The procedure for carrying out the SORA analysis is changing. On 8 November 2022. JARUS published a series of documents proposing changes to the adopted SORA methodology. These were subject to external consultation and comments could be submitted until March 2023. The new SORA, i.e. SORA 2.5, differs mainly in the methods of adjacent area assessment and airspace risk assessment. This paper, which is an introduction to the analysis of the solutions introduced in the so-called “new SORA”, focuses on the changes in terms of definitions and abbreviations used, as contained in Annex I – Glossary of Terms.The proposals for changes to Annex I – Glossary of Terms – submitted for consultation under SORA 2.5 (dated November 2022) are relatively comprehensive and include both new, relative to SORA 2.0, terms to be defined and the amendment of terms contained in SORA 2.0. The document notes that this glossary is intended to assist applicants in using the SORA guidelines. The definitions represent meanings recognised by the majority of the JARUS WG SRM team, but do not reflect the views of national authorities as to their meaning. At the same time, where possible, definitions have been based on those used in ICAO and other NAA regulatory material.New to the previous document is the introduction of a list of abbreviations used in particular in unmanned aviation and specific to it. This list is presented below, but no translation has been made – in most cases, the abbreviations and terms themselves are commonly used and understood in the aviation community, without the need for translation into Polish.
-AEC airspace encounter category
-AEH airborne electronic hardware
-AIP aeronautical information publication
-ANSP air navigation service provider
-ARC air risk class
-AGL above ground level
-AMC acceptable means of compliance
-AO airspace observer
-ATC air traffic control
-ATZ aerodrome traffic zone
-BVLOS beyond visual line of sight
-C2 command and control
-C3 command, control and communication
-COTS commercial-off-the-shelf
-CRM crew resource management
-DAA detect and avoid
-ERP emergency response plan
-EVLOS extended visual line of sight
-FHSS frequency-hopping spread spectrum
-FTS flight termination system
-GRC ground risk class
-GM guidance material
-GNSS global navigation satellite system
-HMI human machine interface
-HF human factors
-IARC initial air risk class
-ICAO international civil aviation organisation
-IGRC intrinsic ground risk class
-ISM industrial, scientific and medical
-JARUS joint authorities for rulemaking on unmanned systems
-METAR aviation routine weather report (in (aeronautical) meteorological code)
-MCC multi-crew cooperation
-MTOM maximum take-off mass
-NAA national aviation authority
-OM operations manual
-OSO operational safety objective
-PDRA predefined risk assessment
-RCM remote crew member
-RCP required communication performance
-RF radio frequency
-RLP required C2 link performance
-RP remote control
-SAA sense and avoid
-SAIL specific assurance and integrity level
-SLA service-level agreement
-SMS safety management system
-SOP standard operating procedure
-SORA specific operations risk assessment
-STS standard scenario
-SW software
-S&A see and avoid
-TCAS traffic collision avoidance system
-TLOS target level of safety
-TMPR tactical mitigation performance requirement
-UA unmanned aircraft
-UAS unmanned aircraft system
-UTM UAS traffic management
-VHL very high level airspace
-VLL very low level
-VLOS visual line of sigh
Annex I contains a list of approximately 150 terms (their acronyms, if any) with their definition or description. The focus of this paper is on those introduced in Annex I of SORA 2.5 (relative to version 2.0), either the definition of the term has changed or the term is of fundamental importance in unmanned aviation law.
Among the definitions introduced in the SORA 2.5 proposal is that of an airspace observer (AO), i.e. a person who assists the pilot of an unmanned aircraft by performing unassisted observation (scanning) of the airspace in which the unmanned aircraft is operating in order to identify potential hazards in the air.
A new definition is Adjacent airspace, which is defined by reference to the relevant provisions of the Main Document – This is the airspace adjacent to the operational airspace, as defined in paragraph 1.4 of the Main Body. Similarly, Adjacent ground area (Adjacent ground area – The ground area adjacent to the ground risk buffer) and Ground risk buffer (Ground risk buffer – An area on the surface of the earth, which surrounds the footprint of the contingency volume and that is specified in order to minimise the risk to third parties on the ground in the event of the UA leaving the contingency volume) are defined by reference to clause 1.4 of the Main Document.
