It is indeed a valiant effort SM and if it were my decision..........
However......
CAP 804
8.2 STD time is creditable towards courses and licence issue
but is not flight time and must not be recorded as such. STD time must be logged separately from flight time recorded in the log.
EC Regulation 1178/2011 Annex I Appendix 3
EXPERIENCE
12. The applicant for a CPL(A) shall have completed
at least 200 hours flight time, including at least:
So, the EC Reg is specific about a requirement for flight time and equally CAP 804 is quite specific that STD time is NOT flight time. Doh!
You can complete 5 hours of the course on a FNPT II, thereby completing 20 hours on the aircraft but only 20 hours would count as flight time for licence issue.