In the letter, which was leaked to TSN, Fehr explains that the proposal "represents very large, immediate and continuing concessions by players to owners."
"Simply put, the owners' new proposal, while not quite as draconian as their previous proposals, still represents enormous reductions in player salaries and individual contracting rights."
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Fehr said he wonders what the owners will offer in return for the salary reductions.
"As you will see, at the five per cent industry growth rate the owners predict, the salary reduction over six years exceeds $1.6 billion US. What do the owners offer in return?"
The NHLPA is expected to offer a formal response to the proposal when the sides meet again on Thursday in Toronto.