An opinion. Flying Clubs operating at mil bases should be operating under CAA - JAA - EASA rules (bit of overlap at present). In many respects therefore the military concept of DH is nothing new in that an RTF or FTO must have an Accountable Manager. Having read a DH's delegation letter and considered its implications for that individual the outcome is very similar in obligation to the Accountable Manager. ASMS has been issued by ICAO long before MAA stood up and a scan through ICAO 9859 Second edition published in September 2009 will indicate to the reader many elements have been used in various MAA documents. ICAO and JAA Ops recommend operators with ac under 5700kg have an ASMS but it is not obligatory.
The key in my mind would thus be when the MAA begins examining flying clubs are they operating to a high enough standard of demonstrated safety equal to the rules being applied by MAA to military ac. Thus if a Club can show it has an Accountable Manager (normally HOT) and demonstrates an ASMS the pressure will be reduced. Risk management and insurance will be key pillars I think. If ASMS is seen as a box ticking exercise the risk of repeating the mistakes identified by HC will exist. Setting up an RTF or FTO with this system is well within our capabilities. Yes, more paperwork but most clubs having FOBs the meat of which can be used to create the key 4 elements of an SMS - I believe it needs brain power more than paper to sit down and ident as many risks as possible and how they are handled. This is not unhealthy if you accept MAA is with us and it will not be long before the spotlight is on Flying Clubs.
Just my views, hopefully helpful and I fully accept there will be many others. I just hope working together we can avoid closure of any mil flying clubs because of risk aversion.
Happy landings,
Mos
