Continuity of operations plans are meant to outline how an agency will plan for, respond to and recover from an incident that makes standard facilities or technology unavailable, prevents employees from accessing their usual worksite or creates a long-term disruption in power or telecommunications. FEMA, the report says, should be overseeing TSA and other Homeland Security agencies' plans, as it has been designated the department's lead on COOP.
Part of contingency planning involves ensuring that an alternate facility is ready for an event that renders standard offices useless. "TSA has secured a number of interim [alternate facilities] to continue operations" but it has never made sure a permanent site is available, the report said.
"If a disaster rendered the data centers inoperable," the report said, "TSA would use its IT contractor facility in suburban Virginia to provide a limited backup capability to recover systems."
In its response to the report, TSA said it allocated $10 million of its fiscal 2006 funds "to the COOP program to support the design and buildout of two alternate operating facilities... and procure emergency equipment." TSA Deputy Assistant Secretary Robert Jamison said in the response that additional internal oversight controls have been implemented, including random unannounced inspections to insure elements of COOP are adequately implemented.
In the letter, dated July 19, Jamison said, "TSA has made several significant changes to the [COOP] program in recent months that are not reflected in the report." But he added that "other direction and oversight controls are still in development."
The program also has been placed under a different authority to ensure better leadership. It is now located in TSA's Office of Law Enforcement - Federal Air Marshal Service, Emergency Preparedness Division, said Conan Bruce, an air marshal spokesman who answered questions for TSA.
"With this reorganization, [the law enforcement office] has heightened interaction and visibility of the COOP program to make it a leading priority behind incident management," Bruce said. "This reporting structure provides improved accountability and ensures direct leadership oversight for the COOP program." He added that TSA is in the process of ensuring the agency implements all the "elements of a viable COOP program."
FEMA Director R. David Paulison said in a written response to the report that "FEMA does not have the authority to serve as a regulatory agent responsible for ensuring that federal departments and agencies are prepared for COOP." Paulison stated that the agency is supposed to, and has, offered "periodic assessments" of TSA's contingency plan and that TSA has offered readiness status reports to FEMA.