Nah, even the FAA recognized that this was an oversight; a situation that hadn't been considered when writing the rule. They said as much in at least one response to a letter requesting clarification. This particular rule wasn't written in blood. This one was written in "Whoops, I hadn't considered that."

It gets better: The flight review requirements are satisfied by the pilot obtaining a new rating. If our pilot completes his ballooning check ride, it resets the clock on his biennial flight review requirement. He is not required to get a separate flight review covering operation of the 747. That's a bigger oversight, IMO, but a prudent pilot is going to get a review for their "highest" rating, and not exploit this technicality.

Correcting the original issue properly, any rated pilot should be considered a "student" when exercising any flight privileges in an aircraft for which they have never been rated. Every pilot is a "student" unless they have obtained every possible flight rating.