EK Lawyer-
I agree with all of your concerns regarding implementation of 1000hrs limit. In my humble opinion, RIGHT NOW AND TODAY, the application of FACTORING towards the absolute flying limīt is the main issue.
The CARs clearly indicate that factoring is applicable for the recording of flight hours ( and so does the FCI-Title, by the way...). The application of factoring towards the maximum allowed hours is a free interpretation of EK (whoever that is...there are enough Managers in EK that do not understand that a crew bunk is not home sweet home..)
Comments to the GCAA should refer to that, and not to a 1000hrs limit which has not even been officially announced yet (although it might be soon..). Agree?