If you are forced to make an emergency landing at the airports you regularly fly in and out of, how ready are they to deal with fire-and-rescue operations? Is the airport where you hangar your aircraft or run your FBO ready for an emergency?
These questions arise out the work I’ve been doing lately at smaller airports around the country. Part of my work in emergency planning is reviewing airport plans and drills for emergencies. I’ve overseen or participated in formulating plans and emergency drills for major air carrier airports, for smaller air-taxi airports and for general aviation airports. Of course, the level of planning and preparation varies by the size and complexity of the airport. And FAA regulations apply to only certain airports, generally those with scheduled passenger-carrying operations of an air carrier operating aircraft of more than nine seats and unscheduled passenger-carrying operations of an air carrier operating aircraft of at least 31 passenger seats.
But even for smaller airports that rarely see an air-taxi or corporate flight, a plan and some evaluation of that plan are necessary to ensure that in the event of an emergency there is an appropriate crash, fire, and rescue response. As pilots, are you checking the emergency preparedness of the airports you regularly fly into or out of? Are your corporate flight departments checking? Do you—or should you—have a role in the event of an emergency at an airport where your aircraft is hangared?
My recent participation in several emergency drills leaves me concerned that some airports—even those with commuter and air-taxi service—are not as prepared as they should be. And that FAA oversight is lacking. It’s likely that airports without requirements or any FAA oversight are probably lacking in emergency preparedness, as well.
Concerns about emergency preparedness are not new. Some of those concerns were highlighted in the NTSB’s accident report and recommendations related to the crash of Asiana Flight 214, which struck a seawall while landing at San Francisco International Airport on July 6, 2013. Of the three people who were killed in that accident, two were ejected from the aircraft. (The NTSB determined that they would not have been ejected and would likely have survived if they had been wearing their seatbelts.) One of these ejected passengers was run over by two firefighting vehicles when crews apparently did not see her after she was covered in firefighting foam. (The San Francisco county coroner concluded that she was alive before the fire trucks ran her over.)
The NTSB determined that the probable cause of the accident was “the flight crew’s mismanagement of the airplane’s descent during the visual approach, the pilot flying’s unintended deactivation of automatic airspeed control, the flight crew’s inadequate monitoring of airspeed, and the flight crew’s delayed execution of a go-around after they became aware that the airplane was below acceptable glidepath and airspeed tolerances.” While the probable cause of the accident was in no way related to the airport’s emergency response, seven of the 15 safety issues identified by the NTSB for follow up relate to the airport’s emergency response and the FAA’s oversight. And, while not concluding that the one passenger died because of the fire department’s actions, the NTSB recommendations address the factors that would have prevented the passenger from being run over.
IG: Fire and Rescue Need More FAA Oversight
As a follow up to the NTSB’s findings and recommendations regarding San Francisco’s airport emergency response preparedness and FAA oversight, the USDOT Inspector General conducted an audit of the FAA and issued a final report in May 2016. The report concluded that the FAA “lacks sufficient oversight of the aircraft rescue and firefighting program.” According to the IG’s report: “The FAA has not ensured that airports are adhering to ARFF [aircraft rescue and firefighting] requirements. FAA inspectors at the four regions we visited did not consistently review compliance with ARFF regulations related to an airport’s ARFF vehicle readiness and certification manuals as described in FAA policy. This is due in part to FAA’s lack of robust requirements in its inspector checklist on how inspectors should review airports’ compliance with ARFF regulations. Also, the FAA has not always investigated and followed up on serious ARFF discrepancies or reported on ARFF enforcement data as required."
From my recent participation in several emergency drills in which the FAA was present, it would not appear that the IG’s report has had its intended effect. And, remember, these are airports with specific regulatory requirements that the FAA is required to oversee. There are thousands of airports that GA and corporate pilots regularly use that don’t have FAA requirements or any FAA oversight.
So what can you do? For starters, you can ask to see an airport’s emergency plan (AEP) and talk to the airport manager about it. Ask how—if—they test it with local fire departments.
There are resources available to small airports. One I would recommend is the Guidebook for Managing Small Airports, published by the National Academies of Sciences, Engineering, and Medicine. It was prepared with input from the Airport Cooperative Research Program and the Transportation Research Board, an independent advisory council to the United States government. The book is available online for free. As the book states, “The primary purpose of an AEP is to establish delegation of duties, assign agency responsibilities, provide coordination of response efforts, and provide an orderly transition between normal and emergency operations.”
The FAA’s advisory circular for airports required to have an emergency plan under FAR Part 139 is a good starting point for developing an AEP or for checking one at your airport. While the standards in the advisory circular are mandatory for certified airports, the FAA recommends using them at non-certified airports, as well.
An airport emergency plan should:
- Assign responsibility to organizations and individuals for carrying out specific actions at projected times and places in responding to an emergency.
- Set forth lines of authority and organizational relationships, and show how all actions should be coordinated.
- Describe how people and property will be protected in emergencies and disasters.
- Identify personnel, equipment, facilities, supplies, and other resources available—within the airport or by agreement with communities—for use during response and recovery operations.
- As a public document, cite its legal basis, state its objectives, and acknowledge assumptions.
- Facilitate response and short-term recovery to set the stage for successful long-term recovery.
Of course, a plan is only as good as it is current and rehearsed. It’s good to ask your airport manager how often they do this and whether local fire and rescue personnel are involved. If a live drill is too expensive to accomplish, I would recommend at a minimum the relevant participants meet once a year for a tabletop exercise.