One step in there, to do nothing, was 4 1/2 months. . .at the point where no final determination on any pilot action, medical or otherwise, should be in the FAA's hands. A third party (not/not NTSB), commission style, pilots chosen by pilots, rotating terms, makes the final call. If FAA has been capricious and arbitrary, treble costs to the victim - and they pay the all the freight up-front, until the final decision is tendered. Any additional actions against a prevailing pilot has to be vetted by the commssion in advance, for, say, the next three years.