14 CFR §107.31
·
§107.39
·
§107.51
·
§107.145
SORA 2.5
·
NRC BEPU 95/95
·
PX4 v1.16.0 architecture
·
Wilks tolerance bounds
Quantitative safety cases for FAA Part 107 waivers.
Kalman Aero is an engineering consultancy that builds Monte Carlo–based safety analyses, Concepts of Operations, and systems engineering deliverables for BVLOS, operations over people, Part 108 readiness, and beyond-§107 drone operations. Built on KASPR — our quantitative safety reasoning platform — every analysis is anchored in a physics-faithful digital twin of your specific aircraft and produces a SORA 2.5–aligned safety case at NRC nuclear-grade statistical rigor. Led by a Principal NASA GN&C engineer with program credits on Orion/Artemis III, the International Space Station, and Gateway — applying the same uncertainty-quantification and proximity-safety methods used on human-rated spaceflight and commercial visiting vehicle acceptance.
Engineering services across the drone safety lifecycle.
Kalman Aero delivers eleven engineering services spanning FAA waiver support, Part 108 readiness, Part 135 certification, Monte Carlo analysis, and Safety Management System documentation. Engagements range from a $5,000–$9,000 narrative-only entry-tier for benign §107.31 BVLOS missions to multi-year Enterprise Program retainers for state DOTs, FAA BEYOND participants, and insurance underwriters. Each engagement is fixed-price or retainer-based with a written scope agreed before work begins. Prices shown are the STANDARD-scope starting band. Each service extends to HIGH scope (+20–30%) for complex operations or HIGHEST scope (+50–100%) for novel or contested-airspace operations. Multi-site, enterprise, and Part 135 engagements are quoted individually.
Core services
Safety Case Analysis for FAA Part 107 Waivers
STANDARD scope: $12,000 – $18,000
HIGH scope: +20–30% · HIGHEST scope: +50–100%
Turnaround: 3–4 weeks
Deliverable: a written safety case and supporting technical appendix aligned with FAA Part 107 waiver evaluation criteria and JARUS SORA methodology, delivered with full reproducibility artifacts including the analysis package, written analysis, and SHA-256–anchored audit trail.
- Hazard identification and mitigation analysis for
§107.31BVLOS,§107.39over people,§107.51altitude/speed, and§107.145over moving vehicles. - Probabilistic risk model covering ground and air risk with quantified assumptions.
- Performance-based mitigation arguments tied to your specific ConOps, aircraft, and operating area.
- Cross-references mapped to FAA Order 8040.6 and AC 107-2 evaluation factors.
- Anchored in a Monte Carlo ensemble of your specific airframe and operational scenario, with statistical confidence intervals computed via Wilks 1-sided 95/95 (the NRC nuclear safety standard).
Operational Volume and Flight Envelope Analysis
STANDARD scope: $18,000 – $28,000
HIGH scope: +20–30% · HIGHEST scope: +50–100%
Turnaround: 4–6 weeks
Deliverable: a technical report defining the operational volume, contingency volume, and ground risk buffer for a specific operation, with Monte Carlo–derived containment probabilities computed across an N=59 (or higher, customer-specified) Monte Carlo ensemble.
- EKF-based state-estimation model of your aircraft under nominal and off-nominal conditions.
- Wind, GPS dropout, and link-loss uncertainty propagation through the trajectory.
- Operational volume and
1-in-10⁶containment buffer sized to your aircraft performance envelope. - Flight-envelope limits justified with quantified margins — ready to attach to a waiver or underwriting file.
Custom Monte Carlo Simulation Development
STANDARD scope: $28,000 – $45,000
HIGH scope: +20–30% · HIGHEST scope: +50–100%
Turnaround: 6–10 weeks
Deliverable: a purpose-built Monte Carlo simulation of your operation, delivered with full reproducibility artifacts (analysis package, written analysis, SHA-256–anchored audit trail) for independent verification. Suitable for novel operations, Part 135 submissions, Part 108 readiness, and insurance portfolio review.
- Full uncertainty quantification across aircraft dynamics, environment, sensor, and human-factor variables.
- Ten-thousand–run ensemble output with sensitivity analysis identifying dominant risk drivers.
