Airport Emergency Planning

Through my career I’ve had the opportunity to work with a number of airports on preparedness efforts.  In the past couple of years, that interaction has been greatly amplified through a contract my company successfully completed involving the development of exercises for airports.  As part of this effort, we designed, conducted, and evaluated exercises at ten airports of varying sizes across the nation, from Georgia to Alaska, Massachusetts to California.  Since the primary intent of exercises is to validate plans, we of course requested and reviewed airport emergency plans (AEPs) from each location as part of our preparation for each exercise.

For those not in the know, the requirement for AEPs originates with Federal Aviation Regulation 14 CFR Part 139, which wholly establishes the standards for the certification of airports.  The requirements for AEPs are further refined in DOT/FAA Advisory Circular 150-5200-31C published in May of 2010.   The Advisory Circular is largely implementation guidance.  It’s quite comprehensive and outlines a planning structure, references emergency management doctrine and standards of practice such as NIMS and the National Response Framework, and models a planning process, which mirrors that of CPG-101.  The NFPA also provides guidance in NFPA 424: Guide for Airport/Community Emergency Planning, which reflects on all these as well.

Just like any community emergency operations plan (EOP), AEPs I’ve reviewed run the full spectrum of quality.  Some plans are thorough and comprehensive, while other plans are so focused on meeting the letter of the regulation that they fall short of meeting real needs and being implementation-ready, even though they technically meet the requirements set forth in §139.325.  Regulated industries, which airports largely are, often have a challenge when it comes to emergency planning.  We see this same challenge in radiological emergency plans as well.  The laws and regulations seem to provide so much structure that it is perceived that local variables and subjective analysis aren’t allowed.  As an example, §139.325 states:

“the plan must contain instructions for response to:

  1. Aircraft incident and accidents
  2. Bomb incidents, including designation of parking areas for the aircraft involved
  3. Structural fires
  4. Fires at fuel farms or fuel storage areas
  5. Natural disaster
  6. Hazardous materials/dangerous goods incidents
  7. Sabotage, hijack, or other unlawful interference with operations
  8. Failure of power for movement area lighting
  9. Water rescue situations (as appropriate)”

While the planning process isn’t prescribed in §139.325, nor does it specify if other hazards can be included in the AEP, the Advisory Circular (AC) does expound on this and prescribes a planning process, including a hazard analysis.  The AC states “Through the hazards analysis program, guidance has been provided to assist in the identification of those hazards and disasters specific to an airport that warrant planning attention”.  That phrasing indicates that airports should be planning for hazards beyond what is required by §139.325, yet I’ve seen many that do not.

Obviously ‘natural disaster’ covers a considerable amount of proverbial territory.  Jurisdictions undergo extensive hazard analysis and hazard mitigation planning to identify the breadth and scope of these hazards (which should include all hazards, not just natural disasters).   Many jurisdictions develop very comprehensive EOPs and annexes to address the response needs of each of their primary hazards.  I saw this as a significantly missing component in many AEPs, which treated ‘natural disasters’ as a single hazard.  Further, as many airports stick to the minimum requirement for planning, they fail to address other hazards which could impact them, ranging from dam failure, and nuclear power facility incidents, to currently hot topics such as active shooter/hostile event response (ASHER) and communicable diseases.

Some airports have thankfully recognized the need for expanding beyond the required hazards and have developed plans that better address all of their needs.  On the unfortunate side, again as a regulated industry, I’ve also seen some airports having two sets of plans… one that meets regulation and the other that they feel is more practical for implementation.  Clearly this isn’t the way to go either.  A single, consolidated plan can be developed that meets all needs.

