Continuity Planning in Emergency Management: Is Your Agency Ready?

by Stephen Owen, Criminal Justice Chair and Professor, Radford University, E-mail: ssowen@radford.edu

The purpose of this article is to advocate the significance of continuity of operations planning, and to provide links to resources that may aid in the continuity planning process.  Doing so can help agencies and organizations to plan for contingencies that may disrupt their usual practices.  Now is an appropriate time to reflect on continuity planning, as the Federal Emergency Management Agency (FEMA) has released a new draft Continuity Guidance Circular, containing useful perspectives on the process for developing a continuity of operations plan and condensing material from its previous circulars (which form the basis for this article).[1]

Overview of Continuity Planning

Continuity of Operations Planning, also known as “COOP,”[2] involves considering how an agency would respond if its usual daily operations were curtailed.[3]  Engaging in continuity planning generates proactive preparations that allow an agency to have a framework in place to ensure that as many of its functions as possible can continue to be carried out, even when operations are disrupted.  While certainly not an exhaustive list, consider the following examples of when a continuity plan might need to be implemented.

In cases of pandemic flu, normal operational practices can be greatly strained.  A report from the National Governor’s Association stated that “Epidemics could last six to eight weeks in affected areas.  Multiple waves of illnesses are likely, with each wave lasting two to three months.  During each wave, absenteeism rates could reach 40 percent.”[4]  An excellent resource from the Police Executive Research Forum provides a series of case studies about how local law enforcement agencies (including Fairfax County in Virginia) considered options for addressing personnel shortages and how some law enforcement functions may have to be deferred until the conclusion of the pandemic.[5]  Similar documents have addressed the needs of community corrections, including how offender supervision might be impacted, based on guidelines set by the American Probation and Parole Association;[6] challenges pertaining to court activities, including caseloads and orders that could be associated with a pandemic situation, with guidelines developed in a collaboration between American University and the Bureau of Justice Assistance;[7] and a planning checklist for correctional institutions developed by the Centers for Disease Control.[8]

The focus on pandemic planning, described above, was influential in leading agencies and organizations to consider (and in many cases newly develop) their continuity of operations plans, particularly as there was concern about the H1N1 (swine flu) and H5N1 (bird flu) strains in the 2000’s.  However, there are innumerable other incidents that could lead to agency disruptions calling for continuity plans.  For instance, some inmates had to be evacuated from their housing units at Louisiana State Penitentiary at Angola, Louisiana when floodwaters from the Mississippi river overcame one of the prison’s levees.[9]  In the wake of a chemical fire in Apex, North Carolina, the city’s emergency operations center, police department, and dispatch center had to be evacuated.[10]  Just this year, a tornado destroyed the fire department’s facility in Autryville, North Carolina.[11]  In each of these instances, usual operations were disrupted.

Continuity plans can also be invoked when the response to a large-scale incident precludes the accomplishment of other tasks, at least until mutual aid or other assistance arrives.  Or, they can become necessary in a large-scale power outage if generators were to fail (or be depleted of fuel), depriving full use of facilities, information systems, and other resources.  In short, there are a variety of circumstances that can impair an agency’s ability to fully meet its mission and operational duties, and it is these circumstances for which continuity plans are designed.

At this point, it is important to draw a distinction.  Continuity plans are invariably invoked when a disaster or crisis is ongoing – it is often that disaster or crisis that led to the need for the continuity plan to be implemented in the first place.  It is the role of the incident action plan, consistent with incident command system principles, to address the specific impacts of the disaster or crisis.  Conversely, it is the role of the continuity of operations plan to allow the agency to continue meeting its mission-essential functions.  For example, if a hazardous materials spill were to cause the evacuation of a public safety facility, the incident action plan would focus on how to clean up the spill, manage any necessary evacuations, establish perimeters and cold-warm-hot hazmat zones, and related activities.  However, the public safety complex’s continuity of operations plan would help agencies determine how to continue providing services to the public, even when their usual operations have been disrupted due to the evacuation from their facility (and the equipment, records, communication systems, and other resources that would invariably be left behind in a rapid evacuation).

