This is very sound stuff from the CAA. A problem has been perceived with fatigue in short haul carriers, a scientific study carried out and changes to the regulations recommended. The tone of the FODCOM is interesting. It sounds like Flight Ops are actually quite annoyed at the working practices of (some) airlines and have decided to put their foot down.
I would give my eye teeth to be a fly on the wall of airline boardrooms when this document hits the desk. It will annoy them considerably. Solicitations to the CAA will doubtless plead the costs of finding and employing more pilots due to the limits proposed on early starts.
This is where it gets interesting. Will the CAA now stand up to persuasive and influential people seeking to reduce the impact of this latest FODCOM? I would hope that, at the very most, no more than an extension of the period proposed for introduction of the new CAP is allowed.
BTW Which airlines took part in the DERA study and where can I get a copy of the report?