My profound apologies for also continuing the thread drift, but will copy the issue to the regulatory reform thread.
The precise cut-over points in the authority timeline continue to be avoided - who has the overriding authority when, working backwards:
+ the aircraft is pushing back,
+ the aircraft is stationary at the gate but the doors are closed, and
+ the aircraft is stationary at the gate, the doors are open and there are some passengers on board?
I’d suggest there is some precision, at least about when persons are obliged to comply with directions under 309A or the prohibition in the ‘new’ PED regulation.
Persons are not obliged to comply during any of the circumstances you’ve listed, because none of those circumstances occurs during flight/flight time as defined.
Decades of regulatory reform and this kind of silliness will remain.