U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

 Evaluation Report 

EPA Needs to Improve 

Continuity of Operations Planning 

 Report No. 10-P-0017 

 October 27, 2009 
 

 

 

Report Contributors:	 Gabrielle Fekete 

 Jeffrey Harris 

Denton Stafford 

Olga Stein 

Steve Weber 

Abbreviations 

COOP Continuity of Operations 

EPA U.S. Environmental Protection Agency 

FCD 1 Federal Continuity Directive 1 

HSPD-20 Homeland Security Presidential Directive 20 

OEM Office of Emergency Management 

OIG Office of Inspector General 

Cover photos:	 From left: The Centers for Disease Control and Prevention-developed 

Polymerase Chain Reaction diagnostic test to detect novel influenza virus; 

image of the newly identified influenza virus; facemask to reduce transmission 

of influenza virus (photos courtesy Centers for Disease Control and Prevention). 
 

 

 

 

U.S. Environmental Protection Agency 10-P-0017 

October 27, 2009 Office of Inspector General 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review EPA Needs to Improve Continuity of 

The objective of this Operations Planning 

evaluation was to determine 

how well the U.S. 

Environmental Protection 

Agency (EPA) can accomplish 

its mission essential functions 

in the event of a pandemic 

influenza or equivalent 

national emergency that 

necessitates Continuity of 

Operations (COOP) 

activation. 

Background 

Federal Continuity Directive 1 

(FCD 1) requires EPA to 

develop a continuity plan that 

ensures its ability to 

accomplish its mission 

essential functions from an 

alternative site with limited 

staffing and without access to 

resources available during 

normal activities. EPA must 

be prepared to continue to 

function during an emergency 

and to effectively resume 

essential operations when they 

are interrupted. 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2010/ 

20091027-10-P-0017.pdf 

What We Found 

EPA has limited assurance that it can successfully maintain continuity of 

operations and execute its mission essential functions during a significant national 

event such as a pandemic influenza outbreak. EPA’s COOP policy does not 

clearly define authorities and responsibilities for continuity planning at all levels 

of the Agency and has not been updated to reflect current national directives and 

guidance. EPA lacks internal management controls, including guidance and 

systematic oversight, to ensure that regional offices have developed continuity 

plans that meet the requirements of FCD 1. Regional plans generally lack 

consistency, particularly in the area of mission essential functions, and there was 

no evidence that EPA Headquarters had reviewed, approved, or commented on the 

regional plans, their designation, or lack of essential functions. 

EPA’s continuity training and exercises have not prepared the Agency to provide 

essential services during a significant national event. EPA has not held and does 

not require any all-employee continuity training. Also, EPA’s continuity exercises 

do not test EPA’s ability to execute its mission essential functions following 

COOP activation. Four out of six regions contacted and all but one program office 

have not conducted internal exercises to test capabilities during a pandemic. 

What We Recommend 

EPA should establish a schedule to complete FCD 1 requirements, designate a 

lead office for COOP planning, and identify Headquarters and regional 

responsibilities and authorities. EPA should also develop consistent mission 

essential functions and COOP plan preparation and training guidance for all 

regions. Further, EPA Headquarters should review and approve all regional and 

program office COOP plans. The Agency concurred with our recommendations. 
 

 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

October 27, 2009 

MEMORANDUM 

SUBJECT:	 EPA Needs to Improve Continuity of Operations Planning 

 Report No. 10-P-0017 

FROM:	 Wade T. Najjum

 Assistant Inspector General 

 Office of Program Evaluation 

TO: Mathy Stanislaus 

 Assistant Administrator for Solid Waste and Emergency Response 

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) 

of the U.S. Environmental Protection Agency (EPA). This report contains findings that describe 

the problems the OIG has identified and corrective actions the OIG recommends. This report 

represents the opinion of the OIG and does not necessarily represent the final EPA position. 

