A REVIEW OF THE POTENTIAL SITING OF A NATIONAL FOOTBALL LEAGUE STADIUM NEAR LOS ANGELES INTERNATIONAL AIRPORT (LAX)

Transcription

1 A REVIEW OF THE POTENTIAL SITING OF A NATIONAL FOOTBALL LEAGUE STADIUM NEAR LOS ANGELES INTERNATIONAL AIRPORT (LAX) Presented by The Honorable Tom Ridge December

2 INTRODUCTION Ridge Global has been asked to conduct a preliminary, high-level review of the various risks associated with locating a National Football League (NFL) stadium adjacent to the Hollywood Park race track and The Forum arena in Inglewood, California venues in close proximity to and directly in the flight path of Los Angeles International Airport (LAX). While not a technical assessment, we have conducted the review and have identified significant macro-level risks and possible threat scenarios that the proposed stadium siting enables. Based on our experience, we would expect that a more in-depth, all-hazard risk assessment would be completed and it would most likely identify additional concerns. The most obvious and relevant concerns arise out of the location s proximity to LAX. Runways 25R and 25L are just 2.5 miles from the Inglewood/Hollywood Park site, while runways 24R and 24L are no more than 3.6 miles (see Exhibit A). Geography is a major element but is not the sole piece of a complex puzzle. As a major American hub for transportation and commerce, it is clear that LAX is attractive to terrorists and other mal-intended actors seeking a target with significant symbolic and economic value. Even a cursory review of incidents specifically directed at LAX in recent years confirms this fact:! Millennium bombing plot (2000)! El Al counter shooting (2002)! Jam iyyat Ul-Islam Is-Saheed plot (2005)! Shooting of TSA Officer Gerardo Hernandez (2013) Likewise, the NFL brand is recognized around the globe for being distinctly American and, for many in the world of sport, an iconic brand. Therefore, placement of the stadium at the Inglewood/Hollywood Park location, would layer existing risk and introduce new risks to an expanded amalgamation of NFL-related stakeholders to include fans, employees, vendors, 1

3 sponsors and most importantly, citizens of Los Angeles, Inglewood, and adjacent communities. At this time, however, it appears that there is no single public agency federal, state or local with the comprehensive responsibility and authority to conduct an in-depth technical assessment of the range of risks associated with siting a large NFL stadium and related commercial infrastructure layered in such close proximity to LAX. Instead, various oversight responsibilities are parochial and restricted by disciplinary, geographic, jurisdictional, political, or economic boundaries. This raises further concerns that there may be substantive gaps in the complex public-private risk management resourcing, planning and execution functions required to mitigate risk in such a target-rich space. Our findings can be categorized into three principal risk groupings: I. Security Risk II. Safety and Operational Risk III. Economic Risk Individually, each grouping of concerns is substantive. But when interdependencies are considered, they constitute a significant risk profile with the potential to produce consequences that will not only impact the airport and region, but global interests. Please let me know what questions you may have. Tom Ridge December

4 I. SECURITY RISK The primary focus of this document is to evaluate security risk. While evaluating the Inglewood/Hollywood Park site vis-à-vis its proximity to LAX, it is important to consider not only immediate and local considerations, but other critical factors that influence the security of such layered facilities. Chief among these factors is the current global aviation threat environment. The leadership of the U.S. intelligence community continues to emphasize how terrorist groups, such as Al-Qaeda and its affiliates remain intent on attacking the U.S. homeland. 1 These terrorist groups prioritize transportation systems primarily the aviation industry as targets for nefarious activities. There are several examples of foiled and perpetrated terror plots over the past 20 years that reflect this approach, not least of which are September 11, 2001 attacks and the failed attempt by Al-Qaeda disciple Richard Reid to destroy American Airlines flight 63 with a shoe bomb on December 22, Unfortunately, the zeal of terror groups to take down airliners has not waned over the last dozen years. In recent months, Intelligence Community concerns surround an individual who is all-too familiar to U.S. and allied security officials: the Saudi-born terrorist Ibrahim al-asiri. Al-Asiri is known as the chief bomb-maker for Al- Qaeda in the Arabian Peninsula (AQAP) and he has been directly connected to or suspected of taking part in a number of plots to attack aviation targets since Al-Asiri In collaboration with the now-deceased former AQAP leader Anwar al-alawki, al-asiri was suspected developing the materials used by Umar Farouk Abdulmutallab, the so-called Underwear Bomber. On Christmas Day in 2009, Abdulmutallab attempted to detonate pentaerythritol tetranitrate (PETN) on Northwest Airlines flight 253 as it descended into Detroit from its origination in Amsterdam. 1 DNI James Clapper Statement for the Record, Senate Select Committee on Intelligence, January 29,

