Jurisdictions must be prepared to continue their minimum essential functions throughout the spectrum of possible threats from natural disasters through acts of terrorism. Continuity of Operations (COOP) planning facilitates the performance of State and local government and services during an emergency that may disrupt normal operations. - Source FEMA
Government organizations should develop Continuity of Operations (COOP) and Continuity of Government (COG) plans as part of a Comprehensive Emergency Management Program using a comprehensive planning process based on federal guidance and best practices in emergency management and continuity planning. This article addresses some of the key issues involved in implementing COOP and COG programs.
COOP and COG are terms that were first used to refer to the “shadow government” that was conceived during the Cold War as a way to ensure that the U.S. government would be able to continue in case of nuclear war. In addition, continuity planning was a requirement for state and local governments under the Civil Defense program mandates. Today, COOP planning remains an important planning requirement. While terrorism may be the threat that is leading to the increase in planning efforts, COOP and COG planning will help ensure government services in the face of any hazard.
Contemporary COOP and COG plans focus on the jurisdiction’s ability to perform minimum essential government functions during any situation. With the necessary preparations, essential government functions like public safety, public works, and health care can be available under almost any circumstance. Many more routine government functions may also be essential to your community and will need to be included in planning. It is also important that local businesses and other community organizations be included in the process and encouraged to have their own COOP plans.
COOP should be seen as part of a complete community emergency management program, and as such, should be included in a Comprehensive Emergency Management Program (CEMP) process, which utilizes an “all hazards” approach and addresses the four phases of emergency management (mitigation, preparedness, response and recovery.) COOP programs build upon existing programs for critical infrastructure protection, business continuity, and (computer) disaster recovery planning. An integrated COOP and CEMP approach should leverage these existing programs and include all essential government operations as well as those essential functions performed by community-based organizations.
While COOP activities serve to support the continuance of government functions, COG activities address the continuance of constitutional governance. COG ensures the command and control of response and recovery operations as well as continuance of basic governmental functions. Key governance functions include legislative activities and the capability for elected officials to convene and operate in a safe location in accordance with local requirements. COG planning includes succession planning, delegations of authority, and alternate locations. Governments must ensure that elected officials and all three branches of government are able to function during and after a disaster.
COOP, and COG plans must be tightly integrated. Together, as part of a CEMP, COOP and COG will ensure essential community services in the face of any threat.
COOP and COG plans should detail all of the procedures that define how a government and the community will continue or recover its minimum essential functions in the event of a disaster. Essential functions are generally understood to mean those functions that must be performed to achieve the jurisdiction’s critical missions. Each jurisdiction must inventory and prioritize all of its functions and determine which ones are truly essential. Specific plans must then be developed and resourced to ensure continuity of each function. Managers will use these plans to ensure that there is minimum disruption to their service delivery in the event of a disaster or other major interruption to services.
Federal COOP guidance provides a useful frame of reference for state and local government COOP efforts. According to federal agency COOP guidance contained in Federal Preparedness Circular (FPC) 65, COOP planning is based on achieving a high level of readiness for implementation both with and without warning. The FPC requires that COOP capabilities be operational no later than 12 hours after activation and must be able to maintain sustained operations for up to 30 days. According to the circular, the objectives of a COOP plan include:
- Ensuring the continuous performance of an agency’s essential functions / operations during an emergency;
- Protecting essential facilities, equipment, records, and other assets;
- Reducing or mitigating disruptions to operations;
- Reducing loss of life, minimizing damage and losses; and,
- Achieving a timely and orderly recovery from an emergency and resumption of full service to customers.
COOP capabilities require substantial effort; as a result, plans should be developed and maintained using a multi-year strategic plan. The strategic plan should outline the process the agency will follow to designate essential functions and resources, define short and long-term COOP goals and objectives, forecast budgetary requirements, anticipate and address issues and potential obstacles, and establish planning milestones. It is important that this not simply be a plan. Arrangements must be made to guarantee the availability of the needed space and equipment for alternate site operations. Without actual buildings and equipment, COOP plans will be worthless.
COOP Capability Elements
Based on current federal guidance, industry standards, and best practices, a COOP Capabilities Assessment for Readiness (COOP CAR) was recently developed to address the elements of a comprehensive COOP Program. Over 400 requirements were identified, organized into 15 sections representing the elements of an effective COOP Program:
Plans and Procedures
Essential Functions Defined
Delegations of Authority
Orders of Succession
Alternate Facilities Identified
Communications and Warning
Protection of Vital Records and Databases
Testing, Training, and Exercises
Roles and Responsibilities
Update, Distribution, and Communication of Plan
Hazard Identification and Risk Assessment
Mitigation and Countermeasures
Command and Control
Many of these functions should already be performed as a part of the local Comprehensive Emergency Management program. A COOP CAR should be conducted to assess operational capabilities and to identify gaps and support the strategic planning process. The CAR should be designed to serve as a basis for actions that need to be taken in order to strengthen the COOP program. The assessment results will assist a local government in establishing priorities and analyzing program performance to improve the quality of the program.
