Air Navigation Order 2005
Interpretation
155. —(1) In this Order—
‘Direct costs' means, in respect of a flight, the costs actually and necessarily incurred in connection with that flight without a view to profit ...............
That creates a distinction between cost-sharing in a hired aircraft and in an aircraft owned by the pilot.
SFH- Direct costs:
- Wet Hire: Hire costs incl fuel.
- Dry Hire: Hire costs plus cost of fuel.
- Landing fees (whether home or away), handling fees, navigation charges etc
Owner-pilot- Direct costs:
- Fuel.
- Landing fees (whether home or away), handling fees, navigation charges etc
- It does not include any contribution to annual running costs, insurance, depreciation etc, Those are are indirect costs.
It follows that a SFH pilot benefits more from the cost-sharing exception than an owner-pilot. Although that might be considered unfair, it keeps the position simple because direct costs are easily identified, calculated and, if there was to be an investigation, checked.
The cost-sharing exception is a concession. I can't now remember when it was introduced but, when I started flying, cost-sharing wasn't permitted. It happened frequently but people were discreet about it. The CAA then caught up with real world practice, accepted that genuine cost-sharing was harmless and changed the law. The criteria stipulated in the cost-sharing provisions are intended to stop private pilots conducting what in reality are public transport flights.
"Are your pax allowed to pay (landing fees) in entirety?"- The pilot must pay at least his/her proportion (relative to the total POB) of the direct costs of the flight.
- So, pax can pay the landing fee(s) in entirety provided their doing so does not mean that the pilot has then paid less than his proportion of the total direct costs of the flight. ie You cannot cost-share with pax as per the provisions set out above and then accept payment of landing fees (handling fees, navigation charges etc) on top because that would mean the pilot has not then paid his legally required minimum proportion of the direct costs of the flight.
BTW, I've occasionally seen some posters fussing about whether pax can pay for the pilot's lunch in addition to their contribution to the direct costs of the flight etc. I don't see a problem.
FL