The remainder of this article will provide perspectives for developing and testing continuity plans.

Preparing for Continuity Planning

As a starting point, there are four preliminary actions that can assist with continuity planning.

Determining a responsible officer. The first action is to determine who has the legal or regulatory authority to develop a continuity plan for an agency.  In many cases, the task of developing and testing the plan will be delegated to a different person (often an emergency manager or planner) than the position or entity holding approval authority.  Stand-alone agencies and organizations may encounter fewer bureaucratic hurdles than those that fall under a larger umbrella organization – but it is important to know the required approval authorities and how the agency’s COOP fits within them.

Of course, this presumes that the agency leadership is supportive of (or aware of) the need to develop a continuity plan.  The Federal Emergency Management Agency (FEMA) provides resources including a briefing guide[12] and training guide[13] to promote buy-in from agency leadership.

Review available resources. The second action is to review the resources that are available pertaining to continuity planning.  The key FEMA documents are the Continuity Guidance Circular series, referenced in the next section of this article; FEMA also maintains a website of continuity planning resources.[14]  State-specific guidance is also of value, and the Commonwealth of Virginia’s Department of Emergency Management (VDEM) has developed webpages specifically for state agency continuity planning[15] and local government continuity planning.[16]  The VDEM resources provided for local government would also be of value to other organizations seeking to develop continuity plans, such as nonprofits or even businesses, as the broad concepts of continuity planning need not be specific to any single type of agency.  On the VDEM local government page, for instance, there are Word-fillable continuity plan templates, a planning guide, and a series of worksheets that help agencies walk through the types of questions that must be answered and information that must be considered in developing agency-specific plans.

Designate a point person. The third action is to, as resources permit, designate a point person who has a sound understanding of continuity principles, and whose responsibility it will be to ensure that the continuity plan is maintained, kept up-to-date, tested on a predesignated schedule, and incorporated into exercise designs when possible.  When several agencies or organizations in the same jurisdiction are developing or reviewing continuity plans, it would also be advisable to develop a working group of representatives from each agency or organization to collaborate during the process.  The benefits of doing so include ensuring that plans do not conflict with one another (e.g., if two agencies identify the same location as a continuity facility – more on continuity facilities below), to explore potential collaborations that can lead to more efficient utilization of resources (e.g., an emergency communication system utilized by multiple agencies), and to ensure that agencies that frequently work together have an awareness of one another’s plans, which will enable working partnerships to continue more seamlessly when functioning in continuity mode.

FEMA provides a number of self-study courses related to continuity planning, through the Emergency Management Institute’s (EMI) independent study program.[17]  The two most foundational courses are IS-546a (“Continuity of Operations Awareness Course”)[18] and IS-547a (“Introduction to Continuity of Operations”).[19]  FEMA also offers credentials as part of its Continuity Excellence Series, as a Professional Continuity Practitioner and a Master Continuity Practitioner.[20]  The former requires completion of a variety of courses, most of which are available online, and the latter requires a combination of coursework and delivery of COOP-related instruction.  For larger agencies in particular, a staff member with either (or both) of these credentials can be an asset in the planning, training, exercising, and (if necessary) implementation of continuity plans.

Conduct an environmental scan. The fourth action is to conduct an environmental scan to anticipate the types of incidents that might necessitate the implementation of a continuity plan.  Of course, planning should follow FEMA’s all hazards model, recognizing that it’s best to be prepared for a broad array of incident types; at the same time, a review of the jurisdiction’s Hazard Mitigation Plan and Threat and Hazard Identification and Risk Assessment (THIRA) can yield valuable insights and can also aid in the design of continuity-based exercises.  A broader awareness of resources and geography of the jurisdiction can also aid in tasks such as identifying continuity facilities, anticipating communication and information resource needs, and more.

