61.315(c)(13) requires sport pilots to maintain "visual reference to the surface." Does that require being able to see the ground directly under the aircraft, or is it sufficient to see the ground elsewhere in the general area?
May be too late, though the interpretation is in regards to student pilots and the reasoning used doesn't seem to carry over very well when applied to sport pilots who presumably should have about the same training in this regard as private pilots: http://www.faa.gov/about/office_org...2008/murphy - (2008) legal interpretation.pdf
"Secondly, you inquire whether a student pilot may operate solo above a scattered or broken cloud layer. You reference the prohibition in 14 C.F.R. § 61.89(a)(7) that a student pilot may not act as PIC when the flight cannot be made with visual reference to the surface.
14 C.F.R. § 61.87 sets forth the requirements that a student pilot must meet prior to operating an aircraft in solo flight. Assuming that the student pilot complies with those requirements for solo flight, section 61.89 sets forth limitations on a student pilot. Section 61.89(a)(7) states, in relevant part, that a student pilot may not act as PIC of an aircraft when the flight cannot be made with visual reference to the surface. 1 This general prohibition against operating in marginal weather conditions is intended to alleviate the problem of student pilots becoming lost or disoriented in those marginal conditions. Operating above a scattered or broken cloud layer could be the sort of marginal conditions that could cause a student pilot to become lost or disoriented. For this reason, section 61.89(a)(7) prohibits a student pilot from acting as PIC above a scattered or broken cloud layer."
The reasoning in that opinion does seem potentially applicable. Please note, however, that my "Amen to that" did not apply to the entirety of his post, only the portion I quoted.
Lazy again; here's a Youtube video on the feature. The icons look a little different but I believe the technique is the same in this version of vBulletin.
A private, commercial, or even airline transport pilot who lets their medical lapse and flies a light sport aircraft under light sport pilot rules may not fly without visual reference to the surface. The exact same people with current medicals may makes such flights. So the rule depends primarily on medical certification, not training or experience.
The rationale cited in the chief counsel opinion letter for student pilots made some dubious claim about getting lost or disoriented that seems to be a post hoc invention. I don't see it applying to the sport pilot limitation for the reasons noted above.
