will help this.
Close working between scientists and the cable industry remains important.
COVID-19 taught us that we can work internationally with a low carbon footprint, but this is dependent on a truly global network of subsea cables. As our reliance on this infrastructure intensifies, so too must our commitment to understanding and mitigating the natural hazards that threaten it. STF

DR MIKE CLARE leads research that focuses on understanding dynamic processes in the deep sea at the National Oceanography Centre and is the Marine Scientific Adviser to the International Cable Protection Committee.


DR LUCY BRICHENO is a coastal oceanography, working on climate change impacts on the sea and society at the National Oceanography Centre.
DR ISOBEL YEO is a Senior Researcher in volcanology, marine geohazards and small island resilience at the National Oceanography Centre.
The study was supported by the Natural Environment Research Council and the International Cable Protection Committee, and was co-authored by experts at National Grid, Victoria University of Wellington, Durham University, Ocean-IQ and Tonga Cable Limited.
Read the full paper, “The diversity, frequency and severity of natural hazard impacts on subsea telecommunications networks”, in Earth-Science Reviews: https://www.sciencedirect.com/science/article/pii/S0012825224003003
PROVEN PROCESSES AND METHODOLOGIES
• Defined Processes
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INTRODUCING THE VIRTUAL REP
• In-Field Analysis Without In-Field Risk
• Remote real-time analysis and reporting without the added cost of today’s in-field representation liabilities.

FEATURE REGULATING DIGITAL LIFELINES
BRIEF OVERVIEW OF SUBMARINE CABLE GOVERNANCE IN AFRICA
BY ANJALI SUGADEV

[Reprinted Excerpts from SubTel Forum’s 2024/25 Submarine Industry Report]
Submarine cables play a pivotal role in connecting African countries to the global digital economy, facilitating high-speed internet, telecommunications, and financial transactions. In recent years, many new submarine cable systems have been deployed across Africa, significantly enhancing the continent’s connectivity with the rest of the world and in turn bridging the digital divide. Some of the most significant
cable systems laid in Africa lately are 2Africa, Equiano Cable, PEACE Cable and METISS Cable. As more submarine cable investments flow in the direction of the African continent, a jurisdictional scan of the regulatory frameworks of key African countries may give a basic lay of the land. A brief analysis of how the following African governments, that is, Kenya, Ghana, South Africa, Nigeria and Egypt manage cable-laying activities, protect
REGULATING AFRICA’S LIFELINES

national security, and ensure environmental sustainability is provided below.
KENYA 1
The competent authority to license all communications systems and services in the country is the Communications Authority of Kenya (CA). According to the provisions of relevant statutes, including the Kenya Information and Communications Act, 1998 and the Kenya Communica1 https://www.ca.go.ke/licensing-procedures
tions Regulations 2001, CA issues commercial licenses on a first-come-first-served basis.
CA has in place a Unified Licensing Framework (ULF), which is technology and service neutral. Investors who intend to land a submarine cable in Kenya require a Submarine Cable Landing license. The license is valid for 15 years. License application fee is Kenyan Shilling (KShs) 5,000 with an initial operating fee of KShs. 15 million and an annual operating fee of 0.4% of Annual Gross Turnover or KShs. 4 million whichever is higher.2 The turn-around time to process the license application is 135 days.
GHANA 3
A submarine cable licensee is authorized to land and operate an optical fibre submarine cable system in Ghana. They are allowed to build and operate Submarine Terminating Line Equipment (STLE) to terminate international cable or spur off an international cable, as well as provide for domestic and/or international interconnection.
Submarine cable landing involves an application fee of Ghanaian Cedi (GHC) 290,000.00, license/ authorization fees of GHC 5,700,000.00 and annual regulatory fees of 1% of Net Revenues each to National Communications Authority (NCA) & the Ghana Investment Fund for Electronic Communications (GIFEC). 4
In addition to licensing from the NCA, submarine cable projects in Ghana are subject to an Environmental Impact Assessment to ensure that marine ecosystems are preserved during cable installation and an authorization from the Ghana Environmental Protection Agency (EPA) is required.
SOUTH AFRICA
The Independent Communications Authority of South Africa (ICASA) regulates the electronic communications industry, electronic communications networks and services, including submarine cables. According to the 2008 Guidelines under the Electronic Communications Act, 2005 (ECA) for Rapid Deployment of Electronic Communications Facilities, an international submarine cable, a cable landing station or an international submarine cable system may only be landed or operated in the Republic with the written authorization issued by the Minister.5 To qualify for
2 https://www.ca.go.ke/sites/default/files/CA/Licensing%20Procedures/New-MarketStructure-Under-The-Unified-Licensing-Framework-February-2017.pdf
3 https://nca.org.gh/submarine-cable-landing/
4 https://nca.org.gh/wp-content/uploads/2021/01/REVISED-Schedule-of-Fees-2016with-new-TV-Rates-Infrastructure.pdf
5 https://www.icasa.org.za/legislation-and-regulations/licensing-processes-andprocedures-for-individual-licences-2010
FEATURE
authorization, the applicant must be a registered individual electronic communications network service licensee.
In terms of environmental permits, the Department of Environmental Affairs and Tourism serves as the competent authority for granting the requisite environmental authorization. Coastal provinces have jurisdiction over the seabed from the coast out to three nautical miles as well as over the land where cables emerge from the sea, hence the respective provincial authorities need to be consulted for applicable permissions.
There are other regulatory requirements applicable, such as the Sea-Shore Act for a seashore lease that may be applicable.
NIGERIA 6

The Nigerian Communications Commission (NCC) is responsible for regulating telecommunications infrastructure, including submarine cables, in Nigeria. Under the 2003 Nigerian Communications Act (NCA), proper authorization from NCC through a communications license or exemption under their regulations is required to operate a communications system or facility. The 2019 NCC Licensing Regulations specifies the process and requirements for obtaining the license. Operators intending to install fibre optic cables will need a specific type of individual license called the Metropolitan Fibre Cable Network (MFCN) license that outlines conditions for operation of submarine cables. An MFCN licensee is permitted to construct, maintain and operate fibre optic transmission facilities and backbone networks on land or underwater. This license is valid for 20 years and may be renewed at the end of its term.
Under the 1992 Environmental Impact Assessment Act, submarine cable projects in Nigeria need to undergo an EIA. The Equiano Cable, for example, was required to submit an Environmental and Social Impact Assessment (ESIA) to minimize environmental impact and to maxi-
mize cable protection and reliability.7
In March 2023, the Management of the Nigerian Maritime Administration and Safety Agency (NIMASA) and NCC announced partnership in developing a regulatory framework to provide operational guidelines for Submarine Cable and Pipeline Operators in Nigeria, in line with the provisions of the United Nations Convention on the Law of the Sea (UNCLOS).8 This move was precipitated by the need to ensure safety of navigation of shipping in Nigerian waters and prevent unregulated underwater cable laying.
EGYPT 9
The 2003 Egyptian Telecommunications Law No. 10 lists the activities subject to licensing obligations and submarine cables is one of them. A Fixed Telephony license is required to establish and operate submarine cable infrastructure. The license is valid for 10 years with financial obligations such as a performance bond of 20 million EGP, among others. Concession fees and annual fees are determined by the National Telecommunications Regulatory Authority (NTRA). The licensing process may take about
7 https://ead.gov.ng/wp-content/uploads/2020/11/Equiano-Nigeria-ESIA-ReportSubmitted-Draft-Final.pdf
8 https://nimasa.gov.ng/maritime-safety-nimasa-ncc-close-ranks-on-submarine-cableregulation-in-nigeria/
6 https://www.doa-law.com/wp-content/uploads/2024/06/Regulatory-Framework-forthe-Deployment-of-Fibre-Optic-Cables-in-Nigeria.pdf
9 https://www.tra.gov.eg/wp-content/uploads/2023/11/Investor-Guide-EN.pdf and https://www.tra.gov.eg/en/regulations/licenses/investor-guide-of-telecom-services-licenses/
three months after complete submission of the required data and documents.
Currently, Telecom Egypt has the exclusive rights (the only Fixed Telephony licensee)10 to establish submarine communications infrastructure while the remaining operators have to lease capacities from it.11
IN THE ABOVE COUNTRIES
Apart from the authorizations and licenses mentioned above, there are permits needed from other government agencies. Similar to the lengthy processes in some other non-African countries, there might be bureaucratic delays, lack of clarity of rules or procedural anomalies to obtain these permits in some of the above jurisdictions. For instance, in the case of PEACE cable system, careful planning and sequential consultation with almost 20 Egyptian government departments and agencies was necessary before the permit application could be successful.12
REGIONAL EFFORTS
Fifteen West African nations have formed a regional economic union called the Economic Community of West African States (ECOWAS) aimed at promoting economic integration and cooperation. One of its key roles is to create common regulatory frameworks that promote trade, infrastructure development, and regional stability, including infrastructure such as submarine cables.
ECOWAS Regulation on Conditions for Access to Submarine Cables Landing Stations, 2012 cover several topics that impact submarine cable landing such as colocation service, backhaul services and so on. The regulation also stipulates minimum requirements for grant of cable landing station licenses by its Member States, such as conditions for preventing anti-competitive behavior, providing open access to landing stations, offering international capacities on non-discriminatory basis, and an obligation to cooperate with the other cable landing stations (established across the Member States’ territories) in providing mutual assistance in case of breakdown.13
This regional framework is an example of how cooperation among states can facilitate cross-border submarine
10 https://www.tra.gov.eg/wp-content/uploads/2021/08/%D9%85%D8%B9%D9%84%D 9%88%D9%85%D8%A7%D8%AA-%D8%B9%D9%86-%D8%A7%D9%84%D9%85% D8%B1%D8%AE%D8%B5-%D9%84%D9%87%D9%85-%D9%84%D8%AA%D9%82%D8%AF%D9%8A%D9%85-%D8%AE%D8%AF%D9%85%D8%A7%D8%AA-%D8%A7 %D9%84%D8%A7%D8%AA%D8%B5%D8%A7%D9%84%D8%A7%D8%AA.pdf
11 https://enterprise.press/hardhats/egypt-make-better-use-position-subsea-internetcable-hub/
12 https://oceaniq.co.uk/projects/peace-pakistan-east-africa-connecting-europe-cablesystem/
13 https://www.itu.int/en/ITU-D/Projects/ITU-EC-ACP/HIPSSA/Documents/ FINAL%20DOCUMENTS/FINAL%20DOCS%20ENGLISH/submarine_cables_ ecowas_regulation.pdf
cable projects. Such rules that ensure open access and non-discriminatory practices can alleviate concerns relating to monopoly control. Nonetheless, while ECOWAS regulations exist, adoption or enforcement of these guidelines may differ across its member states.
HOW WOULD PERMITTING PROCESSES IMPACT AFRICA’S FUTURE?
According to the United Nations, the population of Africa is likely to increase from 1 billion inhabitants in 2014 to 2.4 billion in 2050, representing a quarter of the world’s population, with the 15- to 24-year-old population rising from 200 million to more than 700 million in 2050.14 It is therefore a promising contestant for investments in the rising digital market, which is already the trend (as many operators have invested in cable systems in Africa in recent years). Several cable systems are either underway or planned in the near future. Some of them are India Europe Xpress (IEX), Africa-1, Raman, SeaMeWe-6.
Submarine cable systems in the African coasts face other risks such as seismic activity, piracy, terrorist activities, or political unrest in some of the countries. Although such risks exist, providing a robust and well-coordinated permitting system for submarine cables will make it one less problem for potential investors to worry about. There is general recognition among some regulators of the significance of submarine cables to their economy and many governments are making progress in clarifying their regulations with respect to submarine cables, for instance, Nigeria. However, a streamlined permitting process for submarine cables, either at the national level or through effective regional cooperation is crucial to enjoy the benefits of digital connectivity. STF