- Airframe digital twin of your specific aircraft — geometry, inertia tensor, motor/propeller thrust curves, drag coefficients, sensor stack — built and validated before the ensemble runs.
- Written report written to FAA, EASA SORA, or underwriter audience as specified at kickoff.
Concept of Operations (ConOps) Development
STANDARD scope: $10,000 – $15,000
HIGH scope: +20–30% · HIGHEST scope: +50–100%
Turnaround: 3–5 weeks
Deliverable: a complete Concept of Operations document written to FAA, Part 108, or Part 135 standards, suitable for waiver applications, certificate applications, and internal program documentation.
- Mission description, operational environment, and stakeholder analysis.
- Aircraft and subsystem descriptions with interface definitions.
- Normal, contingency, and emergency procedures documented at the level FAA reviewers expect.
- Written to ARP4754A, NASA SE Handbook, and FAA systems engineering conventions.
Core 5 — BVLOS Waiver Narrative Authorship
STANDARD scope: $5,000 - $9,000
HIGH scope: +20-30% · HIGHEST scope: +50-100%
Turnaround: 2-3 weeks
Deliverable: a complete FAA-formatted §107.31 BVLOS waiver narrative with supporting attachments — hazard identification, mitigation arguments, operational procedures, and cross-references to FAA Order 8040.6, AC 107-2, and the §107.31 Section-Specific Evaluation Information. Suitable for benign operations: rural overflight, sparse population, daytime, single small aircraft with defined operational volumes.
- Waiver narrative authored to the FAA's published §107.31 evaluation factors, with all attachments and supporting documentation.
- Adjacent waiver sections covered: §107.39 over people, §107.51 altitude/speed, §107.145 over moving vehicles.
- One round of revision after FAA initial response (RFI handling) included.
- Entry-tier engagement designed for benign missions where narrative is sufficient. For complex operations — urban airspace, multi-aircraft, DAA Cat C, custom airframes, contested airspace — or for Part 108 transition readiness, narrative alone is insufficient; see Core 1 (Safety Case Analysis) for the quantitative engagement.
Extended engineering practice
Safety Management System (SMS) Documentation
Retainer band: $36,000 – $120,000/year
6–12 weeks initial build
Complete SMS documentation package meeting Part 108 compensated-BVLOS requirements, with optional ongoing retainer for audit support and change management. Retainer pricing band: $36,000 – $120,000/year, monthly cadence.
Systems Engineering and Requirements Analysis
Project-based: $25,000 – $75,000 typical
varies by scope
Learn more →Systems engineering deliverables from early-phase requirements capture through verification and validation planning, drawing on NASA human-spaceflight SE practice.
Means of Compliance Authorship (Part 108 Airworthiness)
Per-MoC document: $35,000 – $90,000 typical
8–16 weeks
Means of Compliance documentation for drone manufacturers pursuing FAA Airworthiness Acceptance under Part 108, authored against ASTM consensus standards.
Specialist services
Detect and Avoid (DAA) Validation and Test Planning
STANDARD scope: $18,000 – $30,000
HIGH scope: +20–30% · HIGHEST scope: +50–100%
4–8 weeks
Quantitative DAA performance analysis, validation test planning, and compliance documentation against ASTM F3442 or RTCA DO-365.
Incident Investigation and Technical Expert Support
Hourly: $375 – $550 · Retainer band: $15,000 – $60,000 per matter
engagement-specific
Learn more →Independent technical root cause analysis and expert engineering support for drone incidents, FAA investigations, insurance claims, and litigation.
Part 135 Certification Technical Support
Per-engagement: $75,000 – $250,000+ over 16–32 weeks
16–32 weeks
Full technical support for operators pursuing Part 135 air carrier certification for drone operations, working alongside your certification team and FAA POI.
About KASPR — the platform behind every analysis.
KASPR — Kalman Aero Safety and Probabilistic Risk-analysis — is the quantitative safety reasoning platform that produces every Kalman Aero deliverable. It isn't a script library or a templated report generator. It's a dynamic, pluggable, end-to-end aerospace simulator and safety-analysis pipeline, built from human-spaceflight GN&C engineering practice and adapted purposefully for unmanned aviation.
