Of course it counts.
I spent a lot of time in Africa in the mid 90s. I can remember pulling up for giraffes. Just set the radar altimeter for 25 feet and press.
Somewhere out there there is a video of a Brit reporter getting buzzed by a Spitfire. Came up from behind him and shook him up pretty bad. I think I heard an F bomb or three.
You can only tie the record for flying low...






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