Will ERAU’s UAS risk to NAS assessment met the SpaceX standard? Will ERAU’s UAS-risk-to -NAS assessment met the SpaceX standard?

P. Barry Butler, president of Embry-Riddle Aeronautical University, has published the below opinion in the respected Aviation Week & Space Technology. Butler is a Ph.D. in Mechanical Engineering, pilot, recognized scholar at several universities and now president of a leading aeronautical university. Doctor Butler took it upon himself to analyze and synthesize a number of research studies that assess the risks posed by introducing uncrewed[1] aerial systems into the National Airspace System. His conclusions are
- that they pose potential danger
- that more research is critical for future safety
- Already there are 1.78 million flying and serious accidents recorded; so, “the most pressing priority is to ensure that they operate safely in our airspace.”

An entrepreneur, like ELON MUSK, also leader of Department of Government Efficiency (DOGE), is familiar with risk. As defined by Nexford University, this talent involves:
Risk taking in entrepreneurship refers to the willingness and ability of entrepreneurs to make decisions and take actions that involve uncertainty, potential loss, and the POSSIBILITY OF FAILURE.
Aviation safety’s risk tolerance in aircraft design is expressed in a fraction 10-9. A number means there is less than an ONE-IN-A-BILLION CHANCE of such a failure occurring during any given hour of flight. ApplyingDr. Butler’s review of the UAS data supports his PRESSING PRIORITY conclusion.
Mr. Musk’s risk tolerance is shown by the following history:
- Falcon 1: The first three launches of Falcon 1 (2006–2008) failed due to technical issues, but the fourth launch was successful.
- Falcon 9: Out of over 450 launches, there have been three failures, including the CRS-7 mission in 2015 and the Amos-6 explosion in 2016.
- Starship: The Starship program has seen multiple test flight failures, with at least four explosions during testing, including two recent failures in 2025.
Overall, SpaceX has had around 10 significant failures or explosions across its history of ~700 launches.
HOPEFULLY, the DOGE team will not ignore Dr. Butler’s recommendation because the Space X team should not regard its entrepreneurial 0.014 failure rate as acceptable for AVIATION SAFETY.



Opinion: Ensuring Air Safety Amid Proliferation Of Drones
P. Barry Butler February 27, 2025

As the Palisades fire raged in Los Angeles, a civilian drone struck a Super Scooper aircraft that was battling the inferno on Jan. 9, leaving the aircraft grounded and with a 3 X 6-in. gash in its wing.

The collision was not an isolated incident. DRONES HAVE DISRUPTED AERIAL firefighting crews repeatedly. They also have forced airspace shutdowns, struck helicopters and narrowly missed commercial aircraft.
The FAA estimates that recreational drones—a category that includes most craft lighter than 55 lb.—have reached 1.78 million units. This raises critical questions: HOW ARE THESE AIRCRAFT OPERATING IN INCREASINGLY CROWDED AIRSPACE, AND WHAT DANGERS DO THEY POSE?
Fortunately, such questions are being investigated by university researchers with the support of the FAA. And these experts increasingly are finding reason for caution. A team from Mississippi State University, Montana State University, Ohio State University and Wichita State University simulated 140 DRONE COLLISIONS WITH WINGS, VERTICAL AND HORIZONTAL STABILIZERS AND WINDSCREENS OF COMMERCIAL AIRCRAFT. They found that DRONE STRIKES CAN CAUSE MORE DAMAGE THAN A BIRD OF THE SAME SIZE AND SPEED.

Another serious potential danger is a DRONE BEING INGESTED INTO THE ENGINE OF A JET IN FLIGHT. Researchers are still learning how uncrewed aircraft systems (UAS)—composed of hard plastic, carbon fiber and metals, and containing parts such as motors, batteries and cameras—could damage commercial jet engines. More experiments and modeling are clearly needed.

Meanwhile, Embry-Riddle Aeronautical University and Oklahoma State University researchers tracked the movements of small UAS around the Dallas-Fort Worth International Airport (DFW) over a three-year period ending in August 2021. The team collected flight telemetry data on location, altitude and speed from drones within approximately 30 mi. of the airport. By combining this information with geospatial mapping data, the researchers recorded MORE THAN 481,000 DRONE FLIGHTS FROM NEARLY 30,000 SMALL UAS, according to the 2024 study.
“We witnessed drone operations near approach paths into airports and very near to heliport locations,” said Ryan Wallace, associate professor of aeronautical science at Embry-Riddle and the first author of the study.
A separate Embry-Riddle study using largely the same dataset compared the proximity of the drone flights to 1.8 million aircraft operations around DFW. Using drone analytics software from Unmanned Robotics Systems Analysis, drone telemetry data was combined with air traffic data from OpenSky Network, which records aircraft flightpaths through ADS-B and Mode S signals, to run “together like a movie,” Wallace said.

The analysis revealed 24 INSTANCES in which drones came within 500 ft. of crewed aircraft. ELEVEN of the cases involved commercial aircraft, and 10 OCCURRED within 1.7 mi. of a runway approach or a departure corridor. As a result, the researchers recommended that the FAA extend the exclusion zone for drones at the ends of runways to 3.5 mi. from 1 mi.
Particularly in the moments after aircraft take off or before they land, “there is an elevated risk of drones encountering manned aircraft,” Wallace said.
Since September 2023, the FAA has required that all drones over 0.55 lb. broadcast their location and identifying information through a system called Remote ID, which is like a digital license plate.

The drone data collected through Remote ID will become another critical source of information for the FAA and researchers. A team at Embry-Riddle already plans to analyze a range of data—including registration, navigation and geolocation—that can offer further insights into drone traffic and collision risks.
The data and research also will help to forecast general trends in drone flight activity across the national airspace and provide reliable observations about the effectiveness of existing regulations for small UAS.
The aviation industry and researchers recognize the value of small drones—whether in delivering medicine and food, helping track hurricanes, monitoring crops or allowing first responders to view areas that are unreachable after disasters, among countless other applications. The learnings from small drones can even be used to make aviation safer.
But the most pressing priority is to ensure that they operate safely in our airspace.

P. Barry Butler is president of Embry-Riddle Aeronautical University.

[1] Per the current FAA recognizing that the M in NOTAM is MAN, can the U in UAS be restored to UNMANNED??? Asking for a friend.