Flight Instructing while at a regional?

[Goose Egg]

I was that way too when I instructed full time. But when you move on and haven't done it for a bunch of years, you'll look back and think "I miss it a little, but not enough to do it full time".

True. Even as I took a moment to consider what I had written about wanting to "get away from" instructing, I thought to myself that I would miss it. But I guess if everything goes well career wise, I'll have a little extra funds to do some fun flying myself. It's so hard for me to mentally separate flying single-engine GA airplanes (which I absolutely love) from flight instructing (which I find marginally rewarding from time to time). The thought just occured to me that I could fly single engine airplanes myself... for fun! I feel so greedy right now! ASES here I come...




....in a few years.

-Goose

 

[flyboy06]

AC560, I liked what you had to say, too bad ALPA and most companies are not on your side (not permitted at XJT anyway)

From the ALPA site regarding flight time:

For example, if a flight crewmember had engaged in commercial flying (e.g., flight instruction charter flying, etc.) that totaled 10 hours during a seven-day period, the crewmember could only accept an assignment of 20 hours during this same period from a
Part 121 air carrier. Flying for the Department of Defense (Reserve or National Guard) is not considered commercial flying time and need not be counted for purposes of the yearly, monthly or weekly flight time limitations.

​

 

[jayme]

I got permission from SkyWest a few years ago. No problem.

 

[Black Hawk]

AC560, I liked what you had to say, too bad ALPA and most companies are not on your side (not permitted at XJT anyway)

From the ALPA site regarding flight time:

For example, if a flight crewmember had engaged in commercial flying (e.g., flight instruction charter flying, etc.) that totaled 10 hours during a seven-day period, the crewmember could only accept an assignment of 20 hours during this same period from a
Part 121 air carrier. Flying for the Department of Defense (Reserve or National Guard) is not considered commercial flying time and need not be counted for purposes of the yearly, monthly or weekly flight time limitations.​

Just another case where ALPA doesn't really know what it's talking about. Of course if a company like XJT has a policy against it then it could be a problem. That would be different than an FAA regulatory requirement though.

 

[AC560]

AC560, I liked what you had to say, too bad ALPA and most companies are not on your side (not permitted at XJT anyway)

What Blackhawk said.

 

[Dirty Sanchez]

I flight instruct while at a regional.

All the time I get these FOs with 300 hours that do not know how to fly an airplane or talk on the radios. I had better instrument students when I was a CFI.

 

[hawaiimei]

XJT doesn't prohibit flight instructing, and you do not have to have permission to do so - the manual changed this year:

"...each pilot must refrain from engaging in any activity or employment outside of the company. However a pilot may do so if the outside employment/activity is not in a competitive field, detrimental to Expressjet's interest, in violation of the Company Conflict of Interest policy, and does not adversely affect or lessen the pilot's efficiency in the performance of his or her duties."

and it goes on to say:

"In the event a pilot is found to be engaging in an outside activity or activity that the Company feels is distracting from his/her ability to properly handle his/her Expressjet job, that employee shall be notified in writing to curtail such activity to the extent that it no longer detracts from his/her primary duties with Expressjet Airlines."

XJTused to prohibit commercial flying, but the change now allows you to 1) go do your thing without first seeking out a letter of permission 2) if the company finds out (no longer places the responsibility on the individual to disclose).. the the worst thing that happens is that the Company is required to advise you of the problem and provide you the oppurtunity to stop before you get your ass in a sling.

That said, in the event you have a duty time problem or an incident while teaching - you best have something better than the Chewbacha defense when you attempt to articulate your situation to the Chief.

 

[Vicman]

a thought

I too am contemplating part-time flight instruction. I don't fully undestand if that time as IP would could as "commercial flying time" against Part 121 FAA flight time limits...BUT...Hypothetically, could'nt an airline pilot time out for the year (1000 hrs) and then be assigned "pt 91" company reposition flights until dec 31st. If so then, flight instruction should pose no conflict (other than certificate action etc.)

If someone's got another take let me know..before i stray down the wrong path here. thx

 

[Freight Dog]

Hypothetically, could'nt an airline pilot time out for the year (1000 hrs) and then be assigned "pt 91" company reposition flights until dec 31st.

Maybe at Mesa.....

If you are being paid to move an airplane from Point A to point B, I believe the 1000 hour limitation applies even for repo flights...

What this "Part 91" rule is referring to is if you had a C-172 that you wanted to take out for $100 burger some place, you're not prohibited from doing that if you flew 1000 hours at your airline as you're not getting paid for it, and it's pleasure flying.

