Banner Towing part FCL
 

Was reading CAP 804 Part 1, Section 4, Part P (Licence Conversions – UK to Part-FCL).

It seems that Banner Towing Privileges exercised on UK National/JAR-FCL
licence issued before 8 April 2018 qualify for grant of the Banner Towing Rating, but the conditions state;

(a) Hold a Part-FCL licence; and
(b) show logbook evidence* of
at least 100 hours of flight time
and 200 take-offs and landings
as PIC on aeroplanes or TMG,
after the issue of the licence. ......

(My bold above)

So the way I read it one must apply for a Part FCL licence, then fly at least 100
and do 200 take-offs and landings as PIC with the new licence before the rating will be placed on it. Is this correct, and does it mean that someone who has been towing for years has to stop for a while as soon as he applies for an EASA licence?

And you are asking a rumour forum instead of the CAA because????