2450.1 ADM (Revalidated) Alternate Sites for Continuity of Operations Plan (COOP) Relocation
GENERAL SERVICES ADMINISTRATION
Washington, DC 20405
ADM 2450.1 Revalidated
July 1, 2002; Revalidated August 2, 2013
SUBJECT: Alternate Sites for Continuity of Operations Plan (COOP) Relocation
1. Purpose. This order transmits the criteria to be used for the selection of alternate facilities in the event of the activation of the agency or a regional COOP.
a. This order is to provide guidance for the selection of alternate facilities to support the activation of a Continuity of Operations Plan (COOP) in a catastrophic situation, such as a major terrorist attack. While steps have been taken to identify alternate facilities, to date, these decisions have been made in the absence of certain key locational criteria that are essential to making choices that ensure that GSA’s alternate facilities will be safe and functional.
b. Alternate facilities are required as part of a COOP to be available for an unannounced relocation of essential agency personnel to continue essential agency functions, should an emergency necessitate such action. The facility must be capable of supporting emergency operations in a secure environment enabling the agency to continue to carry out its responsibilities while taking steps to recover and resume full operations. (For additional information, see Federal Preparedness Circular 67, issued by the Federal Emergency Management Agency.)
c. The following criteria must be followed during the selection process for an alternate facility that would be used in a catastrophic event. If the alternate facilities that have already been selected are not in compliance with these criteria, a reassessment must be made and the alternate facility brought into compliance with this order.
3. Criteria for selection of alternate facilities
a. Proximity of alternate facilities.
(1) An alternate facility that will be used in a catastrophic event must be located at a minimum of 5 miles from all sites and locations identified as “most likely” to be prime targets of terrorist activity. These sites include, but are not limited to, central business districts of major cities, major federal buildings, military installations, national memorials or monuments, major centers of public assembly (e.g., Rockefeller Center, Kennedy Center, Madison Square Garden), major stadiums, major amusement parks, nuclear power plants, facilities for hazardous materials, airport traffic hubs, and other sites that could be seen by terrorists as potential targets for causing disruption and chaos.
(2) In addition to the 5-mile minimum distance, areas must be avoided where the prevailing winds would carry to the alternate facility location a plume of fumes or radiation drifting from a prime target location.
(3) The maximum distance of the primary complaint alternate site from GSA’s customers should be carefully considered at the local level. The principal reason that GSA must ensure its own continuity of operations is to support its customers. While some support activities can be effectively accomplished in a virtual environment, regardless of distance, others benefit from or even require face to face contact. The appropriate maximum distance will depend upon local factors such as customer locations and transportation alternatives.
(4) The central business district (CBD) of a principal U.S. city should not be chosen for the location of a primary alternate site, when the normal (non-emergency) GSA site is in the same area. However, the CBD of a nearby secondary city may be an appropriate choice, because there is a lesser risk that two cities in the same geographic area would be effected by the same emergency situation. For example, if the normal GSA site is in San Francisco, the San Francisco CBD should not be chosen as the primary alternate site; however, San Jose or Livermore may be appropriate choices.
(5) At least one other alternate site to be used in the event of a catastrophic event must be identified that is located at least 60 miles from the identified “most likely” targets. A successor region or an additional alternate site, such as a field office, may serve as the secondary alternate site.
(6) GSA officials responsible for alternate site selection will define the most likely targets and select the alternate site with the advice of the Federal Protective Service and their Emergency Coordinators.
b. Threat and vulnerability assessments.
(1) In selecting an alternate facility, it is essential that a threat assessment be carried out to determine the risks posed by any location. The assessment will be performed by the Federal Protective Service and will cover matters such as the security of the location, potential hazards in the surrounding area, etc.
(2) In evaluating sites, it is vital to have the Federal Protective Service conduct a vulnerability assessment. The vulnerability assessment should consider items such as the building and its surroundings, available transportation routes, surrounding businesses and facilities, etc.
(3) The vulnerability assessment should address a wide variety of matters concerning the building, such as fresh air intakes, number and types of penetrations into the facility, water supply, sewer systems, internal and external power systems, including the power grids and generator sizing. Additional factors include the number of power substation feeds, controlled or public parking, fixtures of the building, such as mailboxes, planters, dumpsters, types of neighboring operations, security camera coverage, screening facilities, gas line locations, underground fuel storage, and types of communications services available (phones, radio, pagers, cell, etc.).
(4) The type of building construction also should be evaluated in relation to surrounding structures and street locations. Location of space in the building should be evaluated in relation to the other tenants and facilities.
c. Information Technology (IT) considerations. During the alternate site selection process, the ability to communicate with GSA’s customers and the other members of the GSA community in multiple ways is critical. While there may be variances based upon unique business and support requirements, at a minimum, the following should be considered:
(1) Site must have a cost effective, robust and redundant access to the GSA data network, either by direct connectivity to the wide area network or through the use of a commercial internet service provider (ISP). In the event of a complete failure of the GSA network or corporate mail system, the ISP mail system potentially could function as the primary method of communications between associates and business partners.
