Peter Duniho wrote

"Bob Moore" wrote in message
. 121...
Agreed. But is required training (and in particular, training
required by 61.31(i)) a "rating limitation"?

No...Fist because it can be endorsed by an Authorized Instructor
and second probably because it comes under the second part of the
title of 61.31 which contains three distinct items:
"Section 61.31: Type rating requirements, additional training, and
authorization requirements".

Well, if it's not a "rating limitation", then 61.31(k) doesn't apply.

(k) Exceptions.
(2) The rating limitations of this section do not apply to—
(ii) The holder of a student pilot certificate;

They can't apply since a student pilot certificate contains no ratings,
only training endorsements.

In addition, any 61.31(i)requirement for student pilots is more than
covered by 61.87c and 61.87n

Section 61.87n: Solo requirements for student pilots.

(n) Limitations on student pilots operating an aircraft in solo flight. A
student pilot may not operate an aircraft in solo flight unless that
student pilot has received:

(1) An endorsement from an authorized instructor on his or her student
pilot certificate for the specific make and model aircraft to be flown; and

(2) An endorsement in the student's logbook for the specific make and model
aircraft to be flown by an authorized instructor, who gave the training
within the 90 days preceding the date of the flight.

Bob Moore