j
\
 5  U.S. ENVIRONMENTAL PROTECTION AGENCY
 *  OFFICE OF INSPECTOR GENERAL

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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).

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    .tfto sr/|,
I
5
                  U.S. Environmental Protection Agency
                  Office of Inspector General

                  At  a  Glance
                                                             10-P-0017
                                                        October 27, 2009
                                                                 Catalyst for Improving the Environment
Why We Did This Review

The 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.

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.
 EPA  Needs to Improve Continuity of
 Operations Planning
 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.
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.qov/oiq/reports/2010/
20091027-10-P-0017.pdf

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                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  WASHINGTON, D.C. 20460
                                                                            OFFICE OF
                                                                        INSPECTOR GENERAL
MEMORANDUM
SUBJECT:
FROM:
TO:
                                    October 27, 2009
EPA Needs to Improve Continuity of Operations Planning
Report No. 10-P-0017
Wade T. Najjum
Assistant Inspector General
Office of Program Evaluation
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.ieffrev@epa.gov.

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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

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                                                                             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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                                                                             10-P-0017
             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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                                                              10-P-0017
•  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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                                                                           10-P-0017
                                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
             2030.1 A, "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 2030.1 A, 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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                                                                               10-P-0017
             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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                                                                              10-P-0017
             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 2030.1 A, 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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                                                                                 10-P-0017
              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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                                                                               10-P-0017
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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                                                                  10-P-0017
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.

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                                                                                    10-P-0017
                  Status of Recommendations and
                      Potential Monetary Benefits
                            RECOMMENDATIONS
                            POTENTIAL MONETARY
                             BENEFITS (in SOOOs)
Rec.
No.
2-1
2-2
2-3
2-4
2-5
Page
No.
8
8
8
8
8
Subject Status1
Establish a schedule for the completion of the 0
requirements in FCD 1.
Establish Headquarters and regional COOP 0
responsibilities and authorities, including
designating a lead office for COOP planning.
Develop consistent guidance and procedures for 0
preparing regional COOP plans.
Develop consistent mission essential functions and 0
priorities for all regions to include in their COOP
plans.
Develop training guidance that incorporates 0
realistic scenarios that prepare personnel to
perform mission essential functions during a COOP
activation (i.e., from an alternate location with
limited staff).
Action Official
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Planned
Completion Claimed Agreed To
Date Amount Amount
11/15/2009
6/30/2010
10/30/2010
10/30/2010
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.
Assistant Administrator
 for Solid Waste and
Emergency Response
0 = 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
                                             10

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                                                                            10-P-0017
                                                                        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
                                         11

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                                                                              10-P-0017
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
                                          12

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                                                                              10-P-0017
        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
       2-1
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
                                          13

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                                                                           10-P-0017
                                                                       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

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