From: Michael Collins Date: Thu, Sep 27, 2012 at 10:50 AM Subject: Farmers Field comments for LA City Council/Administrative Record from EnviroReporter.com To: brian.walters@lacity.org, sharon.dickonson@lacity.org

Toxies character Perchlorate blasts off at Farmers Field

SEPTEMBER 27, 2012

LA City Council ignores toxic fireworks issue as it sets to approve project

Like Wile E. Coyote roping himself to a perchlorate-powered rocket, the Los Angeles City Council is set to launch the city into unknown territory September 28.

That’s when the council will make an historic deal to approve the $1.2 billion Farmers Field project in downtown adjacent Staples Center.

The anticipated approval comes on the heels of a September 14 EnviroReporter.com exposé AEG’s Perchlorate Problem that showed that project applicant Anschutz Entertainment Group appeared to have not accounted for the toxic fireworks mainstay ingredient perchlorate in its $27 million environmental impact report, or EIR.

Perchlorate at minute levels has been shown to affect the thyroid and is especially dangerous to pregnant women and children under the age of 12 because it disrupts proper organ development. Southern California has multiple sites contaminated by perchlorate including the Santa Susana Field Laboratory above Simi Valley and the Jet Propulsion Laboratory in Pasadena.

AEG vice president of communications Michael Roth pledged to answer to our e-mailed questions about the perchlorate and other inconsistencies in the EIR related to fireworks data. Those questions were:

Implicit in the FEIR/DEIR is the use of perchlorate in traditional fireworks at Farmers Field. While the amounts of the four heavy metals that are the coloring agents are listed for the fireworks and quantified, there is no such data regarding perchlorate and the amounts of it that will be used.

1. Is there any data in the FEIR/DEIR on the amount of perchlorate that is expected to be used on a per day and per year basis? Is there any data that analyzes any potential environmental and/or health impacts from said usage?

2. Two of the fireworks-related heavy metals listed in Appendix B, antimony and copper, have the same figure (number) for their respective "Peak Hourly Emissions" as they do for their "Annual Emissions." Is this a mistake? If it is, what would the correct figures be?

3. Are the four heavy metals listed - copper, antimony, barium and strontium - the only heavy metals used as coloring agents in Farmers Field fireworks?

4. Farmers Field's FEIR/DEIR has an impressive emphasis on the "green" credentials of the project. From compressed air propulsion to perchlorate-free fireworks with about a tenth the amount of barium used by traditional fireworks, there are 'greener' fireworks than the ones AEG is planning to use at Farmers Field. Why has AEG chosen to use traditional display fireworks instead of these new technologies?

Seven days after sending the questions to Roth, news broke that the company was up for sale. To date, there has been no reply.

The city-written EIR for AEG also claimed there were no mitigating options for fireworks use, therefore any such use of ‘low-emission’ fireworks would be optional and not required. EnviroReporter.com has found that there are commercially available fireworks that are perchlorate-free with a tenth of the heavy metal barium. Barium produces fireworks’ green color and is toxic by ingestion or inhalation.

That information didn’t give the city’s planning commission pause September 13 when it approved the EIR unanimously and passed it on to the city council. The commission didn’t apparently see the need for the usual health effects studies that come in EIRs when toxins like perchlorate are used in presumably high amounts year-round. Not addressing the fireworks issue in the EIR means that activists have 90 days to ask a court to make AEG and the city fix the EIR in accordance to the California Environmental Quality Act.

The issue doesn’t seem to ignite any concern at the city council level even when it could open the city and any future AEG owner to litigation over toxic clouds of gas in and out of the stadium. Five of the 15 city councilmembers contacted for comment on the perchlorate findings would not comment on the issue; the other ten elected officials did not respond at all to press inquiries.

The virtually-assured vote will codify the unlimited use of conventional fireworks in and on top of Farmers Field every day of the year from 10am until 11:30pm at the semi-enclosed stadium. Even though perchlorate is the primary ingredient in exploding fireworks for pyrotechnic effects, heavy metals are used to color the bursts.

Perchlorate, a rocket fuel oxidizer which has polluted numerous aerospace sites across the Southland, will find a home at new ‘green’ stadium in downtown Los Angeles by 2017. If neighborhood activists are right, land values will skyrocket and along with that will come tony condos costing millions. In fact, they’re already there and within a third of a mile from the future stadium.

Toxic smoke and burning debris fireworks can have a serious impact upon spectators at an entertainment event and not just fouling the air which, in downtown Los Angeles’ microclimate, can remain nearly windless on many warm nights.

Yet the impact of fireworks at Farmers Field has not been fully explored despite the gargantuan length of the EIR. AEG’s Roth seemed hesitant to even admit to how fireworks would be used in Farmers Field even though an AEG video released May 8 shows impressive blasts of pyrotechnics in a computer-generated conception of the future stadium. Indeed, the veteran PR man posited that the video was, perhaps, just the work of just an imaginative artist and shouldn’t be considered the final project design.

“That was an artist’s conception” Roth said in a telephone conversation September 11. “That was an artist’s conception for the video and I could not tell you if that is reflective of the final design plans because typically things for fireworks, while contemplated in the EIR, you know the positioning and the technology used may or may not be representative. Just like the football players on the field? I’m sure there are some people in the stands in all? We obviously haven’t built that yet so those people aren’t there.”

The perchlorate problem isn’t confined to the stadium and its EIR. The powdery white oxidizer has become so pervasive in California and across the country that it is even beginning to penetrate popular culture.

“Perchlorate” has been a character in two Toxie Awards, a satirical awards ceremony for toxic chemicals and pollutants. Admonishing critics to “lighten up” in one Perchlorate interview, the silver-clad siren with rocket boosters on then reminds viewers there are medications for thyroid disease. In another quick Q & A, the toxin asks the viewer rhetorically “What do you do if life hands you

perchlorate?” and answers her own question with “Make perchlorate lemonade” before going on to exclaim how residents in Barstow having to line up for water free of the goo in 2011 learned important life lessons like learning how to stand in line for hours at a time in the hot Mojave Desert sun.

Not all environmentalists are laughing, including the Natural Resources and Defense Council’s senior attorney for the group’s Santa Monica office, David Pettit.

“I wasn’t aware of the perchlorate problem until I saw your article last week,” said Pettit in an email September 20. “Our view is that perchlorate should not be used in fireworks because of the risks it presents to human health and I will make this known to the City Council.”

AEG vice president of communications Michael Roth told EnviroReporter.com September 11 and 12 that answers about the perchlorate and heavy metals would be forthcoming. They never were. Roth offered to get the perchlorate data but asked that nothing be written about it until he did.

“I’m asking if it’s possible if we hold off another day or two, the reason being as you know we have a big hearing tomorrow and almost everybody that’s been involved in the EIR has been preparing for this,” Roth said in a September 12 conversation with this reporter. “It’s the last and final hearing – or we hope – before the planning commission and it’s obviously a big milestone of a day and they literally, you know, first I’ve got to track down the right person who has to track down the right person. So that’s a bit of an issue for us. Can you hold your story off a few days and key it towards the city council hearing?”

When told that attempting to get this information had been an ongoing effort not the least of which was reviewing the entire EIR, and that AEG would have ample opportunity to comment in a future piece (an offer repeated September 24), Roth appeared somewhat mollified.

“You know about our carbon neutrality part of it?” Roth asked before the call ended. “By the way, the NRDC has – we developed this plan with the NRDC who completely supports our project.”

But NRDC support no longer seems complete with Pettit’s criticism of the use of perchlorate at Farmers Field.

That, however, shouldn’t be much of an impediment to passage by the Los Angeles City Council this Friday despite the surprise announcement that AEG would be put up for sale. That caused considerable fireworks at city hall as evidenced Mayor Villaraigosa’s petulant answers to Los Angeles Times and Los Angeles Daily News reporters after the news broke that Phillip Anschutz was selling the huge company just days before the crucial city council vote.

“Whoever buys that team is going to have to live with the contract we negotiated, and I am very proud of that contract,” Villaraigosa said. “So from my vantage point, I feel very comfortable with the deal that we have, and whoever owns AEG is going to have to live by that deal.”

