Taken from the ESIR the aircraft was some 8nm south of AV when it descended to A015. This seems well outside circling areas and rightly caused concern about the intentions of the aircraft...
BTW Avalon airspace after tower hours is now E down to A007 AGL and G below, so all actions basically except landing require ATC clearance. Obviously departing from a cleared level is a minor point when compared with IFR below LSALT at night...