Incorporating ADA and Functional Needs in Emergency Exercises (2018)

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2 Introduction Previous research has included ACRP Synthesis 51: Impacts of Aging Travelers on Airports; ACRP Synthesis 60: Airport Emergency Post-Event Recovery Practices; ACRP Synthesis 72: Tabletop and Full-Scale Emergency Exercises for General Aviation, Non-Hub, and Small Hub Airports; and ACRP Research Report 177: Enhancing Airport Wayfinding for Aging Travelers and Persons with Disabilities. These research efforts suggested that DAFN individuals have not been adequately considered in airport emergency exercises and drills. It was necessary to provide a current snap- shot on what the airport, airline, and aviation-oriented organizations are undertaking to address the DAFN community and the emergency planning process. This synthesis focuses on emergency exercises that airports can effectively use to improve the safety of passengers, airport visitors, and employees at airports, particularly persons in the DAFN community. Definition of the DAFN Population and How Airports Define Their Community for Emergency Exercises After interviewing the partners throughout the global airport industry, it was determined that there was not a universal definition of the DAFN community. Most of the respondents use the C H A P T E R 1 Introduction Source: Linda Howard. Passengers in John Wayne Airport departure lounge.

Introduction 3 legal definition in the ADA; however, others also include the Federal Emergency Management Agency (FEMA) definition which adds temporary access and functional needs. As will be seen in the interview findings in Chapter 3, the DAFN community may be as broad as anyone who needs or requests assistance. Through this research, it became evident that a universal definition for DAFN and the DAFN community is needed to provide better guidance and assistance for airports and their customers. In an airport community, the challenge is to identify persons with disabilities, especially those who need aid in an emergency. In the European Union (EU), the current term is “persons with reduced mobility (PRM),” but this terminology is now under review (L. Van Horn, interview, 11/8/17). Although PRM focuses on mobility, in reality it includes all disabilities as well as access and functional needs that require assistance to access facilities including transportation. Use of the term PRM is being reexamined because its emphasis on mobility may contribute to underemphasizing other types of disabilities. Legal Environment In the United States, the following list contains the main laws and regulations that bear on this synthesis: • ADA • Post-Katrina Emergency Management Reform Act of 2007 (PKEMRA) • Americans with Disabilities Act Amendments Act of 2008 (ADA Amendments Act) • Air Carrier Access Act of 1986 (ACAA) • FAA Advisory Circular 150/5200-31C Airport Emergency Plan (FAA Advisory Circular) The ADA and the ADA Amendments Act along with their implementing regulations protect the rights of persons with disabilities and have the primary goal of outlawing discrimination against persons with disabilities and making public accommodations including transportation accessible to all persons. Although ADA did not directly address emergency response, numerous lawsuits in recent years have extended its concepts to such emergency response activities as evacuations and sheltering. In addition, the ADA implementing regulations and other guidance require effective communications with persons with disabilities; by extension, this will include communications necessary to protect persons during emergencies. PKEMRA explicitly required nondiscrimination toward persons with disabilities in all FEMA disaster and emergency response, recovery, and assistance activities. It also used a broader definition of disability to include access and functional needs such as temporarily reduced mobility and age-related restrictions. Under the ACAA, airlines are required to provide assistance with boarding, deplaning, moving through the terminal, and making connections, and they are not allowed to discriminate against persons with disabilities. In general, airlines contract with wheelchair service providers to provide such assistance. ACAA and its implementing regulations do not address emergency planning and exercises. FAA Advisory Circular 150/5200-31C Airport Emergency Plan spells out the responsibilities of airports for emergency planning. It deals with persons with disabilities and others with access and functional needs as “special needs” populations. As will be discussed more fully in Chapter 3, the FAA Advisory Circular requires attention to special needs in emergency planning in general and particularly in planning for evacuations. Looking at the effects of ADA, ACAA, and the FAA Advisory Circular, it appears that signifi- cant uncertainty exists about the responsibilities of airports and of airlines and their wheelchair

