Thank you all for your thoughts on the issue.
Whilst I am not specifically au fait with Emirates and GCAA policy relating to this matter, on the basis that the UAE is on course for JAR compliance, I quote the following UK CAA requirements on the issue.
UK SRG FODCOM 24/2002 (Flight Operations Department Communication) on recording of flight times states the following:
RECORDING OF FLIGHT TIMES
2.1 This subject refers to the recording of flight time for Flight Crew Licensing purposes only. Flight time recorded in order to comply with Article 72(3) of the Air Navigation Order 2000 (ANO) shall continue to be recorded in accordance with the operator’s approved Flight Time Limitation Scheme and Article 72(a) of the ANO.
2.2 Introduction
2.2.1 There appears to be some confusion over the recording of flight times when an aircraft crew consists of more than the required number of pilots i.e. a ‘heavy’ crew.
2.2.2 The rules on logging of flight time are laid down in JAR-FCL 1.080, but for clarification the following should apply.
2.3 Pilot in Command
2.3.1 The designated commander of the aeroplane may log as pilot in command all the flight time. This includes rest taken on board.
2.4 Co-Pilot
2.4.1 The designated co-pilot of the aeroplane may log as co-pilot all the time he acts as co-pilot whilst sitting in a pilot’s seat.
2.4.2 He may log as Pilot In Command Under Supervision (PICUS) all the time he occupies a pilot’s seat and acts as pilot in command under the supervision of the pilot in command or a cruise relief pilot substituting for the pilot in command.
2.4.3 He may also log as pilot in command all the time he is acting as pilot in command and substituting for the designated commander of the aircraft when he is taking rest.
2.4.4 He may not log as flight time any periods during which he does not occupy a pilot’s seat.
2.5 Cruise Relief Pilot
2.5.1 A cruise relief pilot may log as pilot in command all the time he occupies a pilot’s seat as relief for the designated commander.
2.5.2 He may log as co-pilot all the time he occupies a pilot’s seat as relief for the co-pilot.
2.5.3 He may log as PICUS all the time he occupies a pilot’s seat and acts as pilot in command under the supervision of the designated commander or his relief.
2.5.4 He may not log as flight time any periods during which he does not occupy a pilot’s seat.
This all makes sense when considering the recording of flight time for licensing purposes. If you are not the designated a/c Commander for the flight and have not been at the controls of the a/c for a portion of that flight, then obviously you cannot log that flight time as part of your total flying experience. However, as paragraph 2.1 above states: “This subject refers to the recording of flight time for Flight Crew Licensing purposes only. Flight time recorded in order to comply with Article 72(3) of the Air Navigation Order 2000 (ANO) shall continue to be recorded in accordance with the operator’s approved Flight Time Limitation Scheme and Article 72(a) of the ANO.”
Within the ANO Article 72 comes under the section of FATIGUE OF CREW AND PROTECTION OF CREW FROM COSMIC RADIATION.
Fatigue of crew - operator's responsibilities
72 - (1) The operator of an aircraft to which this article applies shall not cause or permit that aircraft to make a flight unless:
(a) he has established a scheme for the regulation of flight times for every person flying in that aircraft as a member of its crew;
So basically article 72(a) refers to the requirement for an FTL scheme to be in force, in effect the equivalent of a CAP371 document, which I believe Emirates tend to broadly follow. This statement therefore indicates that whilst only time at the controls can be logged for licensing purposes, all time spent on an a/c as part of the operating crew must be considered when considering the avoidance of fatigue of crew, i.e. follow the requirements of CAP371.
EK and the GCAA may follow a variation of CAP371, however the new augmented crewing policy does not appear to follow the spirit of the regulations.
Any further thoughts anyone?