Incorporating ADA and Functional Needs in Emergency Exercises (2018)

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8 Scope of Synthesis The objective of this research is to compile existing resources, experiences, and effective prac- tices from airports conducting emergency exercises that consider the DAFN community, with emphasis on collaboration with persons with disabilities and their representatives. The audience for this synthesis of practice is airport stakeholders such as airport personnel, airline partners, tenants, and responders. As specified in the final scope statement developed by the ACRP Project 11-03/Topic S04-19 panel (the panel) guiding this project, the research shall include a literature review of existing documents and data collection (survey and/or interviews) from airport operators who conduct emergency exercises with participation of the DAFN community. Also, the research will collect data on practices from a range of airports based on geographic location, size classification, and governance. Data collection will include the following, at minimum: • Identification of known industry leaders and their programs • Definition of the DAFN population and how airports define their community for emergency exercises • How airports do or can find community resources to assist in developing an inclusive program C H A P T E R 2 Method Source: Lawrence Rolon. Participant in exercise at Los Angeles International Airport.

Method 9 • Current practices and strategies nationally and internationally for including persons with disabilities, service animals, and specialized equipment and supplies in emergency exercises • Description of effective airport emergency exercise programs, including any tools, templates, and participants on the exercise planning team • Exercise participants, roles, and responsibilities • Logistics, processes, and tools necessary when including the DAFN community • Creatively overcoming limited resources (costs, funding sources, lack of buy-in, leveraging resources) • Challenges and work-arounds • Gaps and further research • Examples of exercise materials such as checklists, templates, planning elements, hazard iden- tification and risk assessment tools, evaluation criteria, after action reports, and other relevant tools and considerations The product of the research will be a concise report and appendices that include tools for incorporating ADA considerations into emergency exercises. Method Early on, it was determined that an online survey would not be used for this research effort. Fully realized exercise programs incorporating DAFN concerns were too rare to find a random survey. With suggestions from the panel, the research team sought suitable case examples to interview in a purposive sample. Based on a preliminary literature review, direct contacts with candidate airports and other organizations, and discussions with experts in the field, 31 candidate airports, 9 candidate airlines, 4 other entities, and the attendees at the 2017 AAAE Emergency Management Annual Conference were identified as potentially meeting the criteria and were contacted by telephone or email. A questionnaire (Appendix A) was provided to each entity, the interview was conducted, and the draft write-up of the case example was provided for review and correction. The questionnaire was aimed at airports and was adapted in minor ways to accommodate airlines and other non- airport organizations. Appendix A can be found on the TRB website (www.trb.org) by searching for “ACRP Synthesis 90.” Of the 45 total entities approached by the research team, interviews with 30 (67%) were completed. Five entities (11%) declined for various reasons. Ten entities (22%) did not respond to repeated contacts via email and telephone. Table 1 shows participation by type of entity. Type Requested Interviewed Declined No Response Airports 31 23 (74%) 2 (6%) 6 (19%) Airlines 9 3 (33%) 3 (33%) 3 (33%) Others 5 4 (80%) 0 (0%) 1 (20%) Total 45 30 (67%) 5 (11%) 10 (22%) (Smith and Haines data 2017) Table 1. Responses to interview requests.

