DRAFT 10/08/2010 VERSION 2 06-01-14
BLANK
Table of Contents COMPREHENSIVE EMERGENCY MANAGEMENT PLAN I. PURPOSE... 1 II. SCOPE... 1 III. MISSION... 2 IV. PLAN DISTRIBUTION... 2 V. GEOGRAPHIC AND DEMOGRAPHIC INFORMATION... 3 VI. PLANNING ASSUMPTIONS... 3 VII. CONCEPT OF OPERATIONS... 4 VIII. RESPONSE PROTOCOLS... 5 IX. TYPES OF EMERGENCIES/LEVELS OF RESPONSE... 6 X. ORGANIZATIONAL COMPONENTS... 6 XI. CEMP ORGANIZATION RELATIONSHIPS AND PRIMARY RESPONSIBILITIES... 7 XII. ROLES AND RESPONSIBILITIES... 8 XIII. ACTIVATION, OPERATION AND DEACTIVATION OF THE SIMON EMERGENCY OPERATIONS CENTER (EOC)... 10 XIV. PREPARATION FOR IMMINENT DISASTERS... 13 XV. RESPONSE TO TERRORISM SECURITY ALERTS... 13 XVI. EMERGENCY PREPAREDNESS ACTIVITIES... 14 XVII. CREDENTIALS FOR ACCESS TO INCIDENT SCENES... 15 XVIII. BUSINESS CONTINUITY PLANS... 16 XIV. AUTHORITY, REFERENCES AND RELATED PLANS... 16 ANNEXES EVACUATION PLAN...Annex 1-1 ACTIVE SHOOTER...Annex 2-1 AMBER ALERT...Annex 3-1 BOMB THREAT...Annex 4-1 EARTHQUAKE...Annex 5-1 ELECTRICAL OUTAGE...Annex 6-1 FIRE/EXPLOSION...Annex 7-1 HAZMAT EMERGENCIES...Annex 8-1 HURRICANES...Annex 9-1 PANDEMIC / MRSA EVENTS... Annex 10-1 WEATHER INDUCED EMERGENCIES... Annex 11-1 SHARP PLAN... Annex 12-1 SUSPICIOUS PERSONS, ACTIVITY, PACKAGES, AND IMPROVISED EXPLOSIVE DEVICES... Annex 13-1
APPENDICES PROPERTY EMERGENCY PLANNING GUIDE... Appendix 1-1 COMMUNICATIONS/MASS NOTIFICATION SYSTEM... Appendix 2-1 TENANT EMERGENCY GUIDE... Appendix 3-1 CONTRACT SECURITY VENDOR RESPONSE CAPABILITIES... Appendix 4-1 SIMON PROPERTY LISTING... Appendix 5-1 STATE AND LOCAL FUSION CENTERS... Appendix 6-1 STATE OFFICES OF EMERGENCY MANAGEMENT... Appendix 8-1 NATIONAL INCIDENT MANAGEMENT SYSTEM (NIMS)... Appendix 9-1 EMERGENCY SUPPORT FUNCTIONS (ESF)... Appendix 10-1 GLOSSARY... Appendix 11-1
COMPREHENSIVE EMERGENCY MANAGEMENT PLAN I. PURPOSE This document is the Simon Comprehensive Emergency Management Plan (CEMP) which is designed to guide the actions of Simon Personnel before, during and after emergencies and disasters. The CEMP is intended to establish policies, procedures and organizational structure for response to emergencies which are of a magnitude to cause a significant disruption of the functioning of all or portions of Simon. This plan describes the roles and responsibilities of personnel during emergency situations. The basic emergency procedures are designed to protect lives and property through effective use of corporate and community resources. Since an emergency may occur suddenly and without warning, these procedures are designed to be flexible in order to accommodate contingencies of various types and magnitudes. Through the use of annexes, the CEMP addresses several specific types of emergencies on an individual basis, providing guidelines for the stabilization and recovery from the incident. These include emergency instructions and references in a concise format for the individuals designated to manage Simon resources. This CEMP will help ensure business continuity for impacted properties. II. SCOPE This plan outlines the preparation, response and recovery roles and responsibilities for Simon Personnel and resources for emergency situations. Because a major disaster is likely to require response and recovery operations from multiple Simon departments, contractors and multiple levels of first responders and Government, the CEMP is intended to be consistent with established practices relating to coordination of emergency response actions. This plan incorporates the use of the National Incident Management System (NIMS) to facilitate interagency coordination between responding Emergency Management Agencies. Simon will cooperate with Federal, State and Local Emergency Management Agencies and other responders in the development, implementation and execution of its emergency response plans. Nothing in this plan shall be construed in a manner which limits the use of good judgment and common sense in matters not foreseen or covered by the elements of the plan. The Simon CEMP is an integral component of a series of plans and procedures and may rely on coordinated, concurrent implementation of these other plans and procedures. The associated plans and procedures include the following: Emergency Planning Guide for individual properties Inventories of equipment and supplies and personnel rosters maintained by the individual properties to be accessed during emergency response and disaster recovery operations Any specific emergency plans prepared and maintained for individual facilities or properties within or adjacent to the property The National Incident Management System guidance document promulgated under the Department of Homeland Security, Presidential Directive Five 1
