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Can a student pilot fly above clouds?

VFR over-the-top

VFR over-the-top (OTT) refers to flying over top of clouds in visual flight, rather than with reference to instruments. This is usually done for brief amount of time to avoid weather or turbulence. [1]

Regulations [ edit ]

Each nation has specific and often different rules that govern when a pilot is permitted to fly VFR OTT. Most countries have requirements that specify weather minima, aircraft equipment and pilot qualifications. [1]

In some countries pilots are required to get an air traffic control (ATC) clearance, or in absence of a controller, advise the nearest flight service station or center.

Pilots are required to adhere to VFR minima when climbing and descending over the clouds. Flight in cloud is not permitted. [1]

National differences [ edit ]

The rules for flying VFR OTT vary greatly from country to country. Some rules, such as those contained in the US Federal Aviation Regulations, are less restrictive. [2] Others, such as the Canadian VFR OTT regulations contained in the Canadian Aviation Regulations, have more regulations to comply with. [1]

United States [ edit ]

The US rules require the aircraft to be fitted with the instruments required for IFR flight, [3] and student pilots [4] and sport pilots [5] must maintain visual reference with the surface. Other operations (such as commercial, turbine powered, and fractional ownership) include special limitations. (Note that 14 CFR 91.507 applies only to fractional operations; see 91.501.)

Canada [ edit ]

The Canadian rules specify that an aircraft may be operated in VFR OTT flight during the cruise portion of the flight during the day, at a vertical distance from clouds of at least 1000 feet. When the aircraft is operated between two cloud layers, the vertical distance between the layers must be at least 5000 feet. The flight visibility at the cruising altitude of the aircraft must be at least 5 miles and the weather at the destination aerodrome must be forecast to have a sky condition of scattered cloud or better, a ground visibility of 5 miles or greater with no forecast of precipitation, fog, thunderstorm or blowing snow, and that these conditions must be forecast to exist for one hour before to two hours after the estimated time of arrival when a terminal aerodrome forecast (TAF) is available or from one hour before to three hours after the estimated time of arrival if a TAF is not available. [1]

The VFR OTT rating requires ground training and a minimum of 15 hours of instrument training, 5 of those can be in a simulator. Commercial pilots automatically receive the OTT rating. [ citation needed ]

Germany [ edit ]

In Germany VFR OTT (Flüge nach Sichtflugregeln über Wolkendecken) is allowed and regulated in §32 LuftVO. [6] The requirements are:

  1. minimum height of 1,000 ft (305 m) above ground or water, minimum weather requirements for airspace E met
  2. pilot is capable of keeping the planned course
  3. approach and landing at destination in visual meteorological conditions (VMC)
  4. pilot possesses radiotelephony license

Additionally the aircraft must be equipped with a VOR receiver or basic RNAV equipment. [7]

See also [ edit ]

References [ edit ]

  1. ^ abcde Transport Canada (May 2010). «Aeronautical Information Manual RAC 2.7.4 VFR Over-the-Top». Archived from the original on 18 February 2011 . Retrieved 8 November 2010 .
  2. ^
  3. Davisson, Budd (July 2001). «Over The Top: The Pros And Cons of Flying VFR Above The Clouds». AOPA . Retrieved 15 August 2013 .
  4. ^
  5. Federal Aviation Administration (9 February 2022). «§ 91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements». Archived from the original on 2 February 2022 . Retrieved 11 February 2022 .
  6. ^
  7. «Sec. 61.89: General Limitations». Federal Aviation Regulations. Federal Aviation Administration . Retrieved 23 November 2014 .
  8. ^
  9. «Sec. 61.315: What are the privileges and limits of my sport pilot certificate?». Federal Aviation Regulations. Federal Aviation Administration . Retrieved 23 November 2014 .
  10. ^§ 32 Flüge nach Sichtflugregeln über Wolkendecken
  11. ^§ 4 air traffic control equipment for operations under visual flight rules

External links [ edit ]

  • Canadian VFR OTT rules – CAR 602.116
  • US FAA VFR rules – FAR 91.155
  • German VFR OTT Rules – §32 LuftVO


The Average lifetime of traditional clouds that do not lead to a thunderstorm is 15-20 minutes and it ends as either fallen precipitation (rain) or evaporation into a higher level to form another cloud.

