Conference Agenda

Recent disruptions to submarine cables in the Baltic Sea and Red Sea have renewed attention to the vulnerability of undersea communications infrastructure and exposed a tension in U.S. infrastructure governance: cables that carry over 95% of international data traffic are treated primarily as licensing and ownership questions rather than operational resilience imperatives. The FCC and the interagency group known as Team Telecom emphasize ownership disclosure and supply chain risk while leaving the operation, maintenance, and repair of cables to private companies and multinational consortia. While these mechanisms address legitimate concerns about foreign influence and equipment security, they leave a structural gap in operational resilience: no federal authority exists to direct the repair, restoration, or operational prioritization of submarine cables when they fail.

This paper argues that U.S. submarine cable governance exhibits two structural limitations. First, the FCC’s increasing role in national security policy places strategic security functions within a licensing agency whose institutional mandate, expertise, and legal authority are oriented toward pre-deployment review rather than operational continuity. Second, unlike other critical infrastructure sectors where Congress and the executive branch have developed frameworks for operational intervention, such as power (where Federal Energy Regulatory Commission and DoE hold authorities), rail (Defense Production Act authorities), and aviation (DoT emergency powers), the US has no analogous authority for submarine cable repair during a disruption. When cables fail, decisions about restoration, prioritization, and repair are made by private actors without public oversight or a national security mandate.

We situate the U.S. model within a comparative international context. The European Union's February 2025 Action Plan on Cable Security and the February 2026 Cable Security Toolbox represent efforts to integrate maritime domain awareness and cross-sector resilience planning into cable governance, with no direct analog in the U.S. framework. Brazil offers a different model: the Brazilian Navy maintains active coordination relationships with private cable operators, national cybersecurity institutions are formally integrated into infrastructure protection, and the government is developing domestic cable repair capacity through Blue Marine Telecom, reflecting a deliberate effort to reduce strategic dependence on foreign repair infrastructure.

Our empirical analysis draws on three original datasets. First, we construct a comprehensive record of all submarine cable landing license applications filed with the FCC since the establishment of the International Bureau Filing System (IBFS). Using filing timelines, docket histories, and public notices, we identify licensing outcomes and infer national security review activity by analyzing procedural signals such as removal from streamlined processing, extended review timelines, executive branch filings, and application withdrawals following interagency review. This approach allows us to reconstruct the actual rate of national security intervention. Second, we analyze the ownership composition of the twenty highest capacity submarine cable systems landing in the United States, measured by total lit capacity in terabits per second as reported in FCC Section 43.82 circuit capacity filings, documenting the accelerating entry of hyperscale cloud providers as primary cable owners. Third, we analyze the global distribution of cable repair vessel capacity, including ownership and flag status of cable repair vessels to assess the adequacy of available repair resources.

The findings reveal a structural misalignment between regulatory oversight and operational resilience. Ownership screening and supply chain review, however necessary, do not address the question of what happens when a cable is cut. While U.S. policy has focused heavily on foreign ownership screening and supply chain risk, the most immediate risk to submarine cable infrastructure is not foreign ownership of cable assets but the absence of any public authority empowered to direct restoration when critical connectivity fails.

The paper concludes by evaluating several policy options to address this gap. We argue that effective submarine cable resilience policy requires moving beyond the licensing layer to develop operational authorities commensurate with the infrastructure's strategic importance.