Analysis: Impact of A.C. 31C

The changes, issues related to FAA rewrite

For U.S. airports, the primary guidance for emergency preparedness is FAA Advisory Circular 150/5200-31C, Airport Emergency Plans. A.C. 31C has three objectives:

  • The format and organization of information in the airport emergency plan (AEP).
  • Provisions for the systematic approach of determining all hazards that warrant emergency preparedness.
  • Involvement of local communities, State organizations, and Federal agencies in emergency management and preparedness so that their expertise and resources are incorporated to the mutual benefit of all parties.

Following is a discussion of the Federal Aviation Administration’s recent rewrite of the A.C.

A.C. 31C was the result of a ten-year evolution from 31A, the prior fully approved guidance for AEPs. During 1999-2009, major events changed the nation’s approach to emergency management. The major nationwide changes were the adoption of an all-hazards approach, the adoption of the National Incident Management System (NIMS) and Incident Command System (ICS) for all federal agencies and federally funded activities, and the extension of emergency planning to communities, regions, and the nation.
In general, the nation’s aviation critical infrastructure had lagged behind nearly all other sectors in adopting all-hazards, NIMS/ICS, and a community orientation to emergency and disaster preparedness. A.C. 31C represents the application of these trends to airports and is intended to bring a major part of the aviation critical infrastructure into compliance with national policy. In no way is 31C intended to diminish the traditional primary emphasis on safety of operations.

Nine contingencies
A.C. 31C contains an AEP template that all certificated (Part 139) airports, commercial and military, must follow. Other airports may use an alternative method so long as it meets the basic requirements of 14 CFR 139.325, which requires every certificated airport to have an AEP that explicitly addresses nine contingencies:

  • Aircraft incidents and accidents;
  • Bomb incidents, including designation of parking areas for the aircraft involved;
  • Structural fires;
  • Fires at fuel farms or fuel storage areas;
  • Natural disaster;
  • Hazardous materials/dangerous goods incidents;
  • Sabotage, hijack incidents, and other unlawful interference with operations;
  • Failure of power for movement area lighting; and
  • Water rescue situations, as appropriate.

This analysis seeks to answer how the all-hazards approach of 31C changes or extends this list and what airports need to do to comply with the new requirements. A.C. 31C requires compliance by all certificated airports within one year — by June 19, 2010.

Summary of Changes Required
Most of the changes incorporate NIMS and ICS. At each point in the advisory circular, the specific NIMS/ICS requirement is specified and there is a link to the specific website containing national guidance — for example, DHS and White House links for HSPD-8 and the National Framework Plan. Throughout the circular, examples of organizational structure compliant with NIMS/ICS have been added. NIMS and ICS training resources have been added with links. The scope of functional services and responsibilities have been enhanced and aligned to the requirements of public law, national standards, and recently revised advisory circulars.

Hazard-specific details required by 14 CFR 139.325 have been revised to incorporate essential response actions and match the all-hazards approach of national emergency and disaster guidance.

The templates for mutual aid agreements have been refined to incorporate both lessons learned under 31A and the new concepts of NIMS/ICS and all-hazards. The revised mutual aid agreements reflect to a far greater extent the mutuality of roles of airports and their communities.

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