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Elements for Continuity of Operations

 

The DHS Nationwide Plan Review Phase 2 Report identified that most emergency operation plans do not reflect sufficient COOP or continuity of government (COG) planning. A significant number of states (59%) and urban areas (65%) do not have a concept of operations in place that is judged to be sufficient for a catastrophic event. Formal plans that describe the general sequence of actions, supported by checklists that describe detailed actions for different threats and hazards, are vital in catastrophic incidents when multi-agency coordination reaches national proportions.

The impact of this area of concern is magnified when the lack of sufficient continuity of operations / continuity of government plans (COOP/COG) is considered. Quite simply, a continuity of operations plan (COOP) facilitates the performance of essential functions during an emergency situation that disrupts normal operations, and it provides for the resumption of normal operations once the emergency has ended.

A review of COOP guidance documents has been conducted to identify a compilation of COOP elements. The literature review focused on available public domain documents circa 2002-2005. The identified COOP elements should be used to develop a local government COOP and be considered as policy recommendation to local government for COOP development. COOP templates can vary in document structure and format from federal, state and local government, however, the identified COOP elements should be contained in all COOP templates and not vary.

Necessary COOP Elements
The COOP elements that should be used when developing a COOP begin with the “Purpose / Objective.” This section states the purpose or objective of the COOP plan. The section should clearly indicate that the plan seeks to maintain only critical services during an all-hazard event. For example, LLIS recommends: “This COOP provides guidance for, and facilitates the preparation of, site- or activity-specific plans and procedures that help ensure the safety of personnel at the alternate facility and allow organizational elements to continue essential operations in the event of an emergency or threat of an emergency. The planning guidance and the plans to be developed in accordance with it do not address day-to-day activities that enable an organization to conduct or safeguard routine operations.”

Next, the “Continuity of Government” has been defined as the preservation, maintenance, or reconstitution of the civil government’s ability to carry out its constitutional responsibilities. Continuity of government is concerned with the full range of governmental services, including the three branches of government (judicial, legislative, and executive) and all levels of government (federal, state, and local). Continuity of operations is a planning concept that focuses on government’s ability to continue essential functions. While these two concepts can be delineated, they are functionally similar for COOP leadership during activation.

The section on “Applicability and Scope” describes to whom and what the plan applies, under what circumstances, and with what limitations. Example: “The provisions of this COOP are applicable to all [insert agency name] personnel located at [insert your agency address and include your zip code]. This plan is applicable to the full spectrum of man-made, natural, and technological emergencies and threats, with the exception of civil defense matters, which are addressed in other documentation.”

Under “Authorities and References,” the COOP plan must list state and local ordinances and statutes that affect government, emergency, and continuity planning, such as the state emergency management acts, local emergency operations plans, authorizing laws and executive decisions, etc. This section refers future readers to relevant plans and authorizing documents.

Agencies must prepare plans for implementing each element of the COOP plan throughout the period of disruption, from initial activation to final reconstitution. COOP implementation can consist of: preparedness, activation, devolution, response, relocation, recovery, and termination of the COOP after recovery.

As for “Classification of Emergencies and COOP Responses,” many of the incidents requiring COOP implementation will be small in scale and occur frequently. Agencies should define the severity of emergencies and tailor the level of COOP plan implementation to meet their needs. With “Delegation of Authority to Key Personnel,” the authority to make key emergency decisions during a COOP event must be clear and compliant with state and local law. COOP plans must delineate and limit the authority that key COOP personnel will have during an event. The loss of an agency or department head and others in key positions requires detailed orders of succession.

Incident Command System
The Incident Command System (ICS) and the National Incident Management System (NIMS) should be incorporated into COOP planning if possible. ICS describes the structure for command and control of the emergency and should be used when the COOP plan is activated. Including ICS as a COOP element serves as a reminder for the person activating the COOP to make sure he is using ICS. Every COOP plan must delineate the essential functions, services, and activities carried out by the agency. The plan must also identify the personnel, facilities, and resources required for each function or service.

The loss of a primary operating facility must be accounted for in a COOP plan. A plan should identify alternate facilities that enable the agency to re-establish critical services within 12 hours after the loss of the primary facility. The alternate facility must be able to support critical mission systems.

Drive-away kits are designed for personnel to pack and go. The drive-away kit can consist of simple things like office supplies, small office equipment, copies of policies, plans and procedures. This simple concept is critical to making an alternate facility productive in a quick manner.

Communications systems should be able to support an agency’s essential functions and internal / external communications during a COOP implementation. The communications component of a COOP plan should identify protective measures for critical communications systems, establish backup systems, and detail contact lists for key personnel. There is the possibility that an incident may take away day-to-day communication systems and methods. If it becomes necessary to occupy the alternate work location, it will be necessary to ensure that communications systems are in place so that essential operations can continue unabated.

In order to maintain critical services to the public, government agencies must protect the vital records, documents, databases, and information systems that support the agency’s essential functions. Agencies should create a records management system that protects vital documents and systems in an emergency. In any COOP activation, finances become a critical issue within a few hours as expendable resources are used up and labor costs mount. It makes sense to incorporate in the COOP guidelines on financial management during activation. Anymore, financing is occurring electronically. The loss of power occurs in many all-hazard events. Having a plan in place to ensure purchasing and expenditures is critical.

