Bald kommt ein neues Guidance Material der EASA, welches dies klarstellt. Es gibt bereits ein Comment Response Document (CRD) dazu, das heisst der Rulemaking-Prozess ist wohl schon weit vorangeschritten und es kann sich nur noch um Stunden Monate oder Jahre handeln (geplant ist gemäss NPA noch 2023). Zitat aus dem NPA 2022-04 mit dem neu vorgeschlagenen GM3:

GM3 SERA.3105 Minimum heights
TERMS OF TAKE-OFF AND LANDING
In the context of SERA.3105, the terms ‘take-off’ and ‘landing’ include operations such as touch-andgo, go-around or missed approach performed to an aerodrome or operating site for which the
necessary obstacle clearance assessment was conducted and approved by the relevant competent
authorities.

Rationale
When designing runways, several requirements and criteria have to be addressed. One of them
pertains to the establishment of the appropriate surfaces associated with runways which ensure safety
of operations for aircraft approaching a runway and descending following a specified slope
guaranteeing protection against potential obstacles. In the specified conditions, an obstacle-free
descent is ensured for approaching aircraft when below the declared minimum flight altitudes.
As regards the exceptions in SERA.3105, aircraft engaged in an approach to a runway or taking off
from a runway are protected through the design of these obstacle limitation surfaces from collision
with objects as long as they remain within the limits published for that runway.
Consequently, aircraft approaching the runway, for landing, or for training to land and take off are
protected from collision with obstacles if remaining within the published limits. Moreover, approaching
for landing is one of the most critical phases of flight with heavy workload, which may result in
unstabilised approaches. It is essential that the pilot is encouraged and allowed to interrupt an
approach as soon it is assessed that continuing the approach might result in unsafe operations.
In summary, the exceptions in SERA.3105 incorporate, in addition to the take-off and landing, other
scenarios such as touch-and-go, go-around, missed approach, cautionary circuits and other
manoeuvres designed and published by the competent authorities for specific traffic scenarios.

Link: NPA 2022-04 - Regular update of the SERA regulatory framework (IRs and AMC & GM) | EASA (europa.eu)