All Hail The Whistleblowers: Starletta Banks, The First To Uncover Trafficking Of Tiny Humans Operations In Michigan CPS

Starletta Banks

Starletta Banks was the first to uncover the deepest, darkest residuals of the peculiar institution, called trafficking of tiny humans, better recognized as Child Welfare.

Child Protective Services.

Foster Care.

Adoption.

Her tale goes like this:

Starletta had just had her third child.

She had a request for a crib through the welfare office.

A CPS worker came out about the crib and heard the baby crying.

The CPS worker called Wayne County Sheriff and Detroit Police who did a joint raid, knocked down her door, to save the kids from abuse and neglect.

Starletta was changing a diaper upstairs and did not hear the knock on the door due to the baby crying.

She heard the police raid the house, but did not know they were police, grabbed her two older children leaving the baby on the bed and hid in the closet, covering the mouths of her two screaming kids.

Police and Sherrif snatched her kids.

In court, CPS investigators gave Jennifer Granholm reports of broken bones of the baby, who was only few months under one year of age.

Granholm, the State Assistant Attorney General for Wayne County, the only county in Michigan where the Attorney General prosecutes child abuse while defending the private contractors of child welfare and its placing agencies with no bid contracts, submitted into evidence x-rays, and broken bones and trauma of a child about 5 years of age, if I correctly recall.

That baby was under the age of one.

Starletta's parental rights were terminated.

She was the first person to ever get permits to protest outside the Michigan Eastern District Courthouse.

No one showed up in the snow, but I did, just to take pictures and cheer her on.

I will have to find those pictures.

She began to teach herself law.

She was embraced by Michigan Republican Leadership who did nothing but use her, but she caught on quickly (which is another tale.)

Starletta shared her research methodologies and findings with me, long before Yahoo Groups.

She said since Michigan did not want to show their dirt in court or in FOIA, she said to find the backdoors.

She would spend days in the bowels of Lincoln Hall of Justice Clerk's Office, pulling cases she found on the Court of Appeals, challenging Termination of Parental Rights in Wayne County where Jennifer Granholm submitted the exact same x-rays, in case after case.

I can recall seeing at least eight case files where the same evidence, and arguments were submitted, as templates for Termination of Parental Rights.

CHILD REMOVAL LAWS ARE UNCONSTITUTIONAL, HURT MICHIGAN FAMILIES, ACLU CHARGES IN FEDERAL LAWSUIT

Consider this a recording of her name in the annals of history, Civil Rights, 2.0.

Starletta Banks v State of ... by on Scribd

I mastered their system, along with all their complex, financial fraud schemes.

I heeded her advice, but took it all to the next level.

Michigan Chronicle V.XXV

Granholm steals babies, protesters say Article from:Michigan Quarterly Review Article date:August 10, 2002Author:Bukowski, Diane

Bukowski, Diane Michigan Citizen 08-10-2002 Carrying signs reading, "F.I.A.: Families in Agony," a small but passionate band of protesters has dogged gubernatorial candidate Jennifer Granholm's steps in Detroit.

In torrential rains outside the Channel 7 candidates' debate in Southfield July 21, and again outside the Northwest Activities Center July 23, Starletta Banks, her mother Barbara Banks, friends and organizers of Unity for Parents and Children demanded the return of Starletta's three small children, taken by Granholm's representatives in the attorney general's office in 1999.

"In the year 2000 alone, 27,000 children across Michigan were taken from their families," said Karon Hamilton, state-wide chair of Unity for Parents and Children. "That's way up from the two years of 1997 and 1998, when 30,000 were taken."

She said a national movement of families is underway, who say state social work agencies like Michigan's Family Independence Agency (FIA) are unjustly pursuing child abuse charges in order to obtain federal bonuses for adoption of children in foster care.

 In August, that movement will come to Michigan with the traveling "Quilt of Tears," listing the names of children who have been taken.

Starletta's children, Darius Banks, now 8, and Danielle and Darren Austin, now 4 and 2 respectively, were taken into foster care after Starletta took Danielle to Henry Ford Hospital when she fell out of her mother's bed.

 Medical personnel at the hospital claimed Danielle's X-rays showed evidence of old healing fractures, but X-rays taken shortly thereafter at Children's Hospital and St. John's Macomb Hospital have shown no such fractures.

Despite the recommendations of all social workers and psychiatrists involved, that the children be returned, Wayne County Circuit Court Judge Patricia Campbell terminated Starletta's parental rights in 2000. Her actions were predicated on the recommendation of the attorney general's representative, Richard Karoub.

"I appealed to Jennifer Granholm in writing in 1999," said Starletta, "and I personally spoke with her outside the UPN 50 offices where she was speaking February 7, 2001. I gave her the newspaper articles from the Michigan Citizen and other documentation. She promised to help, but she has not. Many families have lost their precious children to this type of corruption that she has allowed to go on."

Starletta lost a court battle earlier this month after her court-appointed attorney failed to show up for oral arguments in front of the appellate court, but she has since filed a well-researched letter-perfect motion for re-hearing, citing numerous legal precedents.

"I work midnights, and I get no sleep," said Starletta," because every morning at 7 a.m. I am doing my paperwork, because I have to get my babies back."

 Family friend Irwin Johnson, picketing with the Banks family, said, "In Detroit and across the nation, it boils down to a racial issue. How can Black kids be over 50 percent of the foster care system, but make up only 20 percent of the population?"

Leaving the Northwest Activities Center, Attorney General Granholm would not get out of her car or talk to Starletta and the protesters. The media spokesperson from Attorney General Granholm's office, Genna Gent, said, "I can tell you that the Attorney General immediately turned those documents over to our Children and Youth Services Division and asked them to look into it right away. However, both the trial court and the appellate court have already ruled on the case, and the Attorney General cannot overturn court rulings. Because there is a request for a re-hearing, she cannot comment further. But she does take such concerns of constituents very seriously."

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Michigan's Dark Ages in Child Welfare

Michigan has a long and illustrious history of fraud in child welfare.

During the dark ages of Michigan Child Welfare, (1996 c, - present) Medicaid fraud grew to become the destructive monster lurking in the shadows of a regulatory environment which is non-existent. .

In Wayne County, in the early years of Michigan's dark ages, there was an Assistant Attorney General by the name of Jennifer Granholm who would prosecute child abuse cases over at Lincoln Hall of Justice.

One day, Prosecutor Granholm successfully advocated for the termination of parental rights for a young lady by the name of Starletta Banks

Starletta Banks had her parental rights terminated because, according to Assistant Attorney General Granholm, she had caused her child to have broken bones.

X-Rays were presented to support the charges.

Starletta Banks strongly denied the claims that she hurt her child.  She was so dedicated to prove she did not harm her child she realized the x-ray was that of a child much older than her child.  She began to investigate.

Starletta Banks began to make daily visits to the clerk's office in the basement of the Lincoln Hall of Justice to pull case files of parents who had filed appeals to their own termination of parental rights.

What she found was stunning.

Every case contained the exact same evidence to support the termination of parental rights.  It was the exact same x-ray used to terminate her parental rights and put her children up for adoption.

I saw the files, too, but I took my investigation a step further and discovered Michigan's horrific practice of Medicaid fraud in child welfare.

