It makes for very dramatic footage to skim just above the tree tops. With your camera level slowly pan around while closely observing your FPV. Generally as long as nothing extends above the horizon you are safe.
It's not a woodpecker.
A better question is, how high to you want to climb in a tree.
If you really need to, fly at sunrise or sunset and see which tree stays lit the longest. then fly over to it, and read how high. Earth curvature shouldn't make that to far off.
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