USC0026

Written evidence submitted by The European Subsea Cables Association (ESCA)

The European Subsea Cables Association (ESCA) welcomes the opportunity to submit a response to this Call for Evidence from the Joint Committee on the National Security Strategy (JCNSS) assessing the vulnerability of subsea cables that the UK and international partners are reliant upon.

Executive Summary:

• Subsea cables are vital to global connectivity and energy security, supporting telecommunications, offshore renewable energy, and cross-border electricity trading. As demand for data and clean energy grows, new and diverse subsea cable routes will be required.

• The primary risks of damage to subsea telecommunications cables remain inadvertent human activities. For example, approximately 70-80% of such cable faults result from fishing activity or vessel anchors. The remaining  20-30% of faults are typically caused by other factors such as abrasion, equipment failure or by natural hazards (seafloor currents, storms, submarine landslides, sediment flows etc.).

• Power cables face a different proportion of risks and threats but require similar active steps that are taken by the subsea cable industry to protect them.

• Regulatory challenges and uncoordinated marine developments can impact cable resilience, highlighting the need for clear frameworks for permitting, rapid deployment, and efficient repair.

• The UK’s subsea cable resilience benefits from strong repair response times, supported by strategic vessel positioning and enabling legislation (Marine and Coastal Access Act). However, gaps remain, particularly in power cable repair processes, which require further policy or other support.

• The UK Government must balance security measures with operational efficiency, ensuring that any interventions do not hinder repair operations or introduce unnecessary regulatory barriers that could diminish resilience.

• International cooperation is essential. The UK’s central role in EU transatlantic connectivity places it under pressure to enhance security and resilience. Coordination with EU & international partners and NATO is crucial to avoid overlapping, inefficient regulations.

• ESCA supports the establishment of a cross-departmental function for ‘Subsea Infrastructure Protection’, streamlining engagement across government, reducing regulatory fragmentation, and ensuring policy continuity.

• The Crown Estate’s Whole of Seabed Programme is developing a holistic and long-term strategy for seabed usage with a forward outlook to 2050. This work is crucial for addressing spatial challenges faced by the subsea cable industry, ensuring a coordinated approach to marine resource management.

Future resilience efforts should focus on:

• Upskilling & workforce training both for the subsea cable industry, and for national capability.

• Strengthening cable repair capabilities for both telecoms and power cables.

• Enabling policy amendments in some areas for faster and cost-effective emergency repairs.

• Support for structures and mechanisms to expedite and strengthen restoration efforts.

• Enhancing collaboration with global partners to ensure a harmonised regulatory approach.

Summary

The UK’s subsea cables are designed and built to be resilient, but continued coordination between government, industry, and international partners is critical. It remains vital to promote heightened government awareness, mitigation of risks, ensuring rapid repairs, and protecting subsea infrastructure. ESCA urges policymakers to adopt a balanced approach, prioritising operational resilience alongside security considerations to safeguard the UK’s position as a hub for subsea cables.

About ESCA

[1] ESCA represents national and international companies that own, operate, or service submarine telecommunications and power cables across the UK and Europe. Its primary objective is to promote marine safety and safeguard subsea cable installations in the UK, Europe, and adjacent waters. Both telecommunications and power cables play an increasingly vital role in modern society, with the subsea cable sector experiencing rapid growth in social and economic significance in response to rising global demands.

[2] It is evident that the demand for capacity and clean energy will continue to expand, necessitating the development of new and diverse subsea cable routes to ensure the seamless and efficient transmission of communication, data, and clean energy. Global connectivity is fundamental to economic growth. International and domestic subsea cable systems are indispensable not only for global connectivity and energy security but also for linking the UK’s island communities.

[3] The subsea cable industry also plays a pivotal role in transmitting power from offshore renewable energy projects and facilitating interconnector cable systems between nations and domestic grid reinforcement. The diversification of energy sources, particularly through solar and offshore wind power, alongside the expansion of interconnectors, is essential for strengthening the UK’s energy security and reducing dependence on fossil fuels.

[4] Interconnector cable systems support the secure and cost-effective exchange of energy between countries. By enabling the transfer of surplus energy across borders, they enhance sustainability and contribute significantly to the development of a lower-carbon economy.

[5] ESCA engages at a multi-stakeholder level and collaborates with various organisations, including international bodies, coastal state governments across the UK, Europe, and surrounding waters, and non-governmental organisations (NGOs). This engagement extends to NATO, academia, and defence agencies on security-related topics—both to delineate the respective roles of government and industry in these matters and to raise awareness of the complex challenges that threaten the resilience of this vital subsea infrastructure.

Introduction

[6] The increasing reliance on subsea cables for both global connectivity and energy security has led to heightened governmental focus on the sectors represented within ESCA. In particular, following the sabotage of the Nord Stream pipeline in 2022, there has been intensified scrutiny of subsea infrastructure security, accompanied by speculative assessments of vulnerabilities in media and other publications.