Developing (or Reviewing) the Plan

If your agency or organization has a continuity plan, that’s a sign of proactive emergency planning; still, it is beneficial to conduct a periodic review of all plans.  If your agency or organization does not have a continuity plan, there is no time like the present to develop one.

As noted above, state guidance is often available for continuity planning, and particularly for Virginia agencies and organizations, through the useful resources provided by VDEM.  The discussion below will follow from the two foundational documents offered by FEMA to guide non-federal continuity planning.  They are Continuity Guidance Circular 1: Continuity Guidance for Non-Federal Governments[21] and Continuity Guidance Circular 2: Continuity Guidance for Non-Federal Governments: Mission Essential Functions Identification Process.[22]  Ironically, the guidance provided in Circular 2 needs to be considered before that in Circular 1.

What follows is a very abbreviated discussion of considerations from each circular, which ultimately lead to the composition of the final continuity plan for an agency or organization.  Generally speaking, these are consistent with VDEM’s guidance, worksheets, and templates.

Mission-Essential Functions.  Each agency or organization accomplishes a variety of functions, through its policies, programs, and operations.  The first step in continuity planning is identifying the agency or organizational functions that must be accomplished, whether by law or as a key part of the organizational mission – these are mission-essential functions, a concept fully addressed in Circular 2.  For instance, for a law enforcement agency, of course, enforcement of the law and maintenance of public order would be mission-essential functions.  Maintaining a fleet of vehicles and keeping records of actions (e.g., arrests) would be support functions necessary to accomplish the mission-essential functions.  However, training and community service roles (e.g., crime prevention presentations, community meetings) could likely be deferred.

In a continuity setting, only mission-essential functions, and those supporting functions that facilitate them, are preserved.  All other non-essential functions are deferred.  In some cases, agencies or organizations may be asked to map their mission-essential functions to broadly stated National Essential Functions or State, Territorial, and Tribal Essential Functions (again specified in Circular 2), or to priorities articulated by the state or locality.

The goal is to plan for mission-essential functions to be restored within a specified timeframe, so the work of the agency or organization can continue.  The rest of the continuity plan is based around the mission-essential functions, as the items that follow are entirely focused on accomplishing them when normal operations are otherwise disrupted.  Each is detailed further in FEMA’s Circular 1.

Determining Phases.  No two incidents are the same, but a continuity plan needs to include a recognition of three phases:  1) Activation, in which the plan, including some combination of the below elements, is put into effect within 12 hours of an incident; 2) Continuity, in which the plan is operational with a focus on achieving only mission-essential functions; and 3) Reconstitution, which is the transition to return to normal operational procedures.

It is important for the plan to clearly indicate the criteria under which it will be invoked and how that will be communicated – likewise for reconstitution.  The following items are the elements of the plan that may be put into effect.  In some cases, only one may be necessary, such as a temporary relocation to a different facility; in other cases, all may be necessary.

Order of Succession.  Key leadership roles should have designated orders of succession, so it is clear who will provide leadership and management if administrators or unit heads are unavailable; this is not only due to circumstances such as illness or injury, but also when personnel simply are away from the area at the time of an incident.  It is recommended that orders of succession go three-deep and identify successors by position and title rather than by name (since personnel can change).

Delegation of Authority.  This goes along with order of succession, although one is not necessarily required for the other, per se.  This refers to authorities not usually associated with one’s position that are permitted in exigent circumstances.  Unlike orders of succession, these may need to be listed by position or by name – the latter if credentialing or training must be documented.  Because delegation of authority empowers actions normally outside one’s level of authorization, it is important for such delegations to be carefully documented, potentially with a need for review by counsel or governing boards, and for appropriate parties to be aware when they are enacted.

