Paratransit Emergency Preparedness and Operations Handbook (2013)

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48 C h a p t e r 4 Prevention starts with being aware of potential hazards and avoiding unnecessary risks. These hazards and risks include risks to personal health and safety and damage to vehicles, equip- ment, and facilities. Prevention efforts may include short- and long-term measures. Mitigation is another term sometimes used interchangeably with prevention or preparedness measures and is usually applied to long-term solutions. Also, people, in general, need to be better prepared to cope with emergencies and disasters. This need extends to paratransit employees and customers; some may benefit from better educa- tion and outreach on how to be self-sufficient, while others may need additional assistance due to their medical needs or adaptive equipment. Risk assessment provides the informational basis for prevention strategies. 4.A Risk Assessment 4.A.1 Threat and Vulnerability Assessment A threat and vulnerability assessment is an analysis of safety hazards and security threats including vehicle and workplace accidents; acts of nature; criminal acts; terrorism; and other risks that can cause loss of life, personal injuries, and property damage and disrupt operations. A threat and vulnerability assessment combines knowledge of your paratransit operating envi- ronment with critical analysis to rate the probability and severity of these hazards and threats in order to determine what the greatest risks to your agency may be. A threat and vulnerability assessment establishes a baseline to justify improvements in facili- ties, equipment, policies, procedures, and training to build a more robust and resilient paratran- sit system. It is a key building block of system safety program plans, paratransit security plans, and EOPs. Having these plans in place is one criterion used to evaluate security and emergency preparedness grant applications. Considerations ▪▪ Paratransit agencies that conducted accurate vulnerability assessments have been able to focus their limited resources on risk-reduction strategies addressing the hazards and threats that pose the greatest risk to critical infrastructure and mission capacity. This is true for paratransit operations in urban, suburban, rural, and tribal settings. ▪▪ Threat and vulnerability assessment helps paratransit agencies to better prepare for advance- notice emergencies such as hurricanes as well as no-notice emergencies, like earthquakes, and to develop emergency response strategies that address the actual hazards and threats that they face. Prevention

prevention 49 Effective Practices ▪▪ The Transportation Security Administration (TSA) has been involved with threat and vulner- ability assessments at larger transit agencies as part of its ongoing initiative to secure America’s transportation infrastructure. ▪▪ The number and quality of threat and vulnerability assessments have greatly increased in cases where state DOTs have provided guidance regarding threat and vulnerability assessment activities. ▪▪ In areas recently struck by disasters, paratransit agencies that had performed risk assessments prior to the disaster were typically better prepared and suffered fewer disaster losses. Strategy ▪▪ Threat and vulnerability assessments are typically conducted using matrix analysis to chart likelihood and severity for the wide range of hazards and threats an organization faces. Through careful review of paratransit accident and incident records, vehicle and facility inspections, and discussions with key paratransit staff, partner agencies, emergency management, and first responders, your agency can effectively identify the hazards and threats that pose the greatest risk. Actions can then be taken to avoid, transfer, or control risk. Tools: Threat and Vulnerability Assessment Critical paratransit assets to identify when considering vulnerability include: ❑ Revenue service vehicles ❑ Maintenance vehicles ❑ Administrative vehicles ❑ Administrative facilities ❑ Maintenance facilities ❑ Vehicle storage areas ❑ Fuel storage areas ❑ Transit/transfer centers ❑ Bus stops and shelters ❑ Computers and other office equipment ❑ Trip scheduling and dispatching systems ❑ Communications equipment ❑ Paratransit staff ❑ Paratransit customers Hazards and threats to consider when performing a paratransit vulnerability assessment include: ❑ Vehicle accidents ❑ Passenger incidents ❑ Employee incidents ❑ Acts of nature – Tornado – Hurricane – Tsunami – Earthquake – Flooding – Ice storm – Thunderstorm

