Critical Continuity
Federal guidelines push government agencies to prepare for the worst
Last month, this column
addressed HSPD-20, which
mandates government agencies
to appoint a senior official at
the assistant secretary level as continuity
of government coordinator to prepare
plans, budgets and exercises to test continuity
planning, preparation and capability.
This month’s column highlights key
points, requirements and timelines associated
with the mandates set for continuity
of operations (COOP) and continuity of
government (COG) programs.
HSPD-20 is designed to ensure that
government agencies can initiate plans
with little or no notice in order to remain
open and ready to deal with terrorist,
manmade or natural threats and disasters.
This led to the development and release of
a new national continuity policy implementation
plan (NCPIP) on Sept. 27.
NCPIP builds on guidance provided by
HSPD-20 for identifying and executing
primary mission-essential functions. It
also calls for the integration of COOP and
COG programs into routine government
operations. These objectives require an
active, deliberate response from all
departments and agencies.
Federal Preparedness Circular 65
(FPC-65) provides guidance for developing
COOP programs within the executive
branch, while NCPIP implements the policies
in HSPD-20 and transitions the COOP
planning concepts of FPC-65 into mandated
actions.
NCPIP is designed to initiate a framework
of integrated continuity. It seeks to
integrate the COOP planning efforts within
all departments, branches and levels of
government, also encompassing the private
sector. NCPIP integrates COOP within
organizations, COG within each branch
and enduring constitutional government
among all branches. It asserts that continuity
planning must be part of, and be developed
concurrently with, all existing and
future programs.
The capability to provide continuity of
operations is built upon a foundation of
ongoing continuity planning or program
management. Once established, that foundation
will support the leadership, staff,
facilities and communications needed to
perform essential functions.
NEAR-TERM REQUIREMENTS
FOR NCPIP COMPLIANCE
A revised federal continuity directive
lists requirements for determining
MEFs and PMEFs. Feb. 29, 2008, submit
MEFs and potential PMEFs to the
interagency board for validation. June
30, 2008, expect a listing of approved
PMEFs from the national continuity
coordinator. July 31, 2008, orient and
train all key COOP personnel. Jan. 30,
2009, coordinate PMEFs and MEFs
internally and externally and with key
partners within the private sector. |
Under NCPIP, the president designates
a national continuity coordinator. An
NCC is a federal official reporting directly
to the president who establishes a continuity
policy coordination committee to
develop policies, a continuity advisory
group to implement programs and an
interagency board to validate primary
mission-essential functions. In addition,
the NCPIP requires the establishment of
new leadership roles. A continuity coordinator,
a senior accountable official at a
level equivalent to an assistant secretary,
must report to the NCC on all continuity
matters. A continuity manager is a lead
official who must provide daily management
of the COOP programs and represent
the department on the NCC’s continuity
advisory group as appropriate.
Another requirement of the plan calls
for federal departments to identify mission-
essential functions. To qualify as a
MEF, a function must be required by law
or executive order, and a business process
analysis must determine that the function
must be performed uninterrupted, with
minimal interruption or requiring immediate
execution during an emergency.
In addition to MEFs, departments must
identify primary mission-essential functions.
To qualify as a PMEF, a function
must directly support national essential
functions and continue uninterrupted or
within 12 hours in all circumstances. There
are eight national essential functions that
must be sustained under all circumstances:
• Ensure the continued function of government
under the constitution and
include the function of the three separate
branches of government.
• Provide leadership visible to the nation
and the world, and maintain the trust
and confidence of the American people.
• Defend the constitution against all foreign
and domestic enemies, and prevent
or interdict attacks against the
United States or its people, property or
interests.
• Maintain and foster effective relationships
with foreign nations.
• Protect against threats to the homeland,
and bring to justice perpetrators of
crimes or attacks against the United
States or its people, property or interests.
• Provide rapid and effective response to
and recovery from the domestic consequences
of an attack or other incident.
• Protect and stabilize the nation’s economy,
and ensure public confidence in
its financial systems.
• Provide for critical federal government
services that address the health, safety
and welfare needs of the United States.
In the long run, there are several ongoing
requirements for NCPIP compliance.
First, each government branch must
incorporate continuity requirements into
daily operations and planning. This
includes focusing all planning efforts on
the continuance of PMEFs under all circumstances.
FPC-65 |
NCPIP |
Reflects a model that regards COOP,
COG and ECG as independent entities |
Mandates integration of COOP, COG
and ECG planning efforts across all
levels of government and encompasses
the private sector |
Defines COOP planning as efforts
dedicated towards the continued performance
of essential functions |
Requires integral and concurrent
COOP development with all existing
and future projects |
Provides guidance for developing
plans and procedures within a COOP
program |
Provides official definitions and criteria
for required components and mandates
immediate initiation of COOP
planning |
Outlines essential elements of an
effective COOP program |
Establishes deadlines for completing
essential COOP program activities |
Also, lawful orders of succession
must be pre-planned and documented
to grant a successor the authority,
autonomy and responsibility to replace
delayed or unavailable COOP personnel.
Records, equipment, systems, storage,
buildings, supplies and data must be
safeguarded. Pre-arranged access to
these must be granted to continuity staff,
and procedures must exist to acquire
expended or missing supplies during
COOP procedures.
To prepare for emergencies, departments
and agencies must have internal
and external communications capabilities
that are redundant at primary sites, duplicated
at alternate sites and immediately
available during emergencies. They also
must provide resources that enable recovery
from a catastrophic event to normal
operating status within a primary or alternate
site. And personnel must be designated,
trained, prepared and capable of
relocating to an alternate facility in support
of continuing PMEF performance.
Next, each branch must develop and
maintain a corrective action program, a
listing of procedures to address deficiencies,
funding and personnel requirements,
and resource acquisition tasks within the
COOP program. They’re required to participate
in national exercises sponsored by
DHS and include COOP program development
within all budgetary requests.
Today’s changing threat environment
and recent natural and manmade emergencies
demonstrate the need for
COOP/COG capabilities and plans at the
local, state and federal levels.