Re: FAA PPL night flight requirement - does it have to be DUAL?

[Gary G]

This might be nitpicky, but nothing in the AIM is a
"requirement". Technically the AIM is not the law,
the FAR is.
Nonetheless, the AIM is incredibly important - I know.
It seems subtle, doesn't it?

[Peter Clark]

On Wed, 13 Oct 2004 13:11:00 +0100, Peter >
wrote:

>
>Reading FAR/AIM 2004 it isn't entirely clear to me because different
>sections refer to day and night cross country, and I don't think the
>description of a day cross country applies to the night flight; the
>distances are 150nm and 100nm respectively.
>
>I have night flights with an instructor which exceed 100 miles in
>total distance, and I have a solo night flight which exceeds 100nm
>which was done between two airports whose direct line spacing is
>119nm.
>
>I suspect that the information on the basis of which I did the last
>flight was bogus and I don't meet the FAA PPL requirement.
>
>Can anyone suggest the FAR/AIM 2004 sections which could clarify this?

You want the FAR, 61.109(a), paragraphs 2 and 2(i) - "Except as
provided in 61.110 of this part, 3 hours of night flight training in a
single-engine airplane that includes (i) One cross country flight of
over 100 nautical miles total distance; and (ii) 10 takeoffs and 10
landings to a full stop (with each landing involving a flight in the
traffic pattern) at an airport."

You meet the night cross country requirement with either flight listed
above. There's no requirement for a solo night cross country of any
distance in the regs. If you've done 10 night takeoffs and landings
you meet the requirements for that part of the reg.

The long solo cross-country (150nm) is 61.109(a)(5)(ii) - 150nm, 3
stops, one segment of which needs to be between 2 airports 50NM apart.
If you happened to do this at night, great - the reg doesn't say it
has to be done during the day, but the solo flight mentioned above
doesn't count unless it was over 150NM (the 119NM apart meets the 50NM
distance, but not the total flight distance and 3 landings).

Luck,
P

[Peter Duniho]

"Peter" > wrote in message
...
>>You meet the night cross country requirement with either flight listed
>>above. There's no requirement for a solo night cross country of any
>>distance in the regs. If you've done 10 night takeoffs and landings
>>you meet the requirements for that part of the reg.
>
> My reading of the first paragraph above is that *both* (i) and (ii)
> are required, and the word "night" does apply to both (i) and (ii).

Yes, it does. I assume that Peter Clark was not implying that the XC flight
required by 61.109(2)(i) is not required to be done at night; rather, I read
his statement to (correctly) mean that there's no *SOLO* night XC
requirement. The only night XC requirement specifically requires an
instructor to be on board.

> I have 11 takeoffs after Civil Twilight, and 21 landings after Civil
> Twilight, so (ii) should be satisfied.

Yup.

> I now have (i) also but after advice from some people who should know
> I did it solo.

There was no requirement to do so. The flight you did solo doesn't do
anything to help you meet any of 61.109. However, from your original post,
it appears that you already had the necessary dual flight required by
61.109(2)(i), so you're fine in that respect.

> It is possible that the words "night flight TRAINING" (my emphasis)
> refer to dual flying because in practice that is what the student will
> have to do; at that stage he won't be legal to do it solo.

The student is legal to do it solo if his instructor signs him off to do so.
I hope that you had the necessary instructor endorsement before you made
your 119NM (239NM? you never said whether it was one-way or round-trip)
flight.

As far as what "night flight training" means, it means exactly what it would
seem to mean to someone NOT trying to read between the lines. It's a night
flight during which training is taking place; that is, an instructor is on
board and giving training.

It means that because the FAA wants an instructor on board, not because the
pilot would not otherwise be qualified to make the flight (since, after all,
it's possible the student pilot would be qualified to make the flight
without the instructor).

> In my case, I have some 400 hours, lots of IFR/IMC time (on a UK
> license), and the UK night rating, so can fly at night solo or even
> IFR in IMC.

In a UK-registered aircraft and/or in the UK, of course. AFAIK, the UK
license doesn't make you legal in the US, flying a US-registered aircraft.
It's not clear from any of your posts which certificate (the UK license or
the US student pilot certificate) you're using as the basis for legality for
the various flights you're making, or where those flights were made.

