Trim Stab
So was his trajectory at 200ft at 45 deg to display line a "low pass"? Or was it the start of a Standard category aerobatic manoeuvre, below his DA of 500ft?
I think you are banging the wrong drum here. If the vertical trajectory was more than 30 deg nose up at 200 ft you might have a point, but the issue is
the stage at which a manoeuvre becomes aerobatic. If you keep aileron applied you will keep rolling (= aerobatics) but if you stop the input after 45 deg, so will the roll (= normal turn). Same with pitch, however rapid. A 4g pitch to 30 deg nose up is not aerobatic. If, as is commonly done, you continue into more extreme attitudes and you are above your DA minimum, you are legal.