Sounds fair
I have no real problem with aerocat's limit although I limit it to 200' in a training/checking environment. Note he, and I, sad "with the gear down'. Maybe he flys Aztecs with only one hydraulic pump..or he's used to Seminoles with at best anemic performance...or maybe he has only flown off long runways.
In a training or checking environment I see no point in low altitude simulated failures...the accident statistics bare this out too. With the gear up at 100'/at or above Vyse he probably would be as happy as anyone to continue.
I have no problem with gear up before Vyse either. Often it is a good idea if the runway is of limited length. It allows you to accelerate to Vyse quicker and if you lose one before Vyse you put it down on it's belly and slide to a stop off the end of the runway...better that than risk snapping off the nosewheel on rough ground and flipping. I wouldn't advocate that at Mascot but I would at Redcliffe.
Some aeroplanes, like the Twin Commanche, 'wheel barrow' if you try and hold them on the ground until Vyse. If you are going to be off the ground below Vyse you may as well have the gear up minimising exposure time to an engine failure.
At several airstrips I can think of I used to get airbourne below Vmca and accelerate nearly level in C402s. Before anyone goes ballistic YES I agree that is extreme and YES taking 402s into such a strip is probably not all that clever...but 'we were bush pilots once... and young', to paraphrase a movie. And No I am not going to tell you how to get a loaded 402 into the air at really low speed off really short airstrip.
As to the certification requirement of 1% at 5000' in ISA.
Well that is demonstrated by a test pilot in a brand new aeroplane and with the added bonus of shutting down the engine in a controlled manner and optimising everything.
It bares no relationship to a 25 year old Duchess, Seminole, Twin Commanche which may be being flown by someone of low experience and minimal recurrent training on a 35 degree day out of an 800-1200m airfield. The 'OH !!!!' factor is too high and without 6 mthly recurrent training the chances of such a pilot successfully coping are proved to be minimal by the statistics. As an example I had an engine failure in a 402 at 50' with the gear retracting approaching Vyse once. No room to stop without hitting jungle at high speed. It took 4 minutes to get to 500' over the water passed the trees and I was very lightly loaded. I never got above 500' because of low cloud and heavy rain.
I was flying piston twins full time within the check and training auspices of a 3rd level airline, 6 mthly recurrent checks, and a training pilot as well. I think no one would argue that a 402 has more performance on one engine than a Seminole...although it aint much more
Barons, C310s, Chieftains, 402s etc do have better performance than typical training twins but you pay for that performance with more challenging handling assymetrically.
To return to the thread topic, and at the risk of upsetting Centaurus who has considerable (LOTS and LOTS) experience in this area.
In my view failing on the mixture v failing on the throttle is not the fundamental problem or greatest danger in assy training.
Altitude/speed when the failure is given, what happens next, and the knowledge and competence of the trainer are the main factors.
There are no circumstances where I can accept failing engines below 100' and at less than Vyse+10kts with the gear up in a training/checking environment. 200' is better.
The trainer/checker MUST have significant real multi experience...that precludes all low time instructors hour building.
The individual must have demonstrated ability and knowledge. This is actually tougher than it sounds...you would not believe the crap I have heard espoused by people with CASA approvals...and from CASA FOIs for that matter.
When I was tested for each type specific twin training approval I was tested by people who were VERY experienced on type and grotesquely experienced in general and VERY current. I also gained my individual approvals within the auspices of 3rd level airlines rather than the 50 ME TT/10 on type BS you see at flying schools and as a result had 500 to 1000 hrs on type in the earlier days and at least 200 on type later on. The Falcon was a different story.
Because of the skill, knowledge and experience of the people who trained me I got put through every drama a student could come up with in a 'controlled' environment. No trainee I ever experienced took me places where these guys hadn't taken me first...in fact not even close
I don't think there are any people left at CASA with the currency, knowledge, skill and experience AND the desire to pass it on. There would be relatively few left in Industry and I am not counting those that may have the desire to teach extreme stuff to a potential ME Instructor but shouldn't be because they don't have the knowledge, skill and experience themselves. There are a few though.
In my view twin training is sufficiently serious and the accident rates high enough that short of good Level D equivalent sims being used it should be so hard to get the training approval as to be bordering on impossible for the average flying school instructor.