Ah, now back to the dreaded Part 121B JAR version.
Your scenic/joyflight will soon have to be conducted in the same manner as charter, and under Part 121B almost like RPT.
No more hour building for 200 hr CPLs.
Now the GFA (Gliders) do it 'non-commercially' but still charge. The PFA (meat bombers) fly for money but use PPLs. Why then is a joyflight any different.
I recon JFs (that depart and return to the same place without an intermediate landing) should be Airwork, subject to liability disclaimers (to keep insurance costs down) and available for any CPL holder in an AWK aircraft.
Getting people used to aircraft and getting them accepted (so the journos leave us alone) is half the battle.
The DP for Part 121B is here
http://www.casa.gov.au/avreg/newrule.../121b.htm#docs
Read it, tell them the JARs aint acceptable and that the proposal is totally unacceptable. For fun cc it to a few pollies as well
Chuck