CPL and 100h PIC requirement

[Bubble]

Could anybody let me know if the 100 hours PIC requirement for a CPL (JAR modular course):

a) Have to be complete before course starts,
b) during CPL training,
c) or could some remaining hours of the 100, be completed after CPL skill test but previously to licence issue.

I would must appreciate if you could point me to the law article/s where clearly answer this point, as different people interpret it in a different way.
Thank you very much in advance for all your inputs:ok:

[Keygrip]

You're not going to like this - but the following comments are truly designed to help you (and your colleagues) move in the right direction. Apologies if it sounds confrontational - it isn't meant to be.

I'm sure you didn't mean it that way - but your postings suggests (at least to me) that you might not believe the answers we give yoiu anyway.

Although you clearly haven't started the CPL course yet, one of the impotant factors of the end result of taking the skill test is that you suddenly become a "Professional Pilot". The CPL is a licence change - you move from Private Pilot to PROFESSIONAL pilot and are expected to know the rules and regulations as part of making that transistion - and there's abig push by the CAA to see that this happens.

If you have done the groundschool and exams already - you should know where to find the answer for yourself. If you haven't yet taken the exams then PLEASE do so before doing the hour building, sky drilling, phase of your modular course. Don't do the fun stuff first and then have all the hard work to do whilst getting rusty with your flying skills whilst studying the books.

The question you ask is about JAA pilot licensing - albeit about the course and requirements to achieve that licene - so the answer is in JAR FCL.

I'm working on a remote computer at the moment, so cannot help you by posting the link - no doubt somebody else will do it for you shortly.

The answer to your question - the only pre-course requirement is a total time of 150 hours. By the end of the course you must have at least 175 hours, a night qualification and an R/T licence.

BY the time you APPLY FOR YOUR CPL you must have at least 200 hours total time - which must include 100 hours of P1 including the "long cross country".

Really hope I didn't come over too "angry" - just trying to point you towards how to find the answer.

Now, I'll get round to pressing "submit" and see if anybody else has answered during all the time it's taken me to write all this.

All the best with the training.

[BillieBob]

Or, to answer the question that was asked - c) JAR-FCL 1.155(c)(1)

[Keygrip]

Thank you BB - I knew someb oddy would be along shortly with the link.

[Bubble]

Thanks for your answers KeyGrip and BillieBob.
Sorry if the way I present my post wasn´t right. I didn´t mean to. It´s only that I´ve been doing my CPL training in Spain and there is a different interpretation of the law regarding this matter between my FTO and the Spanish CAA (DGAC). While my FTO agree with you, the DGAC says that you must complete your 100h before CPL course starts or at the most while you do the CPL course. The guy of the DGAC was having a look of the different JAR articles and couldn´t find the one to give him the reason, but he swears he has read it somewhere and he was going to find it for me.
I have already have a look into the JAR-FCL but I couldn´t find anything to give the reason to the DGAC. So I just wanted someone with more knowledge than me about this matter to give their opinions and at the same time if possible to get something in black and white that I could print to show this guy and prove to him that he is wrong. As they want me to retake my CPL and probably fine me for doing it the "wrong way":confused: :{ :uhoh:

[willby]

Hi ,
Bubble's query raises an important point. As has often been mentioned on this forum JAR regulations are not binding on member states but are recommendations which members for the most part seem to adhere to. However, there are some discrepencies between member states e.g.
To commence an initial type rating course the CAA now only require a vaild multi ir within the last five years and JAR FCL 1.250 requires a valid multi IR.
I know of another member state who will accept the multi engine skill test for up to 12 months after completion before adding it to licence whe JAR FCL states the validity period is 6 months.
I believe therfore simply quoting JAR-FCL documents will not always provide the answer to a poster's query, especially if their state for licence issue is other than the CAA.
I would welcome views from Billiebob and Keygrip re the above.
Regards
Willby

[Keygrip]

Willby - agree with you 100%.

It's another example of why we all need to start getting so pedantic (stands by for rocket from BillieBob) when we are asking/answering these questions.

