This is circular nonsense:
7 General requirements
(1) It is a condition on a flight crew licence that its holder must not operate an aircraft for a community service flight unless:
(a) the licence is a private pilot licence, commercial pilot licence or air transport pilot licence; and
It’s like saying it’s a condition on your motorcycle licence that you can’t do something unless you have a truck licence. That’s not a “condition” on the exercise of the privileges of your motorcycle licence.
What they meant to say is:
(1) It is a condition on a private pilot licence, commercial pilot licence or air transport licence that the holder must not operate an aircraft community service flight unless:
(a) the flight is in an aeroplane;
(b) etc
(2) It is a condition of a flight crew licence other than a licence mentioned in (1) that the holder must not operate an aircraft for a community service flight unless the holder also holds one of the licences mentioned in (1).
But once you write it out like that, you see the conundrum that they may have tried to solve through drafting smoke and mirrors.
Do e.g. RAAus pilots have a “flight crew licence” within the meaning of CASR 11.068? I didn’t think a Recreational Pilot’s Certificate is a “flight crew licence” within the meaning of CASR 11.068. If it isn’t, I don’t think CASA can effectively ‘ban’ CSFs by holders of RPCs by imposing conditions under CASR 11.068 on licences that aren’t RPCs.
Is an RPC a “flight crew licence” within the meaning of CASR 11.068?
Does RAAus itself effectively ban CSFs already?