Before operational control can be made an issue, the following phrase needs to be clearly defined:
"visual surface reference, or, at night, visual surface light reference, sufficient to safely control the helicopter." (excerpt from FAA Part 135.207)
Visual surface light reference
I know that everyone will have an opinion as to the definition of the above-referenced term, but what is the actual definition that will be utilized during enforcement of this rule?
Please understand that I am not in disagreement with you- I am merely playing the devil's advocate here in an attempt to get to the bottom of this issue.
There is common sense, and then there is the law- I'm looking for the law in this instance.