Analysis: Impact of A.C. 31C

The changes, issues related to FAA rewrite


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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