In response to your additional thoughts you mention scaling up to government survey level, that seems an odd justification for your homeowners policy content surely? Totally different scenarios, just because you may not remove vegetation on large numbers of roadside trees in Tasmania doesn't mean it's sensible to encourage homeowners not to remove ivy on their one roadside tree in a domestic setting in the UK, hence my original suggestion that you revise that (I'd remove it), apologies if that hasn't gone down well, but I feel it's important to at least register some concern with your document.
You state "To remove vegetation without an obvious tree risk feature to trigger it is disproportionate to the likely overall risk reduction"
I'd add that this is in your view, and although I asked what science you have been doing or encouraging, there doesn't seem to be anything new you are offering to show that this is disproportionate ? I'd suggest you are trying to quantify in terms of risk the un-quantifiable, as unless a very bored arborist somewhere does some stats on failures due to hidden features that hadn't been inspected, we are left with what to me seems a reasonable approach, not your proposed blanket statement that unless there is an obvious risk feature seen you go no further with veg removal. For example, your proposed approach would miss all the big healthy crown condition ivy clad willow and poplar, that upon ivy removal have been found to be long over due a red dot and felling, we all know they exist, surely part of job is to understand that and find them on a survey before they fail onto people or property?
You mention boundaries for decision making on vegetation removal, perhaps you are realising that it isn't something that needs to be laid out in a home owners policy as one way or the other?
Saying it is the duty holders choice seems a bit of a cop out, I think most of us in this area of work will be used to a client expecting us to provide a view and advice on if veg clearance is needed, not pass the buck back to them. I think tree inspection work is such an experience critical field, with so many variables that trying to put a risk output on what might or not might not be under vegetation isn't productive, and doesn't need a set of traffic lights to help, hopefully the PTI stays in the current format to reflect this. If experience of species, wind loading, water logging, soil type, snow loading, previous failures, past land use etc etc, leads me to think I need veg removal I recommend it, if a serious risk feature is found then it is, if it isn't it isn't, that's the nature of massively variable organisms and growing positions.
Semantics on safety or otherwise aren't of huge interest to me, a tree safety improvement policy might be better wording, but more time looking under ivy and vegetation is probably time better spent.... But don't worry I'm sure arbtalkers are aware you can't make trees safe.
Have you been on the PTI? when I did it you were certainly expected to look above 2m, or are you describing other previous training you've had that focused on below 2m assessment? that restricted type of VTA is not something I've ever heard of.