Thank you B73 for the update.
However I do not agree with your interpretation. One can fly above a solid overcast, which (if mainly stratus) will have a flat top surface and will thus be perfectly suitable for wholly visual aircraft control, and if there is a hill or mountain sticking up in the distance, then you are visual with the surface and meet the legal requirement.
The time when the condition
the flight crew being able to see sufficient surface features or surface illumination to enable the flight crew to maintain the aircraft in a desired attitude without reference to any flight instrument
would not be met would be when flying in the common summer haze, especially over the sea, or inside a deep canyon, or perhaps one of the optical illusion cases like flying towards a sloping horizon.
By far the most common "breach" of the "sight of surface" rule has to be flight above a solid layer, and that is perfect for VFR flight.
So, I don't really see what difference the new wording makes.
Now, if they required the sight of enough of the surface to enable
navigation, that would be very different
