The rules are not clear on this question, but they do provide some guidelines. Based on those guidelines, I think we can draw some reasonable conclusions that provide an outside boundary. From those outside bounds, I then make one suggestion for a relatively simple house rule.
Certain: If you're prepared to act, and start falling from more than 670 feet, you can definitely take a full round's worth of action
This is based on the following text:
(PHB 138): Each round represents 6 seconds in the game world. At the table, a
round presents an opportunity for each character involved in a combat
situation to take an action. Anything a person could reasonably do in
6 seconds, your character can do in 1 round.
and
(DMG2 47): That means a character falls roughly 670 feet in the first round. After that, a character falls about 1,150 feet each round.
From that solid information, we can draw some conclusions:
Very Reasonable: If you're falling from more than 335 feet, you can take a move action
A round takes six seconds, and we know you can take two move actions in a round. Therefore, it's reasonable to conclude that a move action takes a maximum of 3 seconds. It may take less time than that, but by reason it couldn't be more.
A Continuation: If you're falling from more than 168 feet, you can take a move action
According to this excerpt (and the laws of physics) speed is not constant — falling creatures accelerate until they reach terminal velocity.
(DMG2 47): A falling character reaches terminal velocity (roughly 130 miles per hour, or nearly 200 feet per second) within the first round of a long fall. That means a character falls roughly 670 feet in the first round. After that, a character falls about 1,150 feet each round.
This follows the laws of gravity — we accelerate as we fall.
The distance, \$d\$, fallen in a time \$t\$, given an acceleration \$a\$, follows this formula:
$$d = \tfrac{1}{2} \times a \times t \times t$$
Physicists refer to the particular acceleration imparted by gravity as \$g\$, which on Earth is approximately \$g_\text{Earth} \approx 9.8\tfrac{\text{m}}{\text{s}^2} \approx 32.2\tfrac{\text{ft}}{\text{s}^2}\$.
We can't use Earth's acceleration due to gravity, because we're not on Earth, but we can easily calculate the gravity constant used in the DMG2 using the same formula and solving for \$g_\text{D&D}\$ (from now on, just \$g\$):
\begin{align}
670\text{ ft} &= \tfrac{1}{2} \times g \times 6\text{ s} \times 6\text{ s} \\
670\text{ ft} &= \tfrac{1}{2} \times g \times 36\text{ s}^2 \\
670\text{ ft} &= 18\text{ s}^2 \times g \\
\tfrac{670\text{ ft}}{18\text{ s}^2} &= g \\
37.22\tfrac{\text{ft}}{\text{s}^2} &= g \\
\end{align}
Now that we have the \$g\$ for the D&D Universe, we now re-solve for \$t=3\text{ s}\$
\begin{align}
d &= \tfrac{1}{2} \times 37.22\tfrac{\text{ft}}{\text{s}^2} \times 3\text{ s} \times 3\text{ s} \\
d &= 167.5\text{ ft} \\
\end{align}
Therefore, based on the information and rules provided, we can reasonably conclude that if you're falling from at least 168 feet, you can take a move action.
Another note — Reaction
While you may have time to make a move action in your first 168 feet, that assumes you are ready to act immediately and have great reflexes. It could be that it takes you a few seconds to figure out what's happening to you, and by the time you figure it out, you've already gone *SPLAT* against the hard ground.
A Practical Suggestion (i.e. An Informed House Rule)
Based on the information above, if this issue arose in a campaign I was running, I would use the following rule, which is based on the above information but uses simplified and round numbers:
- Roll a dexterity check, representing your ability to react quickly
- Multiply that check by 10 ft
Then:
If you want to take a full round action, subtract that resultant number from 750 feet. That's how far you will fall before you complete your full round action.
If you want to take a standard action, subtract the resultant number from 300 feet. That's how far you will fall before you complete your standard action.
If you want to take a move action, subtract the resultant number from 200 feet. That's how long you fall before you are able to take a move action.
If you want to take a swift action, subtract the resultant number from 100 feet. That's how long you fall before you are able to take a swift action.
Obviously, this is a suggestion for a house rule, and it may present its own problems if extended to more complex situations (i.e. what if you want to take two swift actions, or a swift and immediate action, or a swift and a move action?). That being said, it is a single roll with a simple look up table that provides a reasonable set of rules for the first round of falling. I also think the general principles are extendable for all reasonable cases of a single round of action.