Airport Terminal Incident Response Planning (2014)

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18 The passenger terminal is likely the single area of every commercial airport where all required programs and plans apply: the airport certification manual (ACM), the AEP (part of the ACM), the airport security program (ASP), and increasingly, IROPS plans and safety management systems (SMSs). Some airports also have customer service manuals or terminal manuals that may apply. Airport Certification Manual The ACM must address all Federal Aviation Regulation (FAR) Part 139 requirements that apply to the airport. It must be accurate, clear, direct, and state who will perform each required task (FAA Advisory Circular 150/5210-22, 2004). The AEP is always required as part of the ACM. Airport Emergency Plan The AEP details a list of probable incident types that apply to the whole airport, including the terminal. However, the emphasis is usually more on the air operations area (AOA) than on the ter- minal. The only part of most airports’ AEPs that specifically pertains to a terminal is the structural fire annex, and that annex also pertains to any other type of building at the airport. An effective AEP includes specific actions and responsibilities in the terminals and makes appropriate distinc- tions due to the presence of passengers. Airport Security Program Under 49 CFR 1542, every airport is required to have an ASP. Implementation of the ASP means that the TSA and airport security personnel have a constant and powerful presence in the terminal. The security requirements of the ASP must be met during normal opera- tions and during implementation of a TIRP. Security becomes especially important during repopulation since the secure areas of a terminal may have to be re-sterilized. (This will almost always be the case after an evacuation.) The airport’s ASP delineates specific security protocols and approvals that must be accomplished after any event that potentially compromises the security posture of the airport. The requirements of the ASP and any additional appropriate security countermeasures must be completed prior to resuming passenger flight operations. This usually requires effective communication and collaboration between the airport security coordinator (ASC) and TSA’s federal security director (FSD). Consensus approval between the ASC and the FSD or their designees must be obtained prior to resuming passenger flight operations. C H A P T E R 5 Relationship of Terminal Incident Response Plans and Other Plans and Programs

Relationship of Terminal Incident Response Plans and Other Plans and Programs 19 Irregular Operations Since the publication of ACRP Report 65: Guidebook for Airport Irregular Operations (IROPS) Contingency Planning (Nash et al., 2012), many Part 139 airports have completed IROPS plans, and most airports are expected to complete them within the next few years. IROPS plans focus on how an airport should manage customer service during periods of irregular operations caused by storms or other events. Terminal management is an important element of IROPS response, so TIRPs should conform to IROPs plans either by reference or by providing supplemental information. Safety Management Systems All airport-related plans and procedures should be well integrated so as to easily incorporate the four components of a well-developed SMS: 1. Safety policy. 2. Safety risk management. 3. Safety assurance. 4. Safety promotion. As of spring 2013, few airports had SMS plans. However, SMS plans may well be required at Part 139 certificated airports within a couple of years of the publication of the TIRP tool and user’s guide. Each airport will need to revise its evacuation, SIP, and repopulation plans to the extent that such plans trigger SMS issues. It is not clear to what extent, if any, SMSs will apply to airport terminals. Access and Functional Needs Populations Airports must comply with the requirements of the Americans with Disabilities Act (ADA) for normal operations. Such compliance must extend fully to emergency operations such as sheltering in place and evacuation. Accommodations for access and functional needs—mobility, visual impairments, hearing impairments, and other issues—must be incorporated into TIRPs. Beyond ADA requirements, airports should consider other issues typically related to older trav- elers, children, and international travelers with limited English language skills. ACRP Synthesis 51: Impacts of Aging Travelers on Airports (Mein, Kirchhoff, and Fangen, 2014) addresses how airports can best accommodate the needs of aging travelers. Terminal Operations Manuals Some airports have terminal operations manuals. Incorporation of TIRPs into such manuals should be considered. Customer Service Manuals Although most airports focus primarily on the safety and efficiency of operations, a few airports approach those same imperatives through the perspective of customer service. This approach was evident at four airports where customer service manuals specified the standards for customer service across the full spectrum of situations, from low-tempo normal operations to high-tempo operations to IROPs and emergencies, including evacuation and shelter-in-place

20 Airport Terminal Incident Response Planning situations. In the case of the Port Authority of New York and New Jersey, the customer service manual sets standards for all contractors and concessionaires with regards to customer service, including their roles and responsibilities in emergencies. Overlap Areas of plans that overlap should include triggers that alert managers to the need to revise other plans if one plan is altered since plans must be congruent to prevent confusion during a disruptive incident. Tool developers made a conscientious effort to avoid the generation of TIRPs that contradict airports’ AEPs, ASPs, or other plans. Methods of Presenting TIRPs vis-à-vis AEPs Airports employ a number of different approaches to present their TIRPs (evacuations, SIP, and repopulation) vis-à-vis their airport emergency plans. In Table 7, options actually observed from collected documents or in follow-up interviews are indicated by “A.” Options that are theoretically possible but were not observed among the 42 airports are indicated by “T.” Finally, options that would violate Part 139 requirements are indicated by “V.” Option Evacuation SIP Repopulation 1. Incorporate TIRP sections into AEP. A A T 2. Distribute pertinent parts of evacuation and/or SIP plans into hazard-specific annexes of AEP. T A T 3. Maintain TIRPs as separate plans incorporated by reference into AEP. A A A 4. Include evacuation, SIP, and repopulation in terminal management plan or manual entirely separate from AEP. T T T 5. Include evacuation, SIP, and repopulation plan(s) in customer service manual entirely separate from AEP. A A A 6. Include evacuation, SIP, and repopulation plans in tenant contracts but not directly in or referenced in AEP. V V V 7. Include evacuation, SIP, and repopulation plans in the ACM but not in the AEP. V V V 8. Plans reside in plans or standard operating procedures (SOPs) of outside agencies such as police or fire department attached to airport and are incorporated by reference into AEP. T T T 9. Plans reside in plans or SOPs of outside agencies such as police or fire department attached to airport and are not incorporated by reference into AEP. V V V 10. Include evacuation, SIP, and repopulation plans in airport business continuity plan but not in AEP directly or by reference. V T T 11. Unwritten plan(s) only. V V V Note: A = options actually observed, T = theoretically possible but not observed, V = would violate Part 139 requirements. Table 7. Options for AEPs and TIRPs.

