Good question. Obviously the CP is at it's strongest when you're shooting at the 90º position from the sun. When more or less facing directly at or away from the sun you just get the benefit of the ND16. BUT... you do get about a half stop more light reduction at all angles because of the CP. So I've found the ND16/CP is perfect for full on sun when you're trying to keep you shutter speed at a manageable 50-100. Because this is a CP just like any other CP I plan my shots by positioning the Phantom in the right spot... then roll with the shot I'm after.
Thanks for the clarification, that is helpful. Hopefully someday I too will be able to plan shots.