> I have heard of people who did their >100nm night flight solo.

There are no such people. The regulation clearly requires an instructor to
be on board in order to meet the requirements given.

Perhaps you have, instead, heard of people who did *A* 100NM night flight
solo? With the appropriate instructor endorsement (or other qualifying
circumstances), that would be permissible, though would not help the pilot
achieve the requirements given in 61.109(2).

> Are you saying that Americans are able to get an FAA PPL without doing
> 10 *night* takeoffs and landings and without flying 100nm fully at
> night?

Anyone, American or not, can get an FAA Private Pilot Certificate without
doing those. However, they will have a "no night flying" restriction on
their certificate.

The rest of us had to do the required night training, as clearly described
in the regulations.

Pete

[Peter Clark]

On Wed, 13 Oct 2004 19:39:48 +0100, Peter >
wrote:

>
>Peter Clark > wrote
>
>>You want the FAR, 61.109(a), paragraphs 2 and 2(i) - "Except as
>>provided in 61.110 of this part, 3 hours of night flight training in a
>>single-engine airplane that includes (i) One cross country flight of
>>over 100 nautical miles total distance; and (ii) 10 takeoffs and 10
>>landings to a full stop (with each landing involving a flight in the
>>traffic pattern) at an airport."
>>
>>You meet the night cross country requirement with either flight listed
>>above. There's no requirement for a solo night cross country of any
>>distance in the regs. If you've done 10 night takeoffs and landings
>>you meet the requirements for that part of the reg.
>
>My reading of the first paragraph above is that *both* (i) and (ii)
>are required, and the word "night" does apply to both (i) and (ii).
>
>I have 11 takeoffs after Civil Twilight, and 21 landings after Civil
>Twilight, so (ii) should be satisfied.
>
>I now have (i) also but after advice from some people who should know
>I did it solo.
>
>It is possible that the words "night flight TRAINING" (my emphasis)
>refer to dual flying because in practice that is what the student will
>have to do; at that stage he won't be legal to do it solo.

Unless properly endorsed for night solo, correct, it won't be done
solo. I'm confused on your statement that "people who should know"
told you to do the night cross country solo to meet a US requirement
that doesn't call for it to be solo. Generally you get 3+ hours of
dual given at night time which includes the solo.

>In my case, I have some 400 hours, lots of IFR/IMC time (on a UK
>license), and the UK night rating, so can fly at night solo or even
>IFR in IMC.
>
>I have heard of people who did their >100nm night flight solo.
>
>Are you saying that Americans are able to get an FAA PPL without doing
>10 *night* takeoffs and landings and without flying 100nm fully at
>night?

Um, I think I said:

>>You meet the night cross country requirement with either flight listed
>>above. There's no requirement for a solo night cross country of any
>>distance in the regs. If you've done 10 night takeoffs and landings
>>you meet the requirements for that part of the reg.

meaning that the reg doesn't say the cross country has to be solo, and
because of that the dual cross country of over 100NM you mentioned in
the original post meets the requirements of 61.109(2)(a)(i). Anything
else is gravy. Then I continued to say that if you have the 10 to/l
after night you meet 61.109(2)(a)(ii). Perhaps I should have said
"you meet the night cross country requirement with either of the
flights you said you logged above" to be more clear as to what I was
referring to when I said "flight listed above"?

And technically, yes, if you're in Alaska there's a special exemption
in 61.110 from having to do the night work, but you get a "daylight
only" PPL which you can go back later and add night to once you get
the hours done. It would have been useful when I was trying to do the
night work back in July and night started at 9:30 or later, but I
digress :) Everyone else has to have night work.

[Peter Clark]

On Wed, 13 Oct 2004 13:58:27 -0700, "Peter Duniho"
> wrote:

>"Peter" > wrote in message
...
>>>You meet the night cross country requirement with either flight listed
>>>above. There's no requirement for a solo night cross country of any
>>>distance in the regs. If you've done 10 night takeoffs and landings
>>>you meet the requirements for that part of the reg.
>>
>> My reading of the first paragraph above is that *both* (i) and (ii)
>> are required, and the word "night" does apply to both (i) and (ii).
>
>Yes, it does. I assume that Peter Clark was not implying that the XC flight
>required by 61.109(2)(i) is not required to be done at night; rather, I read
>his statement to (correctly) mean that there's no *SOLO* night XC
>requirement. The only night XC requirement specifically requires an
>instructor to be on board.

