It is all about the context of what they are discussing.

in the NPRM commuting and rest was addressed specifically. I do not see it addressed specifically in the rule making like it was in the NPRM. Suffice to say more of that stuff was study and report back. Because of that language in the NPRM, if they try to apply this to commuting, the majority position should be that there was no study and no report ergo it does not apply to the time before your original report for duty.

If for some reason it does, the ATA will have a bird because there was no way for them to message their contracts with their labor groups. I see both sides not wanting to touch commuting with these FAR's. Of course Johnso, it depends on how the FAA "interprets" each little nugget they dropped in this new FAR.