50 paratransit emergency preparedness and Operations handbook Resource for Urban/Suburban Areas ▪▪ Safety and Security Site Assessment Checklist http://bussafety.fta.dot.gov/show_resource.php?id=4123 This document from Nusura, Inc., is a checklist for conducting a comprehensive safety and security site assessment. Resources for Rural/Tribal Areas ▪▪ Threat & Vulnerability Assessment Forms http://bussafety.fta.dot.gov/show_resource.php?id=3320 This series of forms, developed for FTA’s Transit Bus Safety and Security Program by Ream Lazaro and Michael Noel, is for the assessment of accidents and incidents, organizational infrastructure, acts of nature, hazardous materials, criminal activity, and domestic or inter- national terrorism using a severity rating system. ▪▪ Prioritized Vulnerability Report Form http://bussafety.fta.dot.gov/show_resource.php?id=3761 This threat and vulnerability assessment form is used to record elements of vulnerability, current levels of protection, and whether action is required. It is excerpted from “Transit Safety & Security Prototype Approach for Colorado Section 5310 and 5311 Transit Providers.” 4.A.2 Interagency Risk-Related Communication It is critical that your paratransit organization has methodologies in place to communicate with your partner agencies—such as human service agencies, resident care centers, and medical providers—before, during, and after emergencies so your customers can be effectively served throughout an incident. Coordination between paratransit and local emergency management and public safety agencies is essential to effective emergency preparedness, response, and recovery. Paratransit has critical information and resources to help emergency management address the transportation concerns of people with disabilities and others with access and functional needs. Conversely, local emergency management, law enforcement, and fire protection person- nel have critical information to help paratransit with your hazard and threat assessments and – High wind – Wildfire – Debris flow – Volcanic eruption ❑ Extended power outages ❑ Communication loss ❑ Information loss ❑ Facility loss ❑ Vehicle loss ❑ Fuel and critical supply loss ❑ Loss of essential personnel ❑ Facility fires ❑ Vehicle fires ❑ Hazardous material spills ❑ Criminal activity on or around vehicles ❑ Criminal activity in facilities ❑ Acts of terrorism

prevention 51 can be of great assistance in addressing paratransit’s potential role in the overall EOP. Without coordination, misunderstandings regarding roles, responsibilities, and capabilities can develop, and paratransit resources can be either greatly over- or underestimated. Open dialogue is needed to help paratransit providers better understand the risks you will face in serving your own customers during an emergency and to help emergency managers understand what kind of support paratransit may be able to provide during community-wide emergency oper- ations, including equipment, drivers, dispatchers, mechanics, supervisors, and other support staff. Considerations ▪▪ Most urban/suburban transit agencies are involved with their local emergency management and first-responder community and collaborate on risk management issues, but often that relationship does not extend to paratransit operations, resulting in possible disconnect regard- ing paratransit-specific emergency management considerations. ▪▪ Due to resource limitations and a lack of understanding about emergency planning, many rural/tribal paratransit systems have not conducted vulnerability assessments or have not communicated with emergency management regarding risk management concerns. ▪▪ Interagency communication about risk and risk-reduction strategies tends to reduce the impact of no-notice and advance-notice emergencies, though there may be greater benefits for no-notice emergencies where there is limited potential for preparation. Effective Practices ▪▪ The best risk mitigation programs involve input from stakeholders within and outside para- transit, including human service agencies, medical providers, resident care centers, emergency management, and public safety agencies. This input helps ensure that a diversity of perspec- tives are considered and fosters interagency relationships that speed up incident response, thereby reducing disaster impacts. ▪▪ Interagency risk communication leads to a better emergency planning process from the para- transit perspective and helps paratransit providers, partner agencies, and emergency manage- ment understand the risks and benefits inherent in paratransit operations. Strategy ▪▪ Through open dialogue with partner agencies, emergency management, and public safety agencies, paratransit providers can better understand local hazards and threats to help identify vulnerabilities to assets; emergency management can better understand paratransit capabili- ties and limitations; and first responders can better understand and mitigate paratransit safety and security concerns. Share information about your paratransit resources, vulnerabilities, and your mission to customer service with key external stakeholders to jointly develop strategies to reduce risk, mitigate disaster impact, and respond to transportation needs during emergencies. Tool: Interagency Risk-Related Communication Common emergency planning documents that can help facilitate dialogue between paratransit and key external stakeholders include: ❑ Hazard, threat and vulnerability assessments ❑ Gap analysis reports ❑ After-action reports ❑ Safety and security plans ❑ Emergency operations plans ❑ Evacuation plans

