Exactly.

Read the last paragraph first page, first paragraph second page and last two paragraphs on the last page.

Fitness for duty affirmation is separate from the rest requirement. If you didn’t have a 10/8 immediately prior to starting the FDP, you can sign that you’re fit for duty, but if something happens you were in violation of the rest rules. Commuting over 2 hours means you didn’t have an 8 hour sleep opportunity in the 10 prior to duty. The very next section says you’re required to notify the company when you don’t get 10/8
Hence, don’t ask, don’t tell.

The rest rules are pretty clear.
It’s 10/8 immediately prior to beginning a FDP. You could have 3 months off.... it’s the 10 prior to start of FDP that count.

You are applying the English language selectively here to fit your narrative. Additionally, this should be covered yearly in your 121 carriers fatigue mitigation training program. I suggest that you seek out your training department for more clarification as your reading comprehension is leading you astray.

You are correct insofar that the 10 hours of rest has to be prospective in nature and touch your upcoming FDP start time. But that's it. What you do during a required rest period is up to you. Commuting in to work is not a function of your company and has nothing to do with rest rules.

Do you actually fly for an airline? Because it's very obvious you don't understand the rest rules or how to read them. Nowhere does it say that you must have slept 8 hours in the 10 immediately preceding a flight duty period.

Yes, what you do is up to you, but you must have had an 8 hour sleep opportunity during that 10 hours. Commuting to work more than 2 hours leaves less than 8 for a sleep opportunity. Some will debate if commuting is rest or not. A company DH is duty. Jumpseating you are an additional crew member. The only one in a grey area is non-rev.
If you’re driving yourself over 2 hours then your SOL and just didn’t have an 8 hour sleep opportunity.
Once that happens the next section of the rest rule kicks in requiring notification to the certificate holder.
As I said... don’t ask, don’t tell.

No, it says you must have had the opportunity. How do you have an 8 hour sleep opportunity in the 10 hours before going on duty if you drive over 2 hours to work? If you drive/commute over 2 hours then you didn’t get 8 hours opportunity.

Look, if you went to the hotel and the van broke down enroute and by the time you got to the hotel there wasn’t an 8 hour sleep opportunity you’d notify the company that while you had 10 hours, you didn’t get 8 hours of sleep opportunity and the start of the FDP needs to be delayed to allow for the legal rest.
Show me where in the regulation that same requirement for reporting for duty does not also apply on day 1

The difference is, in your scenario, you aren't getting an 8 hour sleep opportunity between your 2 FDPs. On day 1, you have gotten an 8 hour sleep opportunity between your 2 FDPs, just not within the last 10 hours, which is not required as per the text of the reg.

I've read and re-read and re-read that section of 117 trying to see it from your point of view. I will acknowledge that it would have been more clear if they had inserted the word "minimum" in front of all the instances of "10 hour rest period" or just eliminated the "10 hour" modifiers from all of the "rest period" references. However, it's obvious to me from reading it over and over is that you only need one 8 hour sleep opportunity since your previous duty period ended, and the total time from from the previous duty period to the new duty period needs to be at least 10 hours. It does not state that your sleep opportunity needs to fall within 10 hours of your report time.

I understand that you are convinced of your interpretation, but the FAA disagrees, as stated in section 3 of the LOI linked above by another poster. Additionally, your interpretation just doesn't make sense. I realize the FAA is a government agency and making sense isn't a requirement, but that 8 hour sleep opportunity is in the reg with the expectation that the crew member is actually getting approximately that much sleep at that time. They call it an opportunity to give some latitude to people who can't sleep more than 7 hours at a time, and they don't want you to have to log your sleep, etc, but the intent is that you are sleeping.

If I have a 1500 report time for a duty day of less than 3 hours (not unheard of at a regional) does it make sense for me to be required to try to sleep until 2 PM? No, I get my sleep the night before. I've had my 8 hours of sleep and got up at 7 AM, did whatever I wanted from 7 to 3, then reported for duty. If I had a contractor replacing my back patio with a jackhammer going all day, that's not a sleep opportunity. Does that mean I shouldn't be allowed to go to work in that situation? No, of course not.

I always recommend to other pilots to CYA. Even if you don't feel fatigued, if a reasonable person would suspect you were fatigued, and you end up in a mishap, you could be in trouble. However, I think everyone else is in agreement, you won't get in trouble just because you didn't get a sleep opportunity within 10 hours of reporting for duty, just so long as you got one since you were last released from duty.

I will give you your grey area about a jumpseater being an additional crew member. As pilots, we're having our cake and eating it too here, legally. We want to be able to commute without causing FDP problems, but in order to jumpseat, the FAA insists on calling us additional crew members. You could argue that if I'm a crew member in a part 121 operation, even if I'm not employed with that company, that that should start my FDP. That's not the way pilots want it viewed, and that's not the way the FAA is viewing it right now, so everyone's happy

Who says you can't sleep in the back of an airplane while commuting to work? Why are 'commuting' and 'rest' automatically mutually exclusive?

Then, deadheading could be “rest”; then begin the FDP.

GF

It depends on the person. For some it might be restful, for others not.

For that reason, company assigned DHD should never be rest, since you don't have a choice on that.

On their own time, pilots should be trusted to manage their own rest responsibly, whatever that means to the individual.

Otherwise, we would all need to check in to a company dorm ten hours prior to show for enforced rest (cost of said dorm would be payroll deducted of course).