Biggs
You have a point, in that the CPL candidate
should absolutely ensure he/she fly's within the rules. But here's one or two things to think about.
I would not have the mixture pulled and I would simulate changing tanks, checking mags etc and I would not break 500' AGL during the FLWOP... ...If you are unsure about being able to make the field/landing area by the 1,000' point then you need more training
And you would never find out how reliable your aircraft (and indeed you decision making skills) may or may not be under controlled conditions... So then, how are you going to react when you don't make that perfect 1000ft point because your engine has stopped in an entirely inconvenient position at an unexpected height?
That's the whole point in simulations isn't it? To catch the student off guard, to see if they will handle the real thing.
Where ever it is safe to do so, it's always worth going to the ground because no two FLWOPs or EFATOs are the same. Guaranteed the real thing will be different again. The more exposure you get, the better off you will be when that fateful day arrives.
Read what the Regs (sorry, now they are Rules) say
There are two occasions where an LFZ isn't required for flight below 500agl. The Bona-fide purpose (effectively provides examiners with free reign, and they
will exercise it) and the EFATOs under instructors authority.
Paragraph (a)(2) (the 500ft rule) does not apply to a pilot-in-command of an aircraft
(c) if the bona fide purpose of the flight requires the aircraft to be flown at a height lower than that prescribed in paragraph (a)(2), but only if——
(d)
(1) the flight is performed without hazard to persons or property on the surface; and
(2) only persons performing an essential function associated with the flight are carried on the aircraft; and
(3) the aircraft is not flown at a height lower than that required for the purpose of the flight; and
(4) the horizontal distance that the aircraft is flown from any obstacle, person, vessel, vehicle, or structure is not less than that necessary for the purpose of the flight, except that in the case of an aeroplane, the aeroplane remains outside a horizontal radius of 150 metres from any person, vessel, vehicle, or structure that is not associated with the operation.
Paragraph (a)(2) does not apply to a pilot-in-command——
(1) who is the holder of, or authorised by the holder of, a current instructor rating issued under Part 61 and who is conducting flight training or practice flights consisting of——
(i) simulated engine failure after take-off commencing below 1000 feet above the surface; or
(ii) simulated engine failure commencing above 1000 feet above the surface provided that descent below 500 feet above the surface is conducted within a low flying zone in accordance with 91.131;