Assistant Attorney General Jennifer Granholm eventually became Governor and gloriously ruled over the apex of the dark ages in Michigan's child welfare where many children were repeatedly raped, tortured, attempted suicide multiple times, experienced numerous heart attacks and starved.

She knew about it.  She did nothing about it.

Special Report: Shadow of Doubt

CALHOUN COUNTY, Mich. (NEWSCHANNEL 3) - An I-Team investigation uncovers the child abuse convictions of dozens of people in Michigan are now being called into question.

And the tragic death of a three-year-old little girl has opened up new conversations about whether innocent people are sitting in prisons for crimes they did not commit.

The calls to 9-1-1 her family made July 28, 2011 give a glimpse into the last hours of 3-year-old Baylee Stenman's life.

"And what happened," the operator asks. "She bumped her head," says the caller.

Now, four years later Leo Ackley is in prison for her murder. But there are new questions about his guilt.

"Just being here is embarrassing, the crime itself, obviously nobody wants to be labeled as that," Ackley told us by phone from jail.

Ackley, who was dating Baylee's mother at the time, is now serving a life sentence without parole. But his family says what he's accused of never made sense.

"Him being innocent, I never believed you could convict an innocent person and they have found a way to do so and apparently more than just my child," says Ackley's mother Linda Byrd.

Ackley's case is now in front of the Michigan Supreme Court which is deciding if he should get a new trial.

"Leo's case is almost a 100% classic shaken baby, abusive head trauma type case. No witnesses witnessed any abuse, all the evidence is established by medical testimony," says Ackley's attorney Andrew Rodenhouse.

Calhoun County Medical Examiner Joyce deJong testified at trial that Baylee died from severe head trauma and ruled she was murdered.

But Ackley's family and Rodenhouse have cast doubts on that determination, and asked another doctor to review the medical records who says the injuries most likely happened from an accidental fall.

Rodenhouse says this case is shining a spotlight in Michigan on shaken baby cases, also now called abusive head trauma cases.

Since the 1970's if a medical examiner saw a child had three injuries, swelling of the brain, bleeding on the surface of the brain and bleeding in the eyes, they automatically ruled the child was murdered.

"What we've learned is actually there are a lot of causes for those symptoms, both accidental and diseases. There's just a lot of questions now about how accurately we can diagnose shaken baby syndrome or abusive head trauma," says Caitlin Plummer with the Michigan Innocence Clinic.

The highly regarded Innocence Clinic in Ann Arbor has been advocating for Ackley and is now looking into a dozen other child abuse cases in Michigan including two more in Calhoun County.

But despite the uncertainty behind it, prosecutors and medical examiners are still using the shaken baby diagnosis to put people behind bars.

"Even if you didn't have any criminal record, or any history of abuse, if you were the last one with this baby, the baby collapses and the baby has these three symptoms, there's a very good chance you're going to be accused of abusing the baby," says Plummer.

"The only evidence they had, basically to me, was that I was the last one with him, and I took him to the hospital," says Sean Brown who was convicted of killing his own son in 2010.

The I-Team has confirmed Brown's conviction in Calhoun County is one the Innocence Clinic is looking into. Prosecutors claimed Brown shook his child causing severe head injuries.

"I would just hope that in my case, the truth comes out, that I'm an innocent person and I find out what happened to my son," says Brown.

Sources tell us the Innocence Clinic is also looking into the Calhoun County case of Tonia Miller, who was convicted in 2001 of killing her eleven-week-old daughter.

Calhoun County Prosecutor David Gilbert declined to interview with us on this issue because he said he had some of these types of cases currently being appealed.

But Kalamazoo prosecutor Jeff Getting says attitudes are changing.

"I suspect there's going to be a lot of litigation over this and rightfully so. The law evolved, medicine evolves, this isn't 1985 and we shouldn't ignore what we've learned since then," says Getting.

Dr. deJong is also the medical examiner for several other counties, including Kalamazoo.

Just last year in a case similar to Ackley's in Wexford County, deJong ruled 19- month old Kalla Fisher's head injuries showed she was murdered, her father David Ferris was arrested.

But the case was thrown out after other doctors reviewed the case. One of them was the Oakland County Chief Medical Examiner Dr. L.J. Dragovic, who wrote, "the leap to such a conclusion is a result of an incomplete and inadequate assessment… in this case."

"When you have a forensic pathologist that is just so stuck on their side and is unwilling to consider there is an alternate causation to these types of injuries it's really hard to hold them as being a true expert," says attorney Andrew Rodenhouse.

"If this is what had to happen for prosecutors to stop doing this, then he'll accept it that he was the reason, that this all gets squashed. Nobody else can get accused or convicted or sent to prison," says Leo Ackley's mother Linda Byrd.

Dr. deJong, Calhoun County Medical Examiner sent this statement Tuesday: "I am not aware of "many" cases and convictions unraveling. Our approach to the investigation of the sudden and unexpected death of anyone, including children, is methodical and based upon national standards. I have never thought that abusive head trauma could be determined solely on what you describe as "the traditional three indicators of swelling of the brain, bleeding on the surface of the brain and bleeding in the eyes". These findings may exist in children with injuries inflicted by another, but they may also be found in accidental trauma. Differentiating accidental injuries and natural disease processes from inflicted injuries is significantly more complicated and involved than simple recognition of brain swelling, hemorrhage and retinal hemorrhage. Our practice has always been to complete thorough investigations in to the circumstances of the death, evaluate for natural diseases and injuries, consult experts in forensic neuropathology, and after evaluating all information available, determine the cause and manner of death. Efforts by reputable organizations to ascertain convictions are appropriate are valuable to our society."

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Transposable Privatization Models: Engler, Clinton Foundation, MSU & Child Welfare Fraud

It is moments such as this, that makes me melt, and he knows it.

It is just unfortunate that I had to wait for Schuette to run for Governor to actually do something...unless he has been working behind the scenes.  Still sniffing around on that verification.

Engler is back, and he has been marked.

Allow me to introduce to the world, the godfather of privatization, the one, the only, John Engler.

AstraZeneca, The Policy Pimps Of Medicaid Fraud

Rumble In Detroit: Duggan v. Engler

Cummings & Gowdy Got A Flat Out "No" From Snyder On His Fraudulent Flint Testimony

Here is a synoptical overview of Engler:

John Engler & Bill Clinton, MSU

He came into Michigan with a bunch of big time corporate money to finance his campaign to be elected as Governor so he could sell off the state government service operations back to the corporations who funded his campaign, so he could be hired by them when he was term limited because he had planted all his people and policies and politicians in the state departments and agencies who handed out the contracts to the corporations who funded his campaigns and pay him, now, lobbying fees.

This is the world's first privatization model.

I recall the day he just up, and shut down residential institutions.

You woke up to see hundreds of individuals who were institutionalized their entire lives, wondering aimlessly on the streets, without medication, aged, disabled, old, and young.

It was quite the horrific site at 8 mile and Greenfield.

He and his corporate buddies got together and figured out that non-profits do not pay taxes, and, in particular, religious non-profits are even more secretive which means you can just take all the money you want and never get caught when you privatize child welfare services.

He sold off Michigan's children's legacies to the highest bidder by denationalizing, or rather, privatizing human services to "garner the best interests of the child" all around the world, starting with the Child Protective Services Model.