[7] The industry takes the risk of sabotage extremely seriously, though it is considered within the broader context of the various risks and threats faced by subsea cables. These risks may be categorised as those that cause direct physical damage and those that impact resilience more generally. Notably, approximately 70-80% of global telecommunication cable faults result from commercial fishing activity or vessel anchors, with the remainder caused by natural events such as landslides and extreme weather, or even equipment defects. However, permitting constraints, conflicting policy decisions, and uncoordinated marine developments can also have unintended consequences, posing further risks to the resilience of this critical infrastructure.

[8] In light of these considerations, it is imperative that any review of vulnerabilities and security threats to subsea infrastructure avoids reactive security decisions that could inadvertently undermine broader resilience efforts. For instance, measures that impede the timely deployment or repair of subsea cables may, in the long term, prove more detrimental than the risks they seek to mitigate.

[9] The inquiry should consider the extensive and nuanced work already being undertaken by the UK Government to enhance resilience and security, reduce common cable faults, and improve information-sharing between industry and policymakers. DESNZ are members of ESCA and DSIT plays an active role within ESCA and the International Cable Protection Committee (ICPC). The Chairman of ESCA and the DSIT subsea telecommunications cables policy lead both sit on the Joint International Telecommunications Union/International Cable Protection Committee International Advisory Board (IAB) working at an international level.

[10] ESCA engages regularly with departments across the UK government on policy areas that relate to or impact subsea cables and the ability to deploy/repair/protect in a timely manner. DSIT has emphasised the importance of the principles contained in the ICPC government best practices for submarine cable protection and resilience in international discussions. It is recognised that there is more work needed to assess and improve resilience.

[11] A crucial positive message that should be recognised is the UK’s highly effective cable repair response times, which results from enabling policy, and legislation, that reduces administrative barrier to cable repair.

[12] Despite experiencing high annual subsea telecommunications cable fault rates due to high density of fishing and shipping activity, the UK benefits from among the fastest telecoms repair vessel response times. This is largely due to the strategic positioning of repair ships in the UK and France, as well as the specific legal exemptions for emergency cable repairs enshrined in the Marine and Coastal Access Act (MCAA). These provisions serve as a critical resilience measure, significantly reducing the risk of prolonged disruption, particularly in light of the UK’s history of simultaneous multiple faults caused by anchors, fishing activity, and, more recently, natural hazards. The fact that repairs could take place following these multiple faults demonstrates that subsea cables in the UK are quite resilient, and the industry is well prepared to manage repair provisions. However this does not mean there are no gaps in relation to repair capability, and these are described later in this response with possible initiatives that would benefit from government support.

[13] It should be noted that in contrast to statements in media and some governments referring to a rising number of incidents/threats to subsea telecommunications cables, this is not borne out in the data. The number of global kilometres of subsea telecommunications cables was approximately 1 million in 2014. In 2025, it is now at 1.7 million kilometres. According to the latest analysis by the ICPC, the number of faults globally remain quite static at between 150-200 cable repairs taking place each year. This means that the fault rate per kilometre is reducing which represents an improving picture. This is due to active steps in cable protection such as improved installation/burial and proactive cable awareness for example with active outreach and using AIS monitoring.

[14] Repair and maintenance for power cables is not arranged in the same way, and there are steps that can be taken to streamline and improve the processes in relation to power cable repairs – for example through exemptions or self-service licensing for measures to protect cables following their repair where burial may not be achievable or the ability to repair extant cables (that may suffer faults due to age or damage) through replacement. Currently there are regional legislative challenges to cable protection for power cables following emergency repair, or in some circumstances telecommunications cables where external protective structures may be needed (e.g. crossings) which both increase costs but also delay cable owners’ ability to undertake appropriate measures to protect subsea power infrastructure.

[15] Unlike some nations whose swift response times can be circumstantial and subject to discretionary changes, the UK’s approach is underpinned by clear legal frameworks – with some differences between devolved administrations. This provides a robust and predictable system, serving as a strong model for international best practice. ESCA, in its previous incarnation as Subsea Cables UK (and prior to that the UKCPC), played a pivotal role in supporting policy relating to MCAA and worked closely with regulators to ensure its practical implementation to reduce barrier to cable repairs. In English Waters under the current system, emergency repairs require only a simple email notification to the Marine Management Organisation (MMO) within 24 hours following commencement. This means that during a call out and emergency response, the cable owner and vessel owner can focus on the vessel getting to site, and mobilisation does not need prior approval. This process is especially manageable due to the small number of cable repair vessels.

[16] The UK has developed mature coordination processes - guided by ESCA Guidelines and ICPC Recommendations -  between subsea cable repair companies, Kingfisher Information Services, the UK Hydrographic Office (UKHO), the Maritime and Coastguard Agency (MCA), Trinity House, fisheries organisations, and other stakeholders, which further enhance the efficiency and effectiveness of the response system.

1. How might the UK’s reliance on undersea cables evolve over the next 10-15 years?

• What are the key vulnerabilities at the moment and how might these change? (Including both undersea infrastructure and onshore cable landing stations).

