Paso Robles City Council
October 6, 2026

Diversifying a Local Economy | 16
of science and engineering to tell that story. So, the
arts aspect of it. You know helping people be able to
visualize what’s going on out there and what they’re
seeing. I think all
of those things
play into the
long-term health
of the program,
and also just
helping to get
more people
interested, more
kids interested in
perusing those
kinds of education goals.”
The Director of Human Resources for a vehicle launch
provider noted, “At the end of the day, what we are
looking for are people who have been taught the basic
principles of engineering or manufacturing, but have
been encouraged in an academic environment to think
creatively with problem solving skills.”
A Demand for Engineers and Technicians
Across Company Profiles
When probed, participants discussed the specific
roles and skillsets described above. However, most
deliberated needs across the general categories of engineer vs. technician. They emphasized the indispensable roles of both engineers and technicians in driving innovation and facilitating production within the aerospace industry, highlighting a growing demand
for technicians. For example, a business development
manager emphasized the critical role of technicians in
translating engineering designs into tangible products, “Really novel new pieces are being manufactured, and
so it requires people who then can manufacture from
an engineer specification, something that has been
designed. So that’s sort of like the standard process.” An aerospace consultant concurred, “You need people
who can help you figure out how to take your idea and
turn it into reality. That’s really what a technician does.” Numerous participants echoed the sentiment of a
growing need for technicians, especially as businesses expand and the industry evolves. This sentiment was further corroborated by examples from different
sectors within aerospace, indicating a widespread recognition of the increasing demand for technician roles.

A satellite developer reported, “A lot of what we can
do can be built by engineers. But if we’re gonna get to the point where we’re proliferating a lot of our rockets and our satellites and taking advantage
of economies of scale, we’re
gonna need a larger technician
base.” An employee of another rapidly growing company
in the vehicle launch provider
sector reported, “We see more
urgency in the hiring of technicians than the engineers,” with an aerospace consultant explaining, “There is a difference between a startup or a company that is still conducting R&D and a company that is actually in production and
is commercialized.”
“At the end of the day, what
we are looking for are people
who have been taught the basic
principles of engineering or
manufacturing, but have been
encouraged in an academic
environment to think creatively
with problem solving skills.”
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Diversifying a Local Economy | 17
The CEO of a rapidly growing payload provider
outlined a strategic personnel approach, indicating a
shift towards a higher proportion of technicians in response to increased production demands: “The number we are going to have in the next 3 years is 30% engineers or people with higher education degrees, and then 70% of people that have professional training.

A career developed with 2 years of training and then
you go find a job.” However, it was emphasized that
these technician jobs represent highly specialized roles requiring specific skillsets to match the complexity of aerospace projects. For example, a satellite developer
reported, “I do need a large number of smart technicians that can go and look at control drawings, make the smart decisions on how to accomplish a certain
design and get it done for these bespoke kind of new
satellites that are, they’re almost one of a kind rather than the mass-produced types of things.” Another
CEO argued, “the space industry has high requirements for certain skills because we are making things that are difficult to make. They are one of a kind. This is difficult to do.” A CEO of
a start up company argued,
“You have a core team
of engineers that pretty
much do the R&D, but you
are going to have about
65 to 70 percent of your
workforce are technicians.

They machine, they analyze
processes, they do logistics. They mount things, do
procurement. I’m starting a
company from scratch, and
sometimes an engineer is
not what I need most.”
Education and Workforce Development
Opportunities and Challenges
Labor Market Shortages
A pervasive theme emerged regarding the challenges associated with hiring trained and qualified employees with these skillsets. Industry participants
expressed a struggle to find the right people, with
hiring efforts being described as a constant battle over the past few years. Participants note the difficulty of competing for engineers and specialists against industry giants, which are major draws for potential candidates. This intense competition was argued to create a highly competitive hiring landscape within the industry. For example, A CEO of a satellite
operator reported, “I would
say there are not enough people to hire. Hiring is constant.

For the last four years, it has
been a constant struggle to
find the right people.” A CEO
of a service provider said, “Everybody’s looking for the same kind of people. If you went on
[aerospace company’s] website, you’ll see the very same position descriptions as ours.”
A Director of Human Resources argued, “we’re all
looking for the same talent.”
Several participants discussed the challenges
associated with competing for talent among the larger,
established aerospace companies. A CEO of a payload
provider noted, “We are in a really tough spot competing for engineers. We have [company] and [company], that are a big draw. So, lots of competition. A lot.

Very very competitive.”
“A lot of what we can do
can be built by engineers.

But if we’re gonna get
to the point where we’re
proliferating a lot of our
rockets and our satellites
and taking advantage
of economies of scale,
we’re gonna need a larger
technician base.”
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Diversifying a Local Economy | 18
Moreover, participants expressed frustration with
the scarcity of candidates possessing the specific
expertise required for their projects. For example, a
lead engineer mentioned the aggressive interviewing
process that begins as soon as funds are secured, yet
finding candidates with the necessary specialized skills remains a significance challenge, “The minute we get
money, we start interviewing aggressively.

But there are so few candidates that specialize in the
fields that we need.” A particularly illustrative comment from a Director of Human Resources captures the daunting task of finding talent for cutting-edge
projects, “We are working towards designing things
that have never been built before for things we can’t
even imagine.”
The Need to Train and Induct New Entrants to
the Workforce
Space industry participants discussed a prevailing
trend among some companies that favored the hiring
of tenured employees over new entrants to the job
market. This preference for experienced professionals
presents challenges for younger individuals seeking
to break into the industry, as noted by several participants who described the difficulty of securing positions without prior aerospace ties. A CEO reported, “So it’s a robust job market right now. However, if you are a new grad, new entrant, and you don’t have any
ties to the aerospace industry, it’s almost like, you’re not gonna get in. That’s my experience.” A satellite
developer reported, “If I were to look at a traditional aerospace company, their workforce, when I go work
with them, tends to be an older set.” An aerospace
consultant elaborated, “Certainly when you look at
the traditional big space companies, I think they do
tend to hold on to their senior engineers. I don’t see
as many of them moving around, probably because
they’re making a pretty good paycheck there. And
they’re doing exciting and interesting things in those
companies, and they don’t necessarily feel the need to
move on.”
“we’re all looking for
the same talent.”
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Diversifying a Local Economy | 19
Despite these preferences for hiring experienced
professionals, there was also a recognition of the need to cultivate a pipeline of new talent to address future workforce shortages. Concerns were raised about the
impending retirement of seasoned professions and the
lack of mid-level professionals to fill the gap. A CEO of a service provider argued,
It’s part of our diversity issues. You know, we grow
this group of people into senior engineers. They’re all gonna retire. I mean, its life, right? Nobody’s gonna
work for 60 years. That’s doesn’t happen, though it’s
creating new problems for the industry. If we don’t
deal with it, we’re not gonna have those seasoned
people in 20
years, right?
Because we’re not
bringing enough
new people in.

Another
participant said,
“I think there’s
an imbalance in
terms of, there’s
a rush to get new
products to market. So, everybody wants experienced
people because they’re gonna get them there quicker.

When my opinion is, we [should] spend a little time
opening up some entry level positions. So, we get that
pipeline flowing.”
While some described a preference to hire more
experienced employees, a CEO of a satellite operator
said “The more experienced persons are more difficult
“You have to be deliberate about
carving out scope and maybe
understanding where you can take a
little risk, bring in some new grads,
teach them, and help them get up
to speed so they can go faster 2, 3
years from now.”
to find and to keep. At least that’s the case in [country] because it’s a nascent industry and there aren’t many
people with the experience.” And a CEO of a payload
provider company wished he could hire more mid-level professionals. He argued, “We have few mid-careers. Right now, it’s really me and then I have 25 kids who are a generation younger than me. We need more
middle level professionals, and that has been difficult.” In response to these gaps, a CEO of a service provider contemplated how to shift hiring and training
practices to better prepare the newer entrants and
to meet growing employment demands, “You have
to be deliberate about carving out scope and maybe
understanding where you can take a little risk, bring in some new grads, teach them, and help them get up to
speed so they can go faster 2, 3 years from now.”
Amidst these challenges, there was a sense of
optimism about the next generation of aerospace professionals. Participants expressed enthusiasm for the potential of new entrants to quickly learn and adapt,
highlighting the importance of investing in training
and development programs to nurture emerging
talent. For example, a CEO agreed that “training is always an issue as a startup. You always want to go fast.

You don’t want to necessarily take the time to train”,
though he argued, “but people right out of college
tend to learn quickly.” A satellite developer argued, “I would say that in my experience we have a very
aging population of
experts, and they were
from the time when
space and the Cold War
was really happening.

And they have done
phenomenal things. But
we’re ripe for that next
generation. And this is,
this is the time. I’m really excited to see this generation. I wish I could live with this generation.” Uncertainty about Vocational and Apprenticeship Programs Aerospace industry participants discussed the critical needs for vocationally trained technicians to bridge the gap between engineering designs and practical
implementation. However, entrenched biases and misAttachment 4

Diversifying a Local Economy | 20
conceptions about these roles and their training persist, hindering efforts to fully harness their potential.

For example, an aerospace consultant reported, “What
I’ve heard consistently in the workforce discussions
is that there’s a real demand for more of the Vo-tech
types. So, we need people who can actually take what
the engineers come up with and turn it into reality
and then repair it. There just aren’t enough of those
people”. Yet conceptions about inherent differences
between engineers and technicians may challenge
efforts to expand technician roles. A CEO claimed,
“It’s easier for engineers to start fresh. It’s harder for technicians to start fresh,” while another participant
reported, “I prefer to hire master technicians, but that also creates a difficulty because young engineers will
not know how to work with the master technicians.”
Another participant reported “apprenticeships could
be good for technicians, but somebody has to be willing to work in manufacturing day in and day out.” While the demand for skilled technicians is evident, many industry participants remain unaware or uncertain about vocational training programs. Some
express tepid enthusiasm or frustration with their
attempts to recruit from these programs, citing difficulties in finding suitable candidates or concerns about cultural fit. One CEO of a payload provider had heard
of a nearby program that was funded by a grant that
gave potential technicians “community college and
industry experience, but we just didn’t get any good
candidates. So, I know they are there. I just don’t know how to pick them.” When asked if their company has
hired vocationally or apprenticeship trained employees, another participant said, “We have not succeeded, though we haven’t really tried that hard. But we will have to do it if we want to grow technicians.”
Another CEO said, “There is really no, like no college
we can go to. There are specialized programs, people
who can maintain equipment and install you know
plumbing, but we haven’t really found a way to recruit
them.” Another participant had questions about apprenticeship programs in his field, and apprehension about cultural fit, “I’ll be honest, I’m not sure what
apprenticeship training means for software products.

If that means like a web software development boot
camp, then yes, but it would have to depend a lot
on well, cultural, a cultural fit is always key. So if that person is willing to jump in and learn, and I feel like they have that personality that’s cultural fit for us, then I wouldn’t have a problem hiring them out of a boot
camp. But I would have to get that sense out of the
interview.”
Despite these challenges, some industry participants highlighted success stories of technicians trained through apprenticeship programs. A participant with
a payload provider described hiring one of his top
programmers from a vocational training program,
“A gentleman who is out on our floor, who is one of
our best programmers, he started his education in
high school, did two years, I believe, in a vocational
program in high school, then went on and did a fouryear trade school. He used his vocational school earn credits towards that trade school education, and then
went to do on the job training for a certain amount of
hours, and then a certain amount of hours to become
a fully certified journeyman.” A company outside of
the United States also described positive experiences
with apprenticeship programs, “I think it does create
a more balanced technician to have both the practical
experience and the tech qualification. I’ve recently
hired two young apprentices who completed their apprenticeship training, one in [location] and one in [location], where they have come out of very large Rolls Royce style factories where they have very structured
Attachment 4

Diversifying a Local Economy | 21
apprenticeship programs. But what struck me about
both of them was their curiosity, their drive to learn, their interest in how things work and fit together. That’s why I hired both of them and brought them halfway
around the world.”
However, shifting mindsets about technician roles
is not without its obstacles. Technician roles were
described to be less prestigious than engineering
positions, leading aspiring technicians to doubt their
acceptance within the industry. For example, a Director of Human Resources reported. “It’s gotta be seen as a respectable profession, and I think somewhere
in the noise of that elitism, a lot of the people I’ve
spoken to who have applied for apprenticeship roles
are so excited to be talking to an aerospace company,
because they will say ‘I didn’t think you’d be interested in me.’” A United States based participant argued, “I
think something we’ve lost in this country is this idea of apprenticeships. It would be incredibly helpful because then they’re coming in and they don’t just bring their own experience, they bring the experience of the
person they’ve apprenticed to, and that’s gonna be a
lot more easy to accept than it is for the person who
just walks in the door out of technical school.”
Diversifying the Profession
Issues related to diversifying the industry emerged
and were often framed as important opportunities.

Efforts to increase diversity include initiatives targeting high schools to encourage interest in engineering and science among underrepresented groups. Solutions discussed include using diversity metrics to track progress and incentivizing the hiring of diverse candidates, particular among new entrants to the workforce.

Overall, there is recognition of the need for proactive measures to address diversity challenges within the
industry.

A Human Resources Director with a vehicle launch
provider explained, “If we don’t find enough men,
then we gotta get more women in. We did it during
the Second World War. There’s no reason we can’t go
back.” An aerospace consultant argued, “One thing
that has started to happen is that there are programs
that reach down into the high schools and start getting people interested. You know, they’re saying, we’re not
seeing as many women, for example, that are becoming aerospace engineers or electrical engineers, and so they are going into these schools and trying to get
people excited about engineering and science.”
A couple solutions were discussed including
utilizing diversity metrics and increasing the hire of
new entrants to the workforce. As a CEO of a service
provider explained,
We already know the diversity of the pool of the
people that we have already, that you know have 10 to
30 year’s experience. That is kind of set. So if we were to do something like measure how many new grad
positions are you opening versus how many position
do you have? What’s that percentage? How many
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Diversifying a Local Economy | 22
people are you bringing in that bring diversity to those new positions? So making it a little more public and
saying, ‘who’s really contributing to growing the pool
of candidates?
When asked about solutions to diversity challenges in the industry, another participant replied, “it’s a great question. Our industry has never been fantastic
in this area. My opinion? What’s it gonna take? I think it’s gonna take incentives.”
Increasing Experiential Learning
and Certification Opportunities.

When space industry participants were asked what
they would change about the way potential employees
were prepared for their jobs, two themes emerged:
a desire for more experiential learning opportunities
within both vocational and university based educational contexts, and the development of relevant certifications that would signal to employers that an
employee had mastered the skillsets necessary for the
role. For example, a CEO of a service provider said, “I think if I was gonna make any kind of change, I think
it would be having more hands-on understanding as
to what you’re doing in the real world as opposed to
just an idea of how thing go. More experience in the
field.” This applied to both engineering and technician roles. A founder of a startup company said, “we hire
bachelor’s that have very good training and we especially look at project experience. Do they have a skills portfolio? At the technician level, we hire those with
at least 5 years’ experience, and they have developed
hands-on skills.” Another company CEO said, “I think
that it is more important to have practical experience
than a degree, though of course, the degree opens up
different doors and windows.” The Director of Human
Resources for a vehicle launch provider argued, “From
a business perspective, the students need to know use
cases. They need to know real world business ideas
that are happening. What I’m talking about is a mindset where they need to be exposed to what’s going on in industry, and they need to be exposed early on
because then they can also start looking at some of
the problems.” She wished that more training and
education programs made space for risk taking and
failure, noting “In an academic environment, you are
not allowed to admit that you have failed.”
Others discussed the benefit of more certification
programs that would signal mastery of skills relevant to the role. For example, a lead engineer with a service
provider said, “It would help knowing that somebody
has, like you know, proficiency in doing something so
there’s less ramp up when we hire them.” Another participant working at a vehicle launch provider company noted, “It would be helpful if we hire somebody who is
also trained to a level or has some certification under their belt.”
Additionally, there was a call for greater collaboration between industry and educational institutions with suggestions for industry involvement in training programs and partnerships with universities and trade schools. Examples were provided of companies
already engaging in such collaboration to support the
development of the industry. When discussing certification programs, a CEO said, “I think we would need to work directly with the trade schools, to involve us
in the training.” One company described a model
for doing this. His company already works with other
Attachment 4

Diversifying a Local Economy | 23
companies to support the development of the industry “Our manufacturing manager and I went down to [aerospace company] to do a presentation on the
future of manufacturing and engineering and how this
relationship is growing in the future. Just to help some of their engineers understand the challenge in the
manufacturing sector for some of the designs that are
coming down the pipe. We could do that with universities.” Discussion
These findings underscore the thriving state of the
space industry, marked by robust economic conditions, low unemployment rates, and significant growth opportunities. However, this growth has brought forth
challenges in terms of filling job vacancies as well
as concerns about the future pipeline of skilled professionals. These concerns were driven, in part, by a sense of urgency in response to expanding commercial
opportunities, which prompted some organizations to
prioritize hiring experienced professionals over developing new talent. Given the impending retirement of a sizable portion of the current workforce, these findings emphasize the need for strategic workforce development initiatives to ensure the industry’s long-term workforce sustainability.

Addressing the uncertainties surrounding vocational training pathways, industry participants stressed the importance of collaboration between industry and
higher education institutions. The proximity of leading community colleges to the proposed Paso Robles Spaceport presents a unique opportunity for co-developing training programs aligned with the needs of the space industry. These initiatives have the potential to support the burgeoning Central Coast space economy,
including Vandenberg Space Force Base and various
commercial space companies in the region. Such
activities may not only address workforce shortages
but also improve awareness, perception, and diversity
within the industry.

The proposed Paso Robles Spaceport and Paso
Robles Space Innovation and Technology Park holds
important relevance for the Central Coast space region. The establishment of vocational training facilities and programs can support the industry’s pressing
need for skilled professionals and foster collaboration between industry stakeholders and educational institutions. By providing targeted training programs
and certifications, these efforts may contribute to the growth and diversification of the space industry while
enhancing the region’s economic development efforts.

Attachment 4

Diversifying a Local Economy | 24
Limitations and Suggestions for
Future Research
While efforts were made to include participants
from various industry clusters, the perceptions and
experiences shared by the individuals interviewed may
not fully represent the diverse range of organizations
within the space industry. Future studies would benefit from including a broader spectrum of organizations
within the industry.

To address these limitations and further explore
the nuances of education and workforce development needs within the space industry, future research endeavors should consider employing a survey-based
approach. Informed by the themes that emerged from
this study, such a methodology would enable researchers to gather data from a larger and more diverse sample of companies, allowing for a comprehensive
examination of these themes across company contexts.

This study focused upon the perceptions of space
industry professionals. Future studies should also
consider the perceptions of educators and students
regarding new training and vocational programs.

By incorporating multiple perspectives, cross-sector
stakeholders can gain a more holistic understanding of
the challenges and opportunities in preparing the next
generation of space industry professionals.

Conclusion
This research study sheds light on the education
and workforce development opportunities associated
with the proposed Paso Robles Spaceport and the
Paso Robles Space Innovation and Technology Park.

Commissioned by the City of Paso Robles, this study
aimed to inform regional initiatives and collaborations to support the burgeoning space industry in the area.

The findings underscore the promising economic
prospects offered by the space sector, with participants describing a flourishing industry characterized by low unemployment rates and sustained growth.

However, challenges such as filling job vacancies and
concerns about workforce preparation were also identified, emphasizing the need for strategic investments in education and training.

The study highlights calls for greater collaboration between industry and educational institutions, as well as the potential of developing vocational and
apprenticeship programs. Leveraging existing aviation
training programs and partnerships with community
colleges may help to facilitate the development of
specialized training pathways to meet industry needs.

Moving forward, the City of Paso Robles is advised
to consider funding dedicated positions focused on
spaceport development activities and to collaborate
with various stakeholders in the development of space
education and training programs. By investing in education, training, and infrastructure, Paso Robles can position itself as a hub for space innovation, driving
economic growth and prosperity for the region. As an
aerospace consultant interviewed for this study remarked, As people started developing commercial uses for
aircraft and military uses for aircraft, you see airports popping up all over the place. And one of things that
you see with every airport everywhere is that it has
a positive impact on its community. It’s an economic
driver in the community. I think that’s the same thing
that you’ll see with spaceports. Even though there
aren’t many spaceports right now, the unifying factor
is that the community sees it as an opportunity, and
it brings another level of economic impact into those
communities. It draws technical jobs into the area,
and it bring interesting and exciting technologies that opens the doors to a lot of new things.

An aerial view of the Paso Robles Airport (KPRB).

Attachment 4

Diversifying a Local Economy | 25

APPENDIX A
(see page 7)

APPENDIX B
Interview Protocol
▶ Tell me a little about your background as a [job title/ role]…
▶ Tell me about your company and the niche you fill in
the space industry?
▶ What other types of companies do you collaborate
with or rely upon within the industry?
▶ How would you describe the space industry job
market generally? [Probe: Are there adequate
numbers of applicants to choose from when filling a
position?]. How would you describe the horizontal
launch job market specifically? [Probe: Do jobs in
the horizontal launch space differ, if at all, from other space-related industries? If so, how?].
▶ Tell me about the types of jobs your company is
hiring for currently? What, if any, new roles do you
anticipate hiring for in the future?
▶ What skillsets are currently in the highest demand?
How, if at all, do you envision high-demand skillsets
changing as your organization and/or the industry
evolves?
▶ What types of educational and/or workforce training
backgrounds do you look for in an ideal candidate?
▶ If you were to estimate the number of jobs requiring
a BA degree or higher versus the number of jobs
that require job-based training or certification, how
would the distribution fall at your company currently? How, if at all, do you see that distribution changing in the future? Why? ▶ Among those with college degrees, are there degrees or specific college training that you particularly seek out? Which ones?/Why/why not? Which subject
areas do you anticipate being in the highest demand
in the coming years?
▶ What, if any, types of non-college degree training
do/have you sought out? Has your company ever
utilized apprenticeship programs or hired apprenticeship-trained employees? If not, is this a training pathway your company has ever considered? Why/
why not?
▶ Thinking back on your experiences filling job positions, what are some of the issues/dilemmas that you faced? [Probe: What are some of the barriers, if any,
to recruiting/hiring skilled talent?].
▶ Lastly, if you could change anything about the way
potential employees were prepared for their jobs,
what would you change?
▶ What other things do you think we should know, or
think more about, as we continue to learn about the
space industry job market and potential education
and workforce pathways to employment?
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Diversifying a Local Economy | 26

APPENDIX C
Industry Cluster Description
Vehicle Launch Providers
Vehicle launch providers serve as the backbone of
a horizontal launch spaceport, essential for actualizing its purpose. Their dynamic innovations not only enable
space access but also offer invaluable educational experiences, allowing the spaceport to serve as a living classroom for firsthand observation of cutting-edge
systems and technologies. Without these providers,
the spaceport would remain dormant, missing out on
the pulsating lifeblood that propels it into the future.

Launch Services
Launch services play a pivotal role in orchestrating
the intricate process of preparing, fueling, and launching vehicles. The expertise within this industry is essential for executing seamless missions, optimizing payload capacity, and ensuring precise trajectory, thereby maximizing the spaceport’s operational efficiency.

Without these services, the spaceport would lack the
choreography needed to successfully establish itself as a thriving hub for space innovation and technology.

Payload Provider
Payload providers play a crucial role in transforming a horizontal launch spaceport into an educational hub by facilitating the deployment of diverse payloads.

These payloads, ranging from scientific instruments
to satellites, become windows to the heights of the
atmosphere and space, offering insights into weather
patterns, Earth observation, and celestial phenomena.

The quest is not just about reaching new heights but
understanding how to design and craft payloads that
endure and thrive in environments beyond our terrestrial familiarity, fostering innovation and exploration at the forefront of space science and technology.

