Clearing the cost benefit hurdle

To justify the cost-effectiveness of a $500 million program to install more crashworthy seats in airliners, federal officials had to increase the number of lives saved. Under an executive order, all rulemaking initiatives must demonstrate that the benefits are greater than the cost of a safety program. The latest example further illustrates the capricious and arbitrary nature of cost-benefit calculations previously illustrated in this publication (see ASW, Aug. 6, 2001). Details are contained in an Oct. 4 supplemental notice of proposed rulemaking (SNPRM). The document declares that within four years of the new rule becoming effective, all newly manufactured aircraft must be outfitted with passenger and flight attendant seats fully capable of withstanding dynamic impact loads of up to 16G. Within 14 years of the rule's effective date, seats in all other aircraft must be retrofitted to the same standard. The program includes commuter/regional aircraft with as few as 10 passenger seats.

Federal Aviation Administration (FAA) officials estimate the program will cost more than $518 million over the 20-year "period of analysis" spanning 2000-2020. About 55 percent of the total projected cost will be incurred upgrading seats for flight attendants, which represent a mere 2 percent of the seats covered by the SNPRM. The National Transportation Safety Board (NTSB) has expressed its concern about seats for flight attendants. The jumpseat for two flight attendants collapsed in the relatively minor impact during the March 5, 2000, overrun of a Southwest Airlines [LUV] B737-300 at Burbank, Calif. (see ASW, Aug. 19).

Hold that $518 million total cost figure in mind. The more crashworthy seats are estimated to avert $409.6 million in deaths and injuries, using as a basis $3 million per life and $0.5 million per injury. That "benefit" falls some $109 million short of the "cost." How to produce another $109 million in benefit? FAA officials figured that with more crashworthy seats, 2.7 flight attendants would not be injured, and 2.3 flight attendants would not be killed. Ignore for purposes of this brief discussion fractional injuries and deaths. Total: five additional flight attendants functioning in a post-crash scenario. Each flight attendant was estimated to save seven passengers from death. Hence, 5 X 7 = 36 passenger deaths avoided, at $3 million per the statistical value of a life and, tidily, another $109 million in averted fatalities. This sum was precisely the amount needed to justify the upgraded seats in terms of cost-benefit.

The SNPRM alludes to other issues, which evidently have been the subject of no minor controversy in various meetings, symposia and discussions. In the general move to upgrade seats from 9G to the 16G impact standard, and to the additional horizontal and vertical deceleration forces elucidated in the SNPRM, the subject of added weight came up. Various industry representatives asserted that the stronger 16G seats would add as much as 400 pounds to the weight of an airplane. The FAA countered that if the 16G seats are properly designed, they needn't weigh more. The SNPRM then went on to point out that operators are adding things to seats for the entertainment of the passengers while eschewing improvements to make them safer:

"The FAA maintains that the current trend of installing additional equipment on seats for passenger convenience and entertainment primarily causes seat weight increases. Devices like telephones and video screens are common additions to seats that, along with their supporting structure, increase seat weight.

"The FAA maintains that if any increases in weight between a 9G seat without extra features and a 16G seat without extra features exist, they are small and the resultant increase in safety is justified."

By the way, the 16G standard is not all that demanding. Driving a compact car at a speed of 35 mph into a wall will produce about a 35G deceleration, and with the three-point lap and shoulder belts in cars, the body can withstand decelerations of 40 to 50Gs for short peaks.

The SNPRM defines the meaning of the term "16G compatible" and proposes to prohibit operation of aircraft not equipped with such seats. The deadline for comments is Dec. 3, and they should be submitted to Docket No. FAA-2002-13464.

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