IMHO, there are two other glaring holes in the new Scenic Flights scenario:
1/ It is my understanding that a scenic flight is deemed to be a flight that departs from Point A, and returns to Point A, with no landings in between. Who is going to police the young CPL who is offering "scenic flights" to ensure he / she is only offering scenic flights, and not charter?
2/ A scenic fight operator who is offered a charter, from Point A to Point B, is going to take it. No doubt about it.
In my opinion, there is no point in introducing / amending a regulation unless it's going to be enforced. At the moment, it appears that The Regulator has so many people tied up with re-writing regs to the point of incomprehensibility that they have little time or staff to educate or enforce. It is my opinion that The Regulator has always relied on competitors to dob in cowboys.....and they may, or may not, choose to act. Either way, it is an unhealthy way to have an industry.