There’s the rub. The lack of information about the extensive use of fireworks with their attendant toxins is part of the deal. According to the California Environmental Quality Act, CEQA, that is a failing that could

land the city and the new owner of AEG in court costing taxpayers time and money in the quest to bring the National Football League back to Los Angeles.

According to Joe Lyou, head of the Los Angeles-based Coalition for Clean Air, despite the fast track that Farmers Field has been afforded by legislation in Sacramento regarding CEQA, the company is not entirely off the hook on the Farmers Field project. “This is a special case because the law that exempted them from certain requirements under CEQA and said you have to go directly to a court of appeals [if a legal challenge is made to the project’s EIR],” Lyou told EnviroReporter.com September 26. “But normally you would go to superior court to challenge an environmental impact report under the California Environmental Quality Act. The judges will look at it – ‘first review.’ Normally the appellate court looks at the court’s decision made by the lower court but in this case they’ll have to consider the evidence in the record.”

That record includes both articles this reporter has written on AEG and Farmers Field to date.

“So the administrative record includes all of the comments, all the responses to comments that went into making the decision on the part of the city council and, in this case, the judges will look at whether there was an accurate description of the environmental impacts, whether there were significant environmental impacts that were admitted or not admitted [and] potential environmental effects that were not considered,” said Lyou. “Once they determine something is a significant environmental impact, they are obligated to consider all feasible mitigation measures to reduce or eliminate that impact so that it is no longer significant.”

Whether that ever happens is to be seen. If the council and mayor don’t douse the fuse of toxic fireworks at Farmers Field before it’s built, the city and it citizens could have just about the same amount of luck as Wile E. Coyote strapped to a rocket fueled by perchlorate.

SEPTEMBER 27, 2012

AND SEPTEMBER 14, 2012

Farmers Field Environmental Impact Report Omits Toxic Perchlorate Fireworks Usage

Screen capture from AEG YouTube video rendering of fireworks at rock concert at just-approved Farmers Field in

Los Angeles.

* Los Angeles Planning Commission green lights AEG’s $1.2 billion Farmers Field * Perchlorate use and quantities not reported in $27 million AEG environmental report * AEG and city reject use of ‘greener’ fireworks used by Disney and shared royalty-free * Recent study shows huge increase in persistent long-lasting perchlorate after fireworks shows * Faulty EIR may open city and AEG to lawsuits

The Los Angeles City Planning Commission approved late yesterday the final environmental impact report for the $1.2 billion Farmers Field downtown on 68 acres of city-owned land. It was the second to last hurdle for developer, the Anschutz Entertainment Group (AEG).

“We’re going to have a state of the art green stadium,” said planning commissioner Sean Burton before putting the matter to a vote after effusive praise of planning staff for completing the massive environmental impact report (EIR) which is made up of a draft (DEIR) and a final (FEIR) together paid for and produced by the applicant AEG.

The planning commission’s unanimous authorization will bring AEG closer to the expected approval of the city council September 28, a process fast-tracked to help AEG acquire a professional football team by early next year to begin playing in the new stadium in 2017.

City Councilmember Jan Perry sought and got the public hearing notice period for the FEIR to be just 10 days instead of 24 after yesterday’s yes-vote. Now the city council will take its final vote on the project September 28.

Strong objections to this shortened period for public comment on the project next to the Staples Center were to avail. Community activists said that lessened analysis and comment period could burden poor neighborhoods adjacent to the site. Supporters, however, say Farmers Field will bring jobs to the community, increase L.A.’s tax base and bring back pro football, the Super Bowl and even the Final Four to the second largest city in the nation.

Local media has swooned over the project and its open-roofed venue with graceful wing-like translucent outdoor concourses. Two recent Los Angeles Times’ editorials managed to praise the project while all but calling the community representatives extortionists.

“There is still, however, a coalition of community groups pushing for further environmental and other concessions, a fight they say they will pursue with the city's elected leadership and, if that fails, in court,” Jim Newton wrote in a September 10 op-ed piece. “The coalition won't get all it's asking for. It shouldn't.”

The community groups Newton dismissed as mere pests included the Los Angeles Community Action Network, the Legal Aid Foundation of Los Angeles (LAFLA), and the Nobel Peace Prize-winning Physicians for Social Responsibility (PSR-LA) who are part of the Play Fair Farmers Field Coalition. The non-profit organizations are not opposing the stadium, rather they are fighting to reduce the health impacts on surrounding neighborhoods from the project.

These environmental threats include diesel and gasoline fumes from the thousands of cars that may end up idling on streets around Farmers Field for lack of parking – AEG’s plan counts on 27 percent of the people coming to the stadium taking mass transit. Activists question this assumption, and contend the project will put a premium on land surrounding the site to be built out as new parking as the congestion increases the demand for more land for parking. They also say that in the rush to approve the massive construction, which will include tearing down the Los Angeles Convention Center and replacing it, environmental considerations will be missed or ignored entirely.

“The project’s developer, AEG, in return for being granted a special exemption from state environmental laws, has pledged to build the nation’s greenest football stadium that will be an engine of opportunity for working families in our city,” said LAFLA’s Staff Attorney for Community Economic Development, Zahirah Mann in a statement May 30 regarding the group’s DEIR comments on behalf of the Play Fair at Farmers Field Coalition. “Our action today is an important step to holding AEG to that promise.”

Information uncovered in the last week however suggests new hurdles.

THE ROCKETS’ RED GLARE

EnviroReporter.com has discovered that the Farmers Field environmental reports fail to account accurately for all the toxins in planned fireworks displays including the oxidizer perchlorate which is common to most fireworks as a main ingredient. We have also discovered that two the four heavy metals listed in the EIR as the fireworks’ ingredients, both toxic, are listed with quantities that are erroneous. In addition, AEG maintains there are no ways to mitigate its fireworks – but lower-emission fireworks options are in fact readily available.

AEG rendering of Olympic rings in fireworks over future Farmers Field.

Fireworks will be allowed at Farmers Field every day of the year from mid-morning until nearly midnight. An AEG computer-generated videoon its YouTube channel shows a rock concert with robust fireworks going off in the hazy air. Fans’ exposure to fireworks emissions, along with any attendant health effects, are not analyzed in the EIR. Without perchlorate identified as an ingredient, there is little to study let alone mitigate.

Regardless, the EIR does address the risk from fireworks not by analyzing how much perchlorate will be blown off in the stadium but by comparing the explosions to the total emissions of the project. “[P]otential

emissions from fireworks would represent less than 0.1 percent of potential Project-related emissions and would occur on a limited number of days per year,” the EIR reads in response to a public comment. “However, in response to this comment, the health risk assessment has been updated to include air toxic emissions from fireworks.”

The included air toxic emissions from fireworks did not include the perchlorate which is common to most fireworks, including “green fireworks,” as well as the traditional chemical makeups for the bursts like the ones Farmers Field will be using.

In response to public comments on the DEIR submitted by LAFLA regarding the use of perchlorate and heavy metals in the fireworks, AEG countered - without explanation - by reducing the number of dedicated fireworks shows yearly by nearly 60%. But if the fireworks aren’t packing anything toxic like perchlorate, it doesn’t follow that the company would have to reduce its shows.

In regards to so-called low emissions fireworks usage, which swap out the gunpowder propellant with a compressed air launch system, the company has agreed to use such technology as an option but not a requirement. “Lower emissions fireworks shall be used to the extent feasible for ‘proximate fireworks’ where it would achieve a similar fireworks effect.” In other words, traditional fireworks can and will be used.

Depending on which way the wind is blowing, smoke from the fireworks could blow on the predominate breeze from the west into the tony confines of South Park condos which would have a view, and a nose, for the stadium cost a cool million or more. When the wind reverses in Santa Ana conditions, fireworks smoke would blow into the working class and immigrant community of the Pico Union neighborhood.

“It seems like one of the things that’s lacking is fully documenting the extent of the problem and then say whether they can or cannot mitigate the problem,” Martha Dina Argüello, executive director of PSR-LA, told EnviroReporter.com. “I think it lacking specific numbers on the [fireworks] emissions is a problem and not telling us what is actually in the fireworks is a problem.”

