There's a lot to process and many unknowns. First, I think the timing and the 90 day effective date is interesting. For an organization that does nothing quickly its surprising at the speed this was put out considering the study he based this off of was done just a few months ago. It seems he wanted to get out in front of this, maybe prior to mid-term bargaining beginning. I'm also interested if the Agency felt any pressure or fear of possibly being held liable in the event of a tragic accident happening due to a fatigued controller. They have a study recommending that controllers have so much time in between shifts. If the FAA blatantly goes against that and lives are lost, they could open themselves up for all kinds of litigation.
Second interesting piece to this, is staffing. The Agency knows staffing is shit and these new guidelines will only further compound that problem. I have long said that the quickest way to fix staffing is to stop mandatory OT. This may not stop it but it will limit the Agency's ability to assign OT. I can definitely see an outcome that this all but forces the government to approve additional staffing at facilities to account for these new guidelines.
Lastly, and maybe most important to most, how does NATCA respond and turn this into a win for controllers? I understand many of the negatives that could come from this, but I also see an opportunity for NATCA to hit a grand slam for BUEs when it comes to improving their quality of life. Can they get the Agency to the table and negotiate. If they can they could redefine the "standard" controllers work week, add protections for mandatory OT, improve mid-term bargaining language, add staffing in the NAS, and most importantly address controller's overall compensation.