ANJALI SUGADEV is Regulatory & Permitting Manager at WFN Strategies, and an independent legal consultant and recipient of the 2015 Rhodes Academy Submarine Cables Writing Award. Her works include “Global Regulation of Submarine Cables and Pipelines: Similarities, Differences and Gaps” (2016), “India’s Critical Position in the Global Submarine Cable Network: An Analysis of Indian Law and Practice on Cable Repairs” (2017) and “Review of Selected National Legislations Relating to Access and Benefit-Sharing” (2019) among others. Sugadev was also the Law and Policy Lead of Sustainable Subsea Networks, that involved examining the legal and permitting frameworks, international and national, to understand the role of regulation and policy in shaping a carbon-reduced future for the subsea cable industry.
14 https://ferdi.fr/dl/df-9h5z9RWRNm4adFraG5Zd9YpS/ferdi-p241telecommunication-submarine-cable-deployment-and.pdf
FEATURE BEYOND THE CABLE
Why Skilled Field Teams Define Project Success
BY KRISTIAN NIELSEN AND GLENN HOVERMALE

Deploying a submarine cable system is no small feat. It’s a high-stakes, multi-million-dollar endeavor that connects continents, nations, fuels global communication, and supports critical infrastructure. But beyond the engineering, logistics, and financing, one often overlooked factor makes or breaks a project—the people in the field.
The individuals installing the cable, ensuring compliance, and troubleshooting problems need to be top-tier professionals with the right training, experience, and mindset. That’s why selecting the right company and client representative for fieldwork is just as crucial as choosing the right cable route or vessel.
So, what separates the best from the rest? Let’s take a closer look at the key qualifications and requirements you should expect from your team in the field..
EXPERTISE AND EXPERIENCE: THE FOUNDATION OF SUCCESS TECHNICAL EXPERTISE
Working on a submarine cable system requires in-depth knowledge of cable design, route engineering, marine installation techniques, and maintenance procedures. A seasoned company and a highly skilled client representative ensure that every phase of the project, from pre-lay surveys to final bight deployment and release, is executed flawlessly. The more experience they have, the better they can antici-
pate and mitigate potential issues.
Over the past 15-20 years, advances in modeling have enabled several companies to develop both theoretical and practical software programs that aid in the design and implementation of submarine cable systems. This software has become the industry standard and is utilized on all cableships within the industry. It has become imperative that a good representative is not only aware of these programs, but that they have a working knowledge as well.
PROJECT MANAGEMENT PROFICIENCY
A submarine cable project has a lot of moving parts. There are multiple stakeholders, tight timelines, and countless logistical considerations. A strong project management team ensures efficient coordination among marine crews, regulatory agencies, engineering teams, and financial backers. Above all, fully-transparent communications with the purchaser ensures that the real-time updates are available to the future owner of the cable. Without these priorities, delays and cost overruns become inevitable.
REGULATORY ACUMEN
International submarine cable projects require careful navigation of regulatory frameworks, permitting processes, and
compliance requirements. An experienced company understands the local and international laws governing cable landings, marine operations, and environmental regulations. For individuals in the field, an office-based investigation about visas and vessel crew requirements begins at least 1-month before the start of the work. With ample time and expertise, the necessary approvals can be secured without costly delays.
THE NON-NEGOTIABLES: SAFETY, QUALITY, AND ADAPTABILITY QUALITY ASSURANCE COMMITMENT
Modern submarine cables are designed with a lifespan of 25-years, and they are expected to endure harsh ocean conditions for the duration. That’s why stringent quality control measures must be in place at every stage. Companies that prioritize quality assurance minimize the risk of failures, ensuring the system’s longevity and performance. An intuitive representative is prepared to conduct preliminary audits that ensure that all quality control measures are in place and being adhered to.
ENVIRONMENTAL RESPONSIBILITY
Today, submarine cable installations are held to high environmental standards. The best teams understand how to minimize ecological disruption by carefully planning cable routes, avoiding sensitive marine habitats, and using environmentally conscious installation techniques. A comprehensive representative will be aware of local and international marine environmental regulations and will liaise with Marine Mammal Observers and Protected Species Observers as necessary.
PROBLEM-SOLVING UNDER PRESSURE
The ocean is unpredictable, and so are submarine cable projects. Weather delays, unexpected seabed conditions, and technical issues can arise at any time. The best companies don’t just react to problems—they anticipate them. Teams with a strong track record of innovative problem-solving can adapt to challenges in real time, ensuring that projects stay on track.
CLEAR COMMUNICATION
With so many stakeholders involved, communication is everything. The best field teams provide regular, transparent updates about progress, challenges, and solutions. This keeps everyone aligned and prevents costly misunderstandings. Communications consist of Daily Progress Reports (DPRs), emails concerning time-sensitive and schedule-changing decisions,
BEYOND TECHNICAL SKILLS: SAFETY AND FINANCIAL INTEGRITY
SAFETY
CULTURE
Working offshore is inherently risky. Strong safety proto-
cols are not just a requirement—they’re a mindset. The best companies have a deep-rooted safety culture, ensuring that personnel and equipment are protected at all times. Compliance with international health and safety standards is a must.
FINANCIAL INTEGRITY
A reliable company manages budgets efficiently, prevents cost overruns, and ensures financial transparency. This is particularly important in long-term projects where financial mismanagement can derail progress and cause disputes between stakeholders.
ADAPTABILITY AND RESILIENCE
It is a rarity when a submarine cable system is designed, surveyed and installed without delays or unanticipated contingencies, or difficulties with equipment and/or the service vessels. . Additionally, weather disruptions, logistical challenges, and shifting geopolitical factors can impact operations. The best teams are resilient, able to pivot when needed, and find solutions that keep the project moving forward.
THE ROLE OF THE MARINE COORDINATOR IN CLIENT REPRESENTATIVE MANAGEMENT
While identifying and selecting highly qualified client representatives is critical, ensuring they are effectively managed and supported from the home office is also essential. This responsibility often falls to the Marine Coordinator, who plays a vital role in overseeing the performance and well-being of client reps in the field.
THE MARINE COORDINATOR IS RESPONSIBLE FOR:
• Assigning the right representatives to the right projects based on skillset, experience, and geographic requirements. A potential rep who has past experience working with a service provider and possessing a work familiarity with cableships would be optimal for installation operations, while an individual with a background in geophysical and geotechnical investigations would be better suited for marine survey work.
• Providing logistical and technical support to client reps while they are deployed offshore. This includes ensuring that all permissions and visas are in place, opening lines of communication between the client and service providers, planning travel and travel logistics, and providing background and necessary documentation for background knowledge and for reporting during the operation.
• Ensuring clear and consistent communication between field personnel and home office management. The marine coordinator is also copied on all correspondence between
FEATURE
the representative and the client to ensure that there are no surprises and that several people are aware of any issues and prepared to act as necessary.
• Monitoring performance and compliance with project standards and safety regulations. This includes reviewing DPRs and final reports and being familiar with each project’s background information.
• Addressing any concerns or challenges that arise in real-time to prevent operational disruptions.
Strong client rep management from the home office ensures that field operations run smoothly, teams remain engaged and productive, and projects are completed on schedule and within budget.
VISA AND CERTIFICATION REQUIREMENTS FOR FIELD TEAMS
Because these projects span multiple countries and jurisdictions, having the right visas and permits is crucial. Delays in obtaining these documents can push back an entire project or cause a representative to miss an assignment. Here are some of the most important visas and certifications for submarine cable fieldwork:
• Business and Work Visas: B-1, H-1B (USA), Schengen C-Type/D-Type (Europe), Philippines (9c) visa, UK Tier 2 (Skilled Worker Visa)
• Project-Specific and Engineering Visas: Australian TSS (Subclass 482), Canadian TFWP
• Offshore and Marine Work Permits: Seafarer Visa (C1/D, Schengen Maritime, UK Seafarer’s Transit Visa), Seaman’s Book (typically Panamanian, UK or Bermuda).
• Intergovernmental and Special Economic Zone Visas: APEC Business Travel Card, GCC Work Visas, and US Transportation Workers Identification Credential (TWIC).
• Expedited Work Permits for Emerging Markets: African Union, ECOWAS Work Permits, India’s E-Business Visa
WFN STRATEGIES’ CLIENT REPRESENTATIVE DATABASE AND CONTRACTOR CARE PROGRAM
WFN Strategies manages a client representative database of over 150 qualified professionals from more than 25 countries. These representatives bring extensive experience in marine surveying, submarine cable installation, regulatory and/or environmental compliance, and safety protocols. Having access to a broad pool of pre-vetted, highly skilled experts ensures that project owners are engaged with the right personnel for their specific needs, mitigating risks and ensuring compliance with industry best practices.
Beyond recruitment and assignment, WFN Strategies strongly emphasizes contractor care—ensuring that client
representatives receive the support they need before, during, and after their deployments. Through its Contractor Care Program, WFN Strategies provides:
• Pre-deployment guidance, including visa assistance, safety briefings, and technical training.
• 24/7 support while contractors are in the field to address any concerns or emergencies.
• Competitive compensation packages, including timely payments and contract transparency.
• Health and well-being initiatives, ensuring that contractors have access to medical support when needed.
• Career development opportunities, helping client reps enhance their skills and grow within the industry.
By taking a people-first approach, WFN Strategies ensures that client representatives remain engaged, motivated, and equipped to deliver the highest standards of professionalism on every project.
FINAL THOUGHTS: WHY THE RIGHT TEAM MATTERS
In the high-stakes world of submarine cable deployment, hiring the right field team isn’t just a detail—it’s a decision that determines success or failure. The right company and client representative bring technical excellence, regulatory knowledge, and real-world problem-solving skills to the table.
With stringent safety measures, financial responsibility, and familiarity with cutting-edge software, the best teams ensure that projects stay on track, on budget, and meet the highest industry standards. When the stakes are global connectivity, making the right hiring decisions isn’t just important—it’s essential. STF


GLENN HOVERMALE is the Marine Coordinator for WFN Strategies, with more than 20 years of consulting experience in undersea cables, including marine survey, Oil & Gas and offshore wind industries. He has held client representative, offshore project management, and survey positions, and he possesses experience working aboard SubCom, Alcatel, Korea Telecom, and Global Marine cable ships as well as Fugro and EGS survey vessels.
KRISTIAN NIELSEN is based in the main WFN Strategies office in Sterling, Virginia USA. He has more than 17 years’ experience and knowledge in submarine cable systems, including Arctic and offshore Oil & Gas submarine fiber systems. As Chief Revenue Officer, he supports the Projects and Technical Directors, and reviews subcontracts and monitors the prime contractor, suppliers, and is astute with Change Order process and management. He is responsible for contract administration, as well as supports financial monitoring. He possesses Client Representative experience in submarine cable load-out, installation and landing stations, extensive project logistics and engineering support, extensive background in administrative and commercial support and is an expert in due diligence.
Deploying a submarine cable system?
Your success depends on the right team.
At WFN Strategies, we provide access to over 150 highly qualified client representatives across 25+ countries—each pre-vetted, field-proven, and supported by our industry-leading Contractor Care Program.
From technical oversight to compliance management, our experts ensure your project stays on time, on budget, and on course.



