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 H(FldBrChiefs) 

 www.fema.gov/library 

FEDERAL PREPAREDNESS CIRCULAR 

Federal Emergency Management Agency 

Washington, D.C. 20472 

 FPC 66 

 April 30, 2001 

TO: HEADS OF FEDERAL DEPARTMENTS AND AGENCIES 

SUBJECT: TEST, TRAINING AND EXERCISE (TT&E) PROGRAM FOR CONTINUITY 

OF OPERATIONS (COOP) 

1. PURPOSE. This Federal Preparedness Circular (FPC) provides guidance to Federal 

Executive Branch departments and agencies for use in developing viable and executable test, 

training and exercise programs to support the implementation and validation of COOP plans. 

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.” 

3. AUTHORITIES.

a. The National Security Act of 1947, dated July 26, 1947, as amended. 

b. Executive Order (EO) 12148, Federal Emergency Management, dated July 20, 1979, as 

amended. 

c. EO 12472, Assignment of National Security and Emergency Preparedness 

Telecommunications Functions, dated April 3, 1984. 

d. EO 12656, Assignment of Emergency Preparedness Responsibilities, dated November 18, 

1988, as amended. 

e. Presidential Decision Directive (PDD) 67, Enduring Constitutional Government and 

Continuity of Government Operations, dated October 21, 1998. 

4. REFERENCES.

a. PDD 62, Protection Against Unconventional Threats to the Homeland and Americans 

Overseas, dated May 22, 1998. 

b. PDD 63, Critical Infrastructure Protection (CIP), dated May 22, 1998. 

c. Federal Preparedness Circular (FPC) 60, Continuity of the Executive Branch of the 

Federal Government at the Headquarters Level During National Security Emergencies, 

dated November 20, 1990. 
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d. FPC 65, Federal Executive Branch Continuity of Operations (COOP), dated 

July 26, 1999. 

e. Title 41 Code of Federal Regulations (CFR), Section 101.20.003, Definitions, and Section 

101.20.103-4, Occupant Emergency Program, revised as of July 1, 2000. 

f. Title 36 CFR, Part 1236, Management of Vital Records, revised as of July 1, 2000. 

5. DEFINITIONS. 

a. Training - instruction in individual or agency functions, procedures and responsibilities. 

b. Test - demonstration of the correct operation of equipment, procedures, processes and 

systems that support the organization. 

c. Exercise - evaluation of individual or organizational performance against a set of 

standards or objectives. 

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. As a 

baseline of preparedness for the full range of potential emergencies, all Federal agencies shall 

have in place a viable COOP capability, which ensures the performance of their essential 

functions during any emergency or situation that may disrupt normal operations. Inherent in 

this policy is the requirement that all Federal agencies periodically test, train, and exercise 

their COOP plans individually and collectively. 

7. BACKGROUND. A changing threat environment and recent events emphasize the need for 

COOP capabilities that enable agencies to continue their essential functions across a broad 

spectrum of emergencies. FPC 65, in accordance with PDD 67, states that testing, training, 

and exercising of COOP capabilities are necessary to demonstrate and improve the ability of 

agencies to execute their essential functions. An agency’s essential functions include those 

functions, stated or implied, which are required to be performed by statute or EO; involve the 

legal or financial rights of the government or citizens; or directly support important 

administrative functions or mission-related activities, such as counter terrorism and survival 

of critical infrastructures. 

8. OBJECTIVES. The overall objective of a COOP TT&E Program is to develop, implement 

and institutionalize a comprehensive, all-hazard program to improve the ability of agencies to 

effectively manage and execute their COOP plans. The program incorporates the three 

functional areas of testing systems and equipment, training personnel, and exercising plans 

and procedures. Specific objectives of a COOP TT&E Program are to: 

a. Validate COOP plans, policies, and procedures. 

b. Ensure that agency personnel are familiar with alert, notification, and deployment 

procedures. 
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c. Ensure agency personnel are sufficiently trained to carry out agency minimum essential 

operations and functions when deployed at a COOP site or working in a COOP 

environment. 

d. Exercise procedures by deploying designated personnel and equipment to an alternate 

facility to ensure the ability to perform an agency’s essential functions and operations 

during emergency. 

e. Ensure that backup data and records required to support essential functions at the alternate 

facility are sufficient, complete and current. 

f. Test and validate equipment to ensure both internal and external interoperability. 

g. Ensure agency personnel understand the procedures to phase down COOP operations and 

transition to normal activities when appropriate. 

9. TT&E PROGRAM. Agencies should develop a TT&E program that incorporates all levels 

of the agency, including headquarters, regions, and field locations. Funding for the program 

is the responsibility of each agency. 

