Continuity of operations doctrine in the United States was built for federal departments with continuity managers, hardened alternate sites and a budget line, and the templates show it. A three-person emergency management office, a two-person radio shop or a small volunteer fire department gets the same forms and quits somewhere around the business process analysis worksheet. The underlying questions still apply, because a shop with three people is the one most likely to lose all of its capability to a single car wreck. What follows is how to answer those questions at a scale a small jurisdiction can write in a week and actually keep current.

Three people and a template written for a cabinet department

FEMA publishes continuity guidance for non-federal organizations in the Continuity Guidance Circular, and the 2018 edition consolidated the two circulars that came before it into a single document aimed at state, local, tribal and territorial governments along with private sector partners. The circular is the right reference, and the agency also maintains a continuity resource toolkit with templates and worksheets, so check FEMA’s site for the current edition rather than working from a copy somebody emailed you in 2015. The federal executive branch works to a separate set of continuity directives that do not bind a county, which matters because a lot of the paperwork burden people associate with continuity planning comes from those federal requirements.

The circular lists a set of program elements, and the four the owner of this site asked me to address, essential functions, orders of succession, delegations of authority and vital records, are the load-bearing ones. The list runs longer than that, adding continuity facilities, continuity communications, human resources, devolution, reconstitution, and a requirement to test, train and exercise the whole arrangement. A large agency treats each element as a chapter with an owner. A small agency can treat each one as a paragraph or a table, and the plan is still a continuity plan as long as the answers are specific and somebody outside the office can find them.

What makes the small-agency version genuinely different is concentration of knowledge. In a department of three, one person holds the radio system administrative credentials, one person knows which grant reimbursements are outstanding and which are closed, and one person has the cell number for the dispatcher’s supervisor at two in the morning. Nobody wrote any of it down because all three of them see each other every day, which works until the day one of them does not come in. The continuity failure in small jurisdictions is almost never a destroyed building, and it is routinely a person who is in the hospital, on a plane, at a funeral out of state, or newly employed somewhere with a better retirement.

Essential functions, cut down to five or fewer

An essential function is something your organization must keep doing, or resume quickly, because stopping it causes harm, breaks a legal obligation, or prevents you from performing your part of the response. Continuity practice separates that from the much longer list of things you normally do, and the separation is the hard part, because everything on a small agency’s task list feels essential to the person who does it. The test I use is a downtime question asked three ways. If we stopped doing this for twelve hours, who gets hurt or what breaks legally. Then ask the same thing at three days, and again at thirty days. A function that produces no answer at thirty days is not essential, and a function that produces a bad answer at twelve hours goes to the top.

For a small emergency management office the list usually ends up close to this: receive and act on a request for assistance from any hour of the day, notify and warn the public, maintain the legal ability to declare and to request state assistance, keep the resource request and expenditure record that a future reimbursement depends on, and staff the emergency operations center when it opens. For a small fire department add apparatus and personnel availability, and for a two-position public safety answering point the entire list may collapse to answering 911 and dispatching, which is worth writing down precisely because everybody assumes it and nobody has checked what happens when both consoles are dark.

Write each function with a downtime tolerance next to it and the minimum staff and equipment it takes, because that pairing is what makes the rest of the plan decidable. If answering the published administrative line has a tolerance measured in hours, then the plan has to say how that number gets forwarded to a cell phone and who is authorized to order the carrier or the county IT office to do it. Business continuity work calls that a maximum tolerable downtime or a recovery time objective, and the standard formerly published as NFPA 1600 has been folded into a consolidated NFPA emergency, continuity and crisis management standard, so verify the current designation and edition with NFPA before you cite it in a plan.

Orders of succession that survive one vehicle

An order of succession answers who holds the position and its authority when the incumbent is unavailable, and it is written by position rather than by name so that it does not go stale every time somebody retires. The common standard is three deep, which in an office of three people forces the third successor to come from outside the organization, and that is where small agencies stall, because the honest answer sends you to a fire chief, a public works director, the county administrator, or the emergency management director in the county next door under a reciprocal designation.

