Analysis: Impact of A.C. 31C

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.

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.

Second, the airport should use either its internal staff or a consultant to audit its current AEP to identify areas requiring amendment or expansion to comply with 31C. This will include all-hazards, NIMS/ICS implementation, and community interaction. It may also include other areas of the AEP that need to reflect structural, organizational, procedural, or operational changes since the last review. This audit should produce a list of specific changes and suggested individuals or groups to draft the changes.

With the audit in hand, the airport’s AEP planning team — operations, safety, security, ARFF, police, and emergency management — or consultant should begin developing the revised plan components. Ideally, this process will involve stakeholder interactions within the airport and between the airport and its community. Plan development should carefully examine the implications for staffing, space, training, drilling, and exercising and impacts of the revisions being considered. One needs only to look at recent pandemic planning efforts to see how dependent effective plans are on cold-eyed evaluation of staff, space, and training resources.

Mutual aid pacts have been required to be in AEPs since 31A, but no specific requirement for NIMS/ICS interoperability and joint training, drilling, and exercising requirement was included prior to 31C. Fortunately, it has been a very common practice to include these features at nearly every airport, even if they are not written in existing AEPs. One of the most productive actions that an airport can take at this point is an aggressive review of all mutual aid pacts, seeking ways to improve their provisions and the underlying relationships with community and private assets.

Development of each component of the revised AEP will be an iterative process. The draft must be tested against physical, organizational, and fiscal realities. Once a stable AEP is achieved and has been approved by the airport and FAA, it must be maintained as a live document through annual reviews, active training, and good communication with mutual aid partners and other stakeholders.

Since AEPs are required to be reviewed annually, the revisions to comply with 31C should be relatively easy and inexpensive except in one regard. If an airport has deficiencies in its relationships with mutual aid partners or with community agencies or organizations that should be stakeholders in disaster response, the revisions to the airport’s AEP will probably involve serious commitments of attention by airport management and time for meetings.

About the Author

Jim Smith is a professor at American Public University System and president of Smith-Woolwine Associates. He may be reached at jfsmith@swva.net or (540) 763-3068.

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