Very
generally speaking that may be true, but not always. It comes down to whether the operation is undertaken for the purposes of aerial work, or the purposes of public transport.
There is a
document available from the CAA which explains the differences and how to decide whether an operation comes under aerial work rules or public transport rules, the latter perhaps requiring an AOC if the company is an 'air transport undertaking'. The doc is a guide rather than a canonical authority but it's handy reading.
As ever, there can be grey areas though. The document suggests that 'cameramen' are to be considered passengers which would therefore infer a public transport operation. However, there are at least two companies in the UK which consider their sensor operators to be crew, and thereby operate under aerial work rules. Each year these company must have their annual CAA Ops Inspection, and each year the CAA presumably go home happy. That said, I'm talking about operations involving twin turbines and big twin pistons fitted with very expensive sensors rather than spamcans with SLR's poking out the windows.
I digress; the document also explains how to decide what constitutes valuable consideration, which might be useful to Pumper Bob. Notice it talks about a payment being made - not necessarily to the pilot, not even to the cameraman, just to
someone (e.g. the operator). Presumably somebody somewhere will be making money from these pap shots. If that somebody were no longer making money from them, would they still want the shots taking?