NPRM page 85:
This proposal does not exactly mirror the ARC recommendation, because the
FAA is proposing that transportation time to or from a duty station not be included in the
minimum rest periods; nor would it be considered duty. Rather, the rest period would
begin once the flightcrew members reach the hotel. The FAA’s proposal does not change
the intent of the ARC to generally assure an 8-hour sleep opportunity. However, the
FAA believes that time in transit is not rest. In addition, the agency is concerned that
allowing this time to be included in the rest period could result in a reduction in actual
rest opportunity below 8 hours. The ARC members recognized this possibility and
considered an approach whereby any time exceeding 30 minutes would not be considered
in the rest period. Ultimately, the impact is the same; it is simply clearer from a
regulatory perspective to acknowledge that time in transit is not rest. The FAA has
decided against treating this time as duty because it recognizes that the permissible
amount of cumulative duty is only nominally higher than the permissible amount of FDP
and that the location of a rest facility is a lifestyle issue that is typically negotiated
between the carriers and their unions.
The FAA seeks comment on the following:
33) If transportation is not considered part of the mandatory rest period, is there a
need for a longer rest period for international flights?

§ 117.25 Rest period.(d) No certificate holder may schedule and no flightcrew member may accept
an assignment for reserve or a flight duty period unless the flightcrew member is given a
rest period of at least 9 consecutive hours before beginning the reserve or flight duty
period measured from the time the flightcrew member reaches the hotel or other suitable
accommodation.