Yep, I stand corrected in that the 3 hours night training "that
includes" would mandate the cross country be part of that 3 hours and
thus logged as dual received wouldn't it. So the extra solo night
cross country wouldn't be useful for anything under this part.

>In a UK-registered aircraft and/or in the UK, of course. AFAIK, the UK
>license doesn't make you legal in the US, flying a US-registered aircraft.
>It's not clear from any of your posts which certificate (the UK license or
>the US student pilot certificate) you're using as the basis for legality for
>the various flights you're making, or where those flights were made.

If it is a standard UK certificate, wouldn't his easier path be
getting a US PPL based on foreign cert, a-la 61.75?

>Anyone, American or not, can get an FAA Private Pilot Certificate without
>doing those. However, they will have a "no night flying" restriction on
>their certificate.

Actually, I believe you might be mistaken on this one - the only night
exemption is I can see is 61.110 which appears to apply to Alaska
only.

[Peter Duniho]

"Peter Clark" > wrote in message
...
> [...]
> If it is a standard UK certificate, wouldn't his easier path be
> getting a US PPL based on foreign cert, a-la 61.75?

You'd think. But each pilot has their own circumstance. I'll take it as
granted that if a pilot feels it's easier to go through the "long form"
certification process than to convert a UK certificate, then it is. :)

Or perhaps in spite of all that aeronautical experience, he doesn't actually
hold a convertable certificate. I don't know.

> Actually, I believe you might be mistaken on this one - the only night
> exemption is I can see is 61.110 which appears to apply to Alaska
> only.

Hmmm...interesting. Either my memory is too fuzzy, or this is yet another
example of a subtle change that occurred in 1997 (if I even have the year
correct), and which I've failed to note. They appear to have kept in the
general (non-Alaska) exception for gyroplanes, powered parachutes, and
weight-shift-control aircraft.

I could swear that, at least at some point in my past, they permitted
general "no night flying" certificates, even for pilots outside of Alaska.

Of course, the main point is that to be allowed to fly at night, all holders
of an FAA certificate obtained through the usual process must meet the night
training requirements.

Pete

[Bob Martin]

> Hmmm...interesting. Either my memory is too fuzzy, or this is yet
another
> example of a subtle change that occurred in 1997 (if I even have the year
> correct), and which I've failed to note. They appear to have kept in the
> general (non-Alaska) exception for gyroplanes, powered parachutes, and
> weight-shift-control aircraft.
>
> I could swear that, at least at some point in my past, they permitted
> general "no night flying" certificates, even for pilots outside of Alaska.

You're correct... but they closed that. Now, you can only get the
exception living in Alaska, but I _think_ you have to go back and do the
night stuff within six months or something like that. I had to do the
night training (which led to a last-minute hop the night before my
checkride to get the rest of the landings in) but it was all done with
an instructor (the XC is a story for a different time...). I think they
closed the exemption because too many people were trying to cheat the
restriction and were having accidents (read: got themselves killed) so
they figured it was better to make everyone do it even if they aren't
going to use it again. Now, we can debate the intelligence of VFR XC's
at night in single-engined airplanes for a long time to come...
personally, I don't fly more than a few miles from my home area (where I
can reconginze the landscape and airports, and can orient just by seeing
Atlanta on the horizon) at night, and even then I won't go without a
working, lighted GPS.

[C J Campbell]

"Peter" > wrote in message
...
>
> Reading FAR/AIM 2004 it isn't entirely clear to me because different
> sections refer to day and night cross country, and I don't think the
> description of a day cross country applies to the night flight; the
> distances are 150nm and 100nm respectively.
>
> I have night flights with an instructor which exceed 100 miles in
> total distance, and I have a solo night flight which exceeds 100nm
> which was done between two airports whose direct line spacing is
> 119nm.
>
> I suspect that the information on the basis of which I did the last
> flight was bogus and I don't meet the FAA PPL requirement.
>
> Can anyone suggest the FAR/AIM 2004 sections which could clarify this?

