Practices in Airport Emergency Plans (2021)

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4 Introduction Background The processes and practices airports use to update and enhance their airport emergency plans (AEPs) vary because of a number of factors. The factors include threat and hazard iden- tification and risk analysis (which establishes the need for in-depth all-hazards planning and plan development processes), political and executive leadership priorities, the ability to engage with partner agencies and jurisdictions, staff experience and availability, regulatory require- ments, and incidents that provide real-world experiences that lead to enhancements. Airports are required to follow Code of Federal Regulations, title 14, part 139 (14 CFR, part 139), requirements for being a certificated airport while also abiding by the requirements set forth in 14 CFR, part 139.325, to have an AEP. Federal Aviation Administration (FAA) Advisory Circular (AC) 150/5200-31C provides guidance for preparing and planning for the new environment of modern threats, but guidance is 10 years old and may lack nuance for planning for new and modern threats. The AC 150/5200-31C and 14 CFR, part 139.325, have been described by respondents of this synthesis report as overly prescriptive, cumbersome, rigid, and inflexible. Many have opted to maintain AEPs to the regulation standard, then focus on development, training, and exercise of additional all-hazards plans. These bifurcated practices are described throughout this synthesis. Traditional emergency management (EM) practices are being incorporated into airport programs, placing importance on gap and threat assessments, regular training and exercise programs, and a formal improvement planning process. Collaboration with internal and external stakeholders has been of particular importance, with emphasis placed on building relationships, educating partners, and cross-walking plans with the AEP. Throughout this synthesis many scientific, aviation, and EM terms, acronyms, and abbre- viations are used. At the end of this synthesis are the definitions of these items. They should be referred to often to enhance understanding of the report, interpretation of the results, and major findings. The report indicates that airport personnel in the course of their AEP practices may identify gaps the AEP simply does not cover. Therefore, they may want to enhance the AEP through developing other functional annexes and/or standalone plans. They may also choose to conduct specific practices that lead toward development of more inclusive, robust plans by using a comprehensive planning process, establishing specific processes for updating the AEP, and identifying needs through gap analyses. However, many personnel do not have the time or the experience to understand what can or cannot be done with the AEP and how best to C H A P T E R 1

Introduction 5 go about closing the identified gaps. The AEP process (i.e., reviewing, updating, sharing, and exercising the AEP) is often assigned to personnel as an “other duty as assigned,” on top of their already heavy workload. Therefore, the purpose of this synthesis is to document and describe current practices and challenges airports face when developing, revising, and using their AEPs for emergency response and recovery activities. This includes use of their current AEPs in an operational environment, practices for updating the plans to ensure relevancy, and determining when to enhance the AEP with supporting annexes or separate all-hazards plans. Ultimately, this synthesis offers and high- lights successful practices as well as lessons learned from airports as AEPs are updated and refined to create useful and actionable documents. For this synthesis, “successful practice” is defined as a tech- nique or methodology that, through experience and research, has proven to reliably lead to a desired result. “Lessons learned” is defined as learning gained from the process of performing the activity (i.e., exercising or responding to incidents and events). The purpose of documenting lessons learned is to share and use knowledge derived from experience to promote the recurrence of desirable outcomes and/or preclude the recurrence of undesirable outcomes. Study Methodology The objectives of the synthesis were (1) to identify the issues, challenges, and work-arounds experienced by airport managers with AEPs as useful and actionable documents; and (2) to understand FAA inspectors’ perspective with how AEPs ameliorate risks and guide emergency response actions. The audience for this report is the airport community, FAA, and stakeholders. As a result of difficulties connecting with the FAA, the synthesis team was unable to achieve and complete the second objective. Further information about this is provided below in the section titled Selection of Airports and Data Collection. Literature Review For the literature review, the authors used keywords to identify relevant literature for this synthesis. Keywords included “transportation emergency plan,” “airport emergency plan,” “business continuity plan,” “continuity of operations,” and “irregular operations (IROPS).” The literature reviewed can be found in Appendix B: Annotated Bibliography. There is little written about AEP practices. An article by Kraus, Plos, and Vittek (2014) does identify that Airport emergency planning is a very important element in ensuring the safety and security of air transport. Airport emergency planning will therefore get more and more attention, because even a small event will have a great impact on the finances of the airport operator. From the perspective of manage- ment of financial resources, the airport operator would be constantly more inclined to creating and improving the airport emergency plan (AEP). The article gives a broad overview of mistakes made by airport operators as well as success- ful practices in revising the AEP without commenting on the logistical considerations of Firefighters approach a small aircraft, Centennial Airport (APA)

