Like planes,

We are on the same page. I agree that the reg is specific on what time can be counted. What i cannot go along with is that you can take 91.1053(a)(2)(i) in isolation from its context and say "aha, I have an ATP, so I am good," which is what it seems captpappy is saying you can do.

What captpappy seems to think is that merely meeting the qualifications to be a 135 and 91K PIC equates to having served in those capacities for 1,000 hours.

Additionally, in general, you're not going to get away with disagreeing with the FAA lawyers on interpretation of the regulations when they have already published an interpretation. Plenty of case law on that one.