I still have a problem with the 1.33 factor. It clearly was taken from ANGRs in the distant past and follows the old Perf E thing, gross TODR x 1.33 must be less than or equal to EDA, with the logic that perf E was mandatory for AoC operations and advisory for private flights. Anyone operating say a Seneca in the UK on both AoC and private would now have 2 quite different sets of factors to apply, a 20 year old Perf E advisory factor for private and the mandatory Class B factors for AoC ops. Shurely shomething wrong? Also
(1) the ANGR factor is UK only, if we are trying to teach PPL to the EASA syllabus across Europe (as we are) this 1.33 is going to be restricted to UK and a few Northern European nations who still think the CAA is worth following.
(2) over the years the EDA part of it has been forgotten, so now it seems to be applied to what? TORA? TODA? ASDA?