Continuity of Operations Planning for Island Government Agencies

Summary of the paper

Federal continuity of operations (COOP) guidance assumes that a government agency can relocate its essential functions to a geographically separated alternative facility. This ISPI policy brief, "Continuity Without a Continent," argues that for single-island government agencies that assumption is a structural impossibility, and that federal guidance, including Federal Continuity Directives 1 and 2 and FEMA's Continuity Guidance Circular, is written for continental organizations.

The brief proposes redesigning COOP around what island agencies can actually do: keep essential functions running from the primary facility under degraded conditions, and protect those functions through digital continuity. It treats these not as fallback options but as the only viable primary strategies for island governments.

The argument is practical. A continuity plan is only as useful as the facility and partners it names. If the alternative site loses power along with the primary one, or the mutual aid partners are an ocean away and not yet activated, the plan offers compliance on paper rather than continuity in practice. The brief sets out what island agencies should build instead and what federal policy should change so that building it counts.

What the paper finds

• Relocation is not available. Island government organizations cannot achieve the geographic separation that continental COOP frameworks require.
• The same gap recurs. Island government COOP failures in major emergencies document the same pattern across events: continental frameworks applied to island geographic constraints.
• Puerto Rico shows the failure mode. When Hurricane Maria destroyed Puerto Rico's power grid in September 2017, the alternative operating facility named in the government's continuity plan had also lost power, and the mutual aid agreement named mainland agencies that were far away and not yet activated.
• Shelter-in-place must be the primary strategy. That means hardening the primary facility, pre-positioning supplies and power generation, and building communication redundancy at the primary location.
• Digital continuity is real continuity. Cloud-based essential function systems reachable from a ruggedized satellite terminal provide operational continuity that a paper plan citing an unreachable alternative facility does not.

What it recommends

• Reform federal COOP compliance requirements for island and noncontiguous territory government agencies so that shelter-in-place continuity and digital continuity infrastructure are recognized as primary compliance pathways.
• Fund island-specific COOP infrastructure, including hardened primary facilities, pre-positioned power generation and ruggedized communication systems, for Pacific Island territory governments through reformed FEMA continuity grants.
• Develop an Island Government COOP Framework as a practitioner-grounded supplement to federal COOP guidance, designed for island geographic realities.

Who it's for

Continuity planners and emergency managers in Hawaii counties, Guam, the CNMI, American Samoa and other island jurisdictions; agency heads who must certify COOP plans; facilities and IT leads responsible for backup power, satellite communications and cloud systems that would carry essential functions; and FEMA and grant program staff who set continuity compliance requirements and funding.

Further reading

• Sri Lanka: Island Emergency Management and Governance Resilience
• Sri Lanka's Cyclone Ditwah and the Island Emergency Management Gap
• Hawaii's June 14 FEMA Deadline Exposes the Island Disaster Recovery Gap That Lahaina Already Documented
• What Is Supply Chain Singularity? Why Island Communities Face a Different Disaster Risk

Cite as

Pulley, Warren (2026). Continuity Without a Continent: Redesigning COOP for Island Government Agencies That Cannot Relocate Essential Functions (ISPI PB-10). Island Security Policy Institute, Honolulu. https://ispiglobal.com/papers-landing/pb10-coop-island-government https://doi.org/10.5281/zenodo.23450005

@techreport{ispipb102026,
  author      = {Pulley, Warren},
  title       = {Continuity Without a Continent: Redesigning COOP for Island Government Agencies That Cannot Relocate Essential Functions},
  institution = {Island Security Policy Institute},
  address     = {Honolulu, HI},
  number      = {ISPI PB-10},
  year        = {2026},
  url         = {https://ispiglobal.com/papers-landing/pb10-coop-island-government},
  doi         = {10.5281/zenodo.23450005}
}

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