 The TT&E program should include: policy, guidance, and standards; training courses and 

materials; exercises of varying types and scope designed to improve the overall organizational 

response capability to emergency situations; a multi-year TT&E schedule; and evaluation and 

remedial action programs. 

10. PLANNING CONSIDERATIONS. The TT&E program should be developed against the 

objectives identified in Section 8, to ensure agency COOP program viability and readiness. 

Planning considerations should include: 

 a. Training. Regularly scheduled training of agency personnel. This training program should 

consist of: 

 (1) A COOP awareness program for its entire workforce; and 

(2) A comprehensive readiness program to ensure the preparedness of personnel assigned 

to carry out essential operations and functions during an event. 

 b. Testing. Regularly scheduled testing of agency equipment, systems, processes, and 

 procedures used to support the agency during a COOP event. This testing program should: 

 (1) Provide for quarterly evaluations of alert and notification procedures and systems, 

 including instructions for relocation to pre-designated facilities, with and without 

 warning, and during duty and non-duty hours; 

(2) Evaluate the ability to access current vital records, systems, and data management 

software and equipment, including classified or sensitive information necessary to 

perform essential functions; 
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(3) Evaluate the interoperability of communications, to include secure capabilities if 

required; and 

(4) Evaluate the logistical support, services, and infrastructure systems (e.g., water, 

electrical power, heating, and air conditioning) at alternate facilities. 

c. Exercising. Regularly scheduled exercising of agency COOP plans to ensure the ability to 

perform essential operations and functions. This exercising program should: 

(1) Be scaleable in the magnitude of the event and include a variety of potential hazards; 

(2) Incorporate the deliberate and pre-planned movement of emergency personnel to an 

alternate facility; 

(3) Provide for continuation of operations during all phases of the event as outlined in 

FPC-65; and 

(4) Include the phase-down of alternate facility operations and return to normal operations 

(reconstitution). 

d. Joint Initiatives. Participation in joint agency TT&E initiatives, where applicable and 

feasible by: 

(1) Becoming aware of available TT&E resources; 

(2) Developing relationships with other agencies; 

(3) Participating actively in the interagency COOP Working Groups (CWG) and standing 

and ad hoc committees; 

(4) Participating in multi-agency COOP exercises; and 

(5) Participating with other emergency teams as appropriate. 

11. TT&E PROGRAM IMPLEMENTATION. The TT&E program should be progressive in 

 nature, building from simple, individual tasks to complex, multi-organizational interactions. 

An effective program is built on the successful integrating as discussed below. 

a. Training. Regularly scheduled training must be conducted to assure the readiness of all 

agency emergency and non-emergency personnel. Training plans are developed and 

implemented to prepare individuals and groups to accomplish certain tasks, using selected 

equipment, under specific scenarios. This training may encompass a deliberate blend of 

hands-on activities, seminars, orientations, workshops, on-line or interactive programs, 

briefings and lectures. Additionally, a variety of public and private sources, including the 

Federal Emergency Management Agency (FEMA) and the General Services 

Administration (GSA), offer training in various aspects of COOP. 

COOP training should not address the competencies required for “normal” tasks and 

operations. The purpose of the training is to prepare agency personnel to institute 
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emergency operations at an alternate facility, to use equipment and procedures and to 

work with individuals with whom they have little contact during normal day-to-day 

operations. 

The length of the training and the depth of the coverage of the information provided and 

discussed will vary based on the audience and method of training selected. Typically, if 

the audience is essential personnel, details of operations, communications, vital records 

and alternate facilities will require extended discussion. Awareness training for the entire 

workforce might include topics such as compensation during an event, alert/notification 

procedures, work location, information dissemination, etc. Major topics or components of 

the training syllabus could include: 

(1) Definition of COOP. 

(2) Essential elements of COOP. 

(3) Criteria or "triggers" for a COOP event. 

(4) Major operational elements of the specific organization’s COOP: 

• COOP leadership and development within the organization; 

• Leadership during a COOP event; 

• Impact of a COOP event on the individual employee; 

• Implementation; 

• Phases of an event; 

• Essential functions and operations; 

• Alternate facilities; and 

• Migration to normal operations. 

(5) Maintenance of COOP plans. 

b. Testing. Testing is the technique of demonstrating the correct operation of all equipment, 

procedures, processes and systems that support the organizational infrastructure. The 

testing process validates that the equipment and systems conform to specifications and 

operate in the required environments, and that procedures and processes are viable. 

Testing is used as the verification and validation technique to confirm that backup 

equipment and systems closely approximate the operations of the primary equipment and 

systems. Based on the measures and benchmarks desired, there are a variety of methods 

that can be used to test the functionality of backup environments. Examples of tests 

include: 

(1) Static tests determine if all the essential components of the equipment and systems are 

in place and meet the specification and design requirements of the organization. 

