Why I Spent $11,524 to Replace Perfectly Good Fuel Tanks on my R44 Helicopter

The short answer: Lawyers.

I’m not sure when the brouhaha began.

It might have been right after this crash, when a helicopter operating at or near gross weight at an off-airport landing zone in high density altitude situation by a sea level pilot crashed, killing all four on board and starting a forest fire that raged for two days.

Or it could have been earlier, after this crash, which I blogged about here, when a helicopter operating 131 pounds over the maximum gross weight for an out of ground effect hover by a brand new helicopter pilot low-level at an off road race crashed, severely injuring all three people on board.

I’m sure it was before this crash, when a 250-hour pilot landed to “relieve himself” at an off-airport landing zone with a density altitude of at least 11,000 feet, then panicked when he got a low rotor horn and aux fuel pump light at takeoff and botched up a run-on landing on unsuitable terrain, severely injuring himself and his wife.

These three cases have two things in common (other than pilots who did not exercise the best judgement): the helicopters were R44s and the crashes caused fires that injured or killed people.

Crash an Aircraft, Have a Fire

Of course, if you crash any kind of aircraft that has fuel on board hard enough into terrain, a fire is likely to result. Fuel is flammable. (Duh.) When a fuel tank ruptures, fuel spills. (Duh.) If there’s an ignition source, such as a spark or a hot engine component, that fuel is going to ignite. (Duh.)

I could spend the rest of the day citing NTSB reports where an airplane or helicopter crash resulted in a fire. But frankly, that would be a complete waste of my time because it happens pretty often.

Don’t believe me? Go to http://www.ntsb.gov/aviationquery/index.aspx, scroll down to the Event Details area, and enter fire in the field labeled Enter your word string below. Then click Submit Query and check out the list. When I ran this search, I got more than 14,000 results, the most recent being a Cirrus SR22 that crashed on April 27, 2012 — less than 2 weeks ago.

The Knee Jerks

But Robinson reacted in typical knee-jerk fashion. After issuing a ridiculous Safety Notice SN-40, “Postcrash Fires,” that recommended that each helicopter occupant wear a “fire-retardant Nomex flight suit, gloves, and hood or helmet,” they began redesigning components of the helicopter’s fuel system. First they redesigned the fuel hose clamps and issued Service Bulletin SB-67, titled “R44 II Fuel Hose Supports.” Then they redesigned the rigid fuel lines to replace them with flexible lines and issued Service Bulletin SB-68, titled “Rigid Fuel Line Replacement.” And then they redesigned the fuel tanks to include a rubber bladder and released Service Bulletin SB-78 (superseded by SB-78A), the dreaded “Bladder Fuel Tank Retrofit.”

Why “dreaded”? Primarily because of the cost of compliance, which was estimated between $10,000 and $14,000.

Originally released on December 20, 2010 (Merry Christmas from the folks at Robinson Helicopter!), Robinson did give us some breathing room. The time of compliance was set to “As soon as practical, but no later than 31 December 2014.” I did the math and realized that my helicopter would likely be timed out — in other words, back at the factory for overhaul — before then. But the February 21, 2012 revision moved the compliance date up to December 31, 2013. At the rate I was flying — about 200-250 hours per year — it looked as if I’d still be flying it when December 2013 rolled along.

Is it Required?

I talked to my FAA POI. He’s the guy that oversees my Part 135 operations. He’s a good guy: reasonable and easy to talk to. He doesn’t bother me and I try hard not to bother him. After all, he’s got bigger operators with bigger headaches to worry about.

We talked about the Service Bulletin. Neither of us were clear on whether the FAA would require compliance for my operation. After all, it was a Service Bulletin, not an Airworthiness Directive (AD), which is definitely required.

We left off the conversation with acknowledgement that I didn’t have to do anything at all for quite some time. We’d revisit it a little later.

Pond Scum

Around this time, I was contacted by a lawyer representing the family of the 250-hour pilot who crashed in the mountains because he had to “relieve himself.” This guy had seen my blog posts about my problems with my helicopter’s auxiliary fuel pump — perhaps this one or this one or possibly this one. Or maybe all three.