6 Practices in Airport Emergency Plans actionable steps or subgoals. Although this article focuses on non–U.S. airports, the themes identified are similar to what has been identified in the data for this synthesis. Primarily, the literature suggests that the AEP is problematic because it is often created and maintained simply because it is a requirement and regulation. Other available peer-reviewed articles outline the need for special attention to be paid to protected classes and abnormal operation risks and hazards in addition to normal operations. Protected classes include race, color, religion or creed, national origin or ancestry, sex, age, physical or mental disability, veteran status, genetic information, and citizenship. The literature also indicated EM programs, services, and activities should be accessible to everyone, including people with disabilities as defined by the Americans with Disabilities Act of 1990 (ADA) and the Americans with Disabilities Act Amendments Act. The literature review uncovered a sample of possible annexes that can complement AEPs, including the following: • ACRP Synthesis 60: Airport Emergency Post-Event Recovery Practices (Smith et al. 2015) • ACRP Research Report 171: Establishing a Coordinated Local Family Assistance Program for Airports (National Academies of Sciences, Engineering, and Medicine 2017) • ACRP Research Report 201: Airport Emergency Communications for People with Disabilities and Others with Access and Functional Needs and ACRP Synthesis 73: Emergency Communications Planning for Airports (IEM, Inc. 2019 and Smith et al. 2016) • Airport Terminal Incident Response – Terminal Incident Response Plan (TIRP) (National Academies of Sciences, Engineering, and Medicine 2009) • Protected and nontraditional class considerations (ADA, DAFN, and patrons with mental health needs) (Anderson 1988; IEM, Inc. 2019; and National Academies of Sciences, Engi- neering, and Medicine 2016) • ACRP Report 12: An Airport Guide for Regional Emergency Planning for CBRNE Events (Stambaugh et al. 2009) • ACRP Report 160: Addressing Significant Weather Impacts on Airports: Quick Start Guide and Toolkit (ICF International et al. 2016) • Contingency Planning for Unexpected Passenger Delays (National Academies of Sciences, Engineering, and Medicine, April 2013) Small- and nonhub or GA airports may have other considerations outside of the scope of hub airports. These considerations can include GA size, complexity, operations, personnel, facilities, geography, and types of aircraft served. The authors identified Emergency Guidebook for General Aviation Airports: A Guidebook for Municipal Airport Managers (2005–2020) as a resource for GA airports looking to develop an AEP. In other sources reviewed, the authors of ACRP Synthesis 72 (Smith et al. 2016) explain that the development of a “checklist is designed to assist airport managers, EMs, and planners in the development, implementation, and evalu- ation of effective exercise programs . . . [with the added] benefits from going beyond regulatory minima for training and exercises.” Lastly, previous reports and syntheses by the ACRP also informed this synthesis. A review of the ACRP Final Report for Project 04-19, Airport Emergency Planning Template: NIMS–Incident Command System Compliance (Corzine et al. 2018), provides further insight into AEP practices by the 20 airports interviewed during that project. In the Project 04-19 report, the interviews summary revealed that changes were experienced as a result of the 2009 update to the AC, specifically to the airports’ safety, security, and EM cultures. However, these changes were dependent on availability of resources and airport size. Not unique to the Project 04-19 report, and as synthesized here, some airports reported that they do not add information to their AEPs beyond what is required by regulation, thereby becoming “as much a compliance exercise as an effort to improve fundamental emergency readiness.” Because the FAA was unable to provide

