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16 Current Airport Emergency Plan Practices This chapter interprets the data and results collected from three different methods: group discussion during a plenary session at the AAAE International Airport Emergency Manage- ment Conference in Chicago, Illinois, survey results from an online survey provided to airports of all sizes and types throughout the United States, and phone interviews with seven airports providing input into their AEP practices. AAAE International Airport Emergency Management Conference, Plenary Session During the 2019 AAAE International Airport Emergency Management Conference in Chicago, Illinois, July 16â18, 2019, a plenary panel session was held on Tuesday, July 16, from 2:30 p.m. to 3:15 p.m. central daylight time with 175 conference attendees, to discuss their current AEP practices. During this session, a moderator asked a series of informal, unscripted questions (different from the questions contained in the online survey) of the conference attendees in the session about their AEP practices. A panel of two experts, including the principal investigator of this synthesis and one from a large-hub airport, provided input into the discussion and asked additional unscripted questions of the group to gain insight into how the airports at the conference conduct their AEP practices. Furthermore, the synthesis team took notes of the comments from the plenary session, and the interpretation of these results is presented here. Notes captured general comments from the audience as various members shared their thoughts and activities specific to AEPs. Some attendees in the session stated they, as the airport, hesitate to consider the AEP to be an actionable document that can be effectively used during an emergency. However, attendees commented that if an airport were to revise or include more information than is outlined in the AC to have a plan that is more actionable, the airport may be subject to regulatory or monetary consequences if the AEP is not used exclusively as written. To avoid these risks, many airports will simply follow the format outlined in the AC and nothing further. The AEP as required does manage risks and provide planning awareness that does not compromise any proprietary or secure information that an airport would not want accessible through public records. Many airport emergency managers agreed that the AEP, in its current required format, is not comprehensive nor an all-hazards document, and therefore, not actionable. Some attendees commented that the AEP is a sound foundational document, allowing an airport to identify further hazards or threats that may affect the airport and thereby create annexes or plans to address these threats. Some airports felt that although the current AC provides in-depth guidance for the AEP, it has also created a much larger and cumbersome plan C H A P T E R 3
Current Airport Emergency Plan Practices 17 to keep up-to-date and has made it more difficult to ensure stakeholders understand their roles and responsibilities as outlined in the large document. Some airport conference attendees reported that the AEP is regularly updated simply because of regulatory requirements. Participants asked, âIs it the AEP legislation or the Advisory Circular itself that bogs down the development and/or use of the AEP?â Online Survey (SurveyMonkey) Following the AAAE conference panel and plenary discussion, 81 airports throughout the country were invited to participate in an online survey to provide input about their AEP practices. These airports were selected through industry relationships, panel recommenda- tions, and airports requesting inclusion who attended the AAAE conference. The purpose of the questionnaire was to capture the current state of practice as well as any challenges airports face when developing, revising, and using their airportâs AEP for emergency response and recovery efforts. The 81 contacts represented 62 airports (26 large-hub, eight medium-hub, 13 small-hub, three nonhub primary, six nonhub GA, and six nonhub reliever). A total of 45 airports, or 72.58%, completed the survey. Respondents were asked to provide feedback regarding their experience with AEPs, including challenges confronted, the use of companion annexes or additional standalone plans, and how they have socialized and trained their airport communities on these plans. The survey took approximately 20 to 30 minutes to complete. Participants were given the opportunity to attribute their responses; otherwise, anonymity was assured. For the purposes of this synthesis, responses are generalized and overall are not attributed to individuals or airports unless it has been approved. Further follow-up interviews were conducted with seven airports and their in-depth responses are included in the inter- pretation of the results as indicative of their AEP practices at their airport(s). The data collected encompasses information from participants about their AEPs, including effectiveness and usefulness as a response guide, the regulations surrounding development and upkeep, and how the AEP is used at their specific airport. Other data gathered included challenges confronted in the development, maintenance, use, and socialization of the AEP, as well as successful practices in the same areas. The seven airport interviews delved further into seven categories of AEP practices (questions built upon the foundation of the online survey questions) and included the following: â¢ Metrics for developing AEP annexes â¢ Socializing the plan(s) â¢ Incorporating AEPs into training and exercises â¢ Incorporating lessons learned into AEP updates and annexes â¢ Other partner preparedness plans â¢ AEP update challenges â¢ Overcoming challenges Figure 3 illustrates the types of organizations who responded to the survey. A total of 43 of the respondents identified as an airport. Two identified as âotherâ or not an airport, and none identified as FAA inspectors. Figure 4 shows the distribution of the respondents among departments, divisions, and offices represented. Out of the 45 respondents, 53% are emergency managers, 38% are airport operations, and 9% chose other and specified as consultant and fire/police (includes ARFF). One âotherâ respondent identified as airport safety, security, and emergency preparedness. Of the 28 respondents who identified the size of the airport for which they were answering survey questions, respondents indicated they were responding for 17 large hubs