He was looking for an “expert witness” to provide information about the problems with the fuel pump. It was clear that he was trying to pin the blame for his clients’ injuries on the fuel pump manufacturer and Robinson Helicopter. Not on his client, of course, who had caused the accident by making a series of very stupid decisions. Apparently, Robinson is supposed to make idiot-proof helicopters.

I got angry about the whole thing — lawyers shifting the blame to people who don’t deserve it — and responded as you might expect. I also blogged about it here.

I didn’t make the connection between lawyers and bladder fuel tanks. I believed — and still believe — that it’s not unreasonable for post-crash fires to occur in the event of an aircraft accident. It’s part of the risk of being a pilot. Part of the risk of flying.

The Buzz and Insurance Concerns

Meanwhile, the Robinson owner community was buzzing with opinions about the damn bladder fuel tanks. Some folks suggested that they’d been developed as a means for Robinson to make money off owners in a time when helicopter sales were slow.

Maybe I’m naive, but I don’t think that’s the case. I think Robinson was just trying to protect itself from liability. By offering this option, it would be up to the helicopter owner to decide what to do. If the owner didn’t get the upgrade and had a post-crash fire, Robinson could step back and say, “The new fuel tanks might have prevented that. Why didn’t you get them? Don’t blame us.” And they’d be right.

And that got me thinking about my insurance. So I called my insurance agent, who was also a friend and helicopter pilot. The year before, he’d managed to come up with an excellent and affordable policy for R44 owners and I’d switched to that policy as soon as my existing policy ended. Would I be covered if I didn’t get the tanks installed right away? He told me that of course I’d be covered. The compliance date wasn’t until December 31, 2013.

Buy Now, Save Money?

I also talked to my mechanic. He told me that the tanks were on back order and it could take up to eight months to get them. I was also under the impression that the cost of the tanks was going to rise at the end of 2011. And that if I ordered the tanks, I wouldn’t have to pay for them until they arrived. I figured that once they arrived, I’d store them until I was ready to have them installed. Or maybe even hold onto them until overhaul.

So I ordered them in late December, right before the Robinson factory closed for the holiday break.

I’d been misinformed. I had to pay for them up front: $6,800. Merry Christmas.

And, oh yeah: the price didn’t go up, either.

A Horrifying Scenario

Time went by. I thought about the damn tanks on and off throughout the winter months. In February, during my occasional checking of accident reports, I saw this report about an R44 with a post-crash fire. It got me thinking about liability again.

And then I started thinking about lawyers, like that sleezebag who had contacted me. And my imagination put together this scenario:

My helicopter crashes and there’s a fire. One of my passengers is burned. Although my insurance covers it, the blood sucking legal council my passenger has hired decides to suck me dry. He claims that I knew the fuel tanks were available and that they could prevent a fire and that I neglected to install them. He puts the blame squarely on me. My insurance, which is limited to $2 million liability, runs out and the bastard proceeds to take away everything I own, ruining me financially forever.

Not a pretty picture.

Is this what Robinson intended? I’d like to think not. But I’m sure that as I type this, some lawyer in Louisiana is working on a case using the logic cited above. The pilot might be dead, but his next of kin won’t have much left when the lawyers are done with him.

I started thinking that I may as well install the damn tanks — just in case.

Dealing with Logistics

In late March the fuel tanks were delivered. It cost another $310 for shipping. The two boxes weren’t very heavy, but they were huge. I had them delivered directly to my mechanic.

And then I started thinking about logistics. I had originally expected the tanks to arrive during the summer while I was gone for my summer work in Washington state. I figured I’d have them installed at my next annual or 100-hour inspection near year-end. But here they were, waiting for installation any time I was ready.

But when would I be ready? My mechanic said it would take about 10 days (minimum) to install them. Because the tanks had to be fitted to the helicopter, it was a multistep process:

  1. Remove the old tanks.
  2. Put on the new tanks and fit them to the helicopter. (Metal work required.)
  3. Remove the new tanks.
  4. Paint the new tanks.
  5. Reinstall the new tanks.

