Empty legs are easy
... the aircraft is available to ONE charterparty, not to persons generally. Once ONE charterparty has engaged the aeroplane for that leg, THEY ALONE determine who rides.
It's only 'RPT' if you sell the seats, individually, and they are available to persons generally.
Harvey World Travel could charter the aircraft and sell the seats individually, of course... that's different!
As for the Bungles/Uluru/H-Waterfall debate, I have often wondered this myself. I suppose that it's from "point A" to "point A", even if intermediate points are involved (eg: Bellburn, Argyle).
Doesn't get around the fact that the seats are available to "persons generally" and the flights happen at a time specified by the operator, not the client.
Would it be fair to say that CASA recognises the true nature of these operations - and perhaps that they acknowledge that, to be RPT, ALL arms of the test must be fulfilled?