Airports are an interesting animal.  Regardless of governance structure, they are part of the communities which surround them.  Larger airports are also communities of their own, having significant capability, sometimes more than the surrounding jurisdictions.  Airport emergency planning should acknowledge and involve their community relationships and must address all hazards, not just the ones required by Part 139.  Just as with any other type of emergency plan, they must be implementation-ready.  To do so typically requires the added development of standard operating guidelines (SOGs) and job aids, such as check lists and forms.  Plans should also be developed to address recovery issues and business continuity, not just response.  An airport, regardless of governance structure, operates like a business, with many other stakeholders dependent upon their stability and ability to address and rapidly recover from incidents.  They are also obviously transportation hubs, dealing with large volumes of people and significant dollar figures in freight and commerce.

Airport emergency managers have many of the same challenges as the emergency managers of any other community.  Staffing and funding rarely line up with requirements and other priority matters.  I encourage community emergency managers to reach out to their local airports and coordinate, as many hands make easier work for everyone.  Of course, if any airports are seeking assistance in enhancing their preparedness, please contact us as we would love to work with you!

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC™

 

 

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Emergency Management and Succession

Earlier this month, Emergency Management Magazine posted an article by Jim McKay titled ‘Is a Lack of Institutional Knowledge Plaguing Emergency Management?’.  It’s a thought-provoking article on a topic that is relevant to a great many professions.  This is an issue that deals primarily with retirements, but broadly any matter that involves a line of succession.  Not only might someone retire, which is usually, but not always an anticipated event, but they may take or get transferred to a new position, require an extended sick leave, get fired, or even have an untimely death.  In any event, I’m a firm believer that succession should be planned for any situation, and for nearly every position – especially one that’s grown and evolved over time with the individual occupying that position.

If it’s anticipated that someone will be retiring or otherwise leaving, organizations may have the ability to hire or identify a replacement while the person is still there, providing an opportunity for a mentorship.  For as rare as this is, it’s even more rare for that mentorship to be structured or anything but throwing a bunch of paperwork, files, and brain-dumping knowledge at the replacement.  If the departure of the individual isn’t planned, the organization can be left in the lurch.  People hopefully know what that person does, but likely not how they do it.  What are the priority tasks?  How often do they need to be completed?  What is the standard of performance for these tasks?  Who are the primary contacts?  Where can critical files be found?  What do I do if…???

Organizations have an opportunity to hedge against this.  Just as we prepare for disasters, we can prepare for someone vacating a position.  We know it will inevitably happen, so there is no excuse to not prepare for it.  Organizational leadership should promote this effort, spearheaded by human resources.  Checklists and guidance should be developed that cover all aspects of transferring institutional knowledge – from the mundane and practical, to the applied work.  This is a deliberate effort, just like developing an emergency operations plan, and an effort that nearly all positions should be involved in.

For a planned departure, two viable options are a job-share or a structured mentorship.  Both obviously require the organization to commit to overlapping staffing for this position for a period of time since the outgoing and incoming individuals need to work together.  This provides the most effective means of transferring institutional knowledge.  As indicated earlier, these efforts need to be structured, not just a daily data dump.  Use the ‘crawl, walk, run’ concept, giving the incumbent foundational information at first and building from there.  While process is important, there may be some processes that really fall to individual style, so the focus should be more on intent, sources of information, deliverables, and collaboration.  Hands-on experience, as many of us know, is extremely valuable.  The new individual should be going to meetings with the outgoing person, conducting site visits, and participating in other activities.  This also offers an opportunity for introductions to be made to important colleagues and other contacts.

The incumbent should also have face time with their new boss, direct reports, and other interested parties.  This is important to ensuring that expectations of these important stakeholders are communicated directly to the person who will be working with them.

An important tool that should be developed by almost every position is a job book.  This is a written document that outlines every critical aspects of a position.  Starting with the job description and working forward from there.  Fundamentally, this is a simple task, but can take some time over a period of months to develop, and of course it should be kept up to date.  It should identify priority tasks and how they are accomplished, key interactions and contacts, reporting relationships, standards and templates, information sources, deliverables, and due dates.  Each individual should step outside their position and imagine that someone new, who knows little about the position, will walk in tomorrow to take over.  This document should take that person through all important tasks.

