"Peter Duniho" wrote in message

.
I don't see anything in the regulation that requires the training to be
*as
part of* an air transportation provider. Simply that it can only be done
for pilots who are in air transportation service.

Maybe there's an FAA legal counsel interpretation around somewhere that
further limits the ATP's instructional privileges, but at face value, it
appears that an ATP without a flight instructor certificate could still
perform a BFR (for example) for a fellow ATP working as an airline pilot.

Pete, IMO you've misinterpreted the sentence structure.

Where the reg says
"...b) An airline transport pilot may instruct...other pilots in air
transportation service in aircraft of the category, class, and type, as
applicable, for which the airline ....."
I believe the phrase "...in air transportation service..." is the object of
the verb instruct, rather than an adjectival phrase modifying the noun
"pilots", in much the same manner that you might say "I'm giving him
instruction in mathematics".

My interpretation was always that an ATP can instruct other pilots in the
ups and downs (as it were) of air transportation. IOW, "I'm not teaching
you to fly, I'm teaching you to fly this aircraft professionally and
responsibly according to the policies and procedures of our employer, the
Certificate Holder." One gray area we always used to debate as CFIs was
whether an ATP without a CFI can give training to another pilot who is not
employed in air transportation in preparation for that pilot's ATP
checkride. I can't recall what we may have concluded, but it was all 30
years ago, so it is probably different now anyway. :-)

JG