I think there is no doubt the CAA intended to retain the old 500ft rule.
uncomfortable though it feels to side with the Cleptocracy Against Aviation (there being no kinder name for an agency which charges $60 to send an email and which can't bring itself to ask any of its executive board members to scrape by on less dosh than the British prime minister), the way I read the ORS is that it means exactly what it is intended to mean.
But more to the point, no court in the UK will ever decide otherwise, not least because no Prosecutor or Fiscal will see it as being in the public interest to argue that the CAA (peace and blessings, etc.) has its head up its institutional backside.