The job book has several benefits.  First, it helps provide structure to any possible mentorship or job share that might take place for a planned departure.  It strongly supports an unplanned departure as well as an organization that might not be able to provide for any type of overlap between the outgoing and incoming individuals.  Job books are something I recommend not just for managers, but for most staff, even administrative support staff – It’s amazing how many organizations come to a screeching halt when a key administrative specialist leaves.

Lastly, beyond the process-driven and official things, never underestimate the value of social interactions.  There is a great deal of knowledge transfer that comes from the time of enjoying a meal or a beverage with someone.  While this time might be ‘off the books’, it should absolutely be encouraged and shouldn’t be a single occurrence.  These offer good opportunity for some ‘war stories’ and open conversations outside of the office environment in which a great deal can be learned.

Bottom line – organizational succession should be viewed as an aspect of continuity of operations.  It requires planned and deliberate activities to be most successful.

What kind of program does your organization have?

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC™

Expanding Hazard Mitigation Plans to Truly Address All Hazards

Planning efforts and documents are incredibly central to everything we do in preparedness.  When we look at the spectrum preparedness elements of Planning, Organizing, Equipping, Training, and Exercises (POETE), ‘planning’ being first should be a reminder that everything goes back to planning.  Our organizations, equipment, training, and exercises should all reflect back on plans.  These aren’t just emergency operations plans, either, but should include all plans.

A fundamental plan for many jurisdictions is the hazard mitigation plan.  Most responders tend to ignore this plan as it’s not about response, but it has a great deal of valuable information.  Hazard mitigation plans are built on a lot of research and data analysis, trends, and science behind a variety of hazards that could impact the area.  For as much as hazard mitigation plans can get neck-deep into science, they are not only good references but can be built into good, actionable plans.  The leadership of practically every agency in a jurisdiction should be involved in the development and update of hazard mitigation plans and be knowledgeable of what they contain.  That said, there are a couple of issues I have with how hazard mitigation plans are done.

First of all, they should be developed to be more than a catalog of information, which is how many are built.  We should be able to do something with them.  FEMA’s standards for hazard mitigation planning have gotten better and better through the years, thankfully.  While their standards include the identification of potential projects for a jurisdiction to address hazards, I’ve seen many plans (and the firms that develop them) cut this section particularly short.  I’ve seen plans developed for major jurisdictions having only a handful of projects, yet I’ve had experience developing plans for much smaller jurisdictions and identifying a significant list of prioritized projects.  While the onus is ultimately on the stakeholders of the jurisdiction to identify projects, consulting firms should still be actually consulting… not just regurgitating and formatting what stakeholders provide them.  A good consultant will advise, suggest, and recommend.  If your consultant isn’t doing so, it’s probably time to find someone else.

The second issue I have with hazard mitigation plans is that so many truly aren’t ‘all-hazard’.  Many hazard mitigation plans address natural hazards and some human-caused hazards, such as damn failures and hazardous materials incidents.  Rarely do we see hazard mitigation plans addressing hazards such as cyber attacks or active shooter/hostile event response (ASHER) incidents.  There are some obvious issues with this.  First, the hazard mitigation plan is generally looked upon to have the best collection of data on hazards for the jurisdiction.  If it excludes hazards, then there is no one good place to obtain that information.  This is particularly dangerous when other plans, such as EOPs, may be based upon the hazards identified in the hazard mitigation plan.  As I mentioned at the beginning, if something isn’t referenced in our planning efforts, it’s likely not to be included in the rest of our preparedness efforts.  Second, if these other hazards aren’t in our hazard mitigation plans, where are we documenting a deliberate effort to mitigate against them?  While hazards like cyber attacks or ASHER incidents are generally seen to be mitigated through actions labeled ‘prevention’ or ‘protection’, they should still be consolidated into our collective mitigation efforts.  Those efforts may transcend traditional hazard mitigation activities, but why would we let tradition impede progress and common sense?  A fire wall should be listed as a hazard mitigation project just as flood control barrier is.  And bollards or large planters are valid hazard mitigation devices just as much as a box culvert.