The solo night flight counts only if your instructor has conducted the
required training for student solo night flight required by FAR 61.87(o) and
specifically endorsed your logbook for student solo night flight; otherwise
the flight was illegal and cannot be used for meeting any aeronautical
experience requirements. FAR 61.109(a)(2)(i) says that your night training
must include a night cross country of 100 miles total distance. Since this
is training, not solo, your instructor must go with you.

You must also have a solo cross country flight of 150 miles total distance,
with three full stop landings and one segment between stops at least 50
miles long, per FAR 61.109(a)(5)(ii). This flight could be conducted at
night if your instructor has signed you off for solo night flight, but few
instructors will allow that and most students do the flight during the day.

[Peter Duniho]

"Peter" > wrote in message
...
> [...]
> Incidentally, assuming that I have to re-do the flight with an
> instructor, is it ok (for the purpose of the "night x/c training" in
> 61.109) to fly to an airport 58 miles away, land, stop on the runway,
> and without getting out of the aircraft takeoff again and go back? I
> can't see a requirement in FAR/AIM 2004 for landing, taxiing to the
> apron, getting out, etc.

There is none. You may deal with the particulars of the flight however you
see fit. You can fly there, land and come back (you don't even need to make
a full-stop landing, unless you want that for the purpose of meeting the
other areas of night currency/experience). You can fly there, land, park,
grab a bite from the vending machine. You can fly there, land, park, sleep
overnight, sightsee all day, fly back at night. Whatever you want to do, as
long as you meet the "100NM at night" requirement.

Pete

[Peter Duniho]

"Peter" > wrote in message
...
> OK, I omitted to mention what I mention in another reply: this was
> done in the UK, where my UK license and G-reg aircraft entitle me to
> fly at night (I have had the JAA night training) and also IFR. So the
> night flight was legal.

It was legal for you to make. That doesn't mean it meets the requirements
of the regulation.

> From what you say above, if I am allowed to do it solo (which I am)

No, you are not. As has been stated several times in this thread, "flight
training" means that you are required to have an instructor with you.

> then the night flight should count.

No, it shouldn't and doesn't. Not the solo night flight.

> Precisely this is the feedback I
> have received from a few people who are now doing their FAA CFII
> training.

They are mistaken.

>>FAR 61.109(a)(2)(i) says that your night training
>>must include a night cross country of 100 miles total distance. Since this
>>is training, not solo, your instructor must go with you.
>
> But is that true if the pilot is already legal to fly it solo?

Yes, it is still true, even if you are legal to fly it solo.

Pete

[Bob Martin]

> You must also have a solo cross country flight of 150 miles total
distance,
> with three full stop landings and one segment between stops at least 50
> miles long, per FAR 61.109(a)(5)(ii). This flight could be conducted at
> night if your instructor has signed you off for solo night flight, but few
> instructors will allow that and most students do the flight during the day


The XC landings need to be full stop? Oops...

[Gary Drescher]

"Bob Martin" > wrote in message
...
> > You must also have a solo cross country flight of 150 miles total
> distance,
>> with three full stop landings and one segment between stops at least 50
>> miles long, per FAR 61.109(a)(5)(ii). This flight could be conducted at
>> night if your instructor has signed you off for solo night flight, but
>> few
>> instructors will allow that and most students do the flight during the
>> day
>
> The XC landings need to be full stop? Oops...

I almost got that wrong too during my primary training. I made one stop for
fuel, but at the second airport I'd planned to do a touch and go (as I'd
done on my training XCs and my two practice solo XCs). I hadn't reviewed the
appropriate regulation, and my instructor didn't catch the problem either
during the pre-flight briefing. Luckily, for some reason, the tower was only
able to accommodate full-stop landings at the time.

--Gary

[Bob Martin]

> I almost got that wrong too during my primary training. I made one stop for
> fuel, but at the second airport I'd planned to do a touch and go (as I'd
> done on my training XCs and my two practice solo XCs). I hadn't reviewed the
> appropriate regulation, and my instructor didn't catch the problem either
> during the pre-flight briefing. Luckily, for some reason, the tower was only
> able to accommodate full-stop landings at the time.

Well, mine was two and a half years ago... don't think it really matters
anymore. And come to think of it, I never made a full-stop at a towered
field either... so I don't know how to talk to ground (and haven't flown
out of/landed at a towered field since the long XC in my training).

