"Peter" wrote in message
...
Look at 61.109 (Private Pilots, Aeronautical Experience). According to
61.109a2, you need "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". "Training" refers to dual flights, so your night
solo
doesn't count. But any dual cross-country flight of 100nm total distance
does count. There is no straigh-line distance requirement.

I have seen that section, and agree that "training" suggests a dual
flight. But isn't this because the student isn't (at that stage) legal
to fly night x/c solo?

No, a student pilot can legally fly a night x/c solo (with an appropriate
CFI endorsement). In fact, 61.89a6 sets forth a visibility requirement for
student night flights as PIC; and a student pilot can only be PIC if flying
solo. Moreover, 61.129a3iii and iv require x-c "training" (dual) flights as
part of the requirements for a commercial certificate (a prerequisite for
which is a private-pilot certificate); hence, the requirement that they be
training flights is not due to any legal proscription against doing the
flights solo.

--Gary

I have written to the FAA flr a clarification.




Peter.
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