Perchlorate has negatively impacted at least 27 states according to the EPA, none more so than California where the chemical has been used extensively. Perchlorate is heavily regulated in California and its usage, handling and storage must be reported to the government.

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EnviroReporter.com has also discovered that the only fireworks ingredients that are listed in the EIR are the heavy metal contaminants that are used to color the fireworks: strontium (red), barium (green), copper (blue) and antimony (white and glitter effects). Yet even the numbers for these toxins are suspect: the EIR’s figures for the 'per day' and 'per year' usage for copper and antimony, respectively, are the same.

Either the EIR is incorrect or Farmers Field plans to only have blue fireworks and white fireworks with glitter effects just one day a year which is highly unlikely. More likely is that the calculations are incorrect. This seems surprising considering the 18 months AEG took to create its $27 million EIR that totals at least 14,759 pages.

“You’ve got to at least have all the primary colors to get to the other colors you use in fireworks,” says Argüello. “I can’t imagine a show that would only use red or only going to use yellow.”

EnviroReporter.com has contacted AEG and provided a requested email outlining questions concerning the fireworks. AEG will be responding to our inquiries according to the company rep. A list of EnviroReporter.com’s questions about the missing information concerning the pyrotechnics was also submitted to the Los Angeles Planning Commission before its meeting.

Farmers Field will be allowed to shoot off fireworks 365 days a year at the stadium from 10:00am to 11:30pm. There will be 15 dedicated fireworks shows a year lasting up to 20 minutes long like on July 4. Other fireworks may accompany the national anthem, football touchdowns or rock concerts like the May 8 video rendering on Farmers Field’s YouTube channel shows. A virtual crowd watches a rock show as fireworks in the video explode around the edge of the giant oval opening in massive blasts above the stadium filling it with smoke.

Color-creating heavy metals revealed to be in the Farmers Field fireworks can impact human health and the environment as well as perchlorate. Barium nitrate, added to fireworks to create that green color, is toxic according to Hazard.com, which says ingestion of the heavy metal “May cause tightness of the muscles of the face and neck, vomiting, diarrhea, abdominal pain, muscular tremors, anxiety, weakness, labored breathing, cardiac irregularity, convulsions, and death from cardiac and respiratory failure.”

Inhalation of barium, according to Hazard.com, “Causes irritation to the respiratory tract. Symptoms may include coughing, shortness of breath. Systemic poisoning may occur with symptoms similar to those of ingestion.”

One commenter on the project voiced concern about cadmium in the fireworks. “Used to produce a wide range of fireworks colors, [cadmium] is also a known human carcinogen,” the commenter wrote. “Breathing high levels of cadmium can seriously damage the lungs, and consuming it can fluster the stomach, often resulting in vomiting and diarrhea. Long-term exposure can lead to kidney disease, lung damage and fragile bones. Plants, fish and other animals take up cadmium from the environment, meaning that any released into waterways from a fireworks show can be passed up the food chain.”

The closest waterway to the future Farmers Field is the Los Angeles River, a little over two miles to the east. The waterway was recently reaffirmed as being protected by the Clean Water Act.

Copper compounds are used to produce blue colors, even though they produce dioxin, which has been linked to cancer according to a 1999 study by Dr. Robertus Vichman of Braunschweig Technical University in Germany. According to the report, the intense heat generated by the perchlorate in fireworks ignites copper coloring compounds giving off significant amounts of dioxin.

Perchlorate’s use in Farmers Field is particularly troubling not just because its use is obscured and not measured in the EIR let alone mitigated; the chemical has wreaked havoc across California in both its ammonium perchlorate and potassium perchlorate forms. While it’s likely that the potassium perchlorate compound is going to be used in Farmers Field, the EIR’s failure to identify and quantify the amount of perchlorate to be ignited doesn’t provide the opportunity to distinguish the effects of which perchlorate to be utilized.

Regardless, perchlorate’s affects locally, regionally and statewide have been significant. As EnviroReporter.com has previously reported in 2005, perchlorate has polluted more than 330 drinking water sources in California where concentrations of the toxin have exceeded the state’s provisional action-reporting level of 6 ppb. That number has climbed to over 350 now according to the EPA’s Region 9 office which oversees the state.

The San Gabriel Valley is an EPA Superfund Site which is a designation for some of the most contaminated locations in the country. Shorthand for the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, Superfund gives wide federal powers to clean up contamination or anticipated hazardous substances at sites and charge the responsible party or parties for the cost. If the responsible party can’t be found, EPA has a special Superfund trust fund to pay for the cleanup.

At least 23 drinking water wells have been contaminated with perchlorate in the San Gabriel Valley, most of which are situated in the Azusa and Baldwin Park area. The first system to clean up the perchlorate was installed in 2001 with four currently in place. These ion exchange technology-driven systems cost more than $17 million to construct and cost about $5 million a year to operate. By 2024, EPA estimates that the cost of cleaning perchlorate out of the San Gabriel Valley groundwater is staggering – more than $200 million to clean the groundwater of perchlorate and other contaminants just at the Baldwin Park water remediation station alone.

ON BARSTOWED TIME

Over 40,000 people of the Mojave Desert town of Barstow learned about perchlorate the hard way in November 2011. The town, which is exactly midway between Los Angeles and Las Vegas, suddenly became aware of a perchlorate contamination plume that had first been detected from a test on the Soap Mine Road Well which had high perchlorate. For days thousands of people were forced to queue up in long lines for hours to get drinking water that was being hauled into the city on an emergency basis because a number of wells in town used for potable water were testing higher than California’s drinking water limit of 6 ppb for perchlorate.

Investigators for the Lahontan Regional Water Quality Control Board found the source of the perchlorate about a mile away at the private home of a long-deceased man who used to own the Mojave River Pyrotechnics Company. Apparently, after his company went bankrupt in the 1980s, the man buried much of the leftover perchlorate in his back yard on Poplar Lane near the usually dry wash that is the Mojave River.

Perchlorate, which is very mobile and persistent in nature, was eventually mapped out underground with the majority of the goo within an area about 1,400 feet wide and 3,500 feet long. Groundwater, obviously a precious commodity in the desert, was found with perchlorate as high as 110,000 ppb or over 18,000 times the California’s perchlorate drinking water standard. Soil came in at more than 500,000 ppb in the worst hit dumps on the property.

Just cleaning up the soil will cost millions according to the EPA. The groundwater remediation would be a much greater challenge and take far longer.

WAR FACTORIES

Perchlorate is also used in missile fuel as an oxidizer and, just like in fireworks, burns fast and hot. That legacy has left aerospace-related sites like Aerojet Chino Hills massively contaminated with the toxin. When LA Weekly exposed perchlorate pollution at the facility in May 2000 followed by OC Weekly, it helped precipitate $46 million worth of cleanup. The property still isn’t fully free of perchlorate, depleted uranium and unexploded ordnance debris and remains a sore spot with a number of residents in the region.

Closer to Los Angeles 35 northwest of downtown is the Santa Susana Field Laboratory which, besides being infamous for being the site of the country’s worst partial nuclear meltdown in 1959, is polluted by perchlorate. Over 30,000 rocket test took place at the 2,850-acre aerospace complex which had gigantic rocket test stands, many of which are still standing today amidst land impacted by perchlorate.

The perchlorate in the fuel fired off testing rockets like the Atlas, Thor and Saturn, left the test stands, buildings, land and groundwater highly contaminated. In 2004, data showed perchlorate in Building 359, on the property now owned by Boeing, as having 34 of 90 samples contaminated with perchlorate so high that they all exceeded “field action levels” where immediate action is mandatory. One sample came back positive for 71,290 ppb of perchlorate.

Perchlorate is a chemical of concern for many Southern Californians because of its widespread fouling of the environment and its effects on the development of the very young and young. These illustrations point to the seriousness of the chemical, especially when large amounts of it are being used in a semi-enclosed space for optional spectacle.

A decade-long struggle over developing Ahmanson Ranch began coming to a head in 2002. There on land bordering Rocketdyne’s southern buffer zone, now-defunct Washington Mutual was on its way to building 3,050 homes in a huge $2 billion development until media pressure forced the company to test its groundwater. “WaMu” had planned to use 660,000 gallons of the groundwater each day to irrigate it common areas, parks and playgrounds.

