Analysis: Impact of A.C. 31C

The changes, issues related to FAA rewrite


The intent is to promote the 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 citizens and stakeholders. A.C. 31C requires the airport to consult with the local emergency management officials regarding the community’s emergency plan review cycle and to synchronize the processes. And 31C, like 31A, requires annual tabletop and triennial full-scale exercises involving community partners. The A.C. also urges by implication the aggressive use of after action reviews (AARs) of actual incidents to evaluate and improve AEPs.
Last, the appendices for definitions, acronyms, and references have been expanded, upgraded, and provided with verified website links.

What Remains the Same
The basics of 31A remain unchanged. 31C still sets the format and organization of information in the AEP and requires them to be followed explicitly by certificated airports and used as a guide for non-certificated airports. A.C. 31C still requires a systematic approach to planning for and implementing emergency preparedness at airports and in the zone immediately around them. The aspects of community involvement in 31A are sustained but expanded. 31C’s subordinate relationship to HSPD-5, HSPD-8, and other national guidance is the same as 31A; 31C amplifies and gives specific models but does not contradict them.

Issues to consider
Several airport operational concerns that are now getting special attention intersect with AEPs but probably lie outside the immediate scope of 31C. These areas are communicable disease (or pandemic) planning, wildlife planning, and Safety Management Systems (SMS).

Pandemic planning will probably end up being subsumed as part of AEPs under 31C; but for now, the urgency of H1N1 flu entry and exit screening at airports and in airport-community relations is pushing local pandemic plans ahead of AEP revision, in most cases.

Nothing in 31C will complicate the reintroduction of the new pandemic plans into 31C-compliant AEPs. However, it will be important that the health and aviation establishments work together to build NIMS/ICS into the special plans so they will be compliant when eventually added back into the AEPs.

Similarly, FAA is pushing wildlife plans as an item of special emphasis, and there are special criteria for the planners who can do wildlife plans. Unlike pandemic plans, upgraded wildlife plans are unlikely to become routine parts of AEPs. Wildlife management is much more of a daily event. While a significant strike might create an emergency situation, it is a housekeeping issue the majority of the time. There is no reason why it would be shifted under the emergency header as part of an AEP. It is far more likely that the issue of wildlife management will migrate to the SMS process than to the AEP program.

Safety Management Systems (SMS) are a very different issue. They are a fast-evolving type of plan at airports. SMS is likely to become the standard for the prevention of accidents, injuries, and emergencies at airports. However, that very focus on prevention interacts with the almost total focus of AEPs on emergency response to make the merger of AEPs and SMSs unlikely and probably very undesirable. Their objectives are non-overlapping, and so is their degree of dependence on NIMS/ICS.

Action by Airports
Regarding compliance, commercial airports are at all stages, from having made no changes to full compliance with 31C. Miami International Airport, for example, is already in full compliance. Large hub airports and some medium hubs have in-house capabilities that can handle all or most plan revisions for 31C, particularly if they engage their ARFF chiefs, police chiefs, security directors, operations managers, and, where present, emergency managers in all stages of the AEP planning process.

Smaller airports and nearly all general aviation airports depend on consultants to update their plans. General aviation airports are not likely to be 139 certificated airports by definition.

Therefore, it is unlikely that any of them will develop full-blown AEPs under the guidance provided by FAA, even if they are grant recipients. They may, if they are linked to a larger 139 airport in a multi-facility governance unit, have a “lite” version such as Jackson-Evers International Airport has for Hawkins Field. Only a very large, very active reliever GA is likely to have a significant AEP, and the lead role for NIMS/ICS may be taken by a mutual aid partner.

The first step for any airport is to meet with its FAA certification inspector on timelines and specific expectations. The revised AEP will eventually have to be signed by this inspector, so the process should be proactive.

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