What KASPR does.
Given your aircraft, sensor stack, operating environment, and mission profile, KASPR builds a high-fidelity digital twin, runs Monte Carlo ensembles of physics-faithful flight outcomes, and computes SORA 2.5–aligned safety figures across the full framework: Ground Risk Class (GRC), Air Risk Class (ARC), Detect and Avoid (DAA) performance, mitigation effectiveness, Specific Assurance and Integrity Level (SAIL) determination, and Operational Safety Objectives (OSO) compliance. The output is a defensible quantitative safety case — not narrative argument, not qualitative hazard lists.
How KASPR is built.
PX4 v1.16.0 architecture — reference baseline, with extensibility to other flight software stacks.
KASPR's reference flight software mirrors PX4 v1.16.0 — same controller cascade, same state-estimation pattern, the architecture flying on millions of commercial and research drones today. This is a clean-room re-creation against documented PX4 behavior, not a fork. For operations running ArduPilot, custom autopilot architectures, proprietary flight software, or any non-PX4 flight-software stack, KASPR can construct a flight-software digital twin matching your platform — built and validated against your documented architecture as part of engagement scope.
24-state Extended Kalman Filter — reference implementation, with extensibility to alternative sensor stacks and filter architectures.
KASPR's reference state estimator implements the PX4 EKF2 pattern with block-sequential GPS position and velocity updates — the same sensor-fusion technique applied operationally on ISS visiting vehicle proximity navigation, now characterizing GPS dropout, link degradation, and sensor-fusion behavior for your drone operation. For operations with alternative sensor stacks — LiDAR, radar, alternative GNSS or GNSS-denied configurations, custom IMU stacks, electro-optical fusion — or non-PX4 state-estimator architectures, KASPR constructs the matching sensor models and estimator as part of engagement scope.
Pluggable airframe digital twins.
Every customer engagement begins with construction of a high-fidelity simulation model of your specific aircraft. The reference modeling pattern covers multirotor platforms — geometry, inertia tensor, motor and propeller thrust curves, drag coefficients, sensor stack — built and validated before any ensemble runs. Fixed-wing, hybrid VTOL, lift-plus-cruise, single-rotor, and tilt-wing airframes are constructed as part of engagement scope, with propulsion, control surface, and aerodynamic models matched to your platform. Generic-drone modeling cannot capture your operation's actual risk envelope. We build yours.
Methodology engine library.
Default Wilks 1-sided 95/95 tolerance bounds (the U.S. NRC nuclear best-estimate-plus-uncertainty standard with 35+ years of regulatory acceptance), with Hanson-Beard, Clopper-Pearson, Bayesian Beta-binomial, and bootstrap engines available for figures of merit that require different statistical approaches. The right method for the right figure of merit, not a one-size-fits-all toolkit.
Cross-check registry with primary-source provenance.
Every assumption, every parameter, every methodology choice is traceable to a primary source — regulatory references, peer-reviewed literature, vendor specifications. Regulators and underwriters can audit any single decision without traversing internal documentation.
Full reproducibility.
Every analysis carries SHA-256 hashes of every input file and the specific KASPR commit SHA used to produce it. Independent verification is built in. Any party with access to KASPR and the input files can re-run the analysis and verify every number — a standard deliverable, not an upcharge.
Why KASPR matters for your operation.
Today, narrative argument is sufficient for benign BVLOS operations — rural, sparse population, daytime, single small aircraft with defined corridors. The FAA approves these on narrative-heavy applications, and Kalman Aero authors them too (see Core 5 below). But narrative alone is increasingly insufficient for complex operations: urban airspace, multi-aircraft, Detect-and-Avoid Category C, custom airframes, and contested airspace receive substantially harder FAA scrutiny today, with quantitative evidence requirements explicit in the §107.31 Section-Specific Evaluation Information. The proposed Part 108 framework codifies this further — once finalized, even benign operations will need quantitative compliance evidence.
The proposed Part 108 framework — currently in final-rule review — codifies this further. Part 108 establishes a performance-based regulatory structure with five risk categories, two operator authorization tiers (Permit and Certificate), explicit detect-and-avoid and electronic-conspicuity standards, and SAIL-aligned risk assessment. Operations that today rely on case-by-case §107.31 waiver narratives will need to demonstrate quantitative compliance against published Part 108 performance criteria.
