Wed May 23, 2018 8:52 pm
#1613340
The regulation itself is pleasantly clear on this, albeit comprises 2 separate requirements for experience - pre-course and pre-test. Appendix 3 to Part-FCL states:
3. Before commencing the flight training the applicant shall:
(a) have completed 150 hours flight time;
(b) have complied with the prerequisites for the issue of a class or type rating for multi-engine aeroplanes in accordance with Subpart H, if a multi- engine aeroplane is to be used on the skill test.
It then goes on to state:
12. The applicant for a CPL(A) shall have completed at least 200 hours flight time, including at least:
(a) 100 hours as PIC, of which 20 hours of cross-country flight as PIC, which shall include a VFR cross-country flight of at least 540 km (300 NM), in the course of which full stop landings at two aerodromes different from the aerodrome of departure shall be made;
(b) 5 hours of flight time shall be completed at night, comprising 3 hours of dual instruction, which shall include at least 1 hour of cross-country navigation and 5 solo take-offs and 5 solo full stop landings; and
(c) 10 hours of instrument flight instruction, of which up to 5 hours may be instrument ground time in an FNPT I, or FNPT II or FFS. An applicant holding a course completion certificate for the Basic Instrument Flight Module shall be credited with up to 10 hours towards the required instrument instruction time. Hours done in a BITD shall not be credited;
(d) 6 hours of flight time shall be completed in a multi-engine aeroplane, if a multi-engine aeroplane is used for the skill test.
Given that the applicant for a CPL must be at least 18, the 17 year old new PPL holder would have a slight delay before commencing a 25 hour CPL course. An EASA compliant modular CPL course comprises 25 hours of instruction, of which 10 must be instrument instruction. Of these 10 up to 5 may be completed in a suitably approved instrument trainer, as per para (c) above. It is therefore possible for a CPL course to only add 20 hours rather than 25 to an individual's total time, which is worth factoring in to the overall plan - I've certainly tailored CPL courses reasonably neatly to make the most efficient use of someone's existing experience, and how close to 200 hours total time they are.
As regards the PIC time, PIC is PIC, irrespective of whether it is solo time flown under supervision during a PPL course or flown under licence privileges subsequent to a course. While it would be unusual for someone to build 100 hours PIC during a PPL course it would not, strictly speaking, be outside the regulation - in letter at least. It might not provide the best experience in spirit, since part of the reasoning behind the 100 hour PIC requirement is that the CPL student will have experience operating outside a supervised environment, ie scheduling their own flying, true command decisions, etc.