III. MISSION Simon will respond to an emergency situation in a safe, effective and timely manner. Personnel and equipment will be utilized to accomplish the following priorities: Priority 1: Protection of Human Life Priority 2: Protection of Corporate Assets Priority 3: Maintenance of Corporate Services Priority 4: Assessment of Damages Priority 5: Restoration of General Operations IV. PLAN DISTRIBUTION Following the availability of the CEMP and after each update, the Simon Emergency Management Coordinator is responsible for distribution of the plan. The following distribution is required: Every Property with defined responsibilities for implementation of the plan is expected to have one or more copies available at their property. Specifically, a copy of the CEMP should be available in the Security Provider s Office and the Management Office. In addition, all Mall Management Personnel required to perform MOD functions at the property should retain a hard copy of the CEMP at an offsite location. The Emergency Management Coordinator will have sufficient additional copies available for use in Simon s Emergency Operations Center whenever it is activated for coordination of emergency response operations. The CEMP will be posted on the Simon Web Page and will be available electronically via CD. Copies of the CEMP will also be provided to regional members to include the: o Regional Vice President of Property Management o Regional Director of Operations o Regional Vice President of Marketing o Others as directed by the Regional Vice President of Property Management 2
V. GEOGRAPHIC AND DEMOGRAPHIC INFORMATION Corporate Office Simon is headquartered in Indianapolis, Marion County, Indiana. The main office is 14 stories and is located at 225 West Washington Street at the intersection of Washington Street and South Capital Avenue. Simon headquarters sits directly across from the State Capitol and adjacent to the Indiana State Government Building. Also in the area is the Circle Center Mall, owned and operated by Simon, a college campus, a sports/entertainment stadium and the Triple-A Indianapolis Indians baseball stadium. Simon owns or has interest in 382 properties comprising two-hundred and forty five million square feet across the continental United States, Europe and Asia. Simon employs more than 5,000 people worldwide. Indianapolis has a population of approximately 795,458 people. Simon Properties Simon properties are listed in Appendix 7 of this document. VI. PLANNING ASSUMPTIONS This CEMP is predicated on a realistic approach to the problems likely to be encountered during a major emergency or disaster. Hence, the following assumptions are made and should be used as general guidelines in such an event: An emergency or a disaster may occur at any time of the day or night, weekend, or holiday, with little or no warning. The succession of events in an emergency or disaster is not predictable; therefore, published operational plans, such as this plan, should serve only as a guide and a checklist, and may require modifications in order to meet the requirements of the emergency. An emergency or a disaster may be declared if information indicates that such conditions are developing or probable. Disasters may be community-wide. Therefore, it is necessary for Simon to prepare for and carry out disaster response and short-term recovery operations in conjunction with local resources. A major disaster will deplete the available resources of an individual property s capacity and will require requests for assistance, resources and supplies from other sources. Protective actions, including and/or sheltering in place may be necessary for our employees, tenants and customers. These protective actions may be pre-planned for known hazards or could require unplanned but controlled operations. Protective operations could potentially involve thousands of individuals and it is assumed the participants will attempt to comply with all protective action instructions. 3
Simon properties are required to have emergency response plans and procedures, including these, for protective actions and will maintain those plans as current and will implement them effectively whenever needed. All field personnel which qualify as first responders shall have NIMS training at a level determined by the Emergency Management Coordinator. Employees, tenants, contractors and customers will have a substantial need for information and instruction before, during and after disaster events. It will be necessary for Simon to participate with other organizations and levels of Government to ensure timely, consistent and accurate information is released within the jurisdiction of the affected property. VII. CONCEPT OF OPERATIONS This section of the CEMP defines the overall operational concepts which will be utilized by the assigned Simon response units and personnel to implement the emergency preparedness, response and disaster recovery operations. Additional details regarding specific operations are contained in the CEMP annexes. Overview The CEMP is the coordinating document for all aspects of Simon s emergency preparedness, including maintaining preparedness for response operations, implementing those operations and fulfilling of Simon s roles in disaster recovery operations. In general terms, individual Simon properties will respond to emergency situations and larger scale disasters in the following manner: Individual Simon Mall Managers along with the Security Provider will respond to