When one of the wells came back positive with 28 ppb of perchlorate, and Rocketdyne Ranch exposed that and other contamination problems with the property, the public outcry grew and the company begrudgingly accepted an offer of $150 million to give the land to the state which turned it into the Upper Las Virgenes Open Space Preserve. It is the largest single public acquisition of land in the history of both Ventura and Los Angeles counties.

SMOKE ON THE WATER

A May 2007 study by the EPA’s Office of Research and Development, National Risk Management Research Laboratory in Oklahoma City made the danger of perchlorate in fireworks abundantly clear.

“Perchlorate Behavior in a Municipal Lake Following Fireworks Displays” showed that after a fireworks show, the lake’s water had 24 to 1,028 times the baseline amount of perchlorate. It took 20 to 80 days for the perchlorate concentrations to return to background.

That the perchlorate usage is not listed in the Farmers Field EIR, let alone admitted to, creates another challenge in the EIR: mitigation. Without acknowledging the perchlorate-based fireworks, there can be no discussion of how to mitigate them. Indeed, the EIR says as much.

“There are no feasible mitigation measures that would reduce impacts associated with the parking garage and firework displays to a less than significant level,” the DEIR stated. “Impacts related to fireworks displays would be limited (up to 35 shows per year) and of short duration (up to 20 minutes per display show) but would still be significant and unavoidable.”

Activists say that AEG should have considered going greener with Farmers Field fireworks. “Fortunately, there is a better way to mitigate the amounts you use with ‘green fireworks’ or the lower-emission fireworks,” says Argüello. “That technology is readily available from Disney, as I understand, and that’s what they use. They do very elaborate close to ground level fireworks everyday so they’ve developed where you’re using a lot less of the propellant to get the fireworks into the air which is where a lot of those emissions come from.”

Disneyland holds fireworks shows over 230 nights of the year. Responding to numerous complaints since 1991 to the South Coast Air Quality Management District citing ash, smoke, smell and property damage from falling firecracker shells, Disney switched to compressed air in 2004 to shoot up about 350 shells used per show. By removing the gunpowder propellant, much of the smoke that clouds traditional fireworks shows doesn’t exist making the flashes and pyrotechnics brighter.

In its first year alone, Disney ditched 30,000 pounds of the 90,000 pounds it used in 2003, a significant reduction of a third. The company has offered the use of its compressed-air launch design system to other fireworks-using entertainment centers license fee free.

“[AEG] also needs to look into mitigation measures such as air launch technology that can reduce the amount of perchlorate emitted into the air,” says Lyou. “As an entity that wants to be an environmental

leader, I would encourage AEG to take a hard look at this issue as well as other air quality issues associated with their Farmers Field project.”

Compressed air launching of fireworks gets rid of the gunpowder, but not the perchlorate and toxic heavy metals. That means that those 60,000 pounds of fireworks Disney uses are primarily perchlorate, heavy metals, plastic and paper.

All of this perchlorate can be eliminated according a former Los Alamos explosives chemist Mike Hiskey who cofounded a company called DMD Systems that produces perchlorate-free fireworks with about a tenth the amount of barium used in the kind of fireworks AEG will likely use.

Using nitrocellulose as fuel and replacing perchlorate with nitrates as oxidizer, the resultant propulsion and burst produces only stable gases like water, carbon dioxide and nitrogen cutting down greatly on smoke and small particulates. Not only are a wider palette of hues available, there are new formulations of colors resulting in deeper reds and blues impossible to achieve with the fireworks both AEG and Disney use.

In addition, illuminated night kite shows, laser shows and holographic fireworks are all technologies within reach of any large entertainment company like AEG, Disney, Universal Studios and Six Flags that want to truly own the “green fireworks and special effects” mantle.

But don’t look for it in Los Angeles at Farmers Field. This expensive endeavor has been planned down to the tiniest details making the exclusion of the perchlorate data puzzling at best. Cheap Chinese perchlorate filled fireworks are, well – cheaper.

BOOSTER SHOT

The Los Angeles Times boosterism of the AEG project seems to have blinded it to a more critical examination of the Farmers Field EIR. Hostility directed at community activists making the op-ed pages isn’t a replacement for in-depth investigative journalism.

“AEG's already agreed to dozens of community benefits, but if it won't accept more, the project's critics want the council to send the environmental impact report back for more work,” opined Jim Newton. “And if that doesn't work, they're threatening to sue. Of course, one person's mitigation request is another's idea of extortion.”

This was preceded the day earlier in the paper by an unsigned editorial entitled “An L.A.-friendly football stadium” which made this prescient observation: “The final negotiations regarding the football stadium revolve around the project's environmental impact report, a 10,000-page document that the council members have almost certainly not read.”

Had the Times actually read the 11,149-page DEIR and then the 3,610-page FEIR a little closer it might have noticed that demands for better pollution mitigation weren’t extortion. Perchlorate which doesn’t distinguish between people in Pico Union or South Park or the employees, players, performers and fans of Farmers Field.

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enviroreporter.com http://www.enviroreporter.com/2012/09/aeg-punts-perchlorate-football-at-farmers-field/

Toxies character Perchlorate blasts off atFarmers Field

AEG Punts Perchlorate Football at FarmersField

LA City Council ignores toxic fireworks issue as it sets to approve project

Like Wile E. Coyote roping himself to a perchlorate-powered rocket, the Los Angeles CityCouncil is set to launch the city into unknown territory September 28.

That’s when the council will make an historic deal to approve the $1.2 billion Farmers Fieldproject in downtown adjacent Staples Center.

The anticipated approval comes on the heels of a September 14 EnviroReporter.com exposéAEG’s Perchlorate Problem that showed that projectapplicant Anschutz Entertainment Group appeared tohave not accounted for the toxic fireworks mainstayingredient perchlorate in its $27 million environmentalimpact report, or EIR.

Perchlorate at minute levels has been shown to affectthe thyroid and is especially dangerous to pregnantwomen and children under the age of 12 because itdisrupts proper organ development. SouthernCalifornia has multiple sites contaminated byperchlorate including the Santa Susana FieldLaboratory above Simi Valley and the Jet PropulsionLaboratory in Pasadena.

AEG vice president of communications Michael Rothpledged to answer to our e-mailed questions about the perchlorate and other inconsistencies in the EIRrelated to fireworks data. Those questions were:

Implicit in the FEIR/DEIR is the use of perchlorate in traditional fireworks at FarmersField. While the amounts of the four heavy metals that are the coloring agents arelisted for the fireworks and quantified, there is no such data regarding perchlorate andthe amounts of it that will be used.

1. Is there any data in the FEIR/DEIR on the amount of perchlorate that is expected tobe used on a per day and per year basis? Is there any data that analyzes anypotential environmental and/or health impacts from said usage?

2. Two of the fireworks-related heavy metals listed in Appendix B, antimony and

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copper, have the same figure (number) for their respective “Peak Hourly Emissions”as they do for their “Annual Emissions.” Is this a mistake? If it is, what would thecorrect figures be?

3. Are the four heavy metals listed – copper, antimony, barium and strontium – theonly heavy metals used as coloring agents in Farmers Field fireworks?

4. Farmers Field’s FEIR/DEIR has an impressive emphasis on the “green”credentials of the project. From compressed air propulsion to perchlorate-freefireworks with about a tenth the amount of barium used by traditional fireworks, thereare ‘greener’ fireworks than the ones AEG is planning to use at Farmers Field. Whyhas AEG chosen to use traditional display fireworks instead of these newtechnologies?

Seven days after sending the questions to Roth, news broke that the company was up for sale. To date,there has been no reply.

The city-written EIR for AEG also claimed there were no mitigating options for fireworks use, thereforeany such use of ‘low-emission’ fireworks would be optional and not required. EnviroReporter.com hasfound that there are commercially available fireworks that are perchlorate-free with a tenth of the heavymetal barium. Barium produces fireworks’ green color and is toxic by ingestion or inhalation.

