Originally Posted by Dash8widget

From the FAA:

"Definition of Sleep Opportunity

APA asked the FAA to define ‘‘uninterrupted sleep opportunity.'' APA also asked whether the sleep opportunity has to take place at a specific location, such as the flightcrew member's home. Subsection 117.25(e) requires a certificate holder to provide a flightcrew member with 10 hours of rest that includes an 8-hour uninterrupted sleep opportunity immediately before the flightcrew member begins a reserve or FDP. Subsection 117.25(f) requires the flightcrew member to notify the certificate holder if he or she determines that his/her rest period will not provide an 8-hour uninterrupted sleep opportunity. A sleep opportunity generally commences once a flightcrew member is at a location where the flightcrew member can reasonably be expected to go to sleep and not have that sleep interrupted. The sleep opportunity does not need to take place at the flightcrew member's home, but it must take place at a location where the flightcrew member can reasonably expect to obtain 8 hours of uninterrupted sleep. In addition, as the FAA pointed out in the preamble to final rule, specific sleep situations ‘‘are difficult to capture in a regulatory standard.'' That is why § 117.25(f) requires the flightcrew member to notify the certificate holder if the flightcrew member determines that he or she cannot get the requisite amount of uninterrupted sleep."

Seems pretty clear to me - your time in the room MUST allow an opportunity for 8 hours of SLEEP. The fact that ALPA seems to think that 8 hours behind the door meets the above requirements is sad because, clearly, the FAA does not agree. Perhaps ALPA is getting hung up on this part: "A sleep opportunity generally commences once a flightcrew member is at a location where the flightcrew member can reasonably be expected to go to sleep and not have that sleep interrupted." I suppose this might make it sound like the sleep opportunity starts once you are in your room. BUT, the FAA goes on to clarify with the following statement: "...it must take place at a location where the flightcrew member can reasonably expect to obtain 8 hours of uninterrupted sleep." Again - "8 hours of uninterrupted SLEEP." Basically, the FAA could care less about "time behind the door" - what they care about is the chance to get 8 hours of uninterrupted SLEEP. In the end, however, it's that last sentence that is key- if YOU (not Delta, not ALPA, but you) determine that your time in the room does not allow for 8 hours of uninterrupted SLEEP you MUST call scheduling and have your report time adjusted.