Ops
FFF
I'm being lazy and not looking up the tomes. forgive me. However doesn't the JAR's you qoute refer to the 'carriage of passengers'. In this case, the question regards 'Arial work', flight instruction. If the exemptions granted to a club were not exploited and therefore the flight was/is subject to an AOC the AOC would need to account for the actual operations being performed. That is training a pilot who, is not a passenger.