Federal Preparedness Circular 65 (2004)
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U.S. Department of Homeland Security
Washington, D.C. 20472
Federal Emergency Management Agency
Directives Management System
FEDERAL PREPAREDNESS CIRCULAR
FPC 65 June 15, 2004 Office of National Security Coordination
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 contingency plans and
programs for continuity of operations (COOP). COOP planning facilitates the performance
of department/agency essential functions during any emergency or situation that may disrupt
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." The COOP elements outlined herein are for use at all levels of Federal
Executive Branch organizations, regardless of location.
3. SUPERSESSION: The provisions of this FPC supersede:
a. Federal Preparedness Circular 65, Federal Executive Branch Continuity of
Operations, dated July 26, 1999.
b. Federal Preparedness Circular 66, Test, Training and Exercise Program for Continuity
of Operations, dated April 30, 2001.
c. Federal Preparedness Circular 67, Acquisition of Alternate Facilities For Continuity
of Operations, dated April 30, 2001.
a. The National Security Act of 1947, dated July 26, 1947, as amended.
b. The Homeland Security Act of 2002 (Public Law 107-296), dated November 25, 2002.
c. Executive Order 12148, Federal Emergency Management, dated July 20, 1979, as amended.
d. Executive Order 12472, Assignment of National Security and Emergency Preparedness
Telecommunications Functions, dated April 3, 1984.
e. Executive Order 12656, Assignment of Emergency Preparedness Responsibilities
dated November 18, 1988, as amended.
f. Executive Order 13286, Establishing Office of Homeland Security, dated February
g. Presidential Decision Directive 67, Enduring Constitutional Government and
Continuity of Government Operations, dated October 21, 1998.
a. 41 Code of Federal Regulations 101.20.103-4, Occupant Emergency Program,
revised as of July 1, 2000
b. 36 Code of Federal Regulations, Part 1236, Management of Vital Records, revised as
of July 1, 2000.
c. Presidential Decision Directive 62, Protection Against Unconventional Threats to the
Homeland and Americans Overseas, dated May 22,1998.
d. Homeland Security Presidential Directive 3, Homeland Security Advisory System,
dated March 11, 2002.
e. Homeland Security Presidential Directive 5, Management of Domestic Incidents,
dated February 28, 2003.
f. Homeland Security Presidential Directive 7, Critical Infrastructure Identification,
Prioritization, and Protection, dated December 17, 2003.
g. Homeland Security Presidential Directive 8, National Preparedness, dated December
h. Federal Preparedness Circular 60, Continuity of the Executive Branch of the Federal
Government at the Headquarters Level During National Security Emergencies, dated
November 20, 1990.
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. To
support this policy the Federal Executive Branch has implemented the Continuity of
Operations (COOP) Program. COOP is defined as the activities of individual departments
and agencies and their sub-components to ensure that their essential functions are performed.
This includes plans and procedures that delineate essential functions; specify succession to
office and the emergency delegation of authority; provide for the safekeeping of vital records
and databases; identify alternate operating facilities; provide for interoperable
communications; and validate the capability through tests, training, and exercises. All
Federal agencies, regardless of location, shall have in place a viable COOP capability to
ensure continued performance of essential functions from alternate operating sites 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. Today's
changing threat environment and the potential for no-notice emergencies, including localized
acts of nature, accidents, technological emergencies, and military or terrorist attack-related
incidents, have increased the need for COOP capabilities and plans that enable agencies to
continue their essential functions across a broad spectrum of emergencies. This, coupled
with the potential for terrorist use of weapons of mass destruction, has emphasized the
importance of COOP programs that ensure continuity of essential government functions
across the Federal Executive Branch.
To provide oversight and coordination of this effort, Presidential Decision Directive (PDD)
67 established the Federal Emergency Management Agency (FEMA) as the lead agency for
Federal Executive Branch COOP. This authority was transferred to the Department of
Homeland Security on March 1, 2003, and then delegated to the Emergency Preparedness
and Response Directorate (FEMA). FEMA's Office of National Security Coordination has
been designated as DHS's lead agent for the Federal Executive Branch COOP program.
Included in this responsibility is the requirement to formulate guidance and establish
common standards for agencies to use in developing viable, executable COOP plans;
facilitate interagency coordination as appropriate; and oversee and assess the status of COOP
capabilities of Federal Executive Branch agencies. Additionally, each Federal Executive
Branch 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, to include planning, programming, and budgeting for a
viable and executable COOP program that conforms to this FPC.
8. OBJECTIVES: COOP planning is an effort to ensure that the capability exists to continue
essential agency functions across a wide range of all hazard emergencies. The objectives of a
viable COOP plan include:
a. Ensuring the performance of an agency's essential functions/operations during a
b. Reducing loss of life, minimizing damage and losses;
c. Executing as required, successful succession to office with accompanying authorities
in the event a disruption renders agency leadership unable, unavailable, or incapable
of assuming and performing their authorities and responsibilities of office;
d. Reducing or mitigating disruptions to operations;
e. Ensuring that agencies have alternate facilities from which to continue to perform
their essential functions during a COOP event;
f. Protecting essential facilities, equipment, vital records, and other assets;
g. Achieving a timely and orderly recovery from an emergency and reconstitution of
normal operations that allows resumption of essential functions for both internal and
external clients; and
h. Ensuring and validating COOP readiness through a dynamic, integrated test, training,
and exercise program to support the implementation of COOP plans.
9. PLANNING REQUIREMENTS FOR VIABLE COOP CAPABILITY: Viable
department and agency COOP capability consists, at a minimum, of the following elements:
a. Must be capable of implementation both with and without warning;
b. Must be operational within a minimal acceptable period of disruption for essential
functions, but in all cases within 12 hours of COOP activation;
c. Must be capable of maintaining sustained operations until normal business activities
can be reconstituted, which may be up to 30 days;
d. Must include regularly scheduled testing, training, and exercising of agency
personnel, equipment, systems, processes, and procedures used to support the agency
during a COOP event;
e. Must provide for a regular risk analysis of current alternate operating facility(ies);
f. Must locate alternate operating facilities in areas where the ability to initiate,
maintain, and terminate continuity operations is maximized;
g. Should consider locating alternate operating facilities in areas where power,
telecommunications, and internet grids would be distinct from those of the primary;
h. Should take maximum advantage of existing agency field infrastructures and give
consideration to other options, such as telecommuting locations, work-at-home,
virtual offices, and joint or shared facilities;
i. Must consider the distance of alternate operating facilities from the primary facility
and from the threat of any other facilities/locations (e.g., nuclear power plants or
areas subject to frequent natural disasters); and
j. Must include the development, maintenance, and annual review of agency COOP
capabilities using a multi-year strategy and program management plan. The multi-
year strategy and program management plan will outline the process the agency will
(1) Designate and review essential functions and resources,
(2) Define short and long-term COOP goals and objectives,
(3) Forecast COOP budgetary requirements,
(4) Identify COOP program issues, concerns, potential obstacles, and the strategy
for addressing these, as appropriate.
(5) Establish COOP planning, training, and exercise activities and milestones for
10. ELEMENTS OF A VIABLE COOP CAPABILITY: At a minimum, all agency COOP
plans and programs shall include the following elements:
a. PLANS AND PROCEDURES. A COOP plan shall be developed and documented
that, when implemented, will provide for continued performance of an organization's
essential functions under all circumstances. At a minimum, the plan must:
(1) Delineate essential functions and activities, agency interdependencies, and the
resources needed to perform them;
(2) Establish orders of succession to key agency positions and establish and
maintain current roster(s) of fully equipped and trained COOP personnel with
the authority to perform essential functions, to include a devolution of control
(3) Provide for the identification and preparation of alternate operating facilities
for continuity operations;
(4) Outline a decision process for determining appropriate actions in
implementing COOP plans and procedures;
(5) Provide procedures for the notification and relocation of COOP personnel to
one or more alternate operating facilities;
(6) Provide procedures for the orientation of COOP personnel and for conducting
operations and administration at alternate operating facilities;
(7) Provide for operational capability at the COOP site as soon as possible with
minimal disruption to operations, but in all cases within 12 hours of
(8) Establish reliable processes and procedures to acquire resources necessary to
continue essential functions and sustain operations until normal business
activities can be reconstituted, which could be up to 30 days;
(9) Provide for the ability to coordinate activities with non-COOP personnel; and
(10) Provide for reconstitution of agency capabilities, and transition from
continuity operations to normal operations
See Annex A- Plans and Procedures.
b. ESSENTIAL FUNCTIONS. The identification and prioritization of essential
functions is a prerequisite for COOP because it establishes the planning parameters
that drive the agency's efforts in all other planning and preparedness areas. Essential
functions are those functions that enable 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.
