SORA is the latest and hottest acronym which the UK CAA has added to its seemingly ever-increasing lexicon of impenetrable verbiage. We could even go full buzzword and suggest that SORA may be the key to unlocking UAS BVLOS in the UK, but only if you can find a RAE-F to assess your SAIL. Sorry.
So, what the hell is SORA, and do you need to worry about it?
SORA – The Basics
It stands for ‘Specific Operations Risk Assessment’. The aim is a good one: to attach some proper measurability to risk assessment. Let’s take an example. Suppose you plan to bungee jump from your favourite bridge using your own DIY setup. Is this safe? Well, doesn’t sound like it. So, you decide to take some precautions. You buy two pieces of elastic and tie one to each ankle (nothing like a bit of redundancy, huh?). You do a successful test with a shop mannequin which looks like it weighs about the same as you. You even chuck on your wife’s bike helmet for a bit of belt and braces. Nice, now you’ve introduced some mitigations for that hazard ‘may fall head-first into rocky river and bash brains out.’ The risk assessment looks fantastic(ish) on paper. But are you REALLY confident as you make that leap of faith from the bridge? Definitely not.
This is where SORA comes in. The intention is to quantify risk as precisely as possible. We might start with some statistics on bungee jumps. How often does the elastic break? What methodologies have been established to calculate precisely the relationship between mass of the person, elasticity of the rope and length of descent? What manufacturing standards exist for bungee elastic and head protection, and how comprehensively have they been tested. The aim is to get to a point where we can accurately assess the likelihood of death or injury in our initial condition (chunk on a bit of elastic and hope for the best) and our final mitigated condition (top-quality materials, highly experienced operator etc etc). Crucially, we want the likelihood of death of injury in that final condition to be at or below a commonly agreed level (1 in a billion maybe?).
So, what about drones?
The big challenge to regulators (the CAA here in the UK) is that drone operators want to do exciting things like deliver parcels or carry executive passengers. At the moment, those operators have the option to submit an Operational Safety Case (OSC) in the hope that they can persuade the CAA to give them the green light. The problem is that this invariably ends in something of a deadlock:
Operator: Please can I carry nuclear weapons on my drone?
CAA: Maybe, but show me how you will make it safe
Operator: How safe?
CAA: No more dangerous than manned aircraft
Operator: OK, here are 500 pages of design and operating procedures to persuade you
CAA (3 years later): Thanks for that. Is sounds kinda safe, but can you make it safer?
Operator: In what way?
CAA: Sorry, we can’t tell you that. It’s up to you to convince us
Operator (another 3 years later): Ta-da! Remember us? Check out this 1000-page risk assessment. This is SOO-per safe now.
CAA: Thanks. Not really sure it’s safe enough though….
Operator: Actually, let’s do roof surveys instead
SORA aims to remove as much of the subjectivity as possible from this process. It sets out a framework by which risks can be scored to a commonly agreed methodology, in theory simplifying the process to something akin to a questionnaire which spits out numbers rather than opinions. Crucially, there should be much less room for differences of opinion between applicants and CAA reviews, which everyone will be pleased about.
How does all this affect me?
Well, if you are a PDRA01 operator (i.e. you have a GVC, and a standard Operational Authorisation) then the answer is ‘not much’. Your life will continue as normal. In time, the SORA process is likely to enable the CAA to expand the range of ‘off the shelf’ PDRA options too. So, you may be able to access options like increased flight distances (e.g. for mapping large areas) or reduced separation distances more readily.
If you hold a current OSC, or intend to apply for one, then SORA most definitely will affect you. SORA is the ‘Acceptable Means of Compliance’ for all new OSC applications AND renewals, which means existing OSCs will need to be unpicked and reshaped.
What’s this SAIL stuff about?
One of the key elements of SORA is evidencing airworthiness. SAIL (Specific Assurance and Integrity Level) is similar to the EU’s ‘C-mark’ for drones in attempting to define product safety standards. The intention is that any drone manufacturer can seek a SAIL mark for a given product, and that these SAIL marks will bring with them a defined risk score. For example, a SORA application based on a ‘SAIL-2’ drone might fail but might be deemed compliant if resubmitted using a ‘SAIL-1’ drone.
One major fly in the SAIL ointment is that a new set of entities (RAE-F) needs to be appointed to provide SAIL ratings, as the CAA intends to devolve the process. Annoyingly, the EU already has a perfectly decent set of companies in place (e.g. TÜV Rheinland) to conduct its tests, but the CAA is intent on reinventing this particular wheel within the UK. How much enthusiasm there will be for companies to offer themselves as RAE-F providers remains to be seen.
Finally, how safe is ‘safe’?
One intriguing challenge faced by SORA is that it ultimately needs to put a price on a life. Or, at least, set a numerical value on an acceptable number of deaths from drones.
For now, the CAA has (for once) decided to accept the European view on this and has adopted the TLOS (Target Level of Safety) as follows:
Ground risks: less than one fatality per million hours
Air risks: less than one mid-air collision per 10 million flight hours (for self-separated flights)
There are some nice numbers to get your head around.
We offer consultancy on SORA applications. Get in touch now for a free initial call.