10 Incorporating ADA and Functional Needs in Emergency Exercises Appendix B lists the airports, airlines, and other organizations that were interviewed. This appendix can be found on the TRB website (www.trb.org) by searching for “ACRP Synthesis 90.” The synthesis was restricted to airports with scheduled passenger service (Part 139 airports in U.S. terminology). Non-U.S. airports were classified by size by comparing their total passengers (2016) divided by two with the FAA enplanement data for 2016 (FAA 2017). Figure 1 shows the size distribution of the airports. Data from the interviews have been anonymized and aggregated. Where information from a specific airport, airline, or other type of organization is given, the source gave explicit permission. Data Analysis and Presentation Demographic and other background data are included in this chapter. Qualitative (thematic content) methods are the main analytical tool used. Data pertaining to emergency planning and exercises that were gathered in the 30 interviews are presented in Chapter 3. The non-random nature of the samples and the relatively small sample sizes prevented the application of quantita- tive analytical methods other than determining percentages of respondents in certain categories of answers (descriptive analysis). Interviews were sought from nine airlines: three gave interviews, three declined, and three never responded. Demographic and Other Background Data How does your organization define the DAFN community? Through the interviews, the airports’ definitions of the DAFN community were found to fall into four general groups: 1. The legal definition in the ADA (“the ADA definition”) 2. The ADA definition plus the FEMA definition, which adds temporary access and functional needs (“the PKEMRA definition”) 3. Anyone who needs assistance (“the Israeli definition” but not limited to Israel) 4. Anyone who requests assistance (“the E.C. definition” but not limited to the EU) Non-Hub Primary 13% 22% 48% Small Hub Large Hub 17% Medium Hub Figure 1. Size of airports in the synthesis (Smith and Haines data 2017).

Method 11 Of the 23 airports in the synthesis, 8 answered that they use the ADA definition, 3 use the ADA+FEMA definition, 11 use the “anyone who needs assistance” definition, and 1 uses the “anyone who requests assistance” definition. The sorting is complicated by local ordinances and agreements that came out of the ADA lawsuits against cities in 2010–2013, but it shows the current pattern. Clearly, the “anyone who needs assistance” cate gory includes compliance with ADA and FEMA requirements. Several airports go beyond these requirements in differing ways. The two “anyone who” categories differ in who bears the responsibility for initiating assistance: one puts the burden on the airport, airline, or disabilities services contractor to identify and assist whereas the other puts the responsibility on the traveler. The three airlines each reported using a different definition: the ADA definition; the ACAA definition; and the Australian national definition that is identical to the ADA definition. However, in practice, Virgin Australia uses the EU definition that extends assistance to anyone who requests it. What position title in your organization has the primary responsibility for managing and working with your DAFN community? All 19 U.S. airports have a designated ADA coordinator, either as a primary duty or a major collateral duty, and the 4 non-U.S. airports have the function but use different terminology. Four airports emphasized that part of their culture or customer service philosophy is that all airport employees are expected to ensure ADA compliance or assist DAFN persons. One airport uses the ADA coordinator in its city’s human resources department. The ADA coordinator posi- tion may be attached to various airport departments: executive director; operations; facilities and engineering; communications; emergency management; customer service/guest experience; and innovation and business development. The three airlines assign this responsibility to different parts of their organizations: the Man- ager of DOT Compliance and Small Claims, the Corporate Customer Service Manager in the Office of the CEO, and Customer Advocacy. What other staff positions are trained in DAFN support or assistance? As is expected for an open-ended question such as this one, responses to this question varied widely in depth and breadth. Some airports described their overall training program and efforts to include airlines, tenants, agencies, and concessionaires while other airports listed one or two other department heads that play significant roles in caring for DAFN persons. Five airports reported training all airport employees to assist DAFN passengers. Responses from the other 18 airports fell into five main clusters, with some airports falling into two or more of the clusters. The specific groups receiving training for disabilities in emergencies are shown in Figure 2. In discussions triggered by this question, several airports indicated that they find it difficult to engage airlines and other tenants significantly in DAFN training. This is particularly important in U.S. airports where the wheelchair concessionaires work under contract to the airlines and are trained and supervised by the airlines, not by the airports. Even in cases where the airport sets a standard of customer service, the airport depends on airlines to get compliance from the service providers. The question asked what other persons receive special training for supporting or assisting DAFN passengers, but it can also be viewed as a proxy for what groups can usefully be included in an airport’s planning efforts to deal with issues affecting DAFN passengers during emergency response and recovery. No clear relationship is evident between airport size and the DAFN definition an airport practices.