18 Practices in Airport Emergency Plans Figure 3. Question 1. Type of organization. (Source: SurveyMonkey results) 60.00% 50.00% 40.00% 30.00% 20.00% 10.00% 0.00% Emergency Management Airport Operations Risk Management Corporate Federal Aviation Administration Other (please specify) Figure 4. Question 2. Which department/division/office are you representing? (Source: SurveyMonkey results) (of 26 survey recipients), six medium hubs (of eight survey recipients), four small hubs (of 13 survey recipients), and three GA or reliever airports (of 15 survey recipients). It is impor- tant to note three respondents answered for multiple airports under their purview. Not all respondents were willing to name the airport they represented, but of those who did, participating airports included the following: â¢ Austin-Bergstrom International Airport (AUS) â¢ Cecil Airport and Spaceport (VQQ) â¢ Charlotte Douglas International Airport (CLT) â¢ Chicago Midway International Airport (MDW) â¢ Chicago OâHare International Airport (ORD) â¢ Dallas Fort Worth International Airport (DFW) â¢ Ellington Airport (EFD)
Current Airport Emergency Plan Practices 19 â¢ Fairbanks International Airport (FAI) â¢ Fort Lauderdale-Hollywood International Airport (FLL) â¢ George Bush Intercontinental Airport (IAH) â¢ Hartsfield-Jackson Atlanta International Airport (ATL) â¢ John Wayne AirportâOrange County (SNA) â¢ Louisville International Airport (SDF) â¢ McCarran International Airport (LAS) â¢ Memphis International Airport (MEM) â¢ Minneapolis-Saint Paul International Airport (MSP) â¢ Orlando International Airport (MCO) â¢ Portland International Airport (PDX) â¢ Savannah/Hilton Head International Airport (SAV) â¢ Seattle-Tacoma International Airport (SEA) â¢ Washington Dulles International Airport (IAD) â¢ Washington Reagan National Airport (DCA) â¢ William P. Hobby Airport (HOU) Is the AEP Seen as an Actionable and Sufficient Response Document? Throughout the survey, several questions elicited responses from participants that gave indicators of how they view the AEP as an actionable and sufficient response document. In Question 39, as seen in Figure 5, respondents were asked to rate the following statement (on a scale from 1 to 10, with 1 being âStrongly Disagreeâ and 10 being âStrongly Agreeâ): âThe current AEP circular and policies meet the needs of airports to appropriately develop and update AEPs.â The average was 5.1, meaning respondents indicated that on average, they neither agree nor disagree with the statement. When asked why they rated their answer the way they did, the responses indicated agreement to meeting needs but added that the practical application could use improvement as well as Figure 5. Question 39. On a scale from 1 to 10, with 1 being âStrongly Disagreeâ and 10 being âStrongly Agree,â please rate the following statement. The current AEP circular and policies meet the needs of airports to appropriately develop and update AEPs. (Source: SurveyMonkey results)
20 Practices in Airport Emergency Plans another update to the AC. Respondents indicated that airports could take more ownership of creating necessary plans, annexes, or complementary procedures to the AEP beyond what the AC requires. Comments included the following (summarized for clarity): â¢ EM as a profession has grown; several lessons learned have been incorporated, applied, and passed successfully since the AC 150/5200-31C update. â¢ Airport growth, tenant expansion, and additional spaceport requirements should be incorporated into the AC. â¢ The AC provides useful and needed information and requirements. However, because of the prescriptive nature of the AC, the result can be a complicated and difficult-to-use document. â¢ Ensuring the AEP is updated, maintained, managed, and appropriately shared is labor intensive. If staff are assigned to this function as an âother duty as assigned,â there may not be as much return on investment (ROI) or benefit as if someone focused on the AEP as their sole job. â¢ Understanding the AEP outlines the basics for the plan. Airports can always add to the AEP if appropriate. â¢ The hazard-specific sections need to be updated. â¢ The AEP is a necessary document for FAA oversight to objectively determine compliance by airportsâand the AC and policies provide updates and modifications necessaryâbut the AEP itself should not be what causes creation of underlying response/recovery plans. These can and should be developed as part of a logical, long-term EM program and process. â¢ The AC and policies no longer accurately represent the current threat/risk landscape at airports. â¢ The AEP provides a base response and recovery plan for a lot of airports. It has a purpose, but the process needs to be reviewed to ensure airports look at all-hazards. Question 11 asked survey respondents to rate their responses from strongly disagree to strongly agree for 13 statements, as illustrated in Table 1. The average of responses was based on a Likert scale (out of 5 points; 1 being strongly disagree and 5 being strongly agree). On a scale of 1 to 5 (with 1 being strongly disagree and 5 being strongly agree) rate the following statements: The airport's AEP is actionable and sufficient enough to be a response document for the airport. 3.13 I, my airport, and airport community use the AEP regularly. 2.87 The AEP provides adequate and actionable information to respond to and recover from an incident. 3.0 I find the AEP to be generic and does not provide me or those who need to respond adequate information to do so. 3.45 Table 1. Question 11. (Source: SurveyMonkey results)
Current Airport Emergency Plan Practices 21 Updating the AEP is a challenge and does not provide any value added to our response or recovery efforts. 2.95 The AEP checks a box and nothing more. 2.83 I incorporate the AEP into training and exercises beyond the required annual training and triennial exercise. 3.63 The AEP can be improved. 4.65 On a scale of 1 to 5 (with 1 being strongly disagree and 5 being strongly agree) rate the following statements: I have to create and develop other hazard-specific plans that are complements to the AEP to ensure airport personnel understand their roles and responsibilities during an incident or event. 4.08 The AEP contains all hazards that my airport could be threatened by. 2.5 I review lessons learned from other airport incidents and events and incorporate their lessons learned into my own AEP or preparedness plans. 4.08 There is one person solely dedicated to the AEP, its update, and ensuring all airport preparedness plans are cross-walked with it. 3.16 I get active participation from all of the relevant stakeholders during the annual AEP review and update process. 3.13 Table 1. (Continued).
