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Who is responsible for separation during climb/descent to VFR-on-top, and from VFR-on-top back to an IFR level?

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Who is responsible for separation during climb/descent to VFR-on-top, and from VFR-on-top back to an IFR level?

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ATC is responsible for providing a separation standard during climb/descent to VFR-on-top and after the aircraft is assigned an IFR level when leaving VFR-on-top. ATC may impose a clearance limit level to assure an IFR separation standard.

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