Sorry if I am not able to see this issue in the required detached manner. I speak as one who has spent a lot of time and ennergy in organising an event, which struggles on and remains under a cloud because officals are appearing and couning me and the other musicians as performers.
Section 182's numerical requirements refer to specifically to performers. Not musicians, members of the public or to customers.
It would be obvious to anyone, without a hidden agenda, visiting that they are not witnessing a performance.
The onus is on the officers to define the word, for they remain the only ones who are seeing performers and a performance.