Howard Hughes
I can quite easily call myself Howard Hughes Aviation, set up under a tree, sell individual seats, at set times, to any destination, then contract another company (can even be a charter AOC) to operate the service for me!
Not any more.
http://www.casa.gov.au/aoc/chartersub.htm
"CASA is aware that some charter operations are conducted in circumstances which have many of the hallmarks of RPT operations, and which are indistinguishable from RPT operations by the travelling public. These operations are conducted by holders of AOCs authorising charter, but not RPT, operations, carrying passengers who have contracted with another person for their carriage."
"The amendment to CAO 82.0 prohibits charter substitution arrangements, but enables CASA to authorise such arrangements in the public interest."
Wether that's enforced for ALL operators is another question, fair and unbiased, what a joke.
MHA