121.438 (b) - 75 hours of what?

[ksu_aviator]

Let's start with the reg:

[h=2]§121.438 Pilot operating limitations and pairing requirements.[/h][FONT=&quot](b) No person may conduct operations under this part unless, for that type airplane, either the pilot in command or the second in command has at least 75 hours of line operating flight time, either as pilot in command or second in command. The Administrator may, upon application by the certificate holder, authorize deviations from the requirements of this paragraph (b) by an appropriate amendment to the operations specifications in any of the following circumstances:[/FONT]
[FONT=&quot](1) A newly certificated certificate holder does not employ any pilots who meet the minimum requirements of this paragraph.[/FONT]
[FONT=&quot](2) An existing certificate holder adds to its fleet a type airplane not before proven for use in its operations.[/FONT]
[FONT=&quot](3) An existing certificate holder establishes a new domicile to which it assigns pilots who will be required to become qualified on the airplanes operated from that domicile.[/FONT]

I don't care about the exemptions 1-3. What I care about is the weird wording that leaves a lot of ambiguity. Specifically; "...[FONT=&quot]either the pilot in command or the second in command has at least 75 hours of line operating flight time, either as pilot in command or second in command..."

One interpretation is that the PIC must have 75 hours PIC or the SIC must have 75 hours of SIC time. The other interpretation is that either pilot must have 75 hours in any seat. What say you? When I was at Mesaba we used the first, at Envoy they use the second. Does anyone have a LOI that clarifies this? I couldn't find one. [/FONT]