Perhaps - but he does work for the CAA!
Conducting any part of an approved training syllabus should be considered 'normal aviation practice' and specific exemption from Rule 5 should be introduced to facilitate that.
Assessing the last 500' or so is essential. Which is why we had a 100' a.g.l. limit for practising PFLs in HM's Bulldogs!
The lowest level in the civil world is 1 molecule - so long as you aren'r within 500' of a person, vehicle, vessel or 'structure'. What constitutes a 'structure'? Do tell, blueline!