52 paratransit emergency preparedness and Operations handbook Resource for Urban/Suburban and Rural/Tribal Areas ▪▪ Critical Asset Threat and Vulnerability Assessment Form http://bussafety.fta.dot.gov/show_resource.php?id=3760 This form, an excerpt from “Transit Safety & Security Prototype Approach for Colorado Section 5310 and 5311 Transit Providers,” can be used to conduct threat and vulnerability assessments of an agency’s critical assets. 4.B Liability Management 4.B.1 Insurance Limitations Paratransit providers are not always aware of limitations to liability coverage for equipment and personnel involved in disaster exercises or deployed during emergency response and recov- ery. Insurance policies vary in relationship to this issue. Certain insurance policies will not cover paratransit assets mobilized for emergency response, and others will cover such response but only if it involves acts of nature rather than acts of terrorism. Depending on the type of insur- ance coverage, there may be limitations on coverage for staff that are injured or equipment that is damaged or destroyed. In addition to assessing any such policy limitations with your insurance carrier, you should discuss umbrella insurance options for paratransit resources with emergency management. Considerations ▪▪ Paratransit agencies in urban/suburban environments are sometimes self-insured. In such cases, any liability payouts have direct budgetary impacts requiring effective risk management in order to protect assets. ▪▪ Some urban/suburban transit agencies that contract for paratransit service require con- tractors to carry their own insurance as a contract condition. Issues can arise when a private contractor refuses to perform emergency response activities because of liability concerns. ▪▪ Many paratransit providers, particularly in rural/tribal areas, have not discussed with emer- gency management other options that may be available to protect assets. ▪▪ Some paratransit providers have discovered insurance coverage is in effect if the emergency was an act of nature but not if the emergency was the result of an act of terrorism. Effective Practices ▪▪ Paratransit agencies that self-insure have found it helpful to explore liability limitations with local or county emergency management officials and/or legal counsel. ▪▪ In some cases, limitations to coverage have been addressed through MOUs with a contracting transit system, emergency management, or the city or county. ▪▪ In some states, a formal emergency proclamation provides the legal authority for providing emergency response support thereby lessening liability concerns. Strategy ▪▪ Close coordination and ongoing communication between your agency and its insurance carrier can help resolve potential gaps in liability coverage for paratransit equipment and personnel involved in emergency drills and deployed during emergencies, including evacuation-related operations.

prevention 53 Resource for Urban/Suburban and Rural/Tribal Areas ▪▪ Local Disaster Response Reimbursement and Insurance Concerns http://bussafety.fta.dot.gov/show_resource.php?id=3315 Developed by Communique USA, this document takes a look at disaster response reim- bursement, insurance concerns, and FTA’s perspective regarding reimbursable disaster response activities. 4.B.2 Memoranda of Understanding and Mutual Aid Agreements A lack of understanding of when and how paratransit providers will operate during emergen- cies, and whether they will be reimbursed for providing emergency services to other agencies, can be a significant issue. Having written agreements in place in advance of a disaster helps prevent misunderstandings that could negatively affect paratransit budgets and the ability to support normal paratransit operations into the future. Written agreements between paratransit, partner agencies, and/or emergency management that define roles, responsibilities, and procedures for reimbursement, when applicable, are essen- tial to effective emergency response and recovery. Such agreements should include guidance on paratransit emergency operation protocols, cost/hour and cost/mile reimbursement rates, and detailed expectations for record keeping and documentation. Considerations ▪▪ Many paratransit agencies have unwritten or informal agreements with partner agencies and/ or emergency management regarding their roles and responsibilities in emergency situations. Steps to address insurance questions related to participating in emergency exer- cises, providing emergency customer transportation, or responding to community disasters include: ❑ If you are a stand-alone agency, set up a meeting with your insurance carrier to discuss the scope of coverage that your insurance policy provides. ❑ If you are a part of a larger entity such as a municipality, county, or non-profit organization, set up a meeting with the individual who manages the insur- ance coverage for that entity to discuss the scope of insurance coverage for paratransit assets. ❑ Request a letter from your insurance carrier or the larger entity with which you are affiliated that documents coverage of paratransit assets when used during emergency response activities. ❑ Meet with emergency management to discuss paratransit insurance coverage issues, including any limitations that may apply to your agency when partici- pating in community emergency response and recovery. ❑ If there are insurance limitations that preclude your agency from participating in emergency response activities, attempt to resolve them. This may involve blanket coverage that emergency management could extend to your agency for participating in community emergency exercises, as well as actual emer- gency response and recovery. Tool: Insurance Limitations

