I don't think it was intentional, I think they just screwed up the wording and now it's unchangeable law

It is not unchangeable though if it truly was a mistake - though I'm more inclined to believe that there is a reason behind the wording that the rule-making committee decided on.

Silly and inconvienent
 

I'd sure like to know what that reasoning is (yes, I'm officially inquiring through a FSDO and several ASIs I know and I am planning to apply for an exemption). I have 14000+ 121 PIC (B-727 and heavier) but little 121 SIC (right place, right time) over a spotless career of more than 25 years. Unfortunately, I happened to be permanently furloughed from my defunct 121 employer on July 31, 2013 and was looking for a new position on the trigger date.

I would like to know how it serves the interests of the public, air carriers and the administrator to completely disregard this experience (while otherwise giving credits for military or academic programs) and require me to acquire 121 SIC time to qualify for a position I have successfully trained and qualified for over several decades (rhetorical question). Or oddly, completely ignore this experience while granting credit for 135 or 91 time.

Silly.

Don't expect any real answers from FSDOs and ASIs, this stuff is all done in DC. I am in your shoes and have applied for an exemption already.

I'm going on the 91.1053.a.2.i experience requirements as being sufficient and that 121 PIC would fall into that basket by default. Meanwhile, if you have any information you can share about where and how to file for an exemption directly, I'd appreciate the info.

Thanks.

What 121 carriers have allowed FOs to upgrade w/o at least 1,000+ hours PIC/FO time? I can't think of any off the top of my head.

Maybe Air Midwest B1900 back in the day? Or Gulfstream? Other than that, I can't imagine how many people this would actually affect in reality.

The reg you quoted would mean 121 PIC would be acceptable for a 91K PIC, but that doesn't mean it's acceptable for 121 ops. Apples and oranges.

1) Do a quick google search on what information is required by the FAA in a petition and then write the petition.

Here is a start:

https://www.faa.gov/regulations_poli...d_Petition.pdf

2) Go to regulations.gov and search for "FAA 2007-0001"

3)Click on the comment icon and paste your petition in there.

4) FAA will send you a letter once they have received the petition.


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[QUOTE=flapshalfspeed;1740212]What 121 carriers have allowed FOs to upgrade w/o at least 1,000+ hours PIC/FO time? I can't think of any off the top of my head.

There are DEC positions posted on the orange site that I wouldn't qualify for because of the various interpretations of this reg so it kinda hurts.

[QUOTE=Xdashdriver;1740227]The reg you quoted would mean 121 PIC would be acceptable for a 91K PIC, but that doesn't mean it's acceptable for 121 ops. Apples and oranges.

You're right. It's all in the interpretation. I might as well get started. Thanks for the pointers.

Actually, no....

Lakes operates their 1900s Part 135 now, therefore, an FO on the 1900 at Lakes with 1000 hours of SIC time would not have any credit time for 121.436.

To take it a step further: Why would the 1900 CA at Lakes qualify for 121.436 and not the 1900 PIC hauling boxes?

Answer: The 1900 CA in pax operations is required to hold an ATP certificate to conduct such operations. The 1900 cargo PIC is capable of operating under just a CPL.

The way I see it, the FAA wants time where you were either..:
- In a 121 environment which ensures you have an ATP/R-ATP, and thus the experience required to achieve such certificate.
- In a 135 PIC environment which requires an ATP, and thus the experience required to achieve such certificate.
- In a 91k PIC environment which requires an ATP, and thus the experience required to achieve such certificate.

... and that's the time you can count towards 121.436.