Wow, this is a toughie. Those guitar solos have jumps dispersed in them, and we all know that 12th/24th note stream is a bit tougher to read through since the respective rhythms are very similar colors...
This chart is also comparable to Holy Orders in a few ways; the patterning in the introduction, the extended 24th note solos... actually, I'd go as far as saying it's a bit more aggressive than Holy Orders in the solo areas, minus the famous 32nd trill of course. The thing that seems to give the impression of not being a 12 is the lack of density in other areas. When I first took a look at this chart on the replay, it looked pretty easy -- then, I actually tried shadowing alongside of the replay and I have to say, some of those patterns are definitely a lot harder than they look.
Definitely a borderliner in my opinion, but I'm leaning toward the FMO side as well.
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