Enforcement of the JAR-FCL
 

JAR-FCL normally requires you to complete all training, for the issue of a certificate, under the supervision of one JAA member state. I was, in accordance with JAR-FCL 1.065(b), allowed an exception from this. Both authorities involved gave me a statement that I was allowed to transfer my exams since my case provided for exceptional circumstances.

I recently required the state where I took the exams to transfer those. They asked why I didn't complete all 14 fixed-wing exams and the answer was that I have no use for all exams for the helicopter "interim arrangement". Hence I have no reason to complete exams like POF(A) and Performance(A).

They strongly disapprove the "interim arrangement" and refused to provide my results for the issuing state in accordance with JAR-FCL 1.485(a);

"Responsibilities of the applicant
An applicant shall take the entire set of examinations in one JAA member state."

This is true but not very reasonable in my case and I can only speculate why they pointed out this paragraph.


The question I need an answer to;

To whom do I, as an applicant, need to fulfil the abovementioned responsibilities? The state where I took the exams, the state issuing my certificate, or both?

If I only need to fulfil the requirements to the issuing state, the other state where I took the exams would not be able to refuse the transfer. This would save me 9 re-takes of exams I already passed. All parties involved got the point that the "interim arrangement" is disliked by some, but do they really need to give an individual applicant extreme inconvenience because of this?

Thank you in advance.