Yup, I think if someone complained about someone hotdogging into a private site (those are just two I thought up), then I think the CAA would have a case. They would simply point to the syllabus and say show me where it says that's the way to land, and unless you've got a good operational reason to be doing that you'd be bang to rights.
Simulated EFATO has been much discussed and as I understand it the CAA takes the view that it is NOT acceptable at an a/d. That's wrong IMHO, but that's their view. Their wording is quite specific in the latest form "exempt low flying prohibitions in so far as it is flying in accordance with normal aviation practice FOR THE PURPOSE OF
1) taking off from
2) landing at or practising approaches to landing at
3) checking navigation aids or procedures at
a govt. or licensed a/d. EFATO doesn't fit any of those categories, so you can't do it on the field. Presumably they want you to practice it aloft or in a deserted area - daft I agree.
Yes the 1000ft rule is about flying below 1000ft over a congested area whether or not you land. But in attempting to land you'll certainly break it, and no I don't think it will be defensible to say that you stayed over your landing site in a tight spiral. The rule is about whether the site is in a congested area or not, not how you fly into it. Therefore it's important to have a working definition of 'congested area', and hence my question to FL.