That information didn’t give the city’s planning commission pause September 13 when it approved theEIR unanimously and passed it on to the city council. The commission didn’t apparently see the needfor the usual health effects studies that come in EIRs when toxins like perchlorate are used inpresumably high amounts year-round. Not addressing the fireworks issue in the EIR means thatactivists have 90 days to ask a court to make AEG and the city fix the EIR in accordance to theCalifornia Environmental Quality Act.

The issue doesn’t seem to ignite any concern at the city council level even when it could open the cityand any future AEG owner to litigation over toxic clouds of gas in and out of the stadium. Five of the 15city councilmembers contacted for comment on the perchlorate findings would not comment on theissue; the other ten elected officials did not respond at all to press inquiries.

The virtually-assured vote will codify the unlimited use ofconventional fireworks in and on top of Farmers Fieldevery day of the year from 10am until 11:30pm at thesemi-enclosed stadium. Even though perchlorate is theprimary ingredient in exploding fireworks forpyrotechnic effects, heavy metals are used to color thebursts.

Perchlorate, a rocket fuel oxidizer which has pollutednumerous aerospace sites across the Southland, willfind a home at new ‘green’ stadium in downtown LosAngeles by 2017. If neighborhood activists are right,

http://www.enviroreporter.com/wp-content/uploads/2012/09/AEG-punts-perchlorate-football-at-Farmers-Field.jpg

land values will skyrocket and along with that will come tony condos costing millions. In fact, they’realready there and within a third of a mile from the future stadium.

Toxic smoke and burning debris fireworks can have a serious impact upon spectators at anentertainment event and not just fouling the air which, in downtown Los Angeles’ microclimate, canremain nearly windless on many warm nights.

Yet the impact of fireworks at Farmers Field has not been fully explored despite the gargantuan lengthof the EIR. AEG’s Roth seemed hesitant to even admit to how fireworks would be used in FarmersField even though an AEG video released May 8 shows impressive blasts of pyrotechnics in acomputer-generated conception of the future stadium. Indeed, the veteran PR man posited that thevideo was, perhaps, just the work of just an imaginative artist and shouldn’t be considered the finalproject design.

“That was an artist’s conception” Roth said in a telephone conversation September 11. “That was anartist’s conception for the video and I could not tell you if that is reflective of the final design plansbecause typically things for fireworks, while contemplated in the EIR, you know the positioning and thetechnology used may or may not be representative. Just like the football players on the field? I’m surethere are some people in the stands in all? We obviously haven’t built that yet so those people aren’tthere.”

The perchlorate problem isn’t confined to the stadium and its EIR. The powdery white oxidizer hasbecome so pervasive in California and across the country that it is even beginning to penetrate popularculture.

“Perchlorate” has been a character in two Toxie Awards, a satirical awards ceremony for toxicchemicals and pollutants. Admonishing critics to “lighten up” in one Perchlorate interview, the silver-clad siren with rocket boosters on then reminds viewers there are medications for thyroid disease.In another quick Q & A, the toxin asks the viewer rhetorically “What do you do if life hands youperchlorate?” and answers her own question with “Make perchlorate lemonade” before going on toexclaim how residents in Barstow having to line up for water free of the goo in 2011 learned importantlife lessons like learning how to stand in line for hours at a time in the hot Mojave Desert sun.

Not all environmentalists are laughing, including the Natural Resources and Defense Council’s seniorattorney for the group’s Santa Monica office, David Pettit.

“I wasn’t aware of the perchlorate problem until I saw your article last week,” said Pettit in an emailSeptember 20. “Our view is that perchlorate should not be used in fireworks because of the risks itpresents to human health and I will make this known to the City Council.”

AEG vice president of communications Michael Roth told EnviroReporter.com September 11 and 12that answers about the perchlorate and heavy metals would be forthcoming. They never were. Rothoffered to get the perchlorate data but asked that nothing be written about it until he did.

“I’m asking if it’s possible if we hold off another day or two, the reason being as you know we have abig hearing tomorrow and almost everybody that’s been involved in the EIR has been preparing forthis,” Roth said in a September 12 conversation with this reporter. “It’s the last and final hearing – or we

http://youtu.be/vFyFCuBgRTAhttp://www.toxies.com/http://www.youtube.com/watch?v=rTUEe0wvzwo&feature=share&list=UU5f-yNuGd6dMVt6Zt3FDETAhttp://www.enviroreporter.com/gallery/other-stories-gallery/the-2011-toxies/http://youtu.be/e5rLxKY4TAk

hope – before the planning commission and it’s obviously a big milestone of a day and they literally,you know, first I’ve got to track down the right person who has to track down the right person. So that’s abit of an issue for us. Can you hold your story off a few days and key it towards the city councilhearing?”

When told that attempting to get this information had been an ongoing effort not the least of which wasreviewing the entire EIR, and that AEG would have ample opportunity to comment in a future piece (anoffer repeated September 24), Roth appeared somewhat mollified.

“You know about our carbon neutrality part of it?” Roth asked before the call ended. “By the way, theNRDC has – we developed this plan with the NRDC who completely supports our project.”

But NRDC support no longer seems complete with Pettit’s criticism of the use of perchlorate atFarmers Field.

That, however, shouldn’t be much of an impediment to passage by the Los Angeles City Council thisFriday despite the surprise announcement that AEG would be put up for sale. That causedconsiderable fireworks at city hall as evidenced Mayor Villaraigosa’s petulant answers to Los AngelesTimes and Los Angeles Daily News reporters after the news broke that Phillip Anschutz was sellingthe huge company just days before the crucial city council vote.

“Whoever buys that team is going to have to live with the contract we negotiated, and I am very proud ofthat contract,” Villaraigosa said. “So from my vantage point, I feel very comfortable with the deal that wehave, and whoever owns AEG is going to have to live by that deal.”

There’s the rub. The lack of information about the extensive use of fireworks with their attendant toxinsis part of the deal. According to the California Environmental Quality Act, CEQA, that is a failing thatcould land the city and the new owner of AEG in court costing taxpayers time and money in the quest tobring the National Football League back to Los Angeles.

According to Joe Lyou, head of the Los Angeles-based Coalition for Clean Air, despite the fast trackthat Farmers Field has been afforded by legislation in Sacramento regarding CEQA, the company isnot entirely off the hook on the Farmers Field project. “This is a special case because the law thatexempted them from certain requirements under CEQA and said you have to go directly to a court ofappeals [if a legal challenge is made to the project’s EIR],” Lyou told EnviroReporter.com September26. “But normally you would go to superior court to challenge an environmental impact report under theCalifornia Environmental Quality Act. The judges will look at it – ‘first review.’ Normally the appellatecourt looks at the court’s decision made by the lower court but in this case they’ll have to consider theevidence in the record.”

That record includes both articles this reporter has written on AEG and Farmers Field to date.

“So the administrative record includes all of the comments, all the responses to comments that wentinto making the decision on the part of the city council and, in this case, the judges will look at whetherthere was an accurate description of the environmental impacts, whether there were significantenvironmental impacts that were admitted or not admitted [and] potential environmental effects thatwere not considered,” said Lyou. “Once they determine something is a significant environmental

impact, they are obligated to consider all feasible mitigation measures to reduce or eliminate thatimpact so that it is no longer significant.”

Whether that ever happens is to be seen. If the council and mayor don’t douse the fuse of toxicfireworks at Farmers Field before it’s built, the city and it citizens could have just about the sameamount of luck as Wile E. Coyote strapped to a rocket fueled by perchlorate.

http://youtu.be/Upt7ZTvcriY

enviroreporter.com http://www.enviroreporter.com/2012/09/aegs-perchlorate-problem/

Screen capture from AEG YouTube videorendering of fireworks at rock concert at just-

approved Farmers Field in Los Angeles.

AEG’s Perchlorate Problem

Farmers Field Environmental Impact Report Omits Toxic Perchlorate Fireworks Usage

* Los Angeles Planning Commission green lights AEG’s $1.2 billion Farmers Field * Perchlorate use and quantities not reported in $27 million AEG environmental report * AEG and city reject use of ‘greener’ fireworks used by Disney and shared royalty-free * Recent study shows huge increase in persistent long-lasting perchlorate after fireworks shows * Faulty EIR may open city and AEG to lawsuits

The Los Angeles City Planning Commission approved late yesterday the final environmentalimpact report for the $1.2 billion Farmers Fielddowntown on 68 acres of city-owned land. It was thesecond to last hurdle for developer, the AnschutzEntertainment Group (AEG).

