Possum1, you have taken the ideas of the good Mr Fice as your own, without acknowledging them.
Direct Air AAT
Unfortunately for you, your grammar book, your (fictional?) FOI, the estimable Mr Fice and the whole industry, that interpretation of CAR 206 was
rejected by the Federal Court, and CASA's view prevailed.
Send the details of your operation to CASA head office with your reasoning and see what happens...