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Old 8th Dec 2004, 19:17
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MLS-12D
 
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was told that ALL dual flights require a visa. That didn't ring true, as I thought that people who were doing a rental check-out or BFR didn't need a special visa, but of course I don't have a reference to the "official" document...
If you look here, there is a TSA letter that is relatively recent (Oct.19, 2004).

The letter confirms TSA's position that "flight training" means "only training that a candidate could use toward a new airman certificate or rating". Accordingly, the new "Alien Flight Training/Citizenship Validation Rule" doesn't apply to rental check-outs, conversion training on light aircraft (i.e., training that does not lead to an official type rating), or BFRs.
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