Unfortunately, "aerodromes with a known high proportion of delays to traffic" is not always the case. Maybe operators with scheduled flights may have the data to determine what are those airports and mitigate the risk of exceeding the FDP accordingly.
On the other hand, there are operators conducting not scheduled flights, and on one day there is a delay of approximately 1 hour due to ground handling agent delays, and on the other day there are zero delays.
Operators do not always have the data and resources to mitigate the FDP exceedances.
Also, as the SIB and this article indicates, all organizations (operators, GH, aerodromes, etc) are understaffed and the resources are limited. Even if, there are identified aerodromes by the operator that may lead to flight duty period exceedance, is it always possible by the operator to hire additional pilots/cabin crew just to overcome this delay, which in many instances is within 60 mins?
I understand the importance of adherence to regulations and safe operations and I do not want to underestimate them, but limiting the commander's discretion may not always be the solution to this problem.
Probably, the ORO.FTL's AMCs and GMs should be reviewed by EASA.