 

[koepp]

This came from the Q&A section that the FAA used to have on their site.

QUESTION: Does time spent off duty providing flight training under Part 61 as a certified flight instructor (CFI) count toward the maximum time I am permitted to fly commercially in a part 121 air carrier operation? For example, I am a pilot for United Airlines in scheduled passenger carrying operations. I want to provide flight training as a CFI at my home airport in a small general aviation airplane

ANSWER: Ref. § 61.195(a) and § 121.471(a) or (b); Yes, the flight time a person provides giving flight training under Part 61 as a certified flight instructor (CFI) during his “off time” counts toward/against the maximum time permitted to be flown commercially in a part 121 air carrier operation.

The maximum time permitted to be flown commercially in a part 121 air carrier operation is based on the flight time limitations established in:

Subpart Q of Part 121 [i.e., § 121.471]; or

Subpart R of Part 121 [i.e., § 121.481 or § 121.483 or § 121.485 or § 121.487 or § 121.489, as appropriate]; or

Subpart S of Part 121 [i.e., § 121.503 or § 121.505 or § 121.507 or § 121.509 or § 121.515 or § 121.517 or § 121.521 or § 121.523 or § 121.525, as appropriate].

In discussing this question with the FAA’s Air Transportation Division, AFS‑200, air carriers have standing directives to its flight crew personnel that they must inform or refrain from outside commercial flying activities.


Disclaimer Statement: The answers provided to the questions in this website are not legal interpretations. Only the FAA's Office of Chief Counsel and Regional Chief Counsel provide legal interpretations. The FAA's Office of Chief Counsel does not review this website nor does it disseminate legal interpretations through it. However, there are some answers provided in this website where the FAA Office of Chief Counsel's legal interpretations have been reprinted.

The answers in this website address Frequently Asked Questions on 14 CFR Part 61 and represents FAA Flight Standards Service policy as it relates to this regulation. The answers are as result of questions asked by FAA Flight Standards Service’s Regional Offices, District Offices, and from concerned people from the public. The answers provide for standardization.

 

[Vicman]

nice

Thanx Freight Dawg and Koepp for the replies. The Q&A excerpts were a great help (been searchin' on google).

I'll just wait on what the CP says....Hopefully it won't be a problem since I have 450 hrs remaining.

 

[AC560]

Disclaimer Statement: The answers provided to the questions in this website are not legal interpretations. Only the FAA's Office of Chief Counsel and Regional Chief Counsel provide legal interpretations. The FAA's Office of Chief Counsel does not review this website nor does it disseminate legal interpretations through it. However, there are some answers provided in this website where the FAA Office of Chief Counsel's legal interpretations have been reprinted.

Please see my post on the first page of this thread. For those to lazy to click back a page here it is again. Flight instruction is not commercial flying.

"The FAA has determined that the compensation a certificated flight instructor receives for flight instruction is not compensation for piloting the aircraft but is rather compensation for the instruction. A certificated flight instructor who is acting as pilot in command or as a required flight crewmember and receiving compensation for his or her flight instruction is exercising only the privileges of a private pilot. A certificated flight instructor who is acting as pilot in command or as a required flight crewmember and receiving compensation for his or her flight instruction is not carrying passengers or property for compensation or hire, nor is he or she, for compensation or hire, acting as pilot in command of an aircraft. Therefore, since a certificated flight instructor who is acting as pilot in command or as a required flight crewmember and receiving compensation for his or her flight instruction is exercising the privileges of a private pilot, he or she only needs to hold a third class medical certificate"

Source

 

[koepp]

I don't mean to be a pest, but that interpretation letter is only valid for determining what type of medical certificate is required to instruct. It falls short of defining “commercial flying” and whether or not instructing counts.

I thought about instructing on the side several years ago and dug up a bunch of material on the subject (and saved it). Here is an excerpt from an interpretation that deals precisely with instructing on the side (under part 135, but the reg is the same). It’s old, but I have never come across any guidance to the contrary.



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.

The answer is a qualified yes. ABC, as the certificate holder, has no way of forcing the flight crewmember to rest during a rest period. The prohibition against "other commercial flying" during a rest period applies to flying assigned by the certificate holder. 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 "freelance" 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.

An additional caution is that it is a violation of FAR 91.13 for a certificate holder or a flight crewmember to operate an aircraft in a careless or reckless manner so as to endanger the life or property of another. Lack of rest of the pilot is certainly a circumstance which could endanger others, and it is not necessary that the situation devolve into actual endangerment for there to be a violation of FAR 91.13. A certificate holder who uses a crewmember with knowledge of his or her lack of rest may be equally culpable along with the flight crewmember.