Final determinations on matters in this report will be made by EPA managers in accordance with 

established resolution procedures. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time – is $519,022. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this 

report within 90 calendar days. You should include a corrective actions plan for agreed upon 

actions, including milestone dates. We have no objections to the further release of this report to 

the public. This report will be available at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact me at 202-566-0827; 

or Jeffrey Harris, Director for Program Evaluation, Cross-Media Issues, at 202-566-0831 or 

harris.jeffrey@epa.gov. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EPA Needs to Improve 10-P-0017 

Continuity of Operations Planning 

Table of Contents 

Chapters 

1 Introduction ........................................................................................................... 1 

Purpose .......................................................................................................... 1 

Background .................................................................................................... 1 

 Noteworthy Achievements.............................................................................. 2 

Scope and Methodology................................................................................. 2
 

2 EPA’s Continuity of Planning Operations Is Inconsistent ................................ 4 

EPA’s Continuity Policy Should Be More Definitive and Strengthened ......... 4
 

Regional Continuity Plans Vary Significantly.................................................. 5 

Training and Exercises Are Insufficient .......................................................... 6 

Conclusion...................................................................................................... 8 

Recommendations ........................................................................................ 8 

Agency Comments and OIG Evaluation ........................................................ 8 

Status of Recommendations and Potential Monetary Benefits................................. 10 

Appendices 

A Agency Comments on Draft Report .................................................................... 11 

B Distribution ............................................................................................................ 14 
10-P-0017
 

Chapter 1

Introduction 

Purpose 

The overall objective of this evaluation was to determine how well the U.S. 

Environmental Protection Agency (EPA) can accomplish its mission essential 

functions in the event of a pandemic influenza or equivalent national emergency 

that necessitates Continuity of Operations (COOP) activation. Specifically, we 

sought to evaluate: 

•	 The COOP responsibilities and authorities of EPA Headquarters and 

regional offices, 

•	 The consistency of mission essential functions across EPA and its regional 

offices, and 

•	 COOP exercises and training across EPA and its regional offices. 

Background 

Spurred in part by occasional warnings of potential terrorist threats in the 

post-9/11 era, policymakers have intensified their focus on COOP issues. 

COOP planning is a segment of Federal Government contingency planning linked 

to continuity of government. Together, COOP and continuity of government are 

designed to ensure survival of a constitutional form of government and the 

continuity of essential federal functions. 

Broadly, COOP planning refers to the internal effort of an organization, such as a 

branch of government, department, or office, to assure that the capability exists to 

continue essential operations in response to a comprehensive array of potential 

operational interruptions. EPA must be prepared to continue to function during 

all hazards, an emergency, or threat of an emergency, and to effectively resume 

essential operations after they are interrupted. COOP plans provide EPA with the 

capability to perform these essential functions for up to 30 days. 

The Department of Homeland Security’s Federal Continuity Directive 1 (FCD 1) 

requires EPA to develop a continuity plan that ensures its ability to accomplish its 

mission essential functions from an alternative site, with limited staffing and 

without access to resources available during normal activities. A limited set of 

government functions determined to be vital activities are defined as the agency’s 

“mission essential functions.” These functions are used to identify supporting 

tasks and resources that must be included in the agency’s continuity planning 

process. 

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It is EPA’s policy to have in place a comprehensive program (COOP) to ensure 

continuity of its essential functions under all emergency circumstances. Under 

Homeland Security Presidential Directive 20 (HSPD-20), EPA is required to 

designate an Agency Continuity Coordinator charged with ensuring EPA’s 

continuity program is consistent with federal policies. The Office of Solid Waste 

and Emergency Response’s Office of Emergency Management (OEM) is 

responsible for developing EPA’s Continuity Plan. 

EPA’s Office of Homeland Security is responsible for coordinating the Agency’s 

intra-agency Pandemic Influenza preparedness planning. During a pandemic 

outbreak, EPA performs a support role to the Departments of Homeland Security 

and Health and Human Services in preparing and protecting the nation’s drinking 

water and wastewater critical infrastructure. EPA must be prepared for a 

pandemic scenario where social distancing is a key coping strategy because 

essential services and functions may be broader than 30-day COOP planning. 

The Federal Government therefore recommends that government entities and the 

private sector plan with the assumption that up to 40 percent of their staff may be 

absent for periods of about 2 weeks at the height of a pandemic wave with lower 

levels of staff absent for a few weeks on either side of the peak. 

Noteworthy Achievements 

The EPA Continuity Program has ensured the development of a COOP plan for 

each regional office. The Agency recently developed its Primary Mission 

Essential Function, as required by federal directives, and received approval from 

the Assistant to the President for Homeland Security and Counterterrorism on 

June 1, 2009. Regional continuity planners have developed a self-evaluation tool, 

shared best practices, held annual meetings, and partnered with Headquarters 

continuity planners through details to OEM. 

Scope and Methodology 

We conducted this performance evaluation in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform 

the evaluation to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based upon our objectives. We performed our evaluation from 

September 2008 through August 2009. 

