Originally Posted by
JohnBurke
Note that 121.436(a)(3) doesn't apply if you've served as PIC under Part 121 prior to July 31, 2013.
Great, informative post. Unfortunately the regulation does not have the above common-sense provision in the language. The language in 121.436(a)(3) says it doesn't apply if you were serving as PIC under Part 121 ON July 31, 2013. As a result, prior PIC time is null and void unless you were a PIC ON that date. That was one of the main points of the Kelley interpretation you referenced.