Agencies should carefully review all of their organization's missions and functions
before determining those that are essential. Improper identification of essential
functions can have a negative impact on the entire COOP plan, because other aspects
of the COOP plan are designed around supporting these functions. If an agency fails
to identify a function as essential, it will not make the necessary arrangements to
perform that function. If it identifies too many functions as essential, it risks being
unable to adequately address all of them. In either case, the agency increases the risk
that it will not be able to perform its essential functions in a COOP situation.
Planning related to essential functions must also include identification of partners
integral to program delivery, testing data exchanges between partners, developing
complementary COOP plans, sharing key information on readiness with other
partners and the public, and taking steps to ensure that the agency's essential
functions will continue in a COOP situation. Careful consideration must be given to
department and agency interdependencies to ensure the continued delivery and
performance of essential functions across the full spectrum of threats and "All
See Annex B – Essential Functions.
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 other decisions at headquarters, field
levels, and other organizational locations, as appropriate. Clearly established
delegations of authority are vital to ensuring all agency personnel know who has
authority to make key decisions in a COOP situation. Generally, pre-determined
delegations of authority will take effect when normal channels of direction and
control are disrupted and will terminate when these channels are restored.
See Annex C – Delegations of Authority
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 to ensure agency
personnel know who has authority and responsibility if agency leadership is
incapacitated or unavailable in a COOP situation. Orders should be of sufficient
depth to ensure the agency's ability to manage and direct its essential functions and
operations while remaining a viable part of the Federal government throughout any
See Annex D – Orders of Succession
e. ALTERNATE OPERATING FACILITY(IES). All agencies must identify and
prepare 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 personnel to these facilities. As a minimum, alternate operating facilities must
(1) Sufficient space and equipment to sustain the relocating agency;
(2) Capability to perform essential functions as soon as possible with minimal
disruption of operations, but in all cases within 12 hours of activation and
until normal business activities can be reconstituted, which could be up to 30
days under various threat conditions, including threats involving weapons of
(3) Reliable logistical support, services, and infrastructure systems;
(4) Consideration for the health, safety, security, and emotional well being of
(5) Interoperable communications, including means for secure communications,
with all identified essential internal and external organizations, customers, and
the public; and
(6) Computer equipment, software, and other automated data processing
equipment necessary to carry out essential functions.
See Annex E – Alternate Operating Facilities.
f. INTEROPERABLE COMMUNICATIONS. The ability of an agency to execute its
essential functions at its alternate operating facilities is dependent upon the
identification, availability, and redundancy of critical communications and
information technology (IT) systems to support connectivity between key government
leadership, internal elements, other agencies, critical customers, and the public (e.g.
secure and non-secure phone, video conferencing, fax, and messaging capabilities,
etc.) during crisis, disasters, or wartime conditions. All necessary and required
communications and IT capabilities must be operational as soon as possible following
COOP activation, but in all cases within twelve hours of notification. Departments
and agencies listed in the COOP Communications Plan (CCP) must test the
communications capabilities at their alternate operating facilities quarterly. All other
organizations should also validate their internal and external communications
capabilities at their alternate operating facilities quarterly.
See Annex F – Interoperable Communications.
g. VITAL RECORDS AND DATABASES. The identification, protection, and ready
availability of electronic and hardcopy documents, references, records, and
information systems needed to support essential functions during a COOP situation is
another critical element of a viable COOP plan. Agency personnel must have access
to and be able to use these records and systems in conducting their essential
functions. They must also have procedures for protecting and updating them. As a
minimum, categories of these types of records are:
(1) Emergency Operating Records. These include records and databases essential
to the continued functioning or reconstitution of an agency during and after a
COOP event. Examples 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 COOP personnel with the
guidance and information resources necessary for conducting operations
during a COOP situation, and for resuming normal operations at its
(2) Legal and Financial Records. These include vital records critical to carrying
out an agency's essential legal and financial functions 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
execution of essential agency functions, to the detriment of the legal or
financial rights and/or entitlements of the agency or of the affected
individual(s). Examples of this category of vital records are accounts
receivable; contracting and acquisition files; official personnel records; Social
Security, payroll, retirement, and insurance records; and property management
and inventory records.
The COOP Plan must account for the identification and protection of the vital
records, systems, and data management software and equipment, to include classified
or other sensitive data, as applicable, necessary to perform essential functions, 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.
See Annex G – Vital Records and Databases.
h. HUMAN CAPITAL. COOP human capital planning and preparedness encompasses
the following areas:
(1) Agency planning and readiness;
(2) Designation of emergency employees and other special categories of
(3) Dismissal or closure procedures;
(4) OPM and media announcements on government operating status;
(5) Status of non-emergency employees and non-special categories of employees;
(6) Sample agency guidelines for communicating to employees;
(7) Methods of employee communications,
(8) Employee awareness of changes in building operations,
(9) Pay flexibilities,
(10) Staffing flexibilities,
(11) Benefit issues,
(12) Employee roles and responsibilities.
See Annex H – Human Capital.
i. TEST, TRAINING AND EXERCISES. Testing, training, and exercising of COOP
capabilities are essential to assessing, demonstrating and improving the ability of
agencies to execute their COOP plans and programs. Tests and exercises serve to
assess, validate, or identify for a subsequent corrective action program, specific
aspects of COOP plans, policies, procedures, systems, and facilities used in response
to an emergency situation. Training familiarizes COOP personnel with the
procedures and tasks they must perform in executing COOP plans. All agencies must
plan, conduct, and document periodic tests, training, and exercises to demonstrate the
plan's viability and identify deficiencies. Deficiencies and actions taken to correct
them must be documented.
Specific objectives of a COOP TT&E program are to:
(1) Assess and validate COOP plans, policies, and procedures;
(2) Ensure that agency personnel are familiar with alert, notification, and
(3) Test alert, notification and deployment procedures and systems at least
(4) Ensure COOP personnel are sufficiently trained to carry out agency essential
functions in a COOP situation;
(5) Conduct individual and team training of agency COOP personnel to ensure
currency of knowledge and integration of skills necessary to implement
COOP plans and carry out essential functions;
(6) Exercise procedures by deploying designated personnel and equipment to the
alternate operating facilities to ensure an agency's ability to perform essential
functions and operations during a COOP situation;
(7) Ensure that backup data and records required to support essential functions at
the alternate operating facilities are sufficient, complete, and current;
(8) Test and validate equipment to ensure both internal and external
(9) Ensure agency personnel understand the procedures to phase out COOP
operations and transition to normal activities (reconstitution) when
(10) Conduct refresher orientation for COOP personnel;
(11) Document completed COOP training and identify training requirements; and
(12) Develop a Multi-Year Test, Training, and Exercise (TT&E) Plan that
addresses COOP TT&E requirements, resources to support these activities,
and a TT&E planning calendar.
See Annex I – Test, Training, and Exercises.
j. DEVOLUTION OF CONTROL AND DIRECTION. Devolution planning supports
overall COOP planning and addresses the full spectrum of threats and all-hazards
emergencies that may render an agency's leadership and staff unavailable to or
incapable of supporting the execution of its essential functions from either its primary
or alternate location(s). The devolution option of COOP shall be developed to
address how an agency will identify and conduct its essential functions during
increased threat situations or in the aftermath of a catastrophic emergency.
See Annex J – Devolution of Control and Direction.
k. RECONSTITUTION. Extensive coordination is necessary to procure a new operating
site once an agency suffers a facility loss or in the event that collateral damage from a
disaster renders the structure unsafe for reoccupation. Reconstitution embodies the
ability of an agency to recover from a catastrophic event and consolidate the
necessary resources that allow it to return to a fully functional entity of the Federal
See Annex K – Reconstitution.
11. COOP IMPLEMENTATION: A COOP plan involves the deliberate and pre-planned
movement of selected key principals and supporting staff to an alternate operating facility.
Relocation may be required to accommodate a variety of emergency scenarios. Examples
include scenarios in which:
a. An agency headquarters is unavailable and operations can shift to a regional or field
b. A single agency facility is temporarily unavailable and the agency can share one of its
own facilities or that of another agency; or
c. Many, if not all, agencies must evacuate the immediate area.
