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!
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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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