Is there any prohibition in the regs about a student pilot doing touch and go landings?

This question, along with this one, came into the PIC via a chat:

FAR 61.109(a)(5)(iii) compliance. One of our students did solo with a control tower to meet this requirement. She did one stop and go and one full stop. Tower didn't want her doing more stop and goes, so she ended up with three more landing which were touch and goes. Are we legal to sign her logbook as having completed this section of FAR?

The answer to both questions is no.

Touch and go landings are not prohibited of student pilots anywhere in the regulations. However, when meeting aeronautical experience requirements, touch and go landings are not permitted to be substituted for full stop landings, such as the three required by this regulation at a towered controlled airport.

Although the student performed five takeoffs and landings, only two could be counted towards the three needed. Unfortunately, she has to go back to a towered airport and perform one more full stop landing and takeoff.

Close, of course, does not cut it with the regulations.

The AOPA Pilot Information Center stands ready to assist with any regulatory questions you may have. 800-872-2672 or

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@Daddis At AOPA
For those unfamiliar, 61.109(a) says…

(5) 10 hours of solo flight time in a single-engine airplane, consisting of at least -

(iii) Three takeoffs and three landings to a full stop (with each landing involving a flight in the traffic pattern) at an airport with an operating control tower.

Full stop/taxi-backs are fine, and stop-and-go's are fine (because you do come to a full stop and then go around the pattern again, although three stop and go's in a row on the 15000-foot Shuttle Landing Strip at Cape Canaveral won't cut it), but that language doesn't leave much room for argument that a T&G counts – even if ATC doesn't want to cooperate.