Folks,
During the reform program overseen by the PAP from late 1996 until 1999, one of the policy positions agreed between the PAP and the then CASA Director (but, very significantly, not the control freaks of the "Iron Ring") was that "A to A" joy-flights/sightseeing flights" in small GA aircraft up to six POB would operated under the then proposed Part 91, without AOC.
Quite simply, the AOC system, that was never intended for other than RPT, had filtered down through the whole system, was not judged to add anything to air safety outcomes, compared to simply complying with the basic "rules if the air".
As AOC "conditions" have progressively become more onerous,( regulatory creep) these conditions have become more and more divorced from reality --- and held hostage to the whims and prejudices of FOIs, whose lack of knowledge and experienced is continually obvious. I feel really sorry for the good FOIs around (and there are some, carrying the rest) whose reputations suffer for the sins of the incompetents.
For those of us who remember the old "Charter" licenses, the very first Charter License I obtained, for operations in FNQ, entailed a "manual" that was about 12mm thick, most of which was the heavy cardboard cover. The only important page was page 2, which simply stated that all operations will be conducted in accordance with the Air Navigation Act, Air Navigation Regulations, Air Navigation Orders and the AIP.
The only thing that the present AOC requirements does is greatly increase cost and complexity, and the opportunity to become an "inadvertent criminal", without adding one iota to the cause of air safety.
Sadly, many of you, whom I meet, do not know another system, and don't seem to be able to cope with the idea of operating without a modern CASA style Operations Manual/Exposition hanging like a noose around your neck.
Finally, on the subject of "negotiating" law.
jus publicum privatorum pactis mutari non potest
public law cannot be changed by the agreements of private individuals
Sadly, given the shambles that is the Act and Regulations, it happens all the time.
Tootle pip!!