Satellite Operator
Through seamless collaboration with launch service providers, they ensure the precise positioning of satellites, expanding communication networks, Earth
observation capabilities, and scientific research endeavors. Satellite operators not only drive the spaceport’s economic viability but also propel the world into an era of interconnectedness and information dissemination from the vantage point of space.

Government Agency
Government agencies serve as the bedrock of
a horizontal launch spaceport, providing regulatory frameworks, oversight, and strategic direction.

Through collaborations with spaceport authorities,
these agencies ensure compliance with safety standards, environmental regulations, and national security protocols, fostering a secure and responsible launch
environment.

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Diversifying a Local Economy | 27
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3-319-26112-6
Seedhouse, E. (2017). Spaceports: A Definition
and Brief History. In Spaceports Around the World, A
Global Growth Industry (pp. 13–31). Springer International Publishing AG. https://doi.org/10.1007/978-3- 319-46846-4_2
Space Foundation. (2022). Is the space industry
growing? Retrieved from https://cie.spacefoundation.
org/is-the-space-industry-growing/
White House National Science and Technology
Council (2022), The Interagency Roadmap to Support Space-Related STEM Education Workforce, National Science and Technology Council and Office of Science and Technology Policy, September 2022, https://www.whitehouse.gov/wp-content/uploads/2022/09/09-2022-Interagency-Roadmap-to-Support-Space-Related-STEM-Education-and-Workforce. pdf
Yin, R. (2014). Case study research design and
methods (5th ed.). Thousand Oaks, CA: Sage.

Attachment 4

Diversifying a Local Economy | 28
Acknowledgments
We extend our gratitude to the professionals
within the space industry who generously dedicated their time and shared their expertise during the course of this study. Their insights and perspectives
have greatly enriched our understanding of the
complex landscape surrounding the development of
spaceports and the associated workforce needs.

Additionally, we would like to express our
appreciation to the dedicated team of cross-disciplinary Cal Poly students who contributed their skills and passion to the “A Hub for Public-Private Partnership and Innovation: Connecting Cal Poly with the Paso Robles Space Innovation and Technology
Park” project. Their hard work, creativity, and commitment were instrumental in advancing the goals of this project, which was commissioned by the City of
Paso Robles.

We are grateful to all individuals and entities involved in this endeavor for their support, collaboration, and
contributions, which have been instrumental in shaping
the outcomes of this study and laying the foundation for future research associated with education and workforce development opportunities in space innovation and technology.

Oak trees sit in a field as the sun sets in Paso Robles, CA.

Attachment 4

Diversifying a Local Economy | 29
Diversifying a local Economy:

An examination of education and workforce development
opportunities associated with a city-owned spaceport
February 2024
Attachment 4

E C O N O M I C I M P A C T S T U D Y
Paso Robles Spaceport
Economic Impact Analysis
City of Paso Robles
Estimated Spaceport
Economic Impact
March 18, 2026
Prepared by:

RS&H, Inc.

Attachment 5

E C O N O M I C I M P A C T S T U D Y

TABLE OF CONTENTS
A. Introduction and Background ......................................................................................................................................... 1 B. Methodology ......................................................................................................................................................................... 1 B.1 Background ............................................................................................................................................................................ 1 B.2 Existing Airport Tenant and Potential Spaceport Tenant Survey ...................................................................... 6 C. Economic Impact ................................................................................................................................................................. 6 D. Results ...................................................................................................................................................................................... 8

TABLES TABLE OF CONTENTS
Table 1: Standard Industrial Classification Codes Used ....................................................................................................... 4 Table 2: Short-Term Economic Impacts ..................................................................................................................................... 8 Table 3: Short-Term Economic Impacts ..................................................................................................................................... 8

FIGURES TABLE OF CONTENTS
Figure 1: Value Chain of Advanced Aerospace and Space Industries ............................................................................ 3 Figure 2: Driver, Multipliers and total impact of Spaceport Activity ............................................................................... 5 Figure 3: Components of Total Economic Impact .................................................................................................................. 5 Figure 4: Economic Impact Measures ......................................................................................................................................... 7 Attachment 5

E C O N O M I C I M P A C T S T U D Y
© 2026, RS&H, Inc. City of Paso Robles 1 | 8
All Rights Reserved. Estimated Spaceport Economic Impact March 18th, 2026 A. INTRODUCTION AND BACKGROUND
The space industry is growing nationwide and internationally, supported by strong policy and budgetary appropriations for civil and national security space programs. Also, private, and public investments across broad-based commercial initiatives are driving a diverse and richly complex value chain. Opportunities for development, testing, manufacturing, operations, and related services exist and will grow as the industry expands. The City of Paso Robles has been investigating the feasibility of implementing a horizontal spaceport capability at the Paso Robles Airport (PRB).

Research by the City of Paso Robles found that its geographic location, along with existing facilities at Paso Robles Airport, access to regional controlled airspace, and low population densities, could make it a strong candidate for obtaining an FAA-issued Launch Site Operators License.

Recognizing this potential, the City and PRB have conducted analyses and technical studies indicating that establishing a spaceport at the airport may allow Paso Robles to grow the local space and space-adjacent industries. This initiative would be pursued through partnerships with government, commercial, and academic entities, thereby fostering community benefits and facilitating the growth of a space-based economy in Paso Robles.

To further assess the initiative of establishing a spaceport at PRB, the City commissioned this economic impact analysis to estimate potential benefits for Paso Robles and the San Luis Obispo County economies.

B. METHODOLOGY
B.1 Background
This study was designed to provide a quantifiable economic impact assessment of a potential spaceport at PRB in the short-term (5 to 10 years) and the long-term (11 to 20 years) timeframe.

An economic impact study estimates the economic benefits of a spaceport at PRB for Paso Robles, the San Lusi Obispo County, and its surrounding communities by quantifying the following economic impacts:
» Direct Impacts: Direct impacts are economic benefits that occur directly as a consequence of the existence of the spaceport. These benefits are directly generated by spaceport activity associated with its management and operations, service providers, and tenants, all of which have a direct relationship with spaceport activities. The direct economic impact is generally measured as a function of employment, payroll, and sales generated directly by the spaceport.

Attachment 5

E C O N O M I C I M P A C T S T U D Y
© 2026, RS&H, Inc. City of Paso Robles 2 | 8
All Rights Reserved. Estimated Spaceport Economic Impact March 18th, 2026 » Indirect Impacts: These are economic impacts that are indirectly generated by the spaceport and its activity and are generated off-spaceport property but are attributable to space and spaceport activity.
» Induced Impacts: Are multiplier effects caused by successive rounds of spending throughout the economy as a result of the spaceport’s direct and indirect effects.

Variables or indices used to measure the flow of dollars within each of the three above-mentioned impacts include the following:
» Employment—jobs in the space industry, jobs in sectors that support spaceport business and activities.
» Payroll—wages paid to workers employed in the space industry or workers who support or use the space industry.
» Revenue—value of goods sold, value of services sold, capital expenditures, spending by visitors, operating budgets for space-dependent government agencies, etc.

A spaceport’s total economic impact is the sum of the direct, indirect, and induced effects.

Paso Robles envisions the spaceport as a catalyst for economic growth, fostering the development of an advanced aerospace and space industry cluster serving both civilian and military supply chains. This initiative encompasses research and development in aerospace and defense technology, and evaluation, testing, design, engineering, and manufacturing facilities that will support comprehensive spaceport operations.

Considering Paso Robles’ spaceport vision, economic impacts were estimated by first establishing the value chain of advanced aerospace and space industry clusters that would potentially serve commercial, civilian, and national security space supply chains. Figure 1 graphicly depicts this value chain cluster.

Attachment 5

E C O N O M I C I M P A C T S T U D Y
© 2026, RS&H, Inc. City of Paso Robles 3 | 8
All Rights Reserved. Estimated Spaceport Economic Impact March 18th, 2026 FIGURE 1 VALUE CHAIN OF ADVANCED AEROSPACE AND SPACE INDUSTRIES Source: RS&H, Inc. 2026
As there is no spaceport at PRB at present, the analysis focused instead on gathering data from industries, businesses, and entities within the advanced aerospace and space industry value chain—shown in Figure 1—that are situated at currently operating spaceports similar to the type that might eventually be established at PRB. Additionally, an evaluation of current tenant activities at PRB was undertaken to identify businesses that could potentially benefit from the spaceport's presence within the context of the value chain detailed above. Surveys were sent to these tenants to collect important economic information and confirm if their operations would be positively impacted by a spaceport. Additional surveys were also distributed to businesses interested in setting up at PRB, should a spaceport be constructed.

Indirect and induced impacts were determined through the use of multipliers from the RIMS II (Regional Input-Output Modeling System), developed by the U.S. Bureau of Economic Analysis (BEA). RIMS II is a widely accepted tool used by policymakers and planners to estimate projectspecific economic impacts based on regional data.

Attachment 5

E C O N O M I C I M P A C T S T U D Y
© 2026, RS&H, Inc. City of Paso Robles 4 | 8
All Rights Reserved. Estimated Spaceport Economic Impact March 18th, 2026 Using BEA RIMS II multiplier data a standard input-output model was developed to estimate the impact of economic changes in Paso Robles and the San Luis Obispo County region. The model tracks new money that would be generated by the spaceport that enters the region as it is cycled from the original source and re-spent one or more times in the local economy before exiting the region. The BEA multipliers are used to determine the total impact on employment or income created by a change in the economy. BEA uses Standard Industrial Classification (SIC) codes, a system developed by the U.S. Department of Commerce for classifying establishments by type of economic activity. Impacts were categorized into the following industrial and business sectors in the model according to their business activity type.

TABLE 1

STANDARD INDUSTRIAL CLASSIFICATION CODES USED
Source: US Department of Commerce
Figure 2 below illustrates the process of how various spaceport related activities are quantified and, by application of industry multipliers, used to estimate total impact of the airport to local economy.

CODE INDUSTRY TITLE CODE INDUSTRY TITLE

CONSTRUCTION COMPUTER & ELECTRONIC PRODUCT MANUFACTURING 2332OC Office & Commercial Structures Command& Control, Tracking & Telemetry Ops 2332PC Power & Communication Structures 334610 Manufacturing and reproducing magnetic and optical media

FABRICATED METAL PRODUCT MANUFACTURING ELECTRICAL EQUIPMENT, APPLIANCE & COMPONENT MANUFACTURING 332310 Plate work & fabricated structural product man 335210 Small electrical appliance manufacturing (cube sat) 332410 Power boiler and heat exchanger manufacturing TRANSPORTATION & WAREHOUSING 332420 Metal tank (heavy gauge) manufacturing 481000 Air Transportation 332500 Hardware manufacturing CHEMICAL MANUFACTURING
332710 Machine Shop 3259A0 All other chemical product and preparation manufacturing 332800 Coating, engraving, heat treating, & allied activities Commodities (LN, GN, LO2, He)

MACHINERY MANUFACTURING COMPUTER SYSTEMS DESIGN & RELATED SERVICES 333611 Turbine & turbine generator set units manufacturing 541512 Computer systems design services 33351B Cutting and machine tool accessory, rolling mill, and other MISCELLANEOUS PROFESSIONAL, SCIENTIFIC, AND TECHNICAL metalworking machinery manufacturing 541300 Architechtural, Engineering & Related Services 333912 Air and gas compressor manufacturing 541700 Scientific Research & Development Services 333914 Measuring, dispensing, and other pumping equipment 5419A0 All other miscellaneous professional, scientific & tech services manufacturing EDUCATIONAL SERVICES
333415 Air conditioning, refrigeration, and warm air heating 611A00 Junior colleges, colleges, universities, and professional schools equipment manufacturing 611B00 Other educational services 333618 Other engine equipment manufacturing ACCOMODATION COMPUTER & ELECTRONIC PRODUCT MANUFACTURING 721000 Accomodation 334610 Manufacturing & reproducing magnetic & optical media FOOD SERVICES AND DRINKING PLACES OTHER TRANSPORTATION EQUIPMENT MANUFACTURING 722110 Full-service restaurants 336411 Aircraft manufacturing 722111 Limited-service restaurants 336412 Aircraft engine and engine parts manufacturing 722A00 All other food and drinking places 336413 Other aircraft parts and auxiliary equipment manufacturing OTHER SERVICES 336413 Guided missile and space vehicle manufacturing. 811200 Electronic and precision equipment repair and maintenance 33641A Propulsion units & parts for space vehicles & guided missiles 811300 Commercial & industrial machinery & equip repair & maint.

Attachment 5

E C O N O M I C I M P A C T S T U D Y
© 2026, RS&H, Inc. City of Paso Robles 5 | 8
All Rights Reserved. Estimated Spaceport Economic Impact March 18th, 2026 FIGURE 2

DRIVER, MULTIPLIERS AND TOTAL IMPACT OF SPACEPORT ACTIVITY Figure 3 shows how the direct and indirect impacts traceable to economic activity of a spaceport at PRB will then stimulate another round of induced impacts based on the spending by employees and businesses earning income and re-spending it in the regional economy.

FIGURE 3

COMPONENTS OF TOTAL ECONOMIC IMPACT
Attachment 5

E C O N O M I C I M P A C T S T U D Y
© 2026, RS&H, Inc. City of Paso Robles 6 | 8
All Rights Reserved. Estimated Spaceport Economic Impact March 18th, 2026 B.2 Existing Airport Tenant and Potential Spaceport Tenant Survey The airport and the City of Paso Robles supplied a list of currently established airport tenants and of prospective businesses interested in setting up at PRB, should a spaceport be constructed. Research on current tenants assessed whether their businesses could benefit from a spaceport at the airport.

Tenants whose business was identified as benefiting from a spaceport were sent a link to a survey to collect valuable information to be used in the economic impact analysis study. Key information sought included:
» Type of services provided at the airport
» Number of employees at the airport (as of December 31, 2025) » Payroll (range of values)
» Corporate Information
» Company Annual Revenues
» Company Annual Expenditures
Businesses that have expressed interest through letters of intent (LOI) to the county were also surveyed to collect the following information:
» Type of business they would provide at the spaceport
» Estimates of:
 The number of employees at the spaceport
 Annual revenues values from business operations at the spaceport  Amount of land they would rent from PRB for their business  Capital construction values
Surveys were sent to 11 existing tenants and 6 letter of interest (LOI) businesses. 5 surveys were return by existing tenants and 2 by LOI businesses providing a 43.75 percent response rate. This is higher than usual response rates experienced by surveyors of approximately 30%.

Consolidated inputs from the surveys were used as inputs in refining and validating the assumptions used in determining the economic impact of the spaceport.

C. ECONOMIC IMPACT
Economic impact is determined by determining direct, indirect, and induced impacts.

Direct economic impacts refer to the economic benefits realized by the spaceport as a result of its presence at PRB. These benefits stem from activities associated with management and operations, on-site tenants, service providers, and construction projects located within the Attachment 5

E C O N O M I C I M P A C T S T U D Y
© 2026, RS&H, Inc. City of Paso Robles 7 | 8
All Rights Reserved. Estimated Spaceport Economic Impact March 18th, 2026 FIGURE 4

ECONOMIC IMPACT MEASURES
spaceport property. Typically, direct economic impact is assessed based on measures such as employment, payroll (earnings), business revenues (output), and value added to the Paso Robles and San Luis Obispo County economies attributable to the existence of the spaceport.

Source: RS&H 2026
Indirect impacts are measured using the same economic impact measures though these are indirectly generated by suppliers to businesses at the spaceport and by visitors that conduct business with spaceport tenants and that are attracted by spaceport activities. They are generated off-spaceport property but are attributable to the spaceport.

Induced impacts are multiplier economic effects caused by successive rounds of spending throughout the economy of the region as a result of the spaceport’s direct and indirect effects.

Estimated economic impact measure values were established using RIMS II (Regional InputOutput Modeling System) multipliers, developed by the U.S. Bureau of Economic Analysis (BEA) for the various industrial sectors listed in Table 1 and an input-output economic model specifically built for this purpose.

Attachment 5

E C O N O M I C I M P A C T S T U D Y
© 2026, RS&H, Inc. City of Paso Robles 8 | 8
All Rights Reserved. Estimated Spaceport Economic Impact March 18th, 2026 D. RESULTS
Table 2 and Table 3 below show estimated economic impact results of the analysis for the short term (5 to 10 years) and long-term (11 to 20 years) potential operation of the spaceport at PRB.

TABLE 2

SHORT-TERM ESTIMATED ECONOMIC IMPACTS
Impact Total Economic Impact
Direct Jobs 80
Total Jobs 180
Payroll (Earnings) $25,000,000
Business Revenues (Output) $68,500,000
Value Added $29,000,000
Taxes $6,400,000
Source: BEA RIMS II Multipliers and RS&H Analysis, 2026 TABLE 3

LONG-TERM ESTIMATED ECONOMIC IMPACTS
Impact Total Economic Impact
Direct Jobs 315
Total Jobs 875
Payroll (Earnings) $96,000,000
Business Revenues (Output) $334,800,000
Value Added $141,800,000
Taxes $30,000,000
Source: BEA RIMS II Multipliers and RS&H Analysis, 2026 # # # # #
Attachment 5

City of Paso Robles
Launch Site Operators License Scope of Work Evaluation
Introduction: The space sector is experiencing rapid growth and contributing significantly to the economic development of many communities and regions of the country. The industry is also being driven by supportive policy including a new Presidential Executive Order (EO) that aims to greatly reduce the regulatory burden associated with licensing space operations and spaceport development. The policies are backed by material appropriations for civil and national security space programs that must rely on commercial space entities across a diverse and richly complex value chain. These anchor government customers further spur billions of dollars of private capital investment into new commercial ventures, infrastructure, and communities.

Opportunities for development / testing, manufacturing, launch / landing / reentry operations, and many related services exist for communities like Paso Robles. These opportunities will increase as the space industry continues to mature with more diverse launch systems, multiple new and innovative satellite applications, related satellite ground tracking systems, data storage / analytic services, and human spaceflight, to name just a few.

Spaceport as an Economic Engine: To diversify and grow the local economy, the City of Paso Robles is considering the pursuit of a Launch Site Operators License (LSOL) for the municipal airport (PRB) supported by government, commercial, and academic partnerships that can benefit the community and lay the foundation for the space economy to expand locally. For example, a partnership with the California Polytechnic State University (Cal Poly) for propulsion research at the airport was created and continues, while the city also engages with launch service companies as potential tenants.

The City has also consulted with the Federal Aviation Administration’s (FAA’s) Office of Commercial Space Transportation (AST) regarding an LSOL, i.e., becoming a licensed spaceport. Like airports and industrial business parks, spaceports have served as economic engines, even without near term launch operations, and as a magnet for technology companies.

EXECUTIVE SUMMARY
Attachment 6

Estimate to Complete Spaceport License Efforts: The City of Paso Robles and PRB have made a significant investment to address key LSOL application elements that are potential “go/no-go” topics.

It is our professional opinion that with some additional effort the work to date on the LSOL elements will be accepted by FAA.

To submit a completed LSOL application Paso Robles
will need to complete:
• Detailed technical assessments
– including flight safety and risk analyses.
• Formal Letters of Agreement (LOAs)
– with the U.S. Coast Guard and FAA Air Traffic.
• Updated Airport Layout Plan (ALP)
– to include designated Spaceport operations areas.
• Importantly, this ALP update will be done as part of the Airport Master Plan Update already underway, ensuring
alignment and efficiency.
• Environmental permits – both state and federal.

Recent executive orders (EO) are expected to reduce the scope of environmental review, cutting both time and cost.

The estimated timeline and costs to complete
the LSOL application effort is:
• 12–18 months once funded.
• ~$900,000 - $1.2 million in third-party consultant
and subject matter expert costs.
• If CEQA approvals are no longer required and a federal categorical exclusion (CATEX) is granted, the cost could be reduced to as low as $750,000.

Other Key factors that may affect schedule are:
• FAA/AST workload.
• Whether a launch service provider commits to Paso Robles with near-term operational plans (targeting 2027/28).

Attachment 6

©2025, RS&H, Inc., All Rights Reserved.
30 September 2025
City of Paso Robles, California
Launch Site Operators License
Scope of Work Evaluation
Attachment 7

©2025, RS&H, Inc., All Rights Reserved.

LSOL Scope of Work Evaluation
FINAL 1.1
30 September 2025
RS&H Project No.: 1026-008-5000
Purchase Order No.: 260015-00
Prepared by RS&H, Inc. at the
direction of City of Paso Robles, California
Attachment 7

Paso Robles LSOL Scope of Work Evaluation ( FINA L )
©2025, RS&H, Inc. FINAL i
All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 30 September 2025 Table of Contents
Executive Summary .......................................................................................................................................................iv 1 Introduction ............................................................................................................................................................. 1

1.1 Launch Site Operator................................................................................................................................. 1

1.2 Launch Site Location & Launch Area................................................................................................... 2

1.2.1 Name & Location................................................................................................................................... 2

1.2.2 Downrange equipment........................................................................................................................ 3

1.2.3 Spaceport & Launch Site Layout...................................................................................................... 3

1.2.4 Proposed Launch Vehicles / CONOPs............................................................................................ 6

1.2.5 Launch Azimuths / Trajectories......................................................................................................... 8

1.2.6 Scheduled Operational Date.............................................................................................................. 8

1.3 Foreign Ownership ..................................................................................................................................... 9

1.4 Launch Site Location.................................................................................................................................. 9

1.5 Launch Area Evaluation Summary ........................................................................................................ 9 2 Launch Site Location Review .......................................................................................................................... 10

2.1 General (420.19)........................................................................................................................................ 10

2.2 Launch Site Boundary (420.21) ........................................................................................................... 11

2.3 Flight Corridor........................................................................................................................................... 12

2.4 Risk Analysis............................................................................................................................................... 15

2.5 Information Requirements (420.27).................................................................................................. 16

2.6 Unproven Launch Vehicles ................................................................................................................... 16

2.7 Scope, Schedule, and Fee Estimate - Launch Site Location Review...................................... 17 3 Explosive Site Plan (420.17)............................................................................................................................. 18

3.1 Primary Deliverables of the Explosive Site Plan............................................................................ 18

3.2 Scaled Map................................................................................................................................................. 20

3.3 Maximum Quantities of Propellants & Oxidizers Located at Hazard Facilities ................ 20

3.3.1 Maximum Quantities of Liquid & Solid Propellants .............................................................. 20

3.3.2 Quantity Distance Estimates for Propellant Storage ............................................................. 21

3.3.3 Inhabited Building Distance............................................................................................................ 21

3.3.4 Quantity Distance Estimate for Fueled RLV............................................................................... 22

3.3.5 Quantities of Stored Propellants ................................................................................................... 22

3.4 Description of Explosive Hazard Facility Activities ...................................................................... 22

3.4.1 Hazard Classifications for each Hazard Facility........................................................................ 22

3.5 Explosive Site Map................................................................................................................................... 22

3.6 Propellant Storage & Handling .......................................................................................................... 23 Attachment 7

Paso Robles LSOL Scope of Work Evaluation ( FINA L )
©2025, RS&H, Inc. FINAL ii
All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 30 September 2025

3.7 Explosive Site Plan Evaluation Summary......................................................................................... 24 4 License to Operate a Launch Site.................................................................................................................. 25

4.1 General......................................................................................................................................................... 25

4.2 Duration....................................................................................................................................................... 25

4.3 Transfer of License................................................................................................................................... 25

4.4 License Modification............................................................................................................................... 26

4.5 Compliance Monitoring......................................................................................................................... 26

4.6 Operation of a Launch Site Evaluation Summary ........................................................................ 26 5 Launch Site Operations..................................................................................................................................... 27

5.1 Responsibilities ......................................................................................................................................... 27

5.2 Control of Public Access Plan.............................................................................................................. 27

5.3 Scheduling of Launch Site Operations & Notifications............................................................. 28

5.4 Mishap Plan & Accident Investigation Plan................................................................................... 29

5.5 Record Retention ..................................................................................................................................... 31

5.6 Lightning Protection & Advisories .................................................................................................... 31

5.6.1 Lightning Protection .......................................................................................................................... 32

5.6.2 Electrical Power Lines ........................................................................................................................ 33

5.7 Agreements ................................................................................................................................................ 34

5.8 Launch Site Operations Evaluation Summary ............................................................................... 35 6 Environmental ...................................................................................................................................................... 37 7 Summary ................................................................................................................................................................ 38

7.1 LSOL Application Next Steps ............................................................................................................... 41

7.2 Estimated Schedule and Fee................................................................................................................ 42 Appendix A – Environmental Assessment Scope of Work ........................................................................... 43 Attachment 7

Paso Robles LSOL Scope of Work Evaluation ( FINA L )
©2025, RS&H, Inc. FINAL iii
All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 30 September 2025 List of Tables
Table 1: FAA Comments on PRASP ESP............................................................................................................... 19 Table 2: Lightning Advisories................................................................................................................................... 33 Table 3 Approvability & Level of Completeness .............................................................................................. 38 List of Figures
Figure 1-1 PRB Airfield Diagram................................................................................................................................ 4 Figure 1-2 PRB Aerial..................................................................................................................................................... 5 Figure 2-1: Restricted Areas R-2513 & R-2504................................................................................................. 14 Figure 2-2: Warning Area W-532N........................................................................................................................ 14 Figure 7-1: FAA/AST Licensing Process ............................................................................................................... 42 Revisions
Revision
Number Date Description / Comment(s)

0.1 18 July 2025 Draft Submittal for Paso Robles Review and Comment.