Clouds can be sorted by height or characteristics and behavior and but during flight training, student pilots are required to learn clouds sorted by first the specific air and precipitation characteristics then the height in which each type of cloud exists and that is what will be discussed in this article.

Cloud Classification

Cloud ClassificationState of StabilityComposition
CirriformUnstable/StableIce crystals only
CumuliformUnstableWater droplets and/or ice crystals
StratiformStableWater droplets and/or ice crystals

Layer clouds

These clouds form in stable air and can be further subdivided into categories according to the height bands in which they are found. Hence there are three further subcategories as follows:

Low level clouds (surface to 6500ft)Medium level clouds (6500 ft to 23,000ft)High level clouds(16,500ft to 45,000ft)

Notice that the medium level and the high level bands overlap. This happens because in the summer the medium level clouds can extend up to 23,000 feet, and in the winter the high level clouds can come as low as 16,500 feet.

Clouds of Great Vertical Extension

These form in unstable air and air not restricted to a particular height band like the layer clouds.

CumulusSurface to 25,000 ft
CumulonimbusSurface to tropopause
NimbostratusSurface to 15,000 ft

A nimbostratus cloud can be a low cloud or a cloud with vertical extension because when there is strong lifting, nimbostratus can behave like a heap cloud and extend through several height bands

Cumulonimbus clouds are the most dangerous types of clouds, extending from the surface to the tropopause which makes it hard for most pilots to clear the clouds by climbing on top of the cloud. This type of cloud is associated with thunderstorms and hailstorms. During a thunderstorm, a downdraught of more than 8,000 feet can be experienced which in the past has led to several aircraft accidents.

Figure 01 summarizes the different types of clouds and the height they are usually found at along with an accurate illustration of what they look like in general.

VFR over the top: legal, but not clever

VFR on top

This is very likely my all time favorite expression about aviation regulations. And although there are many situations where I find it suitable, today I want to bring some where I don’t, but I know many do.

These quarantine days I was publishing some stories on my Instagram account over the differences of rules between FAA (where I learned to fly) and the Brazilian ANAC (where most of my compatriots did). And one very significant difference is about VFR flight over the clouds. Well, as most of you under the FARs are aware—not to say used to—in the United States it is perfectly legal to fly VFR without any visual contact with the ground. As long as you maintain the minimum VFR requirements regarding visibility and cloud clearances, you are good to go—all you need is a natural horizon. (This is not the same as “VFR-on-top,” which is actually a type of IFR clearance.)

VFR on top

You can’t see the ground, but GPS makes it easy to know where you are.

No rocket science here: you will be obviously navigating in an IFR fashion. If using Victor Airways or VORs in general was already good enough, with ATC vectors and GPS it’s a walk in the park to know precisely your position at any given time. The dead reckoning days are—for good—gone.

It’s been said that most of a pilot’s job is risk assessment. Yes, we love the idea of fighting the controls, rudder inputs, precise throttle movements, and smooth touchdowns. But no one can nail those long enough if they aren’t capable of working out the complex and not always obvious idiosyncrasies of the three elements in any aircraft accident report: the man, the environment, and the machine. In order to do so, you must be both equipped with knowledge and proficiency. With legal boundaries and equipment. With regulations and training. Let’s put all this in perspective in a scenario-based way.

Let’s say you rented an IFR-capable Cessna 172 on a sunny morning and flew two hundred miles north to have lunch in charming Hilton Head, South Carolina, at the extreme tip of the Jacksonville VFR Sectional. Now you’ve got to get back to DeLand, in central Florida, but a nasty fog came from the sea and covered most of the landscape. Both HXD and DED are still well within VFR requirements, but along the way, on nice alternates like Saint Simon’s or Jacksonville, the ceilings are already around a thousand feet. Would it be legal to go? Sure. Would it be clever? Let’s take a deeper look.