12 Incorporating ADA and Functional Needs in Emergency Exercises The airlines reported training their station managers, gate agents, ramp agents, and complaint resolution officers. Approximately how many total persons (employees, tenants, customers, clients) are in your facility during peak times? Of the 23 airports, 20 gave estimates of the total number of persons in their facilities at a single time (Table 2), with the estimates ranging from 100 to 60,000 for total passengers, airport employees, airline employees, agency employees, tenants, concessionaires, and visitors at peak normal operations. The number during irregular operations (IROPS) could be double or triple these numbers. These estimates represent how many persons need to be protected during emergency response and recovery operations, and need to be considered in designing all-hazard emergency exercises as well. The estimated number of DAFN persons in each airport at peak time depends on what percentage is applied, and there is considerable uncertainty in this percentage. If one looks at the number of passengers who request assistance, the range goes from 0.07% of all passen- gers (Airports Council International Europe [ACI Europe] estimate of number of passengers requesting assistance) to 20% to 30% of passengers (estimates by three U.S. airports in retire- ment areas). If one looks at the percentage of the U.S. population that has a disability, the two most prominent values are 12.6% (Rehabilitation Research and Training Center on Disability Statistics and Demographics 2016) and nearly 19% (U.S. Census Bureau 2012). As noted in the interview for Manchester International Airport, relatively fewer persons with disabilities travel by air than does the general population. In any case, any airport is likely to have a significant number of persons who need special assistance in an emergency. This directly affects persons needing assistance but it also affects overall emergency response and recovery actions. Figure 2. Airport employee groups receiving training for DAFN support or assistance. <1,000 1,000-5,000 5,001-10,000 10,001-25,000 >25,000 5 airports 4 airports 4 airports 4 airports 3 airports (Smith and Haines data 2017) Table 2. Estimate of total persons in airport facilities at peak time.

Method 13 Do you have specific programs designed to assist the different categories of disability and access or functional needs? Answers for this question were either about specific events or about systems. Two airports discussed how they prepare for major commu- nity conventions that are sponsored by disabilities groups, noting that working with the event organizers to prepare for the transit of partici- pants through the airport had led to upgrading of emergency plans and exercises. The second main type of event described was special days for families with autistic members—10 airports reported having such programs noting that these efforts were most often led by an airline. In all cases, the airport and airline worked together so that the entire airport experience from curb to plane was included. Although autism is a cognitive disability getting attention at airports, other forms of cog- nitive disabilities such as dementia, Alzheimer’s, and developmental disabilities are getting far less attention. Specific systems cataloged by airports in the synthesis focused on traditional disabilities: 1. Visual impairment, such as auditory paging, raised letter and Braille signage, escort services 2. Hearing impairment, especially visual paging and video relay interpretation 3. Cognitive disabilities 4. Mobility impairment, such as wheelchairs, carts, trolleys, stairchairs, skeds, and aviramps In addition, many of the airports described recent improvements to their service animal relief areas. Many of the 23 airports described expanded and expanding efforts to train employees and other stakeholders on the effective use of these tools and systems. A few of the airports emphasized their outreach efforts to inform passengers, DAFN organizations, and the general community about the availability and capabilities of such tools and systems. One of the airlines reported having specific products to cater to specific disabilities. Another airline described its Complaint Resolution Officials who are available to answer questions from DAFN passengers. Wings for Autism®/Wings for All® are airport “rehearsals” specially designed for individuals with autism spectrum disorders and individuals with intellectual/ developmental disabilities. The programs are designed to alleviate the stress that families who have a child with autism or intellectual/developmental disabilities experience when flying. It provides families the opportunity to practice entering the airport, obtain boarding passes, go through security, and board a plane. Source: Minneapolis–St. Paul International Airport/Metropolitan Airports Commission. Participant in exercise at Minneapolis-Saint Paul International Airport.