Scurvy.D.Dog,
If you remove IFR aircraft from the equation (ie procedurally), how does distance from cloud affect VFR to VFR collision risk? Low visibility does, distance from cloud does not as neither aircraft should be in cloud.
I am all for SVFR being separated from IFR, but I have not yet seen a convincing argument that justifies SVFR to SVFR procedural separation due to lack of distance from cloud alone. When low level in G distance from cloud alone only concerns me if there are IFR aircraft about.
GAAP control zones operate with very high density VFR operations with a significant number of low time pilots. Yet VFR aircraft are only required to operate clear of cloud.
Correct me if I am wrong, but it wont be the distance a VFR aircraft is from cloud that stresses ATC in a GAAP, it will be the density of traffic, the distance (or lack of) between aircraft, the ability of pilots to follow instructions and the ability of pilots to develop SA of other traffic.
Werbil