And? Just because it is published by the aviation authorities does not mean it isn't gibberish. I am sure that the CAA had control of any output of the meeting, even if others were present.

BlueLine

While I think your thoughts are far from 'jibberish', I do think you overlook the mindset that that Rule 5 induces.

The problem is that while they may be conducted without prosecution, they cannot be conducted "without fear of prosecution". It may be possible to be 90% satisfied that a PFL carried out down to low level satisfies Rule 5, but there is still the possibility of:

a) overlooking a person, vehicle, vessel or structure
b) misjudging distances to a person, vehicle, vessel or structure
c) encountering vexatious (or even merely mistaken) complainants whose distance estimates are different from the pilot's

without negligence on the part of the pilot.

As a result of the fear of prosecution, as a PPL I simply gave up practising off-airport PFLs. I figured that the combination of probability and severity of unfavourable consequences of the practice outweighed the probability of engine failure and marginal benefits of the practice.

This was and is the only area where legislation discouraged me from regular practice to maintain and improve proficiency. I do not believe that I can be alone feeling that way. If that was my mindset as a PPL, instructors conducting ab initio training must be affected even more severely.

There is a serious possibility that the legislation, phrased as it is without exemption for reasonably conducted training and parctice, makes a negative contribution to overall aviation safety. If that is the case, it needs changing.