This evaluation specifically focused on the management of EPA’s COOP program 

planning process. This includes federal requirements that dictate the roles and 

responsibilities for EPA, and how specific offices have discharged those 

responsibilities. Our field work included: 

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•	 Interviews with officials in EPA’s OEM and Office of Homeland Security 

to determine Headquarters and regional COOP responsibilities and 

authorities; 

•	 Review of current Regional COOP Plans for Regions 1-10 and Research 

Triangle Park, North Carolina, focusing on consistency of mission 

essential functions; 

•	 Review of Headquarters and selected regional COOP exercise “after 

action” reports for Fiscal Years 2008-2009 to determine the extent of EPA 

preparedness for COOP events; and 

•	 Interviews with regional COOP planners on consistency of mission 

essential functions, responsibility and authority, and exercises and 

training. 

Our review included examining applicable laws, regulations, and Agency 

guidance. We also reviewed internal controls as relevant to our objectives. 

This is our first examination of COOP planning and EPA’s ability to 

accomplish its mission essential functions; there have been no prior Office of 

Inspector General (OIG) reviews in this area. 

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Chapter 2

EPA’s Continuity of Operations Planning 

Is Inconsistent 

EPA has limited assurance that it can successfully maintain continuity of 

operations and execute its mission essential function during a significant national 

event such as a pandemic influenza outbreak. Continuity planning is inconsistent 

because EPA policy does not clearly define authority or Headquarters and 

regional responsibilities to reflect current national directives and guidance. EPA 

has not provided the regions with adequate guidance detailing the identification 

and prioritization of essential functions, nor reviewed, approved, or commented 

on regional plans or essential functions. Further, EPA lacks systematic oversight 

to ensure that regions have developed continuity plans that adequately incorporate 

FCD 1. EPA’s COOP training and exercises are insufficient to prepare or assess 

the Agency’s ability to provide its essential services during a significant 

emergency. As a result, EPA is not prepared to provide its essential services that 

protect human health and the environment during a significant national event. 

EPA’s Continuity Policy Should Be More Definitive and Strengthened 

EPA has not updated its continuity policy to reflect current national directives 

(HSPD-20) and guidance (FCD 1.) EPA’s current COOP policy, EPA Order 

2030.1A, “Continuity of Operations Policy,” does not clearly define authorities 

and responsibilities for COOP planning at all Agency levels. 

HSPD-20 and FCD 1 require the heads of federal executive agencies to appoint a 

senior accountable official at the Assistant Secretary level as the Continuity 

Coordinator for the department or agency. EPA designated the Assistant 

Administrator for Solid Waste and Emergency Response as the Agency’s 

Continuity Coordinator via a November 6, 2007, memorandum. However, this 

memorandum did not define the responsibility and reach of authority for the 

coordinator. OEM staff also said EPA has not outlined the coordinator’s role. 

EPA Order 2030.1A, dated April 2005, predates HSPD-20 and FCD 1 and does 

not meet all national requirements. Specifically, EPA Order 2030.1A does not 

mention the role or responsibilities of the Agency Continuity Coordinator. 

Instead, this order outlines the responsibilities of EPA’s Emergency Coordinator. 

The absence of the Agency Continuity Coordinator’s role and responsibilities 

contributes to the inconsistencies we found throughout EPA’s COOP planning 

efforts. 

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EPA Order 2030.1A does not define the lead authority for continuity planning and 

guidance development. Under current policy, EPA’s Emergency Coordinator is 

responsible for ensuring that the developed EPA COOP plan follows this order. 

The Regional Administrators and Laboratory Directors are also responsible for 

developing COOP plans in accordance with this order. The Emergency 

Coordinator does not have direct approval authority over the Regional 

Administrators’ and Laboratory Directors’ COOP plans. 

Regional Continuity Plans Vary Significantly 

While the EPA regions have actively participated in continuity planning since the 

mid-1990s, mission essential functions and regional COOP plans vary 

significantly from region to region. There was no evidence that EPA 

Headquarters formally reviewed, approved, or commented on the regional plans, 

their designation, or lack of essential functions. EPA lacks internal management 

controls, including guidance and systematic oversight, to ensure regional offices 

have developed continuity plans that adequately satisfy FCD 1 requirements. 

The identification and prioritization of mission essential functions is a prerequisite 

for COOP planning, as they establish the parameters that guide COOP planning. 

For example, FCD 1 directs all federal agencies to identify alternative facilities, 

staff, and resources necessary to support continuation of these functions. Proper 

identification of mission essential functions is vital to ensure EPA has the ability 

to deliver its mission essential functions and services uninterrupted during a range 

of potential emergencies. The COOP plans we reviewed for identified mission 

essential functions varied in number and scope. Regions generally did not 

prioritize or establish the time sensitivity of the functions they had identified. 

