Originally Posted by
DAL757
Just keep in mind any paid flying, even 91, will count against your 121 limits if it is before any 121 flying. You can fly 91 after 121 all you like. But, if it falls before 121 it must be counted and that's why it's usually prohibited because it's impossible for the company to track.
According to ALPA's Part 117 guide only flying performed for a certificate holder (i.e. 121 or 135) or Part 91K (fractional ownership program) is counted towards determining cumulative limits.
See ALPA 117 guide Q 66 and A 66 found on page 17 of guide dated 11/19/13.
I'm no expert and maybe I'm reading it wrong. I just think they dropped the requirement to track hours flying plain old part 91 when they adopted 117.
-UA