[John Galban]

Bob Martin > wrote in message >...
>
> Well, mine was two and a half years ago... don't think it really matters
> anymore. And come to think of it, I never made a full-stop at a towered
> field either... so I don't know how to talk to ground (and haven't flown
> out of/landed at a towered field since the long XC in my training).

I can see how you could get by with a T & G on the cross-country,
depending on how you logged it. In fact, full stop landings on the
long XC have not always been required. When I did mine in '88, I did
a T&G at one airport. Back then, the reg only required that you
"land" at the other airports. I can't remember when it changed.

I am surprised that you made it past the DE without 3 full-stop
landings at a towered field. It's a clear requirement and they
usually check those off on a checklist while going through your
logbook.

John Galban=====>N4BQ (PA28-180)

[Bob Martin]

John Galban wrote:
> Bob Martin > wrote in message >...
>
>>Well, mine was two and a half years ago... don't think it really matters
>>anymore. And come to think of it, I never made a full-stop at a towered
>>field either... so I don't know how to talk to ground (and haven't flown
>>out of/landed at a towered field since the long XC in my training).
>
> I am surprised that you made it past the DE without 3 full-stop
> landings at a towered field. It's a clear requirement and they
> usually check those off on a checklist while going through your
> logbook.

Well, I didn't mark t&g any differently than full-stop in the logbook...
so he saw enough landings at the field, and probably figured they were
full-stop (and had more important things to worry about than to ask).

[Paul Sengupta]

"Peter" > wrote in message
...
> So my night flying was legal, in fact it was done fully IFR, mostly in
> IMC, because I can do that in the UK outside Class A with my night
> rating and IMC rating.

Didn't you do a suitable cross-country for your night rating?

Paul

[Chris]

"Peter" > wrote in message
...
>
> "Paul Sengupta" > wrote
>
>>> So my night flying was legal, in fact it was done fully IFR, mostly in
>>> IMC, because I can do that in the UK outside Class A with my night
>>> rating and IMC rating.
>>
>>Didn't you do a suitable cross-country for your night rating?
>
> Not quite; the FAA night x/c needs to be 100nm total and can be either
> A-B-A (where A-B is >50nm in a straight line) or A-B (where A-B is
>>100nm in a straight line).
>
> I did do well over 100nm (dual) but not between suitably distant
> separate locations.
>
> It also needs 10 takeoffs and full stop landings all done during
> official night (called Civil Twilight in the USA). I think for the NR
> one needs just 5.
>
> Not many UK PPLs with the night rating will have done that particular
> combination as there is no need for it.
>
> I know for a fact that some US-based flying schools have accepted a
> *solo* night x/c flight, but due to lack of time to do this in the USA
> I am following the much more complicated and expensive UK based route
> and the few "methods" of doing it here won't accept this :)
>
> The establishment also refuses to accept any of my current 25 dual
> instrument hours towards the FAA IR 15-hr dual requirement (which any
> of the schools in Florida accepts OK) but that's another story...
>
>
> Peter.

As I have said before my training for the night qualification done in Naples
ensured that I did the necessary take offs and landing and cross country to
meet the US requirements but also included the 5 solo take offs and landings
required for the night qualification. Total time was 6.5 hrs.

As far as the instrument time is concerned, get another training
organisation if you can. The IMC rating training time is allowable towards
the training requirement for the FAA/IR. The school is trying to stiff you
for additional time. In theory you only need three more hours of training
being signed off by a FAA CFII. The rest of the instrument time can be done
with another PPL acting as your safety pilot whilst you practice approaches
etc.

The one thing IMC rated pilots seems to excel at despite the limited
training we have to do is partial panel flying. My US instructor remarked to
me that all his British IMC rated students were far better than average on
partial panel.
Mind you, most of my 15 hours was done on PP anyway.
FWIW, the training done for the IMC renewal was also accepted. At the end of
the day, I went to the US with 30 hours on instruments, over half being
training for the IMC and the renewals, flew another 25 hours in simulated
and actual IMC and passed the checkride.
The DPE checked all the numbers with me and he was entirely satisfied.