While these scenarios involve the unavailability of a facility, the distinction must be made
between a situation requiring evacuation only and one dictating the need to implement COOP
plans. 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 advance 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 allows 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. The phasing
for COOP activation and relocation, alternate operating facility operations, and reconstitution
are as follows:
a. ACTIVATION AND RELOCATION (0-12 HOURS)
Activate plans, procedures, and schedules to transfer essential functions, personnel,
records, and equipment to alternate operating facilities. Agency Headquarters POCs
must notify the FEMA Operations Center (FOC), (540) 665-6100/1-800-634-7084,
and other appropriate agencies of any COOP activation regardless of agency location
and the time of execution or activation of call-down procedures. The FOC will relay
notification information to the Homeland Security Operations Center (HSOC) and the
Office of National Security Coordination (ONSC).
b. ALTERNATE OPERATING FACILITY OPERATIONS
Provide additional guidance to COOP personnel and all other employees. Notify the
FOC and all other appropriate agencies immediately of the agency's alternate
location, operational and communications status, and the anticipated duration of
relocation, if known. Commence full execution of essential functions at the alternate
operating facility(ies). The FOC will relay this information to the HSOC and the
c. RECONSTITUTION (TERMINATION AND RETURN TO NORMAL
Inform all organizational personnel that the necessity to COOP 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). Report the status of relocation to the FOC and other agency points-of-
contact, as applicable. The FOC will relay this information to the HSOC and the
12. RESPONSIBILITIES: The following responsibilities must be clearly outlined in agency
COOP plans and internal documents:
a. Each agency head is responsible for:
(1) Establishing an agency COOP program;
(2) Appointing a senior executive as the agency COOP program point-of-contact;
(3) Developing a COOP Multi-Year Strategy and Program Management Plan that
includes a program budget to support a viable COOP capability;
(4) Developing, approving, and maintaining agency COOP plans and procedures
for headquarters and all subordinate elements;
(5) Conducting tests, training, and exercises of agency COOP plans at least
annually, to include COOP personnel, and essential systems and equipment, to
ensure timely and reliable implementation of COOP plans and procedures;
(6) Participating in interagency COOP exercises to ensure effective interagency
coordination and mutual support;
(7) Notifying the FOC and other appropriate agencies upon any implementation
of COOP plans;
(8) Providing updates on COOP status to the FOC as designated or if the agency's
COOP status changes; and
(9) Coordinating intra-agency COOP efforts and initiatives with policies, plans,
and activities in accordance with directives related to terrorism, Critical
Infrastructure Protection, and all-hazards preparedness. Contingency planning
efforts such as Disaster Recovery Plans, Information Assurance, National
Response Plan, Business Continuity Plans etc., should be integrated into the
agency's COOP plan.
b. FEMA is responsible for:
(1) Serving as the Department of Homeland Security's designated Lead Agent
for Federal Executive Branch COOP;
(2) Coordinating and monitoring COOP activities of Federal Executive Branch
(3) Issuing COOP guidance, in cooperation with the General Services
Administration and the Office of Personnel Management, to promote
understanding of, and compliance with, the requirements and objectives of
(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) Conducting periodic assessments of Executive Branch COOP capabilities and
reporting the results to the National Security Council and the Homeland
(6) Conducting a government-wide COOP exercise every other year as an
assessment and validation tool of Federal COOP readiness;
(7) Assisting as required, the Federal legislative and judicial branches with
COOP planning and implementation; and
(8) Providing oversight for the development of COOP training courses that are
available to all agencies.
c. General Services Administration (GSA) is responsible for:
(1) Developing and conducting a COOP training program available to all
(2) Maintaining a database of all alternate operating facilities.
d. Office of Personnel Management (OPM) is responsible for:
(1) Maintaining and revising Human Capital management guidance for
(2) Assisting the heads of other departments and agencies with personnel
management and staffing during national security emergencies.
13. POINT OF CONTACT: Should you have any questions or need additional assistance with
the information contained in this FPC, please contact the Director, Office of National
Security Coordination, at 202.646.4145.
14. DISTRIBUTION: This FPC is distributed to the heads of Federal departments and
agencies, senior policy officials, emergency planners, and other interested parties.
Michael D. Brown
Emergency Preparedness and Response
ANNEX A – PLANS AND PROCEDURES
ANNEX B – ESSENTIAL FUNCTIONS
ANNEX C – DELEGATIONS OF AUTHORITY
ANNEX D – ORDERS OF SUCCESSION
ANNEX E – ALTERNATE FACILITIES
ANNEX F – INTEROPERABLE COMMUNICATIONS
ANNEX G – VITAL RECORDS AND DATABASES
ANNEX H – HUMAN CAPITAL
ANNEX I – TEST, TRAINING, AND EXERCISES
ANNEX J – DEVOLUTION OF CONTROL AND DIRECTION
ANNEX K – RECONSTITUTION
ANNEX L – GLOSSARY
ANNEX A- PLANS AND PROCEDURES
A Continuity of Operations (COOP) plan shall be developed and documented by each
Federal department and agency to minimize disruption of business operations and
provide for continued performance of essential functions under all circumstances.
Comprehensive COOP plans should include appropriate provisions and lists developed in
advance of COOP activation to ensure a viable COOP capability.
As a minimum, agencies must incorporate lists for the following elements of their COOP
1. Essential functions and other critical activities;
2. Identification and preparation of alternate operating facilities for continuity
3. Vital records, databases and systems and where/how they are stored;
4. Orders of succession for key organizational leadership positions;
5. Delegation of authorities;
6. Decision process for determining appropriate actions in implementing COOP
plans and procedures;
7. Responsibilities of the individuals who have COOP roles (leadership, planners,
8. Recommended content and maintenance of drive-away kits;
9. Interoperable communications systems and contact numbers; and
10. COOP personnel and other employee contact lists.
Additionally, agencies should develop action plans for each stage of COOP
implementation. The following are the types of actions agencies must, as a minimum
1. ACTIVATION AND RELOCATION
a. Decision matrix for COOP:
(1) With warning.
(2) Without warning during duty hours, and during non-duty hours.
b. Notification of:
(1) Alternate facilities.
(2) Department and Agency (D/A) HQs are required to notify the
FEMA Operations Center (FOC), (540) 665-6100/1-800-634-
7084) of COOP activation and relocation. The FOC will relay this
information to the Homeland Security Operations Center (HSOC)
and the ONSC. Subordinate D/A organizations will notify their
respective D/A HQs of COOP activation and relocation, which, in
turn, will notify the FOC.)
(3) Other points of contact, as appropriate.
(4) Employees (COOP essential personnel and non-deployed personnel).
c. Movement to alternate operating facility(ies); directions and maps of routes
from primary location to alternate operating facilities.
d. Movement of records, not pre-positioned, from the primary to the alternate
e. Ordering of necessary equipment/supplies not already in place.
2. ALTERNATE OPERATING FACILITY OPERATIONS
a. Reception and in processing of COOP personnel.
b. Transition of responsibilities to the deployed COOP personnel.
c. Guidance for non-deployed personnel.
d. Identification of replacement personnel and augmentees, as necessary.
e. Execution of all essential functions at the alternate operating facility(ies).
f. Notification of the FOC and all other appropriate points of contact of the
agency's alternate location, operational and communications status, and
anticipated duration of relocation, if known. The FOC will notify agencies
of any additional COOP reporting requirements.
g. Redeployment plans to phase down alternate facility operations and return
operations, personnel, records, and equipment to the primary operating
facility, when appropriate.
3. RECONSTITUTION (TERMINATION AND RETURN TO NORMAL OPERATIONS)
a. Informing all personnel, including non-deployed personnel, that the need
to COOP no longer exists, and providing instructions for resumption of
b. An orderly return to the normal operating facility, or movement to other
temporary or permanent facility(ies) using a phased approach if conditions
necessitate; and the transition of responsibilities from deployed COOP
c. Notification of the status of relocation to the FOC and other agency points
of contact, as applicable.
d. An after-action review of COOP operations and effectiveness of plans and
procedures as soon as possible, identifying areas for correction, and
developing a remedial action plan.
ANNEX B- ESSENTIAL FUNCTIONS
All agencies must identify and prioritize their essential functions as the basis for COOP
planning. Essential functions are those functions that enable an organization to provide vital
services, exercise civil authority, maintain the safety of the general public, and sustain the
industrial/economic base during an emergency. The goal of this annex is to assist with the
identification, prioritization, and resourcing of these essential functions. During preparations
for Y2K, the Office of Management and Budget (OMB) identified Federal programs having
high impact on the public. Lists of these programs are included as tables B-3 and B-4. These
tables are not all-inclusive and may provide examples of potential essential functions for
consideration and planning purposes:
In identifying essential functions, agencies must:
1. Determine which functions must be continued under all circumstances. When
identifying essential functions, agencies must consider those functions that must
continue with minimal disruption or cannot be interrupted for more than 12 hours,
without compromising the organization's ability to perform its mission. Agencies
must be capable of sustaining these essential functions until normal business activities
can resume which may be up to 30 days. Agencies must also consider the following
when identifying essential functions:
a. The function can be documented as an essential mission or responsibility
explicitly assigned to the agency by law, or by order of the President. Consult
Presidential Decision Directives, Executive Orders, Homeland Security and
National Security Presidential Directives, and other Federal Executive Branch
directives for the presence of compulsory essential functions.
b. The function has been determined by the agency head to be essential or is
implicit in complying with a federal law or order issued by the President.
c. The function provides vital support to an essential function performed by
another Federal Executive Branch department or agency. Such functions
reflect interdependency between two or more agencies because they must act
in concert in order to perform the function successfully. Many agency
functions rely on the availability of resources or functions controlled by
another organization, including other agencies, state and local governments,
and private entities. (For example, the Department of the Treasury's Financial
Management Service receives and makes payments for most federal agencies.)
