Continuity of Operations (COOP) for Island Local Government: A Step-by-Step Guide and Checklist
A continuity of operations (COOP) plan keeps a government office's essential services running when its building, power, people or systems are knocked out. FEMA's guidance gives every plan the same core parts: essential functions, succession, delegations of authority, continuity facilities, communications, records, devolution and reconstitution. On an island, the usual answer of moving to a backup site far away often isn't available, so ISPI's PB-10 argues island agencies should plan first for keeping essential functions running at or near home under degraded conditions. This guide walks through the steps and ends with a checklist.
What is a continuity of operations plan?
FEMA defines continuity as the ability to provide uninterrupted critical services, essential functions and support, while keeping the organization viable, before, during and after an event that disrupts normal operations (FEMA Continuity Resource Toolkit). A COOP plan is the written version of that ability for one organization: which services can't stop, who runs them, from where, with what records and systems, and how the office gets back to normal.
FEMA describes an organization's continuity capability as resting on four pillars (leadership, staff, communications and facilities), built on a foundation of continuity planning and program management (FEMA National Continuity Programs). The guidance applies beyond federal agencies: FEMA's Continuity Guidance Circular is written as whole-community guidance for state, local, tribal and territorial governments and other organizations (FEMA Continuity Guidance Circular).
Responsibility sits at the top. FEMA's 2009 circular for non-federal entities says the senior elected official or administrative head of a state or local organization is ultimately responsible for continuing essential services during an emergency and for the related planning (FEMA CGC 1, 2009).
Why island governments need a different starting point
Hawaiʻi has recent evidence that continuity planning matters. In the findings prepared by the Fire Safety Research Institute for the Hawaiʻi Attorney General's review of the 2023 Lahaina fire, finding 47 states that there were no written procedures or guidelines for continuity of operations, and the matching recommendation is for the County of Maui, Maui Police Department and Maui Fire Department to prepare COOP plans (FSRI findings for the Hawaiʻi Attorney General).
The Maui Emergency Management Agency after-action report on the 2023 wildfires reached a similar conclusion. It found that gaps in continuity planning left roles for mission-essential tasks unclear, which made it hard to reassign county employees to key roles and limited the emergency operations center's staffing. Its recommendation 16 is simply to ensure the county has current and relevant COOP and continuity of government plans (Maui Emergency Management Agency after-action report).
The second issue is geography. Standard continuity planning assumes an agency can move its essential functions to an alternate site, or devolve them to staff at a geographically distributed site unaffected by the event (FEMA Continuity Guidance Circular). ISPI's PB-10: Continuity of Operations for Island Agencies argues that for single-island agencies this assumption often fails: an alternate facility on the same island may lose power along with the primary one, and partners on another island or the mainland may be an ocean away and not yet activated. The brief's recommendation is to treat continuing essential functions at the primary location under degraded conditions, backed by digital continuity, as the primary strategy rather than a fallback.
Step 1: Identify essential functions and how fast each must resume
Everything else in the plan depends on this step. FEMA calls identifying and prioritizing essential functions a prerequisite for continuity planning, because those functions set the parameters for every other part of the plan (FEMA CGC 1, 2009). For a county or city, typical candidates are emergency communications and dispatch, water and wastewater, public safety, payroll for responders, permitting needed for emergency repairs, and public information.
For each function, record how quickly it must resume and how long it must be sustained. As a reference point, FEMA's 2009 circular set federal primary mission essential functions to be continuous or resumed within 12 hours and maintained for up to 30 days (FEMA CGC 1, 2009). Island agencies should test that 30-day horizon against resupply realities; ISPI's WP-03: Island Emergency Management Framework argues the common 72-hour household standard is too short for islands and proposes a 30-day community reserve standard.
Step 2: Map what each function needs
FEMA's tool for this is a business process analysis (BPA): a systematic record of the workflows, people, expertise, systems, data, facilities and outside partners each essential function depends on (FEMA Continuity Guidance Circular). A BPA answers practical questions such as which staff and authorities a task needs, what communications and IT it relies on, what facility requirements it has, and which internal and external organizations supply it (FEMA Continuity Guidance Circular).
On an island, pay special attention to single points of failure that a mainland plan would never list: one undersea cable landing, one fuel terminal, one interisland barge route, or one vendor whose technicians fly in from the mainland. ISPI's explainers on Pacific undersea cables and the Hawaiʻi grid after Hurricane Lala show why these dependencies belong in the analysis.
Step 3: Set succession and delegations of authority
Orders of succession tell staff who assumes a leader's authority if that leader is unavailable, and FEMA says they should be deep enough for the organization to keep managing and directing its essential functions (FEMA CGC 1, 2009). Delegations of authority make sure the person who steps in has the legal power to act (FEMA CGC 1, 2009). Have legal counsel review both, and write them by position title, not by name, so they survive turnover.
For island agencies, check that successors don't all live and work in the same hazard zone, and that at least one successor can act if interisland flights stop.
