Originally Posted by
embraer
You guys are over thinking this.
Commuting has nothing to do with rest time. You are still "off" until you sign in.
To put it another way: these rest rules apply when you are signed in for a sequence and receiving per diem.
When signing in on day one you still have to look back 10 hours and find no duty time. Those are your days off. What you do on your days off is your business and does not interfere with 117 rest rules.
Regardless if you spent your days off golfing, commuting, sleeping, or watching porn you were still at "rest". Once you sign in its a different story.
That's my take as well. The point of this is prevent the company from putting you into a fatigue-inducing situation while under their control, ie on an overnight.
As long as you have the required duty-free period prior to starting a trip, it will be assumed that you had "sleep opportunity". It does not require you to sleep, not does it require you to spend eight hours in a a "suitable facility" on your days off.
The existing regs requiring you to be non-fatigued when you come to work still apply. The FAA is not attempting to regulate how you accomplish that, and they are unlikely to ever do so. A reg requiring pilots to be in domicile ten hours prior to show would most likely create that pilot shortage everyone's been talking about, with dire economic consequences. Nobody wants that, not airlines, not ALPA, not pilots, and not the FAA.
There is also no legal precedence that I've ever heard of to regulate an employee's off duty activities to this degree. What if the baby starts crying? You'd be legally obligated to call off the trip.