Thank you for the query - as CFI of both a CPL school and a RAAus school I was pretty confident of my ground. I have revisited the regs and I am still confident - although somewhat less so!
5.104 (1) (f) (ii): A CPL holder must have the experience described in 5.111 or (snip) 5.115
5.111 - a "150 hour" CPL must be flown in a registered aircraft (ie: VH-)
5.115 - must have 100 hours PIC,
and 100 hours in a registered (VH-) or recognised (ie: military) aeroplane.
This is where the ambiguity comes in: subregulation 5.115 (4) stipulates that additional flight time to make up the total 200 hours must be flown in:
(a) a registered (VH-) aeroplane;
(b) a recognised (mil) aeroplane;
(c) a Helicopter;
(d) a gyroplane; or
(e) a glider (other than a hang glider).
Although Reg (2) stipulates what RAAus "recognised flight time" is, Reg 5.115 (4) does not list recognised RAAus flight time as an option.
Para (1) (b), (c) and (d) all make explicit reference to a recognised or registered aeroplane, while (1)(a) does not. 5.115(3) and (4) stipulate just about anything
except an RAAus aircraft.
Having accrued the experience in (1)b/c/d you then need to make up the 200 hours in a VH aircraft. Are you suggesting that, having accrued 100 hours of RAAus experience
before your CPL training you can avoid that requirement, but cannot accrue 100 hours of RAAus time to satisfy that
after you satisfy 5.115(1)?
I am not saying you are wrong, nor that I am right -but I think my interpretation is more consistent than yours.
Cheers