[17] The most significant risks and threats to undersea cables continue to be commercial fishing activities, ship anchors, and natural hazards such as seafloor currents, storms, and sediment flows. While burial and armouring provide a degree of protection, damage remains an operational risk, and it is not possible to prevent all instances of cable damage. Consequently, the industry adopts a holistic approach to assessing and mitigating the causes of such damage.

[18] Cable landing stations and onshore/offshore converter stations can represent  points of vulnerability, as they serve as the interface between undersea infrastructure and onshore networks. Ensuring their physical, personnel and cyber security is a key consideration. While cable owners and operators implement measures to enhance the resilience and security of their infrastructure, engagement with the National Protective Security Authority (NPSA) and the National Cyber Security Centre (NCSC) ensures that these risks are addressed more comprehensively at a national level.

[19] The demand for capacity continues to rise as industry and society become increasingly digitalised. Over the next 10 to 15 years, these trends are expected to accelerate, particularly as the UK advances its ambitions in AI and digital infrastructure[1]. This will drive the need for additional international subsea cables, increasing competition for Cable Landing Stations (CLS) and access to an already crowded marine environment. As congestion grows, de facto corridors or even restricted zones will emerge on certain routes, leading to a more congested operational landscape.

[20] The demand for subsea power cables and interconnector projects is also set to increase significantly as the UK and its international partners accelerate the transition to offshore renewable energy. With a growing emphasis on clean energy transmission and distribution, interconnectors play a crucial role in enhancing grid stability, energy security, and cross-border electricity trading in Europe and beyond. As offshore wind capacity expands and new floating wind technologies emerge, a robust subsea cable network is essential to ensuring that renewable energy generated at sea can be brought ashore and transmitted both domestically and internationally. However, the increasing number of interconnectors and power cables will also contribute to greater competition for space within an already congested marine environment, making strategic coordination and long-term planning critical to balancing infrastructure deployment, other development, marine conservation, and coexistence with other sea users.

[21] The development and increase in the number and capacity of power transmission cables offshore, in the UK marine region, is guided by projects such as the Holistic Network Design (HND) and HND follow up exercise, which set out the development of the UK power transmission Grid to 2030 and beyond, building resilience.

[22] The European Union’s transatlantic connectivity is currently reliant on UK-based nodes, and the UK and mainland Europe rely on interconnectors to import/export electricity. In the meantime, the UK can expect increasing pressure from EU nations to secure strategic vulnerabilities that could impact their own digital and energy infrastructure. This presents an opportunity for collaboration in security and resilience efforts, but if uncoordinated, it risks leading to overlapping, non-harmonised regulations that could cause delays and inefficiencies. A strategic and coordinated approach will be essential to ensure that regulatory frameworks support both security and operational efficiency, benefiting the UK and its international partners. It is essential to establish a clear framework for coordination, rapid deployment, and efficient repair, while also enhancing the policy and operational capability of UK agencies involved in subsea infrastructure.

• How does this compare to the situation in other countries (particularly island states)?

[23] Island regions and communities are often more vulnerable to service disruptions if their dependence is based upon a limited number of subsea cable connections. While the UK benefits from multiple connections to the global & domestic subsea cable network, countries with fewer connections face a significantly higher risk of service disruption in the event of cable damage.

[24] Although the UK is an island nation, its extensive connectivity to the global subsea telecommunications cable network provides a high degree of resilience. Even in the event of multiple cable faults, the redundancy within the system ensures continued operation. To service this connectivity, the UK supports an extensive and mature technical capability in marine engineering, maintenance and repair. By contrast, island  communities with fewer connections to the UK mainland such as Scottish islands can be at higher risk of becoming cut off when one or two simultaneous cable faults can occur at the same time. This can also disrupt export of renewable energy generation in island communities to the mainland.

[25] This was seen in Shetland when two simultaneous incidents related to fishing damage caused disruption to services for a period in 2022. This was often referred to as ‘the Shetland Incident’ and incorrectly described as sabotage, however the area is prone to fishing faults, and the individual cables have been broken multiple times over the previous decade, therefore this would require a different response (e.g. increased cable awareness campaigns and engagement with the fishing community) as opposed to a security response.

• Are there any long-term alternatives to undersea cable infrastructure?

[26]  At present, no viable alternatives exist to subsea cables for high-capacity global data transmission. Offshore energy generation relies on power cables to bring energy ashore. Subsea power cables are also essential to import/export, balance and share power between UK and other nations as well as within the UK (e.g. bootstrap projects Scotland-England).

[27] While satellite communications provide a degree of redundancy for telecommunications, they do not have sufficient capacity, nor do they offer comparable bandwidth, reliability, or cost-effectiveness to present an alternative to subsea cables. Technological advances, such as low Earth orbit (LEO) satellite networks, serve as a complementary solution for connectivity, and can also provide backup, particularly for underserved communities and island states and regions, but it is not currently conceivable that they would replace subsea cables in the foreseeable future. It is important to note that LEO systems also also need significant fibre backhauls including subsea cables.

