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

"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 he
http://ecfr.gpoaccess.gov/cgi/t/text....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?