Interesting ... I'd seek a second opinion from a CASA employee, it may prove interesting.
The Police require an AOC, that became a requirement a few years ago.
7. Selling a photo you took from your aircraft to a newspaper
8. Taking photos from your plane and selling them to a real estate agency
CASA successfully prosecuted a PPL photographer a few years ago in North Queensland for taking photos of properties from his aircraft and selling photos, without an AOC.
Be interesting to see the justification for only Police (?) being required to hold an AOC?