captain cop,
my understanding of this is as follows,
a PPL(H) has never had a requirement to to be 1000 ft clear of cloud or to have 1500m, the requirement has been to be 1. clear of cloud 2. in sight of surface and 3. to fly at an airspeed commensurate with the forward visibilty.
the CAA letter of intent introduces a minimum visibity of 1500m for a PPL(H) only, a CPL(H) would still have the original requirements when flying privately, also on an AOC flight a ops manual will typicall state 1500m with 800m possible if other requirements are met, which also will not change.
this business of 800 feet cloudbase is not correct, as long as you have have 1500m and can comply with the 500 ft rule over an uncongested area, you can go. a reasonable guide might be 600ft cloudbase, but this is not a limit.
anyone care to agree or disagree?
regards
CF