(2) Site must not share common facilities and/or connections with the existing GSA infrastructure through the primary site to avoid a single point of failure. Consideration should be given to making arrangements with available commercial alternatives for Internet access.
(3) Alternate technologies for access to the GSA infrastructure are to be considered, i.e. high-speed wireless and satellite connections.
(4) If remote access Service (RAS) is being considered for connectivity, ensure that the projected site has sufficient telephone lines available to support double the number of anticipated associates at that site to provide concurrent data and voice capabilities.
(5) Ensure that frequent back up for mission critical systems are accomplished and stored (and or accessible) at a location other than the primary site.
(6) Ensure that the selected site telecommunications provider has the capability to reroute essential voice and data lines in the event of power failure, or other event.
(7) Consider the use of wireless network capability within the alternate site to provide flexibility and minimize the cost of hard wiring the site.
(8) Coordinate with the Office of the Chief Information Officer to ensure that IT Infrastructure functionality is maintained at the alternate site and to minimize or eliminate the duplication of enterprise-wide resources provided by the Office of the Chief Information Officer such as email and remote access.
(9) Ensure that sufficient redundant power is available to support hardware and infrastructure requirements.
(10) Ensure that sufficient office equipment, such as facsimile machines, telephones, computers, and the like are available to support the anticipated personnel.
(11) In the event of the loss of the GSA Internet Gateway, direct connectivity with GSA’s customers will cease as the GSA wide area network and Internet connection would no longer exist. Customers would no longer have access to any servers/systems supporting their business requirements that are accessed via the Internet. To overcome the direct customer interface issue, the use of a local ISP service (modem/DSL, etc.) and the use of private email address(s) will provide the ability to process customers’ email and provide required responses. Consideration may be given to outsourcing and relocation of these Customer support systems to commercial facilities that provide for backup, security and redundant connectivity capabilities in the event of a catastrophic event.
d. Electrical grid. A separate electrical grid from the electrical grid supporting the primary worksite or any prime target’s electrical grid must service the alternate facility that is selected. This will increase the likelihood that electrical power is available at the alternate facility despite any damage at the worksite or prime target location. The electrical grid can be of varying sizes, from one building, or one block to an entire area, so long as the selected alternate facility’s electrical power needs can be accommodated. If this is not feasible, back-up power must be provided, e.g., generators and fuel that could provide the necessary power to operate the facility, including computers and other equipment for a 30-day period.
e. Transportation. In choosing a site for an alternate facility consideration should be given to a site that provides for a wide array of transportation options. The ability of agency personnel to reach the facility may rely on the accessibility of alternate routes and/or modes of transportation, such as buses, trains, subways, etc. Consideration should be given to the locations of the essential personnel both at home and at work to determine the most efficient location based on the transportation needs of the essential personnel.
f. Essential resources. The availability of essential resources, such as food, water, lodging, sanitary facilities, and medical facilities, must be evaluated based on the anticipated number of personnel expected to be located at the alternate facility. External resources should be balanced with the resources that are available at the alternate facility to ensure the adequacy of essential resources.
g. Exclusive use of facility
(1) Any arrangement, memorandum of understanding (MOU), interagency agreement or similar document concerning the use of an alternate facility by essential personnel must provide for the exclusive use of that facility or portion of the facility. Upon activation of a COOP, the alternate facility, or that portion of the facility designated for essential functions, must immediately be placed under GSA’s exclusive control as delineated in the arrangement. Whether the site is leased and occupied by GSA or co-located with a tenant or any other co-location, a comprehensive written agreement or MOU is required.
(2) The arrangement or MOU should cover the full spectrum of issues and requirements, including but not limited to:
(a) Space for workstations
(b) IT needs
(g) Work hours
(3) This arrangement for the use of alternate site is separate and distinct for any arrangement for data backup or connectivity. If IT support is provided by another region or office in the event of activation of a COOP, that IT support should be set forth in a separate written agreement or MOU.
h. Coordination with local authorities. To ensure the ability to execute the move to and functioning of the alternate location, coordination with inter-governmental agencies and local authorities in area of operation is required. Such coordination should cover matters such as access to the quadrants of the city where the facility is located and access to power, water, sanitary and medical facilities so GSA’s access does not interfere with or hinder the plans of the other governmental entities in the affected area.
4. Consistency with statute. This order does not override or reduce GSA’s responsibilities under statute, executive order or regulations governing the responsibilities and activities of GSA for federal emergency preparedness. To the extent that any section of this order is inconsistent with applicable statute, executive order or regulation, such section is void.
Stephen A. Perry