1. Given the "land clear" requirement why should it be necessary to specify a higher-than-ICAO limit because the UK is densely populated?
2. Doesn't the specification of a rule of distance using two different units for measurement seem a bit daft? Greengrocers get in trouble for selling potatoes by the pound, but we have rules that talk about X feet and Y metres.
3. *Personally* I'd rather they clarified the use of a SEP plane to transit over the City than worry about this other stuff (which might be 5 times as long as it needs to be, but isn't that difficult to understand). If they think the existing rules are hard to read perhaps they should think about how hard it is to implement them in such a case.