Succession also has to survive a common-cause event. If all three names travel to a regional meeting in one vehicle, work out of one building, and caught the same respiratory virus at a training class that week, then the order of succession listing all three of them has not accomplished anything. Check the list against the question of what single event could remove every person on it, and if you find one, extend the list until you cannot.

Some of this is constrained by law rather than by preference. Many states carry emergency interim succession provisions for local offices, several of them descended from model legislation circulated during the civil defense era and adopted in varying forms, and some authorities attach to an elected office and cannot be handed to an appointed employee at all. Have your county or city attorney read your order of succession and tell you in writing which links in it are legally effective and which are merely operational, and confirm the statutory framework with your state emergency management agency rather than assuming that your neighbor’s arrangement transfers.

The mechanical part gets skipped most often. Somebody has to know that succession has occurred, which means the plan names who makes that determination, how the successor is notified, and who else gets told. At minimum the notification list includes your dispatch center, the chief executive of the jurisdiction, the county attorney, the finance office that will see the successor’s signature on a purchase, and the state emergency management duty officer. A successor with full legal authority and no way to prove it to the finance clerk is going to spend the first day of the incident arguing instead of working.

Delegations of authority with limits, triggers and an end date

Succession says who is in charge, and a delegation of authority says what that person is allowed to do, which is a separate document because the two often do not match. A deputy may be first in the order of succession and still have no signature authority over a purchase, no ability to sign a state resource request, and no standing to activate a mutual aid agreement. Continuity doctrine treats delegations as a distinct element for exactly that reason, and it is the element I most often find missing in small jurisdictions.

A usable delegation names the authority being delegated, the position receiving it, the trigger that activates it, any limitation on it, and how long it lasts. Write the limits as numbers. Emergency purchasing up to a stated dollar figure without further approval, authority to sign a request for state assistance, authority to commit personnel under the statewide mutual aid agreement, authority to release public information without prior review, and authority to order a specific protective action if your state law actually permits that official to order it. Set a duration, something like seventy-two hours or until the incumbent resumes duty, and require the successor to report every action taken under the delegation when the incumbent returns. That reporting requirement is what makes elected officials willing to sign the thing.

Money is where delegations earn their keep, and it is also where they create audit exposure. The federal uniform administrative requirements at 2 CFR part 200 allow noncompetitive procurement under emergency or exigent circumstances, and they expect you to document the circumstance, the price reasonableness and the reason competition was not feasible. The documentation is what gets examined years later during a Public Assistance closeout, so the delegation should state in plain terms that the person exercising emergency purchasing authority creates a written record at the time. Confirm the current procurement expectations with your state administering agency and FEMA’s published procurement guidance, because the thresholds and the guidance have changed over the years.

Keep signed originals in more than one place, and note that the duration of a local emergency declaration before the governing body must ratify or extend it varies considerably from state to state. Verify your own limit in your state code with your attorney, because a declaration that quietly expires on day eight takes your emergency purchasing authority with it.

Vital records and where the only copy lives

Continuity doctrine divides vital records into the ones you need to operate during an emergency and the ones that protect the legal and financial rights of the organization and of the people it serves. The first group is the material your successor needs in the first hour, and for a small agency it is short: the emergency operations plan and its notification annex, the current call list with after-hours numbers, mutual aid agreements and the contacts who can activate them, pre-incident plans for your worst facilities, radio programming files and frequency records with the system administrator contacts, and the delegations and succession order themselves. The second group includes personnel and payroll records, credential and licensure files, insurance policies, active grant files with their deadlines and unliquidated balances, contracts and purchase agreements, deeds and leases, and the expenditure documentation supporting any open reimbursement.

For each item, answer two questions in writing. Where is the only copy, and can somebody other than the person who created it retrieve it without that person, the building or the network. A shared drive that only authenticates through a domain controller in the basement of the courthouse is a single point of failure with extra steps. A printed binder at the alternate facility is not elegant, and it is readable during a power outage by a successor who does not have your password.

