Originally Posted by
Baradium
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.
To answer your question, I call your attention to the underlined portion:
The other commercial flying done by the flight crewmember does count against the daily 8 hour limitation if it is done before the Part 135 flying, and also counts against the pilot's quarterly and yearly flight time limitations. For example, 2 hours of "free lance" flight instruction by the pilot during his rest period limits him to only 6 hours of Part 135 flying time during that 24 consecutive hour period. Any other commercial flying done after the Part 135 flying does not count against the daily limitation, but still counts against quarterly and yearly totals.
Notice the words "free lance". Also contained in the paragraph above the one just quoted:
Your second question asks if this same flight crewmember may participate in the activities previously listed during a rest period if the work was done for another company, not ABC, and whether the flight crewmember could then accept an assignment with ABC for flight operations under Part 135, at the end of the rest period.
Let's include that with what interpretation #2 Says:
acting as flight instructor under Parts 61 and 141 would be considered "other commercial flying."
I see what you are saying - that any required duty for that certificate operator would impact rest. However read the quotes I posted together, and the picture becomes clear.
Flight Instruction = Commercial Flying, which counts towards your maximum hours per calender year.
*** EDIT*** Oh, and the reason it deals with rest is because that's originally why the author wrote to the FAA.
I really don't see how it can get any plainer
?