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5CHAPTER 2 EXISTING GUIDELINES FOR COOP PLANNING Since the late 1990s, the continuity capabilities of state and local transportation agencies within the United States have evolved far more rapidly than at any time since the con- tinuity planning field was first established in the 1970s. Many observers attributed this advance, initially, to concerns over the effects of Year 2000 (Y2K) programming issues on the capability to sustain operations. The Y2K planning initiative was both preceded and fol- lowed by a series of devastating hurricanes and floods that brought into question state and local transportation agen- ciesâ capabilities to manage major emergencies that denied access to facilities, utilities, and equipment. Finally, the attacks of September 11 and the subsequently heightened threat environment have encouraged continuity planning not only for contingencies that deny access to facilities, equip- ment, systems, and vehicles, but also to personnel. Threats from weapons of mass destruction (WMD) have also raised new concerns regarding long-term contamination of facilities. In preparation for Y2K and in response to a changing threat environment, the Federal Emergency Management Agency (FEMA) issued Federal Preparedness Circular 65, Subject: Federal Executive Branch Continuity of Operations (COOP) on July 26, 1999. Then, Federal Preparedness Circular 66, Subject: Test, Training and Exercise (TT&E) Program for Continuity of Operations was issued on April 30, 2001. Also on April 30, 2001, FEMA released Federal Preparedness Circular 67, Subject: Acquisition of Alternate Facilities for Continuity of Operations. These circulars documented the results of federal continuity planning strategies and lessons learned through Y2K planning and other emergencies. UPDATED FEDERAL GUIDANCE Based on the experiences resulting from the terrorist attacks of September 11, 2001, and subsequent drills and exercises, FEMA revised its COOP circulars, publishing Continuity of Operations Federal Preparedness Circular 65 or FPC 65 on June 15, 2004. This document supersedes the earlier guidance and consolidates requirements for COOP planning, alternate facilities, training, testing, and exercising into a single circular. This document also integrates COOP planning with other preparedness guidance developed by FEMA in its new role as part of the Department of Home- land Security (DHS). The updated FPC 65 is available at: http://www.fema.gov/pdf/library/fpc65_0604.pdf or http:// www.fema.gov/txt/library/fpc65_0604.txt. In response to earlier recommendations from the Govern- ment Accountability Office (GAO) (formerly the General Accounting Office) and the National Emergency Management Association (NEMA), the revised FPC 65 offers additional details and examples to support COOP planning activities. It also introduces new requirements for personnel preparedness, risk assessments for alternate facilities, and lists of specific COOP elements to be reviewed and updated annually. FPC 65 requires COOP planning for all federal agencies. In addition, approximately one-half of the states have devel- oped COOP planning requirements based, to varying degrees, on FPC 65. Several major metropolitan areas have also estab- lished COOP planning programs. In many cases, state and local COOP programs are tied to grant programs adminis- tered by DHS/FEMA. FEMAâs COOP guidance is also referenced in the National Response Plan (December 2004) and the National Incident Management System (March 1, 2004). Both of these docu- ments, which are important elements of the DHS emergency preparedness program, are expected to play a major role in shaping both DHS and FEMA grant programs for the next few years. COOP OBJECTIVES FPC 65 defines COOP planning as an effort to ensure that the capability exists to continue essential agency functions across a wide range of possible emergencies. As specified in FPC 65 Section 8, the objectives of a viable COOP plan include: a. Ensuring the performance of an agencyâs essential func- tions/operations during a COOP emergency; b. Reducing loss of life, minimizing damage and losses; c. Executing successful succession to office with accompa- nying authorities in the event a disruption renders agency leadership unable, unavailable, or incapable of assuming and performing their authorities and responsibilities of office;
