He seemed to infer that a "scenic" flight could occur from A back to A, but if you need to make a landing at an intermediate point before returning the same passengers to A "thats a bit too far to be a scenic flight".
Did your FOI happen to define what that flight would then be classified as?
Several times a year Croydon Travel conduct scenic flights to Antarctica, as an interposed entity who don't appear to have an AOC but use Qantas aircraft this appears to meet the ($$$$$) requirements of the Regs. To the best of my knowledge Qantas don't have this route on their AOC. I'm not suggesting there is a safety issue, but why do they need Croydon Travel?
Another better example is Captains Choice. Flies to a schedule - fixed terminals - open to the public if you can afford it. But then it's not G.A. Stupid of me.