The sorry and tragic saga continues
The FAA is to use the NPRM process leading to the final rule.
How common is it for a FSB Review to be put to NPRM, or published in draft before public comment ?
Similarly for the JOEB Validation; unusual ?
These processes provide opportunity for world-wide public review of the proposals and expose any conflicting views between FAA and world authorities (previous leaks), all within a US certification process. Choosing to exclude world opinion could inflame the differences, particularly as the accidents were 'non-US'.
This suggests that descending opinion (public opinion *) on operations and training could influence the final FAA rule. If so, interesting times; possible that US operators would have to train to world standards, or the FAA grant and explain any dispensation, messy. Particularly painful if the FAA agrees a lower standard of training, such that the rest of the world is financially disadvantaged, call lawyers.
Worse still if this openness overflows to disagreements over the technical modifications, currently within the FAA regulatory process, but still subject to multi-agency review ( but not necessarily public comment ?)
Should we expect that there is already a closed-doors agreement between the main regulatory authorities to circumvent most of these issues ?
* world wide 'expert' opinion on creditable human contribution in aircraft with system failure, recognition, reaction time, and performance sufficient to achieve an acceptable level of safety. (Aviation expertise or Human Factors expertise in general ).
Might be a lengthy comment / reply section in the NPA.