I know this question has been hashed out before and I've read the threads. It still seems to be a grey area. From what I read it seems that flight instructing counts toward your totals but not necessarily your rest time with respect to being on duty. If I'm on company rest I could flight instruct however those hours would deduct from my 10 in last 24 hr look back period.

My chief pilot said it's considered outside commercial flying and they would have to log it (if I reported it). This could pose a problem if they needed me for a trip requiring say 9 hrs of flight time and I flight instructed 2hrs that day putting me over the limit.

I still want to instruct on the side but maybe it's time to just give it up completely. I know the worst case scenario would be if I had an incident while instructing which would prompt an investigation uncovering a flight time / duty violation. My company doesn't specifically forbid it. The CP joked and said just get paid cash and don't log it.

So maybe I should just count my lucky stars that none of my students or myself have had any issues in the thousands of hours of instruction
I've given. I just miss the idea of not being able to instruct at all. My other idea would be just do ground / sim instruction and let someone else to do the physical flying. Just not sure how much fun that would be but at least I'd still make a little extra cash.

 

My situation is a little different than yours but very similar at the same time.

I actually work for two 135 companies. When I got hired at my new company my old one allowed me to stay on part time as a training captain, which is done part 91. From what I have been told from my old CP, who coincidentally works at the same new company as me, is that all instructing counts towards flight time limitations and that the instructing is not duty time, however, it is not rest either. Meaning that you can pull 135 duty for the max 14 hours and then instruct for 6 hours(so long as you aren't flying more than 10 hours) but before you start 135 duty again you must have your 10 hours of rest.

I don't know if that's the FAA interpretation on the matter or not, but by adhering to that it will keep me out of trouble with the Feds.

 

The way I read it, duty/rest and flight time are two separate issues.

What company A assigns you to do is duty. If you are not assigned anything, that is rest. If it is a long enough period to qualify, it is LEGAL rest to where you are now able to come back for more flight duty. Anything you do during the time company A doesn't have you assigned for anything, even if it is doing something for company B is on your time, and so is not duty as far as company A is concerned.

Flight time is different. Commercial flight time is commercial flight time. If you instruct for 3 hours of flying and then come on duty with company A, you have your full duty period to fly, but you are restricted where you can only fly the maximum hours (8 or 10, depending on with section of part 135 your company operates under) minus the 3 hours you already flew. Not a problem if your regular assignment has you flying 2.5 hours per day. But if you regularly fly 5 per day, you would be getting close on the daily numbers and you might have issues with the monthly, quarterly or especially yearly limits.

A third thing to keep in mind is not the legalities, but the common sense aspect. If during your "rest" period you are doing 3 hours of flight instruction and a couple hours of ground and then you show up for your "regular" job and fly 1.5 into a hub, get 5 hours off (rest, but not legal rest) and then show back up to load the plane and fly 1.5 hours back home, you're never really getting true rest and you would be getting flirting with dangerous levels of fatigue by the end of the week.

 

If in doubt, give your local FSDO a call and get their interpretation on the matter. They should be able to clear up the issue your having.

 

Without a doubt the flight time itself is counting against you within the given 24hr period. The rest/duty etc is going to be complicated depending on who is giving the interpretation. I would highly recommend you only instruct on your hard days off if you have any to protect your ticket. If sounds like you are on call, so this could prove difficult.

 

Become an instructor/check airman in the aircraft you fly on the line. That looks a lot better on your resume than instructing in a cessna! Regardless, don't let your CFI expire like i did.

 

Don't instruct but don't let it lapse. Your days of going around the pea patch in a 150 should be over and done with. You already paid your dues. Id say you are crazy to go out of your way to get the crap beat out of you low level on a hot summer day.

 

This is my understanding of it as well

and make sure you get it in writing

 

It depends if your commercial flying is under part 135 or 121.
If under 135 you're ok as long as flight time limitations are not exceeded.
In the 121 world, the new rest regulations are worded to include all commercial flight time when calculating rest.