👉 The CAA have requested a consultation on cost shared flights. Our initial thoughts regarding the proposed rule changes.
Since its launch in 2015, Wingly has helped more than 30,000 cost-shared flights from airfields across the European continent. Helping private pilots share their passion for aviation while being able to fly more and share costs. At the same time introduced more than 40,000 members of the public to the thrills of flying in light aircraft. And since 2015 the UK CAA has been one of the strongest advocates of cost shared flight platforms at the European level showing the advantages of such a service for flying safety and the economy by helping pilots to fly more and keep current by making it more affordable.
On Wednesday the 1st of December, the UK CAA provided a proposal to update the cost-sharing flights regulation and launched a consultation to gather feedback from the General Aviation community.
Having learned about this proposal at the same time as many of you, the goal of this letter is to give you our first impressions and make you aware of this ongoing consultation. We here at Wingly applaud the CAA’s efforts to further clarify the cost-sharing regulations. The differentiation of cost-shared flights from illegal grey charter operations will only help alleviate the confusion amongst stakeholders. Furthermore, creating clear blue water between transparent flight-sharing on a publically visible platform as Wingly as opposed to the highly dangerous illegal transport conducted through clandestine channels. This move will only further promote the use of cost-sharing as well as the use of Wingly in the UK General Aviation ecosystem.
That being said, as the largest platform with a history of more than 20,000 cost-shared flights, we wanted to also put forward our thoughts about where certain points have generated concerns as they may do more harm than good. We have requested further clarification from the CAA and once this has been further studied we will publish our official answers to their survey publically next week.
You can find their proposal and survey here
You will find our initial feedback on certain points of the proposal below:
Having looked at the consultation proposal, the definition of common purpose is unclear and hence we do ask the CAA for further clarification regarding this.
In the UK, 77% of all Wingly flights that have taken place have been A-A flights, 21% being A-B-A excursion flights ( such as day trips to have lunch on the isle of wight) and only 2% of the flights have been A-B flights where a pilot advertises a flight they are doing and find passengers that have been willing to go with them.
While the majority of flights remain unaffected we do want to understand why flights without a common purpose are inherently more unsafe. Additionally, as both the pilot and passenger are participating in the costs of the flight, both parties must have an inherent purpose to do the flight. If the pilot wouldn’t have the same purpose as the passenger, why would he pay out of his pocket to fly with the passenger?
While the current cost-sharing rules have not defined what proportion of the costs the pilot needs to share. The Wingly platform has always put as a guideline the flight must be shared equally between all occupants of the aircraft (including the pilot) through our platform’s mechanics. And the fact that it remains a guideline and not the law creates a margin of safety for the pilot. However, if equal sharing is now enforced as the rule, pilots who are sharing flights on Wingly could now be liable to prosecution in the instance of a tailwind cutting their flight a little shorter. Thereby making them pay 45% of the costs rather than 50% in a 2 person flight. While in each instance no profit has been made. The safety of the flight is also not additionally compromised due to the added 5% cost paid by the passenger.
By legally enforcing equal sharing, the rules will remove this valuable safety net that pilots have benefited from when this event occurs. Moreover, by no means will this ever stop the illegal transport operators who have been breaking the rules as they never operated cost-sharing flights, to begin with.
Passenger Declaration Forms and Paperwork:
Being the largest flight-sharing platform as well as the longest-running platform in the UK, Wingly has facilitated cost-shared flights with more than 61,000 passengers on board.
To have the safest flights possible we also need both pilots and passengers to understand the risks involved. Wingly not only has a passenger declaration for flights booked on Wingly but we put forward a briefing to both pilots and passengers with regards to sensitising them to light aircraft flying as well as flying with passengers. The pilot conducting the flight also goes through a briefing with their passengers on the day of the flight. Throughout this period the flight can be cancelled at any time should the pilot not wish to go ahead and the passengers are simply refunded their share of the costs.
Additional paperwork would not change what we already do, and neither will this prevent illegal operators however, we extend our willingness and experience in this sector to work with the CAA to develop an extensive briefing for pilots as well as the implementation of the UK Cost-sharing charter. As we did in the past with the EASA charter when the UK was a member state. Moreover, there is a difference between safety materials made available to the public and waivers enforced by the regulation putting the responsibility on the pilot. We believe it is great to create a safety culture around cost shared flights, but dangerous to create too many layers of red tape where some pilots could become liable not because of pilot error, but because they would have forgotten to file and sign a new additional administrative paper.
In the case of joint owners or aircraft renters, this cost is easily ascertained. At the moment one of the biggest barriers for PPL aircraft owners to take part in cost sharing has been the way direct costs have been defined to be calculated. For aircraft owners, we believe that allowing them to share only the fuel and landing fees costs as direct costs is unfair. We believe that at least all the variable costs should be taken into account such as the hourly costs for the engine, the propeller as well as the 50 hours and 100-hour maintenance checks that have not been included. For example, for an engine certified for a potential of 2,000 hours, the owner could add to the direct costs 1/2,000 of the total cost of the engine per flying hour. And it would also make sense to allow them to share a proportionate amount of the fixed annual costs.
While we were not part of the internal working group that put forward the proposal we want to put forward our expertise and our years of experience working on cost shared flights from both the pilot’s and the passenger’s perspective to the CAA, as while overall we think it is a great idea we also want to help address the above concerns. We hope to enter a positive discussion with the CAA with regards to the new rules as well as for the creation of the cost-sharing charter.
Lastly to our community that has always stood by us over the years, we will continue to push for regulations that allow for cost-sharing to take place in the safest ways possible without the need for additional red tape that would make it more complicated. We will publish our answers to the survey in the next week