1.0 25 Aug 2025 Incorporated comments from reviewers, including a more concise Executive Summary. Updated the assessment of LSOL schedule and ROM pricing based on the initial review of the new Presidential Executive Order (13 Aug 25) titled “Enabling Competition in the Commercial Space Industry.” The EO directs fundamental change in: the nation’s environmental review of spaceports and launch/reentry licensing, how states may influence these federal actions, and other to-be-determined changes to launch and reentry licensing provisions found in 14 CFR Part 450 (some of which may reference back to 14 CFR 420).

1.1 30 Sept 2025 Minor editorials and updates based on additional details and developments since the issuance of the Presidential EO of 13 Aug 25.

Attachment 7

©2025, RS&H, Inc. FINAL iv
All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 30 September 2025 P a s o R ob l e s L S O L S c op e of W or k Ev a l u a t i o n ( F IN A L ) Executive Summary
Introduction: The space sector is experiencing rapid growth and contributing significantly to the economic development of many communities and regions of the country. The industry is also being driven by supportive policy including a new Presidential Executive Order (EO) that aims to greatly reduce the regulatory burden associated with licensing space operations and spaceport development. The policies are backed by material appropriations for civil and national security space programs that must rely on commercial space entities across a diverse and richly complex value chain. These anchor government customers further spur billions of dollars of private capital investment into new commercial ventures, infrastructure, and communities.

Opportunities for development / testing, manufacturing, launch / landing / reentry operations, and many related services exist for communities like Paso Robles. These opportunities will increase as the space industry continues to mature with more diverse launch systems, multiple new and innovative satellite applications, related satellite ground tracking systems, data storage / analytic services, and human spaceflight, to name just a few.

Spaceport as an Economic Engine: To diversify and grow the local economy, the City of Paso Robles is considering the pursuit of a Launch Site Operators License (LSOL) for the municipal airport (PRB) supported by government, commercial, and academic partnerships that can benefit the community and lay the foundation for the space economy to expand locally. For example, a partnership with the California Polytechnic State University (Cal Poly) for propulsion research at the airport was created and continues, while the city also engages with launch service companies as potential tenants. The City has also consulted with the Federal Aviation Administration’s (FAA’s) Office of Commercial Space Transportation (AST) regarding an LSOL, i.e., becoming a licensed spaceport. Like airports and industrial business parks, spaceports have served as economic engines, even without near term launch operations, as a magnet for technology companies.

Estimate to Complete Spaceport License Efforts: The City of Paso Robles and PRB have made a significant investment to address key LSOL application elements that are potential “go/no-go” topics. It is our professional opinion that with some additional effort the work to date on the LSOL elements will be accepted by FAA. To submit a completed LSOL application Paso Robles will need to complete: (i) other detailed assessments (i.e. flight safety and risk analysis); (ii) Letters of Agreement (LOAs) with the U.S. Coast Guard and FAA Air Traffic; (iii) an updated Airport Layout Plan (ALP) with the spaceport Explosive Site Plan (ESP); and (iv) environmental permits (state and federal). Given the recent EO, we believe the environmental review will be materially reduced from prior estimates over the next nine months. Once funded we estimate that Paso Robles’ efforts to receive an LSOL will take 12-18 months and cost between $900,000 and $1.2 Million in third party costs for subject matter experts and consultants. If the new EO eliminates the need for California Environmental Quality Act (CEQA) approvals, and a federal spaceport categorical exclusion (CATEX) ruling is possible, the cost may be as low as $750,000.

Schedules will be governed by the workload of FAA/AST and if there is a launch service provider with a commitment and near term operational date (e.g., 2027/28).

Attachment 7

Paso Robles LSOL Scope of Work Evaluation ( FINA L )
©2025, RS&H, Inc. F I N A L Page 1 of 43
All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 1 Introduction
As part of a larger economic development and diversification strategy, the City of Paso Robles is considering the pursuit of a Launch Site Operators License (LSOL) for the Paso Robles Airport (PRB). A LSOL is sometimes called a “spaceport license.” A license to operate a launch site will authorize the City of Paso Robles to accommodate launch operations and commercial space activities in accordance with the representations contained in the application and accompanying terms and conditions contained in the FAA-issued license order. The City of Paso Robles would be subject to compliance with 49 U.S.C. Subtitle IX, Chapter 701, 14 CFR Part 420, appropriate provisions of the National Environmental Policy Act (NEPA) associated with a major federal licensing action, and any special conditions levied for the site. Additionally, a license to operate a launch site authorizes the City of Paso Robles to offer PRB to Launch Service Providers (LSP) for launch points identified within the launch site boundary, for the type of launch vehicle(s) identified in this license application and upon which the licensing determination is based.

To initiate the LSOL application process, the City of Paso Robles and PRB have made a concerted effort to gather data and address many requirements outlined in commercial space regulations promulgated by the Federal Aviation Administration’s Office of Commercial Space Transportation (FAA AST). The purpose of this project is to assess and validate the completeness of the data previously prepared for use in a LSOL application and associated NEPA review.

The following introductory sections review and track the requirements order of 14 CFR 420 that Paso Robles will need to continue to pursue for the LSOL. The subsections define the exact requirement language in italics, followed by explanatory information, and the current Paso Robles status on the material. Some of this material may be used in the application in the future.

1.1 Launch Site Operator
§420.15 (a)(1) Launch site operator. An applicant shall identify the name and address of the applicant, and the name, address, and telephone number of any person to whom inquiries and correspondence should be directed.

Through pre-application consultation, the identity and address of the City of Paso Robles and PRB have been provided. This information is sufficient for the application (update if information changes prior to submission to FAA).

Attachment 7

Paso Robles LSOL Scope of Work Evaluation ( FINA L )
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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 For the purposes of the application, the name and address of the applicant is the following:

City of Paso Robles, California
1000 Spring Street, 2nd Floor
Paso Robles, CA 93446
Inquiries and correspondence related to the Paso Robles LSOL application may be sent to:

Paso Robles Municipal Airport
Mr. Mark Scandalis
Airport Manager
4912 Wing Way
Paso Robles, CA 93446
Email: [email protected] / [email protected]
Phone: 805-237-3877

1.2 Launch Site Location & Launch Area
§420.15 (a)(2) Launch Site. An applicant shall provide the name and location of the proposed launch site and include the following information:
(i) A list of downrange equipment;
(ii) A description of the layout of the launch site, including launch points; (iii) The types of launch vehicles to be supported at each launch point; (iv) The range of launch azimuths planned from each launch point; and (v) The scheduled operational date.

These information are reviewed below for the inclusion into a LSOL application.

1.2.1 Name & Location
The following information is sufficient for the LSOL application.

The City of Paso Robles, California is located approximately 185 miles north of Los Angeles and 175 miles south of San Francisco. PRB consists of approximately 1300-acres located approximately four miles northeast of downtown Paso Robles, California. Using a bearing of 235°, PRB is positioned approximately 26 Nautical Miles (NM) east of the Pacific Coastline.

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1.2.2 Downrange equipment
The following information is sufficient for the LSOL application.

The City of Paso Robles does not possess any downrange equipment. Downrange equipment will be provided by the Launch Service Provider (LSP). Downrange equipment for telemetry, tracking, or communication services will be either mobile and provided by the LSP or arranged through one of the government partners located at Vandenberg Space Force Base or the Naval Air and Warfare Center (NAWC).

1.2.3 Spaceport & Launch Site Layout
The following information needs to be determined for the future LSOL application.

Not to be confused with “Launch Point”, the Launch Site will include those features necessary to allow the Horizontal Launch Vehicle to depart PRB and gain access to the flight corridor and operating range. While a flight corridor for Paso Robles Air and Space Port (PRASP) has been conceptualized, no formal steps have been taken to memorialize a flight corridor.

Airfield Description. The Spaceport Users Guide (document number PRASP-SUG-1100) provides an acceptable description of the airfield provided by PRB, although FAA/AST may request clarifications when reviewed as part of the larger LSOL application. The actual airfield description is as follows:

PRB occupies approximately 1,300 acres at an elevation of 834 feet above mean sea level (MSL). The National Plan of Integrated Airport Systems (NPIAS) classifies the airport as a General Aviation (GA) airport and a Regional Airport in the California Aviation System Plan (CASP). The Airport does not have an air traffic control tower, however, based on data received from a recently installed Automatic Dependent Surveillance–Broadcast (ADS–B) tracking system, the airport supports approximately 45,000 operations per year.

Figure 1-1 PRB Airfield Diagram and Figure 1-2 PRB Aerial show the airfield configuration.

Approximately 200 aircraft are currently based at the airport. These aircraft include single-engine airplanes, multi-engine airplanes, jets, and helicopters. Key tenants conducting air operations from the airport include CALFIRE and California Highway Patrol. Approximately 40 individual businesses also operate out of the airport.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Figure 1-1 PRB Airfield Diagram
Runways. PRB is served by two runways oriented in an “Open V” configuration. Both runways are served by a network of connecting taxiways that provide access to the terminal, self-serve fuel, aircraft storage hangars, ramps, tiedown areas, FBO, and the Estrella Warbird Museum. A lighted and marked Helipad with six designated parking locations is situated along the east side of Taxiway E, across from the terminal.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Figure 1-2 PRB Aerial
Runway 1/19 is a non-precision marked and lighted runway with a partial-length parallel taxiway to its northwest. Runway 1/19 is 6,008 feet in length and 150 feet wide and serves as PRB’s primary runway. It has a Design Code of C-III, with an ultimate Design Code of C-IV. The design aircraft for Runway 1/19 is the BAE 146 and Gulfstream 500, each with a Maximum Takeoff Weight (MTOW) of approximately 93,000 pounds.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Runway 13/31 is designated for horizontal launch vehicle operations. The Runway is a non-precision marked and lighted runway, which measures 4,701 feet in length and 100 feet in width. Runway 13/31 is not currently served by an accompanying parallel taxiway.

However, the runway is planned to include an adjacent 100 ft x100 ft concrete pad which will serve as a horizontal launch vehicle propellant loading area. The Design Code for Runway 13/31 is B-III. At 100 feet wide, this runway can support 30,000-pound single, 50,000-pound dual, and 90,000-pound dual-tandem wheel loadings.

Taxiways. As reflected in Figure 1-2 the Airport has an extensive taxiway system to support the two runways. The primary runway 1/19 is served by Taxiway ‘A’, a full length parallel taxiway. Additionally, Taxiway ‘A’ is served by a series of taxiways connecting Taxiway ‘A’ to Runway 1/19 and Taxiways ‘B’, ‘C’, ‘D’, ‘E’, and ‘F’. The crosswind runway 13/31 is served by Taxiway ‘F’ and ‘B’. With the exception of the old terminal apron and the fueling pad, all airfield pavements, hardstands, and revetments are asphalt.

1.2.4 Proposed Launch Vehicles / CONOPs
The launch vehicles proposed for PRASP all rely on horizontally launched operations. Vertical launch capabilities will not be explored within the Paso Robles LSOL application. Horizontal launch operations may include the vehicles listed below. • Orbital Expendable Vehicles (launched from a carrier aircraft) • Guided Sub-Orbital Expendable Launch Vehicles (from a carrier aircraft) • Unguided Sub-Orbital Expendable Launch Vehicles (from a carrier aircraft) • Reuseable Launch Vehicles (winged vehicles capable of landing on a runway) Launch Vehicles. For reusable horizontally launched spacecraft, PRASP may consider the FAA/AST-defined Concept X, Y, and Z horizontal launch vehicles. A Concept X reusable launch vehicle (RLV) is designed as one component and appears similar to other aircraft. A Concept X vehicle departs a runway horizontally using turbojet power. Upon reaching a launch point located in the operating range, the vehicle transitions into rocket propulsion. The vehicle flies a suborbital profile before returning to the launch site in an unpowered gliding configuration or under jet propulsion (e.g., that proposed by the former Rocketplane Global). Concept X is not being considered for PRB as there are no foreseeable vehicles of this kind being proposed.

Similar to the Concept X vehicle, the Concept Y vehicle is designed as a single component and maintains many of the same characteristics as a fixed-wing aircraft. However, the Concept Y vehicle departs a runway horizontally using only rocket propulsion. The vehicle rotates to allow a near vertical trajectory soon after takeoff. The Concept Y RLV will remain under rocket power until engine cutoff during ascent, and then continues to coast (gain altitude) with most Attachment 7

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 proposed operations achieving “space” suborbital altitudes (above 50 miles). As gravity overcomes the vehicle, it then begins to fall and re-enters the atmosphere and eventually levels off and glides. For approach and landing, the Concept Y vehicle applies a controlled unpowered glide to land horizontally. The Concept Y RLV is capable of providing suborbital flights for passengers or commercial/scientific payloads. At no point in an operation will a Concept Y vehicle have ability to use jet propulsion. Examples of the Concept Y vehicle include the former XCOR Lynx vehicle and today’s Dawn Aerospace’s Mark II Aurora spaceplane.

The Concept Z RLV consists of two flight articles, a carrier aircraft which is mated to a suborbital RLV. Both the Concept Z carrier aircraft and RLV will include flight crews for piloting. The mated vehicles would depart PRB horizontally. The carrier aircraft would carry the launch vehicle to the designated launch point and release altitude. Once released, the RLV would ignite its rocket engines and fly either an orbital or suborbital trajectory, while the carrier aircraft would return to PRB. Following mission completion, the RLV would return to PRB and land horizontally with an unpowered glide. An example of the Concept Z vehicle is Virgin Galactic’s White Knight 2 / Spaceship II configuration.

In addition to the suborbital reusable launch vehicles described above, Paso Robles is considering the inclusion in the LSOL application of orbital satellite launch over the Pacific using an expendable launcher carrier aloft by an aircraft (e.g., the Stratolaunch/Talon-A system, the former Virgin Orbit/Launcher One concept, and the Dawn Aerospace proposed Mark III Aurora launch system with satellite launcher). Such a configuration may also launch both guided and unguided suborbital rockets over the Pacific.

For the purposes of the LSOL application, it is assumed the Dawn Aerospace Mk-II Aurora spaceplane will be used as a reference vehicle for the LSLR, flight corridor development, and risk analysis. The Mk-II Aurora spaceplane is a Concept Y vehicle which is propelled by rocket propulsion from operational initiation. Additional future larger versions of the Dawn Aerospace fleet should be considered (Mark III). We also recommend that Paso Robles add the Virgin Galactic Spaceship II / White Knight 2 configuration to their LSOL application as an additional vehicle type. This inclusion will be negligible from a schedule and cost perspective while expanding the envelope of the application to the most likely winged flying spacecraft concepts.

To round out the potential launch vehicles considered, a carried aloft orbital and suborbital expendable rocket option set should also be added to the evaluation options.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Concept of Operations. Section 4.2.1 of the Spaceport Users Guide addresses horizontal spaceport CONOPS. The CONOPS description provided in the User’s Guide touches on the different aspects and phases of an operation. For the LSOL Application, it is recommended a CONOPS for the Mk-II Aurora Spaceplane and VG WK2/SH2 be prepared for each of the operational phases listed below, in addition to an orbital expendable launch capability from a carrier aircraft (e.g., the Stratolaunch or Virgin Orbit model of launch addressed earlier). • Storage to Fueling
• Fueling to Takeoff
• Takeoff to Ignition
• Climb to Mission
• Decent to Approach
• Approach to Landing
• Landing to Storage

1.2.5 Launch Azimuths / Trajectories
Typically, the launch azimuth/trajectory is the direction and course a vehicle travels once launched. For the purposes of the Paso Robles LSOL application the azimuth will be measured from 0-degrees, which is north in a clockwise fashion. The initially proposed boundary of the potential flight corridors defined by offshore Warning Area W-532N, Restricted Areas R-2504 and R-2513 used for launch operations originating from PRASP appear to be of sufficient size to allow for a majority of orbital and suborbital operations at a majority of launch azimuths. Prior to formally completing the application it is recommended an analysis be conducted to identify the specific range of available launch azimuths. The launch azimuth used by a specific launch operator will be determined from the requirements of the respective vehicle and mission profile.

1.2.6 Scheduled Operational Date
As defined by PRASP, the anticipated scheduled operational date of spaceport operations is, pending FAA/AST approval, the third quarter of 2026 (3Q2026) and should be included in the LSOL application.

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1.3 Foreign Ownership
§420.15 (a)(3) Foreign ownership. Identify foreign ownership of the applicant as follows:
(i) For a sole proprietorship or partnership, all foreign owners or partners; (ii) For a corporation, any foreign ownership interest of 10 percent or more; and (iii) For a joint venture, association, or other entity, any foreign entities participating in the entity.

This section is self-explanatory and sufficient as discussed within materials produced by the city. [There is currently no foreign ownership of the City of Paso Robles, California or Paso Robles Municipal Airport.]

1.4 Launch Site Location
§420.15 (c) Launch Site Location
(1) Except as provided in paragraph (c)(2) of this section, an applicant shall provide the information necessary to demonstrate compliance with §§420.19–420.29. (2) An applicant who is proposing to locate a launch site at an existing launch point at a federal launch range is not required to comply with paragraph (c)(1) of this section if a launch vehicle of the same type and class as proposed for the launch point has been safely launched from the launch point.

Paragraph (c)(2) is not applicable to Paso Robles. Paragraph (c)(1) requires compliance with 14 CFR §§420.19 – 420.29. The readiness of existing material produced by the Paso Robles team to comply with these paragraphs will be discussed below in Section 2.

1.5 Launch Area Evaluation Summary
The launch site location and documentation of the launch area is a vital component which allows FAA to confirm the safety of launch operations at the respective spaceport and operating range. The management and staff have done a thorough job of documenting the Spaceport and Launch Site Layout, which is provided in the Spaceport User’s Manual. This information can be transferred to the LSOL application. Regarding proposed launch vehicles, time will need to be spent with the respective vehicle operators to develop the spaceport CONOPS and launch azimuths/trajectories. Depending on the number of specific vehicle types, vehicle operators, and if vehicle CONOPS have previously been developed, this task may require as little as four-weeks to as many as 12-weeks.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 2 Launch Site Location Review
The Launch Site Location Review will include compliance for the following sections:
• §420.19 Launch site location review – general
• §420.21 Launch site location review – launch site boundary • §420.23 Launch site location review – flight corridor • §420.25 Launch site location review – risk analysis
• §420.27 Launch site location review – information requirements • §420.29 Launch site location review for unproven launch vehicles None of these paragraphs have been completed by the team. These are discussed below and the general scope and schedule/level of effort needed to develop these materials.

2.1 General (420.19)
§420.19 (a) To gain approval for a launch site location, an applicant shall demonstrate that for each launch point proposed for the launch site, at least one type of expendable or reusable launch vehicle can be flown from the launch point safely. For purposes of the launch site location review:
(1) A safe launch must possess a risk level estimated, in accordance with the requirements of this part, not to exceed an expected number of 1 × 10−4 casualties (Ec) to the collective members of the public exposed to hazards from the flight. (2) Types of launch vehicles include orbital expendable launch vehicles, guided sub-orbital expendable launch vehicles, unguided sub-orbital expendable launch vehicles, and reusable launch vehicles. Orbital expendable launch vehicles are further classified by weight class, based on the weight of payload the launch vehicle can place in a 100-nm orbit, as defined in table 1.
(b) If an applicant proposes to have more than one type of launch vehicle flown from a launch point, the applicant shall demonstrate that each type of expendable or reusable launch vehicle planned to be flown from the launch point can be flown from the launch point safely. (c) If an applicant proposes to have more than one weight class of orbital expendable launch vehicles flown from a launch point, the applicant shall demonstrate that the heaviest weight class planned to be flown from the launch point can be flown from the launch point safely.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Except for the candidate vehicle types, this work remains to be kicked-off and completed by Paso Robles. The application process will require a location review to be completed in order to fulfill the requirements of §420.19. The Location Review will include an evaluation of the airfield located at PRB, development of a departure and arrival corridor and establishment of an “operating range” which is nothing more than the potential range of trajectories target vehicle types may fly during operations, evaluation of trajectories given local population, and the specific vehicle configuration(s) under evaluation. A risk analysis of these variations of flight vehicles and trajectories versus population, need to be performed to confirm operations may be performed within FAA’s cumulative Ec threshold (1 in 10,000).

2.2 Launch Site Boundary (420.21)
§420.21 (a) The distance from any proposed launch point to the closest launch site boundary must be at least as great as the debris dispersion radius of the largest launch vehicle type and weight class proposed for the launch point.
(b) For a launch site supporting any expendable launch vehicle, an applicant shall use the largest distance provided by table 2 for the type and weight class of any launch vehicle proposed for the launch point.
(c) For a launch site supporting any reusable launch vehicle, an applicant shall determine the debris dispersion radius that represents the maximum distance from a launch point that debris travels given a worst-case launch vehicle failure in the launch area. An applicant must clearly and convincingly demonstrate the validity of its proposed debris dispersion radius.

Except for the identification of the runways that will serve as the launch point, this work remains to be completed by Paso Robles.

For traditional vertical launch vehicles, the launch site is a fixed ground-based site located within a secure area on an established operating range. The launch site boundary may extend beyond the physically owned landmass of the spaceport, assuming there are control provisions for the uninvolved public on the property not owned by the spaceport. However, for a horizontally flown RLV similar to the Concept Y or Z vehicles the definition of the launch site boundary is not as clearly defined, but includes the length of the candidate launch runways, and the greatly reduced “worst case” failure dispersion radius at “launch.”

It is noted that for a horizontal launched spacecraft, the launch site boundary does not include the flight corridor and operating range. These are evaluated pursuant to 420.19 above and 420.23 below.