Most of that time was taken up with getting the tanks painted and waiting for them to dry.

Logistics is a major part of my life. I’m constantly working out solutions for moving my helicopter and other equipment to handle the work I have. I’m also constantly trying to schedule any maintenance at a time when I’m least likely to need to fly. This spring was especially challenging: I had to get my truck, RV, and helicopter up to Washington before the end of May. I also had to go to Colorado to record a Lynda.com course before the end of May.

So on April 13, I flew the helicopter down to my mechanic in Chandler and asked my friend Don to pick me up (in his helicopter) and take me home to Wickenburg. Then, the same day, I started the 3-day drive in my truck with my RV to Washington. I arrived on April 15. A week later, on April 22, I took Alaska Air flights to Colorado, where I stayed for another 6 days. Then, on April 28, I flew directly back to Phoenix. Don picked me up at the Sky Harbor helipad and dropped me off at Chandler. All the work on the helicopter was done and it looked great. I flew the helicopter back to Wickenburg that morning. Two days later, on May 30, I picked up passengers in Scottsdale and began the 2-day flight to Washington. We arrived on May 1.

ItemCost
Fuel Tanks$6,800
Shipping$310
Tank Installation$3,960
Tank Painting$454
Total Cost$11,524

The installation and painting had cost another $3,960 and $454 respectively, bringing my total for installing the damn bladder fuel tanks to $11,524.

I Blame the Lawyers

So, yes, I spent $11,524 for tanks that might only benefit me in the event of a crash. No guarantees, of course.

I didn’t need the tanks. They didn’t make flight any safer or better. They only might make crashing safer.

And the only reason I did this is so that a lawyer couldn’t point his finger at me and blame me for ignoring a Service Bulletin that wasn’t wasn’t required by law until (maybe) December 31, 2013.

The only reason I did this was to possibly prevent a lawyer from taking away everything I own, everything I’ve worked hard for all my life, in the unlikely event that my helicopter crashed and a fire started.

Do you want to know why aviation is so expensive? Why it costs so much to fly with me? Ask the lawyers.

Required Reading for Helicopter Tour Pilots

Two accident reports that clearly demonstrate how “hot dogging” can get you — and your passengers — dead.

November 25, 2013 Update:

The NTSB’s probable cause report for this accident is now available. The pilot was not at fault in this particular accident — it was a maintenance issue. As a pilot, I’m glad that the pilot’s name was cleared of fault but, at the same time, I’m concerned that maintenance shortcomings caused five deaths. The pilot was flying a ticking time bomb and it went off. There was nothing he could do to prevent the crash. And that scares me.

While the points presented in this blog post clearly do not apply to the Boulder City crash mentioned here, they are still important reading material for all pilots. Learn from other people’s mistakes.

On Wednesday, a Sundance Helicopters AS350 with a pilot and four passengers on board, crashed in the mountains near Boulder City, NV. It was on a “twilight tour” of the Hoover Dam and Lake Mead.

At this point, there’s no speculation about how the accident occurred. But, as usual, the media is dragging all the dirt they can out into the limelight to sensationalize the event and give people potential places to point blaming fingers.

One of the things the media has brought up is another Sundance Helicopters crash that occurred back in September 2003. I was unfamiliar with this crash — it must have occurred before my regular reading of NTSB accident reports began. Unsure whether I was confusing it with another crash, I looked it up today. But no, this was yet another instance of stupid pilot tricks becoming deadly pilot tricks.

I thought it was worth reviewing this case and another I’ve covered in the past and urge pilots to read both of the final reports carefully to see how reckless flying can kill. What’s interesting to me is how similar these two cases are — heck, they even took place within 30 miles of each other.

