"T o d d P a t t i s t" wrote in message
...
61.31(d) (2) is the catchall for training when a "student"
already has another rating and it "authorizes someone other
than the holder of a Student Pilot certificate to have solo
privileges in an aircraft for which they are not otherwise
qualified (rated, endorsements, etc)?"

Actually, it's 61.31(d)(3), but close enough. For some reason I just
wasn't seeing it. 61.31(d)(2) applies when the pilot is being supervised
while receiving training.

[...]
Note the"or" in the middle. Personally, I think the correct
procedure is to make all the required signoffs before solo.

I'm still not sure. Being shown the regulation that allows solo
endorsements for non-student pilots was helpful, but it still doesn't
address the question about whether the 61.31(i) endorsement is required for
solo in a tailwheel aircraft (for example).

Furthermore, now I'm a bit confused as to why the solo flight
privilege/requirements section in 61.87 is needed, given that 61.31(d)(3)
exists. Not that I've ever held any misconception that the FARs are always
consistent and non-redundant, but still. It seems like a general-purpose
regulation that covers all people, regardless of what pilot certificate they
hold, would be sufficient. And 61.31(d)(3) seems to cover this to some
extent (to be more complete, a one-size-fits-all regulation would carry the
additional training requirements that would not have been covered by
whatever pilot certificate is already held, if any).

Anyway, the bottom line here is that I'm still not seeing the resolution to
the ambiguity about whether the 61.31(i) endorsement is required for solo
flight (by a student pilot or otherwise).

Pete