BY MIKE CONRADI AND CHRISTIAN KEOGH
LEGAL DUE DILIGENCE ON SUBMARINE CABLES
Due diligence is a crucial element of any M&A deal. The term refers to one of the activities undertaken by a purchaser prior to closing a deal, in order to better understand the business that it is acquiring.
The due diligence process can assist a purchaser in understanding the risks associated with proceeding with a transaction, and can ultimately shape the deal which is being entered into between a purchaser and seller, including in the following ways:
• Due diligence assists in identifying any material risks arising from an acquisition, that, if a purchaser moves forward with the acquisition, would need to be mitigated
through warranty coverage or indemnification.
• Identifying specific actions to be taken before or after completion, such as following any processes that were agreed with customers and suppliers which may be triggered as a result of the transaction occurring (such as obtaining a counterparty’s consent to a change of control in a share sale, or following specific processes for the assignment and novation of contracts in an asset sale).
• Informing the value of the deal.
• Helping the purchaser reconsider if it is in its interests to close the deal.
Due diligence of a submarine cable business is no different to due diligence conducted over any commercial business. However, there are a number of nuances involved in a submarine cable business which will need to be taken into account to ensure that relevant risks are identified and mitigated.
We have prepared this article based on our experience working on submarine cable transactions, and have set out some of the specific issues to be considered by a purchaser of a submarine cable business (which we will refer to as the “Target”), in the following key areas:
• infrastructure assets;
• customer contracts;
• supply contracts;
• permits and licensing; and
• separation issues.
This article looks at legal due diligence, where the focus is on identifying legal risks arising from contractual arrangements, compliance with law, and permits and licensing in place (among other issues). We do not consider technical or commercial issues.
INFRASTRUCTURE ASSETS
The main infrastructure assets of a Target will be the submarine cable system itself (or the systems, if more than one).
A Target’s ability to provide capacity, IRUs over fibre pairs on a system, or other services over the system, requires the Target to have requisite rights over the submarine cable system (or part of that system). It is therefore crucial for a purchaser to conduct due diligence on the submarine cable infrastructure assets that are part of a deal, to ensure that the Target has all necessary rights to the assets and infrastructure which a seller claims.
A Target’s interest in a submarine cable system can take several forms, including legal ownership of a system (which can be sole ownership or joint ownership as part of a consortium arrangement), or a wholesale arrangement where the Target (as a customer) is provided with rights of use to fibre pairs on a system owned by a third party.
Each of these “interests” give rise to different matters for consideration as part of the legal due diligence process, as follows:
SOLE OWNERSHIP
If the Target is the sole owner of a system, all matters relevant to the system will generally be the owner’s responsibility, including procuring the construction of the system via a supply contract, being responsible for landing the cable at relevant landing points (including holding associated permits and licences for the landing of the cable), and arranging maintenance for the system.
Where sole ownership is involved, it will be important that the contracts for each of these arrangements be reviewed in detail.
JOINT OWNERSHIP
A common ownership model for submarine cable systems is via consortium arrangement. Here, several parties co-invest into the joint build of a submarine cable system, and will own a certain number of fibre pairs on the system in proportion to their level of investment into the system.
Some matters to consider for joint ownership models include the following:
Joint Build Agreement (JBA)
Members of a consortium will enter into a JBA (which could also be called a “Construction & Maintenance Agreement” or C&MA), which sets out each party’s obligations to each other, and the processes for appointing a submarine cable supplier and maintenance provider and other key contractors. A JBA should also include a governance process for decision making by the consortium, where decisions are taken by vote.
Typically, a JBA will allocate individual fibre pairs for the exclusive use and ownership of designated parties, with all other assets (like repeaters) being shared between all consortium members. By contrast usually under a C&MA the entire system and all its assets are shared on some agreed basis. However, there is no set rule on this and the only way to understand exactly what assets the Target has will be to read the contract.
It will be important to review the JBA in place, to understand any obligations the Target has to its consortium members (including any need to obtain consortium members’ consent to a change of control of the Target) and any instances where other consortium members can exert power over the cable system without the Target’s approval (e.g. through voting arrangements). It will also be important to identify any clauses that may require the Target to offer capacity to other co-owners before selling such capacity to a third party customer (which tends to be an obligation which applies in the first few years after the Ready for Service (RFS) date of the system).
Supply and maintenance
Usually a JBA will set out how the parties will arrange for, and enter into, a contract for the construction and supply of the system itself, and operations and maintenance arrangements for the system.
It is possible that the Target will not be the party respon-
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sible for such arrangements and will not be a direct counterparty to the relevant contracts for these matters. Notwithstanding this, it will still be crucial that these contracts be reviewed as they will contain matters which impact the asset (such as what warranty obligations apply and whether these can be relied upon directly by the Target).
Landing and permits
It is common for a JBA to establish which parties will take on responsibilities as “landing party” of the cable on behalf of other JBA parties, and will enter into Landing Party Agreements (LPAs) with the other consortium members (however, note that third parties can also be selected as landing parties).
It will be important to identify all landing points where the Target is acting as the landing party, and to verify that permits and licences are held by the Target for the landing of the cable, and to review the obligations on the Target in the LPA itself –matters to confirm will include ensuring the Target receives compensation when acting as Landing party, and matters as to reimbursement of costs the Target may incur on behalf of other consortium members.
Where the Target is not the landing party, these arrangements should be reviewed and to ensure that a party is contractually liable to hold relevant permits for the landing of the cable.
It is increasingly common for LPAs to require “open access” terms. This term should be defined in the LPA but it tends to indicate that the designated landing party must offer access to the landing station for the purposes of providing backhaul to any licensed operator in the country on fair and equal terms, and also must offer cross-connects and rackspace within the landing station on an agreed (often price capped) basis.
IRUS AND LEASE ARRANGEMENTS
need to hold any permits for the cable itself, which will all be the responsibility of the “supplier”.
As a customer, the key contractual arrangement to review would be the agreement with the owner of the system, and to ensure that this arrangement provides for guaranteed access to a fibre pair or to capacity on the system.
CUSTOMER CONTRACTS
Due diligence on customer agreements is focused on checking that there are no risks to the continued revenue pipeline for the Target, and that the size of the Target business reflects what has been represented by the seller as well as ensuring that there are no unusual liabilities. When reviewing these matters, there are a number of nuances to consider for submarine cable businesses, including the following:
THE MAJORITY OF THE TOTAL CONTRACT VALUE UNDER CUSTOMER AGREEMENTS IS PAID UP-FRONT
Due diligence on customer agreements is focused on checking that there are no risks to the continued revenue pipeline for the Target, and that the size of the Target business reflects what has been represented by the seller as well as ensuring that there are no unusual liabilities.
A Target may not own a system; it might instead hold an IRU to fibre pairs or spectrum/capacity on the system of a third party submarine cable owner.
For these arrangements, the Target is usually a wholesale customer. As a customer, it will not be party to any JBAs, supply contracts, landing party agreements, and will not
The majority of revenue made by a submarine cable business is through the sale of “indefeasible rights of use” (IRU) over the cable system (which can include an IRU over whole fibre pairs, or to capacity/spectrum on a fibre pair).
Under an IRU, the majority of the total contract value is usually paid upfront (or in the early stages of the arrangement) as a non-recurring charge. Once the non-recurring charge has been paid, a much smaller recurring charge is payable in respect of operations and maintenance (O&M) and other maintenance services.
When considering the value of the customer arrangements in place in a due diligence exercise, the focus should therefore not be on the “total contract value” as this would inflate the ongoing value of the customer to the Target. Rather, the focus should be on the remaining value payable under the contract as of the date of the due diligence exercise. In addition to this, the inclusion of hair triggers for termination in a customer contract may not matter if the majority of the value of the contract has already been paid upfront. However, it should be checked that there is no requirement for the non-recurring charge to be refunded on
termination of the IRU even some years after the RFS date (although this is uncommon we have seen examples of this).
CONTRACTS CAN INCLUDE MOST FAVOURED CUSTOMER CLAUSES
Customers may negotiate “most favoured customer” (MFC) clauses into their agreements, requiring that they be provided with terms that are at least as favourable as those provided to the Target’s other customers.
It should be confirmed that the Target has complied with any most favoured customer clauses, as any non-compliance may require the Target to provide a retrospective refund to a customer. Depending on the way the clause has been drafted, the potential liability for the Target could be very significant – especially if the MFC obligation extends until some period after the RFS date (wince prices for given amounts of capacity on submarine cable systems tend to fall over time anyway).
CONTRACTS SHOULD BE CHECKED TO SEE IF THERE ARE ANY LIMITATIONS ON THE TARGET’S ABILITY TO
SELL CAPACITY
Other customer-favourable clauses can exist in customer contracts which restrict the Target’s freedom to enter into deals with third parties. This includes clauses where existing customers are permitted to reserve capacity, or where customers are provided with first rights of refusal over any capacity sold on the system.
Where these clauses have been agreed by the Target, it should be considered if these clauses have generally been complied with by the Target. However, it should also be noted that any protracted process may hamper a Target’s ability to run efficiently and to jump on new opportunities.
SUPPLY CONTRACTS
Key matters to understand on the supply side include the extent to which the Target is reliant on third parties for running the business, and how robust its contractual arrangements are with these suppliers.
Some of the key supply agreements for a submarine cable operator will be the turnkey supply contract for the system itself, maintenance arrangements, network operating centre (NOC) services arrangements, and crossing agreements. These agreements will need to be reviewed as relevant (see our comments in the section above on infrastructure assets), and any key risks called out. Below, we provide some views and commentary on some of these agreements and any specific issues to be considered:
SUBMARINE CABLE SUPPLY AGREEMENT
It is common for submarine cable supply agreements
to permit the customer to retain a percentage of the total contract value until the system is “accepted” as RFS. From a purchaser’s perspective, retentions constitute a potential future liability for the Target until they have been paid. It is therefore important to understand whether any “retentions” exist that could be payable by a Target, their value and when they are likely to fall due. Where retentions may need to be paid after closing and completion, a purchaser should consider the deal value and whether any adjustment should be made or indemnification requested.
CROSSING AGREEMENTS
It is common for submarine cables to meet and need to “cross” (i.e. be placed over) other submarine infrastructure (including other submarine cables, as well as oil or gas pipelines). “Crossing agreements” are entered into by the owners of such infrastructure prior to the “crossing” taking place, to deal with matters such as the procedure for the crossing, liability for damage and insurance requirements etc.
These arrangements can often provide for significant liability for damage caused by a crossing party though of course the main risk of damage arising is at the time the crossing itself is made. As such, for a cable system that has already been laid the practical risks of these onerous liability provisions applying may be low. In light of this, requesting all crossing agreements the Target is a party to may not be necessary; instead, it may be better to raise relevant queries with the seller to better understand what risk applies in relation to crossings, and whether such a request would be appropriate.
PERMITS AND LICENCES
As communications networks, submarine cable systems are subject to various licensing and authorisation requirements. This includes the following:
TELECOM LICENCES
As part of the due diligence on a Target, this should include confirming that relevant telecommunications licences are held. It will also be important to check that there are no restrictions or requirements relating to changes of control of the Target. In some cases, a regulator will need to be notified, and approval obtained, prior to a change of control occurring. Where approval is required, this should be factored into the relevant deal agreements.
LANDING PARTIES, AND LANDING PARTY AGREEMENTS
As set out in the section above on due diligence of the infrastructure asset, it should be checked that relevant arrangements are in place for the landing of the cable. Where
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a cable is solely owned by the Target, then it should be checked that the Target has necessary permits and licences in place for the landing of the cable.
Where a cable is co-owned, it should be verified which consortium member (or third party landing party) is responsible for landing the cable and that a landing party agreement has been entered into. Where the Target is the landing party, it should be checked that the Target holds relevant license and permits to land the cable, and the LPA should also be reviewed (see our comments above in relation to landing party agreements and relevant issues).
SEPARATION ISSUES
It is possible that a deal may only involve the divestment or carve out of part of the business or certain submarine cable systems in the seller’s overall portfolio. At times, the divested part of the seller’s business may not be a self-contained unit and may rely on arrangements in place at the broader parent level, or held by another part of the group that will be retained by the seller. There is a need to assess these “separation issues” and address how these issues will be resolved prior to completion.
Some specific questions to ask to help identify any separation issues include the following:
1. Where the deal is structured as a share sale, are agreements held by the right entity? If key agreements are held by an entity that will be retained by the seller, then such agreements will need to be reviewed for any limits on novation/assignment to the divested entity and any processes to be followed in respect of such novation/assignment.
contracting entity. It will be necessary for the other part of the business to enter into its own arrangement with the supplier directly. Where such shared supply arrangements exist, a purchaser should ask the seller for their plans for dealing with such arrangements which should be recorded in the sale contract.
4. Have any parent company guarantees been given by a part of the business that is not being sold? If so, then such guarantees will need to be replaced. Relevant obligations should be included to ensure that this is done before completion.
CONCLUSION
The issues set out in this article are just the tip of the iceberg of issues which we have seen. It is important when conducting due diligence on a submarine cable business that the specific nuances of running a submarine cable business are understood, as failure to understand these nuances may mean specific issues are missed, or even that whole contracts are not reviewed. Similarly, a proper understanding of the specific nature of the submarine cable business means it is possible to avoid focussing unnecessarily on issues which do not matter in this context, even though similar issues might be important for other types of business. STF
Where a cable is co-owned, it should be verified which consortium member (or third party landing party) is responsible for landing the cable and that a landing party agreement has been entered into.
2. Is the Target obliged to provide capacity over systems which are retained by the seller? If so, then the purchaser will not be able to comply with its obligations to a customer unless an arrangement is entered into with the seller to permit this (such as by the seller selling relevant capacity or an IRU to the purchaser).
3. Are there any shared supply agreements? Where there are any shared supply arrangements (i.e where the divested entity is party to a supply agreement that services both the divested and retained businesses, and vice versa) then typically the agreement will stay with the

