My apologies in overlooking those that are operating as a PFE. My point is that for those manipulating the flight controls in a 121 operation be qualified as ATP's. If the aircraft still requires an FE for operation you hold a FE certificate for that. On a tangent if a commercial pilot can't operate as an FE which is an additional rating, then why should they be allowed to be a copilot in an operation where they may have to assume command of an operation that does require an ATP?