Originally Posted by
mike sierra
While I see your point, I just want to add some other info:
ICAO recognized countries (which most of places in the world are) also regulate their airlines by PART 121 with the local differences from ICAO standards published in the difference parts. So it still may be possible, I guess the only way to figure out is to ask FAA for a letter of interpretation.
Sounds reasonable to me, but the reg is pretty clearly written and the FAA cannot really "re-interpret" a black-and-white reg even if they wanted to. Wouldn't hurt to ask, but it might take a while to get an answer.