“We’re going to have a state of the art green stadium,”said planning commissioner Sean Burton beforeputting the matter to a vote after effusive praise ofplanning staff for completing the massiveenvironmental impact report (EIR) which is made up ofa draft (DEIR) and a final (FEIR) together paid for andproduced by the applicant AEG.

The planning commission’s unanimous authorization will bring AEG closer to the expected approval ofthe city council September 28, a process fast-tracked to help AEG acquire a professional football teamby early next year to begin playing in the new stadium in 2017.

City Councilmember Jan Perry sought and got the public hearing notice period for the FEIR to be just10 days instead of 24 after yesterday’s yes-vote. Now the city council will take its final vote on theproject September 28.

Strong objections to this shortened period for public comment on the project next to the Staples Centerwere to avail. Community activists said that lessened analysis and comment period could burden poorneighborhoods adjacent to the site. Supporters, however, say Farmers Field will bring jobs to thecommunity, increase L.A.’s tax base and bring back pro football, the Super Bowl and even the FinalFour to the second largest city in the nation.

Local media has swooned over the project and its open-roofed venue with graceful wing-liketranslucent outdoor concourses. Two recent Los Angeles Times’ editorials managed to praise theproject while all but calling the community representatives extortionists.

“There is still, however, a coalition of community groups pushing for further environmental and other

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concessions, a fight they say they will pursue with the city’s elected leadership and, if that fails, in court,”Jim Newton wrote in a September 10 op-ed piece. “The coalition won’t get all it’s asking for. Itshouldn’t.”

The community groups Newton dismissed as mere pests included the Los Angeles Community ActionNetwork, the Legal Aid Foundation of Los Angeles (LAFLA), and the Nobel Peace Prize-winningPhysicians for Social Responsibility (PSR-LA) who are part of the Play Fair Farmers Field Coalition.The non-profit organizations are not opposing the stadium, rather they are fighting to reduce the healthimpacts on surrounding neighborhoods from the project.

These environmental threats include diesel and gasoline fumes from the thousands of cars that mayend up idling on streets around Farmers Field for lack of parking – AEG’s plan counts on 27 percent ofthe people coming to the stadium taking mass transit. Activists question this assumption, and contendthe project will put a premium on land surrounding the site to be built out as new parking as thecongestion increases the demand for more land for parking. They also say that in the rush to approvethe massive construction, which will include tearing down the Los Angeles Convention Center andreplacing it, environmental considerations will be missed or ignored entirely.

“The project’s developer, AEG, in return for being granted a special exemption from stateenvironmental laws, has pledged to build the nation’s greenest football stadium that will be an engine ofopportunity for working families in our city,” said LAFLA’s Staff Attorney for Community EconomicDevelopment, Zahirah Mann in a statement May 30 regarding the group’s DEIR comments onbehalf of the Play Fair at Farmers Field Coalition. “Our action today is an important step to holdingAEG to that promise.”

Information uncovered in the last week however suggests new hurdles.

THE ROCKETS’ RED GLARE

EnviroReporter.com has discovered that the Farmers Field environmental reports fail to accountaccurately for all the toxins in planned fireworks displays including the oxidizer perchlorate which iscommon to most fireworks as a main ingredient. We have also discovered that two the four heavymetals listed in the EIR as the fireworks’ ingredients, both toxic, are listed with quantities that areerroneous. In addition, AEG maintains there are no ways to mitigate its fireworks – but lower-emissionfireworks options are in fact readily available.

Fireworks will be allowed at Farmers Field every day

http://www.latimes.com/news/opinion/commentary/la-oe-newton-football-stadium-20120910,0,6690448.columnhttp://www.lafla.org/laflablog/?m=20120530http://www.lafla.org/pdf/Comment Letter on DEIR.pdfhttp://playfairfarmersfield.wordpress.com/

AEG rendering of Olympic rings in fireworksover future Farmers Field.

Fireworks will be allowed at Farmers Field every dayof the year from mid-morning until nearly midnight. AnAEG computer-generated video on its YouTubechannel shows a rock concert with robust fireworksgoing off in the hazy air. Fans’ exposure to fireworksemissions, along with any attendant health effects, arenot analyzed in the EIR. Without perchlorate identifiedas an ingredient, there is little to study let alonemitigate.

Regardless, the EIR does address the risk fromfireworks not by analyzing how much perchlorate willbe blown off in the stadium but by comparing theexplosions to the total emissions of the project. “[P]otential emissions from fireworks would representless than 0.1 percent of potential Project-related emissions and would occur on a limited number ofdays per year,” the EIR reads in response to a public comment. “However, in response to thiscomment, the health risk assessment has been updated to include air toxic emissions from fireworks.”

The included air toxic emissions from fireworks did not include the perchlorate which is common tomost fireworks, including “green fireworks,” as well as the traditional chemical makeups for the burstslike the ones Farmers Field will be using.

In response to public comments on the DEIR submitted by LAFLA regarding the use of perchlorate andheavy metals in the fireworks, AEG countered – without explanation – by reducing the number ofdedicated fireworks shows yearly by nearly 60%. But if the fireworks aren’t packing anything toxic likeperchlorate, it doesn’t follow that the company would have to reduce its shows.

In regards to so-called low emissions fireworks usage, which swap out the gunpowder propellant with acompressed air launch system, the company has agreed to use such technology as an option but not arequirement. “Lower emissions fireworks shall be used to the extent feasible for ‘proximate fireworks’where it would achieve a similar fireworks effect.” In other words, traditional fireworks can and will beused.

Depending on which way the wind is blowing, smoke from the fireworks could blow on the predominatebreeze from the west into the tony confines of South Park condos which would have a view, and a nose,for the stadium cost a cool million or more. When the wind reverses in Santa Ana conditions, fireworkssmoke would blow into the working class and immigrant community of the Pico Union neighborhood.

“It seems like one of the things that’s lacking is fullydocumenting the extent of the problem and then saywhether they can or cannot mitigate the problem,”Martha Dina Argüello, executive director of PSR-LA,told EnviroReporter.com. “I think it lacking specificnumbers on the [fireworks] emissions is a problem andnot telling us what is actually in the fireworks is aproblem.”

Perchlorate has negatively impacted at least 27 states

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according to the EPA, none more so than Californiawhere the chemical has been used extensively.Perchlorate is heavily regulated in California and itsusage, handling and storage must be reported to the government.

“Perchlorate and its salts are used in solid propellant for rockets, missiles, and fireworks, andelsewhere (e.g., production of matches, flares, pyrotechnics, ordnance, and explosives). Their use canlead to releases of perchlorate into the environment,” says the California Department of PublicHealth (CDPH).

“Perchlorate’s interference with iodide uptake by the thyroid gland can decrease production ofthyroid hormones, which are needed for prenatal and postnatal growth and development, as well as fornormal metabolism and mental function in the adult,” CDPH states in its “Health Concerns” section onperchlorate. “Its effects on the thyroid gland are the basis of the 6-µg/L public health goal (PHG)established in 2004 by Cal/EPA’s Office of Environmental Health Hazard Assessment,” which isequivalent to 6 parts per billion (ppb).

Such is the public health concern over perchlorate thatthe U.S. Environmental Protection Agency (EPA) hasdecided to regulate the chemical under the SafeDrinking Water. California EPA’s Department of ToxicSubstances Control (DTSC), the department chargedwith enforcing toxic chemicals, has attempted robuststate regulation of perchlorate.

“Perchlorate is becoming a serious threat to humanhealth and water resources,” says DTSC on itsperchlorate portal page on its website. “In addition tooverseeing the cleanup of sites contaminated with perchlorate, AB 826, the PerchlorateContamination Prevention Act of 2003, required DTSC to adopt regulations specifying bestmanagement practices for perchlorate and perchlorate-containing substances. The Perchlorate BestManagement Practices were adopted on December 31, 2005 and became operative on July 1, 2006.”