22 Practices in Airport Emergency Plans A total of 41% of respondents agreed or strongly agreed that their airportâs AEP is sufficient as a response document for the airport, while 34% disagreed or strongly disagreed. A total of 23% remained neutral on the question. However, the statement, âI find the AEP to be generic and does not provide me or those who need to respond adequate information to do so,â provided further insight into respondentsâ perceptions of the AEP with 56% agreeing with that statement. A total of 80% of respondents agreed or strongly agreed that to ensure airport personnel understand their roles and responsibilities during an incident, that they (the respondents) may find benefit in creating and developing other hazard-specific plans to supplement the AEP. Support for this is also seen in the varied annexes, SOPs, and all-hazards plans iden- tified during the data gathering and reflected in the AEP-practices case examples included in Chapter 4. Other patterns that emerged show that the AEP, its update, and the process of ensuring that it is in sync with all other airport preparedness plans are often the responsibility of one person solely dedicated to the task. Roughly 43% of respondents agreed that they receive active participation from all relevant stakeholders during the annual review and update process, 35% disagreeing with the statement, and 20% remaining neutral. A combined 20% agree that the AEP contains all-hazards that threaten the airport, and 60% disagree. Again, the results appear to reflect (as further reported in the survey) that to ensure active participation and an all-hazards approach, they, as the airport, consider developing innovative ways to engage stakeholders and develop plans that speak to any threats and hazards that are not included as part of the AC. Lessons learned from other airport incidents are regularly used to inform an airportâs AEP or supplemental plans, and 45% of respondents agree that updating the AEP provides added value to their airportâs response and recovery efforts while 30% do not, and 23% of respondents remain neutral. A total of 67% incorporate the AEP into training and exercises beyond the required annual training and triennial exercise. Finally, 85% of respondents agree or strongly agree that the AEP can be improved. Successful Practices in Developing and Updating the AEP Respondents throughout the survey referenced various successful practices when developing and updating their AEP. In Question 12, 29 respondents were willing to share their successes as well as the challenges they faced when developing or updating the AEP. One respondent considered the fact that they have a plan at all to be a success. The most common text response by participating airports to this question related to âstakeholder engagement.â Though often worded differently, respondentsâ most common successes referenced collaboration with internal and external stakeholders. Responses included the following: âGreat feedback from stakeholders.â âCollaborating with stakeholders.â âPolice, fire rescue, and airport operations build a closer working relationship through the review and updating process; they become fully invested in the document.â âThe biggest success has been our engagement with stakeholders. There is always a willingness from our partners to assist with development and revisions.â âEngagement from stakeholders improves when ownership is explained.â âGetting feedback from co-workers to make it more of a working document.â
Current Airport Emergency Plan Practices 23 âThe major success when updating our AEP is the collaboration of all of our stakeholders. I ensure that each department/agency that has a role in the AEP is present for the discussion, and that we solicit honest feedback from each regarding what the AEP says they will do. . . .â âAdditional input from airport stakeholders and not just emergency response organizations.â Other documented practices reported in Question 12 included the following: â¢ Custom tailoring the AEP to an airportâs specific operation â¢ Contracting with an outside consultant to rewrite the AEP â¢ Assigning each unit, the task of updating the plan specific to their area of responsibility â¢ Creating a process to identify best practices â¢ Acquiring updated tenant contact information to disseminate the AEP via electronic means â¢ Creation of a 3-year cycle to include the AAR/Improvement Plan (IP) from the Triennial Exercise, the thorough review and update to the AEP, and an update to the COOP Challenges in Developing and Updating the AEP Airports showed great consistency in their responses to questions about challenges with AEP development. Common themes were the rigid format of the AEP, stakeholder participation, resistance to making changes, competing priorities, and timeline for executive and final regula- tory approval prior to updated plans being implemented. In addition, airports noted there was redundancy because of the need to have multiple plans which contain the same information to meet local, state, and federal guidelines and regulations. Responses also indicated it was a challenge to keep the plan broad and holistic enough for the various hazards the airport could experience. The format for the AEP includes the same sections in the basic plan, functional annexes, and hazard annexes. Airports felt this format resulted in repetitive information throughout the AEP. For example, Command and Control is included in the basic plan, then again in each annex. For many airports, the command and control structure remains the same, with small variances for some hazards. In addition, airports commented about the rigidity of the plan format. Some felt it did not leave a lot of room to add additional information, such as preparedness and long-term recovery activities. Stakeholder participation in the planning process can make all the difference. When it happens, an active and engaged group of partners can stimulate the entire process; ideas feed off one another in true partnership with all benefiting from the collaborative process. When it does not happen, the negative impact can be just as significant. Just as the most common successful practice listed was an engaged group of stakeholders, one of the biggest challenges noted by respondents was a lack of stakeholder participation or the slow pace at which stakeholder feedback is provided. Survey comments relating to stakeholder challenges include the following: âGetting the units to provide timely responses.â âStakeholder participation.â âGetting ALL to actually read and review [the AEP].â âMost of the partners [are] apoplectic to the process and review.â âGetting [timely] feedback from stakeholders â but they eventually comply with solid input.â âGetting consistent policy/procedural updates/feedback from all levels and users of our facility.â Resistance to change was also noted as a challenge. The AEP has remained relatively consistent throughout its existence. As EM becomes professionalized in airports, there has been tension between airport operators who want to keep the plan the way it has always been and EMs who
