Originally Posted by
SASless
But no mention by the Crew of seeing any lights.
No, no mention.
It's an assumption that the ceiling was a stratified uniform layer, but it may not have been. If they did see lights, it may have been before the CVR part released. If they expected to see them, they they may not have remarked when they did. Isn't the curvature of the earth rule 12 miles =1000 foot lower?
Or they may have seen nothing.