Subsea cables are estimated to carry 95 to 99 percent of intercontinental data traffic, meaning virtually everyone with access to the internet uses these cables (Mauldin, 2023; TeleGeography, n.d.). This network of subsea cables is vast, spanning over 1.48 million kilometers across the ocean floor (TeleGeography, n.d.). Given the large domain of the network and the strategic importance, the cables are vulnerable to various risks and threats, including human-made ones. In recent years, policymakers and others have raised concerns about foreign advisories targeting subsea cables and other associated critical infrastructure to cause disruption (Siebold, 2023). Understanding the vitality of these cables in global communications makes the security of these cables a concern for the United States’ government.
Granted that these cables are an international security issue crossing several domains, protecting their resilience and security is challenging alone. Some of the difficulty is owed to the complexities of international consortiums of owners, multinational connections, and the locations of this infrastructure (Department of Homeland Security [DHS], 2024). Despite these challenges, the U.S. government can begin to strengthen the cable industry within the U.S. by prioritizing partnerships with the U.S. private sector to develop solutions. This can address current gaps within the subsea cable industry between the U.S. government and the U.S. private sector.
Across the U.S. critical infrastructure sectors, there is a continuous effort to strengthen ties between the government and industry to defend critical infrastructure, including subsea cables (DHS, 2024). The subsea cable industry is primarily privately owned and operated. Given that these cables are the backbone of global communications infrastructure, U.S. government involvement in the industry is increasing. In order to safely expand, maintain, and further protect this critical infrastructure, the government and the private sector must increase collaboration to develop effective and efficient solutions to problems this infrastructure faces.
Currently, there is no forum to facilitate interaction between the domestic subsea cable industry and the U.S. government and to identify and address challenges facing this infrastructure. While the Federal Communications Commission (FCC) has the Assessment of Foreign Participation in the U.S. Telecommunications Services Sector oversight body, or Team Telecom, its purpose is only to review applications and licenses for subsea cables that touch a U.S. territory and evaluate the security risks, rather than facilitate cross-sector coordination (Department of Justice, 2023). The lack of such a forum has made collaboration between the public and private sectors regarding subsea cable infrastructure difficult. To capture the entirety of the subsea cable network, we propose that the U.S. government designate a sub-sector: subsea internet cables and associated infrastructure, which should fall under the Department of Homeland Security’s (DHS) Communications Sector. The Communications Sector is responsible for the physical transmission systems of communication and recognizes the private sector as the primary entity that owns and operates communications infrastructure (DHS, 2015). The subsea cable infrastructure fits nicely into this, allowing collaboration between the public and private sectors to address the totality of the subsea cable industry.
The Critical Infrastructure Partnership Advisory Council (CIPAC) exists within the Cyber and Infrastructure Security Agency (CISA)—created to facilitate interaction between government and private entities that are involved in the same type of critical infrastructure (Critical Infrastructure Security and Resilience, n.d.). However, because the subsea cable network fits between two DHS critical infrastructure sectors—the Communications and Information Technology Sectors—there is no set mechanism for the U.S. government to address subsea cables as critical infrastructure. Existing U.S. government mechanisms for engaging critical infrastructure owners and operators include Sector Coordinating Councils (SCC) and Government Coordinating Councils (GCC).
In December of 2024, the DHS released a white paper on the engagement of subsea cable security and resilience (DHS, 2024). The paper underscores the importance of public-private coordination of the subsea cable critical infrastructure that addresses international security and communications (DHS, 2024), while also recognizing that under the current framework, the DHS is limited in what it can accomplish in terms of cooperation. It recommends leveraging existing critical infrastructure collaborative bodies, particularly Government Coordinating Councils and Sector Coordinating Councils, and exploring new ways to address the industry. But the paper fails to go into further detail, and the recommendations made do not address the core issue—subsea cable infrastructure does not fit cleanly into any of the existing mechanisms.
In April of 2024, the federal government released the National Security Memorandum on Critical Infrastructure Security and Resilience (NSM-22). NSM-22 is an updated framework outlining the roles and responsibilities of federal agencies within the national critical infrastructure risk management landscape (Humphreys, 2024). It offers comprehensive guidance for federal agencies to engage in public-private partnerships but, unfortunately, is relatively restrained in its scope. The memorandum does not introduce any new sectors or sub-sectors to the 16 existing critical infrastructure sectors, meaning that subsea cable infrastructure is still left without its own designated sector or sub-sector within the DHS.
We recommend that the U.S. designate a sub-sector: subsea internet cables and the associated infrastructure. This designation would allow the federal government to collaborate with the private sector more closely and engage in public-private partnerships under the framework of documents like NSM-22. Such a move would simplify the way that the federal government approaches collaboration with the private sector on subsea cables by fitting it into a pre-existing framework that the public sector is already comfortable with through its collaboration in other critical infrastructure sectors.
Sources
Critical Infrastructure Security and Resilience. (n.d.). CISA. Retrieved March 4, 2025, from https://www.cisa.gov/topics/critical-infrastructure-security-and-resilience
Department of Homeland Security. (2024, December 18). Priorities for DHS engagement on subsea cable security & resilience. https://www.dhs.gov/sites/default/files/2024-12/24_1218_scrc_Priorities-for-DHS-Engagement-on-Subsea-Cable-Security-Resilience_18-Dec-24.pdf
Department of Homeland Security [DHS]. (2015). 2015 Communications Sector-Specific Plan. https://www.cisa.gov/sites/default/files/publicaTons/nipp-ssp-communicaTons-2015-508.pdf
Humphreys, B. E. (2024). The 2024 National Security Memorandum on Critical Infrastructure Security and Resilience (IF12716). Library of Congress.
Mauldin, A. (2023, May 8). Do submarine cables account for over 99% of Intercontinental Data Traffic?. TeleGeography’s Official Blog. https://blog.telegeography.com/2023-mythbusting-part-3
Siebold, S. (2023, May 3). NATO says Moscow may sabotage undersea cables as part of War on ukraine | reuters. https://www.reuters.com/world/moscow-may-sabotage-undersea-cables-part-its-war-ukraine-nato-2023-05-03/
TeleGeography. (n.d.). Submarine Cable Faqs. Submarine Cable FAQs. https://www2.telegeography.com/submarine-cable-faqs-frequently-asked-questions
U.S. Department of Justice. (2023, September 20). Team telecom. National Security Division. https://www.jusTce.gov/nsd/team-telecom