Engler led the way to hedge human capital with the blessings of the tax exempt god because this was the Bush era of faith-based funding, the new federal campaign slush fund machine for churches to pump out their privatization propaganda and the vote.

This was the beginning of the era of what I like to call "Pastor Pimp and Reverend Pork Chop' that broughtforth the phenomena of the megachurch.

A megachurch, more than likely built in Detroit, in what was and still is considered the mightiest congressional voting district, due to its civil rights, music, automobile history, and geographic location of an international trade border, water ways, grand trunk railroads and freeways, as a representation of community power temples, contolling the vote, the candidates and eventually the elected official by distracting them with pretty shiny things if they tried to join their privatization big money making clubs.

He re-invigored the residuals of peculiar institution with his PERM model, in the splendor of pilfering the coffers of the children's trust funds through Medicaid fraud in child welfare and the churches did not say a damn thing, except for thank you when they got their faith-based funding.

(Side note:  The Michigan acronym PERM was fungible with the federal Payment Error Rate Measurement (PERM), you know, to throw off anyone who even dared think of calling out fraud to make people think you were crazy.)

Michigan Conservative Welfare Reform 1995 by Beverly Tran on Scribd

After his term, Engler did a quick, "peace out" and left the state, that had a budget surplus, on the verge of bankruptcy, diffusing the privatization model all around the nation, and eventually, all over the world.

The world faith-based funding slush fund is warehoused in USAID of the State Department.

Engler sold Michigan's child welfare services to private corporations through contracts, setting up the quagmire of the Attorney General's conflict of interest in contemporaneously advising and advocating child welfare agencies in court.

In Wayne County, only the Attorney General prosecutes child abuse and neglect cases.

Enter Jennifer Granholm.

She got with the Clinton Foundation and her gurl, Hillary, to set up the very first, transposable model of privatizing child welfare fraud services under ASFA, and ran that socioeconomic experiment, right here in Detroit because no one had the sophistication to figure out what was going on but me.

The mortgage foreclosure fraud scheme hustle models were simaltaneously also launched in Detroit.

They ran it through the Michigan Democratic Party.

The Michigan Republican Party was making their dolla's holla's through their faith-based NGOs by promoting the Religious Freedom Restoration Act, that I worked on in dealing with parental rights, when I began to research and found out that the state was complicit in a corporate takeover.

See, it is like this, Michigan, set in motion by Engler's Type III Transfers with an Executive Order, with the finalizing stroke of Grahholm's pen, reorganized state government, put everything in the hands of a corporation, decentralizing executive powers, making governmental muddling to the likes of walking through a sewer, at night, with no lights nor protective equipment, for miles, not knowing if or when you would ever get out.

Not all governmental docs were online nor were federal, state or local governments online to the capacity of today, so I hope you appreciate the picture of what I went through to get this intel.

I was the first person to FOIA data extrapolation of county expeditures in child abuse and neglect court cases from the State.

I still have the original data, too.

They thought I was crazy, but worked with me.

I ran that stuff in my own spline models and I found the patterns.

Wayne County was running child welfare fraud operation to the tunen of $100 million a month and no one said a word, except for Brendan Dunleavy, former Wayne County Auditor General.

Exit Granholm, literally.  She took off to California and, as the article below presents it, Jenny from the Block was a bit too smart to take over as head of MSU because she sees me coming.

We shall leave it like that for now.

Engler did one more thing before he left the Office of Governor; he set up a network model in Michigan State University to run his corporate operations.

Blanchard, the Governor before Engler, was not that sophistocated in fraud schemes, but was eventually appointed as U.S. Ambassador to Canada, you know, to execute a transporting stuff model someone came up with and told him to make it happen, back and forth across the border, under the Clinton Administration.

But I am getting a bit ahead of the investigation and the tale of Michigan stealin'.

MSU was structuring not just child welfare policy and programs for the State of Michigan, it was also running programs and controlling resources, with United Way and Salvation Army linked up (that I will tell that story later or you can show me whacha got and pull PACER).

MSU was also running some bogus ass child welfare operations funneling money to questionable Russian enterprises (or Israeli because it is always the same people who go back and forth, restructuring each time they get busted stealin' like Catholic Charities).

Anyway, I digress because I am getting too excited.

Back to Engler, Clinton and Granholm.

Remember that time I told you the tale about University of Southern California, PriceWaterhouseCoopers and the Emergency Manager Law of Michigan, that next leg in the privatization model to take over government?

Well, if you do not remember, or are just a first time visitor, or if you drowning in your own cognitive dissonance, you can click here ====> for a reminder.

The Emergency Manager law was such a spectacular hit in the corporate, privatization world, that it eventually was implemented on the federal, and international levels which I will go into later, or you can just go through my archives, which brings us back to the article, below, and the resurrection of Engler.

The same university takeover model that was used to establish the USC PriceWaterhouseCooper School of Public Policy that came up with the land bank takeover model that Dan Kildee spearheaded, conjured up the Detroit Land Bank Authority, also came up with Michigan's public assest forfeiture Emergency Manager Law, is the same university takeover model that was implemented at Michigan State University.

MSU is and always has been the think tank for Michigan government, and so far, from what I have observed, is bigger than the Jerry Sandusky, Penn State horrors, which dealt with foster kids and child welfare fraud.

MSU was the place that came up with the Michigan Election Commission models because Chris Thomas told me so.  He told me they were students who put the election system together because they did not have to pay them.  I shall assume someone who negotiated the deal kept and split the federal funding for it.

There is much more to come because I truly cannot wait to see how Engler is going to pull himself out of this trick bag due to the fact that the Clinton Global Initiative University was never incorporated, and its Michigan Charity section filings are all jacked up, too.

The future always unlocks the past and revenge is a dish, best served cold.

I am putting my money on Schuette to do the right thing and serve me, at my pleasure, in the most public fashion.

The moral of the story shall always be, "Do not be mean to my Sweetie".

Former Gov. John Engler to be Michigan State's interim president

Michigan State University will name former Michigan Gov. John Engler to be interim president, multiple sources with knowledge of discussions told the Free Press.

Engler, a Republican, is a MSU graduate. He is expected to be named to the position at a special 9 a.m. MSU board meeting Wednesday.

Also coming on board is another former Michigan governor, Jim Blanchard, a Democrat, who will be named as a senior adviser. Blanchard is also a MSU graduate.

Board members believe that by adding both Engler and Blanchard - former leaders of both major political parties in Michigan - any concerns about politics will be muted.

Read more:

Secchia sponsored dinner for MSU investigator

MSU's Izzo under microscope amid allegations

MSU trustees to meet again Wednesday

Engler will be in place while the board conducts a nationwide search for the replacement to Lou Anna Simon, who resigned last week in the fallout of the Larry Nassar case.

She made the announcement hours after a judge sentenced Nassar to 40 to 175 years in prison as part of a plea deal on seven counts of first-degree criminal sexual conduct involving more than 156 girls and women over more than two decades.

She said in her resignation statement there was no cover-up at MSU.

"The survivors’ accounts are horrific. They are tragic, heartbreaking, and personally gut-wrenching. I take solace that many victims have indicated that the opportunity to confront Nassar is a step toward healing. I am proud of the exceptional work of the Special Victims Unit led by Lieutenant Andrea Munford with the steadfast leadership of Chief Dunlap. I am proud of my support of their work even though the results have been very painful to all who watched," Simon said.