24 Practices in Airport Emergency Plans want a comprehensive, all-hazards plan. At least one airport indicated senior leadership was concerned about the liability of a more comprehensive plan, indicating a more comprehensive plan may have implications if the airport does not follow through with everything in the plan, be it from lack of resources, ability, or for any other reason. There is also concern over receiving FAA approval and the ability to pass inspections if too many changes are made. Concern was expressed multiple times that the plan was more focused on airside events and did not always place the same emphasis on landside, public spaces, or the terminal/secure areas. There was also a desire to include more support services such as food, baggage services, and hotels in the AEP or into the planning process. As a result, airports have created additional annexes, SOPs, and standalone plans to close this gap. Many felt their time and staff were better served focusing on developing and maintaining supplemental plans, as opposed to the AEP, as a result of more use and the applicability of the additional plans. In addition, some airports felt limited time and shifting priorities affected their ability to get participation in AEP development from other departments and stakeholders. Others felt that the AC and policies work, but just need some adjusting. âThe policies typically meet the needs of airports, but thereâs room for improvement.â âWhile it works, it could always be stronger and more useable.â âIt still provides the basis, but we can go further as an organization and as an industry.â The majority opinion as indicated throughout the survey is the requirement that the AEP must be approved by the FAA provides minimum requirements that may not be sufficient in responding to an actual emergency. To have the plans they need to provide a timely and efficient emergency response, the airports prefer to develop separate function-specific and/or hazard- specific plans that will provide the detailed guidance necessary when responding to various emergency incidents. Based on survey responses, the time it takes to update an AEP can be anywhere between under 6 months to a year or more. Adding to the length of the process is a possible executive review. The executive review can significantly prolong the process, depending on who reviews it. In some cases, executive review consists of an executive leader (airport director, executive director, general manager) who reviews, provides input, and then final approval. Or it may be as com- plicated as going before an airportâs director of operations and security, chief operating officer (COO), several other executives, and several other stakeholders for review and feedback, with the revised version being sent through the same group of people one more time. As seen in Figure 6, 61% of respondents indicated there was a process for executive review. Figure 6. Question 22. Was there a process for executive review? (Source: SurveyMonkey results)
Current Airport Emergency Plan Practices 25 Again, based on these responses, airports have developed alternative practices to close gaps theyâve identified, such as developing all-hazards plans, checklists, and reference guides consolidating the AEP information, and pulling stakeholders together to meet regularly for AEP updates, either from exercises, real-world events, or the required annual review. Some of these successful practices are discussed in-depth in Chapter 4, Case Examples. Challenges in Using the AEP During an Incident Challenges are not only present when developing or updating an AEP but are also encoun- tered when using the AEP during an incident, as seen in the responses to Question 15, âWhat challenges have you experienced when using your AEP during response and recovery efforts?â Respondents ultimately indicated that the AEP is difficult to use or not used at all; either because it is too cumbersome, is not detailed enough or updated, or is lacking in the necessary information. Challenges listed include the following summarized responses (grouped into categories): â¢ Hard to Use/Too Big/Unable to Access â Checklists are too lengthy, and/or checklists are not set up in an order that flows with a typical incident. â The AEP is unusable as a real-time reference in the field/at an incident command post (ICP). â The need to flip back and forth in a large binder is a cumbersome process during an emergency. â The AEP is too large and inflexible and difficult to train to. â Because of time limitations during a real-world event, the AEP becomes a reference document only. â Not used because of the sheer size of the document, which makes it impractical for use in field work. â The plan is too robust to use. â Access to the document is a challenge. Having a quick access guide would be helpful. â¢ Plan Information Not Relevant/Does Not Contain Correct Information/Out of Date â The annexes are not updated. â The AEP is not specific enough to guide a response. â The AEP was not adequate enough to address all the response and recovery efforts of the airport. â Not enough detail for recovery information. â Airport plans and airline plans are divergent; airline and airport plans need to be more in sync. â The AEP does not cover anything after the initial response; subsequent responses and recovery are not described. â Contact information for contract vendors is not up-to-date. â Too general; not enough detail provided on actions to take or risks/hazards to assess and mitigate. â The AEP does not accurately reflect the large municipality that an airport encom- passes. There are no sections in recovery that address debris management or damage assessment. â¢ Layout/Formatting Issues â The layout does not lend itself to easy and immediate reference. â If it follows the FAA guidelines, it does not have sufficient information when needed during an incident.
26 Practices in Airport Emergency Plans â¢ Lack of Familiarity with Roles and Responsibilities/Understanding of the AEP â There is lack of familiarity with the AEP by the airport community. â Personnel may conduct activities they deem to be useful or necessary without adhering to the roles and responsibilities listed in the AEP; or personnel may voluntarily respond without being activated or asked for. â There is a need to ensure all responders are briefed on updates that have been made but not pretested. â¢ Communication â There is a lack of communication between administration and field responders when updating the AEP. Administrative personnel do not consult with field responders for content. When asked, âHow do airports integrate the AEP with emergency response and recovery activities?â many respondents reported it is not possible or it is difficult to do so. One respondent said they use it âafter the fact,â while another said, Currently, the AEP provides a loose framework (checklist) for response and recovery to various incidents, mostly focused on the airside of the operation, not the terminal or landside. . . . Part 139 [focuses on] airside activities/equipment; therefore, 90 percent of the AEP focuses on airside. . . . In response to integrating the AEP with emergency response and recovery activities, respondents shared the thoughts and methods by which they do this: â¢ Making actionable plans that accurately reflect staff (including confidential contact infor- mation), training, and capabilities; â¢ Developing a COOP to serve as a guiding document for operations response and recovery and using the EM process to address major business disruptions; â¢ Ensuring the AEP and response activities are in sync; â¢ Separating the AEP from SOPs; making the former a higher-level document and the latter targeted to first responders; â¢ Using the AEP primarily as a training aid and reference document, and occasionally as a confirmation checklist; â¢ Referencing the AEP during emergencies; â¢ Using real-world responses to validate/update their AEP; and â¢ Using the AEP as an overall guide to develop more detailed checklists and operating guidelines. Training and exercises followed by AAR/IP are also commonly seen as an effective practice to integrate the AEP with emergency response and recovery activities. How Is the AEP Used? When asked if the AEP is used operationally, 57% of respondents said ânoâ (see Figure 7). Those who responded âyesâ were asked how; those who responded no were asked why not. Some of those who use the AEP operationally use aspects of it during incidents, but do not use the plan as a reference guide; others use it during training for new airport operations personnel. One respondent uses it daily; others use it in more complex and lengthy response scenarios; and still others only look at it after an incident has occurred. Those who do not use it opera- tionally cite several challenges such as the overwhelming information contained within the AEP, difficulty in maintenance because of the large size of the plan, the generality, and lack of detail, that the AEP is too basic and not based on day-to-day operations, and that the AEP needs to be more actionable.
