Here is the paraphrase of the response I got back.

1) this has been talked aboud industry wide for years

2) the purpose of RAP is to be able to assign a FDP without having to first give an intervening rest period. Said another way, assign an FDP without giving the notice as required under the definition of LC reserve.

3) Why include "reserve" in the requirements of 117.25(b)? If 117.25(b) could preclude the assignment of an FDP during an otherwise legal SC RAP, then requiring 30/168 before starting the RAP becomes redundant.

4) The Hryniw letter doesn't provide any clarificaiton outside the exisit text of the regulation. No other legal interpretations (they he knows of) have been released since the Hyrniw letter. A few years back the FAA stated they were no longer in the 117 "interpretation business" and that while they would potentially respond to individual questions, they were no longer going to publish answers for the industry as a whole.

5) He did say he would forward my question to ALPA National FT/DT Chair to see if they have any additioanl info from that level.

If I hear back with any additional info from the National Commitee, I'll post here.