After Simon resigned, there were a number of names raised to the board as possible interim presidents, including Engler, Blanchard and former Michigan Gov. Jennifer Granholm.

In a tweet shortly after Simon resigned, Granholm said it wouldn't be her.

"Not me, but I’m confident they will find a strong, clear leader. For the sake of current and future Spartans, let’s hope so."

Also raised as a possible interim choice was former Grand Valley State University President Mark Murray, who also served as president of Meijer, Inc. Murray told board members he wasn't interested, sources said.

Blanchard and Murray were all mentioned as a possible MSU president when Peter McPherson left in 2004 and Simon was promoted from provost to president.

But as MSU graduates and top executives of a large bureaucracy, Engler and Blanchard are natural picks, and will appease both the Republicans and Democrats on the MSU board of trustees, which has a 4-4 partisan split.

Engler, 69, has been a longtime political presence in Michigan. He was the youngest person elected to the state House of Representatives in 1970 at the age of 22, where he served until 1979, leaving after winning a seat in the state Senate and serving as the iron-fisted Senate Majority Leader.

He scored a razor thin victory over then incumbent Governor Blanchard in 1990 and stayed in the state's top job through the end of 2002. After leaving the job, he moved to Washington where he served as president and CEO of the National Manufacturers Association and then the head of the Business Roundtable, a national organization of business leaders. He retired last year and has a home in Laingsburg with his wife Michelle. His triplet daughters have all recently graduated from college.

After losing his reelection bid in 1990, Blanchard became the U.S. Ambassador to Canada under President Bill Clinton and later became a partner in the Washington DC-based law firm of DLA Piper. He ran for governor again in 2002, but lost to then Attorney General Jennifer Granholm, who would then go on to win two terms as Michigan's governor.

The choice was applauded by both politicians and people who have worked with the men.

"John Engler is the right choice to be Michigan State University's interim president," said Speaker of the House Tom Leonard, R-DeWitt Township. "He is a strong leader with a proven track record of reform, and the school needs someone who is able to come in from the outside, stand up to the status quo and make immediate changes."

David Doyle was the chairman of the Michigan Republican Party while Engler was governor. While he was surprised that Engler was the choice, given the partisan make-up of the board, "I think he'll do a great job."

Voting is beautiful, be beautiful ~ vote.©

An Introduction To The Michigan Emergency Manager Law & Jennifer Granholm - Michigan Continuity of Government Initiative 2007 Innovations Awards Program & FEMA Presidential Decision Directive 67

Jennifer Granholm & Hillary Clinton

These pearls of wisdom were gifted to me by a cyber-mermaid.

More background on the Human Services Models implemented under ASFA and Whitewater.

The program was created in response to Governor Jennifer Granholm’s recognition of the need for comprehensive planning to ensure that the critical and essential functions of Michigan state government continue to operate in the event of an emergency. In addition, federal guidance, including Federal Preparedness Circular 65 and Presidential Decision Directive 67 provide guidance for states to conduct continuity planning activities.

2007 Innovations Awards Program

APPLICATION

CSG reserves the right to use or publish in other CSG products and services the information provided in this Innovations Awards Program Application. If your agency objects to this policy, please advise us in a separate attachment to your program’s application.

ID # (assigned by CSG): 07-MW-05MICONTINUITY

Please provide the following information, adding space as necessary:

State: Michigan

Assign Program Category (applicant): Government Operations (Use list at end of application)

1. Program Name – Michigan Continuity of Government Initiative

2. Administering Agency – Department of Management and Budget (DMB), Facilities Administration, Security and Emergency Management Section

3. Contact Person (Name and Title) – Jason P. Nairn, Administrator

4. Address – Joint Operations Center, 615 W. Allegan St., Lansing, MI 48933

5. Telephone Number – 517-335-6735

6. FAX Number – 517-241-5639

7. E-mail Address – nairnj@michigan.gov

8. Web site Address – www.michigan.gov

9. Please provide a two-sentence description of the program.

This project, now known as the Michigan Continuity of Government Initiative (COGI), is an interagency enterprise-wide effort to assure that all critical governmental functions can be resurrected within 12-24 hours of an emergency or service disruption. The project has culminated in an online planning tool capable of guiding agencies through the planning process and hosting their plans via a secure, fully backed-up, non-proprietary web application.

10. How long has this program been operational (month and year)? Note: the program must be between 9 months and 5 years old on April 2, 2007, to be considered.

In April 2003, Governor Jennifer Granholm directed the Michigan Department of Management and Budget to begin work on the development of a comprehensive plan to ensure that critical government services could and would continue to function in the event of an emergency. Since then, Michigan’s state agencies have worked together to create plans for their agencies. This effort has culminated in the Michigan Continuity of Government Initiative and the associated web application, which is now live and in use.

11. Why was the program created? What problem[s] or issue[s] was it designed to address?

The program was created in response to Governor Jennifer Granholm’s recognition of the need for comprehensive planning to ensure that the critical and essential functions of Michigan state government continue to operate in the event of an emergency. In addition, federal guidance, including Federal Preparedness Circular 65 and Presidential Decision Directive 67 provide guidance for states to conduct continuity planning activities.

The program was designed to provide a plan for dealing with emergency shutdown of primary facilities, but while addressing this problem, the resulting plan has become valuable in other areas including IT system planning, identification of critical government services, identification of critical interdependencies among departments, and budget planning.

12. Describe the specific activities and operations of the program in chronological order.

Michigan began the planning process in April 2003. The Michigan Department of Management and Budget led state agencies through a planning process that included the following activities in chronological order:

a. Initial Kick-off Meeting and Development of Agency Action Plans

b. Development of the Definition of a Critical Function

c. Agency Business Continuity Plan Development

d. Development of a Final Format which Led to the Web Application

e. Acquisition of Grant Funding for Programming

f. Retention of a Professional Consultant to Review Planning Effort

g. Retention of a Professional Programming Engineer

h. Web Application Development

i. Web Application Roll-out

j. Agencies Populate Business Continuity Plan Data on Web

13. Why is the program a new and creative approach or method?

It is believed to be a unique approach nationally, for the following reasons:

a. The system is designed to provide 24/7 hotsite access to Michigan’s Continuity of Government Plan via secure internet connection.

b. The system is designed using non-proprietary SQL-based programming so that the application can evolve with new planning paradigms (i.e. pandemic flu, etc.) without the need for costly proprietary programming and maintenance contracts.

c. The system was designed to work in conjunction with GIS-based mapping systems. Critical functions are mapped from information in the database and then related to geographical locations so that emergency managers can immediately understand the effects of an emergency on critical functions of state government.

d. The system represents an enterprise-wide approach to continuity planning, encompassing all IT applications on which critical functions are dependent and their associated hardware and software systems.

e. The system has built-in accountability tools to ensure that agencies are conducting their planning and updating activities effectively. For instance, in the agency plan title page, which lists agencies that have built plans, agency names turn red if an agency has not updated their plan in the past 90 days. The system administrator can also review an edit log which shows what specific changes were made.

14. What were the program’s start-up costs? (Provide details about specific purchases for this program, staffing needs and other financial expenditures, as well as existing materials, technology and staff already in place.)

