andrewr...Not sensible at all. Just a sign of Cretins against Sensible aviation.
With the power to make you have an AOC, you are then in the CAsA 'squirrel grip'. Argue with or upset a CAsA perp and they will squeeze for yr pain or cancel to put you out of business. Now that's power !
Lawyers fly off to a case, along with their brief boxes...but CAsA stays away. And so they should.
To deny a person going about their lawful business, just because they use an aircraft is rampant stupidity, and a denial of yr civil right.
If it stops you working, its a denial of yr right to earn a living.
It has SFA to do with "safety"
All CAsA has to worry about is that the pilot conducting the flight is duly licenced , that the a/c has an MR and the appropriate flight rules are adhered to. NOTHING MORE. That is their only interest ...or should be.
CAsA is "a safety agency, not a commercial regulator "..so past DASs have BS-ed away merrily to Senate Hearings over the decades.
But its a great shining LIE.
How to deal with ,and rectify all these bureaucratic hide-bound stupidities that have bought GA to its knees...that is the question.