Yet despite the known threats that perchlorate presents, AEG’s EIR never admits it usage in thefireworks that stadium operators are going to be blasting off in the new Farmers Field. Not only is theperchlorate usage obscured in the EIR, it isn’t weighed up as toxins traditionally are in environmentalimpact reports, usually in pounds per day and pounds per year.

“It’s important for us to look at perchlorate emissions from fireworks,” says Joe Lyou, head of the LosAngeles-based Coalition for Clean Air in a telephone interview with EnviroReporter.com. “We knowthat it’s a source for perchlorate. We know that perchlorate has been found to cause public healthproblems so certainly AEG has not analyzed perchlorate emissions in fireworks. They need to do so.”

HEAVY METAL THUNDER

EnviroReporter.com has also discovered that the only fireworks ingredients that are listed in the EIRare the heavy metal contaminants that are used to color the fireworks: strontium (red), barium (green),

http://www.epa.gov/fedfac/pdf/technical_fact_sheet_perchlorate.pdfhttp://www.cdph.ca.gov/certlic/drinkingwater/Pages/Perchlorate.aspxhttp://www.oehha.ca.gov/water/phg/perchphg31204.htmlhttp://www.oehha.ca.gov/water/phg/perchphg31204.htmlhttp://www.enviroreporter.com/wp-content/uploads/2012/09/Fireworks-in-Kurume-Fukuoka-Japan-August-5-2011.pnghttp://www.dtsc.ca.gov/HazardousWaste/Perchlorate/http://leginfo.ca.gov/pub/03-04/bill/asm/ab_0801-0850/ab_826_bill_20030929_chaptered.html

copper (blue) and antimony (white and glitter effects). Yet even the numbers for these toxins aresuspect: the EIR’s figures for the ‘per day’ and ‘per year’ usage for copper and antimony, respectively,are the same.

Either the EIR is incorrect or Farmers Field plans to only have blue fireworks and white fireworks withglitter effects just one day a year which is highly unlikely. More likely is that the calculations areincorrect. This seems surprising considering the 18 months AEG took to create its $27 million EIR thattotals at least 14,759 pages.

“You’ve got to at least have all the primary colors to get to the other colors you use in fireworks,” saysArgüello. “I can’t imagine a show that would only use red or only going to use yellow.”

EnviroReporter.com has contacted AEG and provided a requested email outlining questionsconcerning the fireworks. AEG will be responding to our inquiries according to the company rep. A listof EnviroReporter.com’s questions about the missing information concerning the pyrotechnics wasalso submitted to the Los Angeles Planning Commission before its meeting.

Farmers Field will be allowed to shoot off fireworks 365days a year at the stadium from 10:00am to 11:30pm.There will be 15 dedicated fireworks shows a yearlasting up to 20 minutes long like on July 4. Otherfireworks may accompany the national anthem, footballtouchdowns or rock concerts like the May 8 videorendering on Farmers Field’s YouTube channel shows.A virtual crowd watches a rock show as fireworks in thevideo explode around the edge of the giant ovalopening in massive blasts above the stadium filling itwith smoke.

Color-creating heavy metals revealed to be in the Farmers Field fireworks can impact human healthand the environment as well as perchlorate. Barium nitrate, added to fireworks to create that greencolor, is toxic according to Hazard.com, which says ingestion of the heavy metal “May cause tightnessof the muscles of the face and neck, vomiting, diarrhea, abdominal pain, muscular tremors, anxiety,weakness, labored breathing, cardiac irregularity, convulsions, and death from cardiac and respiratoryfailure.”

Inhalation of barium, according to Hazard.com, “Causes irritation to the respiratory tract. Symptomsmay include coughing, shortness of breath. Systemic poisoning may occur with symptoms similar tothose of ingestion.”

One commenter on the project voiced concern about cadmium in the fireworks. “Used to produce awide range of fireworks colors, [cadmium] is also a known human carcinogen,” the commenter wrote.“Breathing high levels of cadmium can seriously damage the lungs, and consuming it can fluster thestomach, often resulting in vomiting and diarrhea. Long-term exposure can lead to kidney disease, lungdamage and fragile bones. Plants, fish and other animals take up cadmium from the environment,meaning that any released into waterways from a fireworks show can be passed up the food chain.”

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The closest waterway to the future Farmers Field is the Los Angeles River, a little over two miles to theeast. The waterway was recently reaffirmed as being protected by the Clean Water Act.

Copper compounds are used to produce blue colors, even though they produce dioxin, which has beenlinked to cancer according to a 1999 study by Dr. Robertus Vichman of Braunschweig TechnicalUniversity in Germany. According to the report, the intense heat generated by the perchlorate infireworks ignites copper coloring compounds giving off significant amounts of dioxin.

Perchlorate’s use in Farmers Field is particularly troubling not just because its use is obscured and notmeasured in the EIR let alone mitigated; the chemical has wreaked havoc across California in both itsammonium perchlorate and potassium perchlorate forms. While it’s likely that the potassiumperchlorate compound is going to be used in Farmers Field, the EIR’s failure to identify and quantify theamount of perchlorate to be ignited doesn’t provide the opportunity to distinguish the effects of whichperchlorate to be utilized.

Regardless, perchlorate’s affects locally, regionally and statewide have been significant. AsEnviroReporter.com has previously reported in 2005, perchlorate has polluted more than 330drinking water sources in California where concentrations of the toxin have exceeded the state’sprovisional action-reporting level of 6 ppb. That number has climbed to over 350 now according to theEPA’s Region 9 office which oversees the state.

The San Gabriel Valley is an EPA Superfund Site which is a designation for some of the mostcontaminated locations in the country. Shorthand for the Comprehensive Environmental Response,Compensation, and Liability Act of 1980, Superfund gives wide federal powers to clean upcontamination or anticipated hazardous substances at sites and charge the responsible party orparties for the cost. If the responsible party can’t be found, EPA has a special Superfund trust fund topay for the cleanup.

At least 23 drinking water wells have been contaminated with perchlorate in the San Gabriel Valley,most of which are situated in the Azusa and Baldwin Park area. The first system to clean up theperchlorate was installed in 2001 with four currently in place. These ion exchange technology-drivensystems cost more than $17 million to construct and cost about $5 million a year to operate. By 2024,EPA estimates that the cost of cleaning perchlorate out of the San Gabriel Valley groundwater isstaggering – more than $200 million to clean the groundwater of perchlorate and other contaminantsjust at the Baldwin Park water remediation station alone.

ON BARSTOWED TIME

Over 40,000 people of the Mojave Desert town of Barstow learned about perchlorate the hard way inNovember 2011. The town, which is exactly midway between Los Angeles and Las Vegas, suddenlybecame aware of a perchlorate contamination plume that had first been detected from a test on theSoap Mine Road Well which had high perchlorate. For days thousands of people were forced to queueup in long lines for hours to get drinking water that was being hauled into the city on an emergencybasis because a number of wells in town used for potable water were testing higher than California’sdrinking water limit of 6 ppb for perchlorate.

Investigators for the Lahontan Regional Water

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Quality Control Board found the source of theperchlorate about a mile away at the private home of along-deceased man who used to own the Mojave RiverPyrotechnics Company. Apparently, after his companywent bankrupt in the 1980s, the man buried much of theleftover perchlorate in his back yard on Poplar Lanenear the usually dry wash that is the Mojave River.

Perchlorate, which is very mobile and persistent innature, was eventually mapped out underground withthe majority of the goo within an area about 1,400 feetwide and 3,500 feet long. Groundwater, obviously aprecious commodity in the desert, was found with perchlorate as high as 110,000 ppb or over 18,000times the California’s perchlorate drinking water standard. Soil came in at more than 500,000 ppb inthe worst hit dumps on the property.

Just cleaning up the soil will cost millions according to the EPA. The groundwater remediation would bea much greater challenge and take far longer.

WAR FACTORIES

Perchlorate is also used in missile fuel as an oxidizer and, just like in fireworks, burns fast and hot. Thatlegacy has left aerospace-related sites like Aerojet Chino Hills massively contaminated with the toxin.When LA Weekly exposed perchlorate pollution at the facility in May 2000 followed by OC Weekly, ithelped precipitate $46 million worth of cleanup. The property still isn’t fully free of perchlorate,depleted uranium and unexploded ordnance debris and remains a sore spot with a number ofresidents in the region.

