A defense continuity program can be built. The tide comes in regardless. What changes that is not a better plan – it is a different relationship between the program and the structure that surrounds it.
Built by One Person. Owned by No One.
A Continuity Program Manager (CPM) at a defense command spends two to three years building a program. The Mission Essential Function (MEF) analysis is rigorous. The Business Process Analysis (BPA) entries are complete, including the Step 10 budget requirements that almost no other program bothers to fill in. The alternate site has been validated against the current MEFs by the current Emergency Relocation Group (ERG). The exercise last year found real gaps. The Corrective Action Program (CAP) entries are tracked. The program is, by any honest measure, the closest thing to what the Federal Continuity Directive (FCD) series describes as a viable continuity program.
Then the CPM rotates out.
The incoming CPM inherits a file cabinet, a set of documents, and a predecessor who is unreachable within weeks. The Mission Owners who engaged with the previous CPM have no particular relationship with the new one. The alternate site validation that took eighteen months to complete is now eighteen months old and aging. The CAP entries that were tracked are now in a spreadsheet that the new CPM does not know exists. Within a year, the program that was built has not been destroyed. It has been eroded — quietly, without anyone deciding to erode it, by the structural conditions that surround every defense continuity program regardless of how well it was built.
This is the sand castle problem. The program can be built. The tide comes in anyway. And the compliance structure — the inspection regime, the annual review, the plan certification — does not distinguish between the program that was built above the tide line and the one that was not. Both pass. The tide treats them the same.
What the compliance structure was designed to produce
The federal continuity policy framework requires organizations to produce specific documents: a continuity plan, a MEF list, an orders of succession, delegations of authority, essential records inventories, alternate facility designations, and an annual exercise. The inspection regime verifies that these documents exist, are current, and have been reviewed by an appropriate official. The annual certification confirms the plan is viable.
This is the system working as designed. The policy required documents. The inspection verifies documents. The documents are produced. The requirement is satisfied. The problem is not that the compliance structure is broken — it is that the compliance structure was designed to verify the existence of a document, and a document is not the same thing as the capability the document was supposed to represent.
A MEF list that was inherited from the previous CPM, reviewed at the last plan cycle, and initialed by a Mission Owner who does not remember the conversation satisfies the compliance requirement. A MEF list produced through a rigorous top-down analysis conducted with Mission Owner engagement, validated against the current mission portfolio, and approved by leadership as a genuine prioritization decision also satisfies the compliance requirement. The inspection cannot distinguish between them. The disruption can.
The tide
The force that erodes defense continuity programs is not negligence. It is structure. The CPM role is almost universally a collateral duty — assigned to a staff officer or civilian analyst who carries it alongside other responsibilities, receives limited training for it, and holds it for two to three years before rotating to the next assignment. The knowledge, relationships, and analytical depth that make a program capable are accumulated by a person. When that person leaves, those things leave with them.
The rotation cycle is not a correctable management failure. It is a permanent feature of the defense personnel system. Every CPM who builds a good program will eventually rotate out. Every program that depends on a specific CPM’s knowledge and relationships will degrade when that CPM leaves. The question is not how to stop the tide. It is whether the program was built in a position where the tide cannot reach it.
The tide has a second source that the rotation cycle does not fully explain: the institutional environment the CPM operates in. A CPM who cannot compel Mission Owner participation cannot build a rigorous BPA regardless of how capable they are. A CPM whose resource requests disappear into the budget process without a senior official to carry them cannot fund the capability gaps the analysis identified. A CPM who reports through three layers of staff coordination to reach the commanding officer cannot get the program the organizational attention it requires. The tide is the rotation cycle. The terrain is the institutional environment. The sand castle problem exists because the terrain is almost always set at the waterline.
| At the waterline | Above the tide line |
|---|---|
| CPM role is collateral duty; program capability walks out with the person | Senior OPR designated with direct accountability to the commanding officer; authority persists across CPM rotations |
| Mission Owner engagement depends on the CPM’s relationships and persuasion | Mission Owner participation is a command expectation directed by the OPR; engagement is structural, not relational |
| Resource requests compete at the working level without senior advocacy | OPR presents capability gaps to the commanding officer as risk decisions; continuity requirements enter the resource planning cycle |
| CPM rotation resets institutional knowledge; incoming CPM rebuilds from the file cabinet | Program design embeds accountability in the command architecture; OPR provides continuity of oversight across CPM rotations |
| Compliance inspection validates that documents exist; capability is not measured | OPR requires the program to demonstrate capability, not just document it; exercise findings drive real corrections |
The OPR that changes the terrain
The policy framework does not require every defense command to designate a senior official directly
accountable to the commanding officer for continuity program outcomes. The federal CC designation exists at the Assistant Secretary level — department and agency headquarters. Below that level, accountability for continuity program performance is assigned to staff, not to a named senior official with a specific accountability relationship to the commander. The result is a program that belongs to everyone in general and no one in particular.