LAX01MA272: AS350, August 10, 2001, Meadview, AZ

I covered this accident briefly in Part 5 of my “So You Want to Be a Helicopter Pilot” series. Here’s the NTSB summary:

On August 10, 2001, about 1428 mountain standard time, a Eurocopter AS350-B2 helicopter, N169PA, operating as Papillon 34, collided with terrain during an uncontrolled descent about 4 miles east of Meadview, Arizona. The helicopter was operated by Papillon Airways, Inc., as an air tour flight under Code of Federal Regulations 14 (CFR) Part 135. The helicopter was destroyed by impact forces and a postcrash fire. The pilot and five passengers were killed, and the remaining passenger sustained serious injuries. The flight originated from the company terminal at the McCarran International Airport (LAS), Las Vegas, Nevada, about 1245 as a tour of the west Grand Canyon area with a planned stop at a landing site in Quartermaster Canyon. The helicopter departed the landing site about 1400 and stopped at a company fueling facility at the Grand Canyon West Airport (GCW). The helicopter departed the fueling facility at 1420 and was en route to LAS when the accident occurred. Visual meteorological conditions prevailed, and a visual flight rules flight plan was filed.

The pilot had a reasonable amount of experience with nearly 3,000 hours of flight time, all of which was in helicopters. He had CFI and instrument ratings.

The pilot, however, also had a reputation for hot-dogging. From the NTSB report‘s interview with previous passengers:

According to the passengers, once the tour started, the pilot was talking all the time. He was very informative, and they felt he knew his history and geography very well. They went over the Hoover Dam and Lake Mead. About 20 minutes into the flight, the pilot turned his head toward the back and was talking to the passengers as the helicopter flew toward a cliff. The people in the back were trying to get the pilot’s attention and point out that he was flying toward a cliff, but he pretended he did not understand what they were saying, as if this was all being done on purpose. All this time, the pilot was turned around and talking to the passengers in the back seat, while the passengers were all pointing up trying to get him to climb. One witness said she finally picked up the microphone and said, “they are really scared…turn around and pull up the helicopter,” and he did. She could not estimate how far they were from the cliff when the pilot terminated the maneuver.

One of the passengers stated that there were particularly exciting episodes during the tour that were frightening to some of the others. As part of the tour, they flew over a site that was used in the commercial motion picture film Thelma and Louise, and the pilot pointed out the cliff. The pilot stopped for fuel before he landed in the canyon for the picnic lunch. After lunch, no more stops were made. During the return to LAS, the pilot asked if they wanted to know what it was like to drive a car off of a cliff. She stated that they all said “no” to this question; however, he proceeded to fly very fast toward the edge of the cliff and then dove the helicopter as it passed the edge. The passenger reported that it was “frightening and thrilling at the same time but it scared the others to death.”

Both of these incidents — heading directly for a cliff and then diving like Thema and Louise over a cliff — were confirmed in a video tape provided by the passenger.

Crash Site
I don’t think the pilot expected to end up like Thema and Louise, too.

Evidence at the crash site indicated that not only was the helicopter’s engine producing power at the time of impact, but the collective was full up. The debris field was compact, indicating very little forward movement when the helicopter hit the ground. There was no evidence of any mechanical failure immediately before the crash. The NTSB ruled out many accident scenarios based on mechanical malfunctions before concluding:

In the absence of any evidence to indicate a preimpact mechanical malfunction, and given the density altitude, helicopter performance considerations, and virtually all of the signatures evident at the IPI and in the wreckage, the investigation revealed that a probable scenario involves the pilot’s decision to maneuver the helicopter in a flight regime, and in a high density altitude environment, which significantly decreased the helicopter’s performance capability, resulting in a high rate of descent from which the pilot was unable to recover prior to ground impact. Additionally, although no evidence was found to indicate that the pilot had intended on performing a hazardous maneuver, the high rate of descent occurred in proximity to precipitous terrain, which effectively limited remedial options available.

In other words, he most likely performed his Thelma and Louise maneuver, dove off the cliff, and because of high density altitude, was unable to arrest the decent rate before hitting the ground.