(2) Dynamic tests verify that all of the required equipment and systems function 

independently of each other, function in consort with each other and satisfy the 

operational requirements of the organization. 
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(3) Functional tests verify that the procedures for operating the equipment and systems in 

the backup environment are correct. This testing assures that when trained and 

qualified personnel are required to utilize the backup equipment and systems, the 

instructions for operation are clear and complete. 

c. Exercising. Exercises are conducted for the purpose of validating elements, both 

individually and collectively, of the organization’s COOP. An exercise should be a 

realistic rehearsal or simulation of an emergency, in which individuals and organizations 

demonstrate the tasks that would be expected of them in a real emergency. Exercises 

should provide emergency simulations that promote preparedness, improve the response 

capability of individuals and organizations, validate plans, policies, procedures and 

systems, and determine the effectiveness of the command, control, and communication 

functions and event-scene activities. Exercises may vary in size and complexity to 

achieve their respective purposes. Examples of emergency exercises include: 

(1) Tabletop Exercises simulate an emergency situation in an informal, stress-free 

environment. They are designed to elicit constructive discussion as participants 

examine and resolve problems based on existing plans. There is minimal attempt at 

simulation, no utilization of equipment or deployment of resources, and no time 

pressures. The success of these exercises is largely determined by group participation 

in the identification of problem areas. They provide an excellent format to use in 

familiarizing newly assigned/appointed personnel and senior officials with established 

or emerging concepts and/or plans, policies, procedures, systems, and facilities. 

(2) Drills are a coordinated, supervised activity normally used to exercise a single specific 

operation or function in a single agency. They are also used to provide training with 

new equipment, to develop new policies or procedures, or to practice and maintain 

current skills. 

(3) Functional Exercises are fully simulated interactive exercises. They validate the 

capability of an agency to respond to a simulated emergency testing one or more 

functions of the plans. They focus on policies, procedures, roles and responsibilities 

of single or multiple emergency functions before, during, or after any emergency 

event. 

(4) Full-Scale Exercises simulate actual emergency conditions. They are field exercises 

designed to evaluate the operational capabilities of the agency’s COOP in a highly 

stressful environment. This realism can be accomplished through mobilization and 

actual movement of agency emergency personnel, equipment, and resources. 

The evaluation of an exercise should identify systemic weaknesses and suggest corrective 

actions that will enhance agency preparedness. Following an exercise, a comprehensive 

debriefing and after-action report should be completed. All data collected for the TT&E 

program should be incorporated into a remedial action plan that provides input for annual 

COOP revisions. A No-Fault (e.g., non-punitive) Concept should be utilized during all 

exercises. 
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12. RESPONSIBILITIES. The following responsibilities should be clearly outlined in agency 

COOP test, training, and exercise guidance: 

 a. Each agency head is responsible for: 

(1) Developing and implementing a multi-year strategy and program management plan 

including a budgeting plan for identifying resource requirements necessary to support 

its TT&E program. 

(2) Maintaining a roster of fully equipped and trained emergency personnel with the 

authority to perform essential functions and activities. 

(3) Developing, initiating, and conducting tests, training, and exercises that will: 

• Test their alert and notification plan quarterly, with and without warning, during 

duty and non-duty hours; 

• Train all members of their team and ensure their knowledge and skills are current; 

• Exercise COOP plans and procedures annually; and 

• Identify and incorporate lessons learned/remedial action plan into annual revisions 

of the COOP Plan. 

b. In addition, GSA is responsible for: 

(1) Developing and implementing a plan, in coordination with FEMA, to issue periodic 

guidance to agencies on training to promote understanding of, and compliance with, 

the requirements and objectives of governing directives; 

(2) Developing and conducting a COOP Training Course that is available to all agencies; 

and, 

(3) Coordinating with FEMA to maintain and revise this FPC as required. 

c. In addition, FEMA is responsible for: 

(1) Serving as the Executive Agent for Federal Executive Branch COOP; 

(2) Issuing COOP guidance, in cooperation with the GSA, to promote understanding of 

and compliance with the requirements and objectives of governing directives; 

(3) Coordinating Federal Executive Branch interagency COOP exercises as outlined in 

FPC 65; 

(4) Coordinating the development of a multiyear schedule of interagency exercises to be 

conducted among the Federal Executive Branch agencies; 

(5) Providing guidance, in cooperation with GSA, that imparts methodologies for 

designing, developing, conducting, and evaluating exercises, to include a corrective 

action program; 
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(6) Ensuring a cohesive COOP integration with COG activities and other emergency 

teams as appropriate; and 

(7) Conducting periodic assessments. 

13. DISTRIBUTION. This FPC is distributed to the heads of Federal Executive Branch 

departments and agencies, senior policy officials, emergency planners, and other interested 

parties. 

_____________/s/______________ 

Joe M. Allbaugh 

Director