PIC 121 explained

JCF1974

JCF1974

Well-Known Member
Quick question regarding the previous experience requirements in 121 ops. This is all hypothetical, as I left 121 ops a few years ago, and just wondered if there was a grandfather clause.

My experience

At about 1000 hours, entered 121 ops as SIC, no previous 121 or 135.
Logged 300 hours SIC there.

Second 121 job, another 300 hours of SIC, upgrade. Work several years as PIC.

Third 121 job, street captain on CRJ, work several more years, all PIC.

So, in my 7500 hours or so, I have all of 600 hours of SIC 121. The question becomes, would I have remained qualified as PIC if I were still flying? Additionally, in the unimaginable combination of circumstances that would put me in a street captain seat again, would I be qualified?

Go.
 
I assume you have plenty of 121 PIC from the CRJ job?

There are plenty of guys from the Regional "glory days" who had a 15 month upgrade and many of them don't have 1000 121 SIC. I'm too lazy to find a reference but I'm pretty sure you'd be grandfathered in since you assumedly have 1000 PIC or more.
 
Plenty of 121 PIC from both jobs. I haven't read through the rule, so the forum is admittedly my lazy way out of doing that. I only read the FAA explanation and in their breakdown of acceptable substitutes for the 1000 hours of 121 SIC, I noticed the glaring exclusion of 121 PIC.
 
Looks like according to the rule, the only way a 121 PIC would be grandfathered under 121.436 is if they were a current 121 PIC as of July 31, 2013.

This might be a good thing to have the FAA Chief Council interpret as only current 121 PICs were mentioned and that was only for the effective date of the new regulation. Prior 121 PIC should count for something.
 
Hmm. Practically speaking this means little, but it does feel a little like a personal slap in the face.
 
JCF1974 said:
Quick question regarding the previous experience requirements in 121 ops. This is all hypothetical, as I left 121 ops a few years ago, and just wondered if there was a grandfather clause.

My experience

At about 1000 hours, entered 121 ops as SIC, no previous 121 or 135.
Logged 300 hours SIC there.

Second 121 job, another 300 hours of SIC, upgrade. Work several years as PIC.

Third 121 job, street captain on CRJ, work several more years, all PIC.

So, in my 7500 hours or so, I have all of 600 hours of SIC 121. The question becomes, would I have remained qualified as PIC if I were still flying? Additionally, in the unimaginable combination of circumstances that would put me in a street captain seat again, would I be qualified?

Go.
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Not unless you were PIC on July 31, 2013.
http://www.faa.gov/about/office_org...2014/Kelley - (2014) Legal Interpretation.pdf
 
Thanks all for the response. After reading the rule the interpretation appears right on. I wonder what the intent is for the specific exclusion. I can't see it being an oversight. Or do they just not like me?
 
JCF1974 said:
Thanks all for the response. After reading the rule the interpretation appears right on. I wonder what the intent is for the specific exclusion. I can't see it being an oversight. Or do they just not like me?
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The intent is to ensure that the person in the left seat has adequate SIC (or part 121, for that matter) experience to make a good PIC, I think. I would have to dig out the final rule and comments to see their rationale- should be in the Federal Register.
 
Understand the requirement of the SIC time, completely. Don't understand the exclusion of previous 121 PIC. Speaking hypothetically, a pilot has a few thousand pic 121 in two different aircraft for two different operations, yet does not qualify for lack of 400 SIC? What exactly is the 400 hours of additional SIC time going to get him, that two type rides, an ATP, seemingly endless PC's and line checks haven't already? Never in my life would I have imagined I would look at my logbook and wish I could convert some PIC to SIC.
 
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You could be a Bro captain at AMF with 2000+ hours as PIC in type and then go 121 and not be qualified to operate as PIC in the Bro. Meanwhile a Great Lakes guy that has 1000 hours in the right seat of a 1900 (single pilot aircraft) is all of a sudden more qualified for the same slot. There is no logic in this reg.

Autothrust Blue said:
The intent is to ensure that the person in the left seat has adequate SIC (or part 121, for that matter) experience to make a good PIC, I think. I would have to dig out the final rule and comments to see their rationale- should be in the Federal Register.
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121 really isn't all that different from 135 scheduled ops. If anything (especially since 117) it is more restrictive. Opspecs are typically copied word for word on both sides. Yes passenger ops on the 135 count but for some reason cargo was completely omitted. A 135 Cargo EMB-120 captain could not legally operate a Cargo EMB-120 in the 121 world under the new reg.
 
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Maurus said:
You could be a Bro captain at AMF with 2000+ hours as PIC in type and then go 121 and not be qualified to operate as PIC in the Bro. Meanwhile a Great Lakes guy that has 1000 hours in the right seat of a 1900 (single pilot aircraft) is all of a sudden more qualified for the same slot. There is no logic in this reg.



121 really isn't all that different from 135 scheduled ops. If anything (especially since 117) it is more restrictive. Opspecs are typically copied word for word on both sides. Yes passenger ops on the 135 count but for some reason cargo was completely omitted. A 135 Cargo EMB-120 captain could not legally operate a Cargo EMB-120 in the 121 world under the new reg.
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A great majority of the time, it is very easy to spot an individual with very limited SIC time in 121.
 
Polar742 said:
A great majority of the time, it is very easy to spot an individual with very limited SIC time in 121.
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That may be true, but time making decisions in the left seat of a multi-engine turbine powered airplane should count for something. As it stands right now, it doesn't. A guy can be trained in CRM; experience has to be earned.
 
I wholeheartedly believe that, before this reg became real, if you had asked ANY of us what is more valuable, 1000 hours of PIC or 1000 hours of SIC, we ALL would have answered the same.
 
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