Advocate. As I expect you know better than I, a court would ultimately determine whether having a website from which you can't book yet is advertising. I think it's a case of regs not having caught up with the tech world. Is my personal website on which I have photos etc advertising? It was interesting that there was no link to their website in the article. If they had a corporate office in Main Street Bendigo, could they have signage on the windows or façade?
As for the business model. Bendigo to Melbourne CBD.
Option 1. Drive to Bendigo airport, checkin by 0630. Arrive 0730. 0745 at earliest by the time you are out the front (carry on) then arrange txport. Taxi or sky bus into CBD add 45 mins at peak hour. 0830 at best at CBD.
Option 2. Vline to Southern Cross. Departs Bendigo 0631. Arrive CBD 0812. You always have a seat, and it's an express so you don't have to worry about
this 
What am I missing?