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2.3 Flight Corridor
§420.23 (a) Guided orbital expendable launch vehicle. For a guided orbital expendable launch vehicle, an applicant shall define a flight corridor that:
(1) Encompasses an area that the applicant estimates, in accordance with the requirements of this part, to contain debris with a ballistic coefficient of ≥3 pounds per square foot, from any non-nominal flight of a guided orbital expendable launch vehicle from the launch point to a point 5000 nm downrange, or where the IIP leaves the surface of the Earth, whichever is shorter; (2) Includes an overflight exclusion zone where the public risk criteria of 1 × 10−4 would be exceeded if one person were present in the open; and
(3) Uses one of the methodologies provided in Appendix A or B of this part. (b) Guided sub-orbital expendable launch vehicle. For a guided sub-orbital expendable launch vehicle, an applicant shall define a flight corridor that:
(1) Encompasses an area that the applicant estimates, in accordance with the requirements of this part, to contain debris with a ballistic coefficient of ≥3 pounds per square foot, from any non-nominal flight of a guided sub-orbital expendable launch vehicle from the launch point to impact with the earth's surface;
(2) Includes an impact dispersion area for the launch vehicle's last stage; (3) Includes an overflight exclusion zone where the public risk criteria of 1 × 10−4 would be exceeded if one person were present in the open; and
(4) Uses one of the methodologies provided in appendix A or B to this part. (c) Unguided sub-orbital expendable launch vehicle.
(1) For an unguided sub-orbital expendable launch vehicle, an applicant shall define the following using the methodology provided by appendix D of this part:
(i) Impact dispersion areas that the applicant estimates, in accordance with the requirements of this part, to contain the impact of launch vehicle stages from nominal flight of an unguided sub-orbital expendable launch vehicle from the launch point to impact with the earth's surface; and
(ii) An overflight exclusion zone where the public risk criteria of 1 × 10−4 would be exceeded if one person were present in the open.
(2) An applicant shall base its analysis on an unguided suborbital launch vehicle whose final launch vehicle stage apogee represents the intended use of the launch point. (d) Reusable launch vehicle. For a reusable launch vehicle, an applicant shall define a flight corridor that contains the hazardous debris from nominal and non-nominal flight of a reusable launch vehicle. The applicant must provide a clear and convincing demonstration of the validity of its flight corridor.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Flight trajectories for candidate vehicles have not been developed for PRB operations. However, initial discussions have occurred with Camp Roberts on the possibility of a route.

The PRB LSOL application will need to include flight corridor development, analysis, and documentation for each vehicle type chosen. The development of the flight trajectories will consider many factors, but the specific options for the use of existing airspace include restricted and warning areas close by Paso Robles; these are described below.

For reusable horizontal suborbital operations, PRASP is considering the use of Restricted Areas R-2504 and R-2513. Additionally, the offshore Warning Area W-532N is being considered. Figure 2-1: Restricted Areas R-2513 & R-2504 and Figure 2-2: Warning Area W-532N show the areas under consideration. Restricted Areas R-2504 and R-2513 are positioned north and west of PRB.

From PRB, R-2504 is approximately 8-Nautical Miles (N.M.) northwest of the airfield. Although larger in geographic area, R-2513 is approximately 28-N.M. northwest of the airfield.

For expendable orbital and suborbital rocket launch operations from aircraft platforms, Warning Area W-532N is the only reasonable and available “release” area that should be considered. In these situations, the flight trajectory is in westerly directions and all over water.

Applicability of a given operating location of reusable suborbital spacecraft will be predicated upon the performance and range of the vehicle attempting to access the area. The use of R2504 and R-2513 are advantageous as the geographical location relative to PRB reduces the required vehicle range to complete the proposed mission. Viability of R-2504 and R-2513 will be dependent upon the area required by the launch vehicle to execute the proposed mission and under lying population density, which will be a critical element in calculating the risk analysis.

Warning Area W-532N is an offshore warning area located along the California Coast. W-532N is positioned approximately 34-N.M. southwest of PRB on a bearing of approximately 214°. As a result of the airspace and position over the Pacific Ocean, it is recommended W-532N be included in the LSOL airspace analysis for expendable rocket operations from aircraft. (The distance from PRB may pose a challenge relative to the necessary range of a Concept Y vehicle to be used as the representative vehicle.)
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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Figure 2-1: Restricted Areas R-2513 & R-2504
Figure 2-2: Warning Area W-532N
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2.4 Risk Analysis
§420.25 (a) If a flight corridor or impact dispersion area defined by § 420.23 contains a populated area, the applicant shall estimate the casualty expectation associated with the flight corridor or impact dispersion area. An applicant shall use the methodology provided in appendix C to this part for guided orbital or suborbital expendable launch vehicles and appendix D for unguided suborbital launch vehicles.
(b) For licensed launches, the FAA will not approve the location of the proposed launch point if the estimated expected casualty exceeds 1 × 10−4
.

No risk analysis has been performed for Paso Robles, to date.

The risk analysis should evaluate the operation of the chosen representative launch vehicles. An RLV in the departure phase, arrival phase and while conducting the mission operation within the Flight Corridor is one set of analysis while the launch of orbital or suborbital expendable rockets from a carrier aircraft is also needed, but will be characterized differently, given the CONOPs.

The purpose of conducting a risk analysis is to confirm the remote likelihood any member of the public will be subjected to casualty as a result of the outcome of the operation.

After completing the launch site location review, identification of the launch site boundary and development of a flight corridor, a risk analysis will be performed (as described earlier).

In addition to fulfilling proposed mission requirements, the RLV will traverse airspace closer to populated areas during the departure and arrival phases of a nominal mission. The primary goal of the risk analysis performed for the Departure and Arrival routes will be to determine if the required probability of failure is met to satisfy the FAA’s Ec threshold.

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2.5 Information Requirements (420.27)
§420.27 An applicant shall provide the following launch site location review information in its application:
(a) A map or maps showing the location of each launch point proposed, and the flight azimuth, IIP, flight corridor, and each impact range and impact dispersion area for each launch point; (b) Each launch vehicle type and any launch vehicle class proposed for each launch point; (c) Trajectory data;
(d) Wind data, including each month and any percent wind data used in the analysis; (e) Any launch vehicle apogee used in the analysis;
(f) Each populated area located within a flight corridor or impact dispersion area; (g) The estimated casualty expectancy calculated for each populated area within a flight corridor or impact dispersion area;
(h) The effective casualty areas used in the analysis;
(i) The estimated casualty expectancy for each flight corridor or set of impact dispersion areas; and (j) If populated areas are located within an overflight exclusion zone, a demonstration that there are times when the public is not present or that the applicant has an agreement in place to evacuate the public from the overflight exclusion zone during a launch.

The data required of 420.27 are outcomes of the previous analysis as described. As noted earlier, this assessment and data has not yet been produced. It is recommended all calculations and background data used in the development of flight corridors and risk analyses be presented in an Appendix of the LSOL application.

2.6 Unproven Launch Vehicles
§420.29 An applicant for a license to operate a launch site for an unproven launch vehicle shall provide a clear and convincing demonstration that its proposed launch site location provides an equivalent level of safety to that required by this part.

The level of scrutiny associated with facilitating the operation of an unproven launch vehicle could be significant. For this reason, it is recommended PRASP not include unproven ill-defined launch vehicles in the LSOL application.

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2.7 Scope, Schedule, and Fee Estimate - Launch Site Location Review Definition of the launch site boundary, development of the flight corridor and completion of the risk analysis through the application of the representative vehicle to the launch components serve as the “meat and potatoes” of the LSOL application. The scope of the assessment needed to complete the LSLR has been reviewed earlier and is summarized below.

Because no formal analysis has been completed regarding the LSLR, one of the key data items that needs to be developed is the estimated population in the general vicinity of the intended operations (the nominal and potential off nominal flight corridor, and arrival and departure routes). The performance of candidate launch vehicles and carrier aircraft (as appropriate) need to be determined and airspace needs. Completion of a risk analysis associated with the vehicles and their flight trajectories is needed to satisfy the requirements of the launch site location review. Identification of the local launch site boundary is necessary. Coordination with LSPs will be helpful and instructive to identify operational characteristics or representative vehicles.

Collecting appropriate historic information in the case of a Virgin Orbit type of operation will also be helpful.

These developments will allow the risk analysis that serves as the cornerstone of the LSOL application. It is recommended the analysis be pre-coordinated extensively with FAA/AST and interim results submitted for review by FAA/AST prior to entering into any formal Airspace LOA.

The level of effort and schedule for completion of the LSLR will be based on the amount of time required to collect the relevant vehicle data, define the flight corridor and arrival and departure routes, collect and analyze population data, and perform the risk assessment. It is estimated that data collection and definition of candidate flight corridors should require approximately 16- weeks. FAA review and approval may require an additional 16-weeks, assuming nominal workload on their SMEs. The full evaluation and production of the risk analysis may take an additional 16-weeks for the various vehicle / trajectory configurations, with a similar amount of time to review with FAA/AST SMEs. The ROM estimate for LSLR completion is ~$500,000.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 3 Explosive Site Plan (420.17)
§420.17 (d) Explosive site plan. (1) Except as provided by paragraph (d)(2) of this section, an applicant shall submit an explosive site plan that complies with §§ 420.63, 420.65, 420.67, and 420.69.
(2) If an applicant plans to operate a launch site located on a federal launch range, and if the applicant is required by the federal launch range to comply with the federal launch range's explosive safety requirements, the applicant shall submit the explosive site plan submitted to the federal launch range.

Paso Robles will not be operating a launch site located on a federal launch range. Therefore, Paragraph (d) (2) will not apply to the PRB explosive siting criteria.

The FAA's explosive siting criteria, focuses on the safe storage and handling of explosives at launch sites. The objective of the regulations are to ensure public safety by minimizing risks associated with potential explosions. The status of the existing ESP work at Paso Robles is reviewed below.

3.1 Primary Deliverables of the Explosive Site Plan
§420.63 (a) A licensee must ensure the configuration of the launch site follows its explosive site plan, and the licensee's explosive site plan complies with the requirements of §§ 420.65 through 420.70.

The explosive site plan must include:
• §420.63(a)(1) Scaled Map
• §420.63(a)(2) Maximum Quantities in Hazard Facilities • §420.63(a)(3) Description of Activities in Hazard Facilities • §420.63(a)(4) Explosive Site Map
The City of Paso Robles and PRB have completed an ESP in accordance with the requirements outlined in §420.63. Paso Robles has received and addressed comments from FAA/AST and submitted additional iterations. Revision B of the PRASP Explosive Site Plan was submitted in November 2024. After receiving FAA’s comments, modifications were implemented and a Revision C of the PRASP was generated, which has not been submitted. Comments from Revision B are included in Table 1: FAA Comments of PRASP ESP provided below.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 It is estimated that Paso Robles should be close to approval of the ESP once comments are submitted. Given the past performance of FAA/AST, and in light of an abundance of caution, Paso Robles should expect one more iteration.

Once the ESP is approved, Paso Robles will need to integrate this information into an updated ALP and see ADO approval. This is anticipated to take up to 12 weeks once submitted.

Table 1: FAA Comments on PRASP ESP
FAA Comment Recommendations
Only Figure 3 and Figure 4 provide coordinates.

The oxidizer storage coordinates in Table 2 only
align with the coordinates in Figure 3, which is
the HTP storage pad, but where is LOX stored,
which is listed in Table 3?
For Figures 2 & 5, add the location of the fuel
storage and oxidizer storage areas and
associated coordinates.

In which figure is the location of the Airport Fuel
Storage, which is mentioned in Section 5.3 to be
shown in Figure 1, depicted?
The airport fuel facility is depicted in Figures 1
& 2.

Paso Robles briefly mentions in Section 3.1 KPRB
is in the process of developing a horizontal
launcher propellant loading area. Recommend
discussing more or removing and updating later.

Noted. The ESP addresses the propellant
loading area required for the ESP, no
additional loading areas.

In Section 6 Paso Robles provides general
information Propellant Storage, but this does
not fully explain activities or events at each
facility.

To address activities at each facility,
recommend incorporating a “quasi” concept of
operations stipulating the process and
procedures for receiving propellants and
oxidizers.

Tables list “Unlimited quantity”, which does not
provide enough information. Please update with
quantities.

Table 5. List of the maximum quantity of
energetic liquids and other explosives provided
in Revision C of the PRASP ESP expresses the
maximum quantities in pounds.

Was the equation in 420.65(c)(3) utilized? Where
is it shown to be utilized in the calculations?
c)(2) Are the ILDs measured from the nearest
point of one hazard source to the nearest point
of the next hazard source?

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3.2 Scaled Map
§420.63 (a)(1) A scaled map that shows the location of all explosive hazard facilities at the launch site and that shows actual and minimal allowable distances between each explosive hazard facility and all other explosive hazard facilities, each public traffic route, and each public area, including the launch site boundary;
Figures 1, 2, 3 and 4 of the PRASP Explosive Site Plan (ESP) provides a scaled map fulfilling the requirements of Part 420.63(a)(1). Following issuance of a LSOL, the PRB Airport Layout Plan (ALP) should be updated with a sheet containing the elements of the ESP. Considering this addition will in all likelihood not be allowed as a “pen & ink” change, it is recommended the ALP modification be executed while updating the Airport’s Master Plan.

3.3 Maximum Quantities of Propellants & Oxidizers Located at Hazard Facilities §420.63 (a)(2) A list of the maximum quantity of energetic liquids, solid propellants and other explosives to be located at each explosive hazard facility, including explosive class and division;

3.3.1 Maximum Quantities of Liquid & Solid Propellants
The PRASP ESP addresses maximum quantities of propellants located at each hazard facility to FAA’s satisfaction. In order to provide clarity, our only recommendation would be to add a column to Table 5 to separate Net Equivalent Weight (NEW) from actual weight. Additionally, to assist FAA with reviewing, an additional graphic summarizing the contents of Table 5 may be recommended. Section 3.1.2 clearly states solid propellants will not be considered in the LSOL.

PRASP noted they will limit the use of propellants to the operation of vehicles using liquid or cryogenic Division 1.1 with a NEW of less than or equal to 30,000 lbs. PRASP proposed obtaining confirmation of vehicle commodity types and quantities for each customer by applying a Customer Survey form to verify the maximum NEW is not exceeded. These commodities and maximum allowable quantities should be documented in the Spaceport User Agreement.

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3.3.2 Quantity Distance Estimates for Propellant Storage §420.67 (a) Separation of energetic liquids and determination of distances. Where incompatible energetic liquids are co-located in a launch or reentry vehicle tank or other vessel, a launch site operator must separate each explosive hazard facility from each other explosive hazard facility, each public area, and each public traffic route in accordance with the minimum separation distance determined under this section for each explosive hazard facility. (b) Quantity. For each explosive hazard facility, a launch site operator must determine the total quantity of all energetic liquids as follows:
(1) The quantity of energetic liquid in a launch or reentry vehicle tank is the net weight in pounds of the energetic liquid. The determination of quantity must include any energetic liquid in associated piping to any point where positive means exist for:
(i) Interrupting the flow through the pipe; or
(ii) Interrupting a reaction in the pipe in the event of a mishap. (2) A launch site operator must convert each energetic liquid's quantity from gallons to pounds using the conversion factors provided by table E-6 of appendix E of Part 420.

The PRASP ESP prepared in November 2024 satisfactorily addresses Quantity Distance (QD) for propellant storage in Section 3.1.1, Tables 3 (Minimal Allowable and Actual Explosive QDs) and 4 (Minimal Allowable and Actual Storage QDs (Roll-on/Roll-Off Containers)) and Figure 2 (Spaceport Potential Explosive Sites (PES) with Separation Distances).

3.3.3 Inhabited Building Distance
Appendix E of Part 420 provides quantity distance information as both “Public Area Distance” and “Intraline Distance”. The quantity distance tables provided in DoD 6055-09-STD do not identify a specific distance as a Public Area Distance and instead utilize the descriptions Inhabited Building Distance (IBD) and Public Traffic Route Distance (PTRD). When the tables from Appendix E are compared to the IBD/PTRD tables provided in DoD 6055.09-STD it is apparent that the Public Area Distance of Appendix E most closely matches the Inhabited Building Distance of the DoD Standard. The PRASP LSOL application therefore will assume that IBD is equivalent to the Public Area Distance of 14 CFR 420.

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3.3.4 Quantity Distance Estimate for Fueled RLV
The PRASP ESP addresses Net Equivalent Weights (NEW), quantities and distances in Sections 3, 4 and 5. FAA finds the manner in which PRASP addressed quantity distance for a fueled RLV is acceptable.

3.3.5 Quantities of Stored Propellants
Table 5 of the PRASP ESP titled List of the maximum quantity of energetic liquids and other explosives, addresses the quantities of stored propellants. Initially, FAA had questioned and commented on the method by which the quantities of stored propellants were expressed.

PRASP has since addressed FAA’s comments and reflected in Revision C, which has yet to be submitted to FAA for approval.

3.4 Description of Explosive Hazard Facility Activities §420.63 (a)(3) A description of each activity to be conducted at each explosive hazard facility.

Table 6 of the PRASP ESP provides a description of activities conducted at the explosive hazard facilities. While the activity description provided in Table 6 is relatively light, the verbiage is specific. To fulfill FAA’s requirements, a concept of operations based on an actual vehicle operation will need to be generated.

3.4.1 Hazard Classifications for each Hazard Facility
Table 5 of the PRASP ESP titled List of the maximum quantity of energetic liquids and other explosives, lists the Hazard Classification for each Hazard Facility.

3.5 Explosive Site Map
§420.63 (a)(4) An explosive site map using a scale sufficient to show whether distances and structural relationships satisfy the requirements of this part.

The PRASP ESP provides adequate Explosive Site Maps in Figure 2 (Spaceport Potential Explosive Sites (PES) with Separation Distances), Figure 3 (Loading Area and Propellant Storage Pads) and Figure 4 (Test Stand Areas).

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3.6 Propellant Storage & Handling
§420.65 (a) Quantity. For each explosive hazard facility, a launch site operator must determine the total quantity of division 1.1 and 1.3 explosives as follows:
(1) A launch site operator must determine the maximum total quantity of division 1.1 and 1.3 explosives by class and division, in accordance with 49 CFR part 173, Subpart C, to be located in each explosive hazard facility where division 1.1 and 1.3 explosives will be handled. (2) When division 1.1 and 1.3 explosives are located in the same explosive hazard facility, the total quantity of explosive must be treated as division 1.1 for determining separation distances; or, a launch site operator may add the net explosive weight of the division 1.3 items to the net explosive weight of division 1.1 items to determine the total quantity of explosives. (b) Separation of division 1.1 and 1.3 explosives and determination of distances. A launch site operator must separate each explosive hazard facility where division 1.1 and 1.3 explosives are handled from all other explosive hazard facilities, all public traffic routes, and each public area, including the launch site boundary, by a distance no less than that provided for each quantity and explosive division in appendix E of this part as follows:
(1) For division 1.1 explosives, the launch site operator must use tables E-1, E-2, and E-3 of appendix E of this part to determine the distance to each public area and public traffic route, and to determine each intraline distance.
(2) For division 1.3 explosives, the launch site operator must use table E-4 of appendix E of this part to determine the distance to each public area and public traffic route, and to determine each intraline distance.
(c) A launch site operator must:
(1) Employ no less than the public area distance, calculated under paragraph (b) of this section, to separate an explosive hazard facility from each public area, including the launch site boundary.
(2) Employ no less than an intraline distance to separate an explosive hazard facility from all other explosive hazard facilities used by a single customer. For explosive hazard facilities used by different customers a launch site operator must use the greater public area distance to separate the facilities from each other.
(3) Separate each public area containing any member of the public in the open by a distance equal to −1133.9 + [389 *ln(NEW)], where the NEW is greater than 450 pounds and less than 501,500 pounds.

Section 4 of the PRASP ESP addresses Part 420.65. FAA finds the PRASP ESP compliant with §420.65. FAA questioned the application of the equation stated in 420.65(c)(3) (−1133.9 + [389 *ln(NEW)]). PRASP addressed the comment in Section 4.3 of the ESP. This equation is not applicable given the NEW of propellant applied for Test Sites #1 and #2.

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3.7 Explosive Site Plan Evaluation Summary
The Paso Robles ESP updated document should be re-submitted for FAA/AST review. It is recommended the ESP comments be reviewed and addressed if necessary and submitted to FAA for review prior to moving forward with the completion of the remaining sections of the LSOL. A review of the ESP relating to the remaining comments will require a minimal amount of time (perhaps 1 week). Considering the recent turnover at FAA/AST; however, review time may be several months. No additional funds are anticipated to be needed, beyond sunk costs and labor.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 4 License to Operate a Launch Site
Section 4 considers the requirements of §§420.41, 420.43, 420.45, 420.47 and 420.49.

4.1 General
§420.41(a) – General - A license to operate a launch site authorizes a licensee to operate a launch site in accordance with the representations contained in the licensee's application, with terms and conditions contained in any license order accompanying the license, and subject to the licensee's compliance with 51 U.S.C. Subtitle V, chapter 509 and this chapter. (b) A license to operate a launch site authorizes a licensee to offer its launch site to a launch operator for each launch point for the type and any weight class of launch vehicle identified in the license application and upon which the licensing determination is based. (c) Issuance of a license to operate a launch site does not relieve a licensee of its obligation to comply with any other laws or regulations; nor does it confer any proprietary, property, or exclusive right in the use of airspace or outer space.

As the licensee, the City of Paso Robles will agree to the terms of §420.41 “License to Operate a Launch Site.” No other assessment is appropriate for this paragraph.

4.2 Duration
§420.43 – Duration - A license to operate a launch site remains in effect for five years from the date of issuance unless surrendered, suspended, or revoked before the expiration of the term and is renewable upon application by the licensee.

As the licensee, the City of Paso Robles will agree to the terms of §420.43 “Duration” and shall abide by the 5 year term and conditions of renewal, surrender, suspension, and revocation as identified in this requirement. No other assessment is necessary for this paragraph.

4.3 Transfer of License
§420.45 (a) Only the FAA may transfer a license to operate a launch site. (b) The FAA will transfer a license to an applicant who has submitted an application in accordance with 14 CFR part 413, satisfied the requirements of § 420.15, and obtained each approval required by § 420.17 for a license.(c) The FAA may incorporate by reference any findings made part of the record that supported a prior related licensing determination.

As the licensee, the City of Paso Robles will agree to the terms of §420.45 “Transfer of a License to Operate a Launch Site” and shall abide by the requirements set forth in the event of a proposed transfer of a License. No other assessment is necessary for this paragraph.

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4.4 License Modification
§420.47 (a) Upon application or upon its own initiative, the FAA may modify a license to operate a launch site at any time by issuing a license order that adds, removes, or modifies a license term or condition to ensure compliance with the Act and the requirements of this chapter. (b) After a license to operate a launch site has been issued, a licensee shall apply to the FAA for modification of its license if:
(1) The licensee proposes to operate the launch site in a manner that is not authorized by the license; or (2) The licensee proposes to operate the launch site in a manner that would make an representation contained in the license application that is material to public health and safety or safety of property no longer accurate and complete.
(c) An application to modify a license shall be prepared and submitted in accordance with part 413 of this chapter. The licensee shall indicate any part of its license or license application that would be changed or affected by a proposed modification.
(d) The FAA approves a modification request that satisfies the requirements of this part. (e) Upon approval of a license modification, the FAA issues either a written approval to the licensee or a license order modifying the license if a stated term or condition of the license is changed, added, or deleted.

A written approval has the full force and effect of a license order and is part of the licensing record.

As the licensee, the City of Paso Robles agrees to the terms of §420.47 “License Modification” and shall abide by the requirements set forth in the event of a modification to the license initiated by either the FAA or the City of Paso Robles. As additional LSP and component developers are identified and choose to use PRASP, opportunities will be presented for modifying the LSOL. These modifications will be addressed as prospects are identified. No other assessment is necessary for this paragraph.

4.5 Compliance Monitoring
§420.49 A licensee shall allow access by and cooperate with federal officers or employees or other individuals authorized by the FAA to observe any activities of the licensee, its customers, its contractors, or subcontractors, associated with licensed operation of the licensee's launch site.

