With reference to the answer given to Appendix 4 Research Questions, Q10:
Answer (b) [i] "Any positioning flight, [b]before or after a FDP[/b], must be considered to be part of the FDP and the normal FDP limit that applies must be reduced by the duration of the positioning flight."[/i] (Appendix 4, para 7)
and,
Bob Tait Appendix 4 Summary,
5. Positioning - If a pilot is required to undertake a positioning flight (that is as a passenger, not a FCM), the duration of the positioning flight is to be included in the FDP [b]before or after[/b] the positioning flight.
However, para 7 only states that "[b]On completion[/b] of assigned flight duties in an FDP (the relevant FDP), a FCM may position to a suitable location as required by the AOC holder", and
6.3(d) in the Definitions of CAO 48.1 says that,
"Positioning, [b]if undertaken immediately after[/b] the person's flying duty and no other flying duty is to be conducted in the duty period - is [b]not[/b] part of his or her FDP"
[b]Q:Does positioning [u]after[/u] flying duty count as part of the FDP?[/b]
I think the wording in the Bob Tait Appendix 4 Summary is not completely accurate.
The definition of FDP in CAO 48.1 states that the FDP:
"[i](b) ends at the later of:
(i) the person’s completion of all duties associated with the flight, or the last
of the flights; or
(ii) 15 minutes after the end of the person’s flight, or the last of the flights.[/i] "
As you identified, positioning [b]before[/b] the FDP is considered part of the FDP (and the reporting time for the FDP includes this). Positioning [b]after[/b] the FDP "[i]is not
part of the FDP or off-duty period. However, it is added to the FDP for calculating off-duty period
requirements.[/i]".
It is also "[i]is duty and part of the duty period.[/i]". (CAO 48.1 Para 6.3)
So positioning after a FDP is considered part of the duty period, but not part of the [b]flight[/b] duty period.
