As I experiment with different planes, there seems to be perimeters to fights that each is suited for in a rule of thumb sort of way. As an example I have had great success coming off a carrier with a Seafire and jumping into a furball that is on or very near the deck. It is slow, turns tight and has canons. Not much can turn with it. However, take the fight up a bit and it is in deep trouble.
I can deal with 109s and 190s on the deck easier than I can at 10K. Any of the planes that have skyrocket like climb rates are hard for me to bet in that 5-10K range.
Unless they are pushed down or caught under a fighter cap, I don't see a lot of 109s and 190s low in my limited experience.