So here we have an aircraft operating in airspace that specifically DOES NOT require an ATC clearance (Class E), but which is being made to comply with a CAR that obviously applies only to an aircraft in Controlled Airspace under ATC control, all on the premise of what is in an AIP SUPP. If there is a nearmiss/midair under this arrangement, OAR is going to go for a row.
This is ridiculous. Guys, have the guts to stand up to the Lunatic Fringe and make it Class D!