I can imagine operators embracing your mandated structural change. They would love to have to pay for it as well and then have to change it all back when Part 119 kicks in. You should get a hold of JH and put your proposal forward but let me know when you do, I would love to watch
I think JH would take the suggestion of 2 AOC's and feed it to the local Croc population!
Imagine that, 2 AOC's means double the attention from Fort Fumble. Double administrative costs for AOC renewal, double the silly paperwork involved in dealing with Fort Fumble and double the mistakes made on behalf of the silly Regulator!