2. Who are the main threat actors and what are their capabilities?

[28] It is not the role of the subsea cable industry to comment on threats from other states. However, the industry collects data regarding the causes of cable faults and is generally focussed on the primary causes of damage which is from commercial fishing and ships’ anchors. The industry takes a holistic view of the various risks and threats that subsea cables collectively face.

[29] In assessing both current and future incidents involving subsea cables, it is important to take into account the following key considerations:

• Primary Causes of Cable Damage: In Northern European waters, the most common causes of subsea telecommunications cable damage are commercial fishing activities and ship anchors. A smaller proportion of faults arise from natural hazards such as seafloor currents, storms, submarine landslides, and sediment flows. The causes of failure/damage for power cables can be different such as the risks from abrasion, degradation over time from impacts, or equipment failure or faults.
• Cable Protection Measures: Subsea cables are safeguarded through a combination of burial beneath the seabed, armouring, and careful route selection to avoid known hazards.
• Despite these very effective protective measures, cable damage cannot always be entirely avoided, and emergency repairs and maintenance remain a routine aspect of subsea cable operations.
• In some jurisdictions, policy can support cable protection and resilience, in other jurisdictions there are detrimental policies which may be unrelated to subsea cables but have unintended consequences.  Removing or mitigating these should be a key consideration when considering government actions relating to cable protection.
• Determining the Cause of a Fault: The precise cause of a cable fault is rarely identifiable immediately. Cable repair vessels typically require several days to reach the affected location, and a physical inspection of both the cable and seabed is often necessary to establish a likely cause in combination with vessel monitoring or other analysis.
• Fault Detection Process: When a fault occurs, engineers conduct diagnostic tests to determine the distance along the cable to the point of failure. Using operational records, they can then establish the geographical location of the fault.
• Investigation Methods: Tools such as the Automatic Identification System (AIS) can be used to track vessel movements in the vicinity of the fault at the time of damage. AIS data alone cannot determine whether an incident was accidental or intentional. However AIS can be switched off despite being a legal requirement, and this is not currently well enforced.
• Frequency of Cable Damage: Subsea cable faults are not uncommon. On average, a subsea cable sustains damage somewhere in the world every three days, with an estimated 150–200 faults occurring annually.
• Maritime and Coastguard Agency Marine Guidance Note 661 (MGN 661) advises caution when operating vessels near to subsea cables. The position of ESCA[2] reflects this guidance to advise against fishing over or anchoring near to subsea cables both for safety reasons and to avoid damage to cables.
• Impact on Service: Damage to a single telecommunications cable, or even multiple cables, rarely results in significant service disruption. Cable operators design their networks with redundancy and diversity to ensure continuity of service, thereby minimising any impact on end users.
• As the transition towards subsea power transmission infrastructure accelerates, its criticality and vulnerability to damage also increase. While co-locating transmission cables may be attractive to alleviate spatial constraints, it simultaneously heightens the risk of multiple cables being affected by a single incident. Power transmission has limited options for redundancy, making it more susceptible to disruption and requiring careful strategic planning to mitigate risks.
• Subsea cables are built and designed to be resilient, and cable owners/operators take active steps to ensure robustness in design, and considerations for cable damage or outages.

[30] Given the routine nature of subsea cable faults, premature speculation regarding the cause of an incident can contribute to the spread of misinformation. While most faults do not receive media attention, those that do often lead to conjecture before sufficient facts are available. To ensure an accurate and measured response, it is essential that conclusions regarding the cause of cable damage are based on investigation and fact based analysis rather than speculation.

3. What developments are expected in subsea technologies over the next 10 years?

• Do these favour aggressors or defenders?
• How well positioned is the UK to take advantage?

[31] Technological advancements have the potential to enhance cable protection; however, they should not come at the expense of traditional protection methods, which have been refined over more than 150 years since the installation of the first subsea telegraph cables in the 1850s. The protection of subsea cables, as well as the associated security and geopolitical risks, are not new concerns for this well-established industry - even during periods of heightened threat. While emerging technologies may introduce new risks, they also offer opportunities to strengthen cable resilience. Accordingly, the industry adopts a holistic approach to cable damage, considering the full spectrum of risks and threats to mitigate potential disruption. As previously noted, cable damage can never be entirely eliminated, but through a balanced and comprehensive strategy, its impact can be minimised.

[32]. As an industry group, ESCA facilitates collaboration among subsea cable owners and operators, ensuring effective communication when governments require industry awareness of emerging threats. The industry is well positioned to provide fact-based analysis and an informed assessment of the risks and threats facing subsea cables. Through this cooperative approach, ESCA contributes to a balanced and evidence-driven understanding of subsea cable security and resilience.

How well positioned is the UK to take advantage of new technologies over the next 10 years?

[33] The UK benefits from a significant number of subsea cables landings, and new technology is deployed and developed both for telecommunications cables and power cables to support the increasing demand for capacity, and the development and deployment of clean energy generation onshore and offshore that needs to be imported and exported to and from and distributed within the UK as an island nation. It is anticipated that the UK is well positioned to take advantage of this, but there are regulatory and policy improvements that can create further enabling actions to support this.

