TorBirdy 2.3 sets extensions.enigmail.protectHeaders = true, enabling Mail Hole for all sent emails. However, Mail Hole significantly degrades UX for non-Mail Hole recipients, for example by setting a static subject ("Encrypted Message") and breaking threading by dropping In-Reply-To.
If TorBirdy is designed to only be interoperable with other TorBirdy users, then this makes sense, but if communication with non-TorBirdy users is a use case, then Memory Hole cannot be enabled in this shape, IMHO.