Policy Compliance Standards for Underground Fiber Cable Deployment and Post-Deployment Protection

The general utilization of telecommunication services and the value users place on communication networks has grown exponentially in the past few decades. The dependence on telecommunication networks has become an essential factor in how people survive during a national or global crisis. Telecommunication network infrastructures such as cables, satellites, and cellular towers play an indispensable role in maintaining society’s stability worldwide when there is a major crisis. Therefore, the protection of these telecommunication assets is critical. However, there have not been any measures to protect these vital infrastructures. This colossal gap prompted the authors to write this paper. The paper is a policy framework designed as a regulatory compliance document to guide the stakeholders in ensuring the underground ﬁber cable is fully protected. Additionally, the paper gave a direction on how the monitoring agencies can enact laws to make the active ﬁber cable a critical national infrastructure. There have been a series of underground ﬁber cable cuts in Ghana and other low-income countries. However, the available policies are not stringent enough to prevent individuals and contractors from activities that may lead to the destruction of underground cables. Based on the lapses identiﬁed in the regulatory standards, we proposed a comprehensive policy and regulatory measures to be implemented by the mobile network operators (MNOs) and the state regulatory institutions. This paper touched on regulatory measures to protect the underground ﬁber cables before, during and deployment. The post-deployment management of the underground ﬁber cable is critical in ensuring high network performance, reliability and availablibity. The policy plan proposed in this paper has been divided into various sections to make it more convenient for reading and referencing. The paper’s novelty is the scope of work done by designing and formulating policies as guiding measures to control and mitigate the frequent ﬁber cable cuts.


Introduction
In Ghana, socio-economic activities are vital to the nation's day-to-day functioning and security; for example, transportation of goods and people, communications, banking and finance, the generation and distribution of electricity, gas pipeline, bulk petroleum storage and water supply. Domestic security and the ability to monitor, deter, and respond to hostile acts depend mainly on some of these activities and other more specialized activities like intelligence gathering and command and control of police and military forces. Severe disruption in these activities and capabilities could significantly impact the nation's safety and security (1) . These activities and capabilities are supported by an array of physical assets, functions, information, people, and systems (2) , forming what is known as the nation's critical infrastructures. These infrastructures have grown complex and interconnected, meaning that a disruption in one may lead to disruptions in others. One such infrastructure is the telecommunications system which has its physical infrastructure scattered across the country. Ghana is one of the nations that have adopted fiber optics to form a transmission medium for its telecommunications infrastructure. The country has a layout of underground fiber cables transmitting communications signal from cities to cities and towns to town through the various villages. Protection of this facility is paramount in ensuring quality service delivery and 100% network availability. Over the years, operators of these telecommunications infrastructures have guarded against and quickly responded to many threats that sought to disrupt service. In order to improve the reliability and safety (3) of the underground fiber cable, a deliberate effort must be made to prevent the destruction of the cable. The underground fiber cable networks have been classified as critical national infrastructure. This situation has lead to the rampant destruction of the fiber cables because there has not been any form of policies that strictly protect the facility from assailants.
The value chain process of fiber installation and post-installation management has been reviewed to reflect current international standards, such as enforcing underground fiber cable deployment laws. The entire process has been evaluated technically to align with the best international practices. The mobile network operators (MNOs) and the regulators were consulted in formulating clear regulatory policies and deployment guidelines (4) that are friendly and fair as a well-structured technical framework for underground fiber optics deployment and management. The policy and compliance framework on underground optical network infrastructure protection has been outlined in this document. Government agencies and local authorities must design a streamlined permitting process and then impose a clear procedural framework with tight deadlines for approving or denying a request for the Right of Way (1) or any form of the permit request.