2. Prioritize these functions based on the criticality and time sensitivity of the function
(see Table B-1). To the extent possible, agencies should prioritize these functions
against likely COOP triggers and scenarios. Note that the prioritization of essential
functions might be situation dependent.
3. Establish staffing, resource requirements, and any other supporting activities needed to
perform these functions within 12 hours, or less, of COOP activation and until normal
business activities can resume which may be up to 30 days.
a. Establish a roster of personnel, hereinafter referred to as "COOP personnel" or
the "Emergency Relocation Group" (ERG), needed to perform these essential
functions. COOP personnel must be fully equipped, properly trained, and
possess the authority to perform essential functions.
(1) Based on an agency's essential functions, determine the necessary
knowledge, skills, and abilities required for COOP personnel.
(2) Determine any security clearance requirements for COOP personnel.
(3) Determine, from among the qualified personnel, those who are able to
serve as COOP personnel. In doing so, the agency should consider
extenuating circumstances such as medical conditions, family
responsibilities, and any other circumstances that may prevent an
individual from serving as COOP personnel.
(4) Select the appropriate mix of personnel to satisfy the knowledge, skills,
abilities, and security clearance requirements required to perform
essential functions. The agency should attempt to minimize the number
of COOP personnel, but designation should ultimately be determined
by what is needed to support the organization's essential functions.
b. Identify equipment, including information technology and telecommunications
(ITT) hardware needed to perform essential functions.
4. Identify mission critical data needed to perform essential functions.
5. Identify consumable office supplies needed to perform essential functions.
6. Include a statement that indicates all functions deemed not essential will be deferred.
Lists of resources required to perform essential functions must be reviewed annually and
updated as necessary.
The following table can assist agencies in identifying and documenting their essential
functions and supporting information.
Table B-1: Essential functions and supporting information.
The following table can assist agencies in identifying COOP personnel and their contact
Table B-2: COOP Personnel information
The following table prepared by the Office of Management and Budget (OMB), includes
examples of functions that may assist in determining what is essential to an agency's overall
mission and responsibilities. This listing is not all-inclusive. Each agency must review all of
its functions to determine those functions that enable 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.
Table B-3: High Impact Programs and Responsible Agency
Food safety inspection
Child nutrition programs
Special supplemental nutrition program for women,
infants, and children
Patent and trademark processing
Federal electric power generation and delivery
Federal Emergency Management Agency
Health and Human Services
Disease monitoring and warnings
Indian health services
Child support enforcement
Low income home energy assistance
Temporary assistance for needy families
Housing and Urban Development
Community development block grants
Section 8 rental assistance
Bureau of Indian Affairs programs
Office of Personnel Management
Federal employee health benefits
Federal employee life insurance
Federal employee retirement benefits
Social Security Administration
Social security benefits
Passport applications and processing
Air traffic control system
Maritime search and rescue*
Cross-border inspection services*
Veterans' health care
Source: Office of Management & Budget (OMB) Y2K Guidance
- Organizations responsible for these functions are now part of the U.S. Department of Homeland Security.
The following table prepared by OMB, provides examples that can further assist agencies to
identify COOP essential functions. This listing is not all-inclusive. Component agencies and
others must further review their missions and responsibilities to develop a broader listing of
Table B-4: Component Agencies with High-Impact Program Responsibilities
Department of Commerce
National Oceanic and
Patent and Trademark Office
Patent and trademark processing
Department of Health and
Centers for Disease Control and
Disease monitoring and warning
Center for Medicare and
Medicare and Medicaid
Food and Drug Administration
Indian Health Service
Indian health services
Department of Housing and
Government National Mortgage
Office of Community Planning
Community development block
Office of Housing
Section 8 rental assistance and
Office of Public and Indian
Department of Interior
Bureau of Indian Affairs
Indian affairs programs
Department of Transportation
Federal Aviation Administration
Air traffic control system
U.S. Coast Guard*
Maritime search and rescue
Department of the Treasury
U.S. Customs Service*
Cross-border inspection services
Department of Veterans Affairs
Source: Office of Management & Budget (OMB) Y2K Guidance
- Organizations responsible for these functions are now part of the U.S. Department of Homeland Security.
ANNEX C- DELEGATION OF AUTHORITY
To ensure rapid response to any emergency situation and minimize disruptions requiring
COOP implementation, agencies should pre-delegate authorities for making policy
determinations and decisions at headquarters, regional, field, satellite, and other agency
locations, as appropriate. Delegations of authority specify who is authorized to act on
behalf of the agency head or other officials for specified purposes. To the extent
possible, individuals should be identified by title or position, not by name. Generally,
pre-determined delegations of authority will take effect when normal channels of
direction are disrupted and terminate when these channels have been reestablished. To
ensure legal sufficiency and clarity, these delegations of authority must:
1. Document the legal authority for officials, including those below agency head, to
make key policy decisions during a COOP situation.
2. Identify the programs and administrative authorities needed for effective
operations at all agency levels having essential functions.
3. Document the necessary authorities where essential functions may be required to
a. Delineating the limits of authority and accountability;
b. A statement that explicitly outlines the authority of an official to whom
authority has been delegated to exercise agency direction, including any
exceptions, and their authority to re-delegate functions and activities, as
c. The circumstances under which delegated authorities would be exercised
and when they would terminate.
4. Ensure that officials who might be expected to assume authorities in a COOP
situation are trained to carry out their emergency duties. Training of these
officials should be conducted at least annually.
ANNEX D – ORDERS OF SUCCESSION
Agencies are responsible for establishing, promulgating, and maintaining orders of
succession to key positions. Succession to office is critical in the event agency leadership
is debilitated or incapable of performing their legal authorized duties, roles, and
responsibilities. Orders of succession allow for an orderly, and pre-defined, transition of
leadership within the organization. Orders of succession are an essential part of an
agency's COOP plan and should be of sufficient depth to ensure the agency is able to
perform its essential functions while remaining a viable part of the Federal government
through any emergency.
As a minimum, orders of succession must:
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
a. Geographical dispersion, including regional, field, or satellite
leadership in the standard agency line of succession is encouraged and
ensures roles and responsibilities can transfer in all contingencies.
b. Where a suitable field structure exists, appropriate personnel located
outside the subject region should be considered in the order of
2. Establish orders of succession to other key agency leadership positions.
a. Establish an order of succession to the position of Regional Director or
b. Establish an order of succession to the position of Field Office
Director or equivalent.
c. Establish an order of succession to the position of Satellite Office
Director or equivalent, etc.
d. Establish orders of succession to other agency leadership as necessary.
3. To the extent possible, describe orders of succession by positions or titles,
rather than names of individuals. Consider coordinating Orders of Succession
with General Counsel for legal sufficiency.
4. Establish the rules and procedures designated officials must follow when
facing the issue of succession to office.
5. Include in succession procedures the conditions under which succession will
take place; method of notification; and, any temporal, geographical, or
organizational limitations of authorities.
6. Include orders of succession in the vital records of the agency and ensure they
are available at the alternate facility in the event of COOP activation.
7. Revise orders of succession as necessary, and distribute revised versions
promptly as changes occur. Designate responsibility for updating and
promulgating orders of succession.
8. Provide briefings to designated successors to the position of agency head,
when named, on their responsibilities as successors and on any provisions for
their relocation. Designated successors must be provided annual refresher
The following table can assist agencies in developing their organizational succession
Table D-1: Succession Plan
ANNEX E- ALTERNATE OPERATING FACILITIES
All agencies shall designate alternate operating facilities as part of their COOP plans, and
prepare their personnel for the possibility of an unannounced relocation to these facilities.
Identifying and acquiring alternate operating facilities should, at a minimum, include
consideration of the following:
1. Geographical location of the facility.
2. Power, telecommunications and internet grids serving the facility.
3. Performing a risk assessment.
4. Ensuring the availability of necessary logistics and infrastructure so that the organization
can continue to perform their essential functions during an emergency from an alternate
5. Reducing or mitigating disruptions to relocated or transferred operations.
6. Safety and security of relocated personnel.
7. Achieving a timely and orderly recovery from an emergency and resuming full and
The following is provided for the identification and preparation of alternate operating facilities
for continuity operations:
1. Location of Facilities. Agencies should perform an all-hazard risk assessment for all
facility(ies) being considered for COOP use. This all hazards analysis should include
identification of all natural hazards that may affect the facility; the potential for the
facility to be impacted by technological accidents such as fixed-facility and in-transit
releases of hazardous materials; the ability to secure the facility against crime, sabotage,
and terrorist attacks; and the capabilities of on-site and/or local first responders.