5 Al-Asiri was also suspected in the October 2010 attempt by AQAP to use plastic explosive hidden in toner cartridge packages to bomb UPS and FedEx cargo aircraft bound for U.S. destinations to include Chicago, Illinois. Today, there is credible information that suggests that al-asiri and AQAP, in collaboration with other extremist groups, fashioned explosive devices made of non-metallic components that would be contained within the human body and would be undetectable. In July 2014, this concern led the Department of Homeland Security (DHS) and the Transportation Security Administration (TSA) to heighten security measures for U.S.-bound aircraft at a number of foreign airports. 2 US officials are on the offensive to counter the ability of Al-Qaeda and its affiliates to utilize their new bomb-making capabilities against American interests abroad and at home. In early November 2014, a US MQ-9 Reaper drone launched a missile strike in the Idlib province of Syria and reportedly killed David Drugeon, a French national and key non-metallic bomb-maker within Al-Qaeda s elite, Syrian-based Khorasan Group. Following the attack, US Central Command released a statement regarding its rationale for the strike on Drugeon and other Khorasan leaders: Khorasan bomb-maker David Drugeon This network was plotting to attack in Europe or the homeland, and we took decisive action to protect our interests and remove their capability to act. We will continue to take any action necessary to disrupt attack plotting against U.S. interests. 3 But while strikes against terrorists such as Drugeon have met with success, European and US intelligence officials remain on high alert. They suspect that Drugeon may have passed his bomb-making skills to others to carry out attacks against US and UK airlines as holidays in the West approach. 2 The New York Times, Flights to U.S. Face Scrutiny After Threats Are Reported, July 2, US Central Command Press Release # , November 6,

6 Other potential security threats to commercial aviation particularly during take-off and landing periods are well documented to include potential fire from high caliber rifles and snipers, rocket propelled grenades (RPGs), and man-portable air defense systems (MANPADS). These are not just resurrected post-9/11 scenarios. The location of dispersed Libyan arms in the post-2011 revolution timeframe, for example, remains a credible threat to both commercial and military aviation interests around the world. And, the effect of small weapons of this kind has certainly been made clear in the Ukraine this summer. Rocket fire has been one of the most commonly utilized weapons observed in the recent Israeli-Palestinian conflict in Gaza. With rockets falling as close as one mile to Tel Aviv s Ben Gurion airport, on July 22, 2014, the U.S. Federal Aviation Administration (FAA) temporarily cancelled flights by American carriers into Israel. Other countries took similar action. Additional threats are demonstrated by the proliferation of small drone aircraft and laser attacks directed at aircraft throughout the country. The growing commercialization and availability of Unmanned Aerial Systems (UAS) present both a security and safety challenge for the Federal Aviation Administration (FAA). According to a report in The Wall Street Journal, the FAA has documented that more than 150 drone/aircraft near miss incidents this year alone, to include a September 2014 incident over Southern California that involved a drone and 300-seat Air China Boeing The Wall Street Journal, Increase in Drones Spotted Near Aircraft, November 26,

7 Discussing UAS safety and security issues on the November 30, 2014 CNN program State of the Union, FAA Administrator Michael Huerta stated: We have enforced hundreds of these cases where we have seen someone operating one of these things carelessly and recklessly and posing the danger to aircraft, and that can't happen." In reaction, the agency has moved aggressively to defend its regulatory power over drone operation, successfully lobbying the National Transportation Safety Board (NTSB) to reverse previous rulings and classify drones as aircraft that are subject to FAA authority. 5 What is lacking from this discussion, however, is the terrorism threat these platforms present, particularly as large aircraft reach lower altitudes. If the FAA is struggling to manage concerns over the accidental collision of a UAS with general or commercial aircraft, its regulations will be virtually useless to prevent bad actors from using a small UAS to intentionally attack an aircraft. Laser attacks and have the potential to blind pilots during take-off and landings. Pilots operating aircraft in and out of LAX have not been spared. On June 18, 2014, the flight deck of US Airways 674 was hit by a laser attack on approach to LAX from Phoenix. FBI Photo While the pilots of the Airbus A321 were able to land the aircraft safely at LAX, aviation laser targeting is a growing concern for the FAA and FBI. Since beginning a joint tracking program in 2005, the agencies have reported a 1,100% increase in what the FBI calls the deliberate targeting of aircraft by people with handheld 5 The Wall Street Journal, NTSB Rules Drones Are Aircraft, Subject to FAA Rules, November 18,