Let’s be smart about hazard mitigation planning.  It’s a foundational element of our comprehensive preparedness activities.  We can do better.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

NIMS Alert: NQS Qualifications and Task Books for Recovery, Mitigation, and Incident Evaluation

The National Integration Center (NIC) has been busy with developing more National Qualification System (NQS) tools for incident management.  Here are the titles for the latest release open to public comment:

  • Damage Assessment Coordinator
  • HM Community Education and Outreach Specialist
  • HM Community Planner Specialist
  • HM Engineering and Architect Specialist
  • HM Floodplain Management Specialist
  • EHP Environmental Specialist
  • EHP Historic Preservation Specialist
  • Incident/Exercise Evaluator
  • Public Assistance
  • State Disaster Recovery Coordinator

There may be some incident management and response purists out there wondering why they should care about these particular titles.  I’ll agree that most of them aren’t used in a life-saving response capacity, but these are the people you want to have backing you up – otherwise you may never get away from the incident and you will find yourself in a very foreign land where complex requirements from FEMA and other federal agencies are the rules of play.

Having worked disaster recovery for some massive incidents, such as Hurricane Sandy, I can personally attest to the value so many of these people bring to the table.  It’s great to see qualification standards being established for them, just as they are for core incident management team personnel and resources.  While my experience with most of these is ancillary, however, I’ll leave specific commentary on them to those functional experts.

There is one role in here that I’m particularly pleased to see and will comment on, and that’s the Incident/Exercise Evaluator.  I wrote last year on this topic specifically and have reflected on its importance in other posts.  I see the inclusion of an Incident Evaluator in the NQS as being a huge success and the beginning of a conscious and deliberate shift toward evaluation and improvement in what we do.  Looking at the resource typing definition, I’m pretty pleased with what the NIC has put together.

What I like… I appreciate that they include a note indicating that personnel may need additional training based upon the nature or specialization of the incident or exercise.  They include a decent foundation of NIMS/ICS, exercise, and fundamental emergency management training across the various position types (although most of these are FEMA Independent Study courses -which I think are great for introductory and supplemental matter, but shouldn’t be the only exposure personnel have), including a requirement of completion of the Homeland Security Exercise and Evaluation Program (HSEEP) for a Type 1.

What I feel needs to be improved…  Considering that the Type 1 Incident/Exercise Evaluator is expected to lead the evaluation effort, I’d like to see more than just HSEEP training being the primary discerning factor.  Just because someone has completed HSEEP doesn’t mean they can plan a project, lead a team, or extrapolate HSEEP exercise evaluation practices to be effective for incident evaluation.  I suggest HSEEP should be the requirement for the Type 2 position (which would correlate well to the position description), with additional training on project management and leadership supporting the Type 1 position.  While the note is included re: the potential need for additional training, there is nothing in this about operational experience, which I think is rather important.  Lastly, this seems to identify a need for course and/or guidance specific to incident evaluation, which can and should use the principals of HSEEP as its foundation, but identify the differences, best practices, and approaches to applying them to an incident or event.

I’d love to hear your thoughts on incident evaluation as well as the other positions being identified in the NQS. Do you participate in the national engagements and provide feedback?

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC™

 

 

FEMA’s 2017 Hurricane Season AAR

A few days ago, FEMA published its after action report (AAR) for the 2017 hurricane season.  Unless you’ve been living under a rock, you probably know that last year was nothing short of devastating.  The major hurricane activity revolved around Hurricane Harvey (Texas), Hurricane Irma (Caribbean/South Atlantic coast), and Hurricane Maria (Caribbean), but domestic response efforts were also significantly dedicated to a rough season of wildfires in California.  While each of these major disasters was bad enough on its own, the overlap of incident operations between them is what was most crippling to the federal response.  Along with these major incidents were the multitude of typical localized incidents that local, state, and some federal resources manage throughout the year.  2017 was a bad year for disasters.  I don’t think any nation could have supported disaster response as well as the US did.

