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Old 10-16-2017, 09:56 AM
  #4  
Xdashdriver
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Joined APC: Oct 2013
Posts: 1,666
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Unfortunately the FAA has recently denied at least one petition to allow foreign air carrier flight time to count towards the requirements of 121.436.

The basic reasoning they used was:

"The FAA concluded that, although foreign air carrier operations are similar to U.S. air carrier operations, there are significant differences related to the environment under which foreign air carrier operations are conducted, including possible cultural differences. Most importantly, pilots serving for foreign air carriers do not operate under U.S. regulations and may not have experience in the U.S. national airspace system. The FAA concluded that requiring these pilots to serve first as an SIC in part 121 operations before upgrading to PIC
is appropriate."

If you do a search at regulations.gov for "FAA 2016-8912", you should be able to read the full text of their decision.
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