The question of neither CFI nor trainee being “passengers” with respect to each other and the 61.57 passenger landing currency rules was addressed almost twenty years ago by the Kortokrax interpretation. I guess this move is in response to the current Supreme Court’s evisceration of the past Supreme Court Chevron deference decision. Now all those interpretations must be written into regulations or any knuckle-headed Federal judge will be able to keep the FAA from enforcing their own safety rules.