Thank you tuc, you put it far better than I, as ever. As you say, both military and civilian personnel within DSA (including the DG) are subject to the MOD CoC, just as they were previously when that CoC subverted Air Safety some three decades ago to leave it in the parlous state it is now. The signs on the door may change, the reality does not.
Fortissimo, the analogy you make with civilian aviation does not bear scrutiny. Yes, both systems come under one SoS (Defence and Transport), but the civilian Regulator and Investigator are separate and independent of each other, whereas in military aviation they come under one DG. If his investigator finds (as it should) the regulator to have failed utterly in ensuring airworthiness in investigating accident after accident is he going to severely censure himself? The throttling of UK Military Air Accident Investigation continues unhindered whereas the AAIB can find Regulator or Operator equally to have failed.
The military operator is of course the elephant in the room, and its principal guise is that of the RAF. It is that Service's Very Senior Officers that first caused the subversion by issuing illegal orders and by illegally granting RTS's to knowingly unairworthy aircraft. It is that Service's Very Senior Officers that have ensured the cover up of that subversion ever since. Thus was the Nimrod Report subverted, thus was the MAA founded on a lie.
It is being freed of such baleful influence that is the essential pre-requisite of UK Military Air Safety reform. That can only happen when the MAA and MilAAIB are outside the MOD, and thus independent of it and of each other.