Literature Review
According to (5) , Critical national infrastructure has not been explicitly defined in ITU's Basic Text or ITU bodies' decisions. However, many references to the protection of critical national infrastructure exist, especially in the security of telecommunications/ICT networks and services, including Critical Resources, Critical (national) infrastructure and Critical Information Infrastructure. Primarily, Critical Infrastructure is defined in the context of the adequacy of a nation's public works, e.g. bridges, roads, airports, dams, etc. This includes telecommunications, particularly major national and international switches and connections (2) . The Electronic Communications Act 2008 (Act 775) in Ghana forbids the cut of underground fiber cable in section 57 and 58. However, Ghana is one of the countries with the highest number of fiber cuts. Other countries include Nigeria, Kenya, etc. and other countries in Asia, suffer the same fate.
The submarine fiber cable has not been spared either, even though the United Nations Convention on the Law of the Sea (UNCLOS) is a legal document enacted some years ago as a protective measure to the submarine fiber cable (6) .
As affirmed by (7) , many countries in defining critical infrastructure include in the definition a reference to that nation. Other countries have specifically included the national component in the term itself (e.g. the UK). In general, critical infrastructures are defined as the systems and assets, whether physical or virtual having a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters (8) . Critical infrastructure refers to processes, systems, facilities, technologies, networks, assets and services essential to the health, safety, security or economic well-being of Canadians and the effective functioning of government. Critical infrastructure can be stand-alone or interconnected and interdependent within and across provinces, territories and national borders. Disruptions of critical infrastructure could result in catastrophic loss of life, adverse economic effects and significant harm to public confidence. European Union ' critical infrastructure' means an asset, system or part thereof located in the Member States which is essential for the maintenance of vital societal functions, health, safety, security, economic or social well-being of people, and the disruption or destruction of which would have a significant impact in a Member State as a result of the failure to maintain those functions Continued on next page https://www.indjst.org/ Table 1 continued United Kingdom The [Critical National Infrastructure] comprises those assets, services and systems that support the economic, political and social life of the UK whose importance is such that loss could: 1) cause large-scale loss of life; 2) have a severe impact on the national economy; 3) have other grave social consequences for the community; or 3) be of immediate concern to the national government.

United States
Whether physical or virtual, systems and assets so vital to the United States that the incapacity or destruction of such systems and assets would have a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters. Nigeria Facilitate an Executive Order's issuance, declaring telecoms facilities as Critical National Infrastructure (CNI). Protecting telecoms equipment from vandalization and prevention of disconnection by government officials. Will improve service and stimulate confidence for further investment China, Korea, Turkey and Thailand critical information infrastructure' as 'information infrastructure that affects national security, the national economy and people's livelihoods, such that, if data is leaked, damaged or loses its functionality, national security and public interests may be seriously harmed. India The Transport systems, air and seaports, electricity, water and communications systems, hospitals and health clinics, and centres for fire, police and public administration services.
[Sources: (5,(9)(10)(11)(12) The developed nations such as Australia, Canada, U.S., UK, and many other European countries have a well-defined critical infrastructure (13) . These countries have all the necessary legislation that protects the infrastructure, especially the underground transmission systems such as power cables, fiber cables, gas pipelines, water lines, among many others.
Even though countries in Africa and other low-income countries have defined their critical national infrastructure (14) , they do not have legislation to protect those infrastructures (15) . In Ghana, unlike Nigeria, which has added telecommunications systems and, more specifically, fiber optics infrastructure, the country has not criminalized the destruction of underground fiber infrastructure. Most African nations and low-income countries do not have well-structured policy compliance measures that could be adopted to safeguard the critical national installations.

