Thank you for the reply.
Another play example:
K free kick from the K 30-yard line. The kick is almost at rest at the R 20-yard line near the sideline.
1. R23 illegally bats the ball at the R 20-yard line and the ball goes OOB at the R 19-yard line. K accepts the penalty. What is the next play? This is a loose ball play - shouldn't there be a re-kick from the K 40-yard line?
2. K56 illegally bats the ball at the R 20-yard line and the ball goes OOB at the R 19-yard line. R accepts the penalty. What is the next play? This is a loose ball play - shouldn't there be options?
i. re-kick from the K 20-yard line.
ii. R's ball 1st and 10 at the R 30-yard line. (per 10-4-2 EXCEPTION)
iii. R's ball 1st and 10 at the R 45-yard line. (per 10-5-1a and 6-1-9)
After reading 10-4 forwards and backwards and comparing to the 2022 version (pre-blip), I think I've found the problem.
10-4-2b states that the basic spot is the previous spot for a foul that occurs behind the line of scrimmage on a loose ball play. Previously (2022), the phrasing did not include "behind the line of scrimmage", it covered any foul during a loose ball play. With this edit, there is *technically* no specific rule coverage for determining the basic spot on a foul beyond the line of scrimmage during a loose ball play.
Since your scenarios involve illegal kicks/bats beyond the line of scrimmage during a loose ball play, only 10-4-4a is relevant and *by rule* it's a spot foul enforcement only, which invokes the question of whose ball is it? If R never possessed the kick, then the ball is still in Team K's possession, and Team R is only awarded the ball after it becomes dead not in player possession (or out of bounds, touched by R). So the only conclusion in scenario 1 is that it's A's ball at the time of the foul, therefore A retains possession, enforced from the spot of the illegal bat to *replay the free kick*.
That's absurd. If we're replaying the free kick, we have to have previous spot enforcement regardless of 10-4-4a (illegally) kicking in.
In the second scenario, an illegal bat or kick doesn't change the status of the ball -- it's still a legal free kick, that has now gone out of bounds untouched by R. I propose that 6-1-9 supersedes the action that caused the ball to go out of bounds, and allow the standard options for penalizing the free kick out of bounds and ignore the fact that it was an illegal bat.
Just to put a fine point on it, with the alteration of 10-4-2b to only apply to foul behind the line of scrimmage, there is no rule that determines the basic spot for pass interference anymore.