MIKE CONRADI is Partner of DLA Piper LLP. He is co-chair of the international telecoms practice at global law firm DLA Piper LLP and the lead partner for digital infrastructure. He is rated amongst the leading telecoms lawyers globally by all the various guides and was the editor of the Communications Law Handbook. The legal guide Chambers and Partners says of him that “[he] produces punchy and straightforward answers - he’s direct and commercial, and gets to the point quickly.”
Mike has a particular interest in submarine cable systems - having worked on the legal aspects of more than 100 different cable projects during the course of his 25 year career. He has delivered a legal “masterclass” to every “SubOptic” event since 2004 and was the only private practice lawyer on the SubOptic industry legal standards working group.

CHRISTIAN KEOGH is Senior Associate of DLA Piper’s telecommunications practice. Christian has broad expertise in advising on regulatory and commercial telecommunications projects including in relation to dark fibre, broadband, mobile termination, and sub-sea cables for clients in the Asia-Pacific, Middle East, Africa, Europe, and the UK.

BACK REFLECTION
TESTING AND WORKING THE FIRST THREE ATLANTIC SUBMARINE CABLES
BY PHILIP PILGRIM
INTRODUCTION
In our last article, we covered the basics (test instruments, units (lack of), and test methods) for testing submarine cables in the early 1850’s. This article continues through the late 1850’s (the first Atlantic Cable of 1858), and into the 1860’s; 2nd 1866 Atlantic Cable, and 3rd 1865 Atlantic Cable (revived in 1866). During this period, submarine cable test instruments improved significantly: 1.) Thomson increased the sensitivity of the mirror galvanometer, and 2.) a differential galvanometer exploited “current nulling” (in contrast to the Wheatstone Bridge that exploited “voltage nulling”. Test methods also improved, as well as cable manufacturing and cable laying. In this nearly 10-year period, constant development and innovation improved the submarine cable’s construction and functioning. Transmission architectures also evolved to allow for cable testing and cable communications to be conducted simultaneously during the lay. In a way, this was an early form of multiplexing where two signals operated over the same media. These two actions were also synchronized to allocated time periods, so this was perhaps the first T.D.M. (time domain multiplexing) application. Another exciting find, when researching this article, was that testing automation was developed in
1853. Mechanical “wind-up” machines did the tasks of test engineers! With this new knowledge, the name of the father of automated telecom testing is Frederick Charles Webb. Details of his apparatus are explained in an excerpt from a January 1867 magazine that is provided later in this article.
Another subsea find, from early submarine testing, is directly linked to Einstein’s 1921 Noble Prize. This is due to a chap named Willoughby Smith. He was developing standard resistors for cable testing/simulating and was experimenting with different resistive materials. When experimenting with selenium as a resistor, he discovered the resistance changed when the selenium was exposed to light. This variance was not good as a reference resistor, but he published his unique findings that opened a new path of investigation for scientists. Einstein later went on to explore this effect and found that it was the minimum frequency of the light, not the quantity/intensity of light alone that caused the selenium to release electron’s (causing a change in resistance for Smith). This became known as the Photoelectric Effect and the quantum physics terms Photon and Quanta are derived from it. The development of submarine cables has influenced so much in modern science!
The great minds at the time also
did battle with two bug bears of transoceanic submarine cable communications: Earth Currents and Transmission Impairment due to cable capacitance. Here is an overview of these two challenges:
EARTH CURRENTS
Earth currents are unwanted signals that travel on submarine cables (See STF #136 May 2024). They are carried along submarine cables because the submarine cable’s transmission equipment is grounded at each end of the cable. The architecture of the network assumes that the ground voltage/potential at each end of the cable is the same at 0 Volts. However, due to tides, cosmic radiation, weather, solar activity, the ground voltages at each end of the cable can rise or fall. This causes unwanted current to flow through the cable.
To counter earth currents, two approaches were used:
1. ISOLATE THE CABLE FROM GROUND THROUGH THE USE OF A CONDENSER (CAPACITOR).
The capacitor prevented the grounds at each end of the cable from being in direct contact (isolated). Earth currents are a “direct current” (DC) and require the copper conductor path to travel through. The condenser broke the direct connection. The traffic signals would pass as they were alternating
positive and negative pulses. Perhaps this form of signaling was also the crudest form of an alternating current (AC), as it would induce alternating charges on the plates of the capacitor. A sensitive mirror galvanometer could detect these faint voltage changes. In modern electronics, we would call this submarine transmission architecture “the use of decoupling capacitors” or “an AC coupled circuit” or “a DC filter” or perhaps “a ground lift”.
Although capacitors were around for several decades before submarine cables, their exploitation to eliminate earth currents was not invented in time for the 1858 Atlantic Cable. It was used on the 1866 cable during testing, lay, and early operations. Details will be explained later including long lost drawings of the actual 1866 transmission circuits. [Fig. 20].
2. BALANCED TRANSMISSION LINE.
To save resources and costs, submarine cables required only a single copper conductor, and the return path was through earth (thanks to Carl August von Steinheil). In 1866, there were two Atlantic cables landing at the same locations in Newfoundland and Ireland. The engineers decided to experiment, They used one cable for transmission and the other for return. This eliminated the earth return path, so it also eliminated earth currents. The engineers found the performance to be so improved that they continued to use the two cables as a single transmission system, rather than using them as two separate transmission systems. With the highly sensitive mirror galvanometer as the receiver, an engineer (La-
timer Clark) conducted a hero experiment, in September of 1866, where he made a chemical battery using a silver thimble [Fig. 1] filled with acid and a small piece of zinc. He connected this to the balanced line of two Atlantic cables and could signal with it.