[34] Technology improvements are expected in all areas from the way routes are planned and surveyed to improved installation techniques that enhance cable protection, but these are improvements to tried and tested methods that demonstrably improve resilience.  Continued improvements are also expected in maritime domain awareness technologies that help with threat identification and mitigation including fibre sensing technologies which can be seen as a useful tool in a suite of measures that can enhance cable protection.  Sensing technologies are used by industry to monitor cable integrity, and there remain uncertainties with the use of dual use technologies from a legal and regulatory perspective.

The UK has been a leader in these areas for many decades and has a strong presence in the survey, burial technology, shipboard jointing and surveillance sectors. At present the UK is able to access all critical supply chains and emerging technologies.

4. How resilient are the UK public and private sectors likely to be in the event of major disruption?

• Which sectors would be most affected?
• What would be the immediate and long-term implications?
• What might be the constraints on restoring connectivity swiftly?

[35] The resilience of the UK public and private sectors in the event of major disruption to subsea cables is underpinned by a combination of redundancy measures, robust industry practices, and coordinated government engagement. The UK benefits from the industry having deployed multiple subsea cable telecommunications connections, ensuring a high degree of network resilience, even in the event of multiple simultaneous faults – multiple failures have happened in the past with minimal service disruption for end users. Furthermore, the subsea telecommunications cable industry has well-established incident response mechanisms and routine repair processes, which allow for swift restoration of connectivity in most cases.

[36] However, the extent of disruption would largely depend on the nature and scale of the event. While telecommunications and energy infrastructure are generally resilient, there are further measures that can be taken and are actively being progressed by power and telecommunications cable owners to improve and enhance resilience. Power cable redundancy considerations are not restricted to offshore and must also be considered terrestrially. There are supportive government actions that can also support and enhance this – for example support for repair frameworks for power cables, support in upskilling the next generation of skilled workforce both onshore and offshore to attract and retain new talent, and support for technology development.

[37] In the immediate aftermath of a major disruption, contingency measures including traffic rerouting, alternate pathways, and satellite or other backup systems will help to mitigate the impact. However, prolonged or widespread outages would lead to economic losses, operational delays, and challenges for critical national infrastructure. It is difficult to determine precisely how services and functions would be impacted, but it could negatively impact many sectors including financial markets, international trade & logistics, energy supply/distribution. Given the increasing reliance on energy security, digital connectivity and subsea data exchange, ensuring that policy measures align with industry resilience priorities is critical to maintaining long-term stability.

[38] Restoring connectivity swiftly would be dependent on several key constraints, including the availability of repair vessels, skilled personnel, and favourable weather conditions for subsea repair operations. While the UK has one of the fastest response times for cable repairs globally for subsea cables, supported by the Marine and Coastal Access Act (MCAA), excessive security-focused restrictions risk inadvertently delaying repair operations.  In addition,  there remain some challenges in relation to power cable repair activities that need to be addressed and key sectoral differences between telecommunications and power cables.

[39] Challenges such as overlapping marine/maritime policies, permitting constraints, and coordination across multiple jurisdictions could impede response efforts. To ensure the UK remains resilient, it is essential that security measures are balanced against operational practicality, enabling both rapid response and long-term infrastructure protection without compromising industry efficiency.

5. How effective are the deterrents against the targeting of our undersea cables? Are any improvements needed regarding:

• maritime security capabilities;
• military strategy;
• engagements with Allies and partners;
• legal frameworks, including options for redress?

[40] Deterrents against the targeting of undersea cables are most effective when they address both the predominant causes of cable damage such as commercial fishing and accidental damage from ship anchors[3] and also active deterrence which may be a government activity. Deterrence of traditional threats are also an effective measure/deterrent for sabotage. By minimising routine faults, it supports the ability to detect and respond to potential hybrid threats more effectively as such incidents can be scrutinised to assess and determine the cause.

[41] A key element of maritime security is ensuring that subsea cables remain accurately charted and well communicated to marine users, reducing the likelihood of accidental damage. Cable awareness has been a long standing and effective measure to protect subsea infrastructure and prevent cables from being damaged. Some security related forums have discussed whether it may be beneficial not to share such information.  This is not ESCA’s view because: a) charting cables keeps them safer from inadvertent interactions b) removing cables from charts would not reduce the likelihood of those who may wish to undertake sabotage from finding out where they are c) subsea cables have been charted for decades and the information is already available in the public domain[4] with some specific exceptions.

[42] ESCA continues to promote maritime safety and cable protection through the KIS-ORCA project which charts and shares information with the fishing industry which has been effective in reducing cable faults.

[43] From a military and security strategy perspective, continued collaboration with international partners and NATO is essential to maintaining a coordinated approach to subsea infrastructure protection. The UK’s engagement with the International Cable Protection Committee (ICPC) and the European Subsea Cables Association (ESCA) provides valuable opportunities for intelligence-sharing and risk assessment. Ensuring that military and civilian agencies work closely with industry will further enhance situational awareness and response capabilities.