Alternate operating facilities must be located in an area where disruption to the agency's
ability to initiate, maintain, and terminate operations is minimized. Maximum use should
be made of existing agency local or field infrastructures, and consideration should also be
given to other options such as telecommuting locations, work-at-home agreements,
virtual offices, and joint or shared facilities. Additionally, decisions concerning alternate
operating facility locations should take into consideration the following:
a. The ability to be operational as soon as possible with minimal disruption of
operations, but in all cases within 12 hours after COOP activation and to sustain
operations until normal business operations can resume, which may be up to 30
b. The distance from the threat area to any other vulnerable facilities/locations (e.g.
hazardous materials/nuclear power plants, or areas subject to natural disaster).
c. Access to essential resources such as food, water, fuel, medical facilities, and
municipal services (e.g. fire, police).
d. The accessibility of transportation for associates or a defined transportation plan
that describes procedures for a warning/no warning event.
2. Construction. Since alternate operating facilities will be located at a sufficient distance
from the affected facility and in a relatively low-risk environment, no specific
construction requirements are identified. However, an agency's entire alternate facility
space should have the ability to run emergency power to allow essential functions and
operations to continue in any environment. At a minimum, facilities should be
constructed such that they are not uniquely susceptible to natural disaster risk factors
(e.g., earthquakes, tornadoes, hurricanes, floods, etc.).
3. Memorandum of Agreement (MOA)/Memorandum of Understanding (MOU). If the
facility is not owned or leased by the agency, a signed MOA/MOU must be prepared with
the owner or occupant of the facility. This MOA/MOU must be reviewed annually. Pre-
coordination with the General Services Administration (GSA) to provide assistance in
sourcing potential relocation sites is recommended. MOA/MOUs should include the
a. Time period from notification of requirement to availability of facility for
b. Space and services to be provided.
c. Sole use of allocated space during the period of occupancy.
4. Space. Agency alternate facility space requirements should be sized according to the
scope of their staffing plan for Personnel within the COOP. Contiguous space is
desirable; however, non-contiguous space may be acceptable if adequate communications
are in place to ensure effective operations of the relocated agency.
5. Billeting. If the alternate facility is located at a distance from the primary site, plans
should be developed to address housing for COOP personnel (e.g. billeting within
facility, local motels).
6. Site Transportation. Transportation resource requirements, if any, should be met at the
relocation sites (e.g. buses, automobiles).
7. Communications. Communications at the alternate facility is required to be consistent
with your agency COOP staffing plan during any event. Communications should be
provided in sufficient quantity and mode/media to effectively interface with other agency
elements (e.g. regional offices), other agencies, and other government and private sector
organizations (including key operations centers) critical to the performance of agency
essential functions. Secure/non-secure communications requirements should be
8. Security. Alternate facilities must provide physical security that meets all requirements
established by annual threat assessments and physical security surveys conducted by the
agency's security office, the Federal Protective Service, or a qualified contractor.
Required physical security capabilities must be tested/exercised annually and be in place
within 12 hours of COOP plan activation. Sufficient personnel should be designated to
provide perimeter, access, and internal security functions as required by agency policy.
Technologies for access, surveillance, and early warning of intrusion should also be
considered as part of an alternate facility physical security program.
9. Life Support. Most life support items should be available from external sources (e.g.
food, water, medical services, sanitation, power); however, if not, they must be accessible
to the facility in sufficient quantities to sustain 30 days of operations. In addition, unique
items such as medical supplies, medical records, or housekeeping supplies should be
brought to the facility with the relocated personnel or maintained within the facility.
10. Preparation. After selecting appropriate sites for COOP, pre-positioning of critical
resources, coordination with the site facility managers, and agreements between the
agency and property owners are necessary to ensure the continued availability of facility
space and services. Agencies must have pre-positioned or have detailed site preparation
and activation plans in order to achieve full operational capability within 12 hours of
11. Maintenance. Agencies should develop facility maintenance and inspection procedures
to ensure that their alternate operating facilities are able to support COOP essential
functions and personnel as soon as possible with minimal disruption of operations, but in
all cases within 12 hours of COOP activation and for up to 30 days.
THE ACQUISITION PROCESS:
The alternate facility acquisition process consists of, at a minimum, three steps: alternate
operating facility requirements identification; candidate alternate operating facilities selection
and acquisition; and alternate operating facility reevaluation. All three steps should be taken in
consultation with GSA as necessary.
Candidate Alternate Operating Facilities Selection and Acquisition. In this step, an agency
should consider any and all possibilities for identifying and obtaining alternate operating
facilities. Some of these options are as follows:
1. Existing agency space.
a. Remote/offsite training facilities – Facilities may include an agency training
facility that is located nearby their normal operating facility, but far enough away
to provide for geographical dispersion.
b. Regional or Field Offices – Some agencies have a Regional Office or Field Office
that could operate as an alternate operating facility.
c. Remote headquarters operations – Some agency headquarters are of such size that
their operations and facilities extend beyond the limits of their host city. One of
these locations could act as an alternate operating facility.
2. Virtual offices.
a. Work at Home – Many agencies have programs to allow employees to work from
home. This arrangement could be utilized for some COOP personnel to fulfill
their essential functions.
b. Telecommuting facilities – Several areas of the country have federally funded
telecommuting facilities. These facilities may accommodate some COOP
personnel on a prearranged basis so that they can fulfill their essential functions.
c. Mobile office concept – This concept envisions using such assets as a specially
equipped vehicle that can serve as an office and laptop computers that
communicate via wireless technology.
3. MOA/MOU for co-location with another agency. One agency may relocate to another
agency's facilities. The relocating agency could occupy available space in the other
agency's headquarters, training facility, field office, or other available agency space.
4. Acquisition of an agency specific alternate operating facility.
a. Agency procured and maintained space – For this option, an agency with the
authority to procure their own space may do so to meet their alternate operating
b. GSA procured and maintained space – An agency may request GSA to assign
federally owned or leased space to accommodate their alternate operating
5. Another agency procured and maintained space. Some agencies (other than GSA) offer
space procurement services that could be used by agencies to fulfill their alternate
operating facilities needs.
6. Participation in a joint-use alternate operating facility.
a. Single-use total space, multi-use limited space – Several agencies may pool their
resources to acquire space for an alternate operating facility. If a COOP incident
occurred, the affected agency would relocate to the facility. However, if the
incident affected several or all of the agencies, sufficient space may not be
b. Multiple agencies, individual spaces – An agency may decide to collocate with
another agency, but each would have individually designated space to meet their
alternate operating facilities needs.
c. Multiple uses (COOP/telecommute/training) – An agency may acquire an
alternate operating facility, but ordinarily use it for purposes other than COOP.
For instance, an agency may use the facility as a remote telecommuting facility or
as a remote training facility.
Care must be taken to ensure that shared facilities are not over-committed during a COOP
7. Alternate operating facility reevaluation. Identified alternate operating facilities must be
periodically reevaluated for suitability and functionality. This is recommended at least
annually and whenever the agency's COOP is reviewed and updated to ensure that
alternate operating facilities continue to meet agency needs.
THE REPORTING PROCESS:
As directed by Presidential Decision Directive (PDD) 67, a central database of all alternate operating
facilities will be created and maintained by GSA. All agencies are required to identify alternate
operating facilities and provide the necessary data concerning the facilities to GSA. To facilitate the
reporting process, GSA has developed a form, SF 336: GSA Alternate Facility Reporting Form.
Agencies should complete this form and return it to GSA's Emergency Management Office or your
regional GSA office, as appropriate.
ANNEX F – INTEROPERABLE COMMUNICATIONS
When identifying communications requirements, agencies should take maximum
advantage of the entire spectrum of communications media likely to be available and
needed in any emergency situation. These services may include, but are not limited to:
secure and non-secure voice, video, fax, and data connectivity; Internet access; and e-
mail. Elements of a viable interoperable communications program include:
1. Capability commensurate with an agency's essential functions, including quantity
as per the staffing plan within an agency COOP.
2. Ability to communicate with COOP personnel, other agency employees,
leadership, and other agency elements, to include bureaus, regions, and field
3. Ability to communicate with the FEMA Operations Center and the Homeland
Security Operations Center, other Federal agencies and their COOP sites, and
4. Access to data, systems, and services necessary to conduct essential functions and
support activities. Agencies are required to review redundant IT equipment
countermeasures that provide access to data systems and services to conduct
essential functions and support activities.
5. Redundant communications systems for use in COOP implementation.
6. Redundant communications systems available to support COOP operational
requirements within 12-hours of COOP activation and sustained for up to 30-days.
7. Interoperability with existing field infrastructures.
To identify required interoperable communications systems, agencies must:
1. Based on their essential functions, determine the communications system
requirements necessary to support essential functions.
2. Evaluate potential communications systems that satisfy these requirements.
Consider the full spectrum of communications media that may be available during
3. If the agency is listed in the COOP Communications Plan, test on a quarterly
basis, the agency's COOP communications systems, including the ability to
communicate with the FOC, the HSOC, other Federal agencies, and their COOP
sites. All other organizations should also validate their internal and external
communications capabilities at their alternate operating facilities quarterly or
more frequently as directed.