The planning group which worked to develop the continuity plan for Michigan was a group made up of employees from agencies who were determined by their Directors to be in a position to understand their department’s operations well enough to complete the task. The planning group worked on this project in addition to their normal duties. Funding for professional programming engineering and system software and hardware came from grants which were acquired under the State Homeland Security Grant Program. The total start up costs funded by these grants was $140,000.00. Approximately $60,000.00 of these grants was used to purchase servers required to provide the hosted site and an off-site hot backup. Staff that maintains and updates the website is part of DMB’s Security and Emergency Management Section and they perform system maintenance and administration as part of their duties. Hosting of the web application and server maintenance is provided by the Michigan Department of Information Technology which bills its services to the Department of Management and Budget.

15. What are the program’s annual operational costs?

The annual cost of the program, not counting personnel who are assigned to other duties as well is approximately $75,000.00. This cost is associated with the hosting of the web application and maintenance of the backup servers.

16. How is the program funded?

The program is currently funded through building occupancy charges. The DMB collects building occupancy charges from tenant agencies for the maintenance and operation of state office buildings and support facilities in which state agencies operate. As the continuity plans are intended to prepare for the need to relocate and operate critical agency functions if a primary facility is no longer available, it is appropriate to fund this program from these charges.

17. Did this program require the passage of legislation, executive order or regulations? If YES, please indicate the citation number.

No, it was a directive to DMB from the Governor. However it is thought that an Executive Order would institutionalize the effort in Michigan State Government and appropriate language for an executive order or executive directive is being developed for review by the Executive Office.

18. What equipment, technology and software are used to operate and administer this program?

Two web servers, two SQL servers, IT network, and web application.

19. To the best of your knowledge, did this program originate in your state? If YES, please indicate the innovator’s name, present address, telephone number and e-mail address.

Yes. Project lead has been:

Jason P. Nairn

Michigan Department of Management and Budget

Security and Emergency Management

Joint Operations Center

615 West Allegan Street

Lansing, Michigan 48933

Phone: 517-335-6735

nairnj@michigan.gov

20. Are you aware of similar programs in other states? If YES, which ones and how does this program differ?

Yes. Most states have continuity programs. It is not believed that this type of approach is being used elsewhere. However, Michigan representatives have worked with other states to collaborate and assist with continuity planning. We had extensive discussions and video conferencing with the State of Oregon.

21. Has the program been fully implemented? If NO, what actions remain to be taken?

No. Data is still being input by agencies to complete their individual business continuity plans. In addition, we are waiting to hear on grant funding that will allow us to complete the mapping portion of the application. However the application can function without the mapping capabilities which can be handled manually in the emergency operations center.

22. Briefly evaluate (pro and con) the program’s effectiveness in addressing the defined problem[s] or issue[s]. Provide tangible examples.

The program has provided Michigan with a roadmap for planning not only for emergencies, but also for the future of the state’s technological and organizational infrastructure. As we have made strides toward the ability to recover our critical functions within 12-24 hours of a disruption to normal business, we have also found that the exercise of continuity planning has greatly improved our knowledge of the core functions of state government. This information has been and is being used to prioritize efforts in the area of IT systems, and planning for the continuation of critical services in a time of financial challenges. However, the true value of the project will always be the ability to respond to emergencies and recover critical functions of government in a way that protects the health, welfare and subsistence of Michigan’s citizens.

23. How has the program grown and/or changed since its inception?

At the onset of the planning process, federal guidance combined with best practice guidance from various non-governmental organizations provided the elements which were to be followed in the development of an adequate continuity plan. There was, however, little information available regarding the final format of the plan. In the beginning and throughout the early months of the planning effort we relied on templates and created paper-based plans. It soon became apparent that it would be administratively burdensome to keep these plans updated as essential staff changed and plans evolved. In addition, a consultant hired to review the planning effort and provide recommendations indicated that much of the information was non-essential to the mission. As such, the concept of the web-based planning and hosting tool developed. This allowed us to ensure that the pertinent information was provided in the plans, provided the ability to upload agency-specific supporting documents, and allowed us to monitor agency’s progress in planning and updates.

24. What limitations or obstacles might other states expect to encounter if they attempt to adopt this program?

It is difficult, though not impossible, to plan on an enterprise-wide basis. It requires first the cooperation of all departments with critical functions within state government, second the full cooperation of IT administrators, and finally a thorough understanding of the functions of departments and determination of what is critical. Here are a few of the difficulties that could impact a state’s planning effort:

• Determining what is “critical” - Defining what is critical (and what isn’t) can be an arduous task which can alienate some who are determined not to meet the definition of critical. In Michigan, this was accomplished by mutual agreement on a definition then by creating a method to review agency submittals and discuss those that were controversial in the planning group.
• Gathering a team with the “right stuff” - It is essential that agency representatives selected to sit on the planning group understand their agencies operation well enough to distinguish the critical from the not-so-critical, and have the authority to hold internal meetings at a high-level to make critical planning decisions.
• Agreeing upon the “Look and Feel” – The final format of the plan is something that has to be agreed-upon in advance. If one agency is expecting a web tool, and another a binder, and still a third a .pdf file on a jump drive, it will be difficult to build the plan.
• The Role of IT – The IT people can cause a plan to sink or swim. Since everything has an IT component these days, bringing the right IT people in at the right time will mean the difference between a plan that works, and a plan that provides an alternate facility without critical data…

2007 Innovations Awards Program

Program Categories and Subcategories

Use these as guidelines to determine the appropriate Program Category for your state’s submission and list that program category on page one of this application. Choose only one.

Infrastructure and Economic Development

• Business/Commerce
• Economic Development
• Transportation

Government Operations

• Administration
• Elections
• Public Information
• Revenue

Health & Human Services

• Aging
• Children & Families
• Health Services
• Housing
• Human Services

Human Resources/Education

• Education
• Labor
• Management
• Personnel
• Training and Development
• Workforce Development

Natural Resources

• Agriculture
• Energy
• Environment
• Environmental Protection
• Natural Resources
• Parks & Recreation
• Water Resources

Public Safety/Corrections

• Corrections
• Courts
• Criminal Justice
• Drugs
• Emergency Management
• Public Safety

Save in .doc or rtf. Return completed application electronically to innovations@csg.org or mail to:

CSG Innovations Awards 2007

The Council of State Governments

2760 Research Park Drive, P.O. Box 11910

Lexington, KY 40578-1910

Contact:

Nancy J. Vickers, National Program Associate

Phone: 859.244.8105

Fax: 859.244.8001 – Attn: Innovations Awards Program

The Council of State Governments

E-mail: nvickers@csg.org

This application is also available at www.csg.org, in the Programs section.

ADDITIONAL INFORMATION:

Michigan’s Continuity of Government Initiative

INTRODUCTION

In early 2003, Governor Jennifer Granholm directed the Michigan Department of Management and Budget to begin work on the development of a comprehensive plan to ensure that critical government services could and would continue to function in the event of an emergency. Critical functions are defined as “direct public services which, if interrupted, would immediately affect the life, health, safety and/or subsistence of Michigan’s citizens”. This project, now known as the Michigan Continuity of Government Initiative (COGI), has developed into an interagency enterprise-wide effort to assure that all critical governmental functions can be resurrected within 12-24 hours of an emergency or service disruption. The plans are developed and maintained on a live interactive website capable of being accessed from anywhere via computer and modem connection.