Introduction 7 input or comment into this synthesis, the synthesis team considered information provided by the FAA to Project 04-19 as included in the Final Project Report. As stated in the Project 04-19 Final Report, “The FAA recognized that there is a wide variance in knowledge, experience and capability between larger, well-staffed emergency management teams at larger airports on the one hand, and smaller Index A and B airports on the other that may not be as well staffed and funded, in their relative ability to develop AEPs.” Synthesis Organization The synthesis is organized into six chapters. This first chapter is the introduction to the synthesis. Chapter 2 provides relevant background and history about AEPs and federal regula- tions, and Chapter 3 discusses current AEP practices, as synthesized from the respondent data. Chapter 4 includes the case examples highlighting specific AEP practices by airports around the country. Chapter 5 provides salient findings from the respondent data, to include successful practices, lessons learned, and enduring challenges as they relate to AEP practices. Chapter 6 provides the conclusions of the synthesis. The references, bibliography, further case example reference information, and survey data can be found in the supporting appendices. The glossary of terms, along with the abbreviations and acronyms found at the end of this report, will help provide context or define words, acronyms, or terms that may be new or unknown to the reader. Selection of Airports and Data Collection The authors gathered data and input from respondents, specific to AEP practices, that can effectively be applied to other airports, including GA airports, whether required to maintain an AEP or not. The data was gathered through a review of relevant literature on the topic; an in-person plenary panel discussion at the AAAE International Airport Emergency Management Conference on July 16, 2019, in Chicago, Illinois, with 175 attendees; an online survey using SurveyMonkey provided to 81 airport representatives from 62 airports (26 large-hub, eight medium-hub, 13 small-hub, three nonhub primary, six nonhub GA, and six nonhub reliever) with a response rate of 45 airports or 72.58%; and seven 45-minute phone interviews with airports (five large-hub and two GA). For the purpose of this study, airports of varying cate- gories, as defined by the NPIAS, were included and afforded the opportunity to respond to survey questions about their AEP practices, as well as an opportunity to speak further with the synthesis team about these practices. During the first opportunity for data capture, the 45-minute AAAE International Airport Emergency Management Conference plenary session, “Preparedness, Response, and Recovery,” the audience was asked about their AEP practices and the challenges they experienced when updating and/or developing their AEPs, supporting annexes, or other supporting plans. Comments captured during this plenary session are included in this synthesis in Chapter 3. On August 15, 2019, approximately 3 weeks following the conference plenary session, the second opportunity for data capture was sent to airport representatives. This outreach included an online survey using SurveyMonkey that was sent to airport representatives and FAA Inspectors through FAA representatives. A total of 45 respondents participated in the survey, which was available for response for 60 days. The survey averaged approximately 25 minutes, with 44 required questions, four non- required additional questions, and 29 nonrequired demographic questions, for a total of 77 questions. Once the required section of the survey was complete, respondents were provided

8 Practices in Airport Emergency Plans the option to answer further, in-depth questions or to complete and finish the survey. Respondents completed the entire survey, including follow-on questions, in approximately 40 minutes. A total of 31% of respondents chose to continue the survey beyond the required questions and answer the additional questions. Following the online-survey open period, respondents were provided an opportunity to speak with the authors through a phone interview if they indicated in the online survey that they wanted to be contacted to provide in-depth information about their AEP practices. A total of eight respondents indicated they wanted to be contacted for follow-up. The synthesis team was able to conduct phone interviews with five of those respondents (three did not respond to requests for further follow-up). The team also interviewed two GA airports who did not participate in the initial survey. During the phone interviews, airports were asked the same eight questions about their AEP practices (these questions can be found in Appendix D). Through the interview process, successful practices and lessons learned have been fleshed out and synthesized into case examples. Those airports have also been included in Chapter 4, Case Examples, about their innovative AEP practices. FAA Inspector Survey For this synthesis, the synthesis team attempted to gather information from FAA inspectors. An FAA representative used an official memo and specific survey link to provide to FAA inspectors. The memo was provided to the FAA Union for the FAA inspectors and distributed accordingly. FAA inspectors were informed the survey was anonymous and included five FAA-specific questions to answer. During the 2 months the survey was open and available, the synthesis team received no responses. Following the survey and during development of the synthesis, the FAA was contacted and provided with the synthesis for review and comment. One of the objectives of this synthesis is to “understand FAA inspectors’ perspective with how AEPs ameliorate risks and guide emergency response actions.” Because of the lack of data, the synthesis team was unable to achieve and complete this objective. Collection of Data: SurveyMonkey Data collection was completed using the program SurveyMonkey in which a survey was created based on institutional knowledge of AEPs and recommendations by the project panel. The survey was designed to request honest and open feedback. The sample was taken from large-, medium-, and small-hub airports, as well as nonhub primary, reliever, and GA airports. The survey encouraged anonymity based on the sensitivity of the topic, while also allowing participants to be interviewed and responses attributed later if their identifying information was given. Defining Stakeholders Throughout the synthesis, many groups are considered to be “stakeholders” that inform, influence, or need to support the AEP and practices. Stakeholders can include, but are not limited to, the following: • Airport operators and staff who are directly employed by the airport • Airlines and staff • Tenants and staff • Local, state, and federal government agencies—government, EM, medical examiner, or regulatory • First responders who have roles and responsibilities for an emergency at or with the airport

Introduction 9 • Nongovernmental organizations (NGOs) such as the American Red Cross • Private organizations that may support the airport and/or airline (roles and responsibilities) during an emergency or event (contracted staff ) Successful Practices Throughout the synthesis, the synthesis team uses the term “successful practices.” This term is used to clarify that through the literature review, plenary session, online survey, and phone interviews, multiple practices have been identified by the respondents that proved successful for them, at their airport, as they navigated updating AEPs and developing other types of annexes or plans. Therefore, the synthesis team recognizes that these practices were successful for that airport. The synthesis team has thus synthesized that information and presents it here, should it be of use for other airports. The synthesis team defines successful practice as a technique or methodology that, through experience and research, has proved to reliably lead to a desired result.