[44] Strengthening international cooperation to address the protection and resilience of subsea infrastructure is vital – for example through UK Government representation on the joint International Telecommunications Union (ITU) and International Cable Protection Committee (ICPC) International Advisory Body which held its first in person meeting in Abuja, Nigeria in February 2025.

[45] The EU is also reviewing submarine security and resilience and has announced initiatives to intervene in current arrangements.  Given the interconnected nature of international communication networks - and the processes of installation, repair and maintenance. ESCA supports UK co-ordination and collaboration with EU member states in these developments.  We understand DSIT has started to engage with EU institutions – including participation in the recent EU Experts Group on submarine cable resilience – and we encourage further co-ordination between UK and EU initiatives.

[46] Additionally, a cross-departmental approach to subsea infrastructure protection, incorporating both security and resilience considerations, will enable the UK to proactively mitigate risks while preserving operational efficiency.

[47] Strengthening maritime security capabilities alone is not a sufficient solution; instead, efforts should focus on bolstering the UK’s repair capabilities, ensuring that subsea cables can be swiftly restored in the event of damage. The Government, in collaboration with industry, should also consider national capability for example to repair cables outside of usual peacetime scenarios, ensuring that any measures complement rather than hinder the existing repair ecosystem. By prioritising effective coordination between security, industry, and repair operations, the UK can maintain a resilient and responsive subsea infrastructure, mitigating both routine and hybrid threats.

6. How well is policy and co-ordination working across Whitehall departments, law enforcement and private sector actors? Are any changes needed?

[48] Following the General Election in Summer 2024, ESCA wrote to the newly appointed Secretaries of State responsible for subsea cables and received a joint response from the Secretary of State for Energy Security and Net Zero, Ed Miliband, and the Secretary of State for Science, Innovation and Technology, the Rt Hon Peter Kyle, stating:

“The European Subsea Cables Association is a key stakeholder for His Majesty’s Government in its work to promote marine safety and safeguard submarine cables. It is invaluable to have an industry forum which brings together national and international companies from both the energy and telecommunication sectors to help mitigate risks arising from the increased use of, and reliance on, the seabed.

As your letter emphasised, the strategic importance of subsea cables cannot be understated. This Government is committed to unlocking the ocean’s potential for livelihoods and industries, based on security and sustainability. The Department for Science, Innovation and Technology (DSIT) and the Department for Energy Security and Net Zero (DESNZ) are taking a considered approach to ensure our underwater cables, interconnectors, and pipelines are resilient.

Officials are engaging with industry partners, including with and through ESCA, to better understand the risks to this infrastructure. Appropriate measures must be taken to protect subsea cables from a range of threats, which cut across spatial, ecological, environmental, and human risks. That is why we are adopting a cross-Government approach to build a coherent policy environment.

Engagement with you and your members is essential to ensure Government policy is shaped with the industry that owns and operate this vital infrastructure. Officials have noted how much they appreciate working with your team, which is why both Departments are now Associate Members as of this summer. Both DSIT and DESNZ will continue to look to ESCA for constructive challenge as a forum to help shape Government policy.

We welcome your offer for industry to provide a briefing on policies relating to subsea infrastructure. I envisage that our new Ministers, Minister of State for Energy, Michael Shanks and Minister of State for Data Protection and Telecoms, Sir Chris Bryant, will be able to take this forward. We look forward to continuing to work with you to deliver our collective ambitions.”

[49] The UK Government, particularly the Department for Science, Innovation and Technology (DSIT) and the Department for Energy Security and Net Zero (DESNZ), maintains a well-established engagement with the subsea cable industry across policy and operational aspects of subsea cables including emergency planning. DSIT holds responsibility for telecommunications-related subsea cable policy, while DESNZ oversees power-related infrastructure. Both departments, along with their respective ministers, are thoroughly briefed on the broader strategic context and are actively working to mitigate risks associated with cable damage. Furthermore, both departments engage extensively with the European Subsea Cables Association (ESCA) as a key stakeholder across a range of subsea cable policies encompassing both telecommunications and power.

[50] Ongoing efforts by government via DSIT, DESNZ to enhance cable security and resilience include collaboration across fishing, shipping, security, spatial planning policy areas. They also undertake industry-wide evidence gathering, with ESCA providing a convening role for industry. The industry’s positive reception of this holistic approach underscores the importance for government departments to address the full spectrum of risks and threats to subsea cables. This must take an international view, even when considering domestic policy.

[51] This engagement between ESCA, industry members, and government officials is leading to coordinated measures to enhance overall resilience. Encouraging initiatives have emerged through Whitehall’s cross-departmental coordination on multiple policy areas, with DSIT and DESNZ taking the lead on specific subsea cable-related policies. However, challenges remain, and there is concern within the industry that an intensified security focus in certain areas may inadvertently jeopardise the overall resilience of subsea cables. ESCA therefore urges this inquiry to ensure that any security-related measures are aligned with the industry’s priorities for resilience.

[52] The 2022 UK National Strategy for Maritime Security, led by the Department for Transport, included a dedicated chapter on subsea cables, alongside a commitment to a regulatory review.