No response is ever perfect, however, and there were certainly plenty of issues associated with last year’s hurricane responses. Politicians and media outlets made issues in Texas and Puerto Rico very apparent.  While some of these issues may rest on the shoulders of FEMA and other federal agencies, state and local governments hold the major responsibility for them.

This FEMA AAR contains good information, perspective, and reflections.  There are a lot of successes and failures to address.  While I’m not going to write a review of the entire document, which you can read for yourself, but I will discuss a few big-picture items and highlight a few specifics.

First, is the overall organization of the document.  The document is organized through reflection across each of five ‘focus areas’.  I’m not sure why this was the chosen approach.  The doctrinal approach should be a reflection on Core Capabilities, as outlined in the National Preparedness Goal.  Some of these focus areas seem to easily align with a Core Capability, such as ‘Sustained Whole Community Logistics Operations’, which gives me reason to wonder why Core Capabilities were not referenced.  While we use Core Capabilities as a standard in exercises, the purpose for them being part of the National Preparedness Goal is so that we have a standard of reference throughout all preparedness activities.  Any AAR – incident, event, or exercise – should bring us back to preparedness activities.

The second issue I have with the document is the focus.  While it’s understood that this is FEMA’s AAR, not a wholistic federal government AAR, it’s almost too FEMA-centric.  The essence of emergency management is that emergency management agencies are coordination bodies, as such, most of their work gets accomplished through coordinating with other agencies.  While it’s true that FEMA certainly has a significant work force and resources, the AAR seems to stop at the inside threshold of FEMA headquarters, without taking the additional step to acknowledge follow-on actions from a FEMA-rooted issue that may involve other agencies.

Among the positive takeaways were some of the planning assumptions outlined in the report.  There is a short list of planning assumptions on page 9, for example, that provide some encouraging comparisons between planning assumptions and reality.  This is a great reminder for local and state plans to not only include numbers and percentages in their planning assumptions, which will directly lead to identifying capability and resource gaps, but to also reality check those numbers after incidents.

Page 10 of the repost highlights the success of FEMA’s Crisis Action Planning groups.  These groups identified future issues and developed strategies to address these issues.  This is actually an adaptation of an underutilized function within the ICS Planning Section to examine potential medium and long-term issues.

Pages 11 and 12 highlight how Threat and Hazard Identification and Risk Assessment (THIRA) data from states and UASIs can inform response.  It’s encouraging to see preparedness data directly inform response.  I hope this is something that will continue to evolve.

Pages 22 and 23 discuss the staffing issues FEMA had with massive overlapping deployments.  Along with their regular full time workforce, FEMA also deployed a huge volume of their cadre personnel.  They also tapped into a pilot program called State Supplemental Staffing.  While there were some administrative and bureaucratic difficulties, it seems to have been considerably successful.

Overall, this is a good document citing realistic observations and recommendations.  While the document is FEMA-centric, the way of FEMA is the way of emergency management in the US, so it’s always worth keeping an eye on what they are doing, as many of their activities have reach to state and local governments we as other federal agencies.

What important concepts jumped out at you?

© 2018 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC™

No Standards for Armed Teachers in Colorado

No matter what side you fall on in the debate on arming teachers, I think most people can agree that if teachers are to be armed, there should be some standards.  Apparently, Colorado law makers don’t think so.

Whenever giving someone the ability to handle a deadly weapon, especially as part of or sanctioned by their employer, there should absolutely be some standards in place.  To name a few:

  • What kind of weapon is allowed?
  • Are there any conditions in which that weapon cannot be carried?
  • Can the weapon be secured on the premises?
  • What are the rules for use of the weapon?
  • Does the person have to register their possession of the weapon?
  • What initial and refresher training requirements are in place?
  • Who is responsible for maintaining training and other records?
  • Who carries the legal liability?
  • Are mental health checks required?
  • What procedures are in place for reporting an incident involving the weapon?
  • What procedures are in place if the person is accused of a violent offense outside of work?