LAX03MA292: AS350, September 20, 2003, Grand Canyon West, AZ

This case is a lot worse. I’ll let the NTSB describe what happened briefly:

On September 20, 2003, about 1238 mountain standard time, an Aerospatiale AS350BA helicopter, N270SH, operated by Sundance Helicopters, Inc., crashed into a canyon wall while maneuvering through Descent Canyon, about 1.5 nautical miles east of Grand Canyon West Airport (1G4) in Arizona. The pilot and all six passengers on board were killed, and the helicopter was destroyed by impact forces and postcrash fire. The air tour sightseeing flight was operated under the provisions of 14 Code of Federal Regulations Part 135. Visual meteorological conditions prevailed for the flight, which was operated under visual flight rules on a company flight plan. The helicopter was transporting passengers from a helipad at 1G4 (helipad elevation 4,775 feet mean sea level [msl]) near the upper rim of the Grand Canyon to a helipad designated “the Beach” (elevation 1,300 msl) located next to the Colorado River at the floor of the Grand Canyon.

You need to read the NTSB’s full report to fully understand what happened here. You can download it as a PDF (recommended) or read it online.

The pilot was experienced. He was 44 years old with an ATP certificate for multiengine airplanes and for helicopters. He had CFI and instrument ratings for a variety of aircraft. He’d logged nearly 8,000 hours of flight time, nearly 7,000 of which was in helicopters. He had a clean record with the FAA.

But the pilot had also earned the nickname “Kamikaze” because of the way he flew. (And you can bet your ass that the media is having a field day with that in its coverage of Wednesday’s accident.)

99° Bank Angle
55° Pitch Angle
Two images from the NTSB report, calculating angles based on photographs and videos shot during other flights.

With a great deal of supporting evidence from the pilot’s previous passengers that same day and earlier, as well as photographs taken during flights with the pilot, the NTSB concluded that the pilot had a history of risk-taking behavior. Photographic evidence showed him flying at bank angles exceeding 90° with nose-down attitudes exceeding 50°. It’s estimated that he typically reached speeds up to 140 knots and rates of descent of 2,000 feet per minute.

With passengers on board.

For comparison’s sake, Sundance policy limited bank angles to 30° and pitch angles to 10° — both of which are very reasonable. Other pilots typically flew that portion of the flight at 110 to 120 knots, descending at 1,000 feet per minute.

Yet the report cites one passenger story after another of the pilot diving into the canyon and flying close to canyon walls. One former Sundance employee who had flown with him stated he “flew very close to the canyon wall” and “banked off one wall and then turned the other way, almost upside down.” One passenger claimed that his friend’s wife was screaming throughout the entire descent.

Sundance received at least two formal complaints about the pilot. There’s no evidence that anything was done about the first. The pilot was suspended for a week without pay after the second, but since Sundance was short of pilots, the penalty was never enforced and the pilot continued working with pay.

It should come as no real surprise that the pilot ran out of luck. According to the NTSB, on that September day:

The helicopter’s main rotor blade struck a near-vertical canyon wall in flight. The resulting damage to the main rotor system likely rendered the helicopter uncontrollable, and the helicopter subsequently impacted a canyon wall ledge.

There was a fireball when the helicopter exploded on impact. There wasn’t much wreckage. You can see for yourself; there are photos in the report. I wouldn’t even know it was a helicopter if it weren’t for the arrows pointing out parts.

Probable cause placed the blame on the pilot, as well as Sundance and the FAA:

The National Transportation Safety Board determines that the probable cause of this accident was the pilot’s disregard of safe flying procedures and misjudgment of the helicopter’s proximity to terrain, which resulted in an in-flight collision with a canyon wall. Contributing to the accident was the failure of Sundance Helicopters and the Federal Aviation Administration to provide adequate surveillance of Sundance’s air tour operations in Descent Canyon.

Disregard of safe flying procedures. That’s a bit of an understatement, no?

What We Can Take from This

If you don’t get the message I’m trying to convey here, you probably shouldn’t be flying anything — let alone passengers for hire in a helicopter.

It’s a fact: many of us fly a little nutty once in a while. Maybe low and fast over flat desert terrain. Or maybe threading our way though empty canyons at high speed. Or performing some other maneuver that takes all your attention and can easily turn into a disaster.

But when does “a little nutty” turn into pushing the aircraft beyond company or manufacturer limitations?