Current Airport Emergency Plan Practices 27 How Can Airports Make the AEP Actionable and Relevant? In Question 35, âWhat are ways airports can make the AEP actionable and relevant to the myriad of stakeholders?â the survey gave respondents the opportunity to convey their ideas on how airports can make the AEP actionable and relevant. Some airports are working to minimize their challenges by including field personnel in the process, clarifying roles, continually engaging with stakeholders, stressing the importance of the process of planning and exercising, holding departments accountable, and engaging with top leadership to set expectations and enforce them. Metrics for Developing AEP Annexes Some airports indicated they used metrics to identify if they should or needed to develop AEP annexes. The authors also asked the airports being interviewed to describe their AEP metrics. Each had one commonality: the annual FAA inspection. Airports subject to part 139 requirements are inspected annually by the FAA to ensure the airport meets all requirements necessary to maintain their AOC. One requirement includes maintaining an AEP in accordance with part 139. Across the board, airports noted this as their primary metric for their AEPs. In addition, airports stated the completion of recommendations or changes requested from the inspector were a measure of a successful plan. Additionally, some airports also indicated their measurements of success were not limited solely to the FAA inspection. These metrics were related to having a comprehensive EM program, focused on all-hazards, and the incorporation of stakeholders and partners into their plan- ning efforts. However, airports differed in their approach to this practice. Some developed their AEPs to reflect this. Others kept their AEPs to the minimum requirements and developed additional plans or annexes. Regardless of the approach, airports set the bar for such metrics based on capabilities identified through traditional EM tools, such as gap analysis, THIRAs, improvements identified through AARs, and the need to integrate with stakeholders and community partners. 60.00% 50.00% 40.00% 30.00% 20.00% 10.00% 0.00% YES NO Figure 7. Question 45. Is the AEP used operationally? (Source: SurveyMonkey results)
28 Practices in Airport Emergency Plans Development of Annexes, Plans, SOPs, or Checklists Respondents indicated they have created a multitude of AEP annexes to address their challenges; most specifically, that the AEP does not speak to all-hazards and threats the airport could face. Respondents indicated that they have developed the following annexes, plans, SOPs, or checklists: â¢ Active Assailant Plan â¢ Active Shooter Plan â¢ Active Threat â¢ Administration Facility Evacuation Plans â¢ Air National Guard Letter of Agreement (LOA) â¢ Aircraft Emergency Response â¢ Airport EOC Plan â¢ Airport Terminal Emergency Plan â¢ Airport Training and Exercise Plan â¢ Airside Incident Detailed Responses, including AEP Checklist â¢ All-Hazards Functional Annexes specific to Division Directors, Maintenance, Environmental, and Customer Service Staff (regardless of threat or hazard) â¢ Animal Care Plan â¢ ARFF Equipment & Capabilities â¢ ARFF Tactical Operating Guidelines â¢ Business Continuity Plan (BCP) â¢ Civil Disturbance â¢ Communicable Diseases â¢ Communications All-Hazards Plan â¢ Community Emergency Response Team Memorandum of Understanding (MOU) â¢ Complex Coordinated Terrorist Attack Plan â¢ Continuity of Operations Plan (COOP) â¢ Crisis Communication Plan/Emergency Communications Plan â¢ Critical Infrastructure Airport Grid Map Book â¢ Crowd Control Evacuation Guide â¢ Dependent Population Plan â¢ Directory of Rental Car and Taxicab Companies â¢ Disabled Aircraft â¢ Earthquake Plan â¢ Emergency Medical All-Hazards Plan â¢ Emergency Notification Responsibilities â¢ EOC Activation Manual â¢ EOC Section Coordinating Procedures â¢ Family Assistance Center Operating Guide â¢ Family Assistance Center or Family Assistance Support Plan(s) â¢ Family Assistance Plan for Non-Aviation Related Events â¢ Fire, Police & Aviation Partnership Objectives â¢ Flooding Plan â¢ Gas Drilling â¢ Hazard-Specific Plans, to include tropical weather, pandemic, and so forth â¢ Hazardous Materials â¢ Hurricane Preparedness Plan â¢ Incident Management â¢ Information Technology (IT)/Cyber Attack â¢ Interagency Aircraft Accident Plan
Current Airport Emergency Plan Practices 29 â¢ Irregular Operations (IROPS) â¢ Landside Emergencies â¢ LOA on Emergency Response Between Agencies â¢ Mass Care Plan â¢ Mass Casualty â¢ Mass Evacuation â¢ Media Plan â¢ Minor Medical Incident â¢ Mutual Aid Plan â¢ Pandemic â¢ Power Outages (not just for airfield) â¢ Rapid Recovery Plan â¢ Severe Weather Plan â¢ Spaceport Operations â¢ Special Events â¢ Surface Management â¢ Terminal Building Evacuation â¢ Terrorism Plan â¢ Transportation or Transportation Evacuation Plan â¢ Unmanned Aerial Systems or Drone Plan â¢ Water Rescue â¢ Web Emergency Operations Center (WebEOC) Userâs Manual â¢ Western Airports Disaster Operations Group (WESTDOG) â¢ Winter Storms The survey response to Question 17, âHow is a decision made to add a functional annex that is not required by the FAA?â is shown in Table 2 and illustrates survey indicators of methods used to assist in making the decision that a specific functional annex should be added. Answer Choices Responses(%) Risk analysis (identifying the risks to the airport and developing plans to mitigate those risks) 48.39 Business case analysis (the business wants or needs a plan to manage an issue, such as curbside traffic during an emergency) 25.81 Threat hazard analysis (threats to the airport are identified and plans developed) 58.06 Airport/executive priorities (the airport leadership or executive leadership have asked for plans, or prioritized specific issues) 35.48 After-action reports from our airportâs exercises, incidents, or events 48.39 After-action reports from other airportsâ incidents 45.16 Please list another method for determining development of an annex and/or plan not previously listed. 29.03 Table 2. Question 17. How is a decision made to add a functional annex that is not required by the FAA? (Source: SurveyMonkey results)