emergency situations utilizing their current procedures for command and control of field operations. Two or more properties may cooperate in and support the emergency response, if needed, functioning under the management of the onscene Incident Commander (IC) with operations coordinated from an on-scene command post (CP) and utilizing existing command procedures. If the emergency situation escalates, or if an event can be predicted as likely to escalate to a major disaster, the Simon Emergency Management Coordinator will be contacted by the Incident Commander (IC) for advice and consultation. If deemed necessary, the Emergency Management Coordinator will implement the CEMP and activate the Simon Emergency Operations Center (EOC) to an appropriate level. Operations by Mall Management Personnel at the incident scene(s) will continue to directly address the event, its impacts and actions taken in the field. Command and control of on-scene personnel will continue from the CP. The EOC will be the facility from which additional coordination, support and policy decisions will occur on behalf of Simon. Once activated, the EOC will assist the CP(s) with procuring additional resources and coordinating with other related response or recovery activities, as well as maintaining public information services and similar functions on a corporate wide basis. 4
Operational Concepts The Simon CEMP relies on two fundamental operational concepts. The first are the concepts given under the National Incident Management System (NIMS), as incorporated into the National Response Plan (NRP). NIMS is normally utilized by emergency response officials to manage emergency operations through on-scene command posts under the NRP, and is being established as the nationwide concept for management of all emergency response and disaster recovery operations. NIMS provides an operational approach allowing for efficient allocation of resources and responsibility among available personnel, as well as the capability to rapidly expand or contract the response organizations as the emergency conditions indicate. The organizational structure has some variations but is typically depicted in the organizational structure illustrated in this section. The purpose of incorporating concepts embodied in NIMS and the NRP is to enable this CEMP to be consistent with the operational concepts which will be utilized by City, State and Federal Agencies should Simon require a substantial level of assistance during a disaster from varying levels of Government. In addition, around the country there are specialized emergency response operations such as the Joint Terrorism Tasks Forces (JTTF) and local and state area commands which would respond in the event of a terrorist attack. These units will utilize the NIMS concepts as well. Therefore, for Simon, the CEMP anticipates NIMS will be utilized at the incident scene and will interface with the Simon EOC on that basis. The second operational concept incorporated into the CEMP is known as the Emergency Support Function (ESF) concept. The ESF concept classifies common operations such as Law Enforcement, Fire Fighting, and Emergency Medical Services into organizational groups to improve the management and coordination of these specific functions during an emergency response. ESF s are defined in Appendix 8 of this document. VIII. RESPONSE PROTOCOLS The operational aspect of the Simon CEMP is based on the National Incident Management System (NIMS). NIMS is a modular emergency management system designed for all hazards and all levels of emergency response. This system creates a combination of facilities, equipment, personnel, procedures and communication operating within a standardized organizational structure. Use of NIMS at all Simon properties facilitates Simon s ability to communicate and coordinate response actions with other properties and external Emergency Management Agencies. Some of the types of incidents and events which could be managed through NIMS are listed below: Fire, HAZMAT, and mass casualty incidents Natural disaster, terrorism, civil unrest Active shooter situations Major planned events such as celebrations, parades, or concerts 5
The NIMS Command structure is not utilized during the immediate response to a rapidly unfolding incident, such as an active shooter. Only after the catastrophic incident is the structure put into place with responding agencies and when recovery begins. IX. TYPES OF EMERGENCIES/LEVELS OF RESPONSE There are three levels or types of emergencies: Level 1 Minor Incident: A Minor Incident is defined as a local event with limited impact, which does not affect the overall functional capability of an individual property or Simon. Planning and response is carried out at a limited local level. The CEMP would not be activated. Level 2 Emergency: An Emergency is defined as a serious event which significantly disrupts one or more operations of an individual property or Simon. Multiple resources are involved; the CEMP would be activated to the extent necessary. Level 3 Disaster: A Disaster is defined as a very serious event which seriously