I'm actually surprised there isn't a discussion going on w.r.t. the rule's
interpretation. (AOPA's web has a letter on it their General Counsel wrote
TSA asking for some clarifications.)

There are a bunch of submissions on the docket asking for interpretation
though.

Here's my layman's interpretation:
flight instruction - anything done with an instructor in an airplane or
simulator (doesn't say you have to go flying, but does exclude
"ground instruction")

Hey, Steve, wanna sit in the right seat while I do three and a hold? Don't
say anything, just enjoy the ride. I'll even pay the FBO the standard
instructor rate.

Instruction, or not? Can it come down to whether you write 1.2 in the Dual
Received column?

course of instruction - not really defined in the 44 page document as I
recall,
but the registration web site requires you specify a flight training
provider from the list and specify a start and end date, when you
register
for "flight training"

End date? For a Part 61 Instrument? Oh, please.

Also, in the section that calculates cost, it assume a Candidate will
register,
on average, twice a year.

So, I'd say, as it stands, every BFR requires a registration.

I think that's what it says.

Oh, and although AOPA has asked for a clarification on this one, at this
point
"recurrent training" is defined (on pg. 12) as training required for
employees
of commercial operators or private business aircraft ops, so things like
BFRs,
(the T-6 refresher I'm planning in Nov. etc) are all Category 3
(everything
else in aircraft 12,500lbs gross) and require registrations each time.
(You only have to do the fingerprinting the first time, it notes they'll
keep
them on file. You do pay the $130 each registration, though.)

It may be defined on page 12 as that, but it's defined in the actual Rule
differently. The preamble excludes Part 61, and the Rule itself includes 61.
So even a Part 61 BFR is recurrent training, so subject to different
record-keeping requirements from Category 3.

If I had known I was going to have to do all this for 3 flights in a T-6,
I wouldn't have bothered, but now that I've booked the flights and the
plane
ticket to FL, I'm doing the whole sheebang, rick

That's the problem - the TSA seems deaf to the complaint that there are lots
of businesses that need to plan ahead. We can't just assume they will wait
until the 19th and delay implementation. There are also outstanding requests
for clarification that businesses need, yesterday..

My FBO's chief pilot, who has been following closely, thinks they will fix
the problems with the citizen up-front requirements, but leave the alien
requirements (including Resident) in place.

-- David Brooks