"Michael" wrote in message
om...
Today is October 19, and...

a *great* summary of the TSA IFR, but:

A careful reading of the document (which includes both the text of
1552 and the official explanation) indicates that there is no
grandfather clause - the fact that an alien is already taking flight
training does not mean said training can continue without meeting the
new TSA requirements.

A letter written yesterday, and added to the docket today, by the TSA chief
counsel says that it can continue. The letter doesn't use the same
terminology as the IFR, but hey. It says "flight students" who are already
"enrolled" in such flight training are not subject to the regulation. I
support it's up to us whether we regard the guy who takes 6 years for his
Part 61 instrument rating and goes through three instructors continues to be
enrolled in the training.

They don't say how they justify that opinion, but here's my attempt. The
definition of candidate is "an alien... who *applies for* flight
training...". This definition thus provides the context for everything else.
(The definition, by omission, excludes citizens, which can make it easy to
misinterpret the rest of the rule.) My emphasis on "applies for", not
"undergoes". If you are already in flight training, i.e. you already
applied, you are not defined as a candidate.

The Category 3 rule says "A flight school may not provide training... to a
*candidate*... unless...".

The Category 4 rule (which covers BFRs) says "Prior to beginning recurrent
training for a *candidate*..."

-- David Brooks