[Chris]

"Peter" > wrote in message
...
>
> Peter Clark > wrote
>
>>>Reading FAR/AIM 2004 it isn't entirely clear to me because different
>>>sections refer to day and night cross country, and I don't think the
>>>description of a day cross country applies to the night flight; the
>>>distances are 150nm and 100nm respectively.
>>>
>>>I have night flights with an instructor which exceed 100 miles in
>>>total distance, and I have a solo night flight which exceeds 100nm
>>>which was done between two airports whose direct line spacing is
>>>119nm.
>>>
>>>I suspect that the information on the basis of which I did the last
>>>flight was bogus and I don't meet the FAA PPL requirement.
>>>
>>>Can anyone suggest the FAR/AIM 2004 sections which could clarify this?
>>
>>You want the FAR, 61.109(a), paragraphs 2 and 2(i) - "Except as
>>provided in 61.110 of this part, 3 hours of night flight training in a
>>single-engine airplane that includes (i) One cross country flight of
>>over 100 nautical miles total distance; and (ii) 10 takeoffs and 10
>>landings to a full stop (with each landing involving a flight in the
>>traffic pattern) at an airport."
>>
>>You meet the night cross country requirement with either flight listed
>>above. There's no requirement for a solo night cross country of any
>>distance in the regs. If you've done 10 night takeoffs and landings
>>you meet the requirements for that part of the reg.
>>
>>The long solo cross-country (150nm) is 61.109(a)(5)(ii) - 150nm, 3
>>stops, one segment of which needs to be between 2 airports 50NM apart.
>>If you happened to do this at night, great - the reg doesn't say it
>>has to be done during the day, but the solo flight mentioned above
>>doesn't count unless it was over 150NM (the 119NM apart meets the 50NM
>>distance, but not the total flight distance and 3 landings).
>
> This generated quite a long thread, with a lot of people saying that
> "training" implies a flight with an instructor present.
>
> I wrote to the FAA with a full disclosure of my logbook entries. After
> a few months, they wrote back saying:
>
>>Response (Joel Wilcox) - 01/04/2005 01:20 PM
>>It appears that you meet the night experience requirements. However, you
>>should review these times against the night experience requirements in 14
>>CFR 61.109(a)(2), which can be viewed here:
>>http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=0b4bb79838a2667c2795f58b98a73b25&rgn=div5&view=text&node=14:2.0.1.1.2&idno=14
>>
>>Regards,
>>
>>JW
>
> So, either they did read my question and are saying that doing the
> night flights solo was OK after all, OR they haven't read my
> question...
>
> It doesn't matter now, but I think one should get a better response
> time from the FAA.
>
>
> Peter.

You have been over the ground on this one a few times Peter on this NG and
the Flyer forum. You will not get a better response from the FAA. The
responses that count are from FAA Counsel (the lawyers). You can ask 5
different FSDOs the same question and get five different answers/opinions.

So what's new? Ever had a straight answer from the CAA?

[Gord Beaman]

"Chris" > wrote:

>
>So what's new? Ever had a straight answer from the CAA?
>

Christ!...finally someone who knows the English Language...so
many supposedly 'English Speaking' people say "So what else is
new?" (in abject error of course)
--

-Gord.
(use gordon in email)

[Chris]

"Gord Beaman" > wrote in message
...
> "Chris" > wrote:
>
>>
>>So what's new? Ever had a straight answer from the CAA?
>>
>
> Christ!...finally someone who knows the English Language...so
> many supposedly 'English Speaking' people say "So what else is
> new?" (in abject error of course)
> --
>
> -Gord.

It helps being English

[Gord Beaman]

"Chris" > wrote:

>
>"Gord Beaman" > wrote in message
...
>> "Chris" > wrote:
>>
>>>
>>>So what's new? Ever had a straight answer from the CAA?
>>>
>>
>> Christ!...finally someone who knows the English Language...so
>> many supposedly 'English Speaking' people say "So what else is
>> new?" (in abject error of course)
>> --
>>
>> -Gord.
>
>It helps being English
>
I don't know about that Chris...a helluva lot of English people
say it incorrectly...it's my pet peeve...that and confusing 'luck
out/luck in' or "Take a shovel with you when you come" or "Bring
some beer when you go to the beach" etc...
--

-Gord.
(use gordon in email)