Continuity Facilities.  These are facilities that can be utilized if a primary location is damaged or otherwise cannot be occupied (e.g., due to hazardous materials).  Continuity facilities can be fully equipped to become operational at the flip of a switch, or can simply be shells of spaces that remain to be equipped with necessary materials; the former are more costly, but the latter are more challenging to make operational in a time of crisis.  As a general rule, when possible, continuity facilities should have some geographic separation from the facility they are replacing; this is to ensure that the incident that led to continuity mode does not also impact the continuity facility.  In some cases, similar facilities in adjacent jurisdictions may be used as continuity facilities, such as transferring 911 calls to an another public safety answering point (PSAP) if a jurisdiction’s 911 center must be evacuated.  Telework and similar arrangements may also be considered if there are agency functions that can be completed off-premises.

Continuity Communications.  Standard communications can be impaired in a number of situations.  In an incident of any magnitude, cell phones fail, and power outages can also impair communication.  It is important to classify “communication” broadly, as FEMA notes:  “systems should support full connectivity, under all conditions, among key leadership, internal elements, other organizations, critical customers, and the public.”[23]  This is particularly critical not just to facilitate mission-essential functions, but also to ensure all are aware of the implementation of the continuity plan.

Essential Records Management.  Paper records can be destroyed, electronic systems can crash, server connections can fail, and a variety of other maladies can befall critical data.  It is better to develop backup plans now rather than wait for the inevitable data loss.  In addition to preserving records that are necessary to accomplish mission-essential functions (or which are legally required to be retained), plans should consider how new records and data can be preserved until they can be entered into a permanent records system.  As in any circumstance in which data systems are transitioned or new data sources are created, there should be careful collaboration with information technology personnel to ensure the safety of data and network systems, including protections from malicious activities such as hacking.

Human Resources.  Essentially, this is the distinction between essential personnel (who need to report) and non-essential personnel (who do not need to report, or who can work from alternate locations, or in extreme circumstances can be furloughed).  Human resources offices will likely need to be involved in these decisions, and employees will need to know their status, as this helps them prepare themselves and their families for what to expect (especially if essential personnel are expected to be at a worksite for long periods of time during a crisis impacting the community).

Training and Exercising the Plan

Once a planning process has been completed, staff should be trained on its contents and exercises should be conducted to validate (or revise) its components.  Tabletop exercises can provide useful simulations, but including functional components or drills to test individual pieces of the plan – including its workability and ease (or lack thereof) of operation – are also beneficial.  While there is a strong temptation to structure exercises primarily around response, the continuity function also needs to be practiced on a regular basis.

Conclusion

All agencies and organizations should have, understand, and practice continuity of operations plans.  Doing so helps to ensure that critical mission-essential tasks are not abandoned when a disaster occurs.  The time to consider such eventualities is now, and not when a crisis looms.

 

[1] The new draft circular is open for public comment through July 5, 2017, after which FEMA will review feedback and work to finalize the document.  See https://www.fema.gov/continuity-guidance-circular-cgc.

[2] For an overview of emergency management doctrine and how COOP fits within a larger context, see the author’s “Primer on Emergency Management Response Doctrine” in the prior issue of this Bulletin, at http://www.radford.edu/content/cj-bulletin/home/november-2016-vol-11-no-1/a-primer-on-emergency-management-response-doctrine.html.

[3] For an overview of continuity of operations planning as it pertains to law enforcement, see Owen, S., & Burke, T. (2013, July/August). Continuity of operations planning: Practical considerations for law enforcement. Police and Security News, pp. 36-41.  Available online at https://policeandsecuritynews.com/imgs/archives/2013/digital/JulyAug2013.pdf

[4] National Governor’s Association Center for Best Practices. (2006). Preparing for a pandemic influenza: A primer for governors and senior state officials.  Washington, DC: Author.  Available online: https://www.nga.org/files/live/sites/NGA/files/pdf/0607PANDEMICPRIMER.PDF, quote from page 4.

