Read the APA question & answer linked a few posts above

It doesn’t matter what time of day the 8 hours was, only that in the 10 before the FDP you had an 8 hour sleep opportunity.
That doesn’t mean you actually slept, but you had the opportunity if you wanted to. In your lunch example you had the opportunity but decided to have lunch instead.
In the commuting over 2 hours you no longer have the opportunity even if you did or didn’t need it. That’s the difference.

In the rest period before the FDP, NOT the 10 hours before the FDP. It doesn't say "preceding 10 hours" anywhere, it says preceding rest period. You're getting confused because the FAA refers to the rest period as '10 hour rest period' because that's the minimum amount.

The reg says:
It says "The 10 hour rest period", NOT within the preceding 10 hours. I don't know how to make it more clear. The rest period, which must be at least 10 hours, must contain 8 hours of sleep opportunity.

What you're describing is a rolling 10 hour period, completely separate from your 10 hour rest period. Like looking back in the preceding 168 hours to find 30 hours of rest. You think that before you can report for a FDP you need to look back 10 hours and find 8 hours of sleep opportunity. That's just not how this reg, or that letter, is written.

Jesus. If commuting you had the opportunity but decided to commute. The two examples are identical.

Your mantra for today is "at least." say it with me... AT LEAST. AT LEAST.

At least 10 hours free from duty immediately prior to starting an fdp with 8 hours of sleep opportunity.

40 hours free from duty immediately prior to starting an fdp with 8 hours of sleep opportunity.

100 hours free from duty immediately prior to starting an fdp with 8 hours of sleep opportunity.

1000 hours free from duty immediately prior to starting an fdp with 8 hours of sleep opportunity.

It's all exactly the same meaning.

Cudos for doubling down in the face of unanimous disagreement,though. If you are sure that 1+1=3 but the rest of the class says 1+1=2 then chances are it's 2.

I think the issue is that he's so deep in the hole he can't admit he's wrong anymore. It's don't ask don't tell now

lol I know. I'm an optimist, though and like to believe anyone can be brought back into the light... However wayward the lamb might be.

No, I understand your arguments; they just aren't consistent with the interpretations or the black and white language of the reg. Nobody has asked this specific question for a reason. When reading the interpretations you can literally feel the strain they went to in order to avoid this exact scenario in their responses.
You're required to have at least 10 free from duty prior to starting a new FDP. The last sentence of 117.25 (e) says the 10 must include an 8 hour rest opportunity. It does NOT say the at least 10 hour period must include an 8 hour rest opportunity. It specifically says the 10 hours. This is the 10 hours immediately prior to the FDP.

Until there's reason for them to address it, they won't. I think most of us are us fine with that.

I actually don't think you do understand, because it's not that your misinterpreting the language, you're flat out misreading it. It says 10 hours because that's the minimum amount. It's not a rolling 10 hours.

Your understanding of the intrepretations, and ESPECIALLY the black and white language, is patently wrong.

What's worse in my opinion, is that you're publicly accusing upwards of 80% of the pilot workforce of violating the law, when you are so clearly wrong.

You're basically saying that the FAA accidentally outlawed commuting, and is now conspiring to cover up the fact that anyone who takes more than 2 hours in their transportation to the airport is in consistent violation of a CFR. That is irresponsible and stupid.

Well heck, I'll take a stab at it.

Cujo, I understand what's confusing you. Honestly, the FAA does muddy the water here. They do refer to the requisite rest period as "the 10 hour rest period" in the second sentence of the reg. However, don't be misled by that. The first sentence is the key, which is that the rest period must be "at least 10 consecutive hours..." Why they then in the next sentence refer to it as "the 10 hour rest period" instead of simply "the rest period" is beyond me. Please do not place any special importance to the final 10 hours of the rest period immediately preceeding your report time.

Just remove the words "10 hour" from the second sentence and it makes sense. Unfortunately, it is a poorly written sentence in a FAR. Believe it or not, it isn't the first and it will not be the last.

Take a step back and try not to overthink it, Cujo. You'll get it. And if you don't, then with all due respect...move on. For now, at least. There are far more important things for you to study with this same level of intensity. Obviously you have a gift for minutia and I dig that because I'm the same way. Just be careful and learn when and how to not let that gift hijack your attention from more important studies.

I actually could agree with most of that; the problem is that if their intent was X, they wrote Y. Someday, a lawyer will stand in front of a civil jury and read that last sentence.
The explanation you and everybody else is making is that if you had 25 hours off, and slept in the 10 hours immediately after the FDP ended.... you are legal to start the next FDP 15 hours later.

Compare that to the part about the at least 10 hours being immediately before the FDP, and that THE 10 hours must have an 8 hour sleep opportunity.

Then look how it is applied on every day of a trip from 2 two until finished. It doesn't matter how long your RON is, but lets assume it's 11 hours. That meets the requirement of at least 10 hours. Now the van is late, it breaks down enroute to the hotel. Once at the hotel the XYZ junior Olympic sports team is at the hotel and the noise is so bad your whole crew gets moved to another hotel. You did not get an 8 hour sleep opportunity so you notify the company and they then adjust your show time to allow for legal rest before starting the new FDP.

Show me in the exact same rule, where not getting an 8 hour sleep opportunity in the 10 hours prior to the FDP doesn't apply on day one? Read 177.25 (f).

I really don't care. I don't commute. I think this is going to come back to bite somebody badly in the future. As written, it's clear what the lawyers will say, and how a lay person will interpret it.

I'll drop the debate. I've made the point known.

Over, and over, and over ad nauseam...! :eek::eek: