If the CD already has authority here, then could this be a process to use it?

It counts as landing to fly anywhere at less than X feet AGL without having enough speed to pull up to X feet and be above Y airspeed. (X = 500 feet, Y=60Knots, with a simple chart for the pullup?) The goal being to limit low thermaling and low and slow passes across ridges but still allow flight near terrain.

When you publish the IGC, you also have to publish your landing plan for the whole flight. (For each part of the flight, the area you planned to land and how you were going to get there with energy you had (as opposed to hoped to get) when you committed to that option.) Any pilot can ask for clarification on this and the CD can then access penalties.

In addition, experiment with an occasional safety SUA for specific issues.