That is not the intent....
I suggest you visit the following link:
http://afs600.faa.gov/search.asp?myFolder=640OtherFAQ&Query=&sub=640&lev=Sem&lev2=DPE&title=FAQ
You should get the FAQ anyway, but for our lazier friends, here's the part you want:
QUESTION: Here's a question related to the (in)famous phrase in 61.197(2)(ii), “or in a position involving the
regular evaluation of pilots.”
A CFI, happens to be in the military, is an instructor pilot in his unit and regularly evaluates those pilots. He's
requesting that we renew his CFI based on his military activity since he does very little civil instructing. He argues
the point that he can use his military comp check in lieu of a BFR, so why can't he use his military instruction
experience to renew his CFI?.
Should we renew him or not based on his military experience of being in a position involving the regular evaluation
of pilots?
ANSWER: Ref. §61.197(a)(2)(ii); No you would not renew this military IP’s FAA flight instructor
certificate without some semblance of the training involving the knowledge, skills, and abilities of the certification
standards set forth in Parts 61 or 141.
The intent of “. . . or in a position involving the regular evaluation of pilots . . .” of §61.197(a)(2)(ii) involved
training in the environment of the requirements and standards of Part 61. The rule was never intended to permit a
military IP who flight instructs another military aviator on how to fire a heating seeking missile or evaluating
military aviators on military mission operations to equate to training pilots via Part 61 standards.
However, there are situations where the military IP’s duties and responsibilities may equate to training in the
environment of the requirements and standards of Part 61. For example, if an FAA Aviation Safety Inspector has
“first-hand, direct knowledge of a military IP's instructing duties and responsibilities and the military IP's duties and
responsibilities involve teaching military pilots on instrument ratings, qualifications, and skills in the ATC
environment and further this FAA inspector orally tests the military IP on Part 61 standards then there would be a
case for arguing for the military IP’s position. Another example could be when an FAA Aviation Safety Inspector
has “first-hand, direct knowledge of a military IP's instructing duties and responsibilities and the military IP's duties
and responsibilities involve teaching military aviators on basic piloting skills that equate to private pilot training
under Part 61. Again, if the FAA inspector orally tests the military IP on Part 61 standards, then there would be a
case for arguing for the military IP’s position.
So, probably no to renewing just because you are a military IP. And calling around until you find someone willing to do it because they misunderstand the intent, is in my opinion, wrong. You, sir, as a military officer, should be ashamed if you use that technique to gain your objective, IMHO. Just take an FIRC. Heck, you can do it online, and actually brush up on your Part 61, 91 etc knowledge. You can even mail it all in! (Read the FAQ on how to do that.)
https://www.gleim.com/Aviation/firc/
You can also get the new Far / AIM for $4 with the course among other book specials. The course is only $99. They will even give you the first lesson for free to try it.
Do the right thing.
