Lumberg, Lear, et al, you are in for a serious eye opening experience when these rules come to pass.
You have every right to commute.
Entitled to commute and violate the new rest rules, no. Good luck getting the company to pay for that by the way.
Again, I'm just the messenger, not the guy making the rule.
See you next time!
Read what PCL said again and absorb it (he beat me to it).
They are NOT putting rules in place against commuting or requiring it to be added to your total duty for the day... yet...
The wording from the NPRM (if you bother to read the whole thing) says the FAA was leaning that way, then the committees studying the issue along with BOTH ALPA AND THE ATA said that it wasn't feasible. Too many people commuting, too difficult to track the system, and they decided they would start with training each pilot on these new fatigue rules in a ground school modules, the dangers of fatigue, they would "SUGGEST" that a pilot "CONSIDER" their time commuting similar to time spent in van transportation by the company to/from a hotel, i.e. it is now a part of your total duty day, and continue to leave it to the pilot to act responsibly when commuting.
In the future, if another person does an all-night red-eye commute then starts a 12-14 hour duty day and buries one in at the end of the day talking about being tired on the CVR... well... for all intents and purposes, this is "fair warning" from the FAA that failure of pilots to commute responsibly will "POSSIBLY" result in actual regulations on commuting.
Believe me, airline management doesn't want commuting rules in place, either. It would result in the short-term meltdown of operational integrity, followed by a LOT of additional costs in training and staffing as they add more employees, shorten up the trips, which as a result kills the trip average credit, requiring people to work more trips, less days off at home, and management's life would get just as difficult as ours would.
No one wants that, hence why THERE ARE NO RULES ABOUT COMMUTING IN THIS NPRM.
I suggest you read it in its entirety before you post about the issue again, just so you can post intelligently on the subject. Your call, of course (that's not a moderator position, this is just my personal take on the issue - 121.471 has always been near and dear to my heart).