COGI Website

The COGI has resulted in the Michigan Continuity of Government Planning Website. It is believed that this web-based planning tool is a unique solution nationally in that it has been designed and built to be linked to Geographical Information Systems (GIS) for interface in Emergency Operations Centers during emergencies. Hosted on the Michigan.gov portal in a secure environment, the website provides agencies with the opportunity to develop and maintain detailed Business Continuity Plans (BCP’s) for their individual agency critical functions. These critical functions have been defined through a detailed process led by DMB involving all state agencies. The total number of functions meeting the definition of “critical function” for the continuity initiative is just under one-hundred (100) among the 20 departments of the Executive Branch. For each of these functions, a detailed plan is developed and maintained by the web application for access, manipulation and printing of plan information during training, exercises and / or emergencies.

Figure 1 – The initial screen of the Michigan Continuity of Government Website.

Figure 2 – Screen of the website application showing the structure of the Michigan Continuity of Government Plan (COG).

Figure 3 – Main website screen showing each agency plan. Web application automatically indicates if plans are being regularly updated.

As stated above, this planning tool is believed to be a unique solution in that it has been designed and built as a link to existing GIS capabilities in the Michigan State Emergency Operations Center (SEOC). Existing capabilities in Michigan allow emergency management coordinators to review data and information regarding emergencies and plot these geographically. By assigning physical locations to critical functions of government and by linking these locations in the mapping software to the planning website database, planners and responders can evaluate the impact of emergencies on critical functions of government. Michigan is currently showcasing this tool to other states and the federal government, and is planning, if funding is available, to provide this tool to local governments throughout the state, linking the state together via the GIS system.

Funding for the “initial build” of the web application was provided by federal homeland security planning grants, and additional funding is being sought to enhance the tool with more helpful features. These features include help functions, a glossary and sample data pages.

For more information about this project, including access to the website for review purposes, please feel free to contact us.

Thank you for your consideration!
========================================================================

FEDERAL PREPAREDNESS CIRCULAR
Federal Emergency Management Agency
Washington, D.C. 20472

FPC 65

---

July 26, 1999

TO: HEADS OF FEDERAL DEPARTMENTS AND AGENCIES

SUBJECT: FEDERAL EXECUTIVE BRANCH CONTINUITY OF OPERATIONS (COOP)

1. PURPOSE: This Federal Preparedness Circular (FPC) provides guidance to Federal Executive Branch departments and agencies for use in developing viable and executable contingency plans for the continuity of operations (COOP). COOP planning facilitates the performance of department/agency essential functions during any emergency or situation that may disrupt normal operations.

2. APPLICABILITY AND SCOPE: The provisions of this FPC are applicable to all Federal Executive Branch departments, agencies, and independent organizations, hereinafter referred to as "agencies." While some of the language contained in this guidance focuses on planning for threats to the immediate Washington, D.C., area, the COOP elements outlined herein are for use at all levels of Federal Executive Branch organizations.

3. SUPERSESSION: The provisions of this FPC supersede:

1. Federal Response Planning Guidance 01-94, Continuity of Operations (COOP), dated December 4, 1994.


2. FPC 61, Emergency Succession to Key Positions of the Federal Departments and Agencies, dated August 2, 1991.


3. FPC 62, Delegation of Authorities for Emergency Situations, dated August 1, 1991.

4. AUTHORITIES:

a. The National Security Act of 1947, dated July 26, 1947, as amended.

1. b. Executive Order (EO) 12656, Assignment of Emergency Preparedness Responsibilities dated November 18, 1988, as amended.

c. Executive Order (EO) 12472, Assignment of National Security and Emergency Preparedness Telecommunications Functions, dated April 3, 1984.

1. Executive Order (EO) 12148, Federal Emergency Management, dated July 20, 1979, as amended.


2. Presidential Decision Directive (PDD) 67, Enduring Constitutional Government and Continuity of Government Operations, dated October 21, 1998.

5. REFERENCES:

1. Presidential Decision Directive (PDD) 62, Protection Against Unconventional Threats to the Homeland and Americans Overseas, dated May 22, 1998.
2. Presidential Decision Directive (PDD) 63, Critical Infrastructure Protection (CIP), dated May 22, 1998.


3. FPC 60, Continuity of the Executive Branch of the Federal Government at the Headquarters Level During National Security Emergencies, dated November 20,1990.


4. 41 Code of Federal Regulations (CFR) 101-2, Occupant Emergency Program, revised as of July 1, 1998.


5. 36 Code of Federal Regulations (CFR) 1236, Management of Vital Records, revised as of July 1, 1998.

6. POLICY: It is the policy of the United States to have in place a comprehensive and effective program to ensure continuity of essential Federal functions under all circumstances. As a baseline of preparedness for the full range of potential emergencies, all Federal agencies shall have in place a viable COOP capability which ensures the performance of their essential functions during any emergency or situation that may disrupt normal operations.

7. BACKGROUND: COOP planning is simply a "good business practice"�part of the fundamental mission of agencies as responsible and reliable public institutions. For years, COOP planning had been an individual agency responsibility primarily in response to emergencies within the confines of the organization. The content and structure of COOP plans, operational standards, and interagency coordination, if any, were left to the discretion of the agency.


The changing threat environment and recent emergencies, including localized acts of nature, accidents, technological emergencies, and military or terrorist attack-related incidents, have shifted awareness to the need for COOP capabilities that enable agencies to continue their essential functions across a broad spectrum of emergencies. Also, the potential for terrorist use of weapons of mass destruction has emphasized the need to provide the President a capability which ensures continuity of essential government functions across the Federal Executive Branch.
To provide a focal point to orchestrate this expanded effort, PDD-67 established FEMA as the Executive Agent for Federal Executive Branch COOP. Inherent in that role is the responsibility to formulate guidance for agencies to use in developing viable, executable COOP plans; facilitate interagency coordination as appropriate; and oversee and assess the status of COOP capability across the Federal Executive Branch. Additionally, each agency is responsible for appointing a senior Federal government executive as an Emergency Coordinator to serve as program manager and agency point of contact for coordinating agency COOP activities.


8. OBJECTIVES: COOP planning is an effort to assure that the capability exists to continue essential agency functions across a wide range of potential emergencies. The objectives of a COOP plan include:

a. Ensuring the continuous performance of an agency�s essential functions/operations during an emergency;

b. Protecting essential facilities, equipment, records, and other assets;

c. Reducing or mitigating disruptions to operations;

4. Reducing loss of life, minimizing damage and losses; and,


5. Achieving a timely and orderly recovery from an emergency and resumption of full service to customers.

7. PLANNING CONSIDERATIONS: In accordance with current guidance, a viable COOP capability:

• Must be maintained at a high level of readiness;


• Must be capable of implementation both with and without warning;


• Must be operational no later than 12 hours after activation;


• Must maintain sustained operations for up to 30 days; and,


• Should take maximum advantage of existing agency field infrastructures.

Agencies should develop and maintain their COOP capabilities using a multi-year strategy and program management plan. The 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.