The Army got closest to solving this. Army Regulation (AR) 500-3 requires the CPM to report directly to the commander or immediate deputy. Not through J3. Not through the chief of staff and two layers of staff coordination. Directly. That structural decision — a reporting relationship, not a new position — changes the institutional environment the program operates in. The commander knows the program exists and receives its findings directly. The CPM has access to the authority the program requires. The program has organizational gravity.
The equivalent for every command is not a new billet or a new policy requirement. It is a designation: a senior official — O-6 or civilian equivalent at minimum, at the level where resource decisions are made and Mission Owner accountability can be directed — named as the Office of Primary Responsibility (OPR) for the continuity program, with direct accountability to the commanding officer or organization head, and with a defined set of authorities that the CPM does not hold. The CPM manages the program. The OPR ensures the organization treats it as a command responsibility.
That designation is available to any commanding officer right now, without waiting for a policy change. It is a command decision. The commanding officer who makes it has not created a new requirement. They have created the structural condition that makes their existing requirements executable. The commanding officer who does not make it has a CPM managing a continuity program from the waterline, building sand castles against a tide the program cannot see coming.
Why the OPR designation is the tide line
The OPR changes three things that the CPM cannot change alone.
The first is Mission Owner engagement. A CPM who requests Mission Owner participation in a BPA session is making a coordination request. A Mission Owner who is too busy, too skeptical of continuity planning, or too far removed organizationally from the CPM can decline without consequence. An OPR who directs Mission Owner participation as a command accountability requirement is making a different kind of request. The BPA that could not get Mission Owners in the room can now get them in the room. The analytical foundation of the program changes because the accountability structure changed.
The second is resource advocacy. The CPM who identifies a capability gap and estimates its cost in BPA Step 10 has produced an analysis. Without a senior official to carry that analysis into the resource planning cycle, it remains an analysis. The OPR who presents the gap to the commanding officer as a risk decision — here is what the MEFs require, here is what the program is currently funded to provide, here is the gap, and here is what closing it would cost — has converted the analysis into a decision. The commanding officer may accept the risk. They may fund the requirement. Either way, the decision has been made at the appropriate level with the appropriate information. That is how capable programs get resourced.
The third is rotation resilience. The CPM who built the program rotates out. The incoming CPM inherits the file cabinet. But the OPR is still there. The Mission Owner accountability structure the OPR established is still there. The resource request the OPR carried to leadership is still in the budget cycle. The commanding officer’s expectation that continuity is a command responsibility is still in place. The program has lost its most knowledgeable practitioner. It has not lost its organizational foundation. That is the difference between a program built above the tide line and one built at the waterline.
The enterprise argument
One commanding officer who makes this structural decision changes the continuity program at that command. The program becomes harder to erode. It has organizational gravity. The CPM rotation is still coming — the tide still comes in — but the program was built where the tide cannot reach it.
Across the defense enterprise, the structural decision that every commanding officer could make is almost never made. The policy does not require it. The inspection does not reward it. The compliance structure produces the same passing grade whether the program has a senior OPR with direct accountability to the commander or a GS-13 managing it as a collateral duty from the fourth layer of staff. Nothing in the current system creates pressure to make the structural decision that would change the outcome.
Changing that is not a policy problem. The policy framework is sound. DoDI 3020.42 establishes a planning standard that, if actually implemented, produces capable programs. The FCD series describes what a viable continuity program requires. The problem is not that the policy is wrong. The problem is that the compliance structure does not distinguish between programs that implement it and programs that document it. And nothing compels commanding officers to make the structural decision that would produce real implementation rather than documented compliance.
What changes that is not stricter inspections. Stricter inspections produce better documents. What changes it is commanding officers and senior officials who understand the difference between a program that passes an inspection and a program that would function under the conditions it was built for — and who make the structural decisions that create the second kind of program. That understanding does not come from the policy. It comes from the conversation about what the policy actually requires versus what the compliance structure currently rewards.
The sand castle can be built. It has been built, at commands where the right combination of CPM capability, Mission Owner engagement, and leadership attention came together at the same time. Those programs are real. They demonstrate that what the policy describes is achievable. They also demonstrate that achievable and sustainable are different conditions. The programs that hold — that survive the rotation cycle, maintain their analytical depth, retain their organizational gravity — are the programs built above the tide line. Not because they had better CPMs. Because they had commanding officers who made the structural decision that placed them there.
The tide is not the enemy. The tide is the condition. Every defense continuity program operates in an
environment where the rotation cycle will eventually come, the institutional memory will eventually thin, and the compliance structure will continue to reward the document rather than the capability behind it. The question is not whether the tide comes in.
The question is where the program was built when it did — and
whether the commanding officer understood that building above the tide line was a decision they could make, right now, without waiting for the policy to require it.
About Vision Continuity
Vision Continuity is a Service-Disabled Veteran-Owned Small Business (SDVOSB) that specializes in providing defense continuity expertise and leadership advisory services. With a team of certified defense continuity experts, Vision Continuity helps elevate client continuity programs from compliance-focused to establishing a culture of resilience that translates into durable readiness.
