Hi DFC,
Sorry but I disagree! Note however that I am talking here about what is within the rules, not necessarily what is sensible or good practice.
The ANO (Art 101 (2)(a)(ii) and (iii) and (2)(b)(iii) (aa)and (bb)) says that a licensed aerodrome must be used for “instruction in flying given to any person for the purpose of becoming qualified for the grant of a pilot’s licence or the inclusion or an aircraft rating, a night rating or a night qualification in a licence” or for flying a test for the same purpose.
A licensed pilot undertaking difference training is not receiving “instruction in flying … for the purpose of becoming qualified for the grant of a pilot’s licence or the inclusion or an aircraft rating, a night rating or a night qualification in a licence”, he is simply doing difference training. Therefore the licensed aerodrome is not required and an FI can send such a person solo from a farmer’s field for solo flying as part of the difference training.
Similarly, a licensed pilot who has let his SEP rating lapse is not training for the grant of a license or rating but for the renewal of his rating so the licensed aerodrome is not required.
The final case of a student who wants to go solo from a non-licensed aerodrome is a bit less clear but even there I think a case can be made that, if the solo hours thus achieved are not part of the 10 hours solo or 45 hours total required for licence issue such a flight would not be “for the purpose of becoming qualified for the grant of a pilot’s licence” so could take place from an unlicensed aerodrome. I’d be pretty reluctant to sign up to this in practice as we really are splitting hairs and getting into the letter rather than the spirit of the rules but the first two examples I’d be quite comfortable with.
I wonder what Beagle or FL think about my reading of the rules!!
3 Point