impairs or halts the operations of an individual property or Simon. The CEMP would be fully activated. X. ORGANIZATIONAL COMPONENTS The Simon CEMP consists of several major components: The Executive Management Team (EMT) Based out of the Simon Corporate office, the Executive Management Team (EMT) will evaluate information from various sources during the progress of the event and advise the President on appropriate actions requiring his/her decision. The EMT is also responsible for the review and approval of the CEMP. The Incident Management Assistance Team (IMAT) Based regionally and directed nationally by the Emergency Management Coordinator (EMC), the IMAT is comprised of regional VP staff and region specifically trained and support staff. The IMAT is directed by the EMC and is adjunct to the EOC. The Incident Management Team (IMT) Based out of each individual Property or region, the Incident Management Team (IMT) is activated, based on the type and nature of the incident, to manage the operational aspects of the response to an emergency event. The Mall Manager will serve as the Incident Commander (IC) and heads the Emergency Operations Team. The Incident Commander has responsibility for overall management of the incident and must be fully qualified to manage the incident. The President has designated the Simon Mall Manager as the Incident Commander. 6
Property Emergency Planning Guide These are property or area specific plans developed to reduce the risk of life or property loss through preparation for foreseeable events. The shell of the Emergency Planning Guide is provided to each individual Property. The Mall Manager of the respective property is responsible for completing the plan with their mall specific information and data. Response Annexes Individual functional areas will develop Response Plans to specific types of incidents (i.e. terrorism, natural disaster, etc.) to identify key personnel and define specific responsibilities and procedures to mitigate the specific threat. Reference Appendices Individual documents which contain direction and guidance in response and planning regarding updated organization and contact information. XI. CEMP ORGANIZATION RELATIONSHIPS AND PRIMARY RESPONSIBILITIES Executive Management Team (EMT) Makes critical policy decisions (strategic decisions) affecting Simon during an emergency and recovery. Incident Management Assistance Team (IMAT) At the direction of the Emergency Management Coordinator (EMC), the IMAT responds with appropriate Incident Command System (ICS) positions to support the Incident Commander (IC) and the Incident Management Team (IMT) pre and post event. Incident Management Team (IMT) Executes the CEMP as directed by the Incident Commander during an emergency Reviews all provisions of the CEMP for approval by the EMT Incident Commander (IC) Mall Manager serves as the Incident Commander Member of the Incident Management Team (IMT) In control and in charge of the Incident Management Team (IMT) Makes critical management decisions during an emergency Confers directly with the Executive Management Team (EMT) during an emergency Liaison Officer Office Administrator of designees serves as the Liaison Officer Reports and coordinates with the IC Maintains liaison and point of contact for assisting entities for the IC 7
Safety Officer Security Director or designees serves as the safety officer Reports to the IC Identifies, monitors, and assesses hazardous and unsafe situations and develops measures to ensure personnel safety Corrects unsafe acts or conditions through the chain of command but may exercise emergency authority to stop or prevent unsafe acts when immediate action is required Public Information Officer Mall Marketing Director serves as the Public Information Officer Formulates and coordinates the release of information about the incident to the news media, tenants, employees, customers and other appropriate entities Operations Section Chief Operations Director or Maintenance Supervisor serves as the Operations Chief Reports to the IC Responsible for directing all response and tactical actions to achieve the objectives of the emergency response to the incident Emergency Management Coordinator Consults directly with the Incident Commander during an emergency Maintains the CEMP documentation Serves as Liaison to outside Emergency Management Agencies XII. ROLES AND RESPONSIBILITIES President This plan is promulgated under the authority of the President of the Corporation. All decisions concerning the discontinuation of corporate functions, or cessation of operations, rest with the President or his/her designee. After consulting with the Incident Commander and appropriate members of the Executive Management Team, the President or his designee shall be responsible for declaring any major institutional emergency. Executive Management Team (EMT) The EMT is comprised of the Simon President and his direct reports. The EMT s role is that of policy and major decisions. Typically, this would be centered on planning and preparation prior to and the recovery from the incident, the long-term effects of the incident and the needs to restore to normal operations (continuity of operations planning and recovery management). The EMT would be directly involved in incident stabilization only if major expenditures or policy decisions were needed to complete the stabilization. Accordingly, the responsibilities of this body include: 8
