CFI without commercial?

61.51(e)(3) An authorized instructor may log as pilot-in-command time
all flight time while acting as an authorized instructor.
Seems to me this says that it has to be flight time first, he has to be
acting as an authorized instructor =during= that flight time, and =then=
he can log it as PIC time.
Yes, but, if the CFI is not manipulating the controls, then he is not flying the
aircraft. He has been in an aircraft that someone else is flying.

Ok, he's not "flying the aircraft" but he is "flying" (aloft). OTOH,
when a pilot sits back and lets George do the flying, is the pilot
"flying the aircraft"? Does it matter if George is organic or electrical?

So, off to the definitions:
Flight time means: (1) Pilot time that commences when an aircraft moves
under its own power for the purpose of flight and ends when the aircraft
comes to rest after landing; or (2) [glider stuff, ignored]

Pilot time means:.... nothing. It's not defined. No surprise here!

Provisions are made for a safety pilot to log SIC time(*) even when the
safety pilot is not manipulating the controls. Now this time first has
to be "flight time", which means it first has to be "pilot time", which
is undefined. It might make sense that "pilot time" is only that time
in which the pilot in question is piloting the aircraft, but to hold to
that strictly would make the logging of SIC time for a safety pilot
impossible (except perhaps for the one moment where the safety pilot
grabs the controls after seeing the impending collsion hazard So,
attractive to logic that that definition might be, it must be
(reluctantly) abandoned for something looser. One candidate would be
"that time in which the aircraft is flying, attempting to fly, or in
continuous motion on the ground after flight, and there is a pilot on
board attempting to maintain control of the situation". If it's pilot
time for someone, it's pilot time for everyone onboard that has some
responsibility for the outcome of the flight. It is then loggable
flight time under the right circumstances (like sole manipulator, giving
flight instruction, etc.)

The CFI, while giving instruction, has some responsibility for the
outcome of the flight. He is actively participating in the flight, even
if only as an observer whose input will be considered later. (If there
is no input, then there is no flight instruction being given. The
granting or denial of a certificate or rating counts as input (+).)

(*) yes, under some circumstances he can also log PIC time, but this is
irrelevant to my point
(+) despite the FAA's contention that a flight test doesn't count as
"instruction"; I'm just keeping things simple for illustration. After
all, I'm making this interpretation up anyway

Jose
--
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