KASPR produces the quantitative case to either standard: §107.31 waiver evaluation today, Part 108 performance demonstration tomorrow. Same engine, same digital twin construction, same Wilks 95/95 statistical rigor. The methodology is consistent whether the audience is an FAA evaluator, an underwriter pricing a novel operation, or a state DOT verifying public-safety BVLOS readiness.
KASPR is shaped by NASA experience.
The same engineering principles that govern human-rated spaceflight rendezvous and proximity operations — uncertainty quantification at calibrated confidence levels, full state-vector traceability, independent verifiability of every reported number, methodology defensibility against external review — underpin every KASPR analysis. Drone operations don't need spaceflight overhead. They need spaceflight rigor, applied at the right scale for unmanned aviation. KASPR brings that.
Specialized channels.
Kalman Aero's services are engaged directly by drone operators across the United States. The channels below serve three additional audiences whose engagement structure, procurement path, or use case differs from a standard operator engagement.
For Aviation Law Firms
Kalman Aero works as a technical subcontractor for aviation law firms delivering waiver, exemption, and certificate packages to their clients. The engagement is billed to the firm, deliverables can be branded or unbranded, and the engagement can be structured to preserve attorney-client privilege when retained through counsel under appropriate retention agreements. Useful when the FAA requests quantitative analysis that exceeds the firm's in-house capability.
Litigation support — including independent technical reconstruction of drone-incident flight dynamics, sensor performance, and failure-mode evolution — is also available with methodology suitable for expert technical testimony, supported by SHA-256–anchored audit trails.
Discuss a subcontracting arrangement →For Aviation Insurers and Underwriters
Novel drone operations often land on underwriting desks without actuarial precedent. Kalman Aero provides retained technical risk review for insurers and MGAs — reviewing submissions, producing standardized per-mission casualty-rate distributions and corridor-excursion envelopes for insurance pricing, and supporting underwriting decisions for BVLOS, Part 137, and Part 108 operations.
Retainer range: $36,000 – $120,000/year, monthly cadence options. Per-submission engagements also available.
For Public Agencies and Program Participants
State DOTs, municipal public safety departments, FAA BEYOND program participants, and federally funded research programs engage Kalman Aero for independent quantitative safety analysis on UAS operations with public-interest requirements. Work is structured to fit federal and state procurement conventions, with deliverables formatted to support agency reporting and public release where required.
Engagements can be structured as Enterprise Program multi-year retainers for state DOTs and FAA BEYOND participants running ongoing UAS programs.
Discuss a public-sector engagement →Why operators choose Kalman Aero.
Built on human-spaceflight proximity expertise — same methods, now applied to drones.
Kalman Aero is led by a Principal NASA GN&C engineer with program credits across Orion/Artemis III crewed lunar vehicle, the International Space Station, and the Gateway lunar outpost. As the ISS Visiting Vehicles GN&C expert, this engineer built high-fidelity digital twins of arriving spacecraft — Dragon, HTV-X, Axiom, and others — and plugged them into NASA's human-rated simulator to evaluate their proximity operations and rendezvous safety cases against ISS approach trajectories. KASPR applies that same methodology to drones: build a digital twin of your specific aircraft, plug it into KASPR's physics-faithful simulator, evaluate your operation's safety case at human-rated statistical rigor.
Digital twin of your specific aircraft, built into every engagement.
Every Kalman Aero engagement begins with construction of a high-fidelity digital twin of your specific aircraft — airframe geometry, inertia tensor, motor/propeller thrust curves, drag coefficients, sensor stack — built and validated against your operational characteristics before the analysis ensemble runs. Generic-drone analysis can't capture your operation's actual risk envelope. We build yours.
Aerospace credentials, not aviation paperwork.
Kalman Aero is led by an engineer with fifteen years of human-spaceflight flight-dynamics and risk-analysis experience — Principal GN&C engineer across NASA programs, with space systems engineering work at the Johns Hopkins University Applied Physics Laboratory. The same uncertainty-quantification, sensor-fusion, and proximity-safety methods that underwrite human-rated spaceflight underwrite every Kalman Aero engagement. No outsourced templating, no boilerplate.