[53] The Department for Science, Innovation and Technology continues to undertake structured and systematic work to reduce cable faults. Additionally, DSIT remains actively engaged with the industry to assess the resilience of response processes and incident management, ensuring that government support and information-sharing during crises are as effective as possible. This cooperation has proven beneficial, demonstrating both the role of industry and the areas where government intervention may be necessary or advantageous across various scenarios. However there is more that needs to be done in this area, and further work and support to improve the situation.

[54] To address the potential for sabotage, such a strategy should involve reducing ‘background noise’ - that is, minimising routine faults caused by fishing and commercial shipping - to facilitate the clearer identification and mitigation of potential sabotage or hybrid threats. The UK Government remains well-positioned in this regard. The aim of subsea cable industry is to maintain a measured, fact-based approach to cable resilience and security, avoiding unnecessary alarmism in political and media discourse.

[55] Recent developments, including parliamentary questions raised to the UK Chief Scientist in the House of Lords following incidents in the Baltic, demonstrate the effectiveness of the UK Government’s coordinated approach. Lord Vallance reinforced the importance of geographic diversity, redundancy, and repair capability in accordance with the ICPC best practices.

[56] NATO’s Critical Underwater Infrastructure Coordination Cell has now established its headquarters in the United Kingdom, further reinforcing the UK’s position in subsea infrastructure security.

[57] Beyond Whitehall, a significant and fundamental piece of work is being undertaken by The Crown Estate in coordination with their stakeholders. Spatial challenges remain a key focus for the subsea cable industry and there is a pressing need to take a long term view. The Crown Estate, through its Whole of Seabed Programme, is working with stakeholders to develop a holistic and long-term strategy for seabed usage with a forward look to 2050. This ambitious initiative aims to support the accelerated delivery of nature recovery and the transition to clean energy, while ensuring that the telecommunications sector continues to grow. A specific focus within this programme is on telecoms infrastructure, helping to maintain the UK’s attractiveness as a landing point for international data cables as part of a coordinated approach to marine resource management with resilience as a key provision. Significantly, the work also includes strategic assessment and inclusion of telecommunications cables in UK EEZ despite TCE not granting rights for most linear cables outside of 12NM. ESCA is actively engaged in this work, and it will become increasingly important as spatial challenges continue to grow as a result of increasing use of the seas and seabed.

[58] It is essential to emphasise that subsea cable coordination must also incorporate an international focus. The recent appointment of DSIT to the International Advisory Body for Submarine Cable Resilience marks a significant step in strengthening engagement with international partners to enhance resilience at domestic, regional, and global levels. Given the inherently international and interconnected nature of subsea cable infrastructure, future policy must recognise that these networks are not solely a national concern but require coordinated international responses to ensure security and resilience.

[59] DESNZ and DSIT are both members of ESCA, while DSIT also holds membership in the International Cable Protection Committee (ICPC). These affiliations provide informal but valuable opportunities to collaborate with other governments, maintain insight into international policy developments, and facilitate engagement with the subsea cable industry.

[60] Enhancing Cross-Government Coordination on Subsea Infrastructure Protection

The protection of subsea infrastructure requires tailored approaches across different sectors; however, the commonalities between resilience and security challenges must also be considered. ESCA would therefore support the establishment of a coordinated cross-departmental function dedicated to ‘Subsea Infrastructure Protection’ that takes a holistic view. Such an initiative would:

• Streamline engagement by ensuring that different industry sector priorities are collectively addressed.
• Facilitate cross-government practical, streamlined and efficient collaboration on both domestic and international subsea infrastructure policies.
• Reduce resource demands and costs by improving efficiency in policy development and implementation.
• Enhance industry engagement by providing a single, coherent point of contact for government interactions with the subsea cable sector.
• Prevent siloed decision-making, which could inadvertently introduce risks or challenges that undermine the overall resilience of subsea infrastructure.
• Widen the knowledge base of UK officials, building wider capacity and ensuring policy continuity.

[61] The creation of such a function would significantly enhance the UK’s ability to develop a coherent and proactive approach to subsea infrastructure protection, while also ensuring that government policy aligns with industry expertise and operational realities.

7. In the context of limited resources, what is the appropriate balance to strike between enhancing domestic resilience on the one hand, and improving detection and interdiction on the other?

• How should these be accounted for in the Strategic Defence Review, and the Resilience Review?

[62] The risks and threats to subsea cables should be considered holistically and in the context of the typical causes of cable damage in the UK and surrounding waters. A comprehensive understanding of these factors is essential for effective policy development and risk mitigation.

[63] Domestic policy regarding subsea cables must maintain an international outlook and cannot be developed in isolation. This is due to the inherently international nature of subsea cables, which connect multiple countries and cross national boundaries. Ensuring resilience and security therefore requires coordinated international engagement. An important area here is for the UK to work with other partners to share best practise on permitting for emergency repairs to speed up global repair times which can also have a direct impact on UK resilience and redundancy.

