As you’re aware, it’s not the “video and pictures” that are the real issue requiring PfCO…. it’s the “remuneration or other valuable consideration” … you could be “delivering” something. The thing is there aren’t that many commercial uses for a drone that don’t include “video and pictures” … so people concentrate on this.
Somewhere (that I can’t now find) I’ve mentioned my brush with the CAA and photography, many years ago. I won my case on the “remuneration or other valuable consideration” (… and not knowing at take-off what my passenger (a professional photographer) was going to do … the old “you can’t retrospectively classify a hobby flight as commercial” thing). But they explained to me that the “purpose of the flight” is irrelevant … and the real reason they make the distinction between hobby and commercial (PPL/CPL in fixed wing flying) is the increased chance of a pilot taking that extra risk, or pushing the limits of safety, in order to earn that extra buck and/or keep the client happy.
Let’s face it - most people would do things (legal or not) for sufficient money that they wouldn’t do “as a favour”. And if it was enough, they could also find themselves taking that extra little bit of risk. It does make sense … imo. Hence the weight put on Ops Manuals and risk assessments in PcCO.
As I see PfCO, whilst they never quote that aspect anywhere I still believe this is the better justification for it than the simple “remuneration or other valuable consideration” criteria. But, putting the “extra risk …etc” into black and white wording is nigh on impossible.
So - we are stuck with what we have.