Should include NVFR in my opinion. As someone with 30years flying experiance I have to say VFR is VFR whether it be day or night.Most private pilots do few night hours in a year compared to day so the risk is low anyway, plus even fewer nights are real moonless black nights. In fact as far as navigation goes night flying can often be easier than day. eg at 4000ft Adelaide or any large centre for that matter, can be seen from 100miles away,such as Port Pirie as the city lights glow as a beacon. No way you see it in daylight however. Seems to me CASA are overly regulating private flying for no real safety benefit. Bit like saying you can't drive a car at night on roads with no street lighting unless you hold a heavy vehicle license.