Final plan approval and major policy decisions Allocation and direct distribution of resources required to reduce identified vulnerabilities Allocation and direct distribution of resources required to accomplish the purposes of this CEMP Request needed resources from outside entities which are unavailable internally Delegate necessary authorities for incident stabilization and protection of life and property Identify critical business functions which must quickly be restored and maintained Review needs and allocate resources required in the 24-96 hour range to complete stabilization and commence the recovery process for a 30-day period Determine long-term (greater than 30 days) effects the incident may have on the corporation and how these can be managed Monitor the recovery process to ensure the recovery is proceeding according to plan and to provide guidance/assistance as needed Ensure the Incident Commander is functioning in a responsible manner. This process should be undertaken through joint briefings between the EMT and the Incident Commander. Many incidents require a multi-agency and/or multi-jurisdictional response. Members of the EMT must be aware of how the Incident Command System and interagency (regional) Multi-agency Coordination Systems functions to ensure cooperative response efforts. 9
XIII. ACTIVATION, OPERATION AND DEACTIVATION OF THE SIMON EMERGENCY OPERATIONS CENTER (EOC) The Simon EOC is located at 225 West Washington Street Indianapolis, Indiana on the 11 th floor. This section of the CEMP describes the operational concepts for the activation, operation and deactivation of the EOC. The Simon President, Senior Executive Vice President and Senior Vice President, Chief Security Officer, in consultation, are authorized to activate the EOC. The circumstances which may warrant activation of the EOC include but are not limited to the following: Upon request of the Incident Commander of an emergency response operation being conducted at a satellite property When the corporation is confronted with the imminent impact of a significant disaster event of any type When any portion of the corporation has been significantly impacted by a disaster event Prior to and for the duration of a large, significant or highly controversial event occurring on or near a property Physical activation and deactivation of the EOC s facility and systems will be the responsibility of the Senior Vice President, Chief Security Officer in coordination with the Emergency Management Coordinator. Following the activation of the EOC, the Simon Emergency Management Coordinator or designee will be responsible for activation of the EOC support staff. The Emergency Management Coordinator will also be responsible for securing other necessary support services to sustain EOC operations. Levels of Activation Activation of the Simon EOC will be completed to levels or stages which are commensurate with the scope and magnitude of the response operations necessary. The levels to be utilized by Simon are consistent with those used by Local, State and Federal Emergency management to enhance coordination of response operations. The EOC activation levels are as follows: Level III Inactive/Monitoring Routine monitoring of events and circumstances regarding known or potential emergency situations. The Emergency Management Coordinator may activate the EOC and mobilize key EOC support staff to monitor events. Level II Partial Activation of the EOC A limited activation of core Simon emergency support personnel activated by the Emergency Management Coordinator in order to maintain key support operations to a Command Post, to provide important public information, to gather information and documentation or to implement similar operations which are limited in scope. 10
Level I Full Scale Activation of the EOC All Simon emergency response personnel would be activated and assigned to the EOC. The Simon Emergency Management Coordinator will determine the appropriate level of EOC activation and notify all Simon EMT members. When an emergency or disaster event threatens any Simon asset, the Emergency Management Coordinator will consider the levels of activations by the local Emergency Management Agencies in the affected area in determining the appropriate level of activation for the Simon EOC. Notification and Mobilization for EOC Operations Upon a decision to implement the CEMP and activate the Simon EOC, it will be the responsibility of the Emergency Management Coordinator to notify, as indicated by the level of activation, key support staff and the contact individual for the primary department for each to be activated. The primary department contact individual is, in turn, responsible for notification of all necessary personnel in the primary department. The contact individual