Built for FAA and SORA reviewers.
Deliverables map directly to the FAA's published §107.31 Section-Specific Evaluation Information, FAA Order 8040.6, AC 107-2, and JARUS SORA 2.5. Where the FAA has published performance criteria — and §107.31 is explicit on what is required — Kalman Aero shows the math against those criteria, not around them.
Turnaround measured in weeks, not quarters.
Most safety cases deliver in three to four weeks from kickoff. Operational volume analyses in four to six. Custom simulations in six to ten. Fixed price. Written scope. No surprises.
Engineering rigor, not regulatory advocacy.
Kalman Aero produces the quantitative analysis. You or your counsel own the submission, the narrative, and the relationship with your FSDO. That separation keeps the engineering defensible and keeps you in control.
How the analysis is built.
The methods below are standard practice in human-rated spaceflight, applied here to unmanned aviation. The FAA's published §107.31 BVLOS evaluation guidance is explicit on what reviewers look for: quantitative evidence of state knowledge, command-and-control link performance, detect-and-avoid effectiveness, and operational containment. Narrative argument and qualitative hazard lists routinely fall short of this standard. Each block below is one of the quantitative techniques KASPR brings to that bar.
Monte Carlo simulation.
Each operation is modeled as a stochastic process. Aircraft dynamics, wind, sensor noise, link latency, pilot response, and failure modes are each represented as probability distributions. Ensembles are run at the statistical confidence the customer's operation requires — N=59 by default for Wilks 1-sided 95/95 tolerance bounds (the U.S. NRC nuclear safety standard with over 35 years of regulatory acceptance), upsized to N=100+ for higher-confidence engagements. KASPR's methodology library also supports Hanson-Beard, Clopper-Pearson, Bayesian Beta-binomial, and bootstrap engines where the customer's regulator prefers an alternative.
Extended Kalman Filter state estimation.
For operations sensitive to GPS dropout, link degradation, or sensor fusion performance, KASPR's 24-state Extended Kalman Filter — mirroring the PX4 EKF2 pattern with block-sequential GPS position and velocity updates — predicts how aircraft state uncertainty grows during the operation. This defines contingency volumes with a quantified margin rather than an engineering guess. The same technique is applied operationally to assess ISS visiting vehicle proximity navigation performance across multiple commercial and international docking missions.
Uncertainty quantification.
Every input to the analysis is documented with its assumed distribution, its source, and its sensitivity rank. The resulting uncertainty envelope is propagated through the full model so the output confidence interval is explicit — not buried.
Flight-envelope analysis.
Aircraft performance is characterized across the full range of commanded states. The operating envelope is then defined with margin against loss-of-control boundaries, derived from the same techniques used for aircraft flight-test planning.
Reproducibility and audit trail.
Every Kalman Aero analysis carries SHA-256 hashes of every input file and the specific KASPR commit SHA used to produce the report. Any party with access to KASPR and the input files can independently re-run the analysis and verify every number. This complete audit chain from scenario inputs through to rendered analysis is a standard deliverable, not an upcharge.
From first call to delivered analysis.
Sample analysis review (no cost, a focused read).
Download our Reference Analysis sample — a demonstration of KASPR's methodology applied to a benign rural-corridor BVLOS scenario. Read it before the discovery call so the conversation can focus on your specific operation, not on how the methodology works. Your own engagement will go deeper: full quantitative ARC and DAA simulation, custom airframe modeling, and customer-specific mitigation modeling, rather than the narrative framing used in the baseline sample.
Download sample analysis →Discovery call (30 min, no cost).
You describe the operation, the regulatory target, and the deadline. We confirm whether Kalman Aero is the right fit.
Written scope and fixed-price proposal (within 3 business days).
A one-page proposal with assumptions, deliverables, timeline, and price. Nothing starts until it is signed.
Collaborative analysis (3–10 weeks depending on service).
Analysis runs as an ongoing collaboration, not a hand-off. Kickoff working session sets assumptions and modeling choices. A mid-engagement review aligns preliminary results with your operational understanding. Additional working sessions are scheduled as the analysis develops — typically when modeling choices need your input, when scenario interpretation needs validation, or when results surface questions worth discussing before final write-up. Written documentation accompanies every working session so the engagement record stays clean.
