Simply having an RPL and doing commercial work is definately comparible to having a CPL and doing commercial work without on AOC, and it happens. There is no doubt the pilot in both instances (CPL and RPL) might be perfectly capable of performing whatever commercial flying they are doing. But how can we be certain, and how will we ever find out whether the pilot is operating safely, within the law, and within both his and his' equipments limitations. When there is no system of accountability and auditing, things fall through the cracks quickly. Let's just say the RPL doesn't fill in his battery logs as required (let's be honest it's a pain) there will simply be no indication at all of an impending failure. Take a nice rig with 6kg payload dropping out of the sky from 300ft, it can cause substantial damage, specially when photographing something like real estate (lots of buildings and people around)
Again, I'm not saying the regulation is perfect, but it still serves a purpose. As a manned pilot drones are a real concern, specially when guys are not clearly informed of the dangers and regulations. Remember, as a manned aircraft I am legally allowed to fly as high as I deem safe (outside of built up areas) as long as I'm not being a nuisance and that when it comes to RPAS I have right of way, which is very onerous for the RPL pilot. And drones are invisible in the sky, specially white ones.
PS. Helo pilots suffer the early onset of hypoxia at about 200ft AGL