30 Practices in Airport Emergency Plans Question 17 also asked the respondents to list other methods not previously mentioned for determining development of an annex and/or plan. Responses ranged from âto save time in the AEP review and update process,â to âpublic outcry. . . .â Among the responding airports that have developed annexes or supplemental plans, responses suggests a major motivator in developing those plans to be lessons learned from a real-world incident where the need was made clear to the airport during the response phase; another motivator was the need to ensure a timely and efficient response that will lead to a quick recovery with minimal operational impact. Once it is determined to add a functional annex or supporting plan, airports address devel- opment in several ways. Efforts include the following: â¢ Team effort, driven by a contracted subject matter expert (SME) â¢ Discussion with first responders and tower manager â¢ Team effort with in-house coordination and collaboration with relevant stakeholders â¢ Single-person development of the plan â¢ Development by airside operations with input from stakeholders â¢ Development by EM â¢ Plans and best practices from other airports used to guide and inform the new annex Survey responses indicate that planning teams are used most often as an AEP practice. Table 3 illustrates the makeup of planning teams according to the survey. Overcoming Challenges Survey responses identified several challenges with AEP development, but airports are determined to overcome them. Airports interviewed showed success in ensuring plans are useful and robust while fulfilling FAA AEP requirements. Airports have also used innovation to bring stakeholders onboard with supporting AEP development. Many of the examples of overcoming challenges involved communication and understanding of the AEP. One approach was to use plain language when discussing plans with stakeholders, as is often done during the part 139 annual TTX. The airport survey response indicated that staff made a conscious effort to avoid EM, response jargon, and other lingo in their discussions. As a result, stakeholders had a greater under- standing of the plan and their role in it. Another airport used the âWhatâs in it for me?â approach. They began their conver sa- tions with airport departments and organizations by explain- ing the benefit of the AEP to their business line. This created more investment in the plan. Many airports used working groups for plan maintenance, which has proven to be success- ful in emergency coordination across the country. Two air- ports stated they found success through sheer persistence. They continued to reach out to and ping contributors to the AEP to ensure input was included and engagement was consistent. While some airports want to build out the AEP, others have been successful by reducing the document. Some airports have removed everything beyond the regulatory requirements from the AEP and placed all this information in standalone plans. They indicated this streamlined the AEP and resulted in stronger supplemental plans. In addition, they were able to modify all plans not included in the AEP, allowing for more flexibility. Airport staff participate in an AEP tabletop exercise with stakeholders, CLT Source: Michael Tobin, CLT
Current Airport Emergency Plan Practices 31 Answer Choices Responses (%) Airport Operations 87.10 Law Enforcement 87.10 Fire Department 90.32 Administration 45.16 Information Technology 45.16 Corporate/HQ 16.13 Executives 35.48 Finance 22.58 Airlines 64.52 Tenants 58.06 Airport Volunteer Groups 25.81 Local Jurisdictions 38.71 CBP 48.39 TSA 54.84 FAA 41.94 ATCT 32.26 FBI 41.94 NTSB 19.35 Other (Federal) 22.58 Local EM Agency/Office 51.61 Engineering/Maintenance 41.94 Landside 67.74 Airside 70.97 Transportation/Shuttle/Bus Providers 35.48 Taxi services 6.45 Transportation Network Companies (e.g., Uber, Lyft) 9.68 Other (please specify) â¢ Safety/Risk Management â¢ EM 19.35 Table 3. Question 20. If planning teams were used to develop additional plans, who was involved? (Source: SurveyMonkey results)
32 Practices in Airport Emergency Plans Socializing the Plan Once the plan is finalized and has received FAA approval, it is ready to be rolled out for training, exercising, and implementation. Methods for sharing the plan differ, as illustrated in Table 4. Some airports only share the AEP with new personnel in airport operations, security, police, and ARFF, while others expand it to include all airlines, departments, and external mutual aid agencies. As seen in Table 4, exercises are by far the most popular way to share the plan, especially TTXs, which are attractive because of their informal, no-fault, discussion-based format, as well as the recommendation for the annual review of the AEP with stakeholders. Although in-person communication was considered the most successful practice, there are situations where this is not always feasible. In addition, partners may benefit from having access to the plans and other tools at their convenience for training or reference. The most common approach to providing this is through electronic means. As seen in the survey responses, airports provide electronic access to the AEP with password protection or other security measures in place. This was achieved through intranet and similar systems which could be accessed at the userâs convenience. Other airports provide hard copies to partners. Some airports use innovative tools to share the document, including mobile applications, checklists, photo sharing, and online collaboration tools (see Figure 8). In response to Question 26, âHas the airport enlisted any innovative tools to help with the plan, response, recovery, or general knowledge share of the document?â one airport stated it enlists SMEs as speakers at tabletops and workshops to conduct an educational component on the topic under discussion. For example, when focusing on the Communicable Disease Plan, an airport brought in a local Centers for Disease Control and Prevention (CDC) official and a local public health officer. The airport also invited local law enforcement jurisdictions that have implemented Answer Choices (select all that apply) Responses (%) Workshop 36.67 Tabletop Exercise 70.00 Full-Scale Exercise 43.33 Training Sessions 56.67 Webinars 0.00 Provide Soft/Hard Copy to New Employees with "Need to Know" 56.67 Other Ways Not Listed â¢ List on website â¢ Seminar with airlines â¢ Internal training sessions â¢ Smaller drills in between triennial full-scale exercise â¢ Email soft copies â¢ Secure document portal, password protected â¢ Meetings to share AEP 26.67 Table 4. Question 24. How does the airport share and socialize the new plan(s)? (Source: SurveyMonkey results)
