I'm not sure how this works but we shut part of our operation in response to it.
I discussed it with an FOI who told me that a scenic flight around Menindee Lakes is an open charter type Scenic flight, but a Scenic flight around Lake Eyre booked and "ticketed" (forgive the expression) in exactly the same way "is probably a bit far to be a scenic flight", and would be considered RPT.
I asked if there was an arm of the definition in 206 that mentioned distance and he told me that everything would be made clear in the new regs, sorry for the mess
3 less starting jobs for young fellas now.