Government services are not unlike business functions and the basic concepts of business continuity planning may be applied to COOP programs. Continuity plans must be in place for all essential functions both in the government and the community. Government programs do present some unique challenges; for instance, local law may require that public meeting notices be place at City Hall but provide no alternative should City Hall no longer exist. COOP and COG planning will need to consider a wide array of legal issues, many may require enabling legislation or even charter amendments.
In addition to a comprehensive planning approach, experience shows us that COOP must be a living program and its procedures must be updated and practiced on a regular basis. Delegations of authority and notification lists are two particularly high maintenance elements. In addition, regular exercises and assessments will identify areas needing improvement.
The following sections address some of the key issues in continuity planning.
Succession plans and delegations of authority are a key element of COG programs. These plans should establish orders of succession to all key positions. The orders of succession must be of sufficient depth to ensure your jurisdiction’s ability to perform essential functions of government through any emergency. Geographic dispersion of successors is encouraged, as plans should be useable in the most catastrophic of events.
In addition to elected officials, orders of succession should be established to other key leadership positions (department and agency heads.) Clear succession policies must be in place and well communicated so that confusion is avoided. Establish the rules and procedures designated officials are to follow and use positions or titles, rather than names of individuals. Delegations of authority must clearly identify any limitations. You will need to consult with legal counsel as to the appropriate process and to determine what limitations on succession and delegations of authority exist in your jurisdiction.
Assign successors and delegates to the emergency teams established to perform essential functions to ensure that each team has duly constituted leadership.
Alternate operating facilities are a vital part of any COOP plan. You jurisdiction should identify alternate facilities and prepare your personnel for the possibility of unannounced relocation of essential functions and contingency staff to these facilities. Facilities may be identified from existing infrastructure, or external sources. FEMA recommends that these facilities be capable of supporting operations in a threat-free environment, as determined by the geographical location of the facility, a favorable assessment of the local threat, and/or the collective protection characteristics of the facility. In acquiring and equipping such facilities, FEMA encourages you to consider cooperative interagency agreements and promote sharing of identified alternate facilities. Broad based public-private partnerships and mutual aid agreements should also be used to provide alternate site capabilities. Alternate facilities should provide the capability to perform essential functions under various threat conditions, and offer sufficient space and equipment to sustain operations for up to 30 days.
These alternate sites will need to include equipment to support communications with essential internal and external organizations, partner organizations, and the public. In planning for operations at alternate sites, it is important to consider the health, safety, and emotional well-being of relocated employees; and to provide physical security and access controls.
Incident Command. An incident command system is required for effective command, control, communication, and coordination. The Incident Command System (ICS) is used by many emergency management organizations and should be used in COOP and COG activations. All key players should receive appropriate ICS training. Using ICS routinely in drills, exercises, and smaller emergencies will help reinforce the training.
Mutual Aid. Work with other jurisdictions or organizations to forge mutual aid agreements. These agreements should provide a mechanism to cooperate in sharing resources, such as space, equipment, materials, and staff. These agreements should be in place with both nearby as well as distant jurisdictions that will not be impacted by a regional disaster.
Staff. The people who will be implementing COOP plans are often the same people who would be responding to the emergency that resulted in a COOP activation. It will be helpful to create a management structure, which includes staff that will be divorced from the emergency response. Notification and communication requirements for these employees must be addressed as part of the plan. These staff should be required to have “bug out bags” at the ready with necessary equipment and personal items. Remember that family preparedness issues must also be addressed.
Equipment Needs. Consider sharing agreements with other organizations as well as quick ship and hot site options. Pre-positioning resources is ideal; in addition, essential personnel will need to be prepared to relocate on short notice. Be sure to coordinate with your information technology department to discuss plans to protect your computer systems and how you may be asked to support off-site recovery and back-up provisions. Plans must be developed to address relocation and procurement of computing equipment as well as data restoration.
Transportation. If you need to relocate, you may need to move all or some of your equipment and records. Plan for this ahead of time and establish a relationship with multiple moving companies. Remember that many threat scenarios may severely impact transportation.
Contamination. Biological agents and other hazardous materials, as well as debris and water may contaminate your buildings and equipment. Often the “cure” is worse than the disease. Be prepared to decontaminate equipment and understand the impact of contamination. Plans should include salvage and drying of important documents and equipment. In addition, mold and mildew may be a problem after the event.
Continuity of Operations planning is an important undertaking; your community and government depend on it. To be successful, executive commitment and support are needed along with an organized and comprehensive approach. Take the time and effort required to design a complete COOP and COG process and fully prepare for all relevant scenarios. Build in flexibility so that the plan will work under various scenarios. Make the commitment to keep the plan current, and test the procedures as often as needed. There is a wealth of information available that can help you in your planning efforts. Your local Emergency Management organization is a great place to start.
By Steve Davis, Principal, DavisLogic and All Hands Consulting.
All rights reserved © 2002, Steven C. Davis.
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