7. ELEMENTS OF A VIABLE COOP CAPABILITY: At a minimum, all agency COOP capabilities shall encompass the following elements:

1. PLANS AND PROCEDURES. A COOP plan shall be developed and documented that when implemented, will provide for continued performance of essential Federal functions under all circumstances. At a minimum, the plan should:

(1) Delineate essential functions and activities;

1. Outline a decision process for determining appropriate actions in implementing COOP plans and procedures;


2. Establish a roster of fully equipped and trained emergency personnel with the authority to perform essential functions and activities;


3. Include procedures for employee advisories, alerts, and COOP plan activation, with instructions for relocation to pre-designated facilities, with and without warning, during duty and non-duty hours;

(5) Provide for personnel accountability throughout the duration of the emergency;

(6) Provide for attaining operational capability within 12 hours; and,

1. Establish reliable processes and procedures to acquire resources necessary to continue essential functions and sustain operations for up to 30 days.

b. IDENTIFICATION OF ESSENTIAL FUNCTIONS. All agencies should identify their essential functions as the basis for COOP planning. Essential functions are those functions that enable Federal Executive Branch agencies to provide vital services, exercise civil authority, maintain the safety and well being of the general populace, and sustain the industrial/economic base in an emergency. In identifying essential functions, agencies should:

(1) Identify all functions performed by the agency, then determine which must be continued under all circumstances;

(2) Prioritize these essential functions;

(3) Establish staffing and resources requirements needed to perform essential functions;

(4) Identify mission critical data and systems necessary to conduct essential functions;

(5) Defer functions not deemed essential to immediate agency needs until additional personnel and resources become available; and,

(6) Integrate supporting activities to ensure that essential functions can be performed as efficiently as possible during emergency relocation.

c. DELEGATIONS OF AUTHORITY. To ensure rapid response to any emergency situation requiring COOP plan implementation, agencies should pre-delegate authorities for making policy determinations and decisions at headquarters, field levels, and other organizational locations, as appropriate. These delegations of authority should:

(1) Identify the programs and administrative authorities needed for effective operations at all organizational levels having emergency responsibilities;

(2) Identify the circumstances under which the authorities would be exercised;

(3) Document the necessary authorities at all points where emergency actions may be required, delineating the limits of authority and accountability;

(4) State explicitly the authority of designated successors, referred to in paragraph 10d, to exercise agency direction, including any exceptions, and the successor�s authority to re-delegate functions and activities as appropriate;

(5) Indicate the circumstances under which delegated authorities would become effective and when they would terminate. Generally, pre-determined delegations of authority would take effect when normal channels of direction are disrupted and would terminate when these channels have resumed;

(6) Ensure that officials who may be expected to assume authorities in an emergency are trained to carry out their emergency duties; and,

(7) Specify responsibilities and authorities of individual agency representatives designated to participate as members of interagency emergency response teams.

d. ORDERS OF SUCCESSION. Agencies are responsible for establishing, promulgating, and maintaining orders of succession to key positions. Such orders of succession are an essential part of an agency�s COOP plan. Orders should be of sufficient depth to ensure the agency�s ability to perform essential functions while remaining a viable part of the Federal Government through any emergency. Geographical dispersion is encouraged, consistent with the principle of providing succession to office in emergencies of all types. Each agency should:

(1) Establish an order of succession to the position of Agency Head. A designated official serves as acting head of the agency until appointed by the President or relieved. Where a suitable field structure exists, appropriate personnel located outside the Washington, D.C., area should be considered in the order of succession;

(2) Establish orders of succession to other key headquarters leadership positions;

(3) Establish, for agencies organized according to the standard Federal regional structure, an order of succession to the position of regional director or equivalent;

(4) Identify any limitation of authority based on delegations of authority to others;

(5) Describe orders of succession by positions or titles, rather than names of individuals;

(6) Include the orders of succession in the vital records of the agency;

(7) Revise orders of succession as necessary, and distribute revised versions promptly as changes occur;

(8) Establish the rules and procedures designated officials are to follow when facing the issues of succession to office in emergency situations;

(9) Include in succession procedures the conditions under which succession will take place; method of notification; and any temporal, geographical, or organizational limitations of authorities;

(10) Assign successors, to the extent possible, among the emergency teams established to perform essential functions, to ensure that each team has an equitable share of duly constituted leadership; and,

(11) Conduct orientation programs to prepare successors for their emergency duties.

e. ALTERNATE FACILITIES. All agencies shall designate alternate operating facilities as part of their COOP plans, and prepare their personnel for the possibility of unannounced relocation of essential functions and/or COOP contingency staffs to these facilities. Facilities may be identified from existing agency local or field infrastructures, or external sources. Facilities shall 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, agencies are encouraged to consider cooperative interagency agreements and promote sharing of identified alternate facilities. Alternate facilities should provide:

(1) Immediate capability to perform essential functions under various threat conditions, including threats involving weapons of mass destruction;

(2) Sufficient space and equipment to sustain the relocating organization. Since the need to relocate may occur without warning, or access to normal operating facilities may be denied, agencies are encouraged to pre-position and maintain minimum essential equipment for continued operations at the alternate operating facilities;

(3) Interoperable communications with all identified essential internal and external organizations, critical customers, and the public;

(4) Reliable logistical support, services, and infrastructure systems, including water, electrical power, heating and air conditioning, etc.

(5) Ability to sustain operations for a period of up to 30 days;

(6) Consideration for the health, safety, and emotional well-being of relocated employees; and,

(7) Appropriate physical security and access controls.

f. INTEROPERABLE COMMUNICATIONS. The success of agency operations at an alternate facility is absolutely dependent upon the availability and redundancy of critical communications systems to support connectivity to internal organizations, other agencies, critical customers, and the public. When identifying communications requirements, agencies should take maximum advantage of the entire spectrum of communications media likely to be available in any emergency situation. These services may include, but are not limited to: secure and/or non-secure voice, fax, and data connectivity; Internet access; and e-mail. Interoperable communications should provide:

(1) Capability commensurate with an agency�s essential functions and activities;

(2) Ability to communicate with COOP contingency staffs, management, and other organizational components;

(3) Ability to communicate with other agencies and emergency personnel; and,

(4) Access to other data and systems necessary to conduct essential activities and functions.

g. VITAL RECORDS AND DATABASES. The protection and ready availability of electronic and hardcopy documents, references, records, and information systems needed to support essential functions under the full spectrum of emergencies is another critical element of a successful COOP plan. Agency personnel must have access to and be able to use these records and systems in conducting their essential functions. Categories of these types of records may include:

(1) Emergency Operating Records. Vital records, regardless of media, essential to the continued functioning or reconstitution of an organization during and after an emergency. Included are emergency plans and directives; orders of succession; delegations of authority; staffing assignments; and related records of a policy or procedural nature that provide agency staff with guidance and information resources necessary for conducting operations during an emergency, and for resuming formal operations at its conclusion.

(2) Legal and Financial Records. Vital records, regardless of media, critical to carrying out an organization�s essential legal and financial functions and activities, and protecting the legal and financial rights of individuals directly affected by its activities. Included are records having such value that their loss would significantly impair the conduct of essential agency functions, to the detriment of the legal or financial rights or entitlements of the organization or of the affected individuals. Examples of this category of vital records are accounts receivable; contracting and acquisition files; official personnel files; Social Security, payroll, retirement, and insurance records; and property management and inventory records.