ANNEX G – VITAL FILES, RECORDS AND DATABASES
The identification, protection, and ready availability of vital records, databases, and
hardcopy documents needed to support essential functions under the full spectrum of
emergencies are critical elements of a successful COOP plan.
An effective viable vital records program must account for:
1. The official establishment of a vital records program and assignment of program
responsibility within the organization that:
a. Specifies the purpose and scope of the program;
b. Assigns roles and responsibilities;
c. Provides for staff training; and
d. Requires periodic review and testing of the program.
2. Appropriate medium for accessing vital records. As soon as possible after COOP
activation, but in all cases within 12 hours of COOP plan activation, COOP
personnel at the alternate operating facility must have access to:
a. A local area network (LAN);
b. Vital electronic records;
c. Critical information systems and data;
d. Internal and external email and archives; and
e. Vital hard copy records.
In most cases, agencies choose to maintain these records electronically because of
the ease of updating the records and copying them at an offsite location.
Agencies should strongly consider multiple redundant media for storage of vital
3. Maintenance of a complete inventory of records identified under Emergency
Operating Records and Legal and Financial Records, along with location and
access information. This inventory should be maintained at a number of different
4. Performance of a risk assessment to:
a. Identify the risks involved if vital records are retained in their current
locations and medium, and the difficulty of reconstituting them if they are
b. Determine if off site storage is necessary.
c. Determine if alternative storage media is advisable.
d. Determine if it is necessary to duplicate records to provide a vital records
5. Selection of appropriate protection methods for vital records. This may include
dispersal to other agency locations or off-site storage. When determining
protection methods, it is important to take into account special media needs.
Microforms, paper photographs, and computer disks, tapes and drives all have
different protection requirements. Some require equipment to facilitate access.
6. Procedures for routinely updating vital records to ensure that they always contain
the most current information.
7. Identification of records recovery experts and vendors to assist with recovery in
the event of records damage.
8. Development and maintenance of a vital records plan packet that includes:
a. A hard copy or electronic list of key agency personnel and disaster staff
with up-to-date telephone numbers.
b. A vital records inventory with precise locations of vital records.
c. Necessary keys or access codes.
d. Alternate operating facility locations.
e. Access requirements and lists of sources of equipment necessary to access
the records (i.e. this may include hardware and software and microfilm
readers, Internet access, and/or dedicated telephone lines).
f. Lists of records recovery experts and vendors.
g. A copy of the agency's disaster recovery plan (e.g. COOP or Vital
Records Recovery Plan).
This packet should be periodically reviewed to ensure that the information is
current. A copy should be securely maintained at the agency's alternate operating
facilities and other locations where it can be easily accessible to appropriate
personnel when needed.
9. Development of a training program for all staff involved in the vital records
program. This should include periodic briefings to managers about the vital
records program and its relationship to their records and business needs. Staff
training should focus on the identification, inventorying, protection, storage,
access to, and updating of the vital records.
10. Periodic review of the vital records program to address any new security issues,
identify problem areas, update information, and identify additional vital records
that may result from new agency programs or functions from organizational
changes. The review will provide an opportunity to familiarize staff with all
aspects of the vital records program. It would be appropriate to conduct a review
of the vital records program in conjunction with COOP exercises.
11. Capabilities for protecting classified and unclassified vital records and databases
and providing access to them from the alternate operating facility must be tested
The following table may be useful in identifying and managing vital files, records, and
Table G-1: Vital files, records, databases
Vital File, Record,
Form of Record
ANNEX H – HUMAN CAPTIAL
Agency Planning and Readiness
Each agency is responsible to design, update, and carry out comprehensive plans to take
into account and respond to the threats that its employees are most likely to face. These
plans interact with and impact on human capital management. Agency managers should
be familiar with the many human capital resources and flexibilities that exist to assist
managers and employees in an emergency.
Certain Government wide or agency-specific events, such as:
1. COOP (contingency plans for continuity of operations);
2. OEP (Occupant Emergency Plan); and
3. Dismissals or closures used in emergency situations that prevent most employees
from reporting for work may require:
a. Designation of emergency employees or special categories of employees
(e.g., COOP, emergency, mission-critical, etc., as appropriate);
b. Adjustments in work schedules;
c. Use of special compensation (pay and leave) tools and flexibilities;
d. Temporary staffing arrangements, etc.
Agency managers should:
1. Be fully informed and understand human capital tools, flexibilities, and
2. Review regularly and update human capital information and resources to assure
that the agency's policies remain current and relevant to changing environments
or evolving threats;
3. Conduct regular exercises and simulations;
4. Ensure employees have a clear understanding of what they are to do in an
5. Maintain specific protocols for designating and activating special needs
6. Develop, review, and update emergency guides as needed.
Please see "Federal Manager's/Decision Maker's Emergency Guide," which is posted on
the Office of Personnel Management's (OPM's) Web site (www.opm.gov).
Also, title 5, United States Code, provides for the general authorities to govern an agency,
delegate authorities, and review agency operations:
AGENCY AUTHORITIES, TITLE 5, UNITED STATES CODE
5 U.S.C. 301. Departmental Regulations.
"The head of an Executive department or military department may prescribe regulations
for the government of his department, the conduct of its employees…"
5 U.S.C. 302. Delegation of Authority.
"(b) In addition to the authority to delegate conferred by other law, the head of an agency
may delegate to subordinate officials the authority vested in him--
(1) By law to take final action on matters pertaining to the employment, direction,
and general administration of personnel under his agency; and…"
5 U.S.C. 305. Systematic agency review of operations
"(b) Under regulations prescribed and administered by the President, each agency shall
review systematically the operations of each of its activities, functions, or organization
units, on a continuing basis.
(c) The purpose of the reviews includes--
(1) Determining the degree of efficiency and economy in the operation of the
agency's activities, functions, or organization units…"
Designation of Emergency Employees and other Special Categories of Employees
Each agency head has the authority and responsibility to identify and designate those
personnel that he or she judges to be critical to agency operations in any given emergency
situation such as COOP, OEP, dismissal or closure procedures used in emergency
situations that prevent employees from reporting for work.
There are no standard definitions or categories in this regard, and agency heads (or
their designees, as applicable) are free to make such determinations based on the agency's
unique mission requirements and/or circumstances; such designations may even vary
according to the particular nature of an exigency. Such designations should be part of an
agency's emergency response/continuity of operations plans and should be
communicated in advance to those so designated, so that they can be prepared to support
and sustain agency operations in an emergency.
Dismissal or Closure Procedures
Agencies in the Washington, DC, area should follow the "Washington, DC, Area
Dismissal or Closure Procedures" in emergency situations that prevent significant
numbers of employees from reporting for work on time or which require agencies to
close all or part of their activities. (These procedures are available on OPM's Web site
(www.opm.gov) and are updated annually.)
Federal Executive Boards and Federal Executive Associations coordinate similar
dismissal or closure procedures in other major metropolitan areas.
OPM and Media Announcements on Government Operating Status
Agency managers and employees should be thoroughly familiar with the current meaning
of terms used by OPM and the media to announce the operating status of the
Government. The current terms are defined in the "Washington, DC, Area Dismissal or
Closure Procedures" which is available on OPM's Web site. Current (2004) terms
2. OPEN under an UNSCHEDULED LEAVE policy
3. OPEN under a DELAYED ARRIVAL policy
4. OPEN under a DELAYED ARRIVAL/UNSCHEDULED LEAVE policy
5. EARLY DISMISSAL
Status of Non-Emergency Employees and Non-Special Categories of Employees
In the event of severe hazardous conditions, disruption of public services, or other
emergency situations of short duration, employees may be instructed not to report for
If an employee is prevented from working because he or she has been instructed by the
head of his or her agency or other authorized official not to report for work, the employee
normally will be excused from work without loss of pay or charge to leave. Agency
management also may wish to consider use of alternative worksites, where appropriate
In emergencies, emergency employees and special categories of employees will be
activated by the agency to perform assigned duties. Only designated employees
participate in training and practice exercises. In both instances, agencies are responsible
for managing their other human capital resources, i.e., the employees who are not
1. Agencies must determine if and when it will be appropriate to recall additional
employees to work at their normal worksite or at alternative worksites as the
emergency continues. Further, the agency must communicate how, and the
extent to which, employees are expected to remain in contact with their agencies
during any closure situation. Agencies may wish to issue communications and
other equipment to certain categories of employees to facilitate contact in these
2. In the event of a prolonged shutdown due to severe or hazardous conditions,
disruption of public services, or other emergency situations, an agency may find
it necessary to furlough non-emergency employees. Such an action places an
employee in a non-duty, non-pay status for the duration of the furlough. If the
agency finds that the shutdown may last longer than 1 year or is permanent, the
agency would use reduction in force procedures to separate or demote an
employee from an excess position.
