If we're going to argue weather once again, please let us stick to the issue.
Waypoint change was 1.75 km from the crash scene. Surely, all you can say with any degree of certainty is that at least part of the high ground near the lighthouse and the crash site were obscured by cloud and fog.
Wratten has said* that the pilots were grossly negligent AT WAY POINT CHANGE because they were going too fast under the conditions i.e. with some high ground obscured 1.75 km away.
Walter's photos (6644 or 6651) could meet these conditions so the inference is that it would be negligent to fly within 1.75 km of high ground obscured by cloud when VFR rules stipulate 1500m horizontally or "clear of cloud".
Wratten has argued that whatever may have happened after waypoint change is not pertinent to his judgement. That is the basis for the findings of the RO's as described by Wratten himself.
*Pilot Magazine article