Legislative Instrument (LI) and Executive Order
Every nation's health, wealth, and security rely on producing and distributing certain goods and services. These goods and services can be produced when a strong infrastructure has been put in place to ensure the production processes are executed appropriately. In this document, we will focus on the nation's infrastructure required to deliver certain services. For instance, the collection of physical assets, functions, and systems across which the services revolve are called critical infrastructures (e.g., electricity, hospitals, transportations, telecommunication, mining, refinery, etc.). In most countries, national security makes a deliberate effort to address any form of vulnerabilities identified in the critical infrastructure in line with attacks. In addition, the government often develop and implement plans that would protect the public and privately owned infrastructures. These initiatives call for dialogue between the public and the private sector to establish a NIAP to protect all of the nation's critical infrastructures. In contrast, there is a need to protect both human-made and natural events that directly affect the nation's critical infrastructure.
Under the 1992 Constitution of Ghana, Legislative instruments are laws on matters of detail made by a person or body authorized to do so by the relevant enabling legislation. As issued by the government of Ghana, the Executive Order may define this policy framework as a set of standards, methodologies, procedures, and processes that critical infrastructure owners and operators could implement to reduce the frequent occurrence of failures and damages in their underground fiber cable infrastructure.
1. Through its regulatory bodies, Ghana's government must pass executive orders or enact LIs to make telecommunications systems and fiber optics installations one of the national critical infrastructures. It is in the domain of the ministry of communication, the National Communications Authority and the Ghana Chamber of telecommunication to spearhead the passing of these LIs. 2. The LI must prohibit individuals, group of people or contractors from damaging such critical infrastructure. 3. The LI must also criminalize any activity or events deliberately or unintentionally targeted at destroying underground fiber cables.
Such damages caused by an individual or group of persons or contractors must duly be punished by law or the perpetrator made to https://www.indjst.org/ pay for the damages' cost.

MNOs, Regulators and Contractors
The protection of these critical infrastructures and their supporting structures is of paramount interest to public and private organizations.
Recent catastrophic events such as the 9/11 terrorist attacks in America, Indian Ocean Tsunami, Hurricane Katrina, the Wenchuan earthquake in 2008, the Haiti earthquake in 2010 and the Japan earthquake and tsunami in 2011 have strongly emphasized the significance of protecting critical infrastructure systems against natural occurrences such as anthropogenic or natural disasters. The failure of a telecommunication network will delay the relief effort due to the inability to send the information to responders. Reliance on telecommunications services (e.g. internet, data, voice, etc.) worldwide, during the COVID-19 pandemic in 2019/2020/2021, brought comfort at homes, working remotely, and several other activities were done online when there was general lockdown in many nations. Over the years, policies, programs and legislation related to the physical security of critical infrastructure have helped some developed countries to a large extent.
The key stakeholders to ensure that the Executive Orders or legislative instruments are fully implemented is the mobile network operators, the mobile network regulators, thus, National Communications Authority (NCA) and Ghana Chamber of Telecommunications (GCT)) and the contractors who execute installation projects, private developers, civil contractors, etc.

Research Design and Methodology
This study sought to examine the policy and regulatory framework available to the MNOs as a guide for their underground cable deployment. There has been a series of underground fiber cable cuts in Ghana and other low-income countries (16) . Several international and local policy documents were examined, but we concluded there were not enough biting policies and regulatory standards available that prevent individuals and contractors from destroying underground cables.
There several MNOs in Ghana, including the five submarine fiber landing stations. Our study design followed the concurrent triangulation design, where both survey and interview data were collected at the time. We interacted with twelve senior managers of the MNOs. A simple analysis to measure the need for a stiffer policy document was done in MS Excel, and the result indicated a mean opinion score of 4.2. A 5-point Likert scale was used to obtain data. One (1) was the least, and five (5) was the maximum on the 5-point Likert scale. According to the outcome of the analysis, we concluded that the available laws in Ghana against underground fiber cuts are too lenient.
Based on the lapses in the regulatory standards, we proposed a comprehensive policy and regulatory standards to be implemented by the MNOs and the state regulatory institutions. This paper touched on regulatory measures to protect the installation of underground fiber cables and post-deployment management. The MNOs in Ghana have designed their respective policies for this underground fiber cable infrastructure. The policy plan has been sub-divided into various sections to make it more convenient for reading and referencing.
The outcome of our analysis propelled us to formulate a regulatory policy framework based on the current state of affairs regarding the frequent fiber cable cuts in Ghana.