Current Airport Emergency Plan Practices 33 unmanned aerial system programs to discuss drone technology; and the FAA Flight Standards District Office (FSDO) to discuss recreational and commercial drone regulations. The same airport also hosts quarterly unified ICP drills; they invite law enforcement and fire departments from the surrounding five jurisdictions, intelligence agencies, federal agencies, airlines, and airport divisions to participate. It gives stakeholders an opportunity to run through the basics (ICP vehicle setup, establishing objectives, communication, and relationship building) in a no-fault environment. This airport has found this AEP practice to be of great value. All airports participating in interviews stated they shared their AEPs with other airport departments, airline partners, government agencies, and other stakeholders where applicable. Airports strove to think âoutside the boxâ and were very proactive in the way they communi- cated the plans to partners. Most agreed meeting in person was most effective but also identified alternative means for communicating the plans. Airports have a significant number of partners who not only need access to the plans but need to understand their roles and responsibilities during an emergency. This is best communicated in person to allow for a dialog and ensure understanding. Airports took different approaches to this, including group presentations, road shows, and working groups. In the road show approach, EMs went to the stakeholderâs location and met with them directly. Alternatively, working groups allowed for group conversation, feedback, and requests for changes. Tours of airport EOCs, sites for family assistance centers, and other critical locations also provided an opportunity for partners to better relate to and understand the information in the plan. One of the more successful methods for distributing AEP materials was to provide guides and checklists to stakeholders and partners. These documents are easy-to-read snapshots of the most important information stakeholders need to know. While not directly a part of the AEP, some airports in hurricane areas have applied similar measures with their hurricane plans. Other Partner Preparedness Plans There may have been a time where airports were considered âislands,â operating inde- pendently of outside organizations, but the interviews proved this is no longer the case. Every airport interviewed stated they work closely with their surrounding cities and counties, ensuring 50.00% 45.00% 40.00% 35.00% 30.00% 25.00% 20.00% 15.00% 10.00% 5.00% 0.00% Apps Checklists Photo Sharing Online Collaboration Tools Other Ways not Listed Figure 8. Question 26. Has the airport enlisted any innovative tools to help with the plan, response, recovery, or general knowledge share of the document? (Source: SurveyMonkey results)
34 Practices in Airport Emergency Plans plans are integrated. They have worked to âdeconflictâ discrepancies, while communicating needs and expectations. Most have also developed COOPs or BCPs, which have been included in their local city or county COOPs. Airports also participate in local and state EM planning meetings and committees, with a focus on mass casualty plans being a common thread. Several airports participate in their local areaâs THIRA process and plan development. The ProofâTraining, Testing, and Validation A plan is a living document, constantly changing with each exercise or real-world event. Infor- mation or guidelines that were relevant or accurate in one version may be obsolete in the next iteration. And a plan is only as good as the accuracy of its information. Training stakeholders is the first step for thorough integration of the concepts and principles outlined in the AEP, annexes, checklists, and SOPs. Testing a plan through regular exercises, drills, and workshops validates a plan and keeps it sharp, ensuring it remains an effective tool to guide response actions during an emergency. It is standard practice to train and exercise a plan once it has been communicated. Airport EMs were asked about their practices in this area and responses were mixed. Some only incorporated the AEP into exercises regulated by FAA part 139, preferring to focus on more comprehensive plans for other exercises, while others referred to the AEP for almost all of them. Currently, AEP training is required annually by all airport employees with a role in the emergency plan per Title 14 CFR 139.327, Self-Inspection Program (Federal Aviation Admin- istration 2009). This training usually falls outside of EM and is a part of a larger training program for employees working on the airfield, maintenance, and other critical roles. In addition, airport employees and stakeholders, primarily public safety and airline personnel, are required to annually review the AEP; however, this is not a formal training program. Many airports use a TTX to fulfill this requirement. All airports interviewed stated they provide training beyond the requirements mentioned above. Such training does not necessarily focus on the AEP. Instead, it is centered on an all-hazards approach or hazard-specific approach for critical threats, such as hurricanes and active shooter. Training is strongly focused on coordination, with topics on EOC opera- tions, policy group roles, and department or organizational responsibilities. Most airports also incorporate training on ICS into their program. Airport approaches to exercises appear to be similar, but there are variances. There are two exercises focused on the AEP that are required by the FAA; the annual review, usually in the form of a TTX and a triennial full-scale exercise. For some airports, these are the only times they exercise the AEP. Like training, several airports prefer to take a more comprehensive approach to exercises, focusing on recovery and continuity of operations, for example. They may also exercise an SOP or standalone plan developed for a critical hazard. At least one airport indicated their belief that they should increase the amount of AEP-based exercises and were integrating this into their program and practices. The Mobile EOC is used during the airport emergency exercise Source: Michael Tobin, CLT
