Actually, no, this is a group of law-abiding adults trying to reason out a situation which Ubi clearly does not like on their forum, but which appears to me to fall clearly in the realm of a mod, altering an unprotected, internally commented text file, contained in a directory which has always been open for Ubi endorsed modding, within a file which has been open for Ubi endorsed modding. In fact, over the years, Ubi has used the extreme moddability of the Silent Hunter Series as a sales promotion tool.
The question is, "Can you make a change to a file permitted for modding which Ubi can say is not permitted."
Anyway I think would be hilarious if Ubi comes up with "well you WERE intended to mod that unprotected text file, but we didn't think you would alter THOSE lines!" I know! They could put a commented disclaimer warning in the .cfg file before each forbidden line: "Warning: altering the following line could circumvent our unassailable, uncrackable DRM. If you modify it you will be in violation of law and be subject to fine, imprisonment, death and bad karma." That would stop any problems, wouldn't it?
Having made a terrible sophomoric mistake with their DRM concept and implementation, I don't know how Ubi can close Pandora's box, and I can't see any possibility that they can say that file is not intended to be modded. Any attempt, as shown above, would make them look plain silly. But, of course, they look plenty silly now...