Pt 121 PIC Prev. Experience?

[Tyler Pinkerton]

So here is a question I have that hopefully someone deep in the know can clarify as I can't seem to find any FAA interpretations for it.

I'm not trying to get around the regionals, but this has just been one of those things that has had me pondering and I haven't been able to find a clear answer on my own.

Pt121.436(A)(3) states:

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. For those pilots who are employed as pilot in command in part 121 operations on July 31, 2013, compliance with the requirements of this paragraph (a)(3) is not required.

135.243(A)1 states:

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 as defined in part 119 of this chapter, unless that person holds an airline transport pilot certificate with appropriate category and class ratings and, if required, an appropriate type rating for that airplane.

So 1000hrs of 121 sic or 91 subpart K PIC is easy to get... However, my questions come with regards to the part 135 experience as those listed are the operations that require an ATP under 135.

Now I have always seen people refer specifically to the PIC in Commuter operations aspect when citiing 135.243 for 121 experience, in reference to both single engine and twin engine commuter ops. However, 135.243A1 specifically states Turbojet, 10+ seats or TWIN engine commuter ops and 121.436 does not specifically refer to the commuter aspect of 135.243A1 when it says operations under that part count towards the 121 experience.

So does normal 135 jet PIC or 10+ seats indeed count towards 121 PIC?
Does single engine commuter ops experience count towards 121 PIC experience or is it just strictly Multi engine as the reg is written?
Do scheduled freight operations conducted under 135 get any credit?

 

[Finny]

Scheduled freight ops in a prop would not count towards the 1000 sic requirement.

 

[NickH]

http://forums.jetcareers.com/threads/kelley-interpretation-letter-121-436.207571

 

[Tyler Pinkerton]

Thanks, after looking through that, I remember previously seeing that thread and interpretations but had forgotten about them.