Why Small Airports Need Emergency Plans
FAA Advisory Circular 150/5200-31C provides guidance on developing Airport Emergency Plans. While mandatory AEP requirements apply only to Part 139 certificated airports, the FAA recommends that all airports develop an emergency plan appropriate to their size and operations.
The purpose of an emergency plan is not to create a shelf document. It is to ensure that when an aircraft accident, fuel spill, severe weather event, or medical emergency occurs on your field, everyone involved knows what to do, who to call, and how to coordinate. At a small airport without dedicated emergency response resources, this coordination with external agencies is the critical function your plan must address.
Your plan does not need to be a massive document. A concise, well-organized plan that covers the most likely scenarios and is actually exercised annually is worth far more than a comprehensive document that no one has read or practiced.
What Your Emergency Plan Should Cover
Identify Your Most Likely Emergencies
Start by identifying the types of emergencies most likely to occur at your facility. For most small GA airports, the primary scenarios include:
- Aircraft accidents on or near the airport. Runway excursions, gear-up landings, engine failures on takeoff, and midair collisions in the traffic pattern are the most common aircraft accident types at GA airports.
- Fuel spills. Spills during fueling operations, equipment failures, and storage tank leaks all require immediate response to prevent fire hazards and environmental contamination.
- Severe weather. Tornadoes, thunderstorms, ice storms, and flooding can damage facilities, strand aircraft, and create hazardous conditions on the airfield.
- Medical emergencies. Heart attacks, injuries from propeller strikes or fuel burns, and other medical events requiring EMS response.
- Security incidents. Unauthorized access, suspicious activity, and in rare cases, threats against the airport or its users.
- Hazardous materials events. Beyond fuel, airports may store or handle deicing chemicals, lubricants, solvents, and other materials that require specialized spill response.
Establish Roles and Communication
For each scenario, your plan should define who is in charge at the airport level, who contacts which external agencies, and how communication flows during the event. At a small airport, the "who" may be just one or two people — but those people need to know exactly what their responsibilities are.
Key elements include:
- A call-down list with current phone numbers for the airport manager, alternate contacts, local fire department, EMS, law enforcement, the FAA Flight Standards District Office, the NTSB, your insurance carrier, and environmental response agencies
- The process for securing the accident site and controlling access
- Media communication protocols — who is authorized to speak to the press and what can be said before investigation findings are available
- Notification procedures for the NTSB (required for all aircraft accidents and certain serious incidents under 49 CFR Part 830)
Keep your emergency contact list updated. A call-down list with outdated phone numbers is useless during an actual emergency. Review and verify all contact information at least twice per year — once during your annual exercise and once at a mid-year check.
Mutual Aid Agreements
Small airports rely almost entirely on external agencies for emergency response — fire departments, EMS, law enforcement, and hazardous materials teams. Mutual aid agreements formalize these relationships and establish expectations before an emergency occurs.
An effective mutual aid agreement should cover:
- Access. How will responding units get onto the airfield? Do they know the gate codes or have keys? Are access roads passable for heavy apparatus?
- Airfield familiarization. Firefighters responding to an aircraft accident on a runway need to know how to navigate the airfield safely without driving across active pavement or into propeller arcs. Annual familiarization visits are essential.
- Aircraft hazards training. General aviation aircraft present specific hazards that firefighters may not encounter elsewhere: composite materials, avgas and Jet-A fuel characteristics, battery locations, oxygen systems, ballistic parachute systems, and high-voltage systems in electric and hybrid aircraft. Even a brief annual training session on GA aircraft hazards improves response safety.
- Response times and capabilities. Understand what your mutual aid partners can realistically provide and how quickly. A volunteer fire department 15 minutes away provides a different level of coverage than a career department three minutes away.
- Cost sharing. Define who pays for what — response costs, training time, equipment use — so there are no surprises after an event.
Put your mutual aid agreements in writing. Verbal understandings are unreliable when leadership changes at partner agencies. A written agreement that is reviewed and renewed annually ensures continuity regardless of personnel turnover.
Fuel Spill Response
Fuel spills are among the most common emergency scenarios at any airport with fueling operations. Your plan should address both small operational spills (a few gallons during fueling) and larger events (a storage tank failure or delivery truck accident).
Immediate Response Steps
- Eliminate ignition sources in the area — no vehicles, no electrical equipment, no smoking
- If safe to do so, stop the source of the spill (close valves, stop pumps)
- Deploy absorbent materials to contain the spill and prevent it from reaching drains, waterways, or soil
- Ventilate enclosed areas if fumes are present
- Call 911 if the spill is large, if there is a fire risk, or if anyone has been exposed
Reporting Requirements
Federal and state environmental regulations require reporting of fuel spills above certain thresholds. The federal reportable quantity for gasoline (including avgas) under CERCLA is generally tied to spill size and whether the release reaches navigable waters or groundwater. State requirements vary and are often more stringent. Know your state's spill reporting thresholds and procedures before you need them.
Equipment and Supplies
Maintain spill response supplies at or near your fueling area. At a minimum, keep absorbent pads, absorbent booms for containing liquid flow, granular absorbent material, non-sparking shovels and brooms, personal protective equipment (chemical-resistant gloves and eye protection), and appropriate containers for contaminated absorbent disposal. Inspect these supplies regularly and replace them as they are used or degrade.
Exercising Your Plan
An emergency plan that has never been exercised is a theory, not a plan. The FAA recommends at least an annual tabletop exercise — a facilitated discussion where key participants walk through a scenario and talk through their responses without deploying actual resources.
Tabletop Exercise Format
A tabletop exercise for a small airport does not need to be complex. A typical format takes about 60–90 minutes and involves the following:
- Gather your airport staff, representatives from your mutual aid partners (fire, EMS, law enforcement), and any key tenants such as FBO operators
- Present a realistic scenario — for example, a single-engine aircraft with two occupants suffers a gear-up landing on the runway with a fuel leak
- Walk through the response step by step: who discovers the event, who calls whom, how do responders access the airfield, how is the runway secured, who handles media, who notifies the NTSB
- Identify gaps, confusion, or outdated information
- Update the plan based on lessons learned
The exercise itself is valuable, but the relationships built during the exercise are even more valuable. When the fire chief and the airport manager have sat in the same room and talked through a scenario together, the real-world response will be better coordinated, faster, and safer.
Combine your annual tabletop exercise with an airfield familiarization tour for your mutual aid partners. Walk the field together, show them gate access points, fueling areas, hangar layouts, and any hazards unique to your facility. This dual-purpose event maximizes the value of everyone's time and builds the working relationships that matter most during an actual emergency.
Post-Incident Actions
After any emergency event, there are several follow-up actions that should be part of your plan:
- Secure the site. Do not disturb wreckage or evidence until the NTSB or FAA has authorized it (in the case of aircraft accidents).
- Document everything. Photograph the scene, record times and actions taken, and preserve any records related to the event. This information will be needed by investigators, insurers, and your legal counsel.
- Conduct a hot wash. As soon as practical after the event, bring together everyone who participated in the response for a brief debriefing. Discuss what went well, what did not, and what should be changed in the plan.
- Update your plan. Incorporate lessons learned from both exercises and actual events into your emergency plan. A plan that never changes is a plan that never improves.
The final chapter covers community relations and stakeholder engagement — how to build and maintain the public support that is essential to your airport's long-term viability.