TRANSMISSION IMPAIRMENT (CABLE CAPACITANCE)
The Atlantic Cable engineers knew of the transmission impairment affecting submarine telegraph cables well before the 1858 Atlantic Cable was laid. They observed it in earlier submarine cables and also in subterranean cables (when compared to pole lines). This capacitance problem was a commercial, as well as a scientific problem. The impairment greatly reduced the telegraphic data rate (words per minute). Revenue was based on number of words per minute, so capacitance hurt the company’s bottom line and potential sale of Atlantic Cable shares. Since these early cables were backed by public investment, the cable directors were careful not to disclose the magnitude of this major problem. Great mathematicians, physicists, and engineers of the time tackled the prob-
lem. In fact, James Clerk Maxwell’s foundational electromagnetic equations stem directly from work on this problem with William Thomson (Lord Kelvin). Likewise, transmission theory and transmission devices were also developed to understand and minimize the capacitance problem.
With pole line transmission, the suspended iron wire is surrounded by air. When a telegraph message was sent from one end of the line, it arrived almost instantaneously at the other end. It arrived lower in power due to the line resistance, but the onoff transitions of the voltage were crisp and nearly instant.
With submarine cable transmission, the copper wire is surrounded by a gutta percha insulator and by highly polarized sea water. When a telegraph message is sent from one end of the cable, it arrives almost instantaneously at the other end, but the arrival edge is not defined crisply. It takes time for the signal to reach maximum strength as each pulse it is effectively smeared over time. This is due to the ionized seawater opposing the signal as it travelled along the cable. The cable, insulator, and seawater effectively made the world’s largest cylindrical capacitor. To send a signal, one had to effectively charge and discharge the cable (capacitor). We now know that the time to charge and discharge the cable was related to the resistance and capacitance of the cable. This is the so-called RC time constant. Thomson and Maxwell had discovered the cause and developed the theory & mathematical expression by 1866, but the applied problem still existed. Thomson
Fig. 1 The Latimer Clark “Atlantic Cable” Thimble (Original on left)
BACK REFLECTION
reasoned that it would take too long to charge and discharge the cable to the high voltages used in terrestrial telegraph systems. He knew that by only “charging enough” for the signal to be sensed at the far end was the only way to achieve the maximum data rate. His work in this area also resulted in the copper core of the 1866 cable being larger in diameter to reduce the cable capacitance and resistance.
A plot made by Thomson [Fig. 2] shows the far end voltage rise when a voltage is applied to one end of the cable (curve I). He also showed that when a voltage is applied for short period (α) but increasingly longer periods of time (1α to 7α), the voltage at the far end follows curve I. He also showed that a short pulse, at a much higher applied voltage (II), has a slightly faster rise time. This validated his hypostasis that the data rate was limited by the cable’s RC constant. It also showed that high voltages did not change the speed of transmission. In fact, it was slower to charge and discharge the cable to higher voltages. This lead Thompson to apply the sensitive galvanometer test instrument as the receiver. In turn, it lead him to improve the receiver’s sensitivity for operating at lower voltages. Thomson exploited the use of a mirror and



projected light to amplify the swing of the galvanometer. In a sense, an “optical amplifier” of sorts. [Fig. 12 & 21]
GALVANOMETER TYPES
Here are a few of the many of the galvanometers used in the early days of
submarine telegraph. These instruments continued to be used on submarine cables well into the 1950’s. Note, there are many more variants not mentioned in this article. Some, such as moving coil designs, were invented after 1867. The first galvanometer was simply a
Fig. 2 Thomson’s RX plots of Received Pulse
Fig.3 Ørsted’s Compass (Replica)
Fig.4 Ørsted’s Laboratory Galvanometer
compass. Shown [Fig. 3] is a replica of the one used by Hans Christian Ørsted when he discovered that current in a wire produced a magnetic field that moved a compass needle in 1820.
Figure 4 is Ørsted’s lab instrument based on the same principal:
The tangent galvanometer [Fig. 5 & 6] placed the compass in the center of a coil of wire to increase the sensitivity.
A vertical galvanometer [Fig. 7] was used for convenience of visual orientation. It also used a coil of wire to increase the strength of the magnetic field thus making it more sensitive. Wall-mounted variations were also manufactured.
An astatic galvanometer [Fig. 8] used a coil to increase sensitivity, but it also used two compass needles in opposition [Fig. 9] to remove the earth’s magnetic field from the measurement. The coil affected only one of the compass needles.
A differential galvanometer [Fig. 10] is basically a very sensitive comparator of currents in two adjacent coils. When the currents are the same, the magnetic field between the coils is 0. This current comparator technique was used in subsea fault finding just as the Wheatstone Bridge’s voltage comparator technique was used. Once resistor standards were developed, an engineer could run batteries through the cable connected one side of the differential galvanometer. The engineer would then run the same batteries though resistors and through the other


side of the differential galvanometer. Once they adjusted the resistors to null the magnetic field, the resistance of the resistor standards would exactly match the resistance to the cable fault [Fig. 11].
The mirror galvanometer [Fig. 12] was developed in 1826 by Johann Christian Poggendorff . It is similar to

the early tangent and vertical galvanometers as it uses a coil to increase current sensitivity, however, instead of a compass needle deflecting, it uses a small, suspended magnet that deflects in the coil’s field. The suspended magnet has a small mirror attached. A beam of light from a candle source is reflected by the mirror onto a graduated target. As the mirror/magnet rotates in proportion to the electrical current in the coil, the light moves across the target’s graduations. This galvanometer was used in the development and testing of the first Atlantic Cable project (1857 to 1858). William Thomson, was supporting the transmission aspects of the project, and had also presented a mathematical paper, in 1855, showing the capacitive “retardation” of submarine cables, When preparing for the first Atlantic Cable, he quickly observed (during the two unsuccessful lay attempts in 1857 and 1858 as well
Fig. 5 Tangent Galvanometer (Coil of Single Turn)
Fig. 7 Vertical Galvanometer
Fig. 6 Tangent Galvanometer (Coil of Many Turns)
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Fig. 9 Astatic Galvanometer’s Opposed Needles
Fig. 12 Mirror Galvanometer
Fig. 11 Differential Galvanometer and Fault Finding
Fig. 8 Astatic Galvanometer
Fig. 10 Differential Galvanometer

as on the test lay in the Bay of Biscay) that the output of the cable would be a feeble signal. He also knew that trying to increase the transmitted signaling power will add long delays to messaging. Thomson’s solution was to refine the mirror galvanometer test instrument to become the receiver in place of a magnetic sounder or magnetic ink recorder (that required high current power to activate a solenoid). Thomson’s instrument could measure the far end signal in the order of millionths of an amp. Trivia: this same arrangement is used in modern day phono cartridges in record players to “pickup” and transform weak kinetic energy from record grooves. Both moving magnet and moving coil designs are used in record players and galvanometers.
The following article is from an unnamed author. It was published in the January and February issues of The English Mechanic and Mirror of Science and Art. It describes submarine cable testing methods and instruments used up to 1867.

however, it has received greater attention, and the improvements in that particular department have been great and rapid. And at the present time there are no operations concerned in the manufacture of cable that are more carefully attended to than those connected with the electrical department.
In the earliest cables laid, the testing
Of all operations in connection with submarine cables, there is not one that has a greater bearing upon the ultimate success of the cable itself than the operation of testing. In a great measure, testing a cable was formerly looked upon as simply an unavoidably necessary operation, and for a long time but little attention was given to that department. For some time back,

during submersion was simple enough and, in paying-out the Hague Cable in May, 1853 (the greatest in length manufactured up to that time), the cable was tested for earth from the ship with a power of 288 cells on vertical galvanometer every quarter of an hour. In order to prove that the continuity of the wire was good, signals were exchanged with the shore every three minutes. Galvanometers at that period were not very sensitive, so more battery power was used. It will be noticed that since then, the delicacy of the instrument has increased, so the number of battery cells used has decreased. We believe that testing for conductivity and for the resistance of the conductor was first tried during the manufacture of the Hague Cables, the object being to enable the electricians to measure the resistance of the wire so that on the occurrence of fault, the distance might be localized.
Mr. F. C. Webb, [Fig. 13] who had the supervision of the cables, took these tests for resistance at every additional ten miles of cables [Fig. 14], and from the tests taken was enabled
Fig. 13 Mr. Frederick Charles Webb: “Inventor of Automated Cable Testing”
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to compile a table, giving the mean of the resistances, so that he succeeded when a fault occurred in calculating the distance with great success.
The plan adopted was simply determining the deflection of the galvanometer on short circuit with one pair of plates, the deflection through the resistance of the cable would then be measured and noted. Until the introduction of resistance coils, an electrician had nothing to depend upon for measuring the distance of a fault beyond his previous notes of tests, unless indeed he were fortunate enough to obtain a comparison by being able to test a short length of similar conduction. The introduction of resistance coils and the differential galvanometer simplified the matter considerably, and an electrician in testing for conductivity had then always his means of comparing the resistance obtained with the standard resistance close at hand.
During the submersion of a cable, it had invariably been the custom for the testing to be carried out from the ship, an operator being placed on shore with proper instructions for insulating the end of the cable and for sending signals. The lightness of the Hague Cables rendering them liable to damage, and repairs being frequently necessary, and to do away with the expense of an operator at each end.
Mr. Webb devised clock arrangement, attached one at each end of the cable, for doing what was usually required of the operator: for ten minutes the end was insulated, and for five minutes a current from small battery sent. This

idea found to work admirably and was used for many years afterwards. It was only necessary to wind it up once a

week, and was found to be superior to a clerk during repairing operations, the nature of which depending so much upon the weather prevented one from forming an idea as to when they might be wanted. Clerks may get tired of watching day after day, and night after night, but the clock was always faithful at its post. The use of these clocks was continued for some years afterwards by Mr. George Edward Preece, who introduced a third office, putting the cable to earth so that a test for continuity might be obtained.
From that time (1853) testing continued to improve, owing to the greater delicacy of the galvanometer, the use of more perfect resistance coils, of the differential galvanometer, and of Wheatstone’s bridge or parallelogram. The introduction of resistance coils was of great advantage to electricians
Fig. 14 1853 Factory Cable Measurements: Galvanometer deflection in degrees every 10 nautical miles.
Fig. 15 Mr. Willoughby Smith: First Multiplexing Signals & Photoelectric Effect
in expressing the result of testing for insulation and conduction. Up to that time it was usual to express the insulation (amount of leakage) of a cable to be x degrees, with a certain B battery power on a galvanometer, giving y0 with one cell. This rendered comparison very difficult. When resistance coils came into use that amount of leakage could be expressed in “units” of resistance of the cable itself, and a standard of comparison readily introduced. The ordinary method at that time of working out the “leakage”, or, as it may more properly be termed, the “resistance of the insulation or dielectric”, --- was to measure the leakage by noting the deflection on galvanometer with a large battery power, then with one cell to see what resistance would bring the galvanometer to the same deflection, then that resistance multiplied by the number of cells first used, and by the length of the cable, would give the “resistance of insulation per mile.” The use of Wheatstone’s bridge enabled that result be obtained easier and with greater accuracy.
When resistance coils were first used, they were made to represent one particular sized conductor, and the conductor varied confusion soon ensued. We had resistance coils representing various standards, and it caused some trouble to find out the ratio between any two units. This confusion fortunately has not lasted long. A Committee on Resistance of Electrical Standards was appointed by the British Association, the results of whose Iabours have been the publish-



