Check out this report from the voluntary rulemaking committee working on Part 135 Duty/Rest Rule updates.

https://www.faa.gov/regulations_policies/rulemaking/committees/documents/index.cfm/document/information/documentID/5803

What was a simple uncomplicated concept might become more complicated than an IRS tax code!

Operators will take whatever rulemaking occurs and obtain exceptions. Same, same.

Until a number is written that can't be exceeded by anyone, it's just static.

There are already well defined numbers in Part 135.

14 hrs of rest in a 24/hr lookback is a hard number.   You cannot plan to exceed it!  Simple.

Rest is ANY work performed by the company!   Well defined by the Chief Council; just need it in definitions!   Far too many attempt to use the FLIGHT ATTENDANT definition rule (135.273) for pilots.   Not applicable!

If you WORK for the company, it is not a "day off".   If you go to training/ground school, it is not a "day off".   If you travel for company, it is not a "day off".   It is duty and needs to be shown on the duty/time logs (accounted for).

You are not limited by 14 hrs of duty, you just can't plan to fly Part 135 flights past that point without seeing 10 of rest in the preceeding 24 hrs.   You can work (be on duty) indefinately after the flying ends.

Part 91 is Part 91!   If they are going to apply duty restrictions to Part 91, then they need impose same restrictions to every Part 91 operation, including all general aviation operations.

There is nothing broken with the current Part 135 duty/rest rules except nobody seems to know them or properly operate under them!

you say that you've never worked for one of these operators...without saying that you've never worked for one of these operators. But you definitely think you got a handle on it.

duty day, 6 hours flying, and 3 crews per 24 hour day.  Simple.

where are the crews?  Solution:  Who cares, two 8 hour shifts and to heck with 24/7.  Don't need a help ride in the wee hours.

This is not a correct definition for a pilot's duty period:

Duty period means the period of elapsed time between reporting for an assignment involving flight time and release from that assignment by the certificate holder. The time is calculated using either Coordinated Universal Time or local time to reflect the total elapsed time.

That is for a Flight Attendant under FAR 135.273, which is not applicable for Flight Crewmembers (i.e., pilots)

For pilots, ANY work performed by the pilot for the certificate holder is considered duty.  Thus, a duty period is the period of time from when the person began the day working for the company to when that person ended working for the company.   Simple.   Has nothing to do with "an assignment involving flight time".   You are on duty if you are working for the company, whether it is flying, washing the CEOs car, mopping floors, taxxiing to/from a broken helicopter, deadheading on an airline/bus/train/uber/pov/etc travelling to/from a base other than your domicile (assigned base).   It is all duty!

For pilots operating under FAR 135.267, the correct definition of duty is:

Duty means actual work for an air carrier, or the present responsibility for work should the occasion arise.

https://www.faa.gov/sites/faa.gov/files/faa_migrate/interps/2012/Boyle-IslandAirways_2012_Legal_Interpretation.pdf

this is simple and uncomplicated and we don't need to mess with it

It's ton's simplier than what the ARC is recommending, and more proper!

It's not that simple.

What about when your at home checking weather before you come in, that's a flight duty.

Or when your company mandates you come in early and does not pay you, that's flying duty.

This is why we have an issues, companies abuse, employees try to make it work, and it equals not a good choice.

People abuse this all the time which leads to a lot of accidents, including pilots who should be sleeping or resting on their night shifts, then coming into work tired.

It's not that simple.

Yes it is!

What about when your at home checking weather before you come in, that's a flight duty.

When you are home checking the weather, if it is part of your offical preflight duties, you are on DUTY!   If it's just to check the weather for youself, then it is not DUTY.   If you are required by the company to check the weather from the house, it is DUTY!   Your duty clock has started and you'll be required to show you've had 10 hrs of REST in the preceeding 24 hours from the reasonably planned completion time of your Part 135 flight.

Or when your company mandates you come in early and does not pay you, that's flying duty.

That's duty also!   Duty is not pay.  Duty is DUTY!   Your pay issue is a matter between you and HR.  The FAA, however, is looking for DUTY TIME.

This is why we have an issues, companies abuse, employees try to make it work, and it equals not a good choice.

Making a super complicated regulation who's flowchart has more turns than a Pac-Man game matrix isn't going to fix your problem!   The current system is very simple and thorough enough.   You, obviously, are just not following it!

People abuse this all the time which leads to a lot of accidents, including pilots who should be sleeping or resting on their night shifts, then coming into work tired.

Stop abusing it then.  You are on DUTY whenever you are working for the company, or have an obligation to respond when called (RESERVE/Beeper or phone calls).   Again, the problem is not the regulation!

whether it's simple or not lol

I just looked at the weather 2 hours before my shift starts so I'll be rolling out 2 hours early tomorrow. is that how I do it?

I turned on my computer and there it was from last night. should I have slammed it closed or looked away? is there a time limit for looking at wx so it becomes duty? please advise.

are you making this so complicated

... is not DUTY.   

post.  Been in this game a very long time.  Fed regs are not all the certificate holder needs deal with Irrespective of the railway act etc.  There are state employment regs too, which spell if you do something for the company by their direction, not just your curiousity, then you are encumbered, on duty, and the time is compensible.