54 paratransit emergency preparedness and Operations handbook Such informal agreements can be a source of misunderstanding and conflict, resulting in less than optimal performance during emergency operations and negatively influencing future relationships between paratransit, partner agencies, emergency management, public safety organizations, and other key stakeholders. Informal agreements are more common in rural/ tribal operating environments than in urban/suburban environments. ▪▪ The probability of successful reimbursement for paratransit resources used to support com- munity emergency response is enhanced when paratransit providers, both urban/suburban and rural/tribal, proactively work with emergency management to develop written agree- ments regarding roles and responsibilities. Signed interagency agreements are frequently a requirement of eligibility for local, state, and/or federal disaster relief funds. ▪▪ Regardless of agency size or composition, it is recommended that legal counsel review inter- agency agreements. Effective Practices ▪▪ Several state and national organizations have published sample agreements that can be adapted for use by paratransit managers and emergency managers. ▪▪ Some jurisdictions that contract for paratransit service include contract language addressing emergency roles and responsibilities for their contractors. ▪▪ In the absence of specific contract language, some jurisdictions utilize MOUs, memoranda of agreement, or MAAs to address the paratransit contractor’s role in emergencies. Strategy ▪▪ A formal agreement with emergency management that defines your agency’s role in emer- gency response ensures there are no misunderstandings about the commitment your agency has to providing transportation services to customers while also taking part in community emergency response and recovery. ▪▪ Depending on your organizational structure, you may want to consider interagency agree- ments with other transportation entities, local emergency management, and essential con- tractor agencies. Interagency workshops can be an effective forum for negotiating such agreements. ▪▪ Have legal counsel review MOUs, MAAs, and interagency agreements before authorizing them. All agreements should include expectations for reimbursement of disaster-related costs. Tool: Paratransit/Emergency Management MOUs or MAAs Basics to include in an MOU or MAA between emergency management and paratransit include: ❑ Purpose of agreement ❑ Parties involved ❑ Goals/Mission ❑ Scope of use ❑ Understanding regarding mutual support to be provided ❑ Agreement regarding terms of compensation ❑ Authority over and responsibility for resources when activated ❑ Terms of agreement and periodic review ❑ Indemnification and hold harmless agreement ❑ Termination ❑ List of resources and key points of contact for all parties

