Originally Posted by BeatNavy

Interesting point you bring up. 121.434 says (3) The experience must be acquired in flight during operations under this part. However, in the case of an aircraft not previously used by the certificate holder in operations under this part, operating experience acquired in the aircraft during proving flights or ferry flights may be used to meet this requirement.

Why would they bother to put that ‘however’ part in there if any repo/ferry flight could just be deemed a part 121 flight as you say commutair can do and count toward the 25 hours? Maybe I’m missing something.