As the licensee, the City of Paso Robles will agree to the terms of §420.49 “Compliance Monitoring” and shall allow access by and cooperate with federal officers or employees or other individuals authorized by the FAA to observe any activities of conducted by PRB Staff, PRB clientele, contractors, or subcontractors, associated with a licensed operation of the licensee’s launch site. No other assessment is necessary for this paragraph.

4.6 Operation of a Launch Site Evaluation Summary
FAR Parts §§420.41 through 420.49 outline the stipulations and conditions of operating a spaceport. No other assessment is necessary for this paragraph.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 5 Launch Site Operations
Launch Site Operations includes meeting compliance relative to the Launch Site Operator’s FAA assigned responsibilities and the following items listed below. • General Launch Site Operator responsibilities
• Control of Public Access
• Launch Site Operation Scheduling
• Notifications
• Mishap Plan
• Plan for maintaining records
• Lightning Protection
• Launch Site Accident Investigation Plan

5.1 Responsibilities
§420.51 A licensee must operate its launch site in accordance with the representations in its application.

The implementation of plans and safety systems are the responsibility of the launch site operator to ensure a safe and compliant operation. The management and staff of PRASP have made a significant effort in assembling the documentation required to fulfill the planning obligations of §§420.51 through 420.71. Provided below is a summary of these efforts.

5.2 Control of Public Access Plan
420.53 (a) A licensee shall prevent unauthorized access to the launch site, and unauthorized, unescorted access to explosive hazard facilities or other hazard areas not otherwise controlled by a launch operator, through the use of security personnel, surveillance systems, physical barriers, or other means approved as part of the licensing process.
(b) A licensee shall notify anyone entering the launch site of safety rules and emergency and evacuation procedures prior to that person's entry unless that person has received a briefing on those rules and procedures within the previous year.
(c) A licensee shall employ warning signals or alarms to notify any persons at the launch site of any emergency.

The importance of access control is to ensure a level of security and safety for uninvolved community members as a result of launch operations and activities at explosive hazard facilities.

The fact explosive hazard facilities are not active at all times and the separation distance requirements only apply to an active facility. The document titled PRASP-PLN-1120IR – Public Access Control Plan has been developed to address the requirements of §420.53. Sections 3.0 (Access Control), 3.1 (Hazard Area Access Control) and 3.2 (Site Familiarization & Safety Training) of the Public Access Control Plan provide guidance and the necessary compliance with §420.53 (a) and (b). Section 3.3 (Audible & Visible Warnings) provides compliance with §420.53 (c). The contents of the Public Access Control Plan appear sufficient to meet §420.53.

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5.3 Scheduling of Launch Site Operations & Notifications §420.55 (a) A licensee shall develop and implement procedures to schedule operations to ensure that each operation carried out by a customer at the launch site does not create the potential for a mishap that could result in harm to the public because of the proximity of the operations, in time or place, to operations of any other customer. A customer includes any launch operator, and any contractor, subcontractor or customer of the launch site operator's customer at the launch site. (b) A licensee shall provide its launch site scheduling requirements to each customer before the customer begins operations at the launch site.
§420.57 (a) A licensee shall notify each launch operator and any other customer of any limitations on the use of the launch site. A licensee shall also communicate limitations on the use of facilities provided to customers by the launch site operator.
(b) A licensee shall maintain its agreement, made in accordance with § 420.31(a), with the local U.S. Coast Guard district.
(c) A licensee shall maintain its agreement, made in accordance with § 420.31(b), with the FAA ATC office having jurisdiction over the airspace through which launches will take place. (d) At least 2 days prior to flight of a launch vehicle, unless the Administrator agrees to a different time frame in accordance with § 404.15, the licensee must notify local officials and all owners of land adjacent to the launch site of the flight schedule.

In October 2024, PRASP released document PRASP-PLN-1260, which is a plan to provide LSP’s a method for scheduling hazardous operations and established how notifications will be carried out. PRASP-PLN-1260, Scheduling of Hazardous Operations and Notifications, is accompanied by PRASP-PRO-1280, which outlines the procedure by which scheduling and notification takes place. The portion of the document dedicated to scheduling of launch site operations generally meets the intent of §420.55. In addition to the information requested of the launch site user, it is recommended the launch site operator in PRASP-PRO-1280 also requests propellant and oxidizer types and quantities to be stored and used for the proposed operation.

The remaining sections of PRASP-PLN-1260 and PRASP-PRO-1280 are dedicated to meeting the notification requirements of §420.57. The Notifications sections include contacts, and the procedure serves as a viable foundation. It is recommended the Notification procedure be tailored to the proposed operation. Notifications of a ground-based test will require alerting the PRASP stakeholders. Whereas notification of a launch operation will include not only specific PRASP stakeholders, but also members of the surrounding communities. Additionally, it is recommended the Notification procedure includes the local Paso Robles media outlets.

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5.4 Mishap Plan & Accident Investigation Plan
§420.59 (a) General. A licensee must report, respond to, and investigate any event that meets either paragraph (1) or (5) of the definition of “mishap” in §401.7 of this chapter. A licensee must submit a mishap plan that meets the requirements of §450.173(b) through (f). (b) Launch mishaps. A launch site operator's mishap plan must also contain procedures for participating in an investigation of a launch mishap for launches launched from the launch site. (c) Other agency procedures. Emergency response and investigation procedures developed in accordance with 29 CFR 1910.119 and 40 CFR part 68 will satisfy the requirements of §450.173(d) and (e) to the extent that they include the elements required by §450.173(d) and (e). § 417.111 (h) Accident investigation plan (AIP). A launch operator must implement a plan containing the launch operator's procedures for reporting and responding to launch accidents, launch incidents, or other mishaps, as defined by § 401.5 of this chapter. An individual, authorized to sign and certify the application as required by § 413.7(c) of this chapter, and the person designated under § 417.103(b)(2) must sign the AIP.
(1) Reporting requirements. An AIP must provide for—
(i) Immediate notification to the Federal Aviation Administration (FAA) Washington Operations Center in case of a launch accident, a launch incident or a mishap that involves a fatality or serious injury (as defined by 49 CFR 830.2).
(ii) Notification within 24 hours to the Associate Administrator for Commercial Space Transportation or the Federal Aviation Administration (FAA) Washington Operations Center in the event of a mishap, other than those in § 415.41 (b) (1) of this chapter, that does not involve a fatality or serious injury (as defined in 49 CFR 830.2). (iii) Submission of a written preliminary report to the FAA, Associate Administrator for Commercial Space Transportation, in the event of a launch accident or launch incident, as defined by § 401.5 of this chapter, within five days of the event. The report must identify the event as either a launch accident or launch incident, and must include the following information:
(A) Date and time of occurrence;
(B) Description of event;
(C) Location of launch;
(D) Launch vehicle;
(E) Any payload;
(F) Vehicle impact points outside designated impact lines, if applicable; (G) Number and general description of any injuries;
(H) Property damage, if any, and an estimate of its value; (I) Identification of hazardous materials, as defined by § 401.5 of this chapter, involved in the event, whether on the launch vehicle, payload, or on the ground; Attachment 7

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 (J) Action taken by any person to contain the consequences of the event; and (K) Weather conditions at the time of the event.
(2) Response plan. An AIP must—
(i) Contain procedures that ensure the containment and minimization of the consequences of a launch accident, launch incident or other mishap;
(ii) Contain procedures that ensure the preservation of the data and physical evidence; (3) Investigation plan. An AIP must contain—
(i) Procedures for investigating the cause of a launch accident, launch incident or other mishap; (ii) Procedures for reporting investigation results to the FAA; and (iii) Delineated responsibilities, including reporting responsibilities for personnel assigned to conduct investigations and for any one retained by the licensee to conduct or participate in investigations.

Defined, a “Launch Accident” means: “An event that causes a fatality or serious injury (as defined in 49 CFR 830.2) to any person who is not associated with the flight or an event that causes damage estimated to exceed $25,000 to property not associated with the flight that is not located at the launch site or designated recovery area, or an unplanned event occurring during the flight of a launch vehicle resulting in the impact of a launch vehicle, its payload, or any component thereof.” The purpose of the Mishap Plan, Emergency Response Plan, and Launch Site Accident Investigation Plan is to identify and define the responsibilities of the various parties involved, should a launch site accident occur at PRASP or as a result of a launch initiated from PRASP, for which the FAA or National Transportation Safety Board (NTSB) has responsibility. In today’s environment, launch site operators have the option of combining both the Mishap Plan and Accident Investigation Plan in one document, or establish each as standalone documents.

PRASP has developed a Mishap and Emergency Response Plan, titled PRASP-PLN-1160. The document was drafted using a methodical technique to confirm each of the regulatory requirements were met. The Mishap and Emergency Response Plan is relatively “user friendly” and reads in the manner necessary to gain FAA approval.

At this time, a Launch Site Accident Investigation Plan (AIP) has not been specifically prepared for PRASP. However, a majority of the elements required for an AIP are contained in the existing PRASP Mishap and Emergency Response Plan. Considering this scenario it is recommended the officials representing PRASP expand the current PRASP-PLN-1160 to include those elements required for the AIP. A primary element of the AIP is to stipulate command and control responsibilities for accidents occurring within the geographical bounds of PRASP and beyond the PRASP property line. For those accidents occurring within the limits of the Spaceport, PRASP will have full responsibility to exercise command and control until FAA and NTSB are on site. For Attachment 7

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 accidents occurring beyond the limits of PRASP property, controlling jurisdiction will be dependent upon the accident location. In accordance with §417.111, the launch operator will be responsible for providing a course of action to follow should a launch site accident occur beyond the PRASP physical limits.

5.5 Record Retention
§420.61 (a) A licensee shall maintain all records, data, and other material needed to verify that its operations are conducted in accordance with representations contained in the licensee's application. A licensee shall retain records for three years. (b) For any event that meets any of paragraph (1), (5), or (8) of the definition of “mishap” in § 401.7 of this chapter, a licensee must preserve all records related to the event. Records must be retained until completion of any Federal investigation and the FAA advises the licensee that the records need not be retained.
(c) A licensee shall make available to federal officials for inspection and copying all records required to be maintained under the regulations.

PRASP has developed a Records Retention Plan titled PRASP-PLN-1020. The Record Retention Plan meets the requirements of §420.61. The document specifies documents and document types to be stored and for what period of time. Additionally, the document stipulates the manner in which records are handled once they have exceeded their specific storage time requirements. The document stipulates, “The PRASP Manager is the official Records Custodian and has the ultimate responsibility for proper management of all PRASP records.” In addition to the PRASP Manager, it is recommended to list any other parties who will access to these documents and the specific location of their safekeeping. For the annual FAA inspections, it is customary for the spaceport manager to receive a question regarding the location of the spaceport records and who and who does not have access.

5.6 Lightning Protection & Advisories
§420.71 (a) Lightning protection. A licensee shall ensure that the public is not exposed to hazards due to the initiation of explosives by lightning.
(1) Elements of a lighting protection system. Unless an explosive hazard facility meets the conditions of paragraph (a)(3) of this section, all explosive hazard facilities shall have a lightning protection system to ensure explosives are not initiated by lightning. A lightning protection system shall meet the requirements of this paragraph and include the following:
(i) Air terminal. An air terminal to intentionally attract a lightning strike. (ii) Down conductor. A low impedance path connecting an air terminal to an earth electrode system.
(iii) Earth electrode system. An earth electrode system to dissipate the current from a lightning strike to ground.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 (2) Bonding and surge protection. A lightning protection system must meet the requirements of this paragraph and include the following:
(i) Bonding. All metallic bodies shall be bonded to ensure that voltage potentials due to lightning are equal everywhere in the explosive hazard facility. Any fence within six feet of a lightning protection system shall have a bond across each gate and other discontinuations and shall be bonded to the lightning protection system. Railroad tracks that run within six feet of the lightning protection system shall be bonded to the lightning protection system.
(ii) Surge protection. A lightning protection system shall include surge protection to reduce transient voltages due to lightning to a harmless level for all metallic power, communication, and instrumentation lines entering an explosive hazard facility. (3) Circumstances where no lightning protection system is required. No lightning protection system is required for an explosive hazard facility when a lightning warning system is available to permit termination of operations and withdrawal of the public to public area distance prior to an electrical storm, or for an explosive hazard facility containing explosives that cannot be initiated by lightning. If no lightning protection system is required, a licensee must ensure the withdrawal of the public to a public area distance prior to an electrical storm. (4) Testing and inspection. Lightning protection systems shall be visually inspected semiannually and shall be tested once each year for electrical continuity and adequacy of grounding. A licensee shall maintain at the explosive hazard facility a record of results obtained from the tests, including any action taken to correct deficiencies noted.

5.6.1 Lightning Protection
Lightning protection is a critical element of all launch sites and areas that contain explosive propellants. The geographic location of Paso Robles is not subject or prone to significant lightning, nor are all explosive hazard facilities active at all times. Therefore, it should be made clear lightning protection policies apply to only active facilities. PRASP addresses “Lightning Hazard Mitigation” in Section 5 of the Spaceport’s Ground Operation Safety Plan (PRASP-PLN1140). Table 2: Lightning Advisories below outlines the PRASP lightning requirements. Ultimately, it will be up to the RLV operator to determine which operations and tasks are lightning sensitive.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 In addition to the information provided in the Ground Operation Safety Plan, the following policies are recommended as an operational baseline.
• Vehicle fuel and oxidizer loading will not begin if there is forecast to be greater than a given percentage chance of lightning within a given distance of PRASP. • Do not takeoff if lightning has been detected within a given distance of PRASP within a given time to departure.
• Do not takeoff if there is forecast to be greater than a given percentage chance of lightning within a given distance of the flight corridor by the time the RLV would arrive at the flight corridor location.

Table 2: Lightning Advisories
Lightning Warning Condition Actions
Phase I – Lightning
Watch
Lightning is expected to occur
within 5-miles of PRASP in the
next 30 minutes.

Work to a step in the procedure
where the team can safe
vehicle/system and prepare personnel
to move indoors. Instruct personnel
working on any elevated platforms
descend to ground level.

Phase II – Lightning
Warning
Lightning is imminent or
occurring within 5-miles of the
PRASP.

Safe the vehicle/system. Immediately
seek shelter. Do not initiate operations
for 30 minutes after last lighting strike
within the 5-mile range.

PRASP staff and spaceport users may use the automated surface observation station (ASOS) or an allowable mobile application for detecting lightning. It is recommended Paso Robles officials select an application or use of the ASOS be completed and documented in the Ground Operation Safety Plan.

5.6.2 Electrical Power Lines
§420.71 (b) Electrical power lines. A licensee shall ensure that electric power lines at its launch site meet the following requirements:
(1) Electric power lines shall be no closer to an explosive hazard facility than the length of the lines between the poles or towers that support the lines unless an effective means is provided to ensure that energized lines cannot, on breaking, come in contact with the explosive hazard facility. (2) Towers or poles supporting electrical distribution lines that carry between 15 and 69 KV, and unmanned electrical substations shall be no closer to an explosive hazard facility than the public area distance for that explosive hazard facility. (3) Towers or poles supporting electrical transmission lines that carry 69 KV or more, shall be no closer to an explosive hazard facility than the public area distance for that explosive hazard facility.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 The location, length and strength of electrical distribution is generally an area of concern for facilities attempting to complete the LSOL application process. A cursory review of the electrical sources surrounding and serving the PRASP community indicates all powerlines meet the requirements of §420.71. For the formal preparation of LSOL application a confirmation of the specific location of the powerlines will be undertaken. Additionally, electrical power line compliance for lightning protection is addressed in the PRASP Ground Operations Safety Plan.

Transfer of this information to the LSOL application will be adequate for addressing electrical powerline compliance.

5.7 Agreements
§420.31 Agreements. (a) Except as provided by paragraph (c) of this section, an applicant shall complete an agreement with the local U.S. Coast Guard district to establish procedures for the issuance of a Notice to Mariners prior to a launch and other such measures as the Coast Guard deems necessary to protect public health and safety.
(b) Except as provided by paragraph (c) of this section, an applicant shall complete an agreement with the FAA Air Traffic Control (ATC) office having jurisdiction over the airspace through which launches will take place, to establish procedures for the issuance of a Notice to Airmen prior to a launch and for closing of air routes during the launch window and other such measures as the FAA ATC office deems necessary to protect public health and safety. (c) An applicant that plans to operate a launch site located on a federal launch range does not have to comply with section 420.31 if the applicant is using existing federal launch range agreements with the U.S. Coast Guard and the FAA ATC office having jurisdiction over the airspace through which launches will take place.

PRASP is not a federal launch range. Regarding agreements, §420.31(c) will not apply to the LSOL application process for PRASP. While some coordination has been undertaken to initiate Airspace and USCG agreements, no formal efforts have been made to assemble the necessary terms. Among the terms to be included is a Notifications requirement that is addressed in §420.57. These requirements include a Letter of Agreement (LOA) with the local US Coast Guard (USCG) District and the governing Air Traffic Control (ATC) agency controlling the airspace in which launch operations will take place. Currently, PRASP has neither an agreement with the USCG nor Air Traffic. Once the launch site boundary and flight corridor have been defined, it is recommended pursuit of these agreements be undertaken. The bureaucracy and “red tape” associated with these agreements require a significant lead time and will require a level of coordination to complete, perhaps up to 6 months using template documents to start.

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5.8 Launch Site Operations Evaluation Summary
Compliance with the requirements of FAA/AST’s launch site operations includes the development and implementation of multiple plans and safety systems. The PRASP Public Access Control Plan (PRASP-PLN-1120IR), is sufficient for meeting the requirements of §420.53.

The Scheduling of Hazardous Operations and Notifications (PRASP-PLN-1260) includes PRASPPRO-1280. PRASP-PRO-1280 serves as the procedure and instruction for applying the scheduling component of PRASP-PLN-1260. It is recommended PRASP-PRO-1280 be modified to also request propellant and oxidizer types and quantities to be stored and used for the proposed operation. Regarding the “Notification” elements of PRASP-PLN-1260, notices and announcements alerting stakeholders of operations should be tailored to the specific launch or testing operation. Additionally, it is recommended local media outlets be included as part of the “Notification” procedure.

To address Mishap and Emergency Response Planning, PRASP has developed PRASP-PLN-1160.

The Mishap and Emergency Response Plan is approvable in the current state. PRASP does not currently have a standalone Launch Site Accident Investigation Plan (AIP). A majority of the required AIP components, however, are contained in the existing PRASP Mishap and Emergency Response Plan. As opposed to developing a standalone AIP, it is recommended the existing Mishap and Emergency Response Plan be expanded to include the necessary steps aimed at accident investigation. The proposed modifications should require only a limited amount of time and not reflect negatively on the overall LSOL application schedule.

PRASP-PLN-1020 contains Spaceport’s Records Retention. The plan is thorough and meets the intent of the regulation. The only recommendation is to list the specific storage location and specifically who has access to the Spaceport records. Additional time requirements are not anticipated as a result of the implementation of the recommended modifications.

The objective of lightning protection is to safeguard launch vehicles, personnel and propellant infrastructure from the effects of lightning. The management and staff of PRASP have prepared a Spaceport Ground Operation Safety Plan (PRASP-PLN-1140). The Ground Operation Safety Plan provides an outline and description of the lightning protection advisories and procedures in place at PRASP. As noted in Section 5.6, it is suggested that additional policies be considered or inclusion in the lightning protection policy. These recommendations will require a minimal amount of time for inclusion and should not result in additional FAA questions.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 With the exception of the establishment of agreements with ATC and the USCG, the development and implementation of plans needed to fulfill Launch Site Operations requirements will entail some time, perhaps as much as three months. The development of agreements with ATC and USCG will require a significant effort and amount of time for completion may be as much as six months. As a result of existing government work loads, bureaucracy and required level of coordination, many agencies including FAA Air Traffic Operations (ATO) and USCG have accepted a template form for these agreements.

For these combined efforts, the time required may be up to nine months. The estimated expense of these efforts in SME time and expense is ~$100,000.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 6 Environmental
§420.15 (b) Environmental. The FAA is responsible for complying with the procedures and policies of the National Environmental Policy Act (NEPA) and other applicable environmental laws, regulations, and Executive Orders prior to issuing a launch site license. An applicant must provide the FAA with information needed to comply with such requirements. The FAA will consider and document the potential environmental effects associated with issuing a launch site license.

All environmental impacts regarding the operation and LSOL for Paso Robles Spaceport will be drafted in a separate document set. Although §420.15(b)(2) states, “The FAA may determine that a categorical exclusion is appropriate upon receipt of supporting information from an applicant” no such CATEX exists in FAA/AST policy of history.

However, on August 13, 2025, Presidential Executive Order (EO) 14335, titled "Enabling Competition in the Commercial Space Industry” was signed into force. The EO expressly directs the Secretary of Transportation and others to:
“…use all available authorities to expedite their respective environmental and administrative reviews for authorizations, permits, approval, real property leases, and any other activity relevant to spaceport infrastructure development. The Chair of the Council on Environmental Quality shall coordinate with relevant executive departments and agencies (agencies) on the establishment of new categorical exclusions under NEPA for actions related to spaceport development that normally do not have a significant effect on the quality of the human environment. Agencies shall, for purposes of establishing these categorical exclusions, rely on any sufficient basis to do so as each such agency determines.” Considering no prior spaceport or airport EA has previously been executed at KPRB it is uncertain how much expediting the FAA will implement for a new spaceport license given the EO. And although the EO also encouraged the Federal suspension and intervention of state-level environmental and other regulations, it is possible that Paso Robles will still need to conform to CEQA requirements.

Prior to the EO, Appendix A was prepared that defines a full Scope of Work for the completion of the tasks necessary to address a traditional LSOL NEPA effort within the framework of FAA/AST and CEQA requirements. It remains unchanged to reflect the “worst case”. Historical precedents are now unhelpful, but given the EO’s intent and time to implement, we still anticipate between 12-18 months for these EA/CATEX and CEQA activities running in parallel with the LSOL developments. Even with the new EO, we anticipated costs of environmental efforts will be approximately $600,000. If the EO reduces CEQA it may lower costs by $150,000.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 7 Summary
Following the assessment of the LSOL Application elements completed by the management and staff of KPRB and the City of Paso Robles, the results and findings were summarized in a matrix.

The matrix is presented below in Table 3 Approvability & Level of Completeness and provides a condensed version of the overall evaluation. A LSOL application criteria receiving an “Approvable” grade indicates the element should encounter little or no negative comment from FAA. A grade of “Partial/Questions” indicates the LSOL element is either incomplete or prior to approval, there exists outstanding questions requiring answers. A grade of “Not Approvable” indicates the specific LSOL application element has not been initiated or its status is in the beginning stages.

