Clear of Clouds? Evaluating 91.155 Enforcement Actions
Abstract
The Federal Aviation Administration (FAA) requires pilots to remain a certain distance away from clouds when operating under visual flight rules (VFR). But this regulatory requirement—found at 14 C.F.R. § 91.155—is often referenced by pilots as challenging to comply with. While there are important safety concerns associated with violating 91.155, non-compliance also raises the question about the extent to which the FAA enforces this regulation. Though publicly available data is limited, decisions of the National Transportation Safety Board (NTSB) in FAA enforcement action cases offer some insight into how the FAA has discovered 91.155 violations, the types of penalties associated with these violations, and the decisions of the NTSB itself in reviewing these cases on appeal. Originally presented at the 2023 Collegiate Aviation Education Conference and Expo, this poster showcases an analysis of twenty FAA enforcement action cases involving violations of 14 C.F.R. § 91.155 (and its predecessor).
Clear of Clouds? Evaluating 91.155 Enforcement Actions
The Federal Aviation Administration (FAA) requires pilots to remain a certain distance away from clouds when operating under visual flight rules (VFR). But this regulatory requirement—found at 14 C.F.R. § 91.155—is often referenced by pilots as challenging to comply with. While there are important safety concerns associated with violating 91.155, non-compliance also raises the question about the extent to which the FAA enforces this regulation. Though publicly available data is limited, decisions of the National Transportation Safety Board (NTSB) in FAA enforcement action cases offer some insight into how the FAA has discovered 91.155 violations, the types of penalties associated with these violations, and the decisions of the NTSB itself in reviewing these cases on appeal. Originally presented at the 2023 Collegiate Aviation Education Conference and Expo, this poster showcases an analysis of twenty FAA enforcement action cases involving violations of 14 C.F.R. § 91.155 (and its predecessor).