Davidt.
Well, no we don't both agree it's lawful because the rules relating to the LLR are designed to prohibit it. They are couched in very poor terms though. The fact that people do orbit in the LLR doesn't mean it's legal! If that was the case I could drive up and down the motorway at 150mph! It's illegal but other people do it so it must be O.K. You say you work Liverpool in the LLR, well they may well be not so familiar with the rules cos they're not the designated agency to be working traffic in the LLR. I fly the LLR myself regularly and it can be very difficult to avoid traffic orbiting in the route due to the fact it's only 4nm wide and everyone wants to fly at 1250ft to get the best of the alight clear rule. I used to be a LARS controller and local pilot flying in the BPK, LAM,BNN area and what you say is true regarding the 'rat runs' under the London TMA. If you've flown down there ever tried avoiding someone orbiting over the disused at BNN who keeps turning into you in a C152 and you don't know if he's seen you or not? That's the point I'm making about the LLR. It's the other guy who's put in the difficult situation if you bend the rules.
Spiney