Test the restore rather than the backup, and put a date on the test. I have watched agencies discover during an actual outage that the nightly backup had been failing silently for months, or that the backup existed and nobody present had the credentials to restore from it. While you are in there, deal with credentials as a continuity element in their own right, because in a small shop one person typically holds administrative access to the radio system, the paging system, the mass notification platform and the CAD interface. Your state archives or state records management agency publishes retention schedules for local government records, and those schedules tell you which of the second group you are legally obliged to preserve, so pull the current schedule from that agency rather than guessing.

Alternate facilities you can get without money

Nothing in continuity doctrine requires a hardened alternate emergency operations center with a raised floor. The requirement is a place where your essential functions can be performed, and for a small jurisdiction the honest specification is a room with power, a restroom, parking, a door that locks, a working communications path, and an occupant who will let you in at three in the morning. Fire stations, water treatment plants, school board offices, libraries, county road department shops, hospital conference rooms and the courthouse in the next town over have all served as somebody’s alternate facility, and none of them cost anything but an agreement.

The one rule I would not bend is diversity of exposure. Check whether the alternate shares a substation feed, a fiber path or microwave shot, a floodplain, a wildfire exposure or an access road with the primary, and keep looking until you can account for each of those. I have seen an alternate EOC designated two hundred yards behind the primary, inside the same campus and served by one generator, which satisfied a checklist and would not have survived any event serious enough to make anyone leave the first building. Distance far enough to escape the hazard and close enough for your people to reach it is a judgment call, and it belongs to somebody who knows the local hazards rather than to a template.

Write the arrangement down as a one-page memorandum of understanding that names the position to call, the hours, what space and furniture you get, whether you may pre-position a cache, who unlocks the door, and how the host is reimbursed if they are. Then test the access, because badge systems and key control defeat more alternate facility plans than hazards do. Walk in once a year, plug in, make a radio call and a phone call, open the records you brought, and note what did not work. A go-kit with a portable radio and charger, a paper copy of the vital records, a laptop, a cellular hotspot and a printed call list turns a borrowed conference room into a functioning office, and it is the cheapest continuity investment available to a small agency.

Devolution, mutual aid, and coming back afterward

Devolution answers a harder question than succession, which is what happens when the function has to move to a different organization entirely because your agency has no capability left. In a three-person department that is not an exotic scenario, since two people out and one person on the far side of a flooded river produces it. The devolution partner for a small jurisdiction is generally the county, an adjacent jurisdiction of similar size under a reciprocal agreement, or the state, and the arrangement only works if the receiving organization has your essential function list, your call list, your delegations and your records before the event rather than during it.

Intrastate mutual aid usually runs through a statewide agreement administered by the state emergency management agency, and most states have one that local governments join by resolution, so confirm with your state agency whether your jurisdiction is a signatory and who signed. Interstate assistance moves under the Emergency Management Assistance Compact, which Congress ratified in 1996 and which is administered through the National Emergency Management Association, and it is a state-to-state mechanism that a local agency reaches by asking the state rather than by calling another state directly. Neither of those helps if the person who knew how to make the request is the person you are missing, which is why the request procedure belongs on page one of the continuity plan with the form attached.

Reconstitution is the part everyone leaves blank. Decide in advance who determines that the agency is capable again, what has to be true before the function comes home, and what gets reported to the governing body when it does. In practice the return is messier than the departure, because records created at the alternate site or by the devolution partner have to be brought back into your own files, purchases made under a delegation have to be reconciled, and personnel who worked for somebody else’s incident commander for two weeks have to be released properly with their time documented. Write a paragraph on each of those three items and you have covered more reconstitution ground than most small agency plans do.

Keeping five pages alive for ten years

A continuity plan for a three-person agency should be between five and fifteen pages, and the reason to keep it short has nothing to do with effort. Every page you write is a page somebody has to maintain, and a plan that is too big to review in an hour will not be reviewed, after which it becomes a document that names a retired chief, a disconnected phone number and a facility that changed hands. That is worse than having no plan, because people rely on it.