What is new is the introduction of a definition of a congregation of persons – a concept that is extremely important in the context of flight operations based on European regulations for unmanned aircraft operations. According to SORA 2.5, a congregation of persons is an area from which persons cannot quickly move away in the event of a potential failure of an unmanned aircraft, due to the density of persons. Leaving aside the logical flaws of this definition, the standardisation coincides with European legislation. Indeed, the provision of Article 2(3) of Implementing Regulation 2019/947 defines the concept of a gathering of persons – these are those gatherings where the density of persons present prevents them from moving. This concept should therefore not be directly equated with an assembly within the meaning of the Act of 24.07.2015. – Law on Assemblies nor with a mass event within the meaning of the provisions of the Law of 20.03.2009 on Security of Mass Events. It should be emphasised that an assembly of persons within the meaning of the above-mentioned provision of Executive Order 2019/947 may also mean a small number of persons, however, being in such a place where free movement is prevented, e.g. due to obstacles in the form of walls of buildings, fences, a busy roadway, etc.
A newly introduced concept in SORA 2.5 is the maximum take-off mass (MTOM), i.e. the maximum weight of an aircraft, including payload and fuel, specified by the manufacturer or constructor, at which the aircraft can be operated, which is only defined in the document under review. Due to the universality and comprehensibility of this concept, SORA 2.5 has an ordering value in this respect.
One of the revised definitions is the concept of accident (accident). In SORA 2.0, an accident was defined as an unplanned event or series of events resulting in death, injury or damage to or loss of equipment or property. The new SORA 2.5 defines accident more broadly by relating the scope of meaning to the definition of an aircraft accident set out in Article 2(1) of Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and prevention of accidents and incidents in civil aviation and repealing Directive 94/56/EC. The European definition states that an ‘accident’ means an occurrence associated with the operation of an aircraft which, in the case of a manned aircraft, takes place from the moment any person boards the aircraft with the intention of flying until such time as the persons disembark, or, in the case of an unmanned aircraft, takes place from the moment the aircraft is ready to move for the purpose of flight until it comes to a stop at the end of the flight and the propulsion system is shut down, in which: (a) a person on board the aircraft suffers death or serious injury as a result of being on board the aircraft, or direct contact with any part of the aircraft, including parts that have been detached from the aircraft, or the direct action of the aircraft engine blast, except when the injury is due to natural causes, self-inflicted or inflicted by other persons, or when the person is injured while hiding outside areas normally accessible to passengers or crew members; or (b) the aircraft sustains damage or structural failure which adversely affects the structural strength, performance or controllability of the aircraft, and would normally require major repair or replacement of the affected component, except for engine failure or damage, when the damage is limited to the engine itself (including its cowlings or accessories), propellers, wingtips, antennas, probes, blades, tyres, brakes, wheels, fairings, panels, landing gear flaps, wipers, aircraft skin (such as small dents or holes) or minor damage to the lifting rotor blades, tail rotor blades, landing gear and those caused by hail or bird strike (including holes in the radome antenna cover); or (c) the aircraft is missing or access to it is completely prevented. Minor language modifications have been made to the definition of an accident in the new SORA due to the peculiarities of unmanned aviation, but the premise of the definition and its material scope remain essentially the same.
An extended definition in the new SORA is the concept of emergency procedures, understood as a planned course of action developed by the operator of an unmanned aircraft to respond effectively to an emergency. They refer to the control of the aircraft to return to a state where the operation is under control, or to minimise hazards until the flight is completed. Emergency procedures include actions performed by the pilot of the unmanned aircraft or by the aircraft.
It should be noted that SORA 2.5 refers more often than SORA 2.0 to the content of the Main Body in terms of definitions. As an example, concepts related to the application procedure for an operating authorisation of an aeronautical authority are directly referred to in the Main Body, e.g. for the definition of applicant, Competent Authority or Competent Third Party.