As the article cites, and as most of my readers are likely familiar, law enforcement officers and military personnel participate in many hours of fire arms training.  Before a weapon is even put into their hands, they are schooled on the components of their weapon, rules for use of force, and firearms safety.  On the range, safety discipline is paramount.

It’s not to say there aren’t any standards being put in place by these school districts in Colorado.  Many of them may be addressing all of these questions and more.  Unfortunately, there is a lack of consistency, since, as special districts, they are empowered to self-govern in many aspects (this is similar in most, if not all states).  The lack of statewide standards leaves a lot of room for gaps and liability, and, regardless of altruistic intent, can potentially endanger not only students, but first responders as well.

From a public safety perspective, I encourage local law enforcement, fire service, EMS, and emergency management to coordinate with their school districts (they should be anyway) if they are allowing their teachers to be armed.  Don’t only encourage policy, procedure, and standards to be in place, but press hard for it and offer to be involved.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC™

Changing The Lexicon on Terrorism Preparedness, Response, and Recovery

A couple months ago I posted about NFPA 3000: Standard for Active Shooter/Hostile Event Response Program.  Soon after posting, I ended up purchasing a copy of the standard and, combined with other readings and discussions, am fully bought into not only this standard but a change in our lexicon for this type of incident.

NFPA3000

First off, in regard to NFPA 3000, it’s not rocket science.  There is nothing in this standard that is earth shattering or itself wholly changing to what we do or how we do it.  But that’s not the intent of NFPA standards.  NFPA technical committees compile standards based upon best practices in the field. The standards they create are just that – standards.  They are a benchmark for reference as we apply the principles contained therein.  NFPA 3000 provides solid guidance that everyone in EM/HS should be paying attention to.

What NFPA 3000 has helped me realize is that our focus has been wrong for a while.  Terrorism isn’t necessarily the thing we need to be preparing for.  Why?

First, let’s look at what is generally referenced definition of terrorism in the United States.  This comes from Title 22 Chapter 38 US Code § 2656f.  It states that terrorism is “premeditated, politically motivated violence perpetrated against noncombatant targets by subnational groups or clandestine agents’.  Note that the definition focuses on motive more than action or consequence.  While motive is very important in prevention/intelligence and prosecution, it is far less important to most preparedness, response, and recovery activities.

The term ‘active shooter’ has been used quite a bit, yet it’s not a good description of what communities and responders can face when we consider that perpetrators could use means and methods instead of or in addition to firearms.  We’ve seen a wide variety of these instances that involve knives, vehicles, improvised explosives, and more.

This is why I prefer the term ‘active shooter/hostile event response’ or ASHER.  While the term has been around for a bit (a quick internet search shows references going back to at least 2013), NFPA 3000 has essentially canonized it in our lexicon.  The definition provided in NFPA 3000 is focused on the incident, rather than the motivation, and is comprehensive of any means or methods which could be used.  That definition is – Active Shooter/Hostile Event Response (ASHER): An incident where one or more individuals are or have been active engaged in harming, killing, or attempting to kill people in a populated area by means such as firearms, explosives, toxic substances, vehicles, edged weapons, fire, or a combination thereof.

When it comes to preparedness, response, and recovery ASHER is the focus we need to have.  Motivations generally make little difference in how we should respond.  We should always be looking for secondary devices or other attackers – these are not features unique to terrorist attacks.  As we do with any crime scene, we should always be mindful of evidence that can lead us to the motives and potential co-conspirators of an attacker.  That’s important for investigation, prosecution, and the prevention of further attacks.  Does the term ‘terrorism’ still have a place?  Of course it does.  In our legal system, that’s an important definition.  Philosophically, we can argue that all attacks are acts of terror, but because of the legal definition that exists of terrorism, we can’t – at least in the US.

I encourage everyone to start making the move to changing the lexicon to ASHER where appropriate.  It makes sense and gives us the proper perspective.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC ™