Before we lynch the Virgin pilots, maybe we should examine some of the circumstances...
They (VA) filed a flightplan to LGW with LHR as an alternate. This was accepted by ATC.
The uncertainties of life conspired to leave them with just over RES+ALT approaching the holding fix at destination. Their nominated alternate decided it was too busy to accomodate them and there was a 10min+ delay at destination (not advised previously).
They declared an emergency and landed at destination.
At what point were they non-compliant with JAR-OPS?
In my Company, we would have probably been on a 'PAN' at that stage but I don't know Virgin SOPs for low fuel state - not really central to the argument, anyway.
Yes, we've all (I hope) read the AIC about holding into London but at the end of the day it's only ADVICE (good advice, I know). There is no specific prohibition on arriving at LAM, OCK, WILLO, etc. with <20mins holding fuel.
Where is the AIC forbidding the use of LHR as an alt. for LGW and vice-versa? Maybe there should be one...