Of course, as we are all aware, this will become academic when the EU adopts Eurocontrol's
Draft Implementing Rule on Standardised European Rules of the Air when Rule 5/6 will be replaced by:
4.6 Except when necessary for take-off or landing, or except by permission from the
competent authority, a VFR flight shall not be flown:
a) over the congested areas of cities, towns or settlements or over an open-air
assembly of persons at a height less than 300 m (1 000 ft) above the highest
obstacle within a radius of 600 m from the aircraft;
b) elsewhere than as specified in 4.6 a), at a height less than 150 m (500 ft)
above the ground or water.
Since a
PFL is not '
necessary for take-off or landing' and there is no exemption for training, it will be illegal to descend below 500ft agl. Oh yes, and the comment period closed in April - we all made our comments before then, didn't we?