Relationship of Terminal Incident Response Plans and Other Plans and Programs 21 Options 1 through 8 merit further discussion. Options 9 and 10 can be eliminated because no airport should knowingly adopt a plan or course of action that will create a problem with certification. Option 1 has the virtue of gathering all of the elements in one place, with that one place (the AEP) being one of the most frequently reviewed documents at any airport. The challenge with adding TIRPs to an AEP is that each page of the AEP and each change to an AEP must be approved by the FAA compliance inspector. Since terminal configurations change relatively often, the TIRPs likely will be revised or amended frequently. This will leave the AEP in a form of limbo while await- ing the FAA compliance inspector’s approval on the changes. Option 2 also presents this challenge, while Option 3 avoids it. A second issue of concern with Options 1, 2, and 3 is that the requirements of Part 139 and FAA Advisory Circular 150/5200-31C can be ambiguous about which sorts of incidents affecting a ter- minal are required for inclusion in an AEP. Nothing in the advisory circular precludes including preparedness and response actions inside terminals in an AEP, but many of the incidents that do not create problems for aircraft or the AOA typically are not included in AEPs. Option 2 has considerable merit as it lists the full details of response and recovery for each haz- ard type in the section of the AEP dealing with that hazard. The TIRP tool can generate hazard- specific plans suitable for incorporation into the AEP annexes. The major downside of Option 2 is that it increases the number of documents and related materials that would need revision if the airport’s structural configuration, policies, or other guidance changes. Option 4 (terminal management manual/plan) and Option 5 (customer service manual) are nearly identical functionally. The primary difference between the two seems to be that the terminal management manual is prescriptive, operating outward from the airport toward all other stakeholders, while the customer service manual seems more multilateral, encompass- ing all stakeholders resident in the terminal. [This is a tentative conclusion since the study received only two customer service manuals (Port Authority of New York and New Jersey, 2008) and no documents labeled as terminal management manuals.] Options 4 and 5 may leave gaps in the AEP unless care is taken to articulate the essential parts between them and the AEP. Under Option 4 or 5, the plans should be referenced in the AEP to avoid violation of Part 139 requirements. Option 6 is a sound management tool, but it is not sufficient to stand alone. Contracts can define the roles of non-airport employees and stakeholders in terminal incident responses, but contracts are an awkward method of informing airport employees of specific actions they need to take in an actual response. Therefore, Option 6, if adopted, should be paired with one of Options 1 through 5. Failure to link the contract’s approach to the AEP would put the airport in violation of certification requirements. Option 7, incorporating the evacuation, SIP, and repopulation plans into the ACM but not as part of the AEP portion of the ACM, is an unusual approach. It is not clear that there is any appropriate place in the ACM outside the AEP to attach TIRPs. Option 8 is almost the same as Option 3. They would be identical if the reciprocal agreements between the airport and the response service provider required those plans to be incorporated into the AEP by reference and included ironclad notification and quality standards. Option 8 would converge into Option 1 if the fire department’s or police department’s TIRPs were reproduced verbatim in the AEP. However, this would require perpetual coordination whenever changes were made to the plan by any involved parties. Option 10 is potentially very useful for repopulation. An airport’s business continuity plan should definitely include a plan for terminal repopulation.

22 Airport Terminal Incident Response Planning Concerning Options 9 and 11, there is no explicit requirement in FAA Advisory Circular 150/5200-31C for SIP or repopulation plans. However, SIP is a logical alternative to evacuation for many of the incident types specifically listed in the advisory circular. Moreover, repopula- tion is a logical complement to both evacuation and SIP, especially from a business continuity viewpoint. In general, airports have not focused on repopulation in preparing for incidents. Of the 160 documents and plans included in this study, only four explicitly discussed repopulation. The apparent assumption is that all an airport needs to do after an evacuation or SIP is reverse the steps with no special plans or checklists required. As shown elsewhere, this is far from the case. Repopu- lation presents unique challenges with the potential for moderate to severe negative consequences if not managed properly. Other important airport plans are referenced in the plan produced by the TIRP, but the TIRP does not automatically generate links to those external plans and documents. Once an airport has its plan as a Microsoft Word document, it can edit it to incorporate links relevant to the TIRP, such as contact lists and links to other plans.