EASA invites comments on means of compliance for design of UAS operated in SAIL III

The European Aviation Safety Agency (EASA) is consulting on the Means of Compliance for operations over people.

The Airworthiness task force (AW TF), established In November 2022 under the UAS Technical Body (TeB), is developing means of compliance (MoCs) aimed at supporting, for Specific Assurance Integrity Level (SAIL) III operations, declarations of compliance to SORA OSOs linked with UAS design, therefore under the responsibility of the UAS designer. The MoCs provided in consultation address OSOs #5, #6, #18 and #24 as per AMC 1 to Article 11 of Regulation (EU) 2019/947. A further consultation will follow, focused in particular on MoCs to OSO#3 and OSO#19-20, completing the SAIL III compliance package.

Applicants who wish to propose the application of alternative standards to those referenced by the SAIL III MoCs should contact their Competent Authority. The proposal may need to be assessed by the AW TF and, if found appropriate, may be reflected in further revisions of the MoCs.

The declarations of compliance against the MoCs shall be provided with appropriate forms that will be made available at a later stage by EASA.

Official comments to the proposed Consultation Paper are to be filed through the EASA Comment Response Tool.

EASA guidelines for design approvals

After conducting the Specific Operations Risk Assessment (SORA), the operator determines the SAIL (the level of intrinsic risk of the operation) and identifies the level of robustness of the operational safety objectives (OSOs) to be demonstrated, as following, for the design related OSOs:

  • For SAIL I, II and III operations: an operator may use a drone with a class identification label or with a declaration of compliance of the drone with the technical OSOs. However, for compliance of technical mitigations (M2) and enhanced containment the NAA may ask to use a drone assessed by EASA through a design verification report too in these cases;
  • For SAIL V and VI operations (classified as High risk): the use of a drone with a type certificate according to (Regulation (EU) 748/2012) 2 (known as Part 21) is required;
  • For SAIL IV operations: a more appropriate, simplified and flexible option exists: the Design Verification Report.

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