8 lasers. Nearly 4,000 such incidents were reported in 2013 alone, and the FBI was compelled to launch a new program to counter this escalating concern in June of Finally, the yet unresolved disappearance of a Malaysian Airlines Boeing 777 aircraft on March 8, 2014 with 227 passengers onboard (MH370) has raised questions about possible air crew involvement and is a stark reminder that insider aviation threats must be seriously considered. This discussion of the global aviation threat surface is relevant to LAX security and the potential siting of a stadium. Some might view the latest reported incidents as an elevation of the threat environment for civilian aviation. In reality, the targeting of aviation has been one of the most consistent threat streams since 9/11. It is well established, and patently obvious, that aircraft are uniquely vulnerable at takeoff and landing. That vulnerability is clearly magnified as aircraft would pass merely hundreds of feet above an NFL stadium at the Hollywood Park site. And, as a global aviation hub for both passengers and cargo, LAX cannot be detached from its prominent and permanent place in the global transportation network. As I stated many times as Secretary of Homeland Security, and as I have continued to say in my current role advising private sector companies: We have watches, but the terrorists have time. Whether threats come from known and persistent jihadists such as al-asiri or the array of international actors, the aviation sector and high-profile airports such as LAX will remain a primary target for Al-Qaeda and like-minded terrorist organizations. As such, it begs the question: Have the NFL, developers, and local leaders fully considered the implications of constructing another iconic facility directly in the LAX flight path? 6 Federal Bureau of Investigation press release, June 3,

9 Following the passage of the Gerardo Hernandez Airport Security Act on July 22, 2014 by the U.S. House of Representatives (a bill to enhance airport checkpoint security and named for the TSA agent killed at LAX in the line of duty in November 2013), The Los Angeles Times noted findings from a series of congressional and state hearings investigating the incident: Those hearings revealed security lapses at the nation s third largest airport that interfered with emergency response efforts. They included an emergency phone and panic buttons that did not work, as well as coordination and communications problems involving public safety agencies. 7 This is not an indictment of the hardworking security professionals at LAX. Instead, it again becomes clear that even the basics of multi-tiered, multi-discipline security and coordination for protecting a facility such as LAX are extremely difficult. The complications arising from the site are exacerbated by the fact that the proposed site is in the City of Inglewood. All state and local government agencies are stretched for financial and personnel resources. Smaller jurisdictions are stretched even more. The costs imposed by NFL-scale game-day requirements, including the necessary coordination with LAX security and other jurisdictions, would place additional staffing, equipment and budget strains on Inglewood s public safety agencies. While we can speculate on causes from a lack of understanding of the facts to economic motivations it is not clear why the National Football League and local leaders would consider increasing community, regional, and their own risk by placing a major NFL stadium with complex security concerns in such close proximity to the airport. 7 The Los Angeles Times, House passes bill to improve airport security in wake of LAX shooting, July 22,

10 II. SAFETY AND OPERATIONAL RISK An NFL stadium at Inglewood-Hollywood Park would be intended to serve as a Super Bowl and major year-round public event venue. It will be the L.A. Coliseum of the 21 st Century. Along with the 80,000-seat stadium, a range of housing, hospitality, retail and entertainment facilities and supporting infrastructure are also planned to be constructed around the Hollywood Park site. This would host vastly larger crowds than those that visited the old racetrack and legendary Forum in the decades before or since the harsh lessons of 9/11. Development near runways has become an increasing concern of the Federal Aviation Administration which has cited construction in proximity to runways and growth near flight paths as an ever-increasing risk, particularly in regard to aircraft One Engine Inoperative (OEI) events. 8 The majority of fatal aviation accidents occur during take-off, initial climb, final approach and landings. 9 And the number of LAX take-offs and landings are only increasing year-over-year (605,480 in 2012). 10 In seeking comments on the OEI issue, FAA Docket released in April 2014 stated that even if construction is allowed near runways, the FAA takes action to mitigate the impact of the obstruction by altering procedures (e.g. departure routes, climb gradients) to ensure that safety is maintained. 11 The FAA affirms that aviation flexibility vis-à-vis construction near flight paths may be compromised, and the carriers have noted that they are experiencing a growing erosion of capacity because of the encroachment from obstructions near airports Federal Aviation Administration, Docket # , Issued April 21, Boeing Commercial Airplanes, Statistical Summary of Commercial Jet Airplane Accidents Worldwide Operations Ibid 5, Page Ibid 5, Page 7. 9