A security provision should be included in COOP development that includes security measures for personnel, records and alternate facilities or protection of government resources, facilities and personnel. Given that the COOP will be activated during an all-hazard event, which could easily mean the hazard poses an immediate threat to resources, facilities and personnel, ensuring that security measures are taken will lend itself to the continuity of operation.

Staff / Dependent Care Plans
The protection of personnel and their families is of paramount importance. Employees are unlikely to work at an alternate location for an extended period of time if their families are in danger. COOP plans should work out programs for shelter of dependents during relocation at the alternate location or a nearby facility.

Another critical concern in COOP personnel management is the loss, unavailability and relief of personnel during an all-hazard event. Plans should be made for staff augmentation with the knowledge that mutual aid can be requested but may or may not be available. In addition, plans should reflect the scaling back to essential services during a work-force reduction, for example a pandemic flu. The timeliness of local, state and federal personnel will vary based on the breadth of the all-hazard event.

Having personal needs met assists in personnel morale. Personal plans should include a plan for the employee’s family so the employees can be assured their families are being taken care of during an all-hazard event. A lesson learned from New Orleans was that many of the first responders did not have personal plans for their families and became more concerned with taking care of their families rather than performing their jobs.

Include necessary photographs, charts, rosters and maps in the COOP to provide personnel resources for COOP activation and response. It is also imperative that up-to-date personnel rosters are available to account for personnel during an all-hazard event and for return to duty procedures.

Familiarity with COOP plans and procedures can be fostered through tests, orientation, training, table-top exercises, and full-scale exercises. Agency employees must participate in training and exercises to familiarize themselves with emergency procedures and their roles in COOP response.

After-Action Reports
The organization structures of local governments / jurisdictions change over time, as do the functions assigned to specific agencies. To ensure that COOP plans always reflect current organization conditions, they should be reviewed as part of the training and exercise program. Changes in an agency’s organization structure, function or mission, and service to clients should be made to the plan as they occur.

It is critical that after-action reports become a part of a COOP for two very important reasons: the after-action report memorializes COOP effectiveness for historical / research purposes, and it is a mechanism to learn what worked well and what did not. A revised COOP can result from after-action reports.

There are two policy implications that can be recommended. This is not to suggest that this is an all-inclusive list of policy implications, rather, it is a list that was developed for this article. First, utilize the necessary COOP elements for COOP development and into COOP templates for structure and format.

The compilation of COOP elements can become part of the 2006 Nationwide Plan Review Phase 2 Report federal government’s desired outcome for Goal #24. It calls for the creation of a performance management framework that tracks performance against standard capabilities and tasks as reflected in synchronized plans across levels of government to include continuity of operations and government as a priority performance measure.

COOP templates should not be relied on too heavily, and COOP developers should “own” the process, making the COOP specific for the local jurisdiction. The two templates reviewed, Florida and the modified Ohio plan, offer the necessary structure and format and incorporate the majority of the compilation of COOP elements. However, Florida’s COOP template is the most comprehensive. The best part of the Florida COOP template is it has been the basis of local COOP development in Florida since 2002.

Florida is known for its hurricane season, and local entities have pragmatically exercised their COOPs in an all-hazard event. In fact, Florida was rated by the DHS in 2006 as a “bright spot” receiving “sufficient”—the highest rating given for states with response plans. Florida, accustomed to being whipped with hurricane winds, was the only state assessed as ready in all nine categories of catastrophe planning. Florida’s COOP template has practical utility.

Ohio’s COOP template was developed in 2005 using many of the same documents that were reviewed for this article. Ohio is still in the process of “rolling out” its COOP template, and very few local governments have finished developing their COOPs using Ohio’s suggested template. Ohio’s COOP template consists of many, but not all, of the identified compilation of COOP elements.

An after-action report (AAR) is a review processes that details what happened, why it happened and how can it be done better. An AAR is about learning, not about finger pointing or even fixing a problem. Conducting AARs should focus on improving a process, policy and/or procedure. AARs can be conducted as part of external and/or internal evaluations. Requiring an AAR in a COOP will assist in a COOP review focused on improving the COOP and with the goal of getting better at executing the COOP during an all-hazard event. Furthermore, AARs will provide a valuable resource for COOP research as the AARs become available.

In January 2006, the city of Norwalk, OH started the process of writing its continuity of operations plan for the city and every department within its structure. On June 22, 2006, Norwalk experienced a 100-year storm, and flooding was prevalent throughout the municipality. A state and national emergency was declared for the region. The storm drove home the need to complete the city’s COOP project, which occurred in January 2007. Photographs attached to this article are from Norwalk’s flood.

Kevin Cashen is chief of the Norwalk, OH Police Department. He attended the FBI National Academy and is a certified law enforcement executive through the Ohio Association of Chief of Police. He can be reached at kcashen@mail.norwalkohiopolice.com.

Published in Law and Order, May 2008

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