GM1 Article 11 Annex A – Guidance for the submission of compliance evidence to the CAA

CAA ORS9 Decision No. 46

1. Introduction
1.1 This annex is intended to serve as guidance to support an applicant with gathering, presenting, and retaining their compliance evidence as part of their UK SORA application. The term compliance evidence is used to emphasise the goal of providing evidence that demonstrates compliance to a regulation, requirement, or standard.
1.2 An applicant should consider what they are trying to demonstrate with their chosen compliance evidence. For example, if they are aiming to demonstrate compliance with a specific technical standard then the compliance evidence would likely be some form of technical data rather than an operations document. This is not to say that an operations document couldn’t be used as evidence, but it would be unlikely that it is specific enough to be considered compliance evidence for a technical standard, and so, on its own, would be unlikely to be accepted as compliance with the overall requirement.
What is a compliance approach?
1.3 In this context a compliance approach is meant as a systematic approach used to ensure an applicant complies with the relevant regulation, requirement or standard. The UK SORA Application Service is designed to support applicants to submit their compliance approach and compliance evidence in a structured format.
What is compliance evidence?
1.4 Compliance evidence is the term used to describe a piece of evidence used to demonstrate compliance with a regulation, requirement or standard. Compliance evidence may take several forms such as:

i) Flight logs.

ii) Technical data sheet.

iii) Flight tests.

iv) Design information.

1.5 Evidence used to demonstrate compliance should be relevant to the intended regulation, requirement or standard i.e. if the compliance evidence is a section or paragraph within a document then that section must be clearly referenced rather than submitting the entire document as evidence. For example:

i) Acceptable: Ref: Technical Manual 7602, Section 7, page 16.

ii) Not Acceptable: Ref: Technical Manual 7602.

Collecting, Presenting and Storing Evidence
1.6 When collecting compliance evidence, it is crucial that all relevant information is included. Any form of compliance evidence submitted to the CAA must be in a legible and understandable format.
1.7 Compliance evidence must be stored for the duration of the authorisation and be available to CAA assessors upon request. Where compliance evidence contains personal data, t is recommended to follow UK Government advice on General Data Protection Regulation (GDPR).
1.8 For each requirement in UK SORA, the Applicant must present compliance evidence to the CAA as follows:

i) The applicant enters a compliance statement into the UK SORA Application Service. A compliance statement is a simple statement (a single sentence typically suffices) which describes the method through which the Applicant has complied with the requirement. For example:

1.9 Requirement (CAA): “Effects of impact dynamics and immediate post impact hazards, critical area or the combination of these results are reduced such that the risk to population is reduced by an approximate 1 order of magnitude (90%).”

(1) Compliance statement (Applicant): “Calculation of the UAS deceleration with parachute deployed combined with flight testing shows that the ground impact is reduced by 1 order of magnitude.”

ii) Provide compliance evidence: the physical report(s) that evidence the compliance statement has been achieved. For example:

(1) Parachute deployment analysis report no.XYZ.pdf

(2) Parachute deployment flight test report no.ABC.pdf

Using the UK SORA annexes
1.10 The CAA has developed a reference system for applicants to quickly identify requirements that are relevant to their application. Below is some guidance on how to use this system.

Table 14 - Example Requirements

Level of integrity

Criterion Low (SAIL 2) Medium (SAIL 3) High (SAIL 4 to 6)
Technical issue with the UAS OSO1.L.I

OSO1.L.I

OSO1.M.I

OSO1.H.I

Level of assurance

Criterion Low (SAIL 2) Medium (SAIL 3) High (SAIL 4 to 6)
Technical issue with the UAS OSO1.L.A

OSO1.M.A

OSO1.M.I

OSO1.H.A
Using requirement codes
1.11 All UK SORA requirements have a requirement code, which may be used to find AMC and GM. Figure 7 shows an example of a requirement code for SAIL 2 at low integrity with a single criterion.

Figure 7 - Requirement codes single criterion

Representation of the requirement type, its number, robustness level required and robustness component

1.12 Some requirements have several criteria, this is displayed after the requirement number, prefixed by the letter C for example C2 shown below in figure 8.

Figure 8 - Requirement codes multiple criterion

Representation of the requirement type, its number, criterion (as requirements have several criteria, this is displayed after the requirement number), robustness level required and robustness component

Using the reference system

Integrity requirements

1.13 Requirement codes ending with the letter I (robustness component) represent integrity requirements and must be complied with. Example:

The applicant must meet the following requirements:

(a) Requirement 1.

(b) Requirement 2.

Assurance requirements

1.14 Requirement codes ending with the letter A represent assurance requirements and must be complied with. Example:

The Applicant must meet the following requirements:

(a) The Applicant must provide evidence of compliance with the Integrity requirements.

AMC

1.15 Requirement codes prefixed by the letters AMC may be used to demonstrate compliance with the requirement. AMC.OSO1.L.I relates to Low Integrity. Where AMC relates to a specific requirement or multiple requirements, the corresponding letter is used. For example:

(b) The standard 1234 may be used to demonstrate compliance with the requirement.

GM

1.16 Requirement codes prefixed by the letters GM explain how the applicant may comply and gives general guidance material relating to the overall requirement. GM.OSO1.L.A relates to Low Assurance. Where GM relates to a specific requirement or multiple requirements the corresponding robustness letter is used.
Additional Requirements
1.17 As the SAIL level increases the robustness level and the corresponding number of requirements may also increase. Using the tables provided, the applicant may identify additional requirements. In this example, SAIL 3 has medium integrity requirements OSO1.M.I in addition to low.

Above the additional requirement details section, coloured boxes with the relevant codes display any lower robustness requirement for ease of reference

1.18 Above the additional requirement details section, coloured boxes with the relevant codes display any lower robustness requirement for ease of reference. For example:

Lower robustness level requirements to be complied with:

• OSO1.L.I

• OSO1.L.A

1.19 Following the low robustness level requirements, additional requirements are listed in the same format as above.
1.20 Above the additional requirement details section, coloured boxes with the relevant codes display any lower robustness requirement for ease of reference. For example:

Lower robustness level requirements to be complied with:

• OSO1.L.I

• OSO1.L.A

1.21 Following the low robustness level requirements, additional requirements are listed in the same format as above.