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Old 01-18-2016, 03:18 PM   #21  
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I apologize if this has been answered somewhere, but if it has, I can't find it. According to everything I've seen, the military allowance is 500 hours of PIC towards the 1,000 hrs requirement. I would assume PIC in that case is referring to Aircraft Commander time and not to Primary time, right? However, it seems weird that you would need 500 hours of military AC time towards a 1000-hr minimum to upgrade to captain at a 121 operation. Then again, it's FAA so that's probably the case. Anybody have any experience with this that can offer clarification?


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Old 01-18-2016, 05:26 PM   #22  
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The FSDO level is not authorized to interpret regulation, and no answer you get at that level will be defensible, even if you receive it in writing. In other words, what you get is purely opinion, and at no time will you ever be able to fall back on that answer.

14 CFR 121.436(a)(3) states that a PIC under Part 121 must have 1000 hours as SIC either: under 121, 135, or 91K. Note that the specific 135 requirement is experience in turbojet multi engine (or multi engine in commuter operations) aircraft of 10 seats or more--in which the PIC must hold an ATP. Likewise, the 91K requirement is specifically multi-engine fixed wing airplane or powered lift operations in which the PIC must hold an ATP. In other words, not just any charter or fractional experience will do. The intent is that it's the equivalent level of responsibility and duty that a Part 121 operation would require.

If you operated for a foreign airline, it wasn't under Title 14 of the United States Code of Federal Regulations, and therefore, not a 91K, 121, or 135 operation.

Time spent as pilot in command or second in command in foreign operations does not apply to the 1000 hr. SIC requirement of 14 CFR 121.436(a)(3).

Note that 121.436(a)(3) doesn't apply if you've served as PIC under Part 121 prior to July 31, 2013.

If your experience wasn't working for a US carrier under 91K, 121, or 135, you may count 500 hours of military experience as PIC in a multi engine turbine aircraft (that requires more than one pilot) toward the 1000 hours required by 121.436(a)(3).

The following FAA Chief Legal Counsel Letters of Interpretation will help clarify the answer to your question and give additional insight. These are defensible and are a reliable source regarding the Administrator's position on your question:

http://www.faa.gov/about/office_org/...rpretation.pdf

http://www.faa.gov/about/office_org/...rpretation.pdf

http://www.faa.gov/about/office_org/...rpretation.pdf

The final letter of interpretation above serves to clarify the specific Part 135 reference requirements of the earlier Kelly letter.
What if I had 1000pic as a street captain before and still no 1000sic?
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Old 01-19-2016, 05:59 PM   #23  
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What if I had 1000pic as a street captain before and still no 1000sic?
You can apply for an exemption. PM me.
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Old 10-15-2019, 07:35 PM   #24  
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Reviving or Revising an old thread: Does anyone know if the 121 1,000 hour requirement has been changed at all in the last couple of years?

I had a discussion with a possible employer today who stated my 1,000 hrs PIC 'Commuter Airline' would not count towards the 1,000 121 requirement; but it certainly does the way I read the FAR's. To wit: 121.436 "(3) If serving as pilot in command in part 121 operations, has 1,000 hours as second in command in operations under this part, pilot in command in operations under 91.1053(a)(2)(i) of this chapter, pilot in command in operations under 135.243(a)(1) of this chapter, or any combination thereof." 135.243(a)(1) reads "(1) Of a turbojet airplane, of an airplane having a passenger-seat configuration, excluding each crewmember seat, of 10 seats or more, or of a multiengine airplane in a commuter operation..."
Am I missing something or as I say, have the regs changed recently?
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Old 10-15-2019, 08:55 PM   #25  
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Reviving or Revising an old thread: Does anyone know if the 121 1,000 hour requirement has been changed at all in the last couple of years?

I had a discussion with a possible employer today who stated my 1,000 hrs PIC 'Commuter Airline' would not count towards the 1,000 121 requirement; but it certainly does the way I read the FAR's. To wit: 121.436 "(3) If serving as pilot in command in part 121 operations, has 1,000 hours as second in command in operations under this part, pilot in command in operations under 91.1053(a)(2)(i) of this chapter, pilot in command in operations under 135.243(a)(1) of this chapter, or any combination thereof." 135.243(a)(1) reads "(1) Of a turbojet airplane, of an airplane having a passenger-seat configuration, excluding each crewmember seat, of 10 seats or more, or of a multiengine airplane in a commuter operation..."
Am I missing something or as I say, have the regs changed recently?
Nothing has changed. If you hold an ATP (which you need for the commuter ME PIC operation), that time counts towards 121 upgrade time.
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Old 10-19-2019, 09:31 AM   #26  
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"Note that 121.436(a)(3) doesn't apply if you've served as PIC under Part 121 prior to July 31, 2013." I want to be fairly accurate in a novel I'm writing--would your comment mean that if the main character gets into the right seat of a regional carrier in 2011 and moves to left seat in 2012, that he wouldn't need to meet the new ATP requirements that were installed in 2013? Thanks. I won't be including much detail in the book, but want to be close to accurate in what I present.
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Old 10-21-2019, 05:29 PM   #27  
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"Note that 121.436(a)(3) doesn't apply if you've served as PIC under Part 121 prior to July 31, 2013." I want to be fairly accurate in a novel I'm writing--would your comment mean that if the main character gets into the right seat of a regional carrier in 2011 and moves to left seat in 2012, that he wouldn't need to meet the new ATP requirements that were installed in 2013? Thanks. I won't be including much detail in the book, but want to be close to accurate in what I present.
The regulation actually says that you need to be serving as PIC ON July 31, 2013 to be exempt from the regulation, so if your main character was a 121 PIC on July 31, 2013 then he wouldn't need the 1000 hours. That being said, the FAA has been approving exemptions to count the PIC hours for those who served as 121 PIC prior to but not ON July 31, 2013.
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Old 12-26-2019, 05:32 AM   #28  
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This should clear this up:

https://www.faa.gov/about/office_org...rpretation.pdf
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Old 05-25-2020, 12:33 PM   #29  
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I have been researching my options and a question came up. If I already have my 1000 turbine SIC 121 but decided to move closer to home for a possibly part 135/or charter gig flying the ERJ-135 and upgrade as PIC, does that PIC time counts if I were to apply at another major airline towards the future?
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Old 05-25-2020, 05:17 PM   #30  
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I have been researching my options and a question came up. If I already have my 1000 turbine SIC 121 but decided to move closer to home for a possibly part 135/or charter gig flying the ERJ-135 and upgrade as PIC, does that PIC time counts if I were to apply at another major airline towards the future?
If you're asking does your 121 SIC count towards upgrade requirements at a different airline, then yes. Once you have it (after the cutoff date in the rule), it's totally portable. What you do in the meantime doesn't matter.

Individual airlines can (and some do, or used to anyway) require X amount of hours at that company to upgrade.
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