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5 CHAPTER 2 EXISTING GUIDELINES FOR COOP PLANNING Since the late 1990s, the continuity capabilities of state land Security (DHS). The updated FPC 65 is available at: and local transportation agencies within the United States or http:// have evolved far more rapidly than at any time since the con- tinuity planning field was first established in the 1970s. Many In response to earlier recommendations from the Govern- observers attributed this advance, initially, to concerns over ment Accountability Office (GAO) (formerly the General the effects of Year 2000 (Y2K) programming issues on the Accounting Office) and the National Emergency Management capability to sustain operations. Association (NEMA), the revised FPC 65 offers additional The Y2K planning initiative was both preceded and fol- details and examples to support COOP planning activities. It lowed by a series of devastating hurricanes and floods that also introduces new requirements for personnel preparedness, brought into question state and local transportation agen- risk assessments for alternate facilities, and lists of specific cies' capabilities to manage major emergencies that denied COOP elements to be reviewed and updated annually. access to facilities, utilities, and equipment. Finally, the FPC 65 requires COOP planning for all federal agencies. attacks of September 11 and the subsequently heightened In addition, approximately one-half of the states have devel- threat environment have encouraged continuity planning not oped COOP planning requirements based, to varying degrees, only for contingencies that deny access to facilities, equip- on FPC 65. Several major metropolitan areas have also estab- ment, systems, and vehicles, but also to personnel. Threats lished COOP planning programs. In many cases, state and from weapons of mass destruction (WMD) have also raised local COOP programs are tied to grant programs adminis- new concerns regarding long-term contamination of facilities. tered by DHS/FEMA. In preparation for Y2K and in response to a changing threat FEMA's COOP guidance is also referenced in the National environment, the Federal Emergency Management Agency Response Plan (December 2004) and the National Incident (FEMA) issued Federal Preparedness Circular 65, Subject: Management System (March 1, 2004). Both of these docu- Federal Executive Branch Continuity of Operations (COOP) ments, which are important elements of the DHS emergency on July 26, 1999. Then, Federal Preparedness Circular 66, preparedness program, are expected to play a major role in Subject: Test, Training and Exercise (TT&E) Program for shaping both DHS and FEMA grant programs for the next Continuity of Operations was issued on April 30, 2001. Also few years. on April 30, 2001, FEMA released Federal Preparedness Circular 67, Subject: Acquisition of Alternate Facilities for COOP OBJECTIVES Continuity of Operations. These circulars documented the results of federal continuity planning strategies and lessons FPC 65 defines COOP planning as an effort to ensure that learned through Y2K planning and other emergencies. the capability exists to continue essential agency functions across a wide range of possible emergencies. As specified in UPDATED FEDERAL GUIDANCE FPC 65 Section 8, Based on the experiences resulting from the terrorist the objectives of a viable COOP plan include: attacks of September 11, 2001, and subsequent drills and a. Ensuring the performance of an agency's essential func- exercises, FEMA revised its COOP circulars, publishing tions/operations during a COOP emergency; Continuity of Operations Federal Preparedness Circular 65 or FPC 65 on June 15, 2004. This document supersedes the b. Reducing loss of life, minimizing damage and losses; earlier guidance and consolidates requirements for COOP planning, alternate facilities, training, testing, and exercising c. Executing successful succession to office with accompa- nying authorities in the event a disruption renders agency into a single circular. This document also integrates COOP leadership unable, unavailable, or incapable of assuming planning with other preparedness guidance developed by and performing their authorities and responsibilities of FEMA in its new role as part of the Department of Home- office;