Originally Posted by
fosters
Really? You don't feel that because it contains the definition of "other commercial flying" it is not relevant?
The first letter of interp I posted dealt with working for a different company and instructing on the side. The CFI time was to be counted toward your flight time maximums.
The second letter of interp is about 135 rest, but it actually defines what commercial flying is, and flight instruction certainly is deemed commercial flying in the eyes of the Chief Counsel.
I mean I feel that because it is only dealing with items assigned by the operator the inclusion of flight instructing doesn't tell us much. It would count against crew rest if they had you cleaning toilets, but would it count against it if you got a second job at McDonalds, even if it had you doing the same thing?
The second letter says to me that the operator is the one that can't assign anything else, not neccessarily that you can't do anything else on the side, it just can't be something assigned by the operator. IE, you can get that second job at McDonalds but you can't have your second job be with the same entity that gives you your 135 flying.