Fig. 16 “Plan No 1” Insulation Resistance Test During Lay (Shore-End Open)
Fig. 17 “Plan No 2” Smith’s Insulation Resistance Test During Lay (Shore-End High Resistance)
Fig. 18 “Plan No 3” Varley’s Insulation Resistance Test During Lay (Shore-End High Resistance & Key & Capacitor)
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ing of valuable reports and tables, and the recommendation of one standard unit to be called the B.A. unit, or “British Absolute” unit. This unit now been generally adopted, and the result is that whatever cable is tested, the results are now expressed in one common term and comparison is thus rendered easy.
But during all this time that the instruments used in testing have been undergoing many, and great improvements, the system of testing itself, down to the period of laying the Atlantic Cable of 1866, has undergone little or no change. The testing has been carried on from the ship. The operator has been placed on shore to insulate the end, or to send currents for continuity tests. Such has been the practice, with but little variations. One of the earliest descriptions of testing— certainly one of the best—is given by Mr. Preece in his paper on “Submarine Cables” before the Institution of Civil Engineers in 1860.
Still the same plan carried out in paying out the Atlantic Cable in 1865. Insulation tests were taken during the first thirty minutes. The next thirty minutes were divided into three equal parts, which were employed in receiving reversals from the shore—testing the conductivity of the copper, and sending reversals to the shore, and so on hour after hour. Special arrangements were made in case it was necessary to speak from the ship to the shore, and vice versa.
Mr. Willoughby Smith [Fig. 15], who for many years devoted his attention entirely to testing insulators for

submarine cables brought forward a plan for testing cables during submersion that revolutionized the old system, and was at once brought into use in paying out the 1866 cables. The difficulty of obtaining quick and easy communications with the shore end had always been one of the drawbacks in connection with the old plan of testing. On the occurrence of a “fault” it was desirable to be able, at once, to speak to the shore that tests might be taken, so that the fault could be localized. In addition to this, by the particular system adopted, many minutes might pass before an insulation test could be again taken. All this time the cable would be paying out, and the ship getting farther and farther away from the fault ; it has even been contended that it would be better to
pay out a cable with the shore end insulated, so that a constant insulation test might be kept up, rather than proceed on the old plan. It will be noticed that in paying out the Atlantic Cable the electricians were every other thirty minutes without an insulation test. It will thus be seen in what difficult position the electricians would be placed in the event of a fault going overboard.
To rescue them from this dilemma Mr. Smith brought forward a plan whereby a constant insulation test is simultaneously kept up between ship and shore, and speaking signals can be at any time, and without disturbing the insulation test, freely exchanged.
The accompanying sketch will show the ordinary insulation test [Fig. 16]. The end of the cable on shore is insulated (open). The cable on board is connected with galvanometer G, to the other terminal of which is attached a powerful battery, one pole being to earth, the deflection on G representing, of course, the loss on the cable.
As in the above Plan No 1 [Fig. 16], Mr. Smith connects a battery of large tension on board ship through a galvanometer to the cable, but instead of insulating the end on shore the cable is connected with a large resistance R (see Plan No 2) [Fig. 17] through a very delicate galvanometer G’ to earth.
The resistance R is equal to several knots (nautical miles of cable) of insulation resistance. The battery B, being permanent connection with the cable, will show on G the deflection due to the leakage through the gutta percha, but nearly the full tension of the battery will be exerted
Fig. 19 Mr. Cromwell Fleetwood Varley
on R, causing a weak current to pass through the resistance, and showing a slight deflection on G’. The deflection on G will be increased by this slight current. The deflection on G is therefore due to the leakage of the cable, and the small amount passing to earth through the resistance whilst the deflection on G’ is due only to the small amount that goes to earth. A fault occurring in the cable would be instantly observed at both ends, on board ship, by the increased deflection, and on shore by decreased deflection owing to the tension of the battery being reduced. It will thus be seen how perfect a simultaneous system of testing between ship and shore can be kept up during submersion of the cable. By altering the tension of the battery B on board ship by means of key K, the deflection of G’ on shore may be increased or decreased to such an extent to represent signals, so that letters and words may be conveyed. This plan of speaking from the ship was excessively simple, and consisted only of an arrangement for slightly altering the tension of the battery ; but to enable the shore to speak to the ship the following was the contemplated plan: --- Between the resistance R and the cable was placed key, K’, which on being depressed would connect the cable through resistance R’ (less than R) to earth, the result being that the galvanometer G would show a slightly increased deflection for so long a period as K’ remained depressed. By the duration of these signals, long or short, could shore speak to ship. Such was the plan brought forward by

Mr. Smith, and, with one alteration adopted, and carried out in paying out the cables of 1866 across the Atlantic. Such a system has long been required, and now it has been in use one cannot but wonder how we could have managed so well before.
It will be observed that in the arrangement for sending signals from the shore to the ship, attention is called on G by an increased deflection—this has the disadvantage of appearing as an increased deflection, due to leakage. That particular part of the arrangement was not adopted in the expedition of 1866, but a suggestion of Mr. Cromwell Fleetwood Varley’s [Fig. 19] was carried out, of which Sir William Thomson observes. “ A peculiarly ingenious application of the condenser was added by Mr. Varley, which allowed telegraphic word-signaling to be carried on through the cable during its laying, with a degree of care and rapidity which far exceeded our expectations, and not only proved very useful for the work, but very pleasing to those engaged in it.” Instead of the resistance R’ was insert-
ed (Plan No. 3) [Fig. 18], a condenser, one series of plates being connected to the cable through S, whilst the other was connected to a double key, K’, to a battery of small tension.
A “ condenser “ is a peculiar arrangement, in a small compass, of a Leyden jar of an enormous capacity. It consisted of sheets of tinfoil between sheets of paraffine, and represented an inductive capacity equal to about 30 miles of the Atlantic Cable. On shore signaling to ship a depression of K’ would charge the condenser C + or - , according to the finger depressed. The permanent tension of the cable would consequently be increased, or decreased, according as the induced charge from C was +, or -. The deflection on G would show corresponding signs. This plan is, therefore, exceedingly simple. The condenser receives a + charge; an equal charge of an opposite nature at once enters the cable, causing an increased or decreased deflection on G, according to the nature of the permanent charge of the cable. In order that the deflection on G should not be increased, so as to
Fig. 20 “Plan No 4” Initial Electrical Operating Configuration of 1866 and 1865 Atlantic Cables
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give the appearance of a “fault”, it was arranged that the Initial, or call signal, should be of the nature to decrease the deflection, so that if the permanent tension of the cable were +, or positive, the condenser should be similarly charged, that the induced charge might be - or negative, so causing a decrease in tension.
The system of testing thus used on board the Great Eastern consisted, therefore, in a simultaneous insulation test between ship and shore, by means of permanent current from the ship, passing through a great resistance to earth at the shore end; the amount of the leakage of the cable being shown on board the ship on a Thomson’s marine galvanometer, whilst the galvanometer used on shore, being one of Thomson’s reflecting galvanometers of greater sensitivity, showed a slight deflection, due to the weak current passing to earth through the resistance. Signals were exchanged and messages transmitted by altering the tension of the battery. A system more beautiful, and yet so simple, can hardly be devised, and we fairly expect it to be generally adopted in future. The chances of detecting a fault are greatly increased, and any fault occurring

would be at once noted. In completing the 1865 cable a fault occurred near Newfoundland; its presence was immediately detected, and when the cable was cut, the fault was found on board, the stoppage of the ship immediately after the detection of the fault preventing the fault from being payed overboard. Such a fact, and the ease and rapidity with which messages were conveyed to and from the ship, speak volumes in favour of Mr. Willoughby Smith’s system of testing.
In connection with the foregoing arrangement there was also used on board the Great Eastern a peculiar plan for testing the potential of the line, by the use of Thomson’s electrometer, a matter which at present we cannot go into.
We believe that the suggestions for
using the condenser in the particular way described, and the plan of working actually adopted, were sent in by Mr. Varley before the sailing of the expedition.
The plan No 4 [Fig. 20] of working the cable for ordinary traffic was, in some measure, rather similar to the plan used during the paying out of the cable; but as several accounts have already appeared in our scientific press, giving a somewhat erroneous view of the manner of working, we have much pleasure in bringing the matter forward, and endeavouring, by the aid of the accompanying diagram (Plan No 4) [Fig. 20], to render this simple and easy method plain to our readers.
At Valentia and Newfoundland are fixed G’ and G, two galvanometers, to earth, connected to the cable through
Fig. 21 Thomson’s Mirror Galvanometer

