skydrol,
If you hold an ATP, you are covered under 121.436.
- pilot in command in operations under §91.1053(a)(2)(i) of this chapter
§91.1053(a)(2)(i)
- (2) For multi-engine turbine-powered fixed-wing and powered-lift aircraft, the following FAA certification and ratings requirements:
(i) Pilot in command—Airline transport pilot and applicable type ratings.
Do you hold the requirements of §91.1053(a)(2)(i)?
I don't know you... but I would think you do.
For example, the regs do not specify you need 1000 hours under 91 as PIC, they just state you need to hold an ATP and appropriate Type rating.
The comma means everything....
Think like a lawyer... not a pilot.. and you'll be fine..
(i also agree with the above who stated to not bother with a local FSDO... I recommend you call OKC instead).
My opinion? The FAA screwed the pooch.. as usual. But you can work it to your advantage.