Part-ML and inflating CAMO cost

@Airborne_Again wrote:

We’ve seen a similar increase (+60%).

Do you expect this to be only this year, or for ever ?

@UdoR wrote:

I’ve started on 700EUR/yr now, new contract 2021

Why have you chosen to go with a CAMO instead of your own, I mean, was it only a way to feel “supported” in ownership?
Is the CAMO attached to the mechanics shop as for me ?

@Snoopy
I think I now have the concepts in mind. In my case: the aircraft is owned by a society and I am the sole shareholder. The society aims at renting its aircraft to other pilots and schools. For years, the aircraft was maintained as part-M with a CAMO (with MF/MG agreements), and it’s now transitioning to Part-ML in a CAO (very same shop). Which means a controlled environnement due to my allegedly “commercial operations”.

Those days, I wonder if I shouldn’t consider a significant step: assuming airworthiness on my own and pass orders to an independant part-66 mechanics on my field.
Let’s be clear, I don’t want to improvise, I would mainly stuck with MM, as I have always done. The point is: why would I pay 1300€+tax to have seo take the liability to delay my propellor governor overhaul by a year (ie a deviation, what happened this year). I should as well overhaul it when it’s due: better pay actual work than paper work.
I need to assess what part of my activity would have to stop, hence my need to understand what commercial operations are.

@boscomantico, pointed us toward Part-NCO decryption some years ago.
One could read about the definition of commercial operations, which I struggle with:

The Air Ops Regulation defines “commercial air transport” as “an aircraft operation to transport passengers, cargo or mail for remuneration or other valuable consideration”.

The Basic Regulation defines a “commercial operation” as “*any operation of an aircraft, in return for remuneration or other valuable consideration, which is available to the public or, when not made available to the public, which is performed under a contract between an operator and a customer, where the latter has no control over the operator*”.

(Note, however, the lack of clarity over who the operator is, as discussed in the background section above.)

It would be fair to say that a non-commercial operation is one that is neither a commercial operation nor a commercial air transport operation.

These definitions are very broad, and so the Air Operations Regulation also sets out a number of types of operation that are to be operated under Part-NCO, even though strictly they fall under the definition of commercial operation or commercial air transport operation. These include:

flight training
cost-shared flights by private individuals, on the condition that the direct cost is shared by all the occupants of the aircraft, pilot included and the number of persons sharing the direct costs is limited to six;
competition flights or flying displays, on the condition that the remuneration or any valuable consideration given for such flights is limited to recovery of direct costs and a proportionate contribution to annual costs, as well as prizes of no more than a value specified by the competent authority;
introductory flights, parachute dropping, sailplane towing or aerobatic flights performed either by [an ATO], or by an organisation created with the aim of promoting aerial sport or leisure aviation, on the condition that the aircraft is operated by the organisation on the basis of ownership or dry lease, that the flight does not generate profits distributed outside of the organisation, and that whenever non-members of the organisation are involved, such flights represent only a marginal activity of the organisation.
These operations are also treated as non-commercial for the purposes of the Aircrew Regulation, i.e. they are within the privileges of a PPL holder, as well as falling under Part-NCO

I’m still unsure:

• when I rent my aircraft to an ATO, is it flight training ? (though the ATO may demand the enrollment in a CAMO/CAO)
• when I rent to PPL/CPL holder for private flights, does the client have any control on the operator ? (this sentence is obscure)

I had an idea this morning. My renters are faithful and have been with me for years. The idea was to sell to each of them 1% of the society. It needs some registration paperwork, but in the end, they would definitely have a control over the operator. I’m waiting for your opinions

PS: just a quick survey @peter, @boscomantico. How many years ago since your last propeller, governor and engine overhaul ? Any owner is welcome to answer

(For recall, propeller should be 6 years, governor 5 years in my case, I guess you too Peter ?)