seems everyone has the answers on perfect crew rest, but what would that be? Ground all airplanes between 2100L and 0700L? As posted before. There is no rest policy that will keep a crew fresh for all flights. There is no way anyone who lives on their days off on a 7AM to 11PM wake cycle with their family, can now pick up three nights of 11PM to 7AM flying and not be exhausted. The biggest sham in Part 117, is no controlled napping in the cockpit like some int’l air carriers. I am betting a result of this is going to be more time in hotels on the road in order to make guarantee. As someone else posted here it is the PIC's duty to determine if he can safely make the trip. You cannot regulate that beyond common sense. But I am serious I would like to hear what the prefect crew policy would be, and remember the company still has to make a profit in order to attract capital and pay employees.
It's pretty simple. ONE side of the clock for ALL on-call duty periods for ALL employees. Reserve or otherwise. FOR ALL OPERATORS. 135, 135(k), Supplemental 121, 121 Flag, 121 International.
I don't disagree with you about controlled naps, but they do NOT combat the problem of flip-flopping circadian rhythms. The regs need to account for NO flip-flopping of circadian rhythms in any one group of work days. A minimum of 3 days off on BOTH sides of any flip-flop in circadian rhythm.
All I need is ONE day to get INTO a night rhythm and ONE day to come back off it. If you're going to be doing an entire month of CDO's or Red-Eyes, then a responsible pilot stays on that rhythm for the month, including his/her time at home. That's OUR part of the equation to self-regulate our own sleep cycle according to the flying we're going to be doing.
On-call operators stick with a 16 hour "phone availability" window. If you want your freight guys to be available at night, you can't call them during the day, and vice-versa. Whitlow needs to apply to ALL Commercial operators, not just Part 121.
When EVERY Air Carrier has to work around those rest rules, the financials will work themselves out. Either a company staffs additional pilots and raises their rates accordingly or they just segment themselves into a niche based on night freight or day pax ops. One thing this industry has taught us, is that operators continue to survive when rules changed. This won't be any different.