Also, the apparent importance of the functions was not consistent. For example, a 

number of mission essential functions were of clear importance, such as: 

•	 “Ensure the continued and uninterrupted command, control, and 

leadership of the EPA.” 

•	 “Emergency Response program, time critical actions EPA needs to take.” 

•	 “Communicate and coordinate with state agencies and local 

governments.” 

Other identified functions appeared of questionable importance or overly vague: 

•	 “Oversee the ethics program for the Agency.” 

•	 “Protect the office’s workforce in accordance with guidance issued by 

EPA.” 

•	 “Support current ongoing EPA activities that cannot or should not be 

disrupted...” 

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EPA Headquarters last issued guidance for COOP planning in 2005. This 

guidance outlined basic minimum requirements for continuity plans, training, and 

coordinating personnel. However, unlike EPA Order 2030.1A, FCD 1 does 

require EPA Headquarters to review and approve Agency mission essential 

functions that are a necessary element to COOP plan development. We found no 

evidence of the EPA Continuity Coordinator’s review of regional plans. OEM 

receives courtesy copies of the plans but does not formally review them. This 

absence of management controls has resulted in inconsistent continuity planning 

nationally, and may negatively impact EPA’s readiness to respond to an incident 

of national significance. 

Our review of COOP plans developed or being used by the regions during Fiscal 

Year 2009 showed that many regional offices had not incorporated all of the 

FCD 1 requirements. EPA regions were still citing Federal Preparedness 

Circular 65, which was superseded by FCD 1 in February 2008. Issues such as 

vital records, devolution (capability to transfer statutory authority and 

responsibility), and reconstitution (resume normal agency operations) had not 

been fully addressed by many regions. To address the issue of devolution, the 

regions recently formed a work group. 

Although regional COOP plans generally adhered to the FCD 1 criteria, we found 

four elements that needed improvement in more than one region: 

• Identification of Essential Functions 

• Vital Record Management 

• Devolution of Control and Direction 

• Reconstitution 

Our results show that not all regions have differentiated their essential functions 

from their normal business operations, and not all regions have determined how 

they will address vital record issues, potential devolution issues, or reconstitution 

of normal activities. 

Training and Exercises Are Insufficient 

EPA’s continuity training and exercises do not sufficiently prepare or assess the 

Agency’s ability to provide its essential services during a significant emergency. 

EPA’s training scenarios primarily test equipment, communication systems, and 

access to records. Four out of six regions contacted and all but one program 

office have not conducted internal exercises for a pandemic. Feedback and 

lessons learned in “after action” reports indicate the need for more realistic 

exercises. However, EPA lacks a consistent process for addressing the 

recommendations or gaps identified from these lessons learned. 

EPA training scenarios lack a comprehensive focus. We found that all regions 

reviewed activated a telephone tree or similar emergency system, deployed 

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essential personnel to site, tested information technology and communication 

systems, and reviewed vital records. Few training scenarios required a complete 

deployment of resources and used minimal staff at the alternative site. Exercises 

held at designated alternative sites focused primarily on discussion of possible 

scenarios and communication issues rather than operation of essential functions. 

For example, Regions 1, 2, and 9 all conducted “tabletop” exercises1 at their 

alternative sites but did not require a complete deployment of resources using 

designated staff. 

We found that only Headquarters’ Office of Prevention, Pesticides, and Toxic 

Substances and Region 6 have conducted internal exercises for the pandemic 

influenza. Other regions have added a Pandemic Influenza Annex to their COOP 

plans but have not conducted exercises that would prepare for this scenario. The 

pandemic scenario includes unique requirements, such as a telework component, 

where staff would have to work for many contiguous days in a social distancing 

situation. 

Regions vary on the extent and frequency of training for all employees. We asked 

several of the regional COOP planners if they provided continuity training for all 

of their employees. One replied that regional staff could find COOP information 

on the regional Intranet site. Another said he relies on the divisional COOP 

planners to provide this. EPA Headquarters has not held and does not require any 

all-employee continuity training. 

EPA does not have a consistent process for addressing the recommendations or 

gaps identified from lessons learned during the exercises. The after action reports 

we reviewed all contain different formats and schedules for completion. 

Generally, each report contains sections where the regional COOP manager 

identifies action items and deadlines to complete these items, and designates the 

staff/group responsible for the item. Each regional COOP planner is responsible 

for his or her own plan after action reports and deadlines. 

