Beyond the Regulations: Airport Emergency Planning

Feb. 22, 2018

Airports in many ways operate much like a small city. Infrastructure and resources must be in place to support the safe and efficient movement of aircraft, people, cargo and fuel, and all of them must work together as a symphony. As conductors of that symphony, airport operators are tasked with ensuring safety, security and business continuity in a dynamic operating environment.

No day is routine at an airport and operators must be adequately prepared to respond and recover if the symphony is interrupted. Major emergencies in this environment tend to be low frequency, high impact events with a heavy reliance on rapid response and continuity of operations. If an airport operator’s response is poorly planned, even small incidents have the potential to have a major life safety and financial impact to the surrounding community, aircraft operators and the national airspace system.

According to the Federal Aviation Administration (FAA), airports may be classified as general aviation, small, medium or large hub commercial service, non-hub, primary or reliever. Even to a longtime airport professional, these terms may be confusing. To those outside the industry, it may be easier to simply categorize an airport as small, medium or large- sometimes, really large. Regardless of the classification of airports, it would be reasonable to assume that the complexity and depth of emergency plans including the number of resources available would be based on its size. This assumption though, is not necessarily true for all airports.

For airport industry veterans, the adage "If you've seen one airport, you've seen one airport" is no doubt familiar. This phrase is intended to represent how distinctly different airports may actually operate from one another. Though airports share common goals of safety and efficiency in aircraft operation, how those goals are accomplished tend to be greatly affected by the unique type of aircraft operations specific to that facility.

The United States has an expansive aviation infrastructure system that is estimated to include over 20,000 airports, according to the FAA. Of these 20,000 facilities, roughly 500 are categorized as commercial service airports. Commercial service airports, according to the FAA are publicly owned facilities that have at least 2,500 passenger boardings each calendar year and receive scheduled passenger service. Commercial service airports are held to the most comprehensive level of standards for emergency planning and response by the FAA, requiring an FAA-approved airport emergency plan, yearly tabletop exercise of the plan and a full scale emergency exercise once every three years.

What about the other 19,500 airports in the U.S.? These facilities, made up of general aviation, cargo or corporate aircraft operations may be required to have an FAA approved emergency plan but do not necessarily rise to the level of compliance of a commercial service airport. In plain terms, a commercial service airport with 50,000 aircraft operations a year may be required by the FAA to have more stringent emergency plans, response guidelines and more resources than a general aviation airport with 250,000 aircraft operations a year. Despite fewer aircraft operations, one could conclude the more stringent requirement at commercial service airports is driven- at least in part- by the scheduled passenger service component.

A very relevant example of this difference comes from a look at the importance of a full-scale emergency exercise. At a commercial service airport, local fire, law enforcement, FAA, airport operations, maintenance and additional stakeholders are required to come together in a scenario once every three years to simulate the interagency response in a major aircraft emergency. Full-scale exercises, as defined by the Department of Homeland Security are “multi-agency, multi-jurisdictional, multi-organizational exercises that validate many facets of preparedness.” Yet, by regulation, less than 3 percent of airports fall under this mandate.

Let’s consider the real-life comparison of two busy airports. In the first example, airport A has 200,000 annual operations but is not categorized as a commercial service airport. Airport A also has an FAA-approved airport emergency plan but has no requirement to conduct a full scale emergency exercise. Less than 15 miles away, airport B also has 200,000 annual operations but is categorized as commercial service and therefore is required by the FAA to conduct a full-scale emergency exercise.

If a major aircraft accident involving a large aircraft occurs, and these airports only meet their minimum standard of regulation, airport A may find that first responders such as firefighters and medical response personnel are exchanging business cards and working on interoperability while attempting to put out flames and perform rescue operations. Airport B on the other hand, required to conduct a full scale drill would likely have had the opportunity to practice a “boots on the ground” response, allowing for adjustments to their plan for a better coordinated response during an actual emergency.

An aircraft emergency at any airport has the potential to significantly impact human life, surrounding communities and may carry large-scale financial impacts. Realistically, why should one airport be required to be more prepared than another?

This comparison is not a criticism of the FAA; far from it. The FAA’s oversight is far reaching. At an airport, FAA inspectors are responsible for ensuring airport operator compliance with federal regulation and are expected to have an in-depth level of knowledge of firefighting, fueling operations, snow removal, wildlife, public protection and emergency planning. The FAA is tasked with the difficult job of regulating airports that have a wide range of operating environments, budget constraints and resources.

Instead, this is a call to airport operators to think beyond the regulatory minimum, and develop a comprehensive emergency response program. Airports, regardless of size are likely to be quickly overwhelmed for resources during an emergency. Airports may be best served to plan for emergencies as practical, based on likelihood and overall impact, not simply based on regulatory standards. This assumption may be used in the planning process to explore how facilities may draw upon local and federal level resources for coordination and assistance.

While it is undoubtedly easier to create effective emergency plans with adequate funding and in-house resources, by engaging existing resources such as local fire, law enforcement and other stakeholders, and utilizing known planning assumptions, airports may build relationships and strengthen interoperability plans, finding themselves successfully planning for and managing emergencies, beyond the regulations.

Charity Catalfomo is the Safety and Security Manager at one of the nation’s busiest primary non-hub airports . Charity is responsible for emergency planning and works closely with fire, law enforcement, airport operations ,local and federal agencies. Her background includes airfield operations  and maintenance at a large hub airport and a Master’s degree in Emergency Management.