Step 4: Plan facilities, communications and records for degraded conditions
FEMA's template and circular expect a continuity facility, continuity communications and essential records management (FEMA Continuity Guidance Circular; CISA listing of the FEMA template). Following PB-10: Continuity of Operations for Island Agencies, island agencies should plan these as layers:
- Harden the primary site first: backup power with fuel for the planned sustainment period, pre-positioned water and supplies, and redundant communications at the main building.
- Name alternates realistically: if the alternate site shares the same grid, road or water system, write down what still works when that shared system fails.
- Make records and systems reachable from anywhere: cloud-hosted essential records and applications, plus a satellite or other independent link, so staff can work from wherever they are safe.
- Test communications under the conditions you expect: no commercial power, no cell service and no internet over the cable.
Step 5: Plan devolution and reconstitution
Devolution is the transfer of authority and responsibility for essential functions to other staff at another location when the primary organization can't perform them (FEMA Continuity Guidance Circular). For a single-island agency, the realistic devolution partner may be a sister agency on another island or on the mainland, which means agreements, system access and training must be in place before an event, not negotiated during one.
Reconstitution is the return to normal operations. FEMA's resources include a reconstitution plan template and guidance on synchronizing reconstitution and continuity teams (FEMA continuity resources). Decide in advance who declares the end of continuity operations and what order services come back in.
Step 6: Train, exercise and keep the plan current
A plan that staff have never practiced won't run on the day it's needed. FEMA's National Continuity Training Program offers courses, including the Continuity Excellence Series certificates (FEMA Continuity Resource Toolkit), and FEMA publishes a Continuity Assessment Tool for checking a plan and program (FEMA continuity resources). Use of FEMA's plan template is not required, and FEMA encourages organizations to tailor it to their own needs (FEMA continuity resources).
Run at least one exercise a year built on a realistic island scenario, such as an islandwide power outage after a hurricane, a cable cut, or loss of the main government building, and track corrective actions until they are closed.
Island COOP checklist
| Area | Done when | Island check |
|---|---|---|
| Essential functions | Functions listed and ranked, with resume times | Sustainment period tested against resupply times, not 72 hours |
| Business process analysis | People, systems, data, facilities and partners mapped per function | Single points of failure (cable, fuel, barge, mainland vendor) listed |
| Succession | Position-based orders, several deep | Successors not all in the same hazard zone or on one island |
| Delegations of authority | Written, legally reviewed, with triggers | At least one delegate can act without air travel |
| Facilities | Primary site and alternates named | Primary hardened; alternates checked for shared grid, road and water |
| Communications | Redundant systems listed and tested | Works without commercial power, cell service or the cable |
| Essential records | Identified, backed up, access tested | Reachable from off-site through an independent link |
| Devolution | Partner organization and agreement in place | Partner trained and has system access before an event |
| Reconstitution | Return-to-normal steps and authority written | Order of restoring services decided in advance |
| Training and exercises | Annual exercise and tracked corrective actions | Scenario uses an island-scale outage |
Frequently asked questions
What is the difference between COOP and continuity of government?
COOP keeps an organization's essential functions running. Continuity of government is about preserving leadership and lawful authority across a jurisdiction. Maui's after-action report recommended both COOP and continuity of government plans (Maui Emergency Management Agency after-action report).
Is there a free FEMA COOP plan template?
Yes. FEMA publishes a continuity plan template and instructions for non-federal entities and community-based organizations on its continuity resources page; using it is optional (FEMA continuity resources; CISA listing of the FEMA template).
How often should a COOP plan be updated?
Review it at least once a year and after every real activation or exercise, and update contact lists and succession whenever key staff change.
Why can’t an island agency just relocate to a backup site?
It can try, but an alternate site on the same island may share the same power, roads and communications as the primary one. ISPI's PB-10: Continuity of Operations for Island Agencies argues island agencies should plan first for continuing essential functions under degraded conditions at or near the primary site.
ISPI publishes its research free under CC BY 4.0. If your county, agency or organization needs a continuity plan review, an island-specific COOP gap analysis or a policy brief, you can commission research from ISPI. ISPI is a nonprofit organization; its application for 501(c)(3) tax-exempt status is pending. Contributions are not tax-deductible until IRS recognition is granted.
Sources
- FEMA, “Continuity Resource Toolkit” (updated Jan. 16, 2026)
- FEMA, “Continuity Resources” (templates, Continuity Assessment Tool, reconstitution resources)
- FEMA, “Continuity Guidance Circular” (Feb. 2018, August 2024 update)
- FEMA, “Continuity Guidance Circular 1 (CGC 1): Continuity Guidance for Non-Federal Entities,” January 2009
- FEMA National Continuity Programs, “Federal Continuity” brochure
- CISA, “FEMA Continuity Plan Template and Instructions for Non-Federal Governments”
- Fire Safety Research Institute for the Hawaiʻi Department of the Attorney General, “Lahaina Fire Incident Analysis: Findings and Recommendations,” Sept. 10, 2024
- Maui Emergency Management Agency, “2023 Wildfire After Action Report”
- ISPI papers: PB-10, WP-03
