Yes the regulations are very restrictive but with a little creative thinking, look what you can come up with.
You just have to be a little discreet with your departure times(for the people in Canberra who erroneously think scheduled departure times for the general public means RPT) see here:
Day Tour ex Gold Coast | Lady Elliot Island Eco Resort Great Barrier Reef . Seair has expressed their departure time as a hotel pick-up time but still charges a per person price and operates in the charter category. Everybody on the aircraft is there for the
specific purpose of a scenic return flight plus a day on Lady Elliott Island, yet they are the general public.
I offerred scenic return flights with a champagne breakfast on an island airstrip for six years, a shameless but improved copy of one of Seair's earlier trips way back when. I did not remove my departure time from my brochure. I simply put it in a different and as it turned out, better place on the brochure.
And you're right Aussie Bob. This was nothing to do with safety but everything to do with CASA not understanding their own regulations.
The Hot Air balloon operators offer a similar product with a single passenger fare and a departure time.
Nulli Secundus, if you sit down with pen and paper and think how you can package a product suitable for your location, I think there is good chance of success.
No - it shouldn't be this hard but then if it was easy, everybody would be doing it.