switches, S’ and S; in connection with these switches are two double-fingered keys, K’ and K, commonly known as Bavarian keys.
One finger is connected to the switch, the other to earth, the bridge is connected to one pole of the battery, whilst the other pole is on to the lower contact under the fingers.
The end of the cable at Valentia is connected to a condenser, C, equal in inductive capacity to about 85 miles of the Atlantic Cable, the opposite plates of the condenser being connected to the switch. Having now explained the various connections, we will proceed to show the manner of working. The cable, in its normal position, will be connected at Newfoundland through
the switch, S’, to galvanometer to earth, at Valentia to the condenser, C, the opposite plates being to switch, S, to galvanometer through to earth. Such position, then, will represent the connections at each end when prepared for receiving signals. When Valentia requires to signal, by means of S, the sending key, K, is put in communication with C, whilst G is thrown out of circuit. On depressing the left hand key, the + , or positive pole of the battery, is put in communication with the condenser, the negative, or - pole, being put to earth through bridge, consequently immediately the key is depressed the condenser is charged positively (the Leyden jar arrangement coming into effect).
The cable therefore being in connection with the opposite series of plates is inductively charged with negative electricity, and the galvanometer, G’. at Newfoundland is deflected. So, when the other key is depressed, the poles of the battery are reversed, and the condenser is charged negative. Consequently, the cable has an induced charge of positive electricity, and the galvanometer is deflected to the opposite side. Therefore, according as one key or the other is depressed at Valentia, so is the galvanometer deflected at Newfoundland. For receiving at Valentia the sending apparatus is cut out, and the condenser, C, is placed in direct communication with the earth through G. Newfoundland,
Fig. 22 Later Electrical Operating Configuration of 1866 and 1865 Atlantic Cables (Isolated: No Ground/Earth)
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before sending, throws in his sending apparatus (cutting out G’; on depressing the key the cable and condenser are charged + or - according to the key depressed, the opposite plates of C being charged with electricity of an opposite nature, discharge themselves through G to earth, causing a momentary deflection to the right or left.
It will thus be seen how a condenser at one end only, answers the requirements of sending at both ends, causing signals to be read off with ease and rapidity. The deflections being left and right, similar to the ordinary single needle, the alphabet used being the same. The battery power is small, requiring but few cells to charge a condenser equal to so great a capacity 85 miles of cable. Statements as to speed vary considerably, but we believe that the usual speed in messages is
about eight words per minute, whilst in ordinary conversation the speed has been known to exceed fifteen words. Thomson’s reflecting galvanometers are used for reading off the messages; these are of less delicacy than those usually employed for testing.
It was much feared that earth currents would be found a great annoyance in working the cable, but they have not interfered in any way; this is a result that could only be expected from the present plan of working, inasmuch as one end of the cable is constantly insulated, it being necessary that both ends should be to earth, otherwise no circuit would be established for these earth currents.
We trust we have made this beautiful system of telegraphing sufficiently comprehensive to our non-electric readers; to those thoroughly acquaint-
ed with the subject we feel that the diagram alone would sufficiently explain the whole system. A description of the above has been rendered very essential, for after the slow speed we have hitherto obtained on long submarine lines, the discussions that have taken place on induction and retardation, it becomes a matter of great surprise and interest how a speed was obtained on a long submarine cable, greater than could be obtained on a similar length of land line.
As we have so frequently referred to Thomson’s reflecting galvanometer, we give the following explanation, as many of our renders may not be aware of the peculiarity of their construction [Fig. 21].
The reflecting galvanometer of Sir William Thomson, invented eight years ago (1858), which we have men-
Fig. 23 Heart’s Content Transmission Room 1866 Atlantic Cable
tioned, is thus described by himself: - “ It consists of a very light mirror, with a magnet cemented to its back, suspended by a single fibre of unspun silk, in the hollow core of a bobbin wound round with fine silk-covered copper wire. The adjuncts for its use consist simply of a lamp and a proper screen (a scale printed on white paper) to receive an image of the flame reflected from the mirror. The mirror may be slightly concave; or if the mirror is plane, a convex lens in front of it, through which the light passes and, repasses, produces the same effect.” The mirror is little more than one-third of an inch in diameter and weighs onethird of a grain (22mg). The attached magnet is of the same weight as the mirror ; so that whole suspended moving mass less than three-quarters of a grain. A powerful steel magnet fixed outside the coil causes the suspended magnet to return with extreme rapidity to its middle or undeflected position, when the deflecting force ceases.
The marine galvanometer, or that usually employed on board ship, differs from the above in having the magnet and mirror (which together weigh about 1-1/2 grains) strung on a vertical bundle of stretched silk fibres passing through the centre of gravity of the magnet mirror, and secured both at top and bottom to a thin brass ring, and on either side of this ring, and closely surrounding the magnet, are placed the coils of fine wire. In this instrument a powerful magnet is also used outside the frame which neutralizes the effect of the earth’s magnetism. At sea this is the most valuable instrument of the kind that has ever been used: its sensitiveness is
unequalled, and in spite of the motion of a vessel, the alteration of the ship’s course, observations be made with the greatest ease and delicacy.
The system of working which we have described above [Fig. 20] adopted immediately after the successful completion of the cables, and was continued in operation for some time, but owing to some difficulties in connection with patent rights and the traffic not being sufficiently great to entirely occupy more than one cable, this plan of working with condensers lately been given up, and the cables are now (Jan. 1867) worked in one long metallic circuit without the intervention of the earth [Fig. 22]. The circuit is arranged an ordinary telegraphic circuit, but instead of using the earth as the “return”, the second cable is used as return wire ; thus, making the whole a long metallic circuit of nearly 5.000 miles in length.
We have mentioned that the disturbing effect of earth currents was avoided in the condenser arrangement in consequence of one end only of the cable being in connection with the earth. It will be seen also that they cannot exercise any disturbing influence under the present plan, as neither end is connected with the earth. Upon these “earth currents”, and their peculiar disturbing influence as to land and submarine lines, we trust before long to place some information before our readers.
guess) are:
• solid base for the mirror galvanometer (bolted to floor)
• light source: oil lamp with shield and window
• target screen with shield
• an observer of the received signal: Mr. Black
• a recorder of the received message: Mr. Brown
• submarine transmit telegraph key: right of Mr. Brown
• a NYC backhaul transmitter: Mr. Green
• backhaul transmit telegraph key: Mr. Green’s right hand
• backhaul sounder and switch: near Mr. Green’s left hand
• fireplace (the station temperature was carefully maintained within a few degrees by assigned workers)
This article concludes our look into the past methods for testing and fault finding in the early days of submarine cables. The next issue (May 2025) will reference these and provide guidance on electrical testing of modern-day submarine cables. The materials will come from work I have done since 1991.... so, my reference to “modern” is indeed a “back reflection”.... oh dear.... time flies. STF

Figure 23 is a drawing of the transmission room of the 1866 Atlantic Cable. It was made by an operator at the Hearts’ Content cable station long after 1866. Interesting details (best
PHILIP PILGRIM is the Subsea Business Development Leader for Nokia's North American Region. 2021 marks his is 30th year working in the subse a sector. His hobbies include "Subsea Archaeology" and locating the long lost subsea cable and telegraph routes (and infrastructure). Philip is based in Nova Scotia, Canada.
LEGAL & REGULATORY MATTERS
FIVE THINGS YOU NEED TO KNOW ABOUT MARINE MAINTENANCE AGREEMENTS
BY ANDRÉS FÍGOLI
When it comes to submarine cables, marine maintenance contracts are critical to ensuring the reliability and longevity of these vital communications links. Their importance becomes apparent when a cable fails, and the cable-laying vessel must be mobilised in a race against time.
Here are five important things to know about them:
1.
MENTION THEM IN THE CONSORTIUM AGREEMENTS
Usually in a Construction and Maintenance Agreement (C&MA) or in a Joint Build Agreement (JBA) for a cable consortium there is a provision that obliges the members to cooperate and act together to sign a marine maintenance agreement. This could be on a shared liability basis so that each member receives an invoice from the maintenance provider based on its pro rata share or the number of its respective fibre pairs. By doing so, the consortium members can agree to replicate the same liability scheme for this additional maintenance service agreement, thus facilitating negotiations with whichever provider is chosen for the maintenance.
On the other hand, there should be other maintenance agreements related to the terrestrial segment of a cable system, which is a different market with specialized local providers.
2.
REVIEW THE SCOPE OF ANY CABLE SECURITY FLEET OR SIMILAR PROGRAMME.
In 2022, the United States im-
plemented the Cable Security Fleet initiative, under which two U.S.flagged, U.S.-crewed commercial cable ships are available for any cable repair in time of war or national emergency. It guarantees their availability on 24 hours’ notice. Other governments may have similar programmes. During 2024 India conducted analysis with a view to having its own fleet, and the French state acquired Alcatel Submarine Networks.
the requirements for carrying out the maintenance work itself, then it is time to activate the termination procedure referred to above.
3. LIST OF MARINE OPERATION PERMITS
These permits, authorizations, consents or licences relate to what is required to perform the maintenance services in connection with the operation of the cable ship and they include
The cable maintenance service contracts usually contain provisions regarding the unavailability, major breakdown, total loss or absence of the cable ships, giving the provider the option of proposing an alternative cable ship.
So what would happen if such a cable-laying vessel was mobilized while en route to a maintenance event with a private company? Surely it would be diverted to attend to this government priority. Therefore, it is advisable to ask this question during the contract negotiations and to include a specific provision, thus avoiding surprises, even if the probability of their occurrence is low.
The cable maintenance service contracts usually contain provisions regarding the unavailability, major breakdown, total loss or absence of the cable ships, giving the provider the option of proposing an alternative cable ship. However, if none is available, or if the alternative vessel does not meet
a wide range of issues such as those needed to enter jurisdictional waters for the vessel and crew authorizations/ visas.
Typically, the maintenance service provider is responsible, at its own expense, for obtaining and maintaining such permits as may be required by any governmental authority with respect to a cable ship and its employees, agents and subcontractors.
It is common for the local representatives of the cable owners to cooperate with these authorities, as there are usually documentation requirements regarding the specifications and ownership of the submarine cable that the local authorities need to know. This ensures an expeditious or cost-effective
process for obtaining permits before the cable ship reaches Mile 201.
It is advisable to require the maintenance service provider to prepare a complete list of the marine operating licences required under each applicable law that it needs in order to provide its services in each jurisdiction. And such a list should be updated on a regular basis so that no time is lost during a vessel mobilisation.
Also, when conducting cable awareness campaigns, this is one of the issues that the cable owner should also check with all local authorities on the ground. Otherwise, they would be relying too heavily on a service provider who may not be familiar with local customs and practices and may be obtaining information from outdated official websites.
4. ALLOW CABLE OWNER REPRESENTATIVES ON BOARD
It is advisable to establish a right for the cable owner to send at least two representatives on board so they can observe the repair operation and immediately answer any questions regarding cable system specifications and configuration. They will play an important role in favour of the carrier’s interests by detecting any problems or delays during the subsea operations and by recording and reporting on the progress of an operation at sea.
In recent years, the number of volunteers has decreased due to international regulations that require each of these observers to take safety courses before boarding the cable-laying vessel. However, it is fair to say that this non-bureaucratic activity should be encouraged as it is truly an in-situ
learning experience about the submarine cable industry.
To facilitate proper work and communication with the cable owners’ headquarters, it is recommended that clear provisions be included in the agreement regarding the need to provide adequate accommodation of a standard not inferior to that provided to officers on board, as well as high-speed Internet access at no additional cost.
In addition, the cable owner should have the right to invite a naval officer from the local navy when investigating the cable failure in its jurisdictional waters. He would prepare a report on the operations to recover the damaged cable and cooperate in preserving its chain of custody as evidence to be presented in the national courts. Accordingly, the representative of the cable owner may also request from the maintenance provider any documentation such as statements, photographs, videos about the damaged cable.
5. WARRANTY
The marine maintenance provider should warrant that the services and all materials provided will be free from defects for a period of at least one year after installation. It is also advisable to include a specific condition stating that if the service provider fails to remedy a defect, deficiency or failure, the cable owner may make the repairs itself or have them made by others at the service provider’s expense.
There is an important reason for this requirement. Some regulatory bodies impose obligations to mobilise a cable ship within a certain time, and
it is the cable owner’s priority to maintain its good regulatory status in order to avoid further negative consequences in a country affected by a cable failure. The negative consequences range from bad publicity to loss of political support and confidence when needing to renew the licence for other telecommunication services in that country.
Other common causes of delay include lack of available cable spares in the cable owner’s depot, lack of documentation to clear customs procedures for cable importation, adverse weather conditions, or delays in obtaining maintenance permits from various government agencies. While some of these causes are related to negligent behaviour of either the maintenance provider or the cable owners, others may be strictly related to force majeure events. Therefore, the daily reports of operations performed by the maintenance service provider for the cable owner should be carefully drafted, as they may be used as legal evidence by any local government to prove non-performance of the cable owner’s regulatory obligations. STF

ANDRÉS FÍGOLI is the Director of Fígoli Consulting, where he provides legal and regulatory advice on all aspects of subsea cable work. His expertise includes contract drafting and negotiations under both civil and common law systems. Additionally, he has extensive experience as an international commercial dispute resolution lawyer. Mr. Fígoli graduated in 2002 from the Law School of the University of the Republic (Uruguay), holds a Master of Laws (LLM) from Northwestern University, and has worked on submarine cable cases for almost 21 years in a major wholesale telecommunication company. He also served as Director and Member of the Executive Committee of the International Cable Protection Committee (2015-2023).
ON THE MOVE
IN THE DYNAMIC REALM OF CORPORATE ADVANCEMENTS, THIS MONTH SPOTLIGHTS A SERIES OF NOTABLE TRANSITIONS AMONG INDUSTRY LEADERS.



