Actually VL, you might like to revisit the JAR AMC 3.517 and the flight regimes that require approval to operate with exposure - you will see penetrating the H/V curve is included. What's the TDP for the S-92 helideck take off without exposure? 30ft. Where does the base of the H/V curve start? 15ft!
I have queried it with the proverbial horse, and from his mouth came confirmation my logic is correct.