Table 3 Approvability & Level of Completeness
Paso Robles Air and Space Port
Launch License Data Approvability
FAA Regulation Criteria
Approvability Grade
Approvable Partial/
Questions
Not
Approvable
Subpart B Criteria and Information Requirements for a License 420.15(a) General —
420.15(a)(1) Launch site operator. An applicant shall identify the name and address of the applicant, and the name,
address, and telephone number of any person to whom
inquiries and correspondence should be directed.
420.15(a)(2) Launch site. An applicant shall provide the name and location of the proposed launch site and include the
following information:
420.15(a)(2)(i) A list of downrange equipment;
420.15(a)(2)(ii)1 A description of the launch sit layouts and launch points; 420.15(a)(2)(iii)1 The types of launch vehicles at each launch point; 420.15(a)(2)(iv)1 The range of launch azimuths planned from each launch; 420.15(a)(2)(v) The scheduled operational date.
420.15(a)(3) Foreign ownership. Identify foreign ownership of the applicant, as follows:
420.15(b)2 Environmental. The FAA is responsible for complying with the procedures and policies of the National
Environmental Policy Act (NEPA) and other applicable
environmental laws, regulations, and Executive Orders
prior to issuing a launch site license.
420.15(c)3 Launch site location.
420.19 Launch site location review—general.
420.21 Launch site location review—launch site boundary. 420.23 Launch site location review—flight corridor.
420.25 Launch site location review—risk analysis.
420.27 Launch site location review—information requirements. 420.29 Launch site location review for unproven launch vehicles.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Table 3 continued
Federal
Aviation
Regulation
Criteria
Approvability Grade
Approvable Partial/
Questions
Not
Approvable
420.30 Launch site location review for permitted launch vehicles.
420.15(d)4 Explosive site plan.
420.15(d)(1) Except as provided by paragraph (d)(2) of this section, an applicant shall submit an explosive site plan that
complies with §§ 420.63, 420.65, 420.67, and 420.69.
450.51 Launch site Operations & Responsibilities
420.53 Control of public access.
420.55 Scheduling of launch site operations.
420.57 Notifications.
420.59 5 Mishap plan.
420.61 6 Records.
420.31 7 Agreements.
420.31(a) Except as provided by paragraph (c) of this section, an applicant shall complete an agreement with the local
U.S. Coast Guard district to establish procedures for the issuance of a Notice to Mariners prior to a launch and
other such measures as the Coast Guard deems
necessary to protect public health and safety.
420.31(b) Except as provided by paragraph (c) of this section, an applicant shall complete an agreement with the FAA Air
Traffic Control (ATC) office having jurisdiction over the airspace through which launches will take place, to
establish procedures for the issuance of a Notice to
Airmen prior to a launch and for closing of air routes
during the launch window and other such measures as
the FAA ATC office deems necessary to protect public
health and safety.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Table 3 – continued.

Federal
Aviation
Regulation
Criteria
Approvability Grade
Approvable Partial/
Questions
Not
Approvable
420.71 Lightning protection.
420.71(a) Lightning protection. A licensee shall ensure that the public is not exposed to hazards due to the initiation of explosives by lightning.
420.71(b) Electrical power lines. A licensee shall ensure that electric power lines at its launch site meet the following requirements:
420.71(b)(1) Electric power lines shall be no closer to an explosive hazard facility than the length of the lines between the poles or towers that support the lines unless an effective means is provided to ensure that energized lines cannot, on breaking, come in contact with the explosive hazard
facility.
420.71(b)(2) Towers or poles supporting electrical distribution lines that carry between 15 and 69 KV, and unmanned
electrical substations shall be no closer to an explosive hazard facility than the PAD for explosive hazard facility. 420.71(b)(3) Towers or poles supporting electrical transmission lines that carry 69 KV or more, shall be no closer to an
explosive hazard facility than the public area distance for that explosive hazard facility.

Notes:
1 Launch Points will be predicated on the selected representative vehicle. After the representative vehicle is confirmed, a concept of operations will be developed, which will be instrumental in identifying the Launch Points. 2 The NEPA review is anticipated to begin in the third quarter of 2025. 3 Elements of the Launch Site Location will be defined based on the performance and CONOPs associated with the representative example vehicle.
4 The Explosive Site Plan is complete with comments addressed. However, document needs to be submitted for approval.

Considering FAA turnover, new reviewers may precipitate additional comments. 5 The Mishap Plan will be approvable with the inclusion of Accident Investigation Criteria, which is currently available in other documents.
6 The Records Retention Plan is acceptable in its current state. FAA may question specifics related to storage location and individual accessibility.
7 Development of agreements have not been initiated. Recommended to start agreement negotiations immediately following definition of Flight Corridor and Launch Points.

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7.1 LSOL Application Next Steps
The immediate next step in the LSOL process will be to continue pre-application coordination with FAA/AST. Through this process PRASP will be assigned an FAA/AST Program Manager to oversee the application process. The LSOL process will consist of two distinct components, including the LSOL Application and the required Environmental Review (scope is TBD). Prior to initiating the EA or LSOL, FAA will request a CONOPs detailing the steps involved in executing a licensed launch site operation.

Again, depending on the implementation impacts of the EO, what remains of the Environmental Review process and the LSOL application may be developed in parallel. Historically, some elements of the EA have been driven by components of the LSOL application. These components will include definition of the flight corridor, sonic boom impacts, and approval of the ESP. For purposes of this application, it is assumed FAA/AST will still require an EA (perhaps abbreviated) for the PRASP LSOL, but this may be reduced to a CATEX with some elements of analysis like sonic boom and noise. Considering the potential EO impacts on the additional approval layer associated with fulfillment of CEQA requirements, it is recommended the environmental tasks be discussed with California and Federal officials as soon as possible.

The PRASP Team have done a very good job addressing elements of the LSOL, which are within their respective purview. Considering this scenario, as a next phase it is recommended steps be taken to formally define the flight corridor and departure and arrival routes. Definition of the flight corridor and departure and arrival routes will require coordination with the operator of the representative launch vehicle in order to obtain performance information and vehicle CONOPs.

Once the flight corridor has been defined, should the new approach by FAA/AST (and CEQA officials) require noise and sonic boom analysis, it may be executed. Additionally, with the completion of the flight corridor, the risk analysis, may be initiated.

Assuming the risk, noise and sonic boom analysis (if required) are completed with a positive outcome, the next logical step will be to establish agreements with the governing air traffic agency (Los Angeles Center & Oakland Center) and the local USCG District. The establishment of the agreements as by §420.31 can be exceptionally time consuming as result of a lack of familiarity by the government agencies. It is for this reason coordination and familiarization with the given agencies should begin prior to presentation of the respective agreements.

While these primary components of the LSOL application process are being developed, the remaining required Launch Site Operational elements may be completed in the background simultaneously. Once a draft has been assembled, the document will be submitted to FAA for review and comment. FAA will have up to 180-days to review the draft document.

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Figure 7-1: FAA/AST Licensing Process

7.2 Estimated Schedule and Fee
The City of Paso Robles and PRB have made a significant investment to address key LSOL application elements that are potential “go/no-go” topics. It is our professional opinion that with some additional effort the work to date on the LSOL elements will be accepted by FAA. To submit a completed LSOL application Paso Robles will need to complete: (i) other detailed assessments (i.e. flight safety and risk analysis); (ii) Letters of Agreement (LOAs) with the U.S.

Coast Guard and FAA Air Traffic; (iii) an updated Airport Layout Plan (ALP) with the spaceport Explosive Site Plan (ESP); and (iv) environmental permits (state and federal). Given the recent EO, we believe the environmental review will be materially reduced from prior estimates over the next nine months. Once funded we estimate that Paso Robles’ efforts to receive an LSOL will take 12-18 months and cost between $900,000 and $1.2 Million in third party costs for subject matter experts and consultants. If the new EO eliminates the need for the California Environmental Quality Act (CEQA) approvals, and a federal spaceport categorical exclusion (CATEX) ruling is possible, the cost may be as low as $750,000. Schedules will be governed by the workload of FAA/AST and if there is a launch service provider with a commitment and near term operational date (e.g., 2027/28).

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All Rights Reserved. UNCLASSIFIED Rev 1. 1 , 3 0 S e p t e m b e r 2025 Appendix A – Environmental Assessment Scope of Work
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Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A1 of A24
All Rights Reserved. UNCLASSIFIED 30 September 2025

I EA CONSULTANT SERVICES
The City of Paso Robles (City) has requested an evaluation of the existing work done to date on a launch site operators license. Where work has not been completed, the City has requested RS&H to define the scope of services, potential schedule, and funding needed to complete these efforts.

There has been no environmental work performed for the launch site operator license. As such, this annex defines the scope of services, estimated time, and an estimated fee for the completion of an Environmental Assessment (EA) in compliance with the National Environmental Policy Act (NEPA) as implemented by FAA Order 1050.1G (30 June 2025), and an Environmental Impact Report (EIR) in compliance with the California Environmental Quality Act (CEQA) for obtaining a Launch Site Operator License (LSOL or “spaceport license”) for Paso Robles Municipal Airport (PRB or Airport).

The City’s spaceport development efforts may include up to and including construction of a hangar, apron, taxiway connector, access road, and vehicle parking for launch system providers (LSPs) and/or operators. The City may also need to construct an oxidizer loading area (OLA) to enable launch system operators to complete fueling activities before takeoff on a concrete pad safely away from other airport activities and public transport or observation locations.

The FAA/AST defined suborbital Concept Y and Concept Z launch systems are being proposed to operate under the LSOL at PRB. Also, it is being considered to operate suborbital and orbital expendable rocket flights from carrier aircraft. These are described further below.

Concept Y is a rocket powered reusable launch vehicle (RLV) that may be used for both human spaceflight and/or automated flight with non-human payloads. The Concept Y vehicle ignites its rocket engines while on the ground and takes off horizontally from a runway. The Concept Y RLV flies to altitude, then glides back to the point of origin (i.e., PRB). Examples of Concept Y vehicles include Dawn Aerospace’s family of vehicles (the Mark II Aurora, and eventually the Mark III), and the former XCOR Aerospace Lynx suborbital spacecraft.

The suborbital Concept Z launch system comprises a carrier aircraft and a rocket-powered RLV.

Jet engines typically power the carrier aircraft and would be designed to carry the expendable rocket or RLV to a location, typically over the ocean. At an altitude of approximately 40,000 feet above mean sea level (MSL), the rocket/RLV would be detached and the rocket engine(s) ignited to orbit. The carrier aircraft would return to the launch site and land under jet engine power. The rocket/RLV would complete its mission. The rocket’s expendable components, if any, would be dropped into the ocean, while an RLV would glide back to PRB. An example of a Concept Z launch system includes the Virgin Galactic White Knight 2 and Spaceship Two vehicles.

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Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A2 of A24
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The expendable suborbital and orbital class launchers that may be considered by Paso Robles would be carried aloft by a carrier aircraft and launched over the sea on a suborbital trajectory or to orbit over the Pacific Ocean. An example of such a configuration would be the former Virgin Orbit/Launcher One configuration, the Northrop L-1011/Pegasus configuration, the Stratolaunch/Talon-A configuration, and the potential future vehicle from Dawn Aerospace, the Mark III Aurora with satellite launch capability.

This scope of services outlines the tasks to be performed by a firm such as RS&H (called “the contractor” within), and a team of subject matter experts (SMEs) assisting the City with developing an LSOL EA and EIR for operations at PRB. This scope of services is based on our best judgements at the time of writing this annex. However, the analyses required to properly determine project impacts on various environmental categories may be different than initially envisioned and hence may necessitate separate, in-depth, independent studies beyond the tasks described below. If the FAA or any agency (e.g., US Coast Guard, US Fish and Wildlife Service, US Army Corps of Engineers, etc.) requires such an expanded effort, or if the City or FAA chooses to include such an effort in this EA or EIR, then the outlined effort below would require additional work scope. Fee estimates negotiated for the original scope of services would also require adjustment to complete the necessary work.

It is estimated that the scope of services outlined should take up to 18 months before a CEQA ruling is issued and a FONSI (finding of no significant impact) is issued by FAA-AST, assuming the California authorities and FAA SMEs that evaluate early sections of the documents during the preparation process are efficiently reviewing and replying reasonably to submitted materials.

During this 18 month period the City may incur up to $900,000 in fees and expenses by the contractor chosen for this effort.

II NEPA SCOPE OF SERVICES
Tasks 1 through 7 are the estimated and detailed scope of services needed for preparing an EA for the Proposed Action pursuant to FAA/AST practice in accordance with FAA Order 1050.1G as understood today, soon after its recent publication in the past several weeks. Also, this scope of services assumes practices that have been followed for the past decade, but may evolve given new federal authorities and Presidential directives and orders. Should these initiatives materially change former practice, this detailed scope of services will need to evolve.

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Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A3 of A24
All Rights Reserved. UNCLASSIFIED 30 September 2025
TASK 1 DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES (DOPAA) Task 1.1 Description of the Proposed Action
The contractor shall develop a detailed description of the Proposed Action (facilities and launches) associated with obtaining an LSOL. This description will include exhibits, as appropriate, and information regarding the type of operations envisioned.

Task 1.2 Purpose and Need
The contractor should base the preparation of the Purpose and Need upon analyses and information from previously completed tasks and appropriate studies provided by the City. No new activity forecasts or facility and capacity analysis will be undertaken. The contractor shall describe:
1) the action’s Purpose (i.e., what the City wishes to implement); and 2) the action’s Need (i.e., why the City needs to implement).

To meet FAA guidelines, the Purpose and Need Statement should be as short as possible while clearly conveying the Proposed Action’s purpose and need.

Task 1.3 Alternatives
The contractor will use previous studies provided by the City and any additional, recent, spaceport planning analysis to identify and describe potential alternatives. The contractor shall examine various ways that the Purpose and Need could be met. Among those ways will be the City’s Proposed Action and, in compliance with the requirements of NEPA (40 CFR 1501.2(c)), all other reasonable, feasible, and prudent alternative ways the City and RS&H have considered to achieve the Purpose and Need. The contractor shall ensure the Proposed Action and reasonable alternatives are described so they are easily understood.

The EA will tersely explain the process the contractor will use to “screen” (i.e., accept or reject) various alternatives to the Proposed Action. The EA will include an explanation of why the City has selected the Proposed Action in lieu of other reasonable alternatives identified. The EA also will identify the No Action Alternative to meet NEPA requirements (40 CFR 1502.14(d)) and to serve as the baseline against which all reasonable alternatives are compared.

TASK 2 NOISE APPROACH, ANALYSIS AND REGION OF INFLUENCES The contractor’s team will prepare a noise approach and analysis to, in part, establish a region of influence (ROI) for the EA. The deliverable will include a sonic boom approach and analysis that will be approved by the FAA.

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Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A4 of A24
All Rights Reserved. UNCLASSIFIED 30 September 2025
Task 2.1 Development and FAA Approval of Concept Y RLV Noise Methodology The contractor Team will develop and coordinate the noise and sonic boom methodology with the FAA Office of Commercial Space Transportation (AST) and the Office of Environment and Energy (AEE). The methodology will include the noise and sonic boom data inputs. The Consultant will develop a brief letter and technical memorandum requesting FAA-AST and AEE’s approval of the noise and sonic boom methodology. The FAA-AEE approval letter of the noise and sonic boom methodology will be included as an appendix to the EA.

Task 2.2 Concept Y RLV Noise Modeling
With the FAA’s approval of the noise methodology (Task 2.1), a complete noise analysis will use a fixed set of noise metrics, in compliance with FAA Order 1050.1G, to evaluate impacts on a cumulative event basis. Cumulative impacts are evaluated using Day-Night Level (DNL) contours to determine if the Concept Y RLV operations would cause an increase in noise of DNL 1.5 dBA or more at or above DNL 65 dBA noise exposure when compared to the baseline. GIS contour files and noise contour graphics will be developed.

Task 2.3 Concept Y, Concept Z, and Expendable Launch Sonic Boom Analysis The FAA AEE has approved a number of models for detailed noise analysis. The contractor Team will use the latest version of PCBoom or other FAA accepted noise modelling methods to calculate the location and magnitude of sonic boom overpressures on the ground due to supersonic flight and commercial space operations. The model considers the effects of the atmosphere, vehicle shape and velocity, and altitude to accurately predict the intensity and propagation of the sonic booms resulting from supersonic flight.

The contractor’s team will develop a sonic boom methodology, collect launch vehicle data, and conduct the analyses for FAA review and approval. The contractor’s team will coordinate with the City and the FAA on the launch vehicle’s characteristics to be used in the PCBoom or other model. These data include size, weight, shape, speed, and trajectory of the vehicle. The contractor Team will also collect atmospheric data from NOAA. The contractor’s team will develop sonic boom analysis for up to two (2) return trajectories for each RLV (four (4) return trajectories in total) and one launch trajectory for an expendable orbital and suborbital launch over the Pacific Ocean. For the Concept Y and Z RLVs, it is assumed there will be largely similar gliding return tracks, and it is anticipated that one (1) return trajectory will be from the southerly direction and one (1) return trajectory will be from the northerly direction. The results of the analysis will show one departure flight track to the northerly direction, two approaching flight tracks, one each suborbital and orbital expendable launches over the ocean, and noise contours showing differing levels of pounds per square foot (psf). The psf contours >1.0 will be shown on an aerial map (e.g., Google maps).

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Task 2.4 Establish a Region of Influence (ROI)
Using the results from Tasks 2.3 and 2.4, the contractor Team will establish and qualitatively describe a ROI to be used in the EA. The ROI will include the area potentially affected by the launch vehicle flight corridor established in the license application and the area of the sonic boom contours >1.0 psf.

Task 2.5 Sonic Boom Approach and Assessment
Using the data, analysis, and documentation from the tasks above, the contractor Team will develop a Sonic Boom Approach and Assessment report for the CIty and the FAA’s review and approval. The contractor Team will describe the noise metrics and criteria, sonic boom/aircraft noise and its effects, and the FAA’s guidance. The contractor Team will also describe the sonic boom/aircraft noise methodology, model inputs, and present the sonic boom/aircraft noise modeling results. The contractor Team will be responsible for preparation and distribution of the report, including text, tables, and exhibits. An electronic copy (.pdf) of the report will be sent to the City and FAA; no hard copies will be provided.

The City, FAA, and up to three (3) members of the contractor Team will participate in a 1-hour conference call summarizing the Sonic Boom Approach and Assessment report, establishment of the ROI, and the path forward developing the EA. The contractor Team will acquire the FAA’s concurrence about the ROI prior to continuing further with Task 2 and Task 3.

TASK 3 AFFECTED ENVIRONMENT
The contractor Team will document the existing environmental conditions. The contractor Team will develop study areas used throughout the EA (direct (i.e., physical construction/development on Airport property), ROI (noise and sonic boom described in Task 2.4), and area of potential effect (APE) (historic and archaeological resources; a combined direct study area and ROI)).

These study areas will be presented on base maps using a geographic information system (GIS) and provided to the City and FAA for review and comment.

The description of existing conditions will describe the 2025 conditions for all environmental impact categories identified in FAA Order 1050.1G. The contractor Team will rely primarily on the data in previous studies and other materials already prepared for the City and will supplement and update that data as appropriate. The contractor will independently verify data to be used that the contractor does not collect.

The contractor will also conduct quality control and quality assurance reviews of all subcontractor reports before submittal to the City and/or FAA.

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Task 3.1 Air Quality
The portion of San Luis Obispo County (County), where the Airport is located, has been designated by the U.S. Environmental Protection Agency (USEPA) as in attainment for all criteria air pollutants. A complete description of the air quality environment will be provided in the EA.

Task 3.2 Biological Resources
Using information provided by the City, the contractor Team will describe existing conditions regarding biological resources within the direct study area. This will include narrative accounts and maps of the biological resources with attention to special status species and their habitats.

Any special status species listed under the Endangered Species Act or critical habitat designated within the project study area will be identified and described.

Task 3.3 Coastal Resources
The contractor Team will confirm that no coastal resources exist in the vicinity of the direct study area and that no further analysis is required.

Task 3.4 Department of Transportation, Section 4(f)
The contractor Team will identify any publicly owned park, recreation area, wildlife refuge, or historic site (using the information developed for Task 3.7) within the ROI. Additionally, properties having received Land and Water Conservation Funds under Section 6(f) from the Department of the Interior will be identified within the ROI. Section 4(f) and Section 6(f) properties within the ROI will be shown on a GIS base map.

Task 3.5 Farmlands
The contractor Team will confirm that no prime or unique farmlands exist in the vicinity of the direct study area and that no further analysis is required.

Task 3.6 Hazardous Materials, Solid Waste, and Pollution Prevention The contractor Team will summarize the affected environment for hazardous materials, solid waste, and pollution prevention based on the Phase 1 Environmental Site Assessments and other hazardous materials studies provided by the City.

The contractor Team will also identify local waste disposal facilities and summarize the local disposal capacities for solid and hazardous waste.

Existing pollution prevention plans or programs at the Airport will be summarized, including those applicable to project construction and operation.

Task 3.7 Historical, Architectural, Archaeological, and Cultural Resources The contractor Team will conduct a records search and a site reconnaissance to describe any Attachment 7

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potential cultural resources in the Area of Potential Effect (APE), which will be the same as the direct study area and ROI.

Task 3.8 Land Use
The contractor Team will review relevant data and plans such as local zoning plans, land-use plans, and political jurisdiction plans, among others to prepare a narrative describing the existing local land uses and planned and future land uses in the ROI. The ROI land uses will be mapped using existing local land use planning GIS data.

Task 3.9 Natural Resources and Energy Supply
The contractor Team will gather relevant data and describe the existing utilities used at the Airport including power, sewage, fuel, natural gas, and water. Additionally, utilities and resources required during construction will be identified such as asphalt, water, fuel, and aggregate and where the suppliers are located.

Task 3.10 Noise and Noise-Compatible Land Use
The contractor Team will use the results from Task 2 and the information collected in Task 3.8.

The contractor Team will describe the noise-sensitive land uses in the ROI.

Task 3.11 Socioeconomics and Children’s Environmental Health and Safety Risks Task 3.11.1 Socioeconomics (including Surface Traffic)
The contractor Team will gather relevant data related to socioeconomics within the ROI and will provide a narrative that describes the existing population levels, employment rates, housing occupancy rates, and surface traffic routes.

Task 3.11.2 Children’s Environmental Health and Safety Risks The contractor Team will gather relevant data related to children’s environmental health and safety risks within the general study area and will provide a narrative that describes the existing population grouped by age range and the number of schools, day cares, parks, and children’s health centers.

Task 3.12 Visual Effects
Task 3.12.1 Light Emissions
The contractor Team will describe the existing sources of light emissions from the Airport.

Task 3.12.2 Visual Resources and Visual Character
The contractor Team will describe the existing visual environment of the Airport.

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Task 3.13 Water Resources
Task 3.13.1 Wetlands
Using information provided by the City and the National Wetlands Inventory (NWI), the contractor Team will identify any wetlands within the direct study area.

Task 3.13.2 Floodplains
The contractor Team will identify any regulated 100-year floodplains located within the direct study area using the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) and will provide a narrative that describes existing 100-year floodplain conditions within the direct study area. If regulated 100-year floodplains are located within the direct study area, they will be mapped on a GIS base map.

Task 3.13.3 Surface Waters
The contractor Team will review and document existing surface water quality conditions in the direct study area. The contractor Team will summarize the governing regulations related to water quality in the direct study area including state and federal regulations and existing surface water quality permits that apply to activities in the direct study area.

Task 3.13.4 Groundwater
The contractor Team will review and document existing groundwater quality conditions in the direct study area. The contractor Team will summarize the governing regulations related to groundwater quality in the direct study area and existing water quality permits that apply to activities in the direct study area.

Task 3.13.5 Wild and Scenic Rivers
The contractor Team will confirm that no wild and scenic rivers exist in the vicinity of the direct study area and that no further analysis is required.

Task 3.14 Reasonably Foreseeable Projects
This task identifies and describes reasonably foreseeable actions that, when considered in combination with the Proposed Action, could contribute to potentially significant impacts.

Projects included in this task will represent those undertaken or regulated by the Airport or within a one-mile radius from the Airport.

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TASK 4 ENVIRONMENTAL CONSEQUENCES
This task involves summarizing the potential impacts on environmental resources resulting from the No Action Alternative, Proposed Action, and, if appropriate, reasonable alternatives. The possible categories of impacts are based on FAA Order 1050.1G. The contractor shall use the Order to determine if the No Action Alternative, Proposed Action, and, if appropriate, reasonable alternatives:
» would cause any significant impacts (directly, indirectly, or in combination with other development in the area); or
» the mitigation actions that might be required to avoid or lessen identified impacts below the level of significance FAA has established for each resource category.

The contractor Team shall use the methodologies that FAA (and other review agencies, if involved) has reviewed and that are applicable for the impact categories evaluated in completing this task. For the most part, FAA Order 1050.1G provides those instructions and how they relate to the project.