Attach the review to something that already happens on the calendar. The budget submission, the annual appointment of officials at the January organizational meeting, the anniversary of the plan’s adoption, or the same month you renew your mutual aid resolutions will all work, and what matters is that the trigger is an event nobody can forget rather than a good intention. Put a revision date and a revision number on the front page, and make personnel change an immediate trigger, so that the week somebody is hired, promoted or separated the succession order, the delegations and the credential inventory get updated rather than waiting for the annual cycle.

Testing scales down cleanly if you test one element at a time. A no-notice call to the second successor asking what they would do in the next ten minutes takes fifteen minutes and finds more problems than a tabletop exercise. Forwarding the published administrative line to a cell phone and back takes an afternoon and tells you whether anybody actually has that authority with the carrier. Restoring one file from backup is a single test with a single finding, and so is walking into the alternate facility with the go-kit or having the finance office confirm that they would honor the successor’s signature. Write the finding down with a date and a name next to the correction, because the record of what you tested is the evidence that the plan is real, and it is also what the next person to hold your job will read first.

What to do at your agency

• Have the director or chief write the essential function list this month on one page, with a downtime tolerance and the minimum staff and equipment beside each function, and stop at five entries unless a sixth survives the thirty-day question.
• Ask your county or city attorney in writing to review your order of succession and delegations of authority and to state which authorities are legally transferable and which attach to an elected office, and file the reply with the plan.
• Extend the order of succession to at least one position outside your department, get a written reciprocal designation from that official or from the emergency management director of an adjacent jurisdiction, and notify your dispatch center and your state emergency management duty officer who the successors are.
• Have whoever administers each critical system add a second named administrator from a different person, and produce a written inventory of who holds which credentials, stored with the vital records rather than on the primary network.
• Pick the alternate facility, confirm it does not share a power feed, communications path, floodplain or access road with the primary, and sign a one-page memorandum of understanding that names the position to call and who unlocks the door.
• Restore one vital record from backup this month, in front of a witness, and write down the date, the file and whether it worked, then put that test on the same annual calendar as your budget submission.
• Add one standing item to an existing staff or council meeting agenda requiring the succession order, delegations and credential inventory to be reviewed whenever anyone is hired, promoted or separated.

Takeaways

• FEMA’s Continuity Guidance Circular is the correct reference for non-federal organizations, the 2018 edition consolidated the two circulars that preceded it, and the federal continuity directives that drive most of the paperwork burden apply to federal executive branch agencies rather than to local government.
• Essential functions are decided by asking what breaks at twelve hours, three days and thirty days, and a three-person agency that ends up with more than five or six of them has not finished cutting.
• An order of succession is written by position, runs at least three deep, and in a small department has to reach outside the department, because a list of three people who share a building and a vehicle documents one point of failure three times.
• Succession and delegation of authority are separate documents, and a delegation is only usable if it states the trigger, the dollar limits, the duration and the requirement to report actions taken when the incumbent returns.
• Emergency procurement under the federal uniform guidance at 2 CFR part 200 is permitted in exigent circumstances but has to be documented at the time, so the delegation should say so, and current thresholds should be confirmed with your state administering agency.
• Vital records planning comes down to naming where the only copy lives and whether somebody other than its author can retrieve it without the building, the network or that person’s password, and the test that counts is a restore rather than a backup.
• An alternate facility needs power, a restroom, a locking door, a communications path and a different hazard exposure from the primary, and the arrangement should be a signed one-page memorandum with tested access rather than an assumption about a neighbor’s conference room.
• Devolution to the county, an adjacent jurisdiction or the state only works if the receiving organization already holds your function list, call list, delegations and records, and interstate help moves through the Emergency Management Assistance Compact, ratified by Congress in 1996, as a state-to-state request.
• Keep the document between five and fifteen pages, tie its review to an event already on the calendar, make personnel change an immediate trigger, and record each single-element test with a date and a name.