VFR Cloud Clearances - Gray Area???

Sinistar

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Brad
For this question, lets restrict it to:
  • ASEL
  • Daytime
  • Below 10,000msl
  • Above 1,200agl
  • No SVFR
  • Not within a Bravo, Charlie or Delta airspace.
So 14.CFR.91.155 indicates 500ft below, 1000ft above, 2000ft horizontal.

Can a pilot then fly in the locations A,B,C,D in the diagram?
VFRCloudQuestion.jpg
 
A literal reading suggests the answer is yes. Unless someday we get the advisory circular that decides the answer is no. Now for a fun exercise, contact your local FSDO with the question!


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For this question, lets restrict it to:
  • ASEL
  • Daytime
  • Below 10,000msl
  • Above 1,200agl
  • No SVFR
  • Not within a Bravo, Charlie or Delta airspace.
So 14.CFR.91.155 indicates 500ft below, 1000ft above, 2000ft horizontal.

Can a pilot then fly in the locations A,B,C,D in the diagram?
View attachment 68794
Too much time on your hands?
 
Nah. Write the FAA and ask for the Chief Counsel's opinion, that will clear it up for everyone.

Even better. Does seem a legit grey area.


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A literal reading suggests the answer is yes. Unless someday we get the advisory circular that decides the answer is no. Now for a fun exercise, contact your local FSDO with the question!
Man, I should do that one day over lunch. They already know me :)

What I find weird is that especially in areas C,D descending IFR big guys could be descending at speeds up to 250kts and you could be right by that cloud and be "technically" legal. Stupid - yes. But legal.
 
Man, I should do that one day over lunch. They already know me :)

What I find weird is that especially in areas C,D descending IFR big guys could be descending at speeds up to 250kts and you could be right by that cloud and be "technically" legal. Stupid - yes. But legal.

They will conclude you need to be Y above within the X lateral area and X to the side within the Y vertical area even though the reg doesn’t literally say it. That’s my bet.
 
What if a hypothetical pilot, operating under VFR flight rules wanted to use some go pro video from one of these gray areas.

Wait for a ruling methinks... and in practice it’s hard to actually fly in those areas, clouds are too irregular...


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They will conclude you need to be Y above within the X lateral area and X to the side within the Y vertical area even though the reg doesn’t literally say it. That’s my bet.
I've only been doing this for about a year and half so I have no idea how old the VFR cloud clearances are. Perhaps they are rather old. It would seem if they were written today and intended for those areas to be off limits they might have said: "Remain clear of the volume surrounding a cloud defined by...." and then have each of the various clearances for day, night, class G, Class E, etc.
 
So 14.CFR.91.155 indicates 500ft below, 1000ft above, 2000ft horizontal.
At points A,B,C and D in the picture, you are less than 1000 feet above, less than 2000 feet horizontal and less than 500 feed below. How is that a yes?
 
At points A,B,C and D in the picture, you are less than 1000 feet above, less than 2000 feet horizontal and less than 500 feed below. How is that a yes?

In those regions, there is not a cloud less than 1000' directly below you, there is not a cloud less than 500' directly above you, and there is not a cloud less than 2000' directly beside you.

Technically legal, I suppose, but a bad idea.
 
Sorry, I guess I don
't understand your drawing. The altitudes aside, it looks like your definition of "lateral" only encompasses two directions. Remove the vertical and I see this...
upload_2018-11-5_11-52-1.png
 
For this question, lets restrict it to:
  • ASEL
  • Daytime
  • Below 10,000msl
  • Above 1,200agl
  • No SVFR
  • Not within a Bravo, Charlie or Delta airspace.
So 14.CFR.91.155 indicates 500ft below, 1000ft above, 2000ft horizontal.

Can a pilot then fly in the locations A,B,C,D in the diagram?
View attachment 68794
Then what is the answer?
Why wouldn't the distances be curves around all edges not square?
 
Okay I added a couple key reference points as I guess my diagram was not clear regarding up and down :)

VFRCloudQuestion2.jpg
 
Why wouldn't the distances be curves around all edges not square?
You are right! But as you can tell I already suck at drawing :)

Now given your drawing, how could I ever get within 2000ft horizontally of a cloud to be able to fly under it by 500ft. It doesn't matter if its a cloud shaped like a rectangle or like the much better example you gave. The regs don't seem to mention them all being combined (volume) so technically once you are in a corner area (albient 3D) that area seems to not be covered by the FAR's.
 
In those regions, there is not a cloud less than 1000' directly below you, there is not a cloud less than 500' directly above you, and there is not a cloud less than 2000' directly beside you.

Technically legal, I suppose, but a bad idea.
The reg does not say "distance from clouds directly below" it says "distance from clouds". And if you got your tape measure out then you would find that the distance from where you are at to the cloud is less than 1000 vertically AND less than 2000

untitled.jpg .
A literal reading of the regulations says that's a no-go zone.
 
So I was going to post a "loophole" meme...but I learned a new one today, and just a word of caution: be careful googling the word "loophole"...
 
For this question, lets restrict it to:
  • ASEL
  • Daytime
  • Below 10,000msl
  • Above 1,200agl
  • No SVFR
  • Not within a Bravo, Charlie or Delta airspace.
So 14.CFR.91.155 indicates 500ft below, 1000ft above, 2000ft horizontal.

Can a pilot then fly in the locations A,B,C,D in the diagram?
View attachment 68794
In my opinion, I would say "no". The "500 below, 1000 above, 2000 feet horizontal" defines a cylinder with a "cloud shaped hole" drilled through the center of it. All the airspace contained within the body of the cylinder surrounding the cloud is verboten under VFR.
 
Even though a cloud is not a uniform geometric shape, it is better to view the no go area as a single three dimensional cylinder than four two dimensional squares.
 
1. Unless you're flying with a measuring tape, this is ALL academic.
2. How comfortable are you next to that cloud knowing there's a possibility something may pop out of it, straight at you, head on, doing 200 knots?

As far as videos and picture posting: I've had a few videos that were WELL clear of clouds that look worse during review and the opposite as well. Most of my stuff gets recorded with the phone.
 
Draw the buffer zone around the airplane, instead of around the cloud, and it should be easier to visualize.
 
Because that would mean applying logic and good sense to the regulations, and I'm pretty sure that sort of thing is prohibited.
I thought that would be applying logic and good sense to reading the regulations.
 
PhBsuV8.jpg
 
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