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

What if your engine is operated on condition (over TBO limit)?

I am convinced direct cost is fuel, oil and airfield charges. Projecting future maintenance or engine overhaul costs is not part of them.

How this is applied in reality is a completely different matter. My answer is really only for establishing in principle how the law is directed, as it personally is of interest to me.

always learning
LO__, Austria

Yes; that’s my view also.

It’s not hard to work out what costs are related to the current flight.

All the rest of the discussion is centred on complying with somebody else’s interpretation of somebody else’s interpretation of some guidance publication

For example a “50hr check” is a 50hr check i.e. you do it every 50hrs, so it is an hourly cost.

Same with the engine fund – in any jurisdiction where there isn’t an engine life limit. That’s a clear hourly cost also.

Administrator
Shoreham EGKA, United Kingdom

I can’t find it for some reason, but last time read about what can be included if the owners let’s you fly his/her aircraft:
- Fuel – yes
- engine/prop o/h hourly cost – maybe
- 50/100h labour costs – maybe
- cost of annual, any capital costs, etc – no.

EGTR

trying to COMPLY with the spirit of the law

You need to comply with the law as it is written, no more.

Another source is the CAA doc discussed before CAP1590

Same non exhaustive list.

These authorities do have lawyers available. OK; their calibre will vary, but they all know how to write an exhaustive list. Yet all have chosen to not do that.

Administrator
Shoreham EGKA, United Kingdom

So you pay your maintenance fee after each flight?

always learning
LO__, Austria

I guess if I was doing it and was trying to include everything I could and be as fair as possible I would use last years scheduled mx bill / hours flown. It’s not going to be perfect but it’s a pretty reasonable attempt. Obviously If I flew 50 hours last year and this year I am doing 600 hours of cost sharing flights then that won’t be right, but I am talking about trying to COMPLY with the spirit of the law, not trying to twist it to my advantage.

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?

always learning
LO__, Austria

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

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

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
156 Posts
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