After action reports indicated the need for more realistic exercises; the reports 

often described gaps or necessities in these areas. One comment provided by staff 

was, “The MTSD [Management and Technical Services Division] will work to 

ensure essential staff know their role/responsibilities.” Another report 

recommended that the “Notification program for all EPA HQ employees in the 

National Capital Region must be exercised during a COOP deployment.” Staff 

offered recommendations to improve the design of the exercise, including: 

“Recommend more regular and realistic exercises; need to grow exercise into an 

actual event simulation” and “Recommend increasing the interaction with other 

AA [Assistant Administrator]-ships and external partners.” 

1

 A tabletop exercise is the analysis of a simulated emergency situation in an informal, stress-free environment. 

There is minimal attempt at simulation in a tabletop exercise. Equipment is not used, resources are not deployed, 

and time pressures are not introduced. This is the simplest type of exercise to conduct in terms of planning, 

preparation, and coordination. 

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Conclusion 

EPA has limited assurance that it can successfully maintain continuity of 

operations and execute its mission essential function during a significant national 

event such as a pandemic influenza outbreak. EPA’s current policy does not 

clearly define authority and EPA Headquarters and regional responsibilities. This 

has created inconsistencies in continuity planning and training, and varying 

mission essential functions and continuity plans by the regions. As a result, there 

is no assurance that EPA will be able to provide its essential services to protect 

human health and the environment during a national emergency. 

Recommendations 

We recommend that the Assistant Administrator for Solid Waste and Emergency 

Response: 

2-1 Establish a schedule for the completion of the requirements in FCD 1. 

2-2 Establish Headquarters and regional COOP responsibilities and 

authorities, including designating a lead office for COOP planning. 

2-3 Develop consistent guidance and procedures for preparing regional COOP 

plans. 

2-4 Develop consistent mission essential functions and priorities for all 

regions to include in their COOP plans. 

2-5 Develop training guidance that incorporates realistic scenarios that prepare 

personnel to perform mission essential functions during a COOP 

activation (i.e., from an alternate location with limited staff). 

2-6 Review and approve COOP plans, priorities, training, and exercises to 

ensure that EPA’s regional and program offices (a) systematically identify 

their mission essential functions and personnel, and (b) are prepared to 

respond to an all-hazards event. 

Agency Comments and OIG Evaluation 

In written comments on a draft of this report, the Assistant Administrator for 

Solid Waste and Emergency Response and the Acting Assistant Administrator for 

Homeland Security generally agreed with our findings regarding consistency of 

continuity planning, EPA’s continuity policy, regional continuity plans, and 

training and exercises. They also included a table of the Office of Solid Waste 

and Emergency Response’s planned completion dates for our recommendations. 

These actions are consistent with the intent of our recommendations. However, 

the Agency officials did not concur with the OIG’s overall conclusion that EPA 

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has “no assurance” that it can successfully maintain continuity of operations and 

execute its mission essential functions during a significant national event such as 

a pandemic influenza outbreak. We modified the report language in light of the 

Headquarters’ ongoing actions in response to FCD 1 and the various exercises 

conducted in several regions. The Agency’s written response is in Appendix A. 

9 
 

 

 

 

 

 

 

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Status of Recommendations and 

Potential Monetary Benefits 

RECOMMENDATIONS 

POTENTIAL MONETARY 

BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-1 8 Establish a schedule for the completion of the 

requirements in FCD 1. 

O Assistant Administrator 

for Solid Waste and 

Emergency Response 

11/15/2009 

2-2 8 Establish Headquarters and regional COOP 

responsibilities and authorities, including 

designating a lead office for COOP planning. 

O Assistant Administrator 

for Solid Waste and 

Emergency Response 

6/30/2010 

2-3 8 Develop consistent guidance and procedures for 

preparing regional COOP plans. 

O Assistant Administrator 

for Solid Waste and 

Emergency Response 

10/30/2010 

2-4 8 Develop consistent mission essential functions and 

priorities for all regions to include in their COOP 

plans. 

O Assistant Administrator 

for Solid Waste and 

Emergency Response 

10/30/2010 

2-5 8 Develop training guidance that incorporates 

realistic scenarios that prepare personnel to 

perform mission essential functions during a COOP 

activation (i.e., from an alternate location with 

limited staff). 