3. There are no fixed solutions that will automatically apply to all agencies in every
emergency. Agency managers should work closely with their Chief Human
Capital Officer or Director of Human Resources, as applicable. For Government
wide and many other types of emergencies, OPM will likely provide guidance on
its Web site (or other means) to agency Chief Human Capital Officers.
Sample Agency Guidelines for Communicating to Employees
1. Establish and disseminate written procedures for dismissal or closure to
employees at least annually;
2. Identify employees who must report for work under various emergency
situations and projected scenarios to continue Government operations and notify
these employees in writing that they are so designated;
3. Identify when work may or must be performed at the regular worksite or
4. Establish a procedure for notifying "non-emergency employees" or "non-
special categories of employees" to report for or remain at work when
Government operations are disrupted;
5. Determine when an employee's formal or informal telework agreement may need
to be amended when telework employees may be required to continue to work at
their alternative worksites on their teleworkday when the agency is closed. At
least annually, agencies should remind all teleworkers of this requirement;
6. Notify employees that if they are required to report for work and are not
otherwise granted excused absence, they will be charged absence without leave
(AWOL) for the period not worked and may potentially be disciplined for the
AWOL at the agency's discretion; and
7. Require managers to be responsible for determining closure, dismissal, and leave
policies for employees on shift work and for informing employees of these
Methods of Employee Communications
Employees should be encouraged to familiarize themselves with the procedures that have
been put into place at their agency, as well as the means of notification that an agency
will use to inform and instruct employees. Activities to support communications with
1. Convening town hall meetings;
2. Soliciting employee comments and suggestions;
3. Communicating plans and changes, including recurring distribution of emergency
4. Maintaining current contact information on senior executives;
5. Working with unions to support and strengthen communication activities; and
6. Advising employees of support services available through agency Employee
Assistance Programs (EAPs).
Employee Awareness of Changes in Building Operations
Management responsibilities with regard to facility operations include:
1. Remaining aware, and encouraging employees to be attentive to suspicious
2. Regular testing of fire and safety public address systems;
3. Assuring availability of supplies in the case of shelter-in-place response to an
4. Posting clear signage for evacuation routes; and
5. Developing a protocol for safety and security personnel to maintain
communications in an emergency.
Each Federal agency has the authority and responsibility to establish work schedules for
its employees within general legal and regulatory guidelines. Most agencies are required
to comply with title 5, United States Code, and OPM's regulations when establishing
regularly scheduled administrative workweeks for their employees.
The work schedule for most employees is determined in advance, and temporary periods
of extended work hours in emergency situations are usually quite different than the
employees' regularly scheduled administrative workweek. Agencies must schedule or
reschedule an employee's regularly scheduled administrative workweek so that it
corresponds with the employee's actual work requirements for specific days and hours.
1. Standby Duty. When employees are required to remain in a state of readiness
to perform work during an emergency, they may be entitled to overtime pay for
standby duty. Usually, an employee is in a standby duty status if, for work-
related reasons, the employee is restricted to an agency's work premises (or so
close thereto that the employee's time may not be used effectively for his or her
own purposes) and is required to remain in a state of readiness to perform work.
2. Compressed Work Schedules. Agencies may implement a compressed work
schedule (CWS) instead of a traditional fixed work schedule (e.g., 8 hours per
day, 40 hours per week). For example, if an employee is required to work more
than 8 hours a day, an agency may implement a fixed schedule that is
compressed, enabling employees to complete the basic 80-hour biweekly work
requirement in fewer than 10 workdays. OPM guidance permits an agency to
establish a CWS when necessary for certain periods or seasons of the year.
Therefore, an agency could establish a CWS to be used by employees only during
an extended emergency. The CWS is established and fixed solely by the agency,
and the employee has no flexibility in establishing his or her hours. If an
employee is in a bargaining unit, the agency must successfully negotiate a CWS
program with the union prior to implementation.
3. Biweekly Premium Pay Limitation. A biweekly limitation provides that
premium pay cannot be paid which causes the total of basic pay, overtime pay,
the dollar value of compensatory time off, night pay, annual premium pay,
Sunday premium pay, and holiday premium pay to exceed the greater of the
biweekly rate for (1) GS-15, step 10 (including any applicable special salary rate
or locality rate of pay), or (2) the rate for level V of the Executive Schedule. The
biweekly premium pay limitation does not apply to wage employees or to Fair
Labor Standards Act overtime pay.
4. Annual Premium Pay Limitation. In certain emergency or mission critical
situations, an agency has the authority, without OPM approval, to apply an
annual premium pay cap instead of a biweekly premium pay cap. In this regard,
the agency head, or his or her designee, or OPM may determine that an
a. For any pay period in which the head of an agency/designee or OPM
determines that an emergency exists, the agency must apply an annual cap
to certain types of premium pay for employees performing work in
connection with an emergency, including work performed in the
aftermath of such an emergency.
b. An "emergency" is defined in 5 CFR 550.103, as a temporary condition
posing a direct threat to human life or property, including a forest
c. In addition, agencies may approve the use of an annual cap instead of a
biweekly cap whenever the agency determines that employees are
performing work critical to the mission of the agency as provided in 5
CFR 550.106(b). (When an annual cap is applied, employees may receive
premium pay only to the extent that the aggregate of basic pay and
premium pay for the calendar year does not exceed the greater of the
annual rate for (1) GS-15, step 10 (including any applicable special
salary rate or locality rate of pay), or (2) level V of the Executive
For further information concerning your agency, consult with your agency's Chief
Human Capital Officer, Technical Advisor to the Chief Human Capital Officer, or
Director of Human Resources, as applicable.
Also see OPM's Web site (www.opm.gov) for fact sheets, regulations, and additional
Agencies may fill emergency or special staffing needs by considering one or more of the
following staffing flexibilities:
1. Excepted Appointments (Temporary Emergency Need (Up To 1 Year) and 30-
Day Critical Need);
2. Reemploying Annuitants;
3. Reemploying Buyout Recipients;
4. Direct-Hire Authority;
5. Contract with private sector temporary firms for services to meet its emergency
6. Competitive service appointments of 120 days or less without clearing its Career
Transition Assistance Plan (CTAP) or the Interagency Career Transition
Assistance Plan (ICTAP); and
7. Reemployment Priority List (RPL)
For further information concerning your agency, consult with your agency's Chief
Human Capital Officer, Technical Advisor to the Chief Human Capital Officer, or
Director of Human Resources, as applicable.
Also see OPM's Web site (www.opm.gov) for fact sheets, regulations, and additional
Neither details nor extended assignments to an alternate worksite have an impact on an
employee's retirement, health insurance, or life insurance benefits. Employees covered
under special group provisions of the Civil Service Retirement System or the Federal
Employees' Retirement System, such as law enforcement officers or firefighters; continue
under the special group provisions while on detail.
Employee Roles and Responsibilities
While agency management is responsible for designing employee status, employees also
have an important role in assuring the safety of themselves and teammates in the
workplace. Employees should:
1. Become Familiar with agency procedures and the means of notification that an
agency will use to inform and instruct employees;
2. Ask questions about the agency procedures and talk to managers about any
suggestions which could improve safety;
3. Volunteer to assist in evacuation procedures and other duties during an
4. Become familiar with agency protocol, including knowledge of garments (arm
bands, caps, etc.) worn by floor team leaders, monitors and other volunteers;
5. Create a personal safety kit for emergencies and store it at the workspace.
Appropriate items might include–required medication, bottled water, long-
sleeved shirt or jacket, and emergency contact numbers;
6. Follow the instructions of designated emergency personnel; and
7. Remain vigilant, and report any suspicious circumstances.
Additional information for employees is available in "A Federal Employee's Emergency
Guide," which is posted on the Office of Personnel Management's (OPM's) Web site
ANNEX I – TEST, TRAINING AND EXERCISE (TT&E) PROGRAM
Testing, training, and exercising of COOP capabilities is essential to demonstrating,
assessing, and improving the ability of agencies to execute their COOP plans. Training
familiarizes COOP personnel with the essential functions they may have to perform in an
emergency. Tests and exercises serve to assess, 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.
Agencies must develop and maintain a COOP test, training and exercise program for
conducting and documenting TT&E.
1. The agency test program must include:
a. Quarterly testing of COOP alert, notification, and activation procedures;
b. Semi-annual testing of plans for the recovery of vital classified and
unclassified records, critical information systems, services, and data;
c. Quarterly testing of COOP communications capabilities; and,
d. Annual testing of primary and backup infrastructure systems and services at
alternate operating facilities (e.g., power, water, fuel).
