Hi DFC,
Yes, I agree that solo flying must either be as student or licensed pilot but that’s not the point at issue here.
The content of difference training is not specified in detail but rather is left to the discretion of the instructor administering the training; I might consider that some solo consolidation is a sensible part of the tailwheel training in my organisation and might want to see a pilot complete, say 5 solo circuits before I sign him up and he goes off in a C170 with three passengers for his first solo wheeler! To send him solo as part of the difference training does not remove the requirement for that training. This line of argument is like saying we would never send students solo because “you can’t be a pilot until you are a pilot”! There is a world of difference between a qualified PPL with SEP rating jumping into a taildragger solo with no training or prior experience and him flying a solo flight under my supervision as part of a structured training programme.
Similarly, the “requirement” for training for a lapsed SEP rating is at the CFIs discretion and I might well decide that some solo practice was beneficial.
Pilots flying solo under these conditions are not training for the grant of a licence as I said before so I don’t see the need for a licensed aerodrome!
3 Point