PRADEEP R has been appointed Channel Partner - APAC at Gcore starting March 2025. Previously, Pradeep served as Owner at AI Data Centers and Data Center Realty, along with roles in the Open Compute Project Foundation and Nomad Futurist.
MUHAMMED AL-IBRAHIM took on the role of Regional Sales VP at Nokia in March 2025. Al-Ibrahim brings extensive leadership experience from his previous role as Regional Vice President at Infinera, where he worked for over eight years.
FONG YIEW HSANG assumed the position of General Manager at ADIRA CABLES PTE LTD in February 2025. Hsang previously served as Head of Business Solutions and Head of Sales and Marketing at ASEAN Cableship Pte Ltd, accumulating nearly three decades of experience in the industry.
These transitions underscore the vibrant and ever-evolving nature of the industry, as seasoned professionals continue to explore new challenges and avenues for impactful contributions.
SUBMARINE CABLE NEWS NOW
CABLE FAULTS & MAINTENANCE
PEACE Submarine Cable Cut Disrupts East Africa
Alaska Communications’ Subsea Cable Breaks in Southeast Alaska
Vietnam Internet Infrastructure on the Mend
Taiwan-Matsu Undersea Cable Repairs Completed
Finland Releases Tanker Suspected of Cable Damage
Baltic Subsea Cable Damage Deemed Accidental
Undersea Cables Severed; Taiwan and NATO Respond
CONFERENCES & ASSOCIATIONS
Ghana NCA, ASCOG Partner to Protect Cables
CURRENT SYSTEMS
Pakistan Connected to Africa-1 Submarine Cable
FUTURE SYSTEMS
Caspian Undersea Cable Agreement Reached
Sparkle and Turkcell Partner on New Subsea Cable
SubCo Begins SMAP Cable Landing Station Construction
Nigeria, Glo Collaborate on Submarine Cable Infrastructure
IDC to Back Major South African Subsea Cable Project
GlobalConnect Joins Pan-Arctic Cable Project
Space Norway, SubCom to Build Arctic Way Cable
Hexa Capital Partners With APTelecom for MYUS Cable Project
Meta Announces Project Waterworth
Super Sistem Engages APTelecom for BTI Cable
STATE OF THE INDUSTRY
WFN Strategies Marks 24 Years in Subsea Cable Excellence
Nokia Completes Infinera Acquisition
Nigeria Invests $2 Billion in Digital Infrastructure
EU Acts to Secure Submarine Cables
Alaska Power & Telephone Acquires SEALink Majority
EXA Infrastructure to Acquire Aqua Comms
Chinese Engineers Patenting Submarine Cable-Cutting Tech
SUBTEL FORUM
Submarine Cable Almanac Issue 53 – Out Now!
TECHNOLOGY & UPGRADES
UK-Led AI System Monitors Undersea Infrastructure Threats
Sparkle Partners with OEC to Recycle Subsea Cables
Southern Cross Achieves 1 Tb/s Pacific Transmission with Ciena
ADVERTISER CORNER
BY NICOLA TATE
Welcome to this issue’s advertising and marketing tip! In the last issue I discussed consistent branding in your marketing and how important it can be, especially with the long decision-making timeline within the submarine cable industry. In this issue I’d like to cover what to do with the leads (website visits and interactions) that you generate from your SubTel Forum marketing campaigns!
Once you have built your campaigns around consistent branding, with a great value proposition, and an effective call to action, you will likely start driving people to your website. What do you do with these “leads” that you generate and how can you convert them into customers?
Once you have built your campaigns around consistent branding, with a great value proposition, and an effective call to action, you will likely start driving people to your website.
There are basically two methods to capture leads from a digital marketing campaign. The first, and most obvious, is a lead capture form. You will see these commonly when offering items of value like research papers, webinars, informative newsletters, free consultations, etc. The user enters their contact data and in return they get some item of value.
The lead capture form is a great method to find highly motivated and likely customer targets, but a large percentage of people that visit a landing page never enter their contact details. This poses a problem – there are a bunch of
interested people, and you don’t have their contact details! Fortunately, there is an additional way to capture these visitors. Placing a retargeting pixel on your landing pages allows you to identify web visitors and enables you to target them with future digital marketing campaigns. There are some privacy requirements that vary depending on the country, but in general you can build a list of visitors to your campaign landing page and target them with additional marketing messages through banner advertising, video, audio, and even connected TV. It may sound complicated, but it is simple to implement and we’re happy to provide help. I hope you find these quick tips helpful, and if you are seeking to put all of them into action there is simply no better place to facilitate connections and showcase your product or service than SubTel Forum properties. Contact me to find out the latest, most effective ways to make a connection. I am always happy to help you map out a campaign that will be effective and yield the best chance for conversions. STF

Originally hailing from the UK, NICOLA TATE moved to the US when she was just four years old. Aside from helping companies create effective advertising campaigns Nicola enjoys running (completed the Chicago marathon in 2023 and will be running in the Berlin marathon in 2024), hiking with her husband, watching her boys play soccer,
Submarine Telecoms Advertising

A T A GLANC E
Submarine Telecoms Forum is the leading digital platform for the submarine cable industry, offering a dedicated e-magazine, daily news, and streaming video content. We serve over 150,000 users across 125 countries, providing free, comprehensive insights into submarine telecom cable and network operations. As a trusted source for information, we ensure you stay informed and connected in the fast-paced world of submarine telecommunications.
OU R SPONSORS INCL U DE :

Top 10 Countries by Readership



United States (30.1%)

France (13.22%)

United Kingdom (11.23%)

South Africa (10.47%)

Singapore (7.11%)

India (6.78%)










Japan (6.1%)
Australia (5.48%)



Germany (5.46%)
Philippines (4.05%)
THE DECISION MAKERS: 64.28% of the SubTel Forum audience are either the final decision maker or have a high influence on the final purchase. 35.72% are involved in making purchasing recommendations.
DEEP INDUSTRY EXPERIENCE: 85.72% of the SubTel Forum audience have greater than ten years of industry experience.

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MAGAZINE
SubTel Forum, the premier publication in the submarine telecoms industry, stands out with:
• An average of more than 1,000 unique reads per issue and an average read time of more than 8 minutes.
• Two Months Exposure & Endless Archiving:
SPONSO R SHIP BENEFITS W ITH SUBTEL FO R UM :
• Video Embedding:
• Social Media Shoutouts:
• Dedicated Email Campaign:
A R T & V IDEO R EQ U I R EMENTS :
• Print Ads:
• Video Ads: •
EDITORIAL CALENDAR:
January 2025: Global Outlook and SNW EMEA preview
March 2025: Finance & Legal and ICPC preview
May 2025: Global Capacity and SubOptic preview
July 2025: Regional Systems and SNW World preview
September 2025: Offshore Energy and IWCS preview
November 2025: Data Centers & New Technology and PTC preview

The SubTel Form Almanac, released quarterly,is a key reference for the submarine cable industry. Each issue showcases major international systems with detailed pages featuring system maps, landing points, capacity, length, and RFS year, among other data.
QUA R TE R LY DO W NLOADS & EXPOSURE :
• Each issue averages about 850 unique reads, 215 clicks, and a greater than 24 minute read time.
• Three months of exposure plus permanent archiving.

SPONSO R SHIP BENEFITS :
AD EXAMPLE
2 PAGE SPREAD 11” x 17”
A R T & V IDEO R EQ U I R EMENTS :

REPOR T
The SubTel Forum Annual Report offers the latest, comprehensive data on the submarine fiber market, analyzing system capacity, productivity, and industry outlook. The yearly Industry report typically generates more than 2700 unique reads with an average read time of more than 11 minutes.
ANNUAL PRICE: $3,200
SPONSO R SHIP BENEFITS :
• Two-page Spread Ad.
• Social media acknowledgement.
• Press release and mailer acknowledgement.
A R T & V IDEO R EQ U I R EMENTS
:
• Two-page Spread: 17” W x 11” H, 300 dpi in PDF or JPG.
• Optional video: include a blank box for overlay; no size restrictions.
LOCK IN NO W FO R 20 2 5 !
• Global Overview
• Capacity
• Ownership Financing Analysis
• Supplier Analysis
• System Maintenance
• Cable Ships
• Hyperscalers and The Evolution of Submarine Cable Ownership
• Special Markets
• Regulatory Outlook
• Regional Analysis and Capacity Outlook
NEW FOR 2025 - THE SUBMARINE TELECOMS FORUM DIRECTORY
This new directory is designed for industry professionals to locate companies that provide products or services to the submarine telecom cable and network operations sector. Engage the more than 150,000 users across 125 countries that consume Submarine Telecoms Forum’s e-magazine, daily news, and streaming video content.
• Starting at $599/year
Learn more, customize your campaign, or place an order by contacting Nicola Tate at [+1] 804-469-0324 or ntate@associationmediagroup.com
PRINT CABLE MAP
Limited Availability:
Wide Distribution:
Over 4,500 copies shared at key industry events including PTC (January 2025), Submarine Networks EMEA (Februray 2025), and IWCS Cable & Connectivity Forum (October 2025), ensuring a year-long exposure. Additionally, an updated print-ready PDF cable map will be available for all sponsors.
ANNUAL PRICE: $4,500
SPONSO R SHIP PERKS :
• Comlimentary Web Banner on News Now feed
• Social Media shoutouts
• Acknowledgement in press releases and mailers
• In addition to the print copies that you may pick up during key industry events you can secure a print-ready PDF to print copies for staff and customers. Updated quarterly!
Add a special printing for SubOptic 2025 happening June 2025. $1,750 additional cost for annual sponsors or $3,500 for the single printing.

ONLINE CABLE MAP
• • • • • QUARTERLY PRICE: $3,000
SPONSORSHIP BENEFITS FO R THE SUBTEL FO R UM ONLINE C A BLE M A P :
• Duration:
• Visibility:
•
• Social Media Recognition:

Learn more, customize your campaign, or place an order by contacting Nicola Tate at [+1] 804-469-0324 or ntate@associationmediagroup.com