And who in their right mind would fly so dangerously with passengers on board?

You?

I hope not.

The point is that flying like a stunt pilot can get you killed. And if there are passengers on board, you’ll kill them, too.

Is that something you want to be remembered for? Do you want to be the subject of another pilot’s blog post about flying like an asshole with passengers on board? Do you want a derogatory nickname like “Kamikaze” brought up by the press eight years after your death when another pilot who works for your company is killed in a crash with his passengers?

How do you think the “Kamikaze” pilot’s family feels about his accident being brought up again? And again?

Think about why these pilots flew the way they did. Were they showing off? Or trying to get a rise out of their passengers?

In both instances, passengers made it clear — verbally, during the flight — that they didn’t want the pilot to fly the way he was. Think about the people pointing to a cliff face or the woman screaming throughout the descent. Why did these pilots treat their passengers with such disrespect? Scare them for no reason? Put their lives in danger? Was this fun for them? When is fun an excuse to risk other people’s lives?

Do you do this? If so, why? When will you stop? When your crash makes a big fireball like the ones in these stories?

Do you understand what I’m trying to say?

Read these accident reports. Two pilots are responsible for the deaths of eleven people with a twelfth person permanently disfigured.

Isn’t that enough to convince you not to fly like an asshole?

I only hope that Wednesday’s accident report isn’t another example for this blog post.

And my thoughts go out to the families of the victims of this stupidity.

Run-On Landing to Avoid Brown-Out?

Was this really the best decision?

Although I don’t usually comment on accident reports until the Probable Cause is released, this one seems pretty cut-and-dried. It’s also a good discussion topic. And, best of all, no one was hurt — which also leads me to believe that there won’t be many more facts about it published.

Here’s what happened:

The pilot and the border patrol agent had been dispatched to provide aerial support for an on-going border patrol mission. When the pilot realized there would be a delay in time for when they needed to engage in the mission he decided to land in a grass field and sit idle (to conserve fuel) until their assistance was needed. He said he made a run-on landing to avoid creating a brown-out condition. However, as the helicopter touched down and moved forward (approximately 34 feet) it nosed over and the main rotor blades struck the ground. The helicopter subsequently nosed over and traveled another 34 feet before it came to rest on its right side.

I question the decision to do a run-on landing on dirt/grass. (I suspect the pilot is also rethinking that decision right now.) Would it really reduce the amount of dust blown around enough to justify the added risk of forward motion in contact with the ground on a rough surface?

Brown-Out Landing
Military photo by Staff Sgt. Christopher Boitz of a HH-60G Pave Hawk doing a brown-out landing. (A run-on landing would probably be a piece of cake with wheels.)

I’ve landed [too] many times in dusty landing zones. The dust starts to rise about when I get into ground effect. The longer I’m above the ground pulling pitch, the more dust flies — unless it’s just surface dust and not really deep. The key, it seems, is to get the collective full-down as quickly as possible. When you stop pulling pitch, the dust settles.

When I was trained to do run-on landings, I was taught to make a shallow approach at a speed right around ETL and then slowly lower the collective once contact with the ground was made. So not only is pitch pulled during that shallow approach — when you’re close enough to get the dust flying — but it’s not full down for at least a few seconds after making contact. I can’t see how that would reduce the amount of dust on landing. I’ll be the first to admit that I haven’t tested this theory — we always practiced run-on landings on pavement — perhaps a reader can offer some insight from experience?

I’m thinking that a better way to handle this particular landing would be to make a straight in approach to the ground, thus minimizing the amount of time you’re pulling pitch while in ground effect. It would be important to assure that the touchdown spot was appropriate before committing. Then fly it right to the ground and dump the collective as soon as you’re on the ground. This is the way I try to handle my dusty LZ landings, usually to avoid kicking up dust around spectators or taking even more paint off my rotor blades. (Dust is nasty shit; I’ve already had my main rotor blades painted twice in 1,350 hours.) I admit I’ve never landed on dust so thick that true brown-out was possible — although I’ve come pretty close a few times.

What do you think? How would you handle landing at a LZ where brown-out was possible?