Note 3. A crew member is not considered Operating Crew Member, during the time spent at his/her rest period in an acceptable in-flight rest facility, or its equivalent under unforeseen circumstances, which will be reported to the GCAA. The duration of the flight rest time is not to be included in the flight time cumulative limits, but will be included in the Flight Duty Period Duty Time for cumulative limits consideration.
I stand to be corrected, but believe the intent of this note to mean - yes only the stick time is calculated for the following:
(b) The maximum cumulative duty hours for Flight crew of an aeroplane shall not exceed;
(1) 55 hours in one week, but may be increased to 60 hours, when rostered duty covering a series of duty periods, once commenced, is subject to unforeseen delays.
(2) 95 hours in any 2 consecutive weeks, and;
(3) 190 hours in any 4 consecutive weeks.
(4) 2000 Hours in 12 consecutive months
BUT must still abide by the following:
CAR-OPS 1.1125 Absolute Limits on Flying Hours
(a) No person shall act as an operating crew member of the flight crew of an aircraft if at the beginning of the flight the aggregate of all his previous flight times;
(1) during the period of 28 (twenty eight) consecutive days expiring at the end of the day on which the flight begins exceeds 100 (one hundred) block hours: or
(2) during the period of 12 (twelve months) expiring at the end of the previous month exceeds 900 (nine hundred) block hours:
Which must still abide by the following:
CAR-OPS 1.1126 Duty cycle, days off and leave entitlement
Crew member;
(a) shall not be on duty more than 7 consecutive days between days off, but may be positioned , and operate only, under unforeseen circumstances, when any other prescriptive flight time or duty cumulative limits are not exceeded, to the usual operating base on the eighth day, provided they are then allocated at least 2 consecutive days off, and
(b) shall have 2 consecutive days off in any consecutive 14 days following the previous 2 consecutive days off, and
(c) shall have a minimum of 7 days off in any consecutive 4 weeks, and
(d) shall have an average of at least 8 days off in each consecutive 4 week period, averaged over three (3) such periods.
(e) Shall be entitled to a minimum calendar annual leave according the applicable labour regulation
(f) Wherever possible, by operational demands, should be provided with days off in the home environment.
There is a distinction between flight time(block hours) and Cumulative limits ( all duty time, stick time, Reserve, RTGS, SEP, CRM)
Still is a lot of flying/work!
Maybe, just maybe that's the reason the leave can't be allocated ......not enough resources.