In many countries, you can’t fly VFR without reference to the ground. This is applicable even to sport, recreational, and student pilots in America, but usually after you are a private pilot you can. But what if you need to land? Well, as my personal minimums I never actually flew VFR over the clouds until I had an instrument rating and was on an aircraft certified for it. But that’s me. It wouldn’t be illegal to do it being only a private pilot. As you know, a student pilot must have three hours of IFR training and, during the check ride, has to find and fly to a VOR. And he or she is still far from of holding IFR flight privileges.

Many countries don’t get even close to that requirement and that is the reason why a person holding an FAA license based on a foreign country license has to follow the limitations of the base one. For Brazilian-based FAA certificate holders, seeing 50% of the ground on a VFR flight is exactly one of those. Tricky, right?

That taken out of the equation, let’s get practical. There’s a saying in Portuguese that goes, “who has two, has one; who has one, has none.” Yep, we are talking about engines here. So, from that perspective, flying a single engine piston over the clouds is quite a bet. That’s why, in my opinion, having an instrument rating, being proficient, and counting on an IFR-equipped airplane is essential. It is all about risk assessment. As we figured out by now, 2020 has very high chances to be the safest year ever: no one is flying. Every time we take off, we are taking risks. But some friends consider it too daring to fly over the clouds in a single engine piston, no matter how legal it is.

Of course, taking that approach, they wouldn’t fly a single engine piston on night cross countries or, even worse, in IMC. I have heard some denials on such endeavors. Now it is my turn to ask: what is the point of having an airplane if you can’t count on it most of the time? Yes, because half the time it’s already night, right? Take out the gray days and… what’s left?

On top

It is pretty on top, but is it worth the risk?

I’m not advocating for you to take unnecessary risks, but depending on the reward, some are worth taking. Of course in your risk assessment you have to consider where and how to divert. DeLand has only GPS approaches nowadays. So, being able to request a local IFR and shoot the ILS at the neighboring Daytona Beach if ceilings drop greatly sounds reasonable from the instrument flying perspective.

Yet, one question remains unsolved. What if we lose an engine en route, over the layer? Is it possible? Of course it is. Is it likely? Not that much. After all, piston engines are easy complainers and it is quite rare for them to quit out of nowhere. The oil gauges or consumption, even the noise, the RPMs—in most cases, something will tell you well in advance that your only engine is not doing great. Besides, they are manufactured under very strict rules and maintained like that over the years, so the chances of them quitting are greatly minimized.

But let’s say it happened. Of the two rules of thumb, you just have to worry about one: best glide. You are not exactly looking for a field. Yet, you will start flying toward one and a flight following with a Mayday has good odds to get you on the ground safely if you are flying high enough and the ceilings are fair. It is a risk? Of course. Just like ETOPS is a risk. But it is a low risk, low enough—with rewards good enough— to be taken here and there. Yet, many of the pilots I heard who wouldn’t fly light GA airplanes in such conditions are seasoned airline pilots.

The ETOPS is a much lower risk, they will tell me. Yes, I tend to agree—although none of us would be exactly willing to fly hundreds of tons on one jet engine for three hours over the Arctic. But it is unfair to ask from general aviation the same level of safety we have in our airline offices. The regulations are different, so both can be viable. Imagine an airline half as safe as downtown traffic. Terrible, right? Now, imagine regulations as heavy as those applied to the airlines for a Cessna 152 owner. Impossible too, correct? And this is what the numbers show. GA is not as safe as it could be, and we must do whatever we can to fix this. Nevertheless, it is rare that GA crashes happen because someone lost their only engine while flying IMC. Far more common is loss of spatial orientation while on the clouds with the engines working perfectly, just to mention something to focus on.

The airline environment is so safe, so full of redundancies, that we, airline pilots, tend to get scared in a single engine, roaring, shivering, flying low and slow with little redundancy more than a pair of magnetos. But the truth is, the beauty of general aviation is to take us to places and experiences the airlines can’t. Once you embrace that, it all makes sense. For system managers who fly in class A airspace at nearly the speed of sound, meeting once again with the basics of real flying is a kind of magic one should not try to resist.

Enderson Rafael has been flying since 2005, first as cabin crew, then as a pilot. And although his career brought him from the 737 galley in Brazil to the flight deck of the heavy plastic in the Middle East, he left his heart with the single piston engines in Florida that made it possible.

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