Plans should account for identification and protection of the vital records, systems, and data management software and equipment, to include classified or sensitive data as applicable, necessary to perform essential functions and activities, and to reconstitute normal agency operations after the emergency. To the extent possible, agencies should pre-position and update on a regular basis duplicate records or back-up electronic files.

h. TESTS, TRAINING AND EXERCISES. Testing, training, and exercising of COOP capabilities is essential to demonstrating and improving the ability of agencies to execute their COOP plans. Training familiarizes contingency staff members with the essential functions they may have to perform in an emergency. Tests and exercises serve to validate, or identify for subsequent correction, specific aspects of COOP plans, policies, procedures, systems, and facilities used in response to an emergency situation. Periodic testing also ensures that equipment and procedures are maintained in a constant state of readiness. All agencies shall plan and conduct tests and training to demonstrate viability and interoperability of COOP plans. COOP test, training, and exercise plans should provide for:

(1) Individual and team training of agency COOP contingency staffs and emergency personnel to ensure currency of knowledge and integration of skills necessary to implement COOP plans and carry out essential functions. Team training should be conducted at least annually for COOP contingency staffs on their respective COOP responsibilities;

(2) Internal agency testing and exercising of COOP plans and procedures to ensure the ability to perform essential functions and operate from designated alternate facility(ies). This testing and exercising should occur at least annually;

(3) Testing of alert and notification procedures and systems for any type of emergency at least quarterly;

(4) Refresher orientation for COOP contingency staffs arriving at an alternate operating facility. The orientation should cover the support and services available at the facility, including communications and information systems for exchanging information if the normal operating facility is still functioning; and administrative matters, including supervision, security, and personnel policies; and,

(5) Joint agency exercising of COOP plans, where applicable and feasible.

11. COOP IMPLEMENTATION: Relocation may be required to accommodate a variety of emergency scenarios. Examples include scenarios in which:

• An agency headquarters is unavailable and operations can shift to a regional or field location;


• A single agency facility is temporarily unavailable and the agency can share one of its own facilities or that of another agency; and,


• Many, if not all, agencies must evacuate the immediate Washington, D.C., area.

While any of these scenarios involves unavailability of a facility, the distinction must be made between a situation requiring evacuation only and one dictating the need to implement COOP plans. A COOP plan includes the deliberate and pre-planned movement of selected key principals and supporting staff to a relocation facility. As an example, a sudden emergency, such as a fire or hazardous materials incident, may require the evacuation of an agency building with little or no advanced notice, but for only a short duration. Alternatively, an emergency so severe that an agency facility is rendered unusable and likely will be for a period long enough to significantly impact normal operations, may require COOP plan implementation. Agencies should develop an executive decision process that would allow for a review of the emergency and determination of the best course of action for response and recovery. This will preclude premature or inappropriate activation of an agency COOP plan.

One approach to ensuring a logical sequence of events in implementing a COOP plan is time phasing. A suggested time-phased approach for COOP activation and relocation, alternate facility operations, and reconstitution follows:

a. PHASE I�ACTIVATION AND RELOCATION (0-12 HOURS)

• Notify alternate facility manager(s) of impending activation and actual relocation requirements;


• Notify the FEMA Operations Center (FOC), (202) 898-6100/1-800-634-7084, and other appropriate agencies of the decision to relocate and the time of execution or activation of call-down procedures;


• Activate plans, procedures, and schedules to transfer activities, personnel, records, and equipment to alternate operating facility(ies);


• Notify initial COOP contingency staff to relocate;


• Instruct all other emergency and non-emergency personnel on what they are to do;


• Assemble necessary documents and equipment required to continue performance of essential operations at alternate operating facility(ies);


• Order equipment/supplies, if not already in place;


• Transport documents and designated communications, automated data processing, and other equipment to the alternate operating facility(ies), if applicable;


• Secure the normal operating facility physical plant and non-moveable equipment and records, to the extent possible;


• Continue essential operations at the normal operating facility if available, until alternate facility(ies) is operational; and,


• Advise alternate operating facility manager(s) on the status of follow-on personnel.

b. PHASE II�ALTERNATE FACILITY OPERATIONS (12 HOURS � TERMINATION)

• Provide amplifying guidance to other key staff and non-emergency employees;


• Identify replacements for missing personnel and request augmentation as necessary;


• Commence full execution of essential operations at alternate operating facility(ies);


• Notify the FOC and all other appropriate agencies immediately of the agency�s alternate location, operational and communications status, and anticipated duration of relocation, if known; and,


• Develop plans and schedules to phase down alternate facility(ies) operations and return activities, personnel, records, and equipment to the primary facility when appropriate.

c. PHASE III�RECONSTITUTION (TERMINATION AND RETURN TO NORMAL OPERATIONS)

• Inform all personnel, including non-emergency personnel, that the threat of or actual emergency no longer exists, and provide instructions for resumption of normal operations;


• Supervise an orderly return to the normal operating facility, or movement to other temporary or permanent facility(ies) using a phased approach if conditions necessitate;


• Report status of relocation to the FOC and other agency points of contact (POC), if applicable; and,


• Conduct an after-action review of COOP operations and effectiveness of plans and procedures as soon as possible, identify areas for correction, and develop a remedial action plan.

12. RESPONSIBILITIES: The following responsibilities should be clearly outlined in agency COOP planning guidance and internal documents:

a. Each agency head is responsible for:

(1) Appointing an agency COOP program POC;

(2) Developing a COOP Multi-Year Strategy and Program Management Plan;

(3) Developing, approving, and maintaining agency COOP plans and procedures for headquarters and all subordinate elements, which provide for:

• Identification of agency essential functions;


• Pre-determined delegations of authority and orders of succession;


• Contingency staffing to perform essential functions;


• Alternate operating facilities;


• Interoperable communications, information processing systems and equipment; and,


• Protection of vital records and systems.

(4) Conducting tests and training of agency COOP plans, to include COOP contingency staffs, and essential systems and equipment, to ensure timely and reliable implementation of COOP plans and procedures;

(5) Participating in periodic interagency COOP exercises to ensure effective interagency coordination and mutual support;

(6) Notifying the FOC and other appropriate agencies upon implementation of COOP plans; and,

(7) Coordinating intra-agency COOP efforts and initiatives with policies, plans, and activities related to terrorism under PDD-62 and Critical Infrastructure Protection under PDD-63.

b. In addition, FEMA is responsible for:

(1) Serving as the Executive Agent for Federal Executive Branch COOP;

(2) Coordinating COOP activities of Federal Executive Branch agencies;

(3) Issuing COOP guidance, in cooperation with the General Services Administration, to promote understanding of, and compliance with, the requirements and objectives of governing directives;

(4) Chairing the COOP Working Group (CWG), which serves as the principal interagency forum for discussion of COOP matters such as policy guidance, plans, and procedures, and for dissemination of information to agencies for developing and improving their individual COOP plans;

(5) Coordinating Federal Executive Branch interagency COOP exercises; and,

(6) Conducting periodic assessments of Executive Branch COOP capabilities and reporting the results to the National Security Council.

13. DISTRIBUTION: This FPC is distributed to the heads of Federal department and agencies, senior policy officials, emergency planners, and other interested parties.

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