ah OK, so... because of clause (a) most ab-initio/licence training would not be subject to the reg (because it would be done in aircraft under 9 pax or 8618kg) and so clause (d) therefore doesn't need to be looked at (it does say only one of a, b, c or d must apply - I missed that bit
).
That makes sense.
appreciate the explanation cheers - I was going cross eyed looking at it!