Two Federal Directives for COOP: PPD-40 and FCD 1

The two federal directives for COOP are Presidential Policy Directive 40 (PPD-40) and Federal Continuity Directive 1 (FCD 1). PPD-40 sets the overarching national continuity policy for the executive branch; FCD 1 turns that policy into the specific planning requirements agencies must meet. PPD-40 was signed on July 15, 2016, replacing NSPD-51/HSPD-20, and it directs the FEMA Administrator to publish the Federal Continuity Directives that implement it.¹

What PPD-40 Does

PPD-40 is the top-level presidential directive. It charges the Secretary of Homeland Security, acting through FEMA’s Administrator, with coordinating continuity across every federal department and agency, and it instructs the Administrator to develop and publish the Federal Continuity Directives that spell out program and planning requirements.¹

The whole framework points at eight National Essential Functions (NEFs). These are the federal government’s most critical responsibilities, and every agency’s continuity plan ultimately traces back to supporting one or more of them. The NEFs cover preserving constitutional government, defending the nation, maintaining foreign relations, responding to domestic incidents, stabilizing the economy, and providing essential public services.²

PPD-40 also requires each agency to appoint a Continuity Coordinator at the Assistant Secretary level or higher and to dedicate sufficient resources, including funding, to sustain its continuity program.¹ The directive designated the Assistant to the President for National Security Affairs as the National Continuity Coordinator, a role later reinforced by Executive Order 13961, which established the Federal Mission Resilience Executive Committee to oversee strategy and reduce reliance on reactive relocation of personnel during emergencies.³

What FCD 1 Does

Where PPD-40 sets the strategy, FCD 1 provides the blueprint. Issued by the FEMA Administrator, it establishes the framework, processes, and minimum standards that federal departments and agencies must follow when building their continuity programs. It defines the required elements of a continuity plan and mandates that agencies maintain a viable continuity capability at all times, not just during emergencies.¹

The central operational demand: agencies must identify their essential functions, determine which of them qualify as Primary Mission Essential Functions (PMEFs) supporting the NEFs, and build the infrastructure to keep those functions running through any disruption.⁴ Continuity is treated as something woven into daily operations rather than shelved until a crisis hits.

Required Elements of a Continuity Plan

FCD 1 requires a broad set of plan elements that cover leadership, operations, information, and workforce readiness:

Essential functions. Agencies identify which functions qualify as Mission Essential Functions (MEFs) or PMEFs and document how each will continue during a disruption.
Orders of succession. A documented chain showing who assumes leadership if the primary officeholder is unavailable. Personnel in the succession order must have the legal authority to make key decisions.
Delegations of authority. Written authorizations that allow designated officials to act on behalf of agency leadership during a continuity event.
Essential records. Identification and protection of records needed to sustain operations and resume normal functions, including both emergency operating records and records that protect the legal and financial rights of individuals.
Continuity locations. Alternate sites where operations can relocate. Continuity personnel must be fully operational at the alternate facility no later than 12 hours after plan activation.
Continuity communications. Redundant, interoperable communications systems that remain available during emergencies.
Human resources planning. Procedures for accounting for personnel, communicating with employees, and managing workforce needs during and after activation.
Devolution. A plan for transferring statutory authority and operational responsibility to personnel at a different location if the primary leadership or facility is incapacitated.
Reconstitution. Procedures for returning to normal operations after the disruption ends, coordinated with the Executive Branch Reconstitution Cell composed of personnel from FEMA, GSA, OPM, and the National Archives.
Testing, training, and exercises. A structured program to validate that the plan actually works.

The 12-hour operational deadline is one of the framework’s most concrete benchmarks. Agencies with PMEFs must be able to sustain continuous performance; those with MEFs must achieve operational capability at the alternate site within that same window.¹ Once activated, agencies must be prepared to sustain alternate-site operations for a minimum of 30 days or until normal operations resume.⁵

Training, Testing, and Exercises

A plan that has never been tested is just a document. PPD-40 requires agencies to conduct routine training, testing, and exercises to evaluate program readiness, and the Program Management Requirements directive sets specific frequencies:

Annual awareness briefings for the entire workforce.
Annual role-specific training for all continuity personnel, leadership officials, and individuals listed in orders of succession.
Annual PMEF validation confirming that all required capabilities are accessible and operational.
Function-level exercises for each PMEF annually and each MEF at least biennially.
An annual command and control exercise validating the agency’s ability to maintain organizational command and control during a continuity event.⁵

Who Must Comply

The mandatory provisions apply to executive departments listed in 5 U.S.C. § 101, independent establishments, government corporations, and the U.S. Postal Service.¹ The newer FCD on Essential Functions Risk Identification and Management extends applicability to the intelligence community.² Compliance is mandatory at all organizational levels, including regional and field offices.

The organization head is ultimately responsible for continuity decisions, including which alternate sites will be used.⁵ Day-to-day coordination falls to the Continuity Coordinator, who must ensure continuity requirements are integrated into the agency’s strategic planning and budget processes.

State, local, tribal, and territorial governments, private-sector organizations, and nonprofits are not bound by PPD-40 or the FCDs. FEMA publishes the Continuity Guidance Circular as a non-mandatory resource for those entities.⁶

One Note on the Broader FCD Series

When emergency management courses or certification exams refer to the “two federal directives for COOP,” they mean the PPD-40 and FCD 1 pairing. FEMA has since expanded beyond a single FCD 1 document and now publishes a series that includes a Continuity Planning Framework for the Federal Executive Branch, a directive on Continuity Program Management Requirements, and a directive on Essential Functions Risk Identification and Management.⁷ These newer directives elaborate on FCD 1 rather than replace it, introducing updated concepts including four interconnected planning factors: Staff and Organization, Equipment and Systems, Information and Data, and Sites.⁸ Anyone working in federal continuity planning today should be familiar with the full series, because the detailed requirements now live across several documents.

1
Federal Emergency Management Agency. Federal Continuity Directive 1 – Federal Executive Branch National Continuity Program and Requirements
2
Federal Emergency Management Agency. Federal Continuity Directive – Federal Executive Branch Essential Functions Risk Identification and Management
3
The American Presidency Project. Executive Order 13961 – Governance and Integration of Federal Mission Resilience
4
Federal Emergency Management Agency. Federal Continuity Directive 1 (FCD 1)
5
Federal Emergency Management Agency. Federal Continuity Directive – Federal Executive Branch Continuity Program Management Requirements
6
FEMA. Continuity Guidance Circular
7
Federal Emergency Management Agency. Continuity Resources
8
Federal Emergency Management Agency. Federal Continuity Directive – Continuity Planning Framework for the Federal Executive Branch