Proposed Policy Regulatory Standards
The policy document formulated to help protect and prevent private developers and contractors from destroying the underground fiber cables has been clearly defined and presented in the sections as indicated below.

Best Practice in Underground fiber cable deployment
Before starting any underground cable installation operations, all personnel must thoroughly be familiar with local company safety practices. Practices covering the following procedures should be given particular emphasis:

Land acquisition and Challenges
In most cases, land acquisition and landlord rental payment are not made per the standard set out in a clearly defined policy, which often generates unnecessary tension between contractors and landlords. These processes must duly be followed in land acquisition and payments.
1. It is recommended that the fiber optics land acquisition team conduct a route survey and inspection prior to cable installation. 2. Information about other underground services layout (e.g. electricity supply cable, gas pipeline, water supply lines, etc.) must be obtained from the local government agencies to guide in the survey and land acquisition.
3. Information on pits and ducts for other underground services should be inspected to determine the optimum location for chambers (wells) and duct assignments. 4. There should be a comprehensive plan to compensate landlords and other persons whose properties may be damaged or impacted during the fiber optic network infrastructure implementation. This comprehensive plan must take into account the geographical location of properties, standard valuing procedure, and the extent of damage to land and properties etc.

Cable depth and relocation
Trenching comprises digging pits and trenches and then placing the conduit or duct with the cable inserted in it and then backfilling it. The fiber cable is then pulled through the hole in the conduit. Underground conduit or ductwork allows the fiber cable to be pulled through new or existing underground cableways.
2. Road contractors must make provision or reservation for underground fiber network expansion. 3. The reserved fiber route must not be less than 10m from the roads' edges in highways and must not be less than 3-4m in the metro areas. 4. Contractors are required to contact all operators of these critical infrastructures prior to the start of any excavation, including those that are out of the right-of-way (ROW). 5. The excavating party should also make necessary locate marks on their existing plant. Underground installations typically terminate in a pit or trench that is accessible to the public. Therefore, barricades, warning devices and covers MUST guard pits and trenches.

Digging across Roads and Intersections
The digging pits and trenches across roads and intersections for new cable installations, expansion or fault resolution MUST not be encouraged. Provisions must be made for extra cables (coils), ducts, pipes and conduit when constructing roads.
1. When there are extra cables, ducts, pipes and conduit provisioned across the road at certain defined intervals, new cable installations, expansion or fault resolution can be done much easier without digging across the road. 2. The concept of digging one time must be adhered to by agencies responsible for road constructions.
3. Digging open trenches and pits across roads for underground installations may be accessible to the public. 4. In critical and exceptional cases where Pits and trenches MUST be dug, especially across roads and intersection in the communities, it has to be guarded by barricades, warning devices and covers.

Fiber cable route
Fiber cable, like most other critical underground infrastructures, must have a well-coordinated and structured layout. The layout or cable interconnectivity mapping must be documented and updated regularly as and when new installations and network expansion occurs. All current network topology and routing changes must be updated appropriately in the documentation and then communicated to all stakeholders.

Permit acquisition, Training Compliance with Laws and Norms and Sanctions
Fiber optics deployment in Ghana lacks established processes and guidelines culminating in fiber deployment challenges which have been the root causes of major underground failures. Cumbersome permit processes have been a factor that impedes smooth fiber optics deployment. Local government authorities and the regulators do not have clear procedures and timelines for application and permit application response. Local authorities have therefore taken advantages of the situation to unduly delay permit acquisition processes. ROW acquisition is costly, and undue delayed processes usually frustrate MNOs and contractors. There are delays in deploying optical networks due to its overly burdensome requests for information, bureaucratic procedures for obtaining permits and the unreasonable charges for using the ROW. ROW issues are complex, involving multiple stakeholders with divergent opinions and parochial interest.