National Continuity
The
Federal
Continuity Directives are about keeping the government running and
providing the American people with information. It is where the rubber
meets the road.
The two new Federal Continuity Directives (FCD) turn continuity of
operations policy as stated in NSPD-51, HSPD-20 and FPC 65 into action.
COOP (Continuity of Operations Planning) is the disciplined planning
you do in advance to respond to a natural or man-made emergency.
If your agency/office needs to relocate, your COOP is your coordinated,
efficient action to keep operating. No two COOPs are like; each COOP is
unique to each agency based on their day-to-day operations.
Issued by FEMA in February 2008, FCD 1&2 pave the way for
providing
the overall framework for continuity of operations in the federal
government. Responsible for providing federal agency leadership for
continuity of operations programs is Major General Martha Rainville
(USAF Ret). She brings to FEMA a wealth of knowledge and experience
stemming from 27 years of military service.
The
Unknown Emergency
MG Rainville told the audience at the recent AFCEA Homeland Security
Conference that every federal department and agency must not only
identify what is most important for them to do in any type of
environment, but they must plan for it.
Continuity cannot be a separate office anymore. It must not be a small
group of people in the corner in the office and nobody knows what they
are doing. Continuity needs to be part and parcel of everything that we
do and part of all of our business plans explained MG Rainville.
FCD 1&2 take continuity a step further. One of the
changes in
the continuity directives is that you now have to plan for a no warning
emergency. This changes how an agency approaches continuity issues.
“We must live it and breathe it,” MG Rainville
continued.
For agencies that means continuity is not a one-time exercise; it is an
exercise that is practiced until you know you are able to continue your
essential functions. Everyone is ready to spring into action
with
little or no notice. It requires agencies to really integrate
continuity with the rest of their operations.
Coordination
That Works
National continuity planning also requires coordination with state,
local, tribal and territorial governments as well as the private
sector. Because the private sector owns the vast majority of the
nation’s infrastructure, we have a nation that is a
“system
of systems” that is incredibly integrated.
MG Rainville explained the national continuity policy implementation
plan identifies more than 75 critical continuity actions, and it
outlines roles and responsibilities for major players across the realm
of continuity. It also makes full use of FEMA’s
Readiness
Reporting System (RRS). The RRS is a system that tracks readiness
across federal departments and agencies. “It’s a
dashboard,
so federal leadership can know the status of all the federal
departments and agencies,” said MG Rainville. “We
provide
readiness updates through the system, and this also is good business
and we are looking at ways to continue to improve our RRS.”
90
Days: An Aggressive FCD Timeline For Submission
MG Rainville said the FCDs actually have a pretty aggressive submission
timeline for agencies. They were signed in February 2008 and now
departments and agencies have 90 days to submit their mission essential
functions (MEFs) and to identify what they feel are the primary mission
essential functions (PMEFs). Even if an agency may have
already
done so, they have to revalidate their central functions and their
PMEFs within the 90 days. Then they make their submission to DHS who
has 30 days to go through them before submitting them to the National
Continuity Coordinator.
According to MG Rainville, The National Continuity Coordinator sets up
an interagency board made up of representatives from the agencies with
experience in this and that board will then vet the primary mission
essential functions. “We’ll see where they are
reliant on
other departments and agencies for essential functions, so that we get
a better map of where the fail points might be and where the support
needs to be,” said MG Rainville.
The next six months are critical. “We are doing this by
pulling
together. Necessity is the mother of invention and we are learning that
we have to work together,” explained MG Rainville.
“So we
have built courses; we are putting on more courses so we have had great
support from our contractors to do that, but there’s a lot
more
work to be done and it’s going to come down to the
wire.”
IT: The
COOP Enabler
Networks must connect. Applications must be streamed. Computer screens
must look familiar. Security must be maintained at all costs.
Government business must continue.
The responsibilities of making “what absolutely must
continue” continue rests with an agency’s IT
professionals
and contractor partners. Not only do they have to inventory their
technology, they need to make sure their COOP – with backup
to
the backup – is ready to deliver IT applications and services
to
a
“teleworking” workforce.
“We are really getting to the person who needs to depend on
health care, who needs to depend on the government for essential
services, who needs to depend on a secure border,” said MG
Rainville. “It is all of these things that need to be there,
no
matter what. It’s where the rubber meets the road.”
What Policy Says
FPC-65 policy states that government must have in place a comprehensive
and effective program to ensure continuity of operations for essential
Federal functions under all circumstances – a COOP. 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.
An outgrowth of HSPD-20 and NSPD-51, Federal Continuity Directive 1
(FCD 1) provides direction to the Federal Executive Branch for
developing continuity plans and programs. What FCD 1 says is that it is
just not good practice to plan to have continuity planning, it is
mandatory practice. MG Rainville says FEMA will help agencies by
setting standards for continuity facilities, for their alternate
locations, by establishing minimum communication standards so they
understand what is required at the primary and alternate locations,
what types of communications and what levels of communications must be
in place.
FCD 2 implements the requirements of FDC 1 and provides guidance and
direction for identification of their MEFs and potential PMEFs. It
includes guidance and checklists to assist departments and agencies in
assessing their essential functions through a risk management process
and in identifying potential PMEFs that support the National Essential
Functions (NEFs). Potential department and agency PMEFs and supporting
materials must be submitted to DHS within 90 days of approval of FCD 2.
FCD 1&2 were issued in February 2008. Download them from
www.FEMA.gov.
“We are helping departments and agencies to go through a
process
to identify their mission essential functions and then to derive from
those their primary mission essential functions,” said MG
Rainville.
Sources: GSA; FEMA; DHS
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