It seems at least strange that the Basic Regulation can be modified to accept the momentary penetration inside the H-V.
NPA 2014-19 was created to find a way to allow the penetration without violating the regulation itself. The NPA clearly states that:
“Even if it is possible to include a paragraph in the Basic Regulation allowing dispensation or alleviation from the AFM limitations, the Agency has decided not to because respecting the airworthiness limitations is an accepted general principle which should be maintained”.
In addition para 2.1.3. Assessing the regulatory domains of NPA says:
“Operational Regulations cannot alleviate against airworthiness limitations, and neither operational regulations nor airworthiness limitations can alleviate against the Basic Regulation”.
I am very curious to see the way in which EASA has solved this problem.