2. The agency training program must include:
a. Annual COOP awareness briefing (or other means of orientation) for the
b. Annual team training for COOP personnel;
c. Annual team training for agency personnel (and host or contractor personnel)
assigned to activate, support, and sustain COOP operations at alternate
d. Annual exercise that incorporates the deliberate and pre-planned movement of
the COOP personnel to an alternate operating facility; and,
e. A comprehensive debriefing conducted after each exercise for the participants
to identify systemic weakness in plans and procedures and recommend COOP
3. The agency exercise program, conducted annually at a minimum, must require:
a. An opportunity for COOP personnel to demonstrate their familiarity with
COOP plans and the capability to continue essential functions; and
b. The deliberate and pre-planned movement of COOP personnel to an alternate
c. Communications capabilities and inter- and intra-agency dependencies.
The following table may be useful in developing a training program plan.
Table I-1: Training Program Plan
The following table may be useful in developing an exercise program plan.
Table I-2: Exercise Program Plan
ANNEX J – DEVOLUTION OF CONTROL AND DIRECTION
The full spectrum of threats, including notice and no-notice catastrophic attacks, and all-
hazards emergencies has prompted the Federal Executive Branch to review contingency
planning scenarios for COOP. The possibility that threats or attacks could render Federal
Government operations unavailable, for even the slightest period, is unacceptable, as
essential functions must continue. Therefore, the need to address catastrophic
possibilities and the concept of devolution is critical to ensure the continuation of
Devolution planning supports overall COOP planning and addresses catastrophic or other
disasters rendering an agency's leadership and staff unavailable to or incapable of
performing its essential functions from either its primary or alternate facility(ies). The
COOP devolution option should be developed to address how an agency will identify and
transfer its essential functions. At a minimum the plan should:
1. Identify prioritized essential functions and determine necessary resources to
facilitate their immediate and seamless transfer to a devolution site;
2. Include a roster identifying fully equipped and trained personnel at the designated
devolution site with the authority to perform essential functions and activities
when the devolution option of COOP is activated;
3. Identify the likely triggers that would initiate or activate the devolution option;
4. Specify how and when direction and control of agency operations will be
transferred to the devolution site;
5. List necessary resources (people, equipment, and materials) to facilitate the ability
to perform essential functions at the devolution site;
6. Establish reliable processes and procedures to acquire resources necessary to
continue essential functions and sustain operations for extended periods; and
7. Establish capabilities to restore or reconstitute agency authorities to their pre-
event status upon termination of devolution.
The devolution site and personnel must be capable of supporting all the COOP essential
functions and activities of the devolving organization, as listed in this FPC.
ANNEX K – RECONSTITUTION OPERATIONS
Agencies must identify and outline a plan to return to normal operations once agency
heads or their successors determine reconstitution operations can begin to resume normal
business operations. Agencies must:
1. Provide an executable plan to transition from COOP status to an efficient normal
operations status once a threat or disruption has passed.
2. Coordinate and pre-plan options for reconstitution of an agency regardless of the
level of disruption causing implementation of its COOP plan. These options must
include movement from the COOP or devolution location to the originating
operating facility or a new operating site if necessary.
3. Outline procedures necessary to affect a smooth transition from a relocation site,
whether standard COOP or devolution scenario, to a new or restored headquarters
1. Inform all personnel that the threat of or actual emergency no longer exists, and
provide instructions for resumption of normal operations.
2. Supervise an orderly return to the normal operating facility or movement to other
temporary or permanent operating facility.
3. Verify that all systems, communications, and other required capabilities are
available and operational and that the agency(ies) are fully capable of
accomplishing all essential functions/operations at the new or restored facility.
4. Agency HQ POC reports status of the relocation to the FEMA Operations Center
(FOC) and other points of contact, as necessary.
5. Conduct an after-action review of COOP operations and effectiveness of plans
and procedures, identify areas for correction, and develop a remedial action plan
as soon as possible after the reconstitution.
ANNEX L- GLOSSARY
Activation – When a COOP plan has been implemented whether in whole or in part.
Agencies – Federal Executive Branch departments, agencies, and independent
Agency Head – The highest-ranking official of the primary occupant agency or a
successor or designee selected by the official.
Alternate facility – A location, other than the normal facility, used to carry out essential
functions in a COOP situation.
Automated Data Processing (ADP) equipment – Equipment that performs data
processing largely by automatic means.
Collateral damage – Injury to personnel or damage to facilities that are not the primary
target of attack.
Consumable office supplies – General supplies that are consumed in office use.
Continuity of Government (COG) – A coordinated effort within each branch of the
Federal Government to ensure the capability to fulfill minimum essential responsibilities
in a catastrophic emergency to ensure the capacity to maintain an enduring constitutional
Continuity of Operations (COOP) – The activities of individual departments and
agencies and their sub-components to ensure that their essential functions are performed.
This includes plans and procedures that delineate essential functions; specify succession
to office and the emergency delegation of authority; provide for the safekeeping of vital
records and databases; identify alternate operating facilities; provide for interoperable
communications; and validate the capability through tests, training, and exercises.
COOP Event - Any event that causes an Agency or Department to relocate operations to
an alternate site to assure continuance of its essential functions.
Critical Infrastructure Protection (CIP) – Risk management actions intended to
prevent a threat from attempting to, or succeeding at, destroying or incapacitating critical
infrastructures. Critical infrastructures are those systems and assets so vital to the Nation
that their incapacity or destruction would have a debilitating impact on national security,
national economic security, and/or national public health or safety.
Delegation of authority – Specifies who is authorized to act on behalf of the D/A head
and other key officials for specific purposes.
Devolution – The capability to transfer statutory authority and responsibility for essential
functions from an agency's primary operating staff and facilities to other employees and
facilities, and to sustain that operational capability for an extended period.
Drive-Away Kit: A kit prepared by, and for, an individual who expects to deploy to an
alternate location during an emergency. It contains items needed to minimally satisfy
personal and professional needs during deployment.
Emergency Coordinator – This is the key senior official appointed within an
organizational element or higher who serves as the coordinator for all National Response
Plan and Incident Management System COOP related matters.
Emergency Operating Records – Records that support the execution of an agency's
Enduring Constitutional Government (ECG) – A cooperative effort among the
Executive, Legislative, and Judicial branches of government, coordinated by the
President, to preserve the capability to execute constitutional responsibilities in a
ERG Member – Emergency Response Group member. A person assigned responsibility
to report to an alternate site, as required, to perform agency essential functions or other
COOP related operations.
Essential functions – Functions that enable the Federal government 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.
Essential resources – resources that support the Federal government's ability 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.
Executive Agent – A term used to indicate a delegation of authority by a superior to a
subordinate to act on behalf of the superior. An executive agent may be limited to
providing only administration and support or coordinating common functions, or it may
be delegated authority, direction, and control over specified resources for specified
Interagency Agreements – A written agreement entered into between agencies that
require specific goods or services to be furnished or tasks to be accomplished by one
agency in support of the other.
Interoperability – 1. The ability of systems, personnel, or agencies to provide services
to and accept services from other systems, personnel, or agencies and to use the services
so exchanged to enable them to operate effectively together. 2. The condition achieved
among communications-electronic systems or items of communications-electronics
equipment when information or services can be exchanged directly and satisfactorily
between them and/or their users.
Interoperable communications – Alternate communications that provide the capability
to perform essential functions, in conjunction with other agencies, until normal
operations can be resumed.
Legal and financial records – Records that are needed to protect the legal and financial
rights of the Government and of the persons affected by its actions.
Mission critical data – Information essential to supporting the execution of an agency's
Mission critical systems – ADP equipment essential to supporting the execution of an
agency's essential functions.
Multi-year strategy and program management plan – A process that ensures the
maintenance and continued viability of COOP plans.
Occupant Emergency Plan (OEP) – A short-term emergency response program that
establishes procedures for safeguarding lives and property.
Orders of succession – Provisions for the assumption of senior agency offices during an
emergency in the event that any of those officials are unavailable to execute their legal
Originating facility – The site of normal, day-to-day operations; the location where the
employee usually goes to work.
Reconstitution – The process by which surviving and or replacement agency personnel
resume normal agency operations from the original or replacement primary operating
Risk analysis – The identification and assessment of hazards.
Telecommuting locations – Those locations set up with computers and telephones that
enable employees to work at a location closer to their house than their main office.
Test, Training, and Exercises (TT&E) – Measures to ensure that an agency's COOP
program is capable of supporting the continued execution of its essential functions
throughout the duration of a COOP situation.
Virtual offices – A location or environment where an employee performs work through
the use of portable information technology and communication packages.
Vital databases – Information systems needed to support essential functions during a
Vital records – Electronic and hardcopy documents, references, and records needed to
support essential functions during a COOP situation. The two basic categories of vital
records are emergency operating records and legal and financial records.
Weapons of Mass Destruction (WMD) – Weapons that are capable of a high order of
destruction and/or of being used in such a manner as to destroy large numbers of people.
Weapons of mass destruction can be high explosives or nuclear, biological, chemical, and
Work-at-home – When an employee carries out their work duties at their residence
rather than their official duty station.
June 15, 2004 FPC 65
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