Closer to Los Angeles 35 northwest of downtown is theSanta Susana Field Laboratory which, besidesbeing infamous for being the site of the country’s worstpartial nuclear meltdown in 1959, is polluted byperchlorate. Over 30,000 rocket test took place at the2,850-acre aerospace complex which had giganticrocket test stands, many of which are still standingtoday amidst land impacted by perchlorate.

The perchlorate in the fuel fired off testing rockets likethe Atlas, Thor and Saturn, left the test stands,buildings, land and groundwater highly contaminated. In2004, data showed perchlorate in Building 359, on theproperty now owned by Boeing, as having 34 of 90samples contaminated with perchlorate so high that they all exceeded “field action levels” whereimmediate action is mandatory. One sample came back positive for 71,290 ppb of perchlorate.

Perchlorate is a chemical of concern for many Southern Californians because of its widespread foulingof the environment and its effects on the development of the very young and young. These illustrations

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point to the seriousness of the chemical, especially when large amounts of it are being used in a semi-enclosed space for optional spectacle.

A decade-long struggle over developing Ahmanson Ranch began coming to a head in 2002. Thereon land bordering Rocketdyne’s southern buffer zone, now-defunct Washington Mutual was on its wayto building 3,050 homes in a huge $2 billion development until media pressure forced the company totest its groundwater. “WaMu” had planned to use 660,000 gallons of the groundwater each day toirrigate it common areas, parks and playgrounds.

When one of the wells came back positive with 28 ppb of perchlorate, and Rocketdyne Ranchexposed that and other contamination problems with the property, the public outcry grew and thecompany begrudgingly accepted an offer of $150 million to give the land to the state which turned it intothe Upper Las Virgenes Open Space Preserve. It is the largest single public acquisition of land in thehistory of both Ventura and Los Angeles counties.

SMOKE ON THE WATER

A May 2007 study by the EPA’s Office of Research and Development, National Risk ManagementResearch Laboratory in Oklahoma City made the danger of perchlorate in fireworks abundantly clear.“Perchlorate Behavior in a Municipal Lake Following Fireworks Displays” showed that after afireworks show, the lake’s water had 24 to 1,028 times the baseline amount of perchlorate. It took 20 to80 days for the perchlorate concentrations to return to background.

That the perchlorate usage is not listed in the Farmers Field EIR, let alone admitted to, creates anotherchallenge in the EIR: mitigation. Without acknowledging the perchlorate-based fireworks, there can beno discussion of how to mitigate them. Indeed, the EIR says as much.

“There are no feasible mitigation measures that would reduce impacts associated with the parkinggarage and firework displays to a less than significant level,” the DEIR stated. “Impacts related tofireworks displays would be limited (up to 35 shows per year) and of short duration (up to 20 minutesper display show) but would still be significant and unavoidable.”

Activists say that AEG should have considered going greener with Farmers Field fireworks.“Fortunately, there is a better way to mitigate the amounts you use with ‘green fireworks’ or the lower-emission fireworks,” says Argüello. “That technology is readily available from Disney, as I understand,and that’s what they use. They do very elaborate close to ground level fireworks everyday so they’vedeveloped where you’re using a lot less of the propellant to get the fireworks into the air which is wherea lot of those emissions come from.”

Disneyland holds fireworks shows over 230 nights ofthe year. Responding to numerous complaints since1991 to the South Coast Air Quality ManagementDistrict citing ash, smoke, smell and property damagefrom falling firecracker shells, Disney switched tocompressed air in 2004 to shoot up about 350 shellsused per show. By removing the gunpowder propellant,much of the smoke that clouds traditional fireworks

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shows doesn’t exist making the flashes andpyrotechnics brighter.

In its first year alone, Disney ditched 30,000 pounds ofthe 90,000 pounds it used in 2003, a significantreduction of a third. The company has offered the use of its compressed-air launch design system toother fireworks-using entertainment centers license fee free.

“[AEG] also needs to look into mitigation measures such as air launch technology that can reduce theamount of perchlorate emitted into the air,” says Lyou. “As an entity that wants to be an environmentalleader, I would encourage AEG to take a hard look at this issue as well as other air quality issuesassociated with their Farmers Field project.”

Compressed air launching of fireworks gets rid of the gunpowder, but not the perchlorate and toxicheavy metals. That means that those 60,000 pounds of fireworks Disney uses are primarily perchlorate,heavy metals, plastic and paper.

All of this perchlorate can be eliminated according a former Los Alamos explosives chemist MikeHiskey who cofounded a company called DMD Systems that produces perchlorate-free fireworks withabout a tenth the amount of barium used in the kind of fireworks AEG will likely use.

Using nitrocellulose as fuel and replacing perchlorate with nitrates as oxidizer, the resultant propulsionand burst produces only stable gases like water, carbon dioxide and nitrogen cutting down greatly onsmoke and small particulates. Not only are a wider palette of hues available, there are new formulationsof colors resulting in deeper reds and blues impossible to achieve with the fireworks both AEG andDisney use.

In addition, illuminated night kite shows, laser shows and holographic fireworks are all technologieswithin reach of any large entertainment company like AEG, Disney, Universal Studios and Six Flagsthat want to truly own the “green fireworks and special effects” mantle.

But don’t look for it in Los Angeles at Farmers Field. This expensive endeavor has been planned downto the tiniest details making the exclusion of the perchlorate data puzzling at best. Cheap Chineseperchlorate filled fireworks are, well – cheaper.

BOOSTER SHOT

The Los Angeles Times boosterism of the AEG project seems to have blinded it to a more criticalexamination of the Farmers Field EIR. Hostility directed at community activists making the op-edpages isn’t a replacement for in-depth investigative journalism.

“AEG’s already agreed to dozens of community benefits, but if it won’t accept more, the project’s criticswant the council to send the environmental impact report back for more work,” opined Jim Newton.“And if that doesn’t work, they’re threatening to sue. Of course, one person’s mitigation request isanother’s idea of extortion.”

This was preceded the day earlier in the paper by an unsigned editorial entitled “An L.A.-friendlyfootball stadium” which made this prescient observation: “The final negotiations regarding the football

stadium revolve around the project’s environmental impact report, a 10,000-page document that thecouncil members have almost certainly not read.”

Had the Times actually read the 11,149-page DEIR and then the 3,610-page FEIR a little closer itmight have noticed that demands for better pollution mitigation weren’t extortion. Perchlorate whichdoesn’t distinguish between people in Pico Union or South Park or the employees, players, performersand fans of Farmers Field.

Taking the residents seriously and obeyingenvironmental laws related to compounds asdangerous as perchlorate could have the added benefitof protecting against potential future lawsuits over themissing fireworks data, data that almost certainlyinvolves large amount of perchlorate use. Thoselawsuits could target the city and, if successful, end upcosting the taxpayers plenty because their governmentwas too cozy with the developer and the media tooenfeebled to expose it.

After the unanimous vote late last night, the Timescouldn’t help but lampoon community advocates onceagain with the provocative headline “Anti-poverty group seeks $60 million from NFL stadiumdeveloper” making it look like one of the Play Fair Farmers Field coalition members, the Los AngelesCommunity Action Network, was being insanely greedy. Actually the request was for $2 million a yearfor 30 years.

AEG claimed to reporter David Zahniser that they could have “had a deal by now” if it had paid thegroup off its $10 million demand. That below the belt – and inaccurate – accusation seems to indicateAEG’s inclination to perhaps, well, not play fair.

For now, however, activists are still sounding a conciliatory tone.

“You know if the happiest place on Earth can do it, I think AEG can do it,” Argüello says. “I see noreason why they couldn’t, given their commitment to environmental stewardship, or why they wouldn’t beable to get this new technology into their stadium so they can tout their sustainability practices.”

Don’t hold your breath. Until you have to.

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11-0023_pc_09-27-12.pdfAEG Punts Perchlorate Football at Farmers Field

11-0023_pc_9-27-2012.pdfAEG’s Perchlorate Problem