Through my career I’ve had the opportunity to work with a number of airports on preparedness efforts. In the past couple of years, that interaction has been greatly amplified through a contract my company successfully completed involving the development of exercises for airports. As part of this effort, we designed, conducted, and evaluated exercises at ten airports of varying sizes across the nation, from Georgia to Alaska, Massachusetts to California. Since the primary intent of exercises is to validate plans, we of course requested and reviewed airport emergency plans (AEPs) from each location as part of our preparation for each exercise.
For those not in the know, the requirement for AEPs originates with Federal Aviation Regulation 14 CFR Part 139, which wholly establishes the standards for the certification of airports. The requirements for AEPs are further refined in DOT/FAA Advisory Circular 150-5200-31C published in May of 2010. The Advisory Circular is largely implementation guidance. It’s quite comprehensive and outlines a planning structure, references emergency management doctrine and standards of practice such as NIMS and the National Response Framework, and models a planning process, which mirrors that of CPG-101. The NFPA also provides guidance in NFPA 424: Guide for Airport/Community Emergency Planning, which reflects on all these as well.
Just like any community emergency operations plan (EOP), AEPs I’ve reviewed run the full spectrum of quality. Some plans are thorough and comprehensive, while other plans are so focused on meeting the letter of the regulation that they fall short of meeting real needs and being implementation-ready, even though they technically meet the requirements set forth in §139.325. Regulated industries, which airports largely are, often have a challenge when it comes to emergency planning. We see this same challenge in radiological emergency plans as well. The laws and regulations seem to provide so much structure that it is perceived that local variables and subjective analysis aren’t allowed. As an example, §139.325 states:
“the plan must contain instructions for response to:
- Aircraft incident and accidents
- Bomb incidents, including designation of parking areas for the aircraft involved
- Structural fires
- Fires at fuel farms or fuel storage areas
- Natural disaster
- Hazardous materials/dangerous goods incidents
- Sabotage, hijack, or other unlawful interference with operations
- Failure of power for movement area lighting
- Water rescue situations (as appropriate)”
While the planning process isn’t prescribed in §139.325, nor does it specify if other hazards can be included in the AEP, the Advisory Circular (AC) does expound on this and prescribes a planning process, including a hazard analysis. The AC states “Through the hazards analysis program, guidance has been provided to assist in the identification of those hazards and disasters specific to an airport that warrant planning attention”. That phrasing indicates that airports should be planning for hazards beyond what is required by §139.325, yet I’ve seen many that do not.
Obviously ‘natural disaster’ covers a considerable amount of proverbial territory. Jurisdictions undergo extensive hazard analysis and hazard mitigation planning to identify the breadth and scope of these hazards (which should include all hazards, not just natural disasters). Many jurisdictions develop very comprehensive EOPs and annexes to address the response needs of each of their primary hazards. I saw this as a significantly missing component in many AEPs, which treated ‘natural disasters’ as a single hazard. Further, as many airports stick to the minimum requirement for planning, they fail to address other hazards which could impact them, ranging from dam failure, and nuclear power facility incidents, to currently hot topics such as active shooter/hostile event response (ASHER) and communicable diseases.
Some airports have thankfully recognized the need for expanding beyond the required hazards and have developed plans that better address all of their needs. On the unfortunate side, again as a regulated industry, I’ve also seen some airports having two sets of plans… one that meets regulation and the other that they feel is more practical for implementation. Clearly this isn’t the way to go either. A single, consolidated plan can be developed that meets all needs.
Airports are an interesting animal. Regardless of governance structure, they are part of the communities which surround them. Larger airports are also communities of their own, having significant capability, sometimes more than the surrounding jurisdictions. Airport emergency planning should acknowledge and involve their community relationships and must address all hazards, not just the ones required by Part 139. Just as with any other type of emergency plan, they must be implementation-ready. To do so typically requires the added development of standard operating guidelines (SOGs) and job aids, such as check lists and forms. Plans should also be developed to address recovery issues and business continuity, not just response. An airport, regardless of governance structure, operates like a business, with many other stakeholders dependent upon their stability and ability to address and rapidly recover from incidents. They are also obviously transportation hubs, dealing with large volumes of people and significant dollar figures in freight and commerce.
Airport emergency managers have many of the same challenges as the emergency managers of any other community. Staffing and funding rarely line up with requirements and other priority matters. I encourage community emergency managers to reach out to their local airports and coordinate, as many hands make easier work for everyone. Of course, if any airports are seeking assistance in enhancing their preparedness, please contact us as we would love to work with you!
© 2018 – Timothy Riecker, CEDP