Well
Interpreting the Regs is something the retired SQDLDRS in CASA do daily, but never get the same answer twice.
Looking at it, scheduling flights rather than randomly taking people when they want is grey, but would still be a scenic.
Selling tickets via other agencies, ie the NT Travel Bureau, seesm to make it even more RPT ish. But, if it only uses one strip, like te Uluru flights then it doesn't have a 'destination' and seems OK. If it goes elsewhere, the Bungles example, then perhaps it is different.
I will run this past a lawyer I know and see what he says.
Chuck