Resilience Review

[64] While national capabilities remain critical, they must be considered within the broader global context of the subsea cable industry. Measures designed to bolster and enhance national resilience should include:

• Enhancing support for the telecoms and power cable repair ecosystem, ensuring the industry is equipped to address the challenges associated with subsea power cable repairs. This can include training, vessels, enabling policy/legislation – as well as consideration regarding national capabilities.
• Providing support for the cable repair ecosystem, potentially including strategic investment in capability  - including vessels, equipment, training and upskilling personnel. Ensuring adequate resources are in place for a robust cable repair environment in the future. This required public-private cooperation to ensure that any measures are complementary to existing highly effective processes.
• Working collaboratively across relevant government departments led by subsea cables policy leads DSIT (telecommunications) and DESNZ (power), as well as the subsea cable industry via ESCA and directly with companies, to develop solutions that enhance overall security. 
• Working collaboratively with EU institutions as they undergo their own security and resilience reviews, and ecosystem funding and development initiatives.
• Supporting a review of emergency repair measures for subsea power cables, ensuring that repairs and maintenance can be conducted swiftly. This can include creating the correct conditions to encourage industry to invest in vessels, equipment, and personnel.
• Such a review should include provisions to allow for additional protection measures following a repair operation in cases where a cable cannot be reburied. This is a current example of a key challenge that poses a risk to subsea cables caused by policy that is not related to cable resilience but has a direct and concerning impact upon cable resilience.

Strategic Defence Review

[65] As previously noted, subsea cables across the UK’s telecommunications and power sectors are generally considered resilient today – but it is vital to be mindful of future resilience. However, the Resilience Review should explore potential improvements to consider in the Strategic Defence Review. Different considerations apply to subsea infrastructure in the event of a national crisis or conflict situation, where government involvement may be required, and capacity building needs to commence early.

[66] In such scenarios, it is important to assess national capabilities, particularly in relation to repair and maintenance operations, to address situations where civilian vessels may be unable to undertake repair activities.

[67] Strengthening the UK’s subsea cable resilience from an industry perspective requires capacity building through public-private cooperation, which could include:

• Upskilling personnel (e.g. naval reservists) to enhance preparedness. This would support the existing subsea telecommunications cable repair ecosystem during peacetime while also ensuring the availability of skilled and trained personnel should government intervention become necessary. A secondary benefit of this approach would be an overall improvement in routine operations and maintenance. It is estimated that it typically takes approximately 10 years to train a subsea cable engineer/jointer – but this timescale could be improved with focussed and active investment and support.
• Ensuring that security considerations are developed in a manner that enhances, rather than undermines, the overall resilience of subsea cables. Given the frequency of subsea cable damage, the industry is well-versed in responding to such incidents to minimise disruption. Even in cases of multiple cable breaks in the UK, disruption has historically been limited due to robust existing measures. It is therefore vital that security measures do not compromise the industry’s ability to protect and maintain subsea cables effectively.

[68] There are further measures outlined throughout this response which can further enhance and support the resilience and security of subsea cables.

[69] Conclusion and Recommendations

In conclusion, the following recommendations outline specific measures to enhance the resilience of subsea cables in the UK:

1. Support industry-led initiatives to upskill, train, retain, and encourage early-career professionals, ensuring a sustainable pipeline of skilled workers for both offshore and onshore subsea cable operations.
2. Consider upskilling national response capability for situations that may not be business as usual for the industry. This can include training naval reservists on jointing, cable handling, and other functions and skills that may be needed for cable repair or deployment. This would need to be through investment in public private partnerships.
3. Collaborate with industry to strengthen and expand existing repair capabilities for telecommunications & power cables, ensuring swift and effective responses to faults.
4. Develop enabling policies or explore direct support for the establishment of a framework to facilitate faster and more cost-effective repair responses for subsea power cables. These policies to include creating the correct conditions for industry investment.
5. Establish a structured, cross-departmental approach to subsea infrastructure protection, encompassing subsea telecommunications and power cables, pipelines, and other critical seabed infrastructure, to ensure coordinated government action. This could be a focussed group, clustering of departments with policy responsibility (DSIT, DESNZ, etc). Formation of a new Subsea Infrastructure Protection grouping of another type can make cross government working more practical and efficient, as well as improving engagement with industry.
6. Look at enforcement of current legislation such as the requirement for AIS being switched on. In addition reviewing access to VMS data would also support effective deterrence of cable faults.
7. Introduce policy amendments to enable adequate protection of subsea power cables following emergency repairs, such as through rock placement or mattressing, to mitigate the risk of long-term exposure and potential future vulnerabilities.
8. Continue to promote and uphold International Cable Protection Committee (ICPC) Best Practices, ensuring alignment with global industry good practice and international norms.
9. Strengthen international cooperation by working with global partners to enhance wider subsea infrastructure resilience, recognising that disruptions in other countries/regions can have direct consequences for the UK.
10. Continue to promote advance pre-permitting mechanisms or introduce targeted permit exemptions for emergency cable repairs, expediting response times and minimising delays in critical restoration efforts.

6 March 2025