As I've asked, so many, many times in the past - a lot of the answers to questions are based on "What are you actually trying to do and where are you trying to do it".

We all try to jump in with the answers for fellow pilots with a genuine question and then find that the question asked didn't have all the facts in it - nor do so many of the answers.

As you say, each member state has its own interpretations of JARs (the Dutch, for example, say that if you have a Single Engine Instrument Rating, then the transfer to a Multi Engine one is a conversion - and can be done by a local examiner. The UK CAA say it's still an INITIAL and, as such, must be done with a staff examiner (I agree wiutht them, btw)).

[BillieBob]

No rocket, Keygrip. Detail and accuracy are essential when dealing with JARs for the very reason that they are only Requirements and not Regulations. It is when this required accuracy is dismissed as pedanticism, with the implication that it is no more than unnecessary nit-picking that the missiles start flying.

The fact is that individual countries can only implement the Joint Aviation Requirements so far as existing national legislation allows, in this case the Spanish Authority clearly has a problem implementing the requirement for 100hrs PIC for issue of the licence, although whether this is a matter of Spanish law or the competence of the civil servant(s) involved is debateable. It is the same conflict that resulted in the UK CAA approving training outside the JAA, contrary to the requirements of JAR-FCL - UK legal opinion was that to implement the Requirement would have been contrary the provisions of the UK's Aviation Act that bound the UK CAA to approve any organisation that met the stated requirements, wherever it was based. As Keygrip doubtless knows, JAR-FCL still limits overseas training to all or part of the integrated ATPL course, which requirement the UK is still legally bound to ignore (for another year or two, at least).

The panacea to this confusion is, of course, EASA, which will enshrine large parts of JAR-FCL in European law, consequently making it binding on all EU member states. That, at least, is the theory, although history suggests that the whole thing will become mired in the corruption and dishonesty that epitomises the EU and will be routinely ignored by many states, principally, on past form, France, Italy and Spain. It does not bode well that the UK's opinion was largely (totally) ignored during the consultation process. Having eventually found the Comment and Response documentation on the EASA website, (it was in a locked filing cabinet in the basement under a sign that said 'Beware of the Tiger') close study revealed that the UK CAA was not mentioned once as having presented a response to any of the questions raised. The implication is that licensing under EASA will be stitched up by 'old Europe' to its own advantage and the galloping protectionism evidenced by the recent 'bra wars' debacle will be the inevitable result.

Keygrip is quite correct in his observation that accuracy and detail are important when presenting a question on PPRuNe. In a clear majority of cases, questions presented on this forum are all but unanswerable as there are so many possibilities dependant upon experience, qualifications, State of Licence Issue, future intentions, etc. All that the well-intentioned respondent can do is to present the facts from JAR-FCL and hope for the best. However, this is made no easier, as willby points out, when the UK CAA ignores the clearly stated requirements of JAR-FCL for no good reason and publishes blatantly incorrect information in its own document. LASORS - The Definitive Guide? - Horse droppings!

In the absence of any other information, advice and responses to questions on this forum tend to be based on the UK's interpretation of the Requirements on the assumption that most of the questions come from UK-issued licence holders or from others seeking a UK-issued licence. This may be frustrating to those who do not have the UK as the State of Licence Issue but understandable when one considers that the UK approves more training organisations under JAR-FCL than all other member states put together.

[willby]

Keygrip, Billiebob,
Thanks for those comprehensive replies with which I agree wholeheartedly. Hopefully, EASA will eventually bring more cohesion between member states.
Regards
Willby

[mateyboy]

I did the IR first and the CPL afterwards. Therefore I only had to do 15 hours for the CPL. I also had to build hours after passing the CPL, as I was about 5 hours short of 100 hours as PIC. This was in the UK. I had 12 months to do so, and found it no problem. If I were to do it all again though I would do the CPL first and the IR second, and have all the hours ready, so after the tests you can just send off for the licence straight away, and then wait 3 months for the CAA to issue, after ensuring your cheque for hundreds is securily banked.

Regards

[Bubble]

Thanks very much to everybody for your inputs.
I know now the track to follow, and it seems that this matter would be sorted for good within a few days.
;)