100% Totally Wrong.

Am I being abrupt here? Maybe. But it's possible that somebody has already signed up to spend 12 hours and $350 that they did not need to based on what you posted.

However...on this note the previous discussion about the language allowing use of an expired written at a 121 operator appears correct: It only applies to actual CA upgrade. An FO who is just getting an ATP and not completing PIC training would need a current written (within 24 months). The FAA did not really intend for this to happen, it probably just never occurred to them when they did the new reg. Sucks, but there it is.

I know some airlines have already handed out FO ATP's...I bet some of those had expired writtens and eventually the FAA will circle back around and fix that. I bet some folks will getting a letter in the mail.