prevention 55 Resources for Urban/Suburban Areas ▪▪ APTA/Public Transit Industry Mutual Aid Assistance Agreement http://bussafety.fta.dot.gov/show_resource.php?id=4136 APTA and its public transit members established a process whereby public transit systems and their geographic operating regions may receive and provide assistance in the form of personnel and equipment to aid in restoring and/or maintaining public transit or evacuation service when such service may be required. This Mutual Aid Assistance Agreement sets forth the terms and conditions to which the undersigned APTA member entity agrees to provide assistance. ▪▪ Draft Mutual Aid Agreement http://bussafety.fta.dot.gov/show_resource.php?id=4146 A template from Caltrans Transit Emergency Planning Guidance Technical Appendices for documenting the intention of a transit agency and local public safety agency/agencies to work together on a continuing and lasting basis toward maximum cooperation and mutual assistance in the areas of emergency preparedness and disaster response. Resources for Rural/Tribal Areas ▪▪ Basics to Include in an MOU http://bussafety.fta.dot.gov/show_resource.php?id=4113 This document from the Community Transportation Association of the Northwest (CTANW) website lists the basic issues to include in any MOU. ▪▪ Sample MOU Between Transit and Emergency Management http://bussafety.fta.dot.gov/show_resource.php?id=4114 This is an example of an MOU between a business and the local office of emergency man- agement, from the CTANW website. ▪▪ Sample Interagency Agreement MOU http://bussafety.fta.dot.gov/show_resource.php?id=4115 This is an example of an interagency agreement for emergency bus mobilization, from the CTANW website. ▪▪ Sample Commitment to Partnership MOU http://bussafety.fta.dot.gov/show_resource.php?id=4116 This is an example of a collaborative MOU to address transportation needs, from the CTANW website. ▪▪ Sample Mutual Aid Agreement http://bussafety.fta.dot.gov/show_resource.php?id=4117 This is an example of a public transportation emergency response MAA, from the CTANW website. ▪▪ Managing Requests for Transportation Assistance from Vulnerable Populations http://bussafety.fta.dot.gov/show_resource.php?id=4118 This is an example of a transportation annex appendix to a regional disaster plan for man- aging requests for transportation assistance from vulnerable populations, from the CTANW website. ▪▪ Best Practices—Special Needs Transportation Emergency Preparedness http://bussafety.fta.dot.gov/show_resource.php?id=4119 This document from the CTANW website presents important issues for transit systems to consider when working with regional emergency management and in developing transporta- tion MOUs addressing emergency preparedness. ▪▪ Sample Emergency Bus Mobilization Plan http://bussafety.fta.dot.gov/show_resource.php?id=4120 This sample plan from the CTANW website can be used to coordinate the mobilization of bus resources in support of emergency activities. This plan is usually a part of the ESF-1 Transportation function within a county comprehensive emergency management plan.

56 paratransit emergency preparedness and Operations handbook ▪▪ MOU for Vehicle Augmentation and Emergency Response http://bussafety.fta.dot.gov/show_resource.php?id=3943 This document outlines the agreement between Wiregrass Transit Authority and local emergency management to provide transit vehicles in the event of a community emergency. 4.C Education and Outreach 4.C.1 Customer Preparedness Emergency planning is everyone’s responsibility, including paratransit customers. Because people with disabilities and others with access and functional needs often have greater needs for support during emergencies, some argue that emergency planning is particularly critical for paratransit customers. Paratransit agencies are encouraged to conduct outreach regarding personal emergency preparedness and the impact that an emergency may have on regular para- transit service. Some paratransit agencies provide personal preparedness information to their customers as part of their ADA eligibility certification/recertification or otherwise; however, most do not. When paratransit customers are not prepared to shelter in place or evacuate in the face of a disaster, it is often paratransit that becomes the provider of last resort. It is incumbent upon paratransit, emergency management, and other agencies to provide good information about how to prepare for emergencies in general, as well as strategies for evacuating or sheltering in place. Considerations ▪▪ When urban/suburban and rural/tribal paratransit providers do not emphasize customer per- sonal preparedness, customers may have unrealistic expectations about paratransit assistance during community emergencies. ▪▪ In emergency events where advance notice is possible, customers may have a small window to assemble necessary supplies and develop appropriate response strategies. Many emergency response activities are hampered by customers’ poor preparation for evacuation, which puts the customer in jeopardy and distracts paratransit’s attention from its overall emergency response mission. ▪▪ Advance preparation is critical to ensure personal safety during no-notice emergencies. Effective Practices ▪▪ Some paratransit agencies provide free preparedness training to customers to help them understand their personal responsibilities during a disaster and the services they can expect from paratransit. ▪▪ Guidance documents on personal emergency preparedness are available from the American Red Cross, FEMA, and local emergency management. These materials are often available in accessible formats (braille, large print, discs, audio, etc.). ▪▪ Some paratransit agencies distribute basic preparedness kits. Strategy ▪▪ Providing paratransit customers with personal preparedness information and realistic expec- tations regarding what paratransit can and cannot do during emergencies may help keep cus- tomers safe and at the same time, alleviate some emergency response burden from paratransit. This is an opportunity to collaborate with social service agencies, public health agencies, and emergency management on effective outreach strategies.

