You are bang on, I wrote a blog post on this and basically what it boils down to is that you must be 9.26kms away from anything larger than a "farmstead" if you wish to operate commercially under exemption...yeah I said farmstead.Thank you very much. I don't want to get an exemption, they are too limiting in where you can operate. I will go the SFOC route so my operating options are not constricted.
Seriously not kidding that's exactly what is written within the Advisory Circular (AC) N0. 600-004 4.2 (26). Effectively, for 99% of the commercial space this means there really is no "exemption". If you are looking to go commercial I am not a lawyer, don't play one on TV but I do have a pretty good handle on this stuff and also offer some services to Canadians in this area, look me up on Recon Aeral Media.