within the activated support department is responsible for notification of personnel within that department of the activation of the EOC. Following notification, one or more representatives of the primary department and, as indicated, from support departments, will mobilize to the Simon EOC and initiate operations. Operations in the Simon EOC The Simon EOC will serve as the center for coordination and administration for the following: Monitoring and assessing an emergency or disaster to anticipate needed response and recovery operations Securing resource support for mall operations at the incident scene from Simon staff and assets Making basic policy decisions regarding Simon s emergency response and disaster recovery operations Planning and prioritizing Simon s corporate response and recovery operations Preparing and issuing public information and emergency instruction Maintaining communication and coordination with the property CP and any EOCs, if activated, of Local Authorities, and directing Simon operations accordingly, including activating Mutualink when applicable Ensuring appropriate documentation regarding response and recovery operations is maintained by all affected Simon properties Simon will develop and maintain a detailed implementing procedure to guide its operations, and this procedure will define the necessary actions to staff, equipment, and operate the EOC, as described below. 11
EOC Staffing The EOC will function under the overall management and policy direction of the Emergency Management Team, serving as the principal decision-making body for Simon at the time of a disaster. The functioning of the EOC will be directed by the Emergency Management Coordinator. The Emergency Management Coordinator will designate an individual to serve as the EOC Operations Officer, if needed. If the situation is likely to require EOC operations on a 24 hour/day basis, the Emergency Management Coordinator will ensure adequate personnel for EOC support staff are assigned for continuing operations. From the staff present at the Simon EOC, the Emergency Management Coordinator will designate individuals to serve as the designated contact for the Planning, Logistics, Operations and Administrative Sections of the NIMS organizational structure. The names and contact information for these individuals will be provided to any external facility or operation functioning under the NIMS structure to include any command post established in the field. Information Processing and Documentation When a response to a request is necessary, a numbered mission assignment (a task tracked through the EOC) will be prepared by the coordinating individual. In all cases involving a significant expenditure of Simon funds, a mission assignment will be made and documented. The mission will be clearly stated, with a priority given, and an individual or unit will be designated to complete the mission. The Emergency Management Coordinator and/or EOC Operations Officer will maintain a log of mission assignments. Upon completion of a mission, the originating CP or individual will be advised for recording on the mission log. Periodically, the Emergency Management Coordinator will request mission logs from all EOC support staff. The logs will be consolidated and reviewed to establish completed and open missions. When needed, corrective actions to complete open missions will be defined and implemented. Situation Reports and Briefings On a schedule established by the Emergency Management Coordinator (EMC) in conjunction with the Incident Commander (IC) a report summarizing the impacts of the event, Simon s response and recovery operations and the open and completed missions/tasks will be prepared by a designee in the EOC. Upon review and approval of the situation report by the Emergency Management Coordinator, the situation report will be distributed to the EMT. Periodically the Emergency Management Coordinator or designee will conduct a briefing for the EOC EMT to summarize the current situation to explain the current strategic plan and priorities for Simon s response and recovery efforts. EOC Deactivation and Transition to Recovery Operations As the Simon EOC s open missions for emergency response operations are completed, the EMT may consider deactivation of the EOC. The decision to deactivate the EOC will consider the following conditions: 12