O Assistant Administrator 

for Solid Waste and 

Emergency Response 

2/15/2011 

2-6 8 Review and approve COOP plans, priorities, 

training, and exercises to ensure that EPA’s 

regional and program offices (a) systematically 

identify their mission essential functions and 

personnel, and (b) are prepared to respond to an 

all-hazards event. 

O Assistant Administrator 

for Solid Waste and 

Emergency Response 

O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

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Appendix A 

Agency Comments on Draft Report 

MEMORANDUM 

SUBJECT:	 Response to the OIG Draft Evaluation Report “EPA Needs to Improve 

 Continuity of Operations Planning,” Project No. OPE-08-0024 

FROM: Mathy Stanislaus 

 Assistant Administrator 

Office of Solid Waste and Emergency Response 

 Juan Reyes 

 Acting Assistant Administrator 

Office of Homeland Security 

TO: Jeffrey K. Harris, PhD 

 Director for Program Evaluation, Cross Media Issues 

Office of Inspector General 

Thank you for the opportunity to review and comment on the subject OIG draft report. 

The report addresses EPA’s continuity policy, Regional continuity plans, training and exercises 

and provides a list of recommendations for improvement. We would also like to thank you for 

incorporating some of the comments that we had requested in our June 25, 2009, response to the 

discussion draft and for describing noteworthy achievements at Headquarters and in the Regions. 

As we stated in our June response, the OIG performed the evaluation in the midst of 

OSWER’s efforts to update the EPA Headquarters Continuity Plan, the Pandemic Influenza 

Annex, and the Devolution Annex. We are also in the process of updating the existing EPA 

Order that incorporates the requirements of the Department of Homeland Security’s Federal 

Continuity Directives 1 and 2. We generally agree with the findings regarding consistency of 

continuity planning, EPA’s continuity policy, Regional continuity plans, and training and 

exercises. However, many of the OIG’s concerns will be addressed upon completion of the 

updated Continuity of Operations Plan and a revised EPA Order. 

We do, however, take exception that these findings lead to a conclusion that EPA has “no 

assurance” that it can successfully maintain continuity of operations and execute its mission 

essential functions during a significant national event such as a pandemic influenza outbreak. 

Recognizing that our program does need improvement, we have made extensive progress 

developing our COOP plans and exercising key capabilities of essential personnel. While our 

exercises have shown areas in need of improvement, we have been evaluated by FEMA, GAO 

and other independent subject-matter assessors, and these appraisals have generally received 

acceptable scores for key Federal requirements. Based on your findings and our program 

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knowledge, we assess that your conclusion of “no assurance” is imprecise because it does not 

accurately reflect the status of our program, and is not consistent with previous outside 

evaluations. We ask that the statement be changed to “limited assurance” to more accurately 

reflect the state of our COOP Program. 

As requested, we have included the table of proposed recommendations and OSWER’s 

planned completion dates. We look forward to coordinating with OIG, other AAships, and the 

Regional offices to continue to improve our continuity program. If you have any questions, 

please contact Deborah Dietrich, Director of the Office of Emergency Management, at 

202-564-6743. 

Attachment 

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OIG Recommendations to Improve EPA’s Continuity Program 

Recommendation Subject OSWER Planned 

Completion Date 

2-1 Establish a schedule for completion of the 

requirements in FCD 1. 

11/15/2009 

2-2 Establish Headquarters and Regional 

COOP responsibilities and authorities, 

including designating a lead office for 

COOP planning. 

6/30/2010 

2-3 Develop consistent guidance and 

procedures for preparing Regional COOP 

plans. 

10/30/2010 

2-4 Develop consistent mission essential 

functions and priorities for all Regions to 

include in their COOP plans. 

10/30/2010 

2-5 Develop training guidance that 

incorporates realistic scenarios that prepare 

personnel to perform mission essential 

functions during a COOP activation (i.e., 

from an alternate location with limited 

staff). 

2/15/2011 

2-6 Review and approve COOP plans, 

priorities, training, and exercises to ensure 

that EPA’s Regional and program offices 

(a) systematically identify their mission 

essential functions and personnel, and (b) 

are prepared to respond to an all-hazards 

event. 

Annual review 

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Appendix B 

Distribution 

Office of the Administrator 

Assistant Administrator for Solid Waste and Emergency Response 

Acting Assistant Administrator for Homeland Security 

Director, Office of Emergency Management, Office of Solid Waste and Emergency Response 

General Counsel 

Agency Follow-up Official (the CFO) 

Agency Follow-up Coordinator 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Audit Follow-up Coordinator, Office of Solid Waste and Emergency Response 

Acting Inspector General 

14