Requiring all newly manufactured helicopters to comply with existing crash resistance standards would cost the industry approximately $764 million over 10 years, a working group has found.
The estimate appears in a cost-benefit analysis report submitted to the U.S. Federal Aviation Administration’s (FAA’s) Aviation Rulemaking Advisory Committee (ARAC) by the Rotorcraft Occupant Protection Working Group. According to the report, the costs of mandating compliance with U.S. regulations for crash resistant seats, structures, and fuel systems are more than five times greater than the projected economic benefits, which were estimated at around $144 million over 10 years.
However, these figures should be regarded with caution. The industry working group arrived at its cost estimate using nonstandard methodology that may have resulted in a higher estimate than FAA cost calculations would have yielded.
Meanwhile, the working group used standard FAA methodology to calculate benefits, despite some members arguing that “current FAA methodology for calculating the economic costs of fatal and serious injuries significantly underestimates the actual societal costs of these injuries.”
The FAA created the Rotorcraft Occupant Protection Working Group in late 2015, after high-profile fatal accidents — notably the fiery crash of a Flight For Life helicopter in Frisco, Colorado — drew attention to the fact that many new-build helicopters fail to meet safety standards that have been in place for decades.
The FAA adopted its current helicopter fuel system crash resistance standards in 1994, and dynamic crashworthiness standards in 1989. But because the standards do not apply to rotorcraft with type certificates approved before those dates, a majority of civil helicopters manufactured over the past two decades do not fully comply with these requirements.
In announcing the creation of the working group, the FAA noted that the numbers of U.S. fatal helicopter accidents and associated fatalities have remained “virtually unchanged” over the past decade, despite a decline in the total number of accidents.
“If the occupant protection improvement rules are not incorporated in new production helicopters,” the FAA stated at the time, “there will be no meaningful reduction in the number of fatalities in helicopter accidents.”
Twenty members of the helicopter industry were appointed to the working group, including representatives from operators, manufacturers, and industry associations. Their first assigned task was to perform a cost-benefit analysis for incorporating existing occupant protection standards into newly manufactured rotorcraft.
To accomplish the task, the working group divided into two subgroups: a Cost Task Group, consisting primarily of manufacturer and operator representatives; and a Benefits Task Group, including accident investigators, accident analysts, and safety experts.
The working group submitted its initial cost-benefit analysis report to the ARAC on March 13, 2016, but was granted additional time to complete a more accurate and detailed report, which was submitted on Nov. 10 and accepted by the ARAC last week.
In performing its cost analysis, the Cost Task Group considered both the non-recurring design costs and ongoing manufacturing costs likely to be incurred by manufacturers, as well as operator costs related to the reduction in payload, reduction in fuel load and range, and increase in fuel burn rate resulting from the design changes.
In its final report, the working group expressed the opinion that “current FAA standard methodology does not accurately consider the practical costs of aircraft modification,” and stated that it “sought to correct this by using a methodology that it feels more accurately predicts actual industry costs.”
According to an FAA statement attached to the report, the working group’s operator cost methodology does not follow the method of accounting for impact on empty weight and useful load that is used in other ARAC and FAA economic impact analyses. The FAA also noted that non-recurring costs are not broken down to a level that allows review and validation of costs from each manufacturer, and that international development costs are not split out separately, as they typically are in the FAA’s economic impact studies.
By contrast, the Benefit Task Group did use FAA methodology to calculate the value of the lives that would be saved and serious injuries avoided if crash resistant seats and structures (CRSS) and crash resistant fuel systems (CRFS) were fully implemented in newly manufactured helicopters. This methodology values the avoidance of a fatality at $9.6 million, the avoidance of a serious injury at approximately $2.4 million, and the avoidance of a minor injury at $28,800.
By analyzing accidents of rotorcraft manufactured between 2006 and 2015, the group was able to confirm that compliance with the CRFS standards of 14 Code of Federal Regulations 27/29.952 is “extremely effective at preventing post-crash fires and thermal injuries.” The group found that there were no post-crash fires in survivable accidents involving compliant rotorcraft, and that fully compliant CRFS are moderately effective even in extreme impact crashes.
However, the working group noted that its analysis was “greatly inhibited by the fact that neither [the National Transportation Safety Board] nor FAA determine impact conditions in an accident investigation nor injuries for the involved occupants,” and that “lack of these data render occupant protection analysis almost impossible.”
In a statement of non-concurrence attached to the report, working group member Krista Haugen pointed to the Frisco Flight For Life crash as an example of how the absence of detailed injury data can lead to underestimating the value of safety improvements. In the group’s analysis, the flight nurse who suffered serious injuries in that crash represented a net benefit valuation of $2.4 million, yet his medical expenses alone are likely to be much higher than that — and that’s without taking into account his lost earnings, the impact on his quality of life, or the burdens placed on family members.
“The thermally injured survivor of this crash sustained full-thickness burns to 90 percent of his body because of the post-crash fire. He was hospitalized in the burn intensive care unit for 11 months, with total hospitalization time just over 12 months,” Haugen stated. “He will require medical care for the rest of his life . . . and it must be emphasized that he literally would have walked away with minor blunt injuries, were it not for the post-crash fire.”
The lack of detailed injury data also makes it difficult to determine the effectiveness of designs that are in partial compliance with existing standards. For example, David Shear of Robinson Helicopter Company noted that Robinson has performed voluntary dynamic seat testing that “showed that the existing occupant protection features on the R22 and R44 are very effective,” meeting the head impact criteria, lumbar spine load, and seat belt tension load requirements of 14 CFR 27.562. For these models, he claimed, “there would be little to no benefit if the design revisions required to demonstrate full compliance with [the CRSS standards of ] 27.561, .562, and .785 were incorporated.”
Likewise, working group member John Wittmaak of Bell Helicopter contended that “all in-production Bell models, whether certified to 27/29.952 or not, currently have CRFS as part of their basic aircraft offering. . . . Bell Helicopter believes efforts to certify currently in-production CRFS systems provide no benefit and ultimately delay availability and increase costs associated to retrofit solutions for pre-CRFS aircraft.”
In its report, the working group observed that “partial implementation of the subject regulations may provide a significant portion of the benefits while avoiding much of the costs.” The group expects to study this further in its next task phases, which will include making specific recommendations on how to implement existing occupant protection standards, or proposing new, alternative performance-based safety regulations.
The FAA stated that it will continue to work with the group, “with the desire to create a more refined cost-benefit analysis which aligns with other ARAC and FAA economic analysis to support the next tasking actions.”