Originally Posted by
Torres
The "substantially similar" would relate to the fact that both tools of trade, goods and staff are substantially connected to the conduct of a commercial business.
The rule says nothing about tools of trade, staff, or the conduct of a commercial business. It says "carriage, for the purposes of trade, of goods being the property of the pilot, the owner or the hirer of the aircraft". It doesn't even include goods that are
not "the property of the pilot, the owner or the hirer of the aircraft".
Clearly, it is intended to prevent someone from buying an aircraft and setting up a business bringing in seafood from King Island etc. without an AOC on the basis that it's their own aircraft and the are not charging anyone for transporting the goods. It's not a general prohibition on commercial businesses using aircraft without an AOC. There are plenty of circumstances where you can use an aircraft in the conduct of a business without an AOC.