Interesting times! The UK CAA are switching across to EASA for 2016 and the way they are doing it is found in the following 2 links.
EASA Flight Time Limitations (FTL) | Airlines | Operations and Safety
More information | Airlines | Operations and Safety
The recommended implementation plan is included at:
http://www.caa.co.uk/docs/2948/20141128%20EASAFTLRegulationsCombinedDocumentGuidance%20edn% 202.pdf
This document states:
"A person on board an aircraft is either a crew member or a passenger. If a crew member is not a passenger on board an aircraft he/she should be considered as ‘carrying out duties’. The crew member remains an operating crew member during in-flight rest. In-flight rest counts in full as FDP, and for the purpose of."
That seems pretty clear!
EASA says:
“flight time” means, for aeroplanes and touring motor gliders, the time between an aircraft first moving from its parking place for the purpose of taking off until it comes to rest on the designated parking position and all engines or propellers are shut down;
That does too!
EASA limits on Flight Times says:
ORO.FTL.210 Flight times and duty periods
(a) The total duty periods to which a crew member may be assigned shall not exceed:
(1) 60 duty hours in any 7 consecutive days;
(2) 110 duty hours in any 14 consecutive days; and
(3) 190 duty hours in any 28 consecutive days, spread as evenly as practicable throughout that period.
(b) The total flight time of the sectors on which an individual crew member is assigned as an operating crew member shall not exceed:
(1) 100 hours of flight time in any 28 consecutive days;
(2) 900 hours of flight time in any calendar year; and
(3) 1 000 hours of flight time in any 12 consecutive calendar months.
(c) Post-flight duty shall count as duty period. The operator shall specify in its operations manual the minimum time period for post-flight duties.
So it seems someone at the GCAA is prepared to go out on a limb against the regulations that underpin CARS. Bearing in mind the fatigue conclusions coming out of the Colgan debacle and others, a brave man indeed!