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DGAC objecting to cost sharing / flight pooling in France

Peter wrote:

Can anyone guess at the DGAC’s motivation for its relatively hard position on this issue?

The unions

That’s an interesting paper, bookworm. [ local copy ]

However, AFAICS, that one is from Brussels, not from France, so I wonder why EASA (which is an agency of Brussels) brought in this very liberal concession and seemingly only France has picked up on that paper? Is the ETF specially powerful in France?

The ETF union wants to block all cost sharing with the general public which probably means advertising to be limited to a flying club – a rule like the UK had for many years. However, the internet busts this “physical club” model and even that has been a grey area in the UK for ages.

The ETF hangs its coat on the US situation but that is not the same as the European one. US pilots seem to do little cost sharing (why, is another fun discussion) whereas much of the European rental scene would vanish if the strict US-style “common purpose” cost sharing was implemented. Many people here will not fly at all unless they can cost share.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

much of the European rental scene would vanish if the strict US-style “common purpose” cost sharing was implemented

Absolute nonsense. In the years after I got my PPL in 1992, I did lots of flying for bachelor parties and stuff like that and bringing along friends and family sharing the costs. More than two decades before this quasi-commercial EASA “cost sharing” thing, cost me “nothing”. Also, I did “countless” glider tows before this EASA thing, cost me nothing. The cost sharing was a knee-jerk reaction to other EASA regulations being implemented. They did not open up for the usual sporting activities, like glider towing, lifting skydivers, taking along passengers and sharing costs in the usual non profit organisation as a club or sporting teams. Everything like that would have to be commercial, and this would kill all sporting activities, because the costs would sky rocket. It was particularly the sporting (gliding and skydiving) communities in Germany that objected loudly, maybe also in France? Eventually EASA made these cost sharing regulations, which also includes actual cost sharing on a quasi commercial way for passenger transport. This quasi commercialization does nothing but to increase the per hour cost of GA. Higher insurance costs, makes it possible to purchase higher priced aircraft and so on. A normal person in his 20-30s cannot fly much unless he shares costs. What we need is a decrease in cost. Cost sharing can be done just fine in a strict non-commercial, common purpose way, as it always has been done, and is still being done for “microlighters”. Today I tow gliders in a microlight, cost me nothing.

The elephant is the circulation
ENVA ENOP ENMO, Norway

Absolute nonsense.

Possibly in Norway.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Possibly in Norway.

Not just in Norway…

ESKC (Uppsala/Sundbro), Sweden

Peter wrote:

Is the ETF specially powerful in France?

No, but this issue has been discussed within french pilots unions
ETF usually pick up issues at national level and brings to the European level.

Peter wrote:

I wonder why EASA (which is an agency of Brussels) brought in this very liberal concession and seemingly only France has picked up on that paper?

This is not a surprise. For the lasts few years, the agency only had liberal views (ATM, airops, maintenance…).
Just like we also have maintenance organizations association against Part-M light.

LeSving wrote:


Absolute nonsense.
This quasi commercialization does nothing but to increase the per hour cost of GA. Higher insurance costs, makes it possible to purchase higher priced aircraft and so on

I agree.
Most of the GA flying scene in France is performed by clubs which are some sort of NPO. For now, these clubs are exempted from VAT.
However, it looks like that the quasi commercialization of flights would make them subject to the VAT.
So the immediate effect of this regulation is more likely to be an immediate 20% increase of the cost.
This is why the flying club scene is likely to prohibit commercialization of such flights regardless the law permits it or not.

LeSving wrote:

What we need is a decrease in cost. Cost sharing can be done just fine in a strict non-commercial, common purpose way, as it always has been done, and is still being done for “microlighters”. Today I tow gliders in a microlight, cost me nothing.

Agree.

[ local copy of above doc ]

Last Edited by Guillaume at 02 Jun 10:46

Just like we also have maintenance organizations association against Part-M light.

That is REALLY interesting… do you have any examples, @Guillaume?

One always suspected that, of course.

However that really belongs here

The 20% VAT angle has not been mentioned before. Yes that will kill cost sharing on the French club rental scene, so only owners (operating out of the club system) will be able to offer it.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

do you have any examples ?

Yes. EASA CRD 2015-08 . In french

comment 546 comment by: GIPAG France (French General Aviation Operators Professional Union)
……
To conclude, the GIPAG France can’t support this new regulation since all the negative effects are impacting GIPAG members as you well described it in the paragraph 2.3.4. Moreover the consequences of this new regulation on approved frameworks will both, create unfair competition and will discourage them to keep the approval and they will therefore prefer not to extend the approval. This is not what GIPAG France wants.

Last Edited by Guillaume at 02 Jun 11:41

Peter wrote:

Possibly in Norway.

Not only in Norway. In France too. Concerning the “bachelor party” flights they were covered by the “Baptême de l’air”, but there were relatively strict rules about who could carry out the flights. The pilot needed a medical less than 12 months old and at least 30 or 40 hrs in the last 12 months. The flying club got the profit. The volume of flight hours had to represent a small part of the total flight hours flown by the club aircraft.

These flights are now known as “introductory flights” in the EASA regulations, but contrary to French regulations, there is no minimum experience or recent experience requirement.

Cost-sharing with friends and family has always been allowed, just like they are now according to EASA regulations, and EASA has not changed anything about that.

The only thing new in the EASA regulations as far as France and Norway are concerned is the ability to advertise cost-sharing flights to the general public.

LFPT, LFPN

I think the comments on “possibly in Norway” are misplaced because the comment I was commenting on was

Me: “much of the European rental scene would vanish if the strict US-style “common purpose” cost sharing was implemented”
LeSving: “Absolute nonsense”

The subsequent comments imply that the GA scenes in Norway, Sweden (airborne-again being in Sweden which I assume his “Not just in Norway…” comment is aimed at) and France don’t need cost sharing in order to flourish. That would be great, and is probably true for the US one, but the UK one most definitely does need it.

Look up the US common purpose rule to see what I was talking about (several past threads).

I actually have no clear personal view (no stake in this discussion) on allowing free advertising of cost sharing and allowing the pilot get 99.9% of his cost recovered. Sure, this will not allow anybody to run a business on the back of this concession, but it will draw out some number of incompetent pilots into offering flights. Ask any number of experienced pilots privately on how many would fly in the back of a plane flown by some random pilot and the majority will say NO WAY. And it isn’t just plain PPLs; there are some truly crazy risk takers who have an IR. So I can see the objections too. The UK average is of the order of 20-30hrs/year so you don’t need a PhD to work out the potential for trouble. Whether we will get any, I have no idea. It is wholly possible that the whole issue will not fly anywhere simply because of a lack of demand combined with a “lack of rental aircraft availability” when cost sharing is suspected by the club business which owns the plane. And only a tiny % of pilots are outright owners who also want to fly with random people breaking their €800 Bose A20 headsets, etc.

Administrator
Shoreham EGKA, United Kingdom
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