4 Incorporating ADA and Functional Needs in Emergency Exercises service contractors toward DAFN passengers during emergencies. Where emergency exercises are conducted that include DAFN participants, there may be a greater chance to identify such issues and to develop cooperative fixes. In the EU, this uncertainty is avoided by European Community (E.C.) Regulation 1107/2006, which specifies that the airport is responsible for PRM passengers throughout the airport and the airline is responsible for them only after they board an aircraft. E.C. regulations also state that for emergency management (including aviation), the policies and procedures of each nation apply. Regulatory Setting for Emergency Planning and Exercises Within the airport community, full-scale exercises are conducted every 3 years for U.S. airports and every 2 years for non-U.S. airports. These requirements are dictated by the FAA and International Civil Aviation Organization (ICAO). Through this research, it was revealed that many organizations exceed these requirements by having quarterly seminars, workshops on emergency management, or preparedness topics, and at least an annual tabletop exercise that brings internal and external stakeholders together to discuss a relevant emergency situation. Throughout the interviews, the research team determined that most airports believed they need to do more seminars, workshops, tabletops, or full-scale exercises to improve the airport. In addition, many airports understood that integrating the DAFN community into emergency planning and exercises would provide airports and emergency personnel with crucial knowledge of the DAFN community’s needs during an emergency. DAFN and Emergency Exercises During a literature review for this synthesis, the most pertinent document found was Incor- porating Special Needs Populations into Emergency Planning and Exercises (Davis and Mincin 2005) that is based on research sponsored by Nobody Left Behind: Disaster Preparedness for Persons with Mobility Impairments. Davis and Mincin defined special needs, the legal system, and mandates in addition to the background of special needs and emergency management. This document provided an overview of case studies on special needs during real-life incidents and exercises. The authors look at each aspect of emergency planning and exercises in detail to examine how best to include DAFN persons. The conclusion of this document emphasizes the immediate need to start integrating the DAFN community into emergency exercises: “In response to the inevitable reality of future disasters, it is vital to have a disability component when developing and implementing emergency plans and exercises. Without having the expertise of special needs subject matter experts, plans and exercises risk not addressing specific issues unique to the disability population and others with special needs such as communication issues and outreach, better provision of services, and perhaps enhancing life-safety strategies. Keep in mind that if a drill scenario were a real event, the impact would go beyond the disability community and also include the responders, the general population and entire response. If these issues and concerns are not resolved or considered, consequences could be devastating. Impact would be felt within the decision making processes, deployment and utilization of resources (or lack of), and limiting damage or death (or lack of). One cannot overemphasize the value of fully incorporating special needs issues into emergency planning, preparedness, response and recovery. Not dealing with disability issues in an appropriate and meaningful way results in the “disabling” of the whole response.” (Davis and Mincin, 2005, p. 33.) Drills and Exercises Guidance for Inclusive Emergency Planning (County of Los Angeles 2014) deals with all aspects of developing, executing, and evaluating drills and exercises that are inclusive of DAFN individuals. It is especially useful in describing effective means of outreach to engage DAFN advocacy groups and individuals in the process.