The need for continuing coordination of Simon responsibilities and decision making as response operations are completed and the affected Simon properties transition to disaster recovery The continued operation of the mall command posts or other field activities The capabilities of the involved Simon properties to effectively conduct remaining operations from their normal offices or other places of operation Upon the decision to deactivate the Simon EOC, the Emergency Management Coordinator will ensure all documentation regarding the operations directed from the EOC has been completed accurately and received. XIV. PREPARATION FOR IMMINENT DISASTERS When a disaster situation is anticipated to occur, the Simon Emergency Management Coordinator will advise the President, the EMT and all Management Personnel of the situation. Simon will then promptly begin preparation for emergency operations and staffing of the Simon EOC. These will include but not limited to: Canceling leave and vacation of essential personnel Reviewing intention to close any Simon properties Review of emergency plans and procedures Gathering needed inventories, rosters, forms and other documentation necessary for the activation of the EOC Taking actions to safeguard or otherwise protect vital Simon documents and records Taking actions to safeguard Simon properties and equipment from the impact of the event to ensure its readiness for emergency response and recovery operations XV. RESPONSE TO TERRORISM SECURITY ALERTS The US Department of Homeland Security maintains an alert system known as the National Terrorism Alert System. This is a three tiered system to advise the nation on the level of threat of a terrorist attack. The highest level Imminent warns of a credible, specific, impending terrorist threat against the U.S. When the Department of Homeland Security issues an Imminent threat level, the following actions will be taken by the Simon Emergency Management Coordinator or designee until the threat level is lowered: Establish ongoing communication with the FBI JTTF, local Fusion Centers, and State and Local Police regarding the applicability of the threat to Simon assets Establish ongoing communication with the Department of Homeland Security regarding recommended actions for the private sector Advise Simon executive leadership regarding the threat classification Review the need for additional security plans for Simon assets 13
XVI. EMERGENCY PREPAREDNESS ACTIVITIES In order to facilitate effective implementation of the CEMP and its annexes, it is necessary for Simon to maintain an ongoing emergency preparedness program. This section defines the basic elements of this program. The Simon Emergency Preparedness Program Simon will develop and maintain an emergency preparedness program which will consist of the programs and activities described in this section. This program will be disseminated through the Simon intranet website with appropriate references on preparedness information. (Simon CEMP, Fema.gov, State and Local programs by State) Maintenance of the Simon CEMP The CEMP will be maintained and updated through the following activities: Annually, the Emergency Management Coordinator will review the DHS recommended preparedness policies and recommendations to determine if any changes or recommendations have been made which would warrant modification of the Simon CEMP. The Emergency Management Coordinator will review the basic plan component of the CEMP and the annexes and with the assistance of the Simon EMT, will update these as needed. Each individual Mall Manager will review their Property Emergency Planning Guide to determine if any updates are required. Prior to June 1 of each year, a new updated CEMP will then be distributed if changes are made. In addition, following each major disaster event and/or training exercise which required the implementation of the CEMP, the Emergency Management Coordinator will ensure a post event exercise critique and evaluation is conducted by or for the involved Simon properties. If indicated by the evaluation, modifications will be promptly made to the CEMP and its annexes and distributed. Training and Exercises Simon s emergency preparedness program includes both training and exercises. The training component will be implemented as follows: The Emergency Management Coordinator will ensure the Simon staff/personnel involved in the implementation of the CEMP and its annexes receive both initial and refresher training in its implementation. The Emergency Management Coordinator will ensure the support staff for the Simon EOC is trained to activate, operate and deactivate the facility. The individual Simon properties will continue to maintain their existing staff training programs regarding normal and emergency operations which are their normal responsibilities. Where necessary and appropriate, the existing training programs will be modified to incorporate reference of the CEMP and its annexes, as well as 14
policies and methods to be used for interface between field personnel, command posts and the EOC. The Emergency Management Coordinator will ensure personnel participate in training and exercise opportunities provided by NIMS compliant competent resources when relevant to implementation of Simon s CEMP. The exercise component will be implemented as follows: (Recommendations only) At least annually the Emergency Management Coordinator will ensure Simon conducts an exercise of the CEMP and at minimum one of the annexes. This exercise may be a live drill, table top, functional or full scale exercise. Exercise scenarios will be such that the basic plan and the annexes are implemented. Simon will adopt the DHS/FEMA HSEEP exercise compliance standards and recommended cycle of progressive and regular exercise administration. Exercises of the Simon CEMP may be conducted more frequently than