Current Airport Emergency Plan Practices 35 Of the airports who responded to the survey, 56% have had an opportunity to test and validate their plans using a combination of seminars, workshops, tabletops, games, drills, functional exercises, and full-scale exercises. All (100%) conducted AARs after exercises or significant events. This AEP practice appears to be universal and demonstrates a successful practice across the industry. Most respondents implement a standard AAR/IP process that begins with a hotwash and then a debrief meeting and roundtable discussion resulting in a list of corrective actions that are documented in an AAR with assigned tasks and deadlines for completion, including any necessary changes made to the AEP. Discrepancies are documented and corrective action plans established with specific tasks assigned to specific individuals with specific deadlines. One respondent said their AAR process consists of an executive-led discussion of their obser- vations, with input encouraged from some stakeholders. Another respondent provided a log, commonly known as ICS Form 214, to all exercise participants. This allowed participants to capture information that feeds into AARs. Another airport designed exercises that focused on the basics of a response. Exercises were designed to make participants look at the specifics of what they would be doing at the time to ensure no detail was overlooked. Another respondent pointed out that AARs have been used to modify procedures and learning tools but not to amend the AEP âbecause of the current general nature of the AEP.â Inspection Feedback Some respondents throughout the survey asserted that the AEP as submitted to FAA to meet regulatory requirements is not useable for specific emergencies envisioned at the airport. Respondents state that it is too complicated or too generic; that it is not actionable, flexible, or realistic enough; and that it does not meet the needs of their particular airport. Despite these objections to the AEP, some airports report positive feedback from their FAA inspectors regarding their submitted AEPs. When asked what kind of feedback they have received from the FAA inspectors, respondents reported the following: âThat [the AEP] is innovative, extremely up-to-date, thoroughly researched, and collabora- tively created.â âThat [the AEP] is a great document and meets all of the requirements plus more.â âThe Southwest region has been very supportive of the AEP as written and the airportâs efforts in the development of the plan.â âPositive feedback was given, though 450 pages to stamp.â âThey allow us to distribute the AEP electronically to stakeholders.â â[The AEP] meets the requirements of the FAA.â âSolid documentâin 4 years, no recommended changes.â âWe have not received any feedback specifically about our AEP. We did have an inspector tell us that we should conduct more tabletop exercises; hence why we conduct one every other month.â Lessons Learned Analysis of lessons learned is a significant part of an AAR. Some survey respondents said lessons learned have been incorporated into the AEP or annexes with others indicating they had not. Some lessons learned are incorporated into the AEP shortly after postexercise debrief,
36 Practices in Airport Emergency Plans while others are included in the AEP revisions and submitted with the next annual update. When asked how they have been incorporated, respondents gave the following replies: âWe update and change the plan after major mitigation plans have been created and/or when new major initiatives have been put into place to close a gap.â âUpdated our Communicable Disease Plan, Evacuation Plan, and Fuel Farm Fire Plan.â âIt appears to be too much of a âliftâ to make the wholesale changes to the AEP, so we incorporate them into other, more functional plans.â âThe few updates that have occurred were token changes; none of the needed major updates have been made.â âTasks were moved to more appropriate areas.â âLessons learned get captured by all AEP review stakeholders as the year progresses, including Emergency Preparedness as the coordinator of this processâand they get woven into the AEP as appropriate. Some do not, as they are too tactical. But they are generally referenced in the AEP [document] (just not duplicatedâthe AEP points to underlying plansâbut does not repeat them).â âAdditions of new hazard-specific sections such as Active Shooter.â Every airport interviewed had a method for ensuring lessons learned were incorporated into plans. Airports did point out lessons learned were often written into other plans or resulted in the creation of an entirely new plan. However, there were times when changes were also made to AEPs and/or annexes following an exercise or real-life event. This was another area where traditional EM practices influenced airport practices. Many airports have a formal process in place to ensure updates take place. Airports develop AARs following an event to capture strengths and challenges and identify areas for improve- ment. Some airports created working groups, responsible for tracking improvement items, ensuring changes take place, and including changes in future plans. What Would Airport Respondents Change About the AEP? When asked in Question 41 what respondents would change about the AEP and how they would do it, responses repeated or confirmed statements made in other sections of the survey. Question 42 asked how they believe those changes would improve emergency response at airports. Responses continue to include making the plan smaller and more manageable. However, again, respondents have overcome this enduring challenge by creating checklists from AEP information and quick reference guides for stakeholders to use during a response. Other thoughts include allowing the AEP to be more in line with, or mirror, local emergency plans such as emergency operations plans (EOPs) or use the established EM planning process (as outlined in the Comprehensive Preparedness Guide 101), THIRA process, or the National Fire Protection Association 1600. Other responses include changing how the airport manages the AEP to include having the EM office or department (if one is at the airport) manage the AEP throughout the life cycle.