Willow, NPA ~ NPRM, yes
Sorry lapsed into Euro mode.
Thus for clarity, and for others whom I may have mislead:-
The FAA update page gives the history; 9/16/20 - 8/3/2020
https://www.faa.gov/news/updates/?newsId=93206
There is a link to the NPRM
https://www.faa.gov/news/media/attac...-R3-8-3-20.pdf
However, a further link to the review provides an easier read, particularly with the technical aspects and the rationale for the changes
https://www.faa.gov/news/media/attac...ummary-v-1.pdf
Thus 'what' changes are required are in the NPRM, and by exclusion what remains unchanged, which then leaves all those subjective issues requiring judgement by respective regulators; or even by public comment on the NPRM, i.e. BALPA.