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The world¡¯s population is growing. And with it, so is the need for ocean cables providing high-speed internet access. To meet that growth, our planning and permitting team has worked on projects along North America¡¯s Pacific and Atlantic coasts and Australia. Our experts monitor and anticipate industry trends, including new marine technology, research, and regulations regarding marine life.

This brings us to a discussion of an unusual, bottom-dwelling Pacific Ocean creature you may never heard of¡ªthe sunflower sea star.

A planning case study for submarine telecommunication cables

The sunflower sea star is a perfect case study to understand the complexity of planning and permitting for submarine telecommunication cables.

Once common along the Pacific Coast of North America, the sunflower sea star¡¯s numbers are in steep decline due to a disease called sea star wasting syndrome. NOAA Fisheries is proposing to list the sunflower sea star as threatened under the Endangered Species Act. Scientists worry it may become extinct.

What does this species and new designation mean for companies hoping to lay new submarine telecommunication cables on the ocean floor? Their projects will need to consider the presence of sunflower sea stars. And they will need to avoid impacts to this one-metre-wide creature.

Let¡¯s take a deep dive (pun intended) into sunflower sea stars and other issues telecommunications companies face when planning submarine cable projects. Sea stars are just one of the many challenges facing these cable projects.

The seafloor presents many obstacles to cable planning and permitting. They include deep canyons, coral reefs, critical fish habitats, fisheries, shipwrecks, and even unexploded bombs.

Why the sunflower sea star matters

There are many threatened and endangered species in the ocean. Some of them, like whales, have broad ranges and cross international borders. Importantly, our submarine telecommunication cable team understands how to determine a project¡¯s impact to these marine creatures. And we include this in our impact assessments and provide permitting pathways.

The sunflower sea star is the world¡¯s largest sea star and one of the fastest. They have up to 26 arms and resemble small sea stars you see in tidal pools. They¡¯re just much bigger. Sunflower sea stars can weigh up to 13 pounds and are voracious predators, feeding on other bottom creatures, especially sea urchins.

In fact, they have a vital ecological role in the ocean. Like sea otters, they keep sea urchin populations in check. Why is that important? Sea urchins primarily feed on kelp and other important marine vegetation. Kelp provides a critical nursery and foraging habitat for fish and other creatures. Kelp forests are disappearing along much of the Pacific coastline of North America where the sunflower sea star has declined.

In 2023, NOAA Fisheries proposed listing sunflower star stars as threatened throughout its range along the Pacific coast. Why? More than 90 percent of them were killed by a deadly pathogen outbreak from 2013 to 2017. Scientists considered it the largest marine wildlife disease outbreak ever.

While the disease isn¡¯t well understood, scientists believe it¡¯s connected to stressors such as warming ocean temperatures. Once stressed, a sunflower sea star is more susceptible to viral infection and can then develop lesions, lose its arms, and turn into a dead, gooey mass. Populations don¡¯t appear to be bouncing back from the die-off either.

What a threatened status means to cable projects

The sunflower sea star¡¯s new legal status will likely impact cable projects. We believe regulators may require dive surveys to see if the animals are living within the cable¡¯s path. If sunflower sea stars are found, we may need to relocate individuals away from an impacted area during submarine telecommunication cable installation, so they are not harmed.

What happens if moving animals isn¡¯t an option? We may have to upgrade the severity of the potential impacts to this species in our assessment and look at offset options, including the long-term monitoring of potential impacts on sunflower sea stars.

These creatures live in a challenging environment. While they often live in shallow waters, even exposed at low tide, they can also live down to depths of 1,000 feet (300 metres). Our dive team can conduct surveys in the shallower water. But surveying sunflower sea stars at extreme depths may require remote operating vehicles. What does this all mean for submarine cable project developers?

The threatened listing will require more planning and permitting hurdles. And maybe higher costs for developers.

The sea star could be important during pre-permitting. So are many other obstacles in the marine environment and beach landings where cables come ashore. In route planning, often called a constraints analysis or feasibility study, we look for any potential obstacles and consider the options.

A team looking out for fisheries and old bombs

How do you plan for new submarine telecommunication cables? For us, it starts with our team. We assemble a group of ecologists, biologists, archeologists, Geographic Information Systems (GIS) experts, and many others.

What do they do? Our ecologists and marine biologists specialize in understanding risks to the marine environment. They are also experts in state and federal permitting and regulatory requirements. (This would include the sunflower sea star rules.) Our archaeologists are knowledgeable in cultural artifacts, such as shipwrecks, on the seafloor and permitting requirements associated with them. Our GIS experts help map the most feasible path using current data.

Mapping is critical. The Department of Defense, for example, has maps of unexploded ordnance and munitions. For obvious reasons, we must avoid or move these old bombs.

Canyons and coral reefs also pose a challenge. On the US Atlantic coast, there are deep canyons where laying cable isn¡¯t possible, so we help clients plan routes around them. Laying cables can endanger fragile coral reefs, so our geophysical surveys look for the perfect narrow band on the soft bottom on which to lay or bury cables.

Fisheries are also important. Does a cable project pose a risk to an important commercial fishery in the area? Should the cable be buried so it doesn¡¯t get snagged by fishing gear or anchors? Our biologists help answer these questions.

Let¡¯s meet the regulators

With many cable projects in the US, federal permitting from the U.S. Army Corps of Engineers (USACE) is required. That process will lead to consultation with NOAA Fisheries, the U.S. Fish and Wildlife (USFWS), and the State Historic Preservation Office (SHPO) will occur.

This consultation is required under several laws:

• Endangered Species Act
• Marine Mammal Protection Act
• Magnuson-Stevens Fisheries Conservation and Management Act
• Section 106 of the National Historic Preservation Act.

In addition, depending on where the cable will make landfall, some states have their own regulations. So, state or even local permitting may be required.

Our planning process starts with early consultation with the USACE, NOAA Fisheries, USFWS, SHPO, and other agencies to get their input. We have deep experience working with agencies in the US and Canada when submarine telecommunication cables cross the international border. In Canada, we would consult with the federal department known as Fisheries and Oceans Canada.

With more speed, more careful cable planning

Our oceans and marine life are under more and more pressure.

Ocean temperatures are warming, species are disappearing, and coral reefs are dying. It is vital that we protect our marine environments because oceans play a vital role in the health of our planet.

With careful planning, we can ensure that we can protect creatures like the sunflower sea star and that your next internet call across the globe is faster and clearer than ever.