I flew over the clouds for a very smooth flight noting weather through ADS-B and ATC all along my route (forward, backwards and sideways). Plenty of ground visibility especially since I was a good 3500' above the tops. Clouds started to fill in and most Dallas area airports were reporting overcast so I descended below the clouds before any overcast layer. I had my hands full landing in 18G28 winds but, otherwise, a great flight.
I was exercising Sport pilot privileges and am 100% comfortable I adhered to FAR 61.315(c)(13) that states an SP must not operate "Without visual reference to the surface". I had this at all times and descended with the appropriate cloud clearances.
This brings up a topic for discussion.
Clearly, flying over a solid overcast would not be consistent with the FAR but I've heard some CFI's state that an SP cannot operate over a broken layer. I don't think this is in line with the FAR. A committee member posted on another forum that the intent of FAR 61.315(c)(13) was for spacial orientation so flying above clouds was OK provided there was reference to the ground (which would include broken layers up to 7/8). This makes sense otherwise I would think the reg would have referenced cloud coverage.
Thoughts?
P.S.
And, no, I don't want an FAA interpretation
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