Hello,
after having talked to a DE and a FSDO I figured out the following.
Solo flight at night is ONLY possible with either a student pilot license and proper endorsements or with a unrestricted US license.
For foreign pilots there are 3 ways if they already hold a based-on PPL:
- surrender the based-on and get a student pilot license (because you can only hold one at a time), get the endorsements and fly night solo. Then get the based-on back and go to the commercial checkride.
- surrender the based-on and get a student pilot license (because you can only hold one at a time), get the endorsements and fly night solo. Then go to a combined checkride for private and commercial (if the examiner is ok with that).
- go to a private checkride and get the normal US license, fly the 5 hours solo at night and go to the commercial checkride.
To make it clear: You can NOT give a private pilot any endorsement that allows him to fly solo at night!
§ 61.87 (o) only applies to student pilots (holding a student pilot license!)
It gets worse if you know that you can endorse a PP to solo an aircraft he is not rated in. This does not apply here, because he IS rated in the aircraft, but not for night flight!!! This is a restriction of his foreign license.