The whole topic is insanely hilarious that people think this is something to concern themselves with. If you think that the inspectors at the FAA give one rat's ass about any of this, or are out to get you, you medical is what is really at risk. I just went through a 6 month, I hate to even call it an ordeal, with the FAA after I bellied in my plane and dealt directly with 5 inspectors and a supervisor across 4 different FSDOs in Milwakee, Philly, Long Beach, and finally So Florida where I finally got my 709 ride done in .6 with 2 T&Gs and a full stop. I also met with the entire FSDO and NTSB contingent at OSH trying to figure out how to make this all fit into my schedule without having to issue a suspension in a month when I wouldn't have it done, since they couldn't schedule an inspector to do it that week (I offered to rent a plane and do it that evening, and to the initial guy's credit, he made some calls to try to get it done). We came up with putting my ticket on deposit, and when the Philly inspector cancelled on me, he sent it back to me, "It wouldn't be fair to you for us to hang onto it." Those were his words, think about that the next you think the FAA inspectors are out to screw you. Heck, when I finally got the ride scheduled, the Seminole I reserved had been sent out,it was the only retract I could find on the field. The inspector made some phone calls to his contacts and found a plane for me to use.
People need a serious reality check when it comes to this stuff. They have no concern with this minutia, they have enough keeping their current, 90% 135/121, files cleared. They could really give a **** less about the chief counsel's interpretations, they use the FARs and interpret them for themselves.
Way back when when I was a pretty fresh PP and had been making at least part of my living as a photographer since high school and had a full studio, I asked at the Long Beach FSDO which was right next door about this very thing, "Hey, I have a photography business, is it ok if I shoot aerials out of a 152?" "That's fine" Simple as that. These are the people you are concerned with, not Chief Counsel, you'll never get there. There is not an inspector who cares, and besides, the worst that would happen if the gates of hell burst open and the Furies descended upon you with all the legal might FAA possesses, you would be told to please stop doing that.
Remember, inspectors are pilots and mechanics, not lawyers and cops.
I think I'd better pursue cat videos. I've got three lazy bastards around here that need to start pulling their weight... now where's that goldfish bowl and my laser pointer??