prevention 57 Resources for Urban/Suburban and Rural/Tribal Areas ▪▪ Prepare Your Family for Disasters http://bussafety.fta.dot.gov/show_resource.php?id=4126 This three-page document from the American Red Cross and the Centers for Disease Con- trol provides information on advance preparations a family can make to cope with a disaster. ▪▪ Preparing for Disaster http://bussafety.fta.dot.gov/show_resource.php?id=4127 This booklet from FEMA and the American Red Cross provides steps on how families can be prepared to cope with disaster—get informed, make a plan, assemble a kit, and maintain the plan and kit. ▪▪ Be Red Cross ready. Get a kit. Make a plan. Be informed http://bussafety.fta.dot.gov/show_resource.php?id=4129 This informational one-page brochure from the American Red Cross provides a checklist of things families can do to be prepared for disasters and other emergencies. ▪▪ Disaster Preparedness for Those with Special Needs http://bussafety.fta.dot.gov/show_resource.php?id=4140 This excerpt from the Florida Agency on Aging of Pasco-Pinellas, Inc. website provides information on preparing in advance for a disaster and is intended especially for people who have special needs or are caring for someone with special needs. 4.C.2 Adaptive Equipment When people with disabilities are evacuated without their wheelchairs, oxygen, or other adap- tive equipment, they lose their independence and become an added burden on the emergency response system. Paratransit emergency plans must account for this fact. Additionally, your paratransit agency should work with its local emergency managers to help them understand the kinds of adaptive equipment your customers may need in shelters or other evacuation facilities. Tool: Customer Preparedness Shelter-in-place planning: ❑ Sufficient food and water stores for a week ❑ Prescription drugs for at least one week ❑ Backup systems for heating and cooking ❑ Backup power supply for critical systems such as powered wheelchairs and oxygen collectors ❑ Backup systems for sanitation Evacuation planning: ❑ Go kit for home and workplace including: – Sufficient food and water stores for three days – Prescription drugs for at least three days – Essential adaptive equipment – Personal identification and essential documents – Power chargers for critical systems such as powered wheelchairs and oxygen collectors – Cash in small bills ❑ Personal preparedness plans should account for the needs of loved ones and pets and should include a family reunification plan.

58 paratransit emergency preparedness and Operations handbook Sharing statistics about the types of customers paratransit serves also helps emergency manage- ment with its emergency planning assumptions. When possible and practical, your paratransit agency should encourage emergency management to work with disability care providers to bet- ter understand the kinds of equipment that people with disabilities need to take with them when required to vacate their homes for an extended period of time. Considerations ▪▪ Lack of information regarding the adaptive equipment needs of evacuees can result in para- transit providers, whether urban/suburban or rural/tribal, being deployed to transport evacu- ees with equipment that paratransit is unable or unqualified to transport. ▪▪ Due to size and scope of operations, paratransit agencies in rural/tribal environments are often more familiar with the particular needs of the customers they serve including the adap- tive equipment they require. Effective Practices ▪▪ Close coordination between paratransit providers, customers, partner agencies, emergency management, emergency medical responders, and other key stakeholders results in better systems for dispatching the most appropriate transportation resource capable of serving the evacuee and accommodating his or her needed adaptive equipment. Strategy ▪▪ It is essential to transport adaptive equipment with evacuees. Train all paratransit drivers that may operate vehicles during an emergency response on handling and securing adaptive equip- ment. When appropriate, drivers should also be encouraged to question evacuees on whether they are bringing sufficient supplies of prescription medications, oxygen, and other essentials to last them for several days. Tool: Adaptive Equipment Examples of adaptive equipment: ❑ Orthotics/prosthetics ❑ Manual or motorized wheelchair ❑ Scooter, Segway, walker, cane, or other mobility device ❑ Electronic speech aids ❑ Seating and/or positioning aids ❑ Portable oxygen tanks ❑ Oxygen concentrator ❑ Suction and breathing equipment ❑ Apnea monitor ❑ Commode chair ❑ Halter monitors for heart conditions Resource for Urban/Suburban and Rural/Tribal Areas ▪▪ Congregate and Residential Care Facilities http://bussafety.fta.dot.gov/show_resource.php?id=4166 Chapter 6 of FHWA’s “Evacuating Populations with Special Needs” discusses the transporta- tion accommodations necessary for evacuating CRCF and the associated adaptive equipment.