annually if in the judgment of the Emergency Management Coordinator, conditions warrant a practice exercise of the Simon CEMP. Whenever practical, exercises of the Simon CEMP will be conducted concurrently with or integrated with local or State emergency management exercises. In all cases, an after action critique will be held under the direction of the Emergency Management Coordinator. If indicated by the critique, the Simon CEMP or its annexes will be modified accordingly. XVII. CREDENTIALS FOR ACCESS TO INCIDENT SCENES Simon embraces the concept of credentialing for corporate and contractual emergency responders to disasters having a life safety and property damage impact on a property. Credentialing will not provide automatic access to an incident site but can serve to prevent unauthorized and unqualified personnel access to an incident site. The Emergency Management Coordinator (EMC) will be responsible for ensuring at a minimum all corporate and field personnel who may respond in support of the corporate Emergency Operations Center (EOC), Incident management Assistance Teams (IMAT), and the local property Incident Command structures are issued Simon corporate identification cards for entry into an incident site. It is recommended the current Simon hard card photo identification be used as the standard Simon corporate credential to be issued and used not only for entry into an incident scene, but as a daily identification source in the field at Simon properties. It is further recommended that the Simon corporate hard card photo identification be issued to all Simon management in the field, the contract security provider s director and supervisors and the contract housekeeping supervisor and lead supervisors. A system will be established for the issuance, tracking and accounting for any Simon corporate hard card identification issued. The EMC may also authorize the on-scene Incident Commander (IC) to authorize the issuance of temporary identification on a daily basis to all personnel authorized to enter an incident scene based on site safety and security guidelines. A record shall be maintained accounting for the identification, authorization and movement of all personnel entering and exiting an incident scene. 15
Each security provider shall be responsible for establishing a credentialing system consistent with the standards set by the EMC. Each mall manager and security provider security director will make contact with the state and/or local emergency management agency to determine their protocols for credentialing and access to an area where a Simon property is located that has been affected by a natural or manmade disaster. Each jurisdiction is different in their requirements and each property should know the requirements in their areas prior to an incident. In the case of a jurisdiction that establishes an authorized access list in advance of a natural or manmade disaster, the mall manager and contract security provider will provide a list of emergency responders who will be mobilized in the event of an incident. The mall manager will also provide a list of companies that have been contracted to assist in security and mitigating any damage to a Simon property as a result of an incident. Form Aa found in the Hurricane Guide can be used as an example for providing this information to the local or state emergency response agency responsible for providing access to a restricted area. In the case of a local or state jurisdiction that does not have a pre-established list identifying those authorized to enter into an area affected by a natural or manmade disaster, it is the responsibility of each mall manager and security provider to determine what protocol that jurisdiction has for entry into an affected area and if there are any specific requirements for access to a restricted area where a Simon property may be located. While there is currently no national standard set forth by DHS for a credentialing system, DHS does reference the need for identifying personnel who will be responding to and entering an area impacted by a natural or manmade incident requiring emergency response. This section of the CEMP is intended to meet the minimum requirements for credentialing set forth by DHS. XVIII. BUSINESS CONTINUITY PLANS As soon as feasible, Simon will develop business continuity plans which will define methods to maintain and/or quickly resume their essential operations. These plans will address the alternate facilities and sources for resources to be used should those normally available be disrupted by an emergency or disaster. The plans will define an essential function as the corporation s capabilities to initiate and sustain its roles as defined in the CEMP and its annexes. XIV. AUTHORITY, REFERENCES AND RELATED PLANS The Authority for the plan and program are also established through Simon and the formal adoption of the Simon CEMP by the EMT in compliance with the National NIMS Guidance under Homeland Security. Simon may develop and incorporate into the Simon CEMP additional annexes to address special hazards or concerns whenever deemed necessary. 16