The contractor Team shall analyze and discuss only those impact categories and issues that are key to the decision-making process for this project. The contractor Team shall dismiss those environmental categories that the No Action Alternative, Proposed Action, and, if appropriate, reasonable alternatives would not affect by providing sufficient discussion to substantiate a lack of impacts. This is acceptable because those categories would not directly affect the overall decision-making process for the Proposed Action.

The temporary impacts relating to construction activities shall be investigated for each applicable environmental category (e.g., air quality, noise, traffic, solid waste, water resources).

Specific attention shall be devoted to construction impacts on soil disposal and borrow areas, transportation of materials, haul routes, noise and erosion control, as needed.

As the contractor Team determines the environmental consequences during this task, coordination with the appropriate reviewing agencies will occur as needed. The coordination shall occur primarily via email or letter correspondence but may also include telephone communications and limited meetings.

A qualitative discussion of the potential consequences of reasonably foreseeable actions will be provided.

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Task 4.1 Air Quality
The Airport is currently in an area designated by USEPA as in attainment for all criteria air pollutants. As a result, the focus of this analysis will be on construction-related air pollutant emissions only. The proposal does not include operational air emission impacts. At this time, the contractor Team does not anticipate that the Proposed Action and reasonable alternatives would substantially change the air pollutant emissions associated with the operation of the Airport. This is because none of those actions would substantially change the airport’s operational or vehicular traffic levels. Those levels would occur with or without the Proposed Action. If operational impacts are required, the contractor Team can prepare a scope of work and cost estimate to include such activities.

The contractor Team will prepare a construction emissions inventory to demonstrate that the emissions from such activities would not result in the potential for pollutant concentrations to exceed the National Ambient Air Quality Standards (NAAQS). The contractor Team will calculate the air pollutant emissions related to the construction of the Proposed Action using the MOVES air quality model. The information will be used in the MOVES model to determine air pollutant emissions related to construction activities. Information regarding the equipment utilization, activity level, and timing information for the construction projects that will be required to perform these calculations will be supplied as part of the project description. Construction emissions will be calculated for the worst-case day of construction for each component of the project. Overall, construction emissions include, but are not limited to, estimation of construction type; materials used; number, type, duration, and intensity of construction equipment usage; vehicle miles traveled; ambient meteorological conditions; fuel type used; and anticipated quantity of materials consumed. It is not anticipated that the construction of the Proposed Action would result in a de minimis exceedance.

Because the project is in an area designated by USEPA as attainment, no General Conformity determination will need to be made. However, for transparency, construction emissions will be compared to the USEPA de minimis levels to demonstrate that emissions will not exceed the NAAQS. This scope assumes that construction emissions will be below de minimis levels and no further analysis will be necessary. A separate scope of work and cost estimate will be provided if net emissions are above de minimis levels.

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Task 4.2 Biological Resources
The contractor Team will analyze the extent to which terrestrial biological resources would be affected by the Proposed Action and any reasonable alternatives compared against the No Action Alternative. Terrestrial biological resources include species listed as threatened or endangered under the Endangered Species Act and/or stated protected species, native plant species, and common vegetation and wildlife. The contractor Team assumes that because the direct study area is already disturbed by Airport activities, no endangered or threatened species occur in the direct study area, and that no further analysis or Endangered Species Act consultation is required.

Task 4.3 Department of Transportation, Section 4(f)
The contractor Team will evaluate any Section 4(f) identified properties where physical or constructive use could occur. The contractor Team will use the requirements in FAA Order 1050.1G to assess whether properties may be affected and the level of physical use or constructive use on the property. If there is “use” of the affected Section 4(f) property, the contractor Team will identify mitigation measures that will result in a reduction in the impact to the Section 4(f) property. The FAA can make a de minimis impact determination in regard to physical use of the property, after taking into account measures to minimize harm that result in no adverse effect to the property. If the FAA cannot make a de minimis impact determination, then a Section 4(f) evaluation must be prepared and included as part of the EA review process.

This evaluation must determine if there is a feasible and prudent alternative that avoids “use” of the Section 4(f) property. In order for the FAA to approve use of Section 4(f) property, the Section 4(f) evaluation must conclude the required finding that there are no feasible and prudent alternatives that avoids use of the property and the project includes all possible planning to minimize harm resulting from the use. As part of this review, the contractor Team also will determine if any Section 4(f) property that is being affected by the Proposed Action and any reasonable alternatives has received any Land and Water Conservation Funds under Section 6(f) from the Department of the Interior. If the property did receive any such funds, the contractor Team will work with the FAA to complete applicable Section 6(f) requirements under additional scope and fee.

Task 4.4 Hazardous Materials, Solid Waste, and Pollution Prevention On the basis of previous hazardous materials studies provided by Airport staff, the contractor Team will discuss the impacts to hazards and hazardous materials that would occur as a result of the implementation of the Proposed Action and any reasonable alternatives. The contractor Team will incorporate the results, conclusions, and recommendations contained in hazardous materials studies into the EA, including any applicable mitigation measures.

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The contractor Team will identify types and quantities of solid waste that would be generated by the implementation of the Proposed Action and reasonable alternatives, and describe how the solid waste would be stored, managed, and disposed.

The contractor Team will describe pollution prevention activities, plans, programs, or policies that would be undertaken during construction and operation to avoid, prevent, or reduce pollutant discharges or emissions, potential for accidental discharges, and methods to control spills and any other unauthorized releases.

The contractor Team will evaluate impacts based on the consideration of the following factors:
potential to violate applicable federal, state, tribal, or local laws or regulations regarding hazardous materials and/or solid waste management; involve a contaminated site; produce an appreciably different quantity or type of solid or hazardous waste; exceed local disposal capacity; or adversely affect human health or the environment.

Task 4.5 Historical, Architectural, Archaeological, and Cultural Resources The contractor Team will evaluate the potential impacts associated with the Proposed Action and reasonable alternatives on these resources by using the existing City/Airport documents shared with the contractor Team. The contractor Team will summarize the research previously conducted and the results of the agency consultation into the EA.

Task 4.6 Land Use
The contractor Team will analyze the consistency of the Proposed Action and reasonable alternatives with local adopted plans and policies, including the City of Paso Robles General Plan, the local zoning ordinances. This section will determine if there are any compatibility issues from the development of the Proposed Action and alternatives based on existing and future planned uses. This section will also include discussion of the required airport sponsor land use assurance letter.

Task 4.7 Natural Resources and Energy Supply
The contractor Team will disclose any changes in energy consumption that would occur as a result of the Proposed Action and reasonable alternatives, including energy consumption that will occur during construction. The impacts to existing utility providers servicing the area such as electricity, water and sewage would be evaluated based on the changes from the Proposed Action and reasonable alternatives.

Using information provided by Airport staff, the contractor Team will discuss the sustainable practices that are currently used by the City or that the City would employ and how the Proposed Action would be implemented in accordance with the City’s sustainability practices.

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Task 4.8 Noise and Noise-Compatible Land Use
Using the results from Task 2, the contractor Team will overlay the DNL 65, 70, and 75 dB noise contour sets over an aerial base map. Seven graphics will result: (1) Existing Conditions DNL, (2) No Action build out year DNL contours displayed over land use, (3) Proposed Action (Concept Y RLV) build out year DNL contours displayed over land use, (4) Proposed Action (Concept Z) build out year DNL contours displayed over land use, (5) No Action build out plus five years DNL contours displayed over land use, and (6) Proposed Action (Concept Y RLV) build out plus five years DNL contours displayed over land use, and (7) Proposed Action (Concept Z RLV) build out plus five years DNL contours displayed over land use. Per FAA Order 1050.1G, the contractor Team will determine and report all noise-sensitive parcels (residences, schools, places of worship, etc.) that experience an increase of 1.5 dB or greater increase within the 65 DNL contour with the Proposed Action as compared to the No Action. In addition, the contractor Team will determine and describe all noise-sensitive parcels that moved into higher 5-dB contour bands between the 65- and 75-dB contours.

Task 4.9 Socioeconomics and Children’s Environmental Health and Safety Risks Task 4.9.1 Socioeconomics (including Surface Traffic)
The contractor Team will identify and disclose any potential impacts as a result of the Proposed Action and reasonable alternatives on population exposure.

The contractor Team will identify the impacts associated with temporary changes in traffic patterns in a study area developed specifically for traffic.

Task 4.9.2 Children’s Environmental Health and Safety Risks The contractor Team will identify and disclose any potential impacts as a result of the Proposed Action and reasonable alternatives on the population of children and children’s facilities.

Task 4.10 Visual Effects
Task 4.10.1 Light Emissions
The contractor Team will describe the extent to which any lighting associated with the Proposed Action and reasonable alternatives would create an annoyance for people in the vicinity of the Airport or interfere with their normal activities. This analysis will include an assessment of changes in the night sky that could occur as a result of the Proposed Action and each reasonable alternative.

Task 4.10.2 Visual Resources and Visual Character
The contractor Team will describe the change in visual resources and visual character that would occur with the Proposed Action and reasonable alternatives and propose mitigation measures to reduce these impacts, if needed.

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Task 4.11 Water Resources
Task 4.11.1 Wetlands
The contractor Team will analyze the extent to which wetlands would be affected during the construction phases of the Proposed Action and reasonable alternatives compared against the No Action Alternative.

Task 4.11.2 Floodplains
The contractor Team will disclose any regulated 100-year floodplains within the direct study area and identify any potential impacts from encroachment or alteration of the floodplains as a result of the Proposed Action and reasonable alternatives. If encroachment or alteration occurs, the contractor Team will estimate the volume of encroachment based on the footprint of the Proposed Action and reasonable alternatives. The contractor Team will review and outline potential mitigation opportunities for any unavoidable impacts identified for the Proposed Action and reasonable alternatives. For purposes of this scope of services, a Conditional Letter of Map Revision (CLOMR) is not expected to be submitted to FEMA for the Proposed Action or any reasonable alternative.

Task 4.11.3 Surface Waters
The contractor Team will identify the potential impacts to water quality associated with the Proposed Action and reasonable alternatives. The contractor Team will review the potential impacts to water quality from stormwater runoff. For normal rain events, the contractor Team will review potential impacts of the Proposed Action and reasonable alternatives with regard to the conventional pollutants that can exist in normal runoff from paved surfaces. These will be reviewed in reference to the existing water quality permits that regulate these types of discharges in the project study area and the benchmarks that have been established to protect adjacent surface waters. In addition, the contractor Team will review potential impacts associated with stormwater runoff from construction activities. The contractor Team will review the various mitigation methods available for minimizing the potential impacts to water quality from the Proposed Action and reasonable alternatives and determine if any changes to existing NPDES permits will be required.

The contractor Team will calculate and compare pre- and post-development stormwater runoff quantities using applicable rainfall data and design methods. The contractor Team will recommend Best Management Practices (BMPs) to mitigate any increase in stormwater runoff as a result of the Proposed Action and reasonable alternatives. For the purposes of this scope of services, the analysis will be limited to the Proposed Action and reasonable alternatives.

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Task 4.11.4 Groundwater
The contractor Team will analyze potential impacts from the Proposed Action and reasonable alternatives on groundwater recharge and supply and if it would affect public health. The contractor Team will also analyze if the Proposed Action and reasonable alternatives would cause groundwater quality to exceed federal, state, and/or local standards.

Task 4.12 Reasonably Foreseeable Actions
The contractor Team will qualitatively describe the effects of reasonably foreseeable development at the Airport in combination with those project-related potential impacts.

TASK 5 OTHER EA SECTIONS
The following sections of the EA shall be prepared as required by the FAA: List of Preparers, References, and all necessary appendices. The contractor Team shall also prepare and provide an Agency and Public Involvement section in the EA that briefly: 1) describes the federal, state and local coordination efforts; 2) describes the agency and public involvement program; and 3) provides key correspondence either directly or by referencing an appendix (see Task 6 for further details).

TASK 6 AGENCY AND PUBLIC MEETINGS
This task describes the EA’s initial public and agency outreach.

Task 6.1 Key Stakeholder List
contractor will request contact names and information from the City for those key stakeholders for the project and create a Key Stakeholder List. In addition, the list will be updated throughout the process to include agencies, organizations, and members of the general public who express a desire to be added to the database.

Task 6.2 Project Website
A project website will be developed to provide applicable information to the public about the EA. contractor will provide information to the City for uploading to their website regarding the public scoping, the release of the Draft EA and workshop, opportunities to participate and comment, the Final EA, and FAA’s environmental determination. The contractor will provide Americans with Disabilities Act (ADA or 508-compliant) EA content for publication on the City’s website as needed.

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Task 6.3 Draft EA Public Workshop
Task 6.3.1 Approach and Arrange Logistics for Public Workshop The contractor will provide all coordination, logistics, and facilitate a public workshop during the 30-day comment period on the Draft EA. The public workshop will occur during evening hours to maximize attendance by the general public and will be up to two (2) hours in duration.

It is assumed that the public workshop will be held at the City. The contractor will be responsible for the preparation and publication of the notice of the public workshop in one (1) local newspaper at least 30 days before the public workshop.

Task 6.3.2 Meeting Materials for Public Workshop
The contractor will prepare meeting materials for the public workshop. These materials include sign-in sheets, fact sheets, informational display boards, and comment sheets, will be provided to the City and FAA for approval before production of the materials.

Task 6.3.3 Attendance at Public Workshop
The contractor will facilitate a public workshop for the Draft EA. The workshop will be held in an open-house format, allowing the public to explore various stations and learn about the project's associated issues. The public can view informational displays explaining the process and identifying the issues to be studied (at different stations), ask City staff and The contractor Team members questions, and provide written comments. A court reporter will be provided to record all public comments made during the public workshop.

TASK 7 NEPA DOCUMENTATION
The contractor will prepare, print, and distribute the various stages of EA documents. The following sections of the EA shall be prepared. These include:
» Chapter 1 – Introduction
» Chapter 2 – Purpose and Need
» Chapter 3 – Proposed Action and Alternatives
» Chapter 4 – Affected Environment
» Chapter 5 – Environmental Consequences
» Chapter 6 – Public Involvement and Agency Consultation » Chapter 7 – References
» Chapter 8 – List of Preparers
» Appendices (as appropriate)
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Task 7.1 Preliminary Draft EA
This task includes document preparation, word processing, graphics preparation, and quality management of up to four (4) Preliminary Draft EAs (PDEA). The PDEA will be organized in a format consistent with FAA Order 1050.1G. The contractor will document the results of the project coordination and analyses in the PDEA version 1 document to be submitted to the City and FAA for review and approval (production of hardcopies is not proposed for this deliverable).

If the FAA requires additional versions of the Preliminary Draft EA for review and comment, additional scope and fee will need to be negotiated between The contractor and the City.

Task 7.2 Draft EA
Written comments from the City and the FAA on the PDEA version 4 will be incorporated into a Draft EA document. This task includes document preparation, word processing, graphics preparation, and quality management. The contractor will print up to ten (10) hard copies of the Draft EA.

Additionally, the contractor will provide an electronic Section 508-compliant version of the Draft EA. For the electronic version, the contractor will convert text, tables, and graphics of the Draft EA document into Adobe Acrobat (.pdf) files. The document may be divided into separate files for each chapter if the files are large, so they are more useful for posting the files on the City’s website if desired.

The contractor will prepare a draft distribution letter for FAA’s approval. The contractor will be responsible for reproducing and distributing the letter and Draft EA. The contractor will prepare a newspaper Notice of Availability for the EA, which will be provided to the City for publication in a local newspaper.

Task 7.3 Preliminary Final EA
This task includes document preparation, word processing, graphics preparation, and quality management of up to three (3) Preliminary Final EA (PFEA). The contractor Team will revise the Draft EA into a PFEA document to be submitted to the City and the FAA for review and approval (production of hardcopies is not proposed for this deliverable).

If the FAA requires additional versions of the Preliminary Final EA for review and comment, additional scope and fee will need to be negotiated between the contractor and the City.

Task 7.4 Final EA
The City and FAA comments on the PFEA version 3 will be incorporated into a Final EA document. This task includes the technical specialist document preparation, word processing, graphics preparation, and quality management. The contractor will print up to ten (10) hard copies of the Final EA.

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Additionally, the contractor will provide an electronic ADA Section 508-compliant version of the Final EA. For the electronic version, the contractor will convert text, tables and graphics of the Final EA document into Adobe Acrobat (.pdf) files. The document may be divided into separate files for each chapter if the files are large, so they are more useful to posting the files on the City’s web site, if desired.

III CEQA SCOPE OF SERVICES
Tasks 8 through 10 are the scope of services associated with preparing the EIR for the Proposed Action pursuant to CEQA rules and conventions.

TASK 8 PREPARE NOTICE OF PREPARATION (NOP)
Using the City’s standard format for an NOP, the contractor will prepare a draft NOP for City review and comment. Upon receipt of City comments on the draft NOP, the contractor will prepare a final NOP for publication. The following environmental resource categories will be dismissed as part of the NOP:
» Agricultural and Forestry Resources
» Energy
» Geology and Soils
» Mineral Resources
» Population / Housing
» Public Facilities
» Recreation
» Utilities and Service Systems
» Wildfire
Once the NOP has been posted to the State Clearinghouse website, CEQA Submit, a 30-day scoping period begins. It is assumed that a public scoping meeting will not be required.

TASK 9 PREPARE EXISTING CONDITIONS, ENVIROMENTAL IMPACTS, AND

MITIGATION
Using information associated with Task 3, the contractor will document the existing conditions for the proposed project site. The contractor will rely on data contained in previous studies and other materials already prepared by the City, where applicable, and will supplement and update that data, as appropriate.

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Task 9.1 Aesthetics
Using the analysis prepared for Task 4.10, the contractor will evaluate and describe the extent to which the Proposed Project would have a substantial adverse effect on a scenic vista or create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

Task 9.2 Air Quality
Using the analysis prepared for Task 4.1, the contractor will evaluate and describe if the Proposed Project would conflict with or obstruct implementation of the applicable air quality plan; result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment; expose sensitive receptors to substantial pollutant concentrations; or result in other emissions adversely affecting a substantial number of people.

Task 9.3 Biological Resources
Using the analysis prepared for Task 4.2, the contractor will evaluate and describe the extent to which the Proposed Project would have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service; have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or US Fish and Wildlife Service; have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means, interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites; conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance; or conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

Task 9.4 Cultural and Tribal Cultural Resources
The contractor will prepare a draft letter for the City to initiate Assembly Bill (AB) 52 consultation with Native American tribes who have indicated that they would like to be notified of projects within San Luis Obispo County.

Using the analysis prepared for Task 4.5, the contractor will evaluate and describe the likelihood of encountering and/or disturbing archaeological and tribal resources during construction of the Proposed Project. A summary of the outcome of AB 52 consultation will be included.

Attachment 7

Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A20 of A24
All Rights Reserved. UNCLASSIFIED 30 September 2025
Task 9.5 Greenhouse Gas Emissions
Using the analysis prepared for Task 4.1, the contractor will evaluate and describe if the Proposed Project would generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment, or would conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. .

Task 9.6 Hazards and Hazardous Materials
Using the analysis prepared for Task 4.4, the contractor will to describe if the Proposed Project would create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment; emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school; be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the Environment; or result in a safety hazard for people residing or working in the project area; impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.

Task 9.7 Hydrology and Water Quality
Using the analyses prepared for Tasks 4.11.2, 4.11.3, and 4.11.4, the contractor will evaluate whether the Proposed Project would violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality, substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin; substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or through the addition of impervious surfaces, in a manner which would result in a substantial erosion or siltation on- or off-site, substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site, or create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; impede or redirect flood flows; in flood hazard zones, risk release of pollutants due to project inundation, or conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Attachment 7

Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A21 of A24
All Rights Reserved. UNCLASSIFIED 30 September 2025
Task 9.8 Land Use and Planning
Using the analysis prepared for Task 4.6, the contractor will evaluate and describe the extent to which the Proposed Project would physically divide an established community or cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Task 9.9 Noise
Using the analysis prepared for Task 4.8, the contractor will evaluate and describe the extent to which the Proposed Project would generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; generate excessive ground-borne vibration or ground-borne noise levels; or expose people residing or working in the project area to excessive noise levels.

Task 9.10 Transportation
Using the analysis prepared for Task 4.9.1, the contractor will evaluate and describe the extent to which the Proposed Project would conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities; conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b); substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or result in inadequate emergency access.

Task 9.11 Mandatory Findings of Significance
On the basis of the analysis prepared for Tasks 9.1 through 9.10, the contractor will prepare the mandatory findings of significance.

Task 9.12 Alternatives
On the basis of the analysis contained prepared for Tasks 9.1 through 9.11, the contractor will identify the significant impacts that will occur with the implementation of the Proposed Project.

The contractor will use this list of impacts to develop a list of potential alternatives that will eliminate or minimize the magnitude of the identified impacts.

Attachment 7

Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A22 of A24
All Rights Reserved. UNCLASSIFIED 30 September 2025
TASK 10 CEQA DOCUMENTATION
Task 10.1 Prepare Administrative Draft EIR
The contractor will prepare and submit to the City an Administrative Draft EIR. R&H will conduct an internal QA/QC process prior to submittal. City staff will have 15 calendar days to review the Administrative Draft EIR.

Task 10.2 Prepare Screencheck Draft EIR
The contractor will prepare a Screencheck Draft EIR that incorporates all revisions identified during the review of the Administrative Draft EIR. The Screencheck Draft EIR will be the final document review by the City before publication of the Draft EIR. The Screencheck Draft EIR will be reviewed over the course of one day at City offices.

Task 10.3 Publish Draft EIR
Task 10.3.1Print and Distribute Draft EIR
The contractor will produce five paper copies and five electronic / jump drive / disc copies of the Draft EIR for distribution. The contractor will provide an electronic copy of the Draft EIR to the City to place on their website. The electronic Draft EIR will comply with the requirements of Section 508 of the Americans with Disabilities Act for electronic documents.

In addition, one hard copy of the Draft EIR will be placed at up to two local libraries, one hard copy at the City offices, and one hard copy at the Airport administrative offices.

Task 10.3.2Public Notice of Availability and Notice of Completion The contractor will prepare a Notice of Availability of the Draft EIR for City review and comment.

The contractor will publish this Notice of Availability in up to two local newspapers of general circulation and provide a copy to the City to place on their website.

The contractor will prepare the Notice of Completion and assist the City with submittal to the State Clearinghouse.

If translation services are required for any public notices, the City will be responsible for obtaining the services.

Task 10.4 Final EIR
Task 10.4.1Review Comments on Draft EIR and Prepare Administrative Final EIR Following a 30-day comment period in which the public workshop will occur, the contractor will collect, review, summarize, and respond to all agency and public comments.

Attachment 7

Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A23 of A24
All Rights Reserved. UNCLASSIFIED 30 September 2025
An Administrative Final EIR will be produced by the contractor for review and comment by the City. The format of the Administrative Draft EIR will include the full reproduction of the revised Draft EIR, a section on changes to the Draft EIR (the Addenda), and a chapter on comments and responses to comments. The number and type of comments received during the 30-day comment period will be summarized by the contractor. The contractor will submit an electronic version of the Administrative Final EIR to the City for review and comment. This will include a chapter (or an appendix) containing each comment letter and an appropriate response to that comment.

Task 10.4.2 Publish Final EIR
The contractor will produce 5 paper copies and 5 electronic / jump drive / disc copies of the Final EIR for distribution. The contractor will provide an electronic copy of the Final EIR to the City to place on their website. In addition, one hard copy of the Final EIR will be placed in up to two local libraries, one hard copy at the City offices, and one hard copy at the Airport administrative offices. An electronic copy will be submitted to the State Clearinghouse and submitted to the San Luis Obispo County Clerk.

