If your paid you are.

 

Your statement is incorrect. Anytime you are giving instruction as a CFI, you are by definition exercising your commercial privileges as well as those of your CFI certs. The CFI certs are only valid with the commercial. Legally, you must have both in your possession/accessible to instruct in any capacity for compensation. This is basic.

I believe the FAA had no idea that people would try to rationalize their way around the obvious intent behind the regulation. I mean, they did take the time to ensure it said on the back of the plastic cert itself “valid only with commercial cert...” I’d say that is pretty obvious to any reasonable person. And think back to those commercial single and multi-e checkride orals. No way you would tell the examiner sitting across from you... “Well Mr. Examiner, technically when I go on to earn my CFIs soon, I won’t actually be engaging in commercial activity since the student is paying me to instruct them and not to fly”. “I just need to pass this commercial certificate to sort of jumpstart my CFIs is all.”
Anyone who thinks that sort of thing wouldn’t earn them a pink slip, is just flat wrong.

But then again, some people try to rationalize their way around almost any rule or law. Probably the same sort to pencil-whip their logbooks to get to ATP mins a few hours faster. It’s actually a hazardous attitude, “the rules don’t apply to you”. The antidote? Follow the rules. Don’t try to rationalize your way around them.

My .02 worth at least.


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Not to be devil's advocate, but there is also CFIS - Sport Pilot CFI achievable prior to Commercial certificate.
Per Envoy FM1 instruction on the side can't be done. Republic doesn't mind.

 

I’m aware of the Sport CFI, but since it’s not possible for an airline pilot to hold only a sport CFI, without being commercially certificated, it’s not relevant to the discussion IMHO as every ATP pilot is commercially certificated, negating the the Sport pilot/sport instructor conversation. Spot on about the FM-1 though. That’s what keeps me from occasionally instructing on my days off when I’m bored.


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For the sake of the argument, you can be ATP AMEL, and private/CFIS asel/weightshift/gyro etc.

 

Rationalizing leads to gender fluidity....

 

Part 117 only applies to part 121, 91 subpart k and part 91 operations conducted on behalf of an air carrier. Therefore instruction does not fall under the limitations of 117.

 

Just call your FSDO, they will confirm that in fact instructions time does not go toward the 1000 hours annual limit. You can make all the arguments you want. That's their interpretation and what matters.

 

Any way to check what captains are check airmans?

 

Jetnet.

/Filler