11 Aircraft approaching or departing LAX fly at an altitude as low as feet when over the proposed Inglewood/Hollywood Park site. The elevation of the actual stadium edifice, along with supporting infrastructure and lighting, will reduce clearance even further. The FAA has noted that, in order to mitigate the impact of obstructions near runways, airline carriers alter departure routes, climb gradients and other flight details, and thereby must absorb new costs associated with greater fuel burn, reduced payload or reduced number of passengers. 13 On approach to LAX, an Airbus A380, the world s largest passenger airliner, is just hundreds of feet above the Inglewood/Hollywood Park site. NFL teams typically host 10 home games during the course of a season (2 pre-season and 8 regular season games). Temporary Flight Restrictions (TFRs) are already put into place for most games. However, if as intended, the Inglewood/Hollywood Park stadium were to host a Super Bowl, which is typically assigned federal National Special Security Event or NSSE status under U.S. Secret Service leadership, far more rigid TFRs would be put into place that would further complicate LAX and airline operations. The likely detrimental impacts to commercial and general aviation operations at LAX may generate friction between local governments, community leaders, the NFL and other commercial interests such as airlines, airport-related businesses, employees, trade associations, etc. that are dependent upon consistent airport function. And while advocates and developers may highlight the positive economic development benefits that accompany a new NFL stadium, the range of operational concerns, and possible negative implications across the overlapping stakeholder and community interests, should be fully and publicly evaluated. In 2013, investigative reporters in the San Francisco Bay Area exposed how aviation operational issues concerning the San Jose International Airport and proximal airspace were 13 Ibid 5, Page 7. 10

12 not holistically considered prior to the NFL s most recent stadium construction project in Santa Clara, CA. 14 For example, reporters learned that local homeland security officials and airport air traffic control professionals were not consulted until stadium construction was well underway. The proposed Inglewood/Hollywood Park site is in the direct east-west flight path of the much larger airport in Los Angeles, which lacks north-south runway alternatives for approach or departure. Locating an NFL stadium at the Inglewood/Hollywood Park location would create a host of new operational issues that would bleed into public safety, transportation, and economic realms in more consequential ways. III. ECONOMIC RISK For the world, LAX is the gateway into the City of Los Angeles and into the United States. And for the United States, LAX is a gateway to the world particularly the destinations and markets of Asia. It is the world s busiest origination and destination airport, the 3rd busiest U.S. airport and the 6th busiest airport in the world in terms of passenger traffic (~67 million enplaning and deplaning). 15 And LAX is the 13th busiest airport in the world in regard to cargo traffic (1.8 million metric tons loaded and unloaded), maintaining a critical position in the global supply chain. In total, LAX operations have an annual economic output of nearly $40 billion. This activity adds more than $2.5 billion to local and state revenues annually. 16 Meanwhile, LAX is a Southern California job engine, sustaining a total of over 294,000 direct/indirect jobs and more than $13 billion in wages Ibid Ibid Los Angeles County Economic Development Corporation, Los Angeles International Airport in 2011, Economic Impact Analysis. 11

13 In the broader picture, Los Angeles County, is the Nation s largest manufacturing hub. 18 And the companies large and small that make products such as computer and electronic equipment, apparel, food, machinery and pharmaceuticals are dependent upon LAX to help export their products to international markets. The statics explain why operational or security disruptions at LAX, to include those that could be related to potential NFL operations at the Inglewood/Hollywood Park site, have both LOCAL impact and cascading GLOBAL implications. And the NFL should carefully evaluate how any disruption at LAX may likewise impact their operations. CONCLUSION As is the case in any review of this type, the goal is to identify potential macro-level risks. As previously stated, it is clear after this review, that a more in-depth technical assessment could be expected to raise more specific concerns. Effective risk management is about limiting exposure as much as possible. Placing an NFL stadium in the operational space of another well-known target, layers additional safety and security risks, materially increases the risk of a terrorist event twofer, and increases the likelihood that an incident involving one facility will adversely impact the other. Specifically, locating an NFL stadium at the Inglewood-Hollywood Park site needlessly increases risks for existing interests: LAX and tenant airlines, the NFL, the City of Los Angeles, law enforcement and first responders as well as the citizens and commercial enterprises in surrounding areas and across global transportation networks and supply chains. That risk would be expanded with the additional stadium and soft target infrastructure that would encircle the facility locally. 18 Los Angeles County Economic Development Corporation, Manufacturing: Still a Force in Southern California (2011). 12

14 To be clear, total risk cannot be eliminated at any site. But basic risk management principles suggest that the proximity of these two sites creates a separate and additional set of risks that are wholly unnecessary. In the post 9/11 world, the threat of terrorism is a permanent condition. As both a former governor and secretary of homeland security, it is my opinion that the peril of placing a National Football League stadium in the direct flight path of LAX layering risk outweigh any benefits over the decades-long lifespan of the facility. If a decision is made to move forward at the Inglewood/Hollywood Park site, the NFL, state and local leaders, and those they represent, must be willing to accept the significant risk and the possible consequences that accompany a stadium at the location. This should give both public and private leaders in the area some pause. At the very least, an open, public debate should be enabled so that all interests may understand the comprehensive and interconnected security, safety and economic risks well before a shovel touches the ground. 13

15 EXHIBIT A: MAP - DISTANCE OF SITE TO LAX RUNWAYS 14