d. Reducing or mitigating disruptions to operations; e. Ensuring that agencies have alternate facilities from which to continue to perform their essential functions during a COOP event; f. Protecting essential facilities, equipment, vital records, and other assets; g. Achieving a timely and orderly recovery from an emer- gency and reconstitution of normal operations that allows resumption of essential functions for both internal and external clients; and h. Ensuring and validating COOP readiness through a dynamic, integrated test, training, and exercise program to support the implementation of COOP plans. COOP PLAN CONTENTS FPC 65 requires federal agencies to develop COOP plans that address 10 planning topics: ⢠COOP Planning Topic 1: Essential functions are iden- tified and prioritized to provide the basis for COOP planning. ⢠COOP Planning Topic 2: Plans and procedures are developed and documented to provide for continued performance of essential functions. ⢠COOP Planning Topic 3: Delegations of emergency authority identify the legal basis for the officials to make decisions in emergencies and the circumstances under which authorities begin and end. ⢠COOP Planning Topic 4: Orders of succession iden- tify alternates to fill key positions in an emergency, to a sufficient depth to address the absence or incapacity of multiple levels of key personnel. ⢠COOP Planning Topic 5: Alternate facilities are iden- tified to support essential operations in a secure envi- ronment for up to 30 days (including sufficient secure space; logistical support; consideration for the health, safety, security, and emotional well being of relocated personnel; and adequate communications and technol- ogy systems. ⢠COOP Planning Topic 6: Interoperable communica- tions provide voice and data communications with oth- ers inside and outside the organization, including such communications from an alternate facility. ⢠COOP Planning Topic 7: Vital records are identified and made readily available in an emergency, including access from alternate facilities, and including steps to protect the security and integrity of emergency opera- tions records, legal records, and financial records. ⢠COOP Planning Topic 8: Preparedness of personnel to implement the COOP plan is assured, including proce- dures involving closure, relocation, notification of per- sonnel, designation into teams, media relations, and the 6 appropriate staffing and pay flexibilities, benefits issues, and employee roles and responsibilities. ⢠COOP Planning Topic 9: Tests, training, and exercises are designed to occur regularly to demonstrate and improve agenciesâ COOP capabilities, including testing of equipment and plans, exercises for personnel, ade- quate evaluation of the testing, exercise and creation of improvement plans. ⢠COOP Planning Topic 10: An all-hazards approach is undertaken to address the potential devolution of author- ity and operations, as well as an approach for reconsti- tution of essential services at a new site, should an emer- gency result in permanent loss of a facility. PLANNING REQUIREMENTS FOR VIABLE COOP CAPABILITY In providing greater specificity regarding COOP planning requirements, FPC 65 Section 9 now requires federal agencies to demonstrate viable COOP capabilities that at a minimum: a. Must be capable of implementation both with and without warning; b. Must be operational within a minimal acceptable period of disruption for essential functions, but in all cases within 12 hours of COOP activation; c. Must be capable of maintaining sustained operations until normal business activities can be reconstituted, which may be up to 30 days; d. Must include regularly scheduled testing, training, and exercising of agency personnel, equipment, systems, pro- cesses, and procedures used to support the agency during a COOP emergency; e. Must provide for a regular risk analysis of current alter- nate operating facility(ies); f. Must locate alternate operating facilities in areas where the ability to initiate, maintain, and terminate continuity operations is maximized; g. Should consider locating alternate operating facilities in areas where power, telecommunications, and internet grids would be distinct from those of the primary; h. Should take maximum advantage of existing agency field infrastructures and give consideration to other options, such as telecommuting locations, work-at-home, virtual offices, and joint or shared facilities; i. Must consider the distance of alternate operating facilities from the primary facility and from the threat of any other facilities/locations (e.g., nuclear power plants or areas sub- ject to frequent natural disasters); and j. Must include the development, maintenance, and annual review of agency COOP capabilities using a multi-year strategy and program management plan. The multi-year
