Can anybody work out whether the derogation is available to paid pilots flying for the aircraft owner?
The question is more subtle than it may at first appear, because such ops do not breach the "aerial work in a FRA" ANO article and are thus effectively private flights. As this
letter (obtained under FOIA in 2005) shows, it was realised by the CAA that the then Article 115 breached ICAO on these ops as it sought to force them to obtain a DfT permission for each flight, which was clearly not intended.