I didn't find it that confusing in my situation. The receptacles on the living room side that could not "serve the countertop" per 210.52(C) were 210.52(A) and would be AFCI if I was on the 2008.
If I had a receptacle on the kitchen side >12" below they would be SABC but not required to be GFCI. In a practical sense they probably still would be. The only reason I could think of not to would be if it was the fridge.
My fridge is on the bathroom fan/light circuit because that is the way it was wired, way back in 1963 and I saw no reason to change it. I did pull in a separate 20 for the bath vanity top for the hair dryers, very soon after I moved here. (maybe one "trip" after I moved here)
