Originally Posted by
Baradium
As far as the CFI thing, does anyone have a letter or interpretation or reg to show that CFI counts against 121 time? These all seem to be based off of opinion right now, and saying "this is what the feds think" without backing it up can be misleading if you aren't 100% from an interpretation from them.
Do you have a letter of interpretation that says it DOESN'T count toward 121 maximum hours flown?
That would be the more conservative train of thought. Obviously there is no reg that directly addresses it, or we wouldn't be having this conversation. There isn't a reg that directly says you cannot taxi at 100 knots on a taxiway either.
I see the "CON" side of the argument - especially when they pull the no-medical-required tactic - however in "my" mind I see that as an exemption rather than going to show that working as a CFI isn't a commercial operation.