Here's the link

http://www.faa.gov/about/office_org.../interpretations/data/interps/1991/Bodlak.rtf

 

[AC560]

I don't mean to be a pest, but that interpretation letter is only valid for determining what type of medical certificate is required to instruct. It falls short of defining “commercial flying” and whether or not instructing counts.

No it defines instruction as non-commercial and a function of a private pilots certificate, not a commercial certificate. The key sentence is A certificated flight instructor who is acting as pilot in command or as a required flight crewmember and receiving compensation for his or her flight instruction is exercising only the privileges of a private pilot.

 

[koepp]

Here's a definition of "commercial flying" from a 2003 interpretation. (Sorry, I am very bored today.) Feel free to pick it apart all you want - I didn't write it. Just be careful. I would get a written policy statement from the FSDO before putting my career on the line for a little side instruction. The FAA even considers flight time itself to be "compensation".



"Other commercial flying" means any nonmilitary flying as a required crewmember, other than in air transportation, for which the crewmember is paid for his or her services). So, for example, when an individual is paid (e.g., with money) for flying corporate officers on a corporate jet in Part 91 service or when an airman provides flighttraining for compensation to another, such Part 91 flying is "other commercial flying" for the corporate jet pilot and for the flight instructor.


"The other commercial flying done by the flight crewmember does count against the daily 8hour 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.


The FAA construes "compensation or hire" very broadly. It does not require a profit, a profit motive or the actual payment of funds. Instead, compensation under the FAA's view, is the receipt of anything of value. Thus, compensation for the flights as proposed would exist in two forms. First, the expenses associated with the flight would be paid by donors to the charity, not the individual pilot; and second, the pilots would acquire flight hours at the charity's expense -- flight hours that could be used to demonstrate aeronautical experience eligibility for an airman certificate.3 These forms of compensation are sufficient to require the operator to have a part 119 certificate.

 

[freightrash]

As long as you don't get paid, it's not commercial flying.

 

[The_Russian]

You have to hold a commercial certificate to gain or use the privileges of an instructor certificate. It is not considered commercial flying by the FAA which is why it does not require a 2nd class medical.

"The FAA has determined that the compensation a certificated flight instructor receives for flight instruction is not compensation for piloting the aircraft but is rather compensation for the instruction. A certificated flight instructor who is acting as pilot in command or as a required flight crewmember and receiving compensation for his or her flight instruction is exercising only the privileges of a private pilot. A certificated flight instructor who is acting as pilot in command or as a required flight crewmember and receiving compensation for his or her flight instruction is not carrying passengers or property for compensation or hire, nor is he or she, for compensation or hire, acting as pilot in command of an aircraft. Therefore, since a certificated flight instructor who is acting as pilot in command or as a required flight crewmember and receiving compensation for his or her flight instruction is exercising the privileges of a private pilot, he or she only needs to hold a third class medical certificate"

Source

AC560,

You are absolutely correct.

 

[The_Russian]

As long as you don't get paid, it's not commercial flying.

Wrong!

 

[The_Russian]

"Other commercial flying" means any nonmilitary flying as a required crewmember, other than in air transportation, for which the crewmember is paid for his or her services). So, for example, when an individual is paid (e.g., with money) for flying corporate officers on a corporate jet in Part 91 service or when an airman provides flighttraining for compensation to another, such Part 91 flying is "other commercial flying" for the corporate jet pilot and for the flight instructor.


"The other commercial flying done by the flight crewmember does count against the daily 8hour 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.


The FAA construes "compensation or hire" very broadly. It does not require a profit, a profit motive or the actual payment of funds. Instead, compensation under the FAA's view, is the receipt of anything of value. Thus, compensation for the flights as proposed would exist in two forms. First, the expenses associated with the flight would be paid by donors to the charity, not the individual pilot; and second, the pilots would acquire flight hours at the charity's expense -- flight hours that could be used to demonstrate aeronautical experience eligibility for an airman certificate.3 These forms of compensation are sufficient to require the operator to have a part 119 certificate.

Official source please?

How is a flight instructor providing instruction a "required crewmember"?

 

[flyboyike]

If you fly for an airline and instruct on the side, whether instructing is really interpreted as commercial flying or not isn't the point. The restriction is usually in your airline's FOM, not the FARs.

Exactly right. Best to get clarification from one's own Cheif Pilot or Director of Ops.