You are on page 1of 15

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 2014

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, Californiavenues 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 locations 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)
Jamiyyat 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,

sponsorsand most importantly, citizens of Los Angeles, Inglewood, and adjacent


communities.
At this time, however, it appears that there is no single public agencyfederal, 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.
II.
III.

Security Risk
Safety and Operational Risk
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 2014

I.

SECURITY RISK

The primary focus of this document is to evaluate security risk. While evaluating the
Inglewood/Hollywood Park site vis--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 systemsprimarily the aviation industryas
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, 2001. 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 AlQaeda 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 2009.

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.

DNI James Clapper Statement for the Record, Senate Select Committee on Intelligence, January 29, 2014.

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-Qaedas elite, Syrian-based Khorasan Group. Khorasan bomb-maker
David Drugeon
Following the attack, US Central Command released a statement
regarding its rationale for the strike on Drugeon and other Khorasan leaders:
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
3

The New York Times, Flights to U.S. Face Scrutiny After Threats Are Reported, July 2, 2014
US Central Command Press Release #20141105, November 6, 2014.

Other potential security threats to commercial aviationparticularly during take-off and


landing periodsare 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 Avivs 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 777.4

The Wall Street Journal, Increase in Drones Spotted Near Aircraft, November 26, 2014.

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

The Wall Street Journal, NTSB Rules Drones Are Aircraft, Subject to FAA Rules, November 18, 2014.

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 2014.6
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?

Federal Bureau of Investigation press release, June 3, 2014.

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 nations 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
Inglewoods 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.

The Los Angeles Times, House passes bill to improve airport security in wake of LAX shooting, July 22, 2014.

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 21st 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 2014-0134 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--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.12

Federal Aviation Administration, Docket #2014-0134, Issued April 21, 2014.


Boeing Commercial Airplanes, Statistical Summary of Commercial Jet Airplane Accidents Worldwide Operations 1959-2012.
10
http://www.lawa.org/welcome_LAX.aspx?id=40
11
Ibid 5, Page 7.
12
Ibid 5, Page 7.
9

Aircraft approaching or departing LAX fly at an altitude as low


as 600-700 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 worlds 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

not holistically considered prior to the NFLs 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 worlds 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.17
14

http://www.nbcbayarea.com/investigations/Santa-Clara-Stadium-in-SJC-Flight-Path-189463971.html.
Ibid 7.
16
Ibid 7.
17
Los Angeles County Economic Development Corporation, Los Angeles International Airport in 2011, Economic Impact Analysis.
15

11

In the broader picture, Los Angeles County, is the Nations 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

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

EXHIBIT A: MAP - DISTANCE OF SITE TO LAX RUNWAYS

14