Even with the apparent holes in the new ruling, and the knowledge that it isn't perfect (nothing is); is it at least a good foundation that can be built upon? What are the costs, good or bad, of doing so?
The implementation time frame of 24 months, as you know, is almost an eternity in regulation land. The revisions, exemptions, deviations, variations that can be made between now and then are the biggest bugaboos.
The International rules, I think, could be not very good from 2 Pilot Aircraft rules now. They are a big improvement from a 3-required crewmember airplane. Right now, planes with an FE can have the pilots in the seats for 12 hours. That is absolutely silly.
Also, the rest credits are interesting. I don't see how any augmented operation can get by with NO rest facilities, specifically a separate bunk. The idea of the augment is to allow the pilots to be rested for takeoff and landing, and the augmenting crewmemeber(s) to provide time after takeoff to allow the operating pilots to be rested for descent and landing. I've done both positions and the relief pilot really isn't a high-workload position. So, trying to rest, even in business or first, with FA's walking, pax walking, behind a curtain really can't be that good of rest. I've been in seats across the aisle from them as a paying pax. Just from some of the noises and the people bumping into your chairs, you can't get solid sleep.
As to conditions like DE posted, that's just as bad. I jumpseated on one of the major express carriers on a 3 man leg. They had a foam pad tossed onto the floor for rest. Then they hit turbulence. We have to belt down bags, but not pilots. Amazing.
And again, you have the scenario where the day meets the XX hour rule. However, if it's a 2 or more sector day, and one of the sectors does not allow for adequate rest, kind of changes things.