Renewed rules in the special category (Part 10)

After a lengthy preparation, the so-called AMC amendment containing SORA 2.5 was published on the European Aviation Safety Agency’s (EASA) website on September 29. The renewed AMC (Acceptable Means of Compliance) describes the new methodology for mandatory risk analysis in the special operation category, which must be applied uniformly throughout the European Union. Applications for new operational authorisations should now be submitted in accordance with SORA 2.5, while incumbent operational authorisations (including the documentation of LUC holders) must be brought into line with SORA 2.5 within two years, as per the EASA decision. In our series of articles, we will review the most significant changes affecting the methodology.

Previously, we discussed the changes to the mandatory risk assessment in the special category following the introduction of SORA 2.5 in 9 articles. Previously, we have tried to show the changes in the methodology’s content. However, there are two significant procedural amendments “hidden” in the new AMC.

One modification is that steps 8 and 9 have switched; containment is now step 8, and operational safety objectives (OSOs) are in step 9.

The other change is that although SORA 2.5 still consists of 10 steps, according to the new AMC, the operator must first submit the application for prior approval after step 9, in which the authority checks the result of the SORA and its adequacy, the level of substantiation, and the appropriateness of the applicability of the OSOs.

The comprehensive security portfolio compiled in step 10 can only be submitted after a positive regulatory decision on steps 1 to 9, which, as the figure below shows, can also be negative. It is not yet clear to what extent this amendment will affect the regulatory procedure, but it is certain that the assessment of the comprehensive security portfolio will receive greater emphasis in the future.

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