Background

All airports face risks from emergencies, whether man-made, mechanical, or natural. While 14 C.F.R. Part 139 Airports are required to establish an Airport Emergency Plan to address at least nine types of emergencies, some airports also create emergency plans to manage and plan for their response. The role of the Airport’s legal counsel in the AEP should be examined at various airports, considering steps airport legal counsel can take preparing, responding, recovering from major emergencies to support prompt emergency response and mitigate liability and risk to the airport.  

Objective

The report will provide analysis to explain the legal requirements for an Airport Emergency Plan (AEP) under 14 C.F.R. Part 139, identify other statutes and regulations that create responsibilities for emergency response outside of 14 C.F.R. Part 139, as well as other emergency plans airports implement. Additionally, it should evaluate tools an airport legal counsel can utilize, both in terms of emergency planning and conducting typical airport business to help manage potential risks during an emergency. It should discuss the roles of legal counsel and resources they can utilize during and immediately following the initial response and examine the benefits and drawbacks to these approaches. The report should include two or three case studies that explore whether and how legal counsel supports the Airport in responding to and recovering from an emergency.

Status RFP expected to be released in April 2026.