[5] Luna, A. M., Brito, C. S., & Sanberg, E. A. (2007). Police planning for an influenza pandemic: Case studies and recommendations from the field. Washington, DC: Police Executive Research Forum.  Available online: http://www.policeforum.org/assets/docs/Free_Online_Documents/Public_Health/police%20planning%20for%20an%20influenza%20pandemic%20-%20case%20studies%20and%20recommendations%20from%20the%20field%202007.pdf.

[6] Bancroft, P. (2009). Pandemic influenza preparedness and response planning: Guidelines for community corrections.  Lexington, KY: American Probation and Parole Association.  Available online: https://jpo.wrlc.org/bitstream/handle/11204/349/Pandemic%20Influenza%20Preparedness%20and%20Response%20Planning_Guidelines%20for%20Community%20Corrections.pdf?sequence=4

[7] American University & Bureau of Justice Assistance. (2007). Guidelines for pandemic emergency preparedness planning: A road map for courts.  Washington, DC: Bureau of Justice Assistance.  Available online: https://www.bja.gov/publications/pandemic_road_map.pdf.

[8] Centers for Disease Control. (n.d.). Correctional facilities pandemic influenza planning checklist.  Atlanta, GA: Centers for Disease Control.  Available online: https://www.cdc.gov/flu/pandemic-resources/pdf/correctionchecklist.pdf

[9] Todd, B. (2011, May 22). Prisoners pitch in to keep the mighty Mississippi River at bay.  CNN.  Available online: http://www.cnn.com/2011/US/05/22/flooding/.

[10] Sensenig, D., & Simpson, P. (2008). Chemical fire in Apex, North Carolina. Washington, DC: U.S. Fire Administration.  Available online: https://www.usfa.fema.gov/downloads/pdf/publications/tr_163.pdf.

[11] Cutler, A. (2017, May 23). Group hid under fire engines as tornado destroyed Autryville fire station.  WCNC.  Available online: http://wncn.com/2017/05/23/group-hid-under-fire-engines-as-tornado-destroyed-autryville-fire-station/.

[12] Available online: https://www.fema.gov/media-library/assets/documents/86276

[13] Available online: https://www.fema.gov/media-library/assets/documents/86264

[14] Available online: https://www.fema.gov/additional-resources-and-videos-continuity-operations

[15] Available online: http://www.vaemergency.gov/emergency-management-community/emergency-management-plans/continuity-planning/

[16] Available online: http://www.vaemergency.gov/emergency-management-community/emergency-management-plans/local-government-coop-resources/

[17] The website for the FEMA Independent Study program follows; a search for “continuity” will yield a variety of courses:  https://training.fema.gov/is/crslist.aspx

[18] Available online: https://training.fema.gov/is/courseoverview.aspx?code=IS-546.a

[19] Available online: https://training.fema.gov/is/courseoverview.aspx?code=IS-547.a

[20] Requirements for each are described by FEMA at: https://www.fema.gov/continuity-excellence-series-professional-and-master-practitioner-continuity-certificate-programs

[21] Federal Emergency Management Agency. (2013). Continuity guidance circular 1 (CGC 1): Continuity guidance for non-federal governments (states, territories, tribes, and local government jurisdictions). Washington, DC: Federal Emergency Management Agency. Available online: https://www.fema.gov/media-library-data/1386609058803-b084a7230663249ab1d6da4b6472e691/CGC-1-Signed-July-2013.pdf

[22] Federal Emergency Management Agency. (2013). Continuity guidance circular 2 (CGC 2): Continuity guidance for non-federal governments: Mission essential functions identification process (states, territories, tribes, and local government jurisdictions). Washington, DC: Federal Emergency Management Agency. Available online: https://www.fema.gov/media-library-data/1386609058826-b084a7230663249ab1d6da4b6472e691/Continuity-Guidance-Circular2.pdf

[23] Continuity Circular 1, page H-1.