strategy and program management plan will outline the process the agency will follow to: (1) Designate and review essential functions and resources, (2) Define short- and long-term COOP goals and objectives, (3) Forecast COOP budgetary requirements, (4) Identify COOP program issues, concerns, potential obsta- cles, and the strategy for addressing these, as appropri- ate, and (5) Establish COOP planning, training, and exercise activi- ties and milestones for these activities. TIME-PHASING FPC 65 also recognizes time-phasing, a feature embraced as a primary COOP planning tool by state and local public agen- cies. Time-phasing enables agencies to identify and list key activities, which are performed during distinct periods of time triggered by activation of the COOP plan. In many instances, time-phasing produces checklists that can be used by agencies to support COOP implementation. As discussed in FPC 65 Section 11, COOP time-phasing covers three phases: activa- tion and relocation, alternate operating facility operations, and reconstitution. These phases are described below. Activation and Relocation This phase typically occurs 0 to 12 hours after COOP Plan Activation and includes ⢠Use of a decision matrix for implementing the COOP plan, in response to emergencies both with warning and without warning during duty hours and non-duty hours; ⢠Notification of COOP team personnel required to per- form essential functions immediately and long-term; ⢠Notification of appropriate authorities, alternate facili- ties, and other specified points of contact; ⢠Movement to the alternate operating facilities; ⢠Directions and maps of routes from the primary location to alternate operating facilities; ⢠Movement of records, not pre-positioned, from the pri- mary to the alternate operating facilities); and ⢠Ordering of necessary equipment/supplies not already in place. Alternate Facility/Work Site Operations This phase typically occurs12 hours to 30 days after COOP Plan Activation and includes 7 ⢠Reception and in-processing of COOP personnel; ⢠Transition of responsibilities to the deployed COOP personnel; ⢠Guidance for COOP team personnel whose responsi- bilities will commence after the initial response phase activities; ⢠Identification of replacement personnel and augmentees, as necessary; ⢠Execution of all essential functions at the alternate oper- ating facility(ies); ⢠Notification of appropriate emergency management authorities that the COOP plan has been activated and relocation is required, so that those authorities can make other appropriate contacts; and ⢠The development of redeployment plans to phase down alternate facility operations and return operations, per- sonnel, records, and equipment to the primary operating facility, when appropriate. Reconstitution This phase typically consists of Termination and Return to Normal Operations and includes ⢠Informing all personnel, including non-deployed per- sonnel, that the need for the COOP plan no longer exists and providing instructions for resumption of normal operations; ⢠An orderly return to the normal operating facility, or movement to other temporary or permanent facility(ies) using a phased approach if conditions necessitate; and the transition of responsibilities from deployed COOP personnel; notification of the status of the relocation to appropriate emergency management authorities; and; ⢠An after-action review of COOP operations and effec- tiveness of plans and procedures as soon as possible, identifying areas for correction and developing a reme- dial action plan. Using time-phasing, agencies can map activities for each phase to the chronology of events following a disruption of operations. Based on this listing, state and local agencies can prepare checklists, job aids, employee outreach materials, and operating procedures to support COOP implementation. This approach focuses and organizes activities required to restore essential functions. Table 1 presents actions that might be taken in each of the three phases.
8Phase Frame Activity Phase I- Activation and Relocation 0-12 Hours ⢠Notify alternate facility manager of impending activation and relocation requirements. ⢠Notify impacted local, regional and state agencies. ⢠Activate plans to transfer to alternate facility. ⢠Instruct advance team to ready alternate facility. ⢠Notify agency employees and contractors regarding activation of COOP plan and their status. ⢠Assemble documents/equipment required for essential functions at alternate facility. ⢠Order needed equipment/supplies. ⢠Transport documents and designated communications. ⢠Secure original facility. ⢠Continue essential functions at regular facility, if available, until alternate facility is ready. ⢠Advise alternate facility on status. ⢠Where are the operations and support teams? ⢠Activate advance, operations, and support teams as necessary. Phase II- Alternate Facility/Work Site Operations 12 Hours to Termination of Emergency ⢠Provide guidance to contingency team personnel and information to the public. ⢠Identify replacements for missing personnel (delegation of authority and orders of succession). ⢠Commence full execution of operations supporting essential functions at the alternate facility. Phase III- Reconstitution Termination of Emergency ⢠Inform all personnel that the threat no longer exists. ⢠Supervise return to normal operating facility. ⢠Conduct a review of COOP plan execution and effectiveness. Time TABLE 1 Time-phased implementation
