Shelter from the storm

The elements of a COOP plan

The Federal Emergency Management Agency issued Federal Preparedness Circular 65 in June 2004 to give agencies a road map to creating effective continuity-of-operations plans.

From FPD-65, the Judiciary Emergency Preparedness Office identified six critical elements that a COOP plan must address:

Essential functions. Identify the core functions and activities of an agency, agency interdependencies and the resources needed to carry them out.

Orders of succession. For all key COOP positions, identify who is in charge and who takes that slot if the key person is unavailable.

Delegation of authority. Designate who has authority to carry out all the aspects of the COOP plan.

Alternate facilities. Identify facility requirements and possible alternate locations, both nearby and farther away, including notifying and relocating COOP personnel, as needed.

Interoperable communications. Identify key lines of communications that are needed, and alternative ways of maintaining contact if cell phones don't work, for instance, or computer networks are down.

Vital records and databases. Identify which information is critical to supporting essential functions, and ways and means of maintaining access to them, whether through the use of backups, relocation of IT resources, replication of records or other means.

William Lehman heads the Judiciary Emergency Preparedness Office, which was established to handle continuity-of-operations planning.

Zaid Hamid

Continuity-of-operations plans can protect vital functions in a crisis, but only ifagencies have done the groundwork

The attacks of Sept. 11, 2001, and this year's hurricane season are clear examples of the ripple effects a crisis can have on government operations.

The geographic scope of 9/11 was limited to lower Manhattan, the Pentagon and a field in western Pennsylvania, but the devastation touched all three branches of government'legislative, judicial and executive.

Hurricane Katrina devastated areas of three states, and that bigger geographical impact had a correspondingly larger effect on all levels of government.

Each crisis presented a test for agencies' continuity-of-operations, or COOP, plans.

After Katrina, the National Finance Center in New Orleans, for instance, which processes payroll for more than half a million federal employees all over the country, had to relocate its operations. But in a testament to the effectiveness of their plan, no one missed their checks.

Mixed success

Not every agency is prepared to perform so well. Although COOP has become a government priority, agencies have had mixed success in putting plans in place.

In October 1998, President Clinton issued Presidential Decision Directive 67, 'Enduring Constitutional Government and Continuity of Operations,' in response to the first World Trade Center bombing in 1993 and the Oklahoma City bombing in 1995. The directive ordered all federal agencies to prepare continuity-of-operations plans and gave the Federal Emergency Management Agency responsibility for providing guidance. COOP gained even more urgency after 9/11.

FEMA was transferred into the Homeland Security Department in 2003, but it kept its role as lead agency in COOP coordination and execution. In June 2004, FEMA issued revised guidance, Federal Preparedness Circular 65, that significantly expanded the factors agencies had to consider in developing their COOP plans, based on the lessons learned from Sept. 11.

Despite this emphasis, the government has been inconsistent in its preparations.

According to a survey by Larstan Business Reports earlier this year of 533 federal IT professionals, 67 percent of civilian agencies have a COOP plan. Military and intelligence agencies have fared better, with 81 percent of the intelligence and military combatant organizations saying they have a COOP plan and 86 percent of the military noncombatant agencies reporting having a plan in place.

FEMA declared in FPC-65 that 'COOP planning is simply a 'good business practice.' ' The 50-page document spells out the objectives of such plans'ensuring essential operations, reducing casualties and damages, protecting essential records and assets, and other aims.

The circular also spells out what a COOP plan needs in order to be viable, including:
  • The plan can be implemented regardless of whether there was warning of a crisis (the difference between a hurricane and a terrorist attack, for instance).

  • It can be implemented within 12 hours of activation.

  • It allows agencies to maintain vital operations for up to 30 days.

FEMA has created a working group, co-chaired by its Office of National Security Coordination and the DHS chief of staff, to help with COOP planning, department spokesman Larry Orluskie said.

'The working group gets together with all government departments to make sure their plans are all coordinated,' Orluskie said. 'There are overall plans for the overall government, then plans for the components, then plans within agencies and offices.'

FPC-65 applies only to executive branch departments and agencies'the bulk of the federal government'but the other two branches are using it as guidance in developing COOP plans of their own.

How to keep Congress running

In the aftermath of hurricanes Katrina, Rita and Wilma, Greg Hanson has been a very busy fellow.
Hanson, the assistant sergeant-at-arms and CIO of the Senate, is responsible for providing IT support to all 100 senators, not just in Washington but also in all their field offices.

'In a situation like the hurricanes, when offices are damaged or destroyed, we're helping to reconsistute them,' Hanson said. 'We're preparing after-action studies for all three of [the hurricanes].'

When it comes to planning in advance for disaster, however, Hanson can't take charge and make sure everything is prepared.

'The Senate is really decentralized,' he said. 'All the offices are responsible for their own plans.'

Instead, Hanson's office handles mission-critical enterprise systems. Since the Senate is only half of the legislative branch, he coordinates COOP preparations and testing with his counterparts on the House side. He also has plans in place for alternate computing facilities and replication of all mission-critical information.

'Replication is a lot different than backing up systems,' he said.

Backup records only provide a snapshot of point-in-time information, he explained, while replication includes all the background data that provides context.

'In the event that something were to happen ... we could have access to the information in near real time,' Hanson said.

The details of congressional COOP plans are not available to the public, Hanson said, but he shared a couple of observations.

'It's always good to be prepared with some equipment that's ready to be deployed, [but] you have to be creative in how to do it,' he said.

Keeping the wheels of justice turning

Hurricane Katrina closed federal courts in three states, and some of the courthouses will be unusable for some time.

The federal court system also falls outside FEMA's area of responsibility. The Administrative Office of the U.S. Courts, which runs the operations in the nation's 94 districts, including federal appeals and bankruptcy courts, has established the Judiciary Emergency Preparedness Office to handle continuity-of-operations planning.

Like the challenges facing Hanson in the Senate, JEPO has to work with each individual federal district court because they are autonomous, said William Leh- man, the head of JEPO.

At the same time, because the U.S. court system is dependent on the other branches of government'the executive for buildings and U.S. Marshals Service, for instance, and the legislative for statutory authority to conduct its work'close working relationships are a must, Lehman said.

'Judicial districts are set up in a way that the courts are capable of handling cases only in their own districts,' he said. JEPO has asked for and got legislation to let district courts, in emergencies, work outside their geographic limits.

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