After reading the Carpenter interpretation from 1999, I just have to laugh.
The first part I agreed with. I logged PIC and dual rec'd while attaining instrument and commercial ratings, as well as in KingAirs operated under Part 91. (Note to noobs....figure out away to separate the PIC time to be used for future jobs (i.e.: You need 100 hrs BE90 PIC for a job. Or you need the PIC time to do MEI work [ya know, Mr. Rich Dude bought a BE200 cash money, and wants someone to be there, or insurance requires it.)
However, I know this guy is a lawyer, and went to law school, and is in a politically appointed job. How can I tell? Reading the 121 interpretation.
I still can't see how in a professional environment, you can be PIC under Part 1, but not part 61. Or you can't be PIC under Part 1 but you can under part 61. If you are at a 121 carrier, you have no need to log experience toward a future rating. Say you're a commercial/inst/multi as a lot of F/Os are. Once you meet ATP mins, you meet them. If you don't have a certain ratio of PIC to Total time you get an ICAO restriction, as I did. Then you fly a month or 2, go to the FSDO and get a new license cut.
Let's say everyone gets typed at Airline "A" (not WN, because you have to have 1000 turbo PIC). You get hired at 550TT, after 10 years, you never upgraded and the doors close. I'm sitting at the interview table with your log book. I look and you have 5000 PIC (hypothetical 1000 hrs/yr and you fly 1/2 the legs). I laugh.
We've also read all the AOPA stories of ATP rated much experienced guy riding with his PPL buddy. The ATP is enjoying the view, but hasn't flown GA in years, so isn't up on the TFRs and other crap that makes GA so enjoyable these days
sarcasm
. PPL guy pops some airspace. All of a sudden the guy who was sitting and relaxing in the airplane is designated PIC since he was in the right seat.
So while, yes, I agree you are correct in the reading of the interpretation, I still wouldn't do it. When the next lawyer takes the place of the guy writing the interpretation and the "view" is changed, you have alot of logbook shuffling to do.
Just like the rest requirement reversal issued via the Whitlow letter, what's true today, might not be tomorrow.
Just food for thought.
And yes, grayson, I still think you're the smartest dude on the board.