PIC time is not the issue. The fact is that flight instructors are flying
for hire because they're flying and they're being paid while they're doing
it. That may bother you no end but that's the way it is, there's simply
no
way around the logic.


That's your opinion, not the FAA's, and yours is not the one that matters.
I'll wait for word from them that you've convinced them to change the
Preamble to Part 61, but I won't hold my breath.