Final delivery, formal revision cycle, and 60-day Q&A support.
After collaborative analysis lands the deliverable, you receive one formal revision cycle to incorporate any remaining feedback, then sixty days of written responses to FAA or underwriter follow-up questions.
Questions drone operators ask.
Does Kalman Aero guarantee my waiver is approved?
No — and be skeptical of anyone who does. The FAA makes the final determination. What Kalman Aero delivers is a quantitative safety case built to the evaluation factors the FAA has published, which materially improves the strength of the submission.
How is Kalman Aero different from a drone law firm?
A law firm writes the legal and regulatory narrative of your application. Kalman Aero writes the engineering analysis that backs that narrative up. Many operators engage both. The two roles are complementary, not substitutable.
What does an engagement actually cost?
STANDARD-scope pricing: Part 107 BVLOS waiver narrative $5,000–$9,000 (entry tier for benign missions); Part 107 quantitative safety case $12,000–$18,000; operational volume analysis $18,000–$28,000; custom Monte Carlo simulation $28,000–$45,000; ConOps development $10,000–$15,000; DAA validation $18,000–$30,000. HIGH scope (complex operations) adds 20–30%. HIGHEST scope (novel operations, urban airspace, multi-aircraft, contested airspace, NVIDIA Isaac Sim perception integration) adds 50–100%. Multi-site, Part 135, and Enterprise Program engagements quoted individually, typically $35,000 to $250,000+. Insurance underwriting retainers $36,000–$120,000/year. Every engagement is fixed-price, written, and agreed before work begins.
How long does a typical engagement take?
Most safety cases deliver in 3–4 weeks from kickoff, operational volume analyses in 4–6 weeks, and custom simulations in 6–10 weeks. Rush engagements are accepted subject to capacity at a 25% surcharge.
What information do you need from me to start?
Your ConOps narrative, aircraft make and model with any available performance data, intended operating area, and the specific waiver section or regulatory pathway you are targeting. A kickoff checklist is shared when the proposal is signed.
Is my information kept confidential?
Yes. A mutual NDA is signed before any ConOps, aircraft data, or proprietary information is shared. Kalman Aero does not publish client names or operation details without written permission.
Do you work outside the United States?
Yes. Deliverables can be written to the JARUS SORA framework used by EASA, the UK CAA, and Transport Canada. Engagement scope is adjusted accordingly.
What is KASPR and how does it relate to the analysis I receive?
KASPR — Kalman Aero Safety and Probabilistic Risk-analysis — is our internal quantitative safety reasoning platform. It is the engine that produces your Monte Carlo ensemble, statistical confidence intervals, SORA 2.5 GRC/ARC/SAIL determinations, and the rendered safety-case report. You don't receive KASPR itself; you receive the analysis it produces, with full reproducibility artifacts (analysis package, written analysis, SHA-256–anchored audit trail) so any reviewer can independently verify the work.
Are you ready for Part 108?
Yes. The Part 108 NPRM was published August 7, 2025 and is currently in final-rule review; the framework establishes a performance-based regulatory structure with five risk categories and SAIL-aligned risk assessment. Kalman Aero authors Means of Compliance documentation against the NPRM text today and is positioned to revise rapidly once the final rule publishes. KASPR's GRC/ARC/SAIL pipeline maps directly to the explicit risk-based categorization Part 108 is bringing in. The market window for quantitative analysis is opening now — operations that today rely on case-by-case §107.31 waiver narratives will face quantitative review under Part 108.
Start with a 30-minute call.
The best way to evaluate fit is a short call. Bring your ConOps, your waiver target, and your timeline. You will leave the call with a clear read on whether Kalman Aero is the right team and what an engagement would look like. No obligation, no pitch deck.
Direct email.
contact@kalmanaero.com — for scoping questions, document review, or NDA exchange before a call.
What happens next.
You pick a time. You receive a short pre-call questionnaire. We speak for 30 minutes. Within three business days, you receive a written fixed-price proposal if the work is a fit.
Response time.
Email and Calendly requests are acknowledged within one business day.