Stricter flight training interpretation than in the past?

Some of you involved in flight training or still in the process of flight training might be interested in this regulatory interpretation that recently came out and is circulating on a pilot board I'm on:

http://www.yourdpe.com/FAAInterpretationtraining.pdf

The questions being answered relate to Rotorcraft training and night flight for Commercial, but there's no reason the interpretation wouldn't be extended to airplanes and other training. For example, when I went from PP-ASEL to add the IFR certification, many years ago, I used cross country time and instrument time from the PP training as contributing to my total hours required for IFR certification. Under this interpretation, it seems those would no longer be eligible flight hours.

In fact, the letter above was used by the San Jose FSDO this November as justification for this statement:

If this interpretation persists, which seems contrary to decades of prior practice, this could add to the cost and time required for all levels of training!