Trust me we tried to get around the 'public' vs 'private' charter when CO demanded it for SMD2. CO asked for it due to some valid reasons, some of it being consumer protection.@:-)

Also the DoT is pretty clear on the art what constitutes an organisation that can do private charters. Just dropping 10 bucks in a pot when you enter the door to sign up probably doesn't do it. But hey, they should be knowing what they are doing.