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New GA friendly cost sharing rules (and what can and cannot be cost-shared)

It is less clear that you can’t share engine depreciation costs and 50/100 hrs inspection costs.

Exactly. Costs which are flying time related are clearly “direct costs”.

Posts moved to existing thread.

Administrator
Shoreham EGKA, United Kingdom

Moreover – the law cannot treat owners in a different way than renters.

If I rent – I can share rental fee – which includes everything! Camo, hangar, insurance, engine time and so on.. AND profit for owner!

If I own – only fuel and airport fees?

Sorry guys, there is something like “equall treatment”. The law cannot discriminate owners.

I am pretty sure that the “spirit” of wording “rental fee” includes more related costs in case of owners. (Explanation for Snoopy).
And we have to push it that way. The law that we have currently from EASA is much much more friendly and realistic than 20 years ago. Why? Because mostly GA community stood up and shouted for our needs. So go with the “good spirit” and not blindly read the papers.

Poland

Raven wrote:

Sorry guys, there is something like “equall treatment”. The law cannot discriminate owners.

Of course it can. That kind of “discrimination” happens all over the place.

ESKC (Uppsala/Sundbro), Sweden

I’m not „blindly reading papers“, I’m answering your question so as to remain on the safe side by a margin.

Sharing only fuel cost → legally safe.
Sharing engine cost → legally unclear.

If your opinion is that you can share all kinds of non-direct annual costs when flying strangers around in an airplane you own, that’s totally fine, just don’t state it is legal.

Freelance IRI / CB-IR Instructor
LOWG | Worldwide

Everything not explicitly prohibited is 100% legal (excepting more general principles e.g. public policy; not applicable here).

And in any functioning justice system any ambiguity is construed in favour of the defendant.

I suggest a review of arguments posted further back this thread – example. AFAIK nothing has changed – because nothing has been clarified. I am not counting threatening letters sent out by some flying school or an aeroclub president, as mentioned previously.

Of course, an owner has to pay some non hourly related costs e.g. the Annual. So an owner cannot recover his total expenditure, whereas if the same person rented the plane, he could recover his entire expenditure. I don’t think anybody disagrees with this.

Worth a mention in this thread that the UK CAA is not allowing cost sharing at all if the PIC is flying on the pilot medical declaration – see e.g. here – unless the aircraft is Annex 1. Very few people are aware of this.

Administrator
Shoreham EGKA, United Kingdom

Raven wrote:

Sorry guys, there is something like “equall treatment”. The law cannot discriminate owners.

It’s not discriminating against people. The owner is perfectly at liberty to rent an aircraft and recover his total cost through cost-sharing.

What’s discriminated against is the activity. That happens all the time in regulation.

EGLM & EGTN

Graham wrote:

It’s not discriminating against people. The owner is perfectly at liberty to rent an aircraft and recover his total cost through cost-sharing.

Ok, you are joking right?

Poland

To finish the discussion.
Guidance Material:

GM2 Article 6.4a(a);(b) Derogations
DIRECT COST
‘Direct cost’ means the cost directly incurred in relation to a flight, e.g. fuel, airfield charges, rental fee for an aircraft. There is no element of profit.

Clearly states that engine time and even maintenance expenses are also included.

Last Edited by Raven at 20 Nov 21:39
Poland

After some googling on the above words I found the doc here local copy and in it it has this

I highlighted the “e.g.”. This is crucial. It is a non exhaustive list. The items given are merely examples.

The “no element of profit” is obvious.

This clearly means that all flight-time-related costs can be included, because if you didn’t do the said flight, those costs would not be incurred.

One could argue it is poorly drafted because a real lawyer would have listed permitted items and nothing else would be permitted. But much EASA text is like this – badly drafted and ambiguous.

It is like the UK CV19 “regulations”. They were done in a hurry, not by real lawyers but by some bunch of officials down the pub, and all the lists of permitted activities are non-exhaustive lists.

We should be grateful that there are so many useless “lawyers” around; the only drawback is that they are all on €100k+ and somebody has to pay for all that

Administrator
Shoreham EGKA, United Kingdom

Raven wrote:

Clearly states that engine time and even maintenance expenses are also included.

Example:
I own a Pa28. If fly one hour that I want to cost share.

How much can I charge for maintenance and engine time?

Freelance IRI / CB-IR Instructor
LOWG | Worldwide
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