I don't think this session looks too difficult if a runner knows their threshold pace well enough to not stray from it during the workout. 400m is so short that I could easily see a lot of runners putting themselves in a ditch early because they got a little too carried away with the pacing.
I just did 8 x 1600 @ 5:30 as a threshold workout. I should be able to do 20-25 x 400m @ 82-83 off of :20-30 rest. I would be tempted to run faster with the shorter repeats. I prefer the longer stuff for threshold running & would rather do 12-16 x 400 @ 5k off of 1:00 or 16-20 x 400 @ 10k off of 2:00ish cycles.