Introduction 5 FEMA’s (2013) presentation “Disability Inclusive Emergency Management—Understanding the preparedness, response and recovery needs of the whole community—Overview” provides a comprehensive summary of the means to include DAFN persons in all aspects of emergency management. In the slide on Exercises, FEMA makes three main points: 1. People with a variety of disabilities must be included. 2. Actors should not be used. 3. People with disabilities should pose real-life challenges. FEMA’s Emergency Management Institute offers a course, IS-0368 “Including People with Disabilities and Others with Access and Functional Needs in Disaster Operations” but it does not emphasize exercises. In addition to FEMA resources, there are other newer state initiatives. Examples are the Georgia Emergency Preparedness Coalition for Individuals with Disabilities and Older Adults (State of Georgia 2017) and Iowa’s Emergency Planning for People with Disability (Ford undated). The Arizona Commission for the Deaf and Hard of Hearing’s Emergency Response Inter- preter Credentialing Program includes exercises and drills to simulate emergency situations (Bond undated). The Texas Disability Task Force on Emergency Management updated its “Effective Communications Toolkit: Emergency Communications with People Who Have Disabilities” (2017). In June 2017, the International Association of Emergency Managers (IAEM) Bulletin published a special issue dealing with the DAFN community and emergency management. The following papers offer valuable insights that will be useful in developing emergency plans; however, they do not directly address exercises: • The Illiterate: An Overlooked Vulnerable Population (Manning-Armstrong 2017) • Establishing a Plan: Importance of Emergency Planning for Individuals with Developmental Disabilities (Canjura; Mauro, Jr.; and Cherofsky 2017) • Caring for Psychiatric and Special Needs Patients During a Mass Casualty Incident (Burket III and Lawall 2017) • The Whole Community Approach and Vulnerable Populations: A Case for Improving Diversity Among Emergency Managers (Kirkland and Averette 2017) • Considerations for Engaging and Serving the Deaf and Hard-of-Hearing Community; Inclusive EM Planning (Batten-Mickens 2017) • Emergency Managers Are Challenged to Ensure That the Special Needs of Vulnerable Populations Are Considered and Met (Lloyd 2017) • Is It Time to Shore up the Foundation for Vulnerable Populations? (Warnick 2017) Research for the National Fire Protection Association noted signifi- cantly increased times for persons with reduced mobility to evacuate a building (Hoskins and Heimberger 2017). There are predictive tables for this. Manley et al. (2011) address this more specifically, modeling emergency evacuation of individuals with disabilities in a densely popu- lated airport. How Airports Find Community Resources to Assist in Developing an Inclusive Program A recurring theme throughout the research was using local commu- nity resources that currently assist the DAFN community and inviting those organizations to play a more active role in the airport through Specialized hospitals can be a major source of help for airports. Aspen-Pitkin County Airport gets advice and help from the Disabled American Veterans (DAV) Hospital in Grand Junction to prepare for the annual DAV Week in Aspen. Jacksonville International Airport gets advice and assistance from Mayo Clinic and Brooks Memorial Hospital. The advice is useful for both regular operations and emergencies.

6 Incorporating ADA and Functional Needs in Emergency Exercises review of design, accessibility during construction projects, the overall flow of passenger travel, and emergency exercises. The research showed the importance of establishing lines of communication within the DAFN community and with the local community and the airport as well. It is critical for the success of an airport to incorporate the residents of their local community with their special needs and challenges before an emergency situation occurs. The community resources help educate all airport employees on how to interact with the DAFN community, identify barriers that may not be obvious, provide training opportunities, and test the emergency plans and procedures so the airport can continually improve customer service. American Association of Airport Executives Emergency Management Conference In July 2017, the American Association of Airport Executives (AAAE) hosted an International Airport Emergency Management Conference in Atlanta, Georgia. During the conference, there were two presentations that were relevant to this synthesis: (1) Americans with Disabilities Act During Events and (2) a review of the 2017 Fort Lauderdale Airport Shooting. The speakers included Michael Nonnemacher, Acting Assistant Director of Aviation and Jason Alvero, Air- port Emergency Manager for the Fort Lauderdale/Hollywood International Airport; and Frank Ciaccio, Emergency Management Coordinator for the Houston Airport System and Steve Mayers, Director of Customer Experience and ADA Compliance for the Hartsfield−Jackson Atlanta International Airport. The lessons that were shared during this conference are opportunities for airports to be proactive when planning emergency exercises. The opportunities for improvement include the following: • Mobility impaired individuals were assisted by other passengers during the emergency. • Re-unification with assistive devices took up to 1 day. • Communications with persons with vision and/or hearing disabilities were not successful. • Having the DAFN community more involved with planning and executing emergency exercises is highly desirable. • Establishing an online disability training program for all badge holders is helpful. • Identify escape routes using flooring and wall devices that show the direction of exits. One important takeaway to assist in emergency exercises preparation and overall emergency response resource management was that the evacuation of one non-ambulatory person might need up to four emergency responders to assist. Summary This synthesis provides a snapshot of current practices for the integration of DAFN persons in the planning for, execution of, and evaluation of emergency exercises at airports. The data were collected at a time when airports and airlines were becoming more aware of the need to assist the whole community—including the disability community—in the response to and recovery from emergencies. Fort Lauderdale/Hollywood International Airport cited the American Red Cross as a major community partner for emergency exercise design and execution.

Introduction 7 Source: Denver International Airport. Visual paging at Denver International Airport.