Originally Posted by
Xdashdriver
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.
Hence the purpose of turning to the correct source for gaining an authoritative and defensible interpretation of the regulations. The FAA Chief and Regional Legal Counsels are the only sources authorized by the Administrator to interpret the regulation; an interpretation of the regulation at the FSDO level is not authorized and any opinion received at that level cannot reliably be supported or relied upon.