Task 10.5 CEQA Findings
Task 10.5.1Prepare CEQA Findings
The contractor will prepare a draft of the CEQA Findings. One round of revisions by the Consultant based on comments from the City is assumed. This document will be submitted to the City in electronic format for final editing and use by the City Council in consideration of certifying the Final EIR.

Task 10.5.2Prepare Statement of Overriding Considerations Based on the assumption that a significant and unavoidable impact will be identified, the contractor will prepare a draft Statement of Overriding Considerations. This document will be submitted to the City in electronic format for final editing and use by the City Council in consideration of certifying the Final EIR. If no significant and unavoidable impacts are identified, this task will not be completed.

Task 10.5.3Prepare Mitigation Monitoring and Reporting Program (MMRP) Public Resources Code Section 21081.6 (a) (1) requires that a Mitigation Monitoring and Reporting Program (MMRP) be adopted at the time that the City determines to carry out a project for which an EIR has been prepared to ensure that mitigation measures identified in the Final EIR are fully implemented. The contractor will prepare a draft of the MMRP. This document will be submitted to the City in electronic format for final editing and use by the City Council in consideration of certifying the Final EIR.

Attachment 7

Appendix A PRB LSOL EA /CEQA – Scope of Service s
© 2025, RS&H, Inc. FINAL Page A24 of A24
All Rights Reserved. UNCLASSIFIED 30 September 2025
Task 10.5.4 Prepare Notice of Determination
In the event that the City Council certifies the Final EIR, the contractor will prepare a Notice of Determination (NOD) for the City to review and for the Consultant to submit to the State Clearinghouse. The City will file the NOD at the San Luis Obispo County Clerk’s Office.

Task 10.6 Public Meeting on the Draft EIR
One public meeting will be held in an open house format during the public review period of the Draft EIR. In an open house format, the public will arrive at any time during the specified event hours. At their own pace, the public will be able to view informational displays explaining the EIR process, learn about the issues associated with the Proposed Project, ask questions of City/Airport staff and the contractor staff, and provide written comments at the meeting. The contractor will facilitate these meetings. The location will be secured by the City. If translation services are required, the City will obtain these services. Up to four members of the the contractor Team will be present at the meeting.

IV PROJECT MANAGEMENT SCOPE OF SERVICES
Task 11 is the scope of services associated with managing the preparation of the EA and EIR for the Proposed Action.

TASK 11 PROJECT MANAGEMENT
The contractor will provide EA-specific and EIR-specific project management that will consist of maintenance and monitoring of the EA and EIR for the duration of the assignment. EA and EIR scope and budget adherence will be of primary concern as part of this task. The contractor Project Manager will use the following methods to ensure that the scope and budget adherence goals are met: project scope monitoring, project budget maintenance, direct client coordination (through telephone conversations, e-mail correspondence and meetings), quality management reviews, and general project documentation.

During the project duration, the contractor Project Manager will prepare for and attend up to four (4) in-person meetings at PRB to discuss the project status or other project-related needs.

This task also includes up to twenty-four (24) 1-hour teleconferences involving the Project Manager (supporting the LSOL Project Manager) with the City and/or FAA. # # # # #
Attachment 7

City of Paso Robles
1000 Spring Street
Paso Robles, California 93446
805.237.3877

REQUEST FOR PROPOSALS
Spaceport Consultant Services
Paso Robles Municipal Airport
Release Date: June 12, 2026
Deadline for Questions: July 3, 2026, before 5:00 p.m. Pacific Daylight Time Proposal Due Date: August 3, 2026, before 5:00 p.m. Pacific Daylight Time Attachment 8

TABLE OF CONTENTS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 1 City of Paso Robles, California (JUNE 12, 2026)

1. NOTICE OF REQUEST FOR PROPOSALS ...................................................................................................... 2

1.1. Purpose......................................................................................................................................... 2

1.2. Requirements................................................................................................................................ 3

1.3. Expected Timeline ......................................................................................................................... 3

1.4. Delivery of Proposals..................................................................................................................... 3

2. OVERVIEW OF THE OPPORTUNITY............................................................................................................ 4

2.1. Introduction.................................................................................................................................. 4

2.2. Description of Requested Services.................................................................................................. 4

2.3. Compliance with Legal Requirements............................................................................................. 6

2.4. Insurance Requirements................................................................................................................ 7

3. BACKGROUND INFORMATION.................................................................................................................. 8

3.1. Airport Sponsor............................................................................................................................. 8

3.2. Airport Geographic Locations......................................................................................................... 8

3.3. Airport Profile and Infrastructure................................................................................................... 9

3.4. Aircraft Operations...................................................................................................................... 10

3.5. Based Aircraft ............................................................................................................................. 10

3.6. Commercial Operators................................................................................................................. 10

4. PROPOSER INSTRUCTIONS .....................................................................................................................11

4.1. Introduction................................................................................................................................ 11

4.2. Investigation of Conditions and Circumstances............................................................................. 11

4.3. Preparation of Proposals............................................................................................................. 11

4.4. Questions.................................................................................................................................... 11

4.5. Anticipated Schedule................................................................................................................... 12

4.6. Delivery of Proposals................................................................................................................... 12

4.7. Withdrawal of Proposal ................................................................................................................ 13

4.8. Prohibition Against Lobbying......................................................................................................... 13

4.9. Contact with the City and Others.................................................................................................... 13

4.10. Discrimination............................................................................................................................. 13

4.11. Disqualification of Proposal and/or Rejection of Proposal............................................................. 13

4.12. Evaluation Criteria....................................................................................................................... 14

4.13. Evaluation Committee ................................................................................................................. 14

4.14. Interviews................................................................................................................................... 14

4.15. Additional or Supplemental Information ...................................................................................... 15

4.16. Selection and Negotiation............................................................................................................ 15

4.17. Award of Professional Services Agreement................................................................................... 15

4.18. Failure to Execute Agreement...................................................................................................... 15

4.19. Failure to Meet and/or Perform Related Obligations.................................................................... 15

4.20. Reservation of Rights................................................................................................................... 15

5. PROPOSAL CONTENT..............................................................................................................................17

5.1. Cover Letter ................................................................................................................................ 17

5.2. Executive Summary ..................................................................................................................... 17

5.3. Qualifications and Experience...................................................................................................... 17

5.4. Proposed Scope of Services.......................................................................................................... 18

5.5. Proposer Rates and Fee Schedule ................................................................................................. 18

5.6. Additional Information................................................................................................................ 18 Attachment 8

NOTICE OF REQUEST FOR PROPOSALS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 2 City of Paso Robles, California (JUNE 12, 2026)

1. NOTICE OF REQUEST FOR PROPOSALS

1.1. Purpose
The City of Paso Robles (City) is in the process of obtaining a Launch Site Operator License (LSOL) for the Paso Robles Municipal Airport (PRB or Airport), which is located within the City limits. The City has consulted with the Federal Aviation Administration’s (FAA) Office of Commercial Space Transportation (AST) regarding PRB becoming a licensed horizontal launch spaceport and has completed the Pre-Application process required under Code of Federal Regulations (CFR), Title 14, Part 420 of the FAA Commercial Space Transportation Regulations (Part 420).

In furtherance of this effort, the City is requesting proposals from qualified and experienced entities (Proposers) interested in providing spaceport licensing consulting services for PRB. The City is pursuing an FAA Part 420 LSOL (Part 420) to designate PRB as a horizontal launch spaceport. This effort has been underway for several years, and portions of the Part 420 license application have already received conditional approval from the FAA.

To date, the following documents have received conditional approvals from the FAA and are available to the selected proposer as part of this RFP, unless noted otherwise:
• Explosive Site Plan (available upon request)
• General Site Familiarization and Safety Training
• Ground Operations Safety Plan
• Mishap and Emergency Response Plan
• Public Access Control Plan
• Scheduling and Notifications Plan
• Scheduling and Notifications Procedure
• Spaceport Record Management Plan
• Spaceport Users Guide
The City needs to complete the final application packet for the Part 420 License including: (i) detailed operational assessments (i.e. flight safety and risk analysis); (ii) Letters of Agreement with the U.S. Coast Guard and FAA Air Traffic Organization (ATO) and other agencies as necessary; (iii) a review of the previously completed documents listed above; and (iv) environmental approvals (state and federal) as part of the licensing process and other incidental tasks associated with the Part 420 application.

The City desires to retain a qualified firm to complete the remaining elements of the Part 420 license application work on behalf of the City as detailed in Section 2. In general, the remaining items include, but are not limited to:
• Prepare for, and participate in, a Part 420 pre-application refresh meeting with FAA AST • Environmental review and compliance
• Launch site location review and hazard analysis
• Facilitating Letters of Agreement with the Coast Guard, FAA ATO, and other coordinating agencies Attachment 8

NOTICE OF REQUEST FOR PROPOSALS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 3 City of Paso Robles, California (JUNE 12, 2026)
• Airport Layout Plan update (pending completion through ongoing Airport Master Plan Process) • Review of previously completed application documents to ensure that they are current and compatible with the entire Part 420 application
• Finalize the Part 420 license application for submission to FAA AST • Coordination with local governmental bodies and stakeholder groups, including but not limited to Paso Robles City Council, Paso Robles Airport Commission, San Luis Obispo County Airport Land Use Commission, and tribal groups as necessary
• Other related consulting advisory services required to achieve full licensing.

1.2. Requirements
The ideal Proposer will demonstrate substantial qualifications and recent experience related specifically to Part 420 pre-application and application processing requirements and protocols as detailed in this RFP.

The following link provides access to the RFP and to subsequent addenda issued by the City:
https://www.prcity.com/Bids.aspx?CatID=17&txtSort=Category&showAllBids=on&Status=.

1.3. Expected Timeline
The table below details the anticipated schedule for this RFP process (which is subject to change):

RFP Schedule (subject to change)
Milestone Date
Issue date of RFP 6/12/2026
Optional Pre-Proposal Meeting and Site Visit (online option upon request) 1:00 PM at 4900 Wing Way, Paso Robles, CA 6/24/2026 Proposers’ Question Submission Deadline 7/3/2026
City’s Response Deadline for Answering Questions 7/15/2026 Proposal Submission Deadline 8/3/2026
Interviews (if necessary) 8/18/2026
Anticipated City Council Award 9/1/2026
Anticipated Project Start Date 10/1/2026

1.4. Delivery of Proposals
One digital copy of the proposal, including any additional supporting information, must be submitted electronically (in a PDF format) to Assistant City Manager David Malewitz via email to [email protected] prior to 5:00 p.m. Pacific Daylight Time (PDT) on August 3, 2026 (Proposal Submission Deadline) with a subject line stating “Proposal – Spaceport Consultant Services at Paso Robles Municipal Airport.” Email submissions must be confirmed by a returned email. Facsimiles will not be accepted. One hard copy of the proposal will also be delivered to David Malewitz postmarked prior to 5:00 p.m. PDT on August 3, 2026, at the Paso Robles City Hall, 1000 Spring Street, Paso Robles, CA 93446. Additional details pertaining to the delivery of proposals are outlined in Section 4.6 of this RFP.

Attachment 8

OVERVIEW OF THE OPPORTUNITY
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 4 City of Paso Robles, California (JUNE 12, 2026)

2. OVERVIEW OF THE OPPORTUNITY

2.1. Introduction
The City is requesting proposals from qualified and experienced Proposers interested in providing spaceport consulting services for the Airport with the goal of achieving a Part 420 Launch Site Operator License to designate PRB as a horizontal launch spaceport facility, as detailed herein.

2.2. Description of Requested Services

1. FAA pre-application consultation
o Coordinating with FAA AST and related stakeholders
o Update and incorporate existing Part 420 pre-application work product. o This has been done previously, but will need to be updated with the successful proposer.

2. Review, update as necessary, and incorporate all previously completed Part 420 information into an application based on the Paso Robles LSOL Scope of Work Evaluation document, Exhibit A.

Exhibit A is provided for background and gap-analysis purposes only and does not limit the Consultant’s obligation to prepare a complete and current Part 420 application unless expressly incorporated in the final Agreement.

3. Licensing Application Preparation
o Develop and finalize the Part 420 License Application (Application to Operate).

4. Outstanding Part 420 License Application items that need to be completed include, but are not limited to:
o (420.15(a)(2)(ii)) Id entification and description of launch site(s) layout(s) and launch point(s) o (420.15(a)(2)(iii)) Types of launch vehicles proposed at each launch point and associated Concept of Operations (CONOPS) for each vehicle type
o (420.15(a)(2)(iv)) Range of launch azimuths planned/proposed from each launch site o (420.15(c)) Launch Site Location Review – For vehicle-specific CONOPS o (420.19) General
o (420.21) Launch Site Boundary
o (420.23) Flight Corridor
o (420.25) Risk Analysis
o (420.27) Information Requirements
o (420.30) Launch Site Location Review for Permitted Launch Vehicles. o (420.59) Mishap Plan
o (420.61) Records and Record Keeping
o (420.31(a)) Develop and complete a Letter of Agreement (LOA) between the City and U.S.

Coast Guard Southwest District establishing procedures for launches o (420.31(b)) Develop and complete an LOA between the City and FAA Air Traffic Control (ATC) office having jurisdiction over the airspace through which launches will take place, establishing procedures for launches, including Part 77 Airspace analysis or similar as necessary.
o (420.71(a)) Lightning Protection
o Ensure that the public is not exposed to hazards due to the initiation of explosives by lightning.

Attachment 8

OVERVIEW OF THE OPPORTUNITY
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 5 City of Paso Robles, California (JUNE 12, 2026)

5. (420.15(b)) Environmental.
o The FAA is responsible for complying with the procedures and policies of the National Environmental Policy Act (NEPA), 42 U.S.C. § 4321 et seq., and other applicable Federal environmental laws, regulations, and Executive Orders prior to issuing a launch site license.

The City will be the lead agency for compliance with the California Environmental Quality Act (CEQA), Cal. Public Resources Code § 21000 et seq., and related California environmental requirements. Environmental compliance shall be accomplished in parallel with the application development process. (Per Paso Robles LSOL Scope of Work Evaluation, Exhibit A, Appendix A – Environmental Assessment Scope of Work) o Consultant shall complete all environmental compliance requirements as detailed in Part 420, including, but not necessarily limited to:
o Task 1 - Description of Proposed Action and Alternatives (DOPAA) o Task 2 - Operational Noise Impact Analysis, including Regions of Influence, and Mitigation Plan
o Task 3 - Affected Environment
o Task 4 - Environmental Consequences
o Task 5 - Other Environmental Assessment (EA) Sections as required by the FAA o Task 6 - Agency and Public/Stakeholder Meetings
o Task 7 – Prepare Required NEPA Documentation
o Task 8 - Prepare Notice of Preparation (NOP) as required under CEQA o Task 9 - Prepare Existing Conditions, Environmental Impacts, and Mitigation as required under CEQA
o Task 10 – Develop Required CEQA Documentation
o Task 11 - Project Management regarding NEPA and CEQA development

6. Completion of revisions to application documents as necessary - based on FAA review and comment.

7. Coordination with local advisory bodies as necessary and stakeholder groups, including the Paso Robles City Council, Paso Robles Airport Commission, tribal groups, and San Luis Obispo Airport Land Use Commission. Preferably onsite.

8. Deliverables:
• Complete project management, including but not limited to kick-off meeting, risk register, Part 420 Compliance Matrix, FAA/public/internal comment log, monthly progress reports, schedule/critical path updates, stakeholder coordination plan, draft submittal package, and final submittal package.
• Complete a compliant Part 420 License Pre-Application and Application package. • Complete the FAA Compliance Checklist, which is available online at the FAA AST website. • Complete/Finalize any and all required technical reports, e.g., Risk Analysis, Flight Corridor, Explosive Siting, airspace analysis, NOTAM coordination study/plan, and others as required for Part 420 application.
• Complete NEPA and CEQA documents (Preparation of environmental documentation as determined necessary by the applicable lead agencies, which may include an environmental assessment or environmental impact statement under NEPA and/or a mitigated negative declaration or environmental impact report under CEQA).

Attachment 8

OVERVIEW OF THE OPPORTUNITY
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 6 City of Paso Robles, California (JUNE 12, 2026)

9. Key Technical Requirements and Evaluation Criteria to Include:
• 14 CFR Part 420 Compliance
o Consultant shall demonstrate knowledge of and contemporary experience with federal requirements for launch site licensing.
• Prior Experience
o History of developing successful Part 420 spaceport license applications and related documents.
• Staff Expertise
o Qualifications of Consultant’s staff assigned to the project, including relevant experience with applicable spaceport licensing requirements, environmental review and compliance, launch vehicle types, and spaceport operations.
• Project Approach
o Consultant’s plan for early Part 420 pre-application consultation with stakeholders to streamline the process. (Even though an initial Part 420 pre-application consultation has been completed, the Consultant will need to have a plan to re-engage in consultation.) • Airspace Coordination
o Evaluation of spaceport operational impacts on FAA Air Traffic Control, the airspace surrounding PRB, and impacted airports.
• Safety Zone Modeling
o Modeling of risk areas, launch hazards, and potential accident scenarios. • Financial Responsibility
o Ability to develop guidance documents to determine the launch operator’s ability to meet insurance requirements for use of Spaceport infrastructure(Maximum Probable Loss).
• Technical Understanding
o Familiarity with the specific site hazards and proposed launch vehicles. • Environmental Team
o Expertise in NEPA and CEQA processes and compliance.
• Cost and Schedule
o Realistic, detailed timelines.

2.3. Compliance with Legal Requirements
Proposer shall comply with all federal, state, and local rules, regulations, laws, ordinances, statutes, or orders, including FAA requirements, federal grant assurances, and adopted airport plans.

Attachment 8

OVERVIEW OF THE OPPORTUNITY
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 7 City of Paso Robles, California (JUNE 12, 2026)

2.4. Insurance Requirements
A letter of commitment or certificate of insurance (COI) from an acceptable (authorized by the Insurance Commissioner to transact business of insurance or is on the List of Approved Surplus Line Insurers in the State of California with an assigned A.M. Best rating of A VIII [A:8]) insurance company setting forth the following types and amounts of insurance coverage, at a minimum, will be required at the time of commencement of the Agreement term: (The City must have the COI and all endorsements before the Professional Services Agreement is executed.)
⮚ Commercial General Liability - $1,000,000 per occurrence/$2,000,000 aggregate for bodily injury, personal injury, and property damage
⮚ Automobile Liability - $1,000,000 per occurrence for bodily injury and property damage ⮚ Employer’s Liability - $1,000,000 per occurrence
⮚ Professional Liability - $1,000,000 per claim and aggregate (errors and omissions) The City shall be named as additional insured, requires primary, non-contributing and waiver of subrogation coverage, and must have an indemnification agreement clause.

Attachment 8

BACKGROUND INFORMATION
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 8 City of Paso Robles, California (JUNE 12, 2026)

3. BACKGROUND INFORMATION

3.1. Airport Sponsor
The Airport is owned and operated by the City of Paso Robles and governed by the City of Paso Robles’ City Council.

3.2. Airport Geographic Locations
Figure 1 – Airport Geographic Locations
Attachment 8

BACKGROUND INFORMATION
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 9 City of Paso Robles, California (JUNE 12, 2026)

3.3. Airport Profile and Infrastructure
Table 1 – Airport Profile
Item Information
Airport Name Paso Robles Municipal Airport
FAA Airport Identifier PRB
City and State Paso Robles, California
Distance/Direction from CBD 4 miles Northeast of the Central Business District Airport Sponsor (Type) City of Paso Robles (City)
Airport Governing Body City of Paso Robles City Council Type of Airport Governing Body ☒Elected ☐Appointed
Airport Operator (Type) City of Paso Robles (City)
Service Level (NPIAS) ☐General Aviation Reliever ☒General Aviation Airport Role (NPIAS) ☐Basic ☒Local ☐Regional ☐National
Airport Reference Code (ARC) AAC: ☐A ☒B ☐C ☐D ☐E ADG: ☐I ☒II ☐III ☐IV ☐V RVR: ☐VIS ☐5000 ☐4000 ☐2400 ☐1800 ☐1200 ☒N/A
Market Segments Served Industry
☐Air Carrier ☒Military ☒General Aviation
General Aviation
☒Personal ☒Business ☐Commercial ☒Government
Air Traffic Control Tower ☐FAA ☐Contract ☒None
Acreage 1,300 acres
Table 2 – Airport Infrastructure
Airport Infrastructure Details
Runway 01/19
Length/Width 6,008’ x 150’
Weight Bearing Capacity S-60, D-106, ST-150
Runway Pavement/Condition Asphalt/Good
Taxiways (WBC and Width) Fair/50’
Precision Approaches None
Non-Precision Approaches 19: RNAV (GPS), VOR, VOR-B
Other Navigation Aids 19: 4-light PAPI on left (3.00 degrees glide path) Lighting 01/19: HIRL , 19: PAPI
Runway 13/31
Length/Width 4701’ x 100’
Weight Bearing Capacity S-30, D-50, ST-90
Runway Pavement/Condition Asphalt/Good
Taxiways (WBC and Width) Fair/50’
Precision Approaches None
Non-Precision Approaches 31: RNAV (GPS)
Other Navigation Aids 31: 4-light PAPI on left (3.00 degrees glide path) Lighting 13/31: MIRL, 31: PAPI
Attachment 8

BACKGROUND INFORMATION
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 10 City of Paso Robles, California (JUNE 12, 2026)
Heliport
Helipad H1 100 x 100 ft.

Surface Asphalt in Excellent Condition
Lighting Perimeter

3.4. Aircraft Operations
Airport does not have a tower, but based on ADS-B tracking, the City estimated 43,968 operations occurred in calendar year 2025.

3.5. Based Aircraft
Currently, 190 aircraft are based at the Airport, as reported to the FAA.

3.6. Commercial Operators
Loyds Aviation is the current provider of FBO products, services, and facilities, including fueling (jet and avgas), aircraft ground handling services, aircraft parking (hangar and tiedown), and aircraft maintenance.

Table 5 identifies additional providers of commercial and non-commercial aeronautical activities.

Table 5 – Providers of Commercial and Non-Commercial Aeronautical Activities Loyds Aviation FBO
Loyds Aircraft Maintenance Aircraft Maintenance
Air Paso Flight Services Flight Instruction, Aircraft Rental, Sightseeing Airport Rental & Leasing Lilly Hangars
Antique Aero Vintage Aircraft Mechanic
Avlite Corporation Aircraft lighting parts
CDF Air Attack Base Cal Fire
CHP Air Operations CHP station
Cooks Coastal Enterprises Pilot Examiner/flight simulator Del Rio Aviation Helicopter services
Estrella Warbirds Museum Museum
FAA-Airways Facility Sector FAA tech ops
Helicomm Avionics Shop
Nunno Corporation Hangars/metal buildings
Sinton Helicopters Helicopter Services

3.7 Attachments
(1) PRB Airport Layout Plan
(2) PRB Spaceport Test Sites
(3) PRB Introductory Letter
Attachment 8

PROPOSER INSTRUCTIONS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 11 City of Paso Robles, California (JUNE 12, 2026)

4. PROPOSER INSTRUCTIONS

4.1. Introduction
Proposer is responsible for undertaking such investigation as necessary to formulate the basis of its proposal and determine Proposer’s ability to comply with this RFP.

4.2. Investigation of Conditions and Circumstances
The submission of a proposal shall be considered conclusive evidence that the Proposer: (i) is thoroughly familiar with all terms, conditions, and provisions set forth in the RFP and all related materials, (ii) is fully qualified, experienced, and competent to successfully provide the required consultant services, (iii) has thoroughly investigated all aspects of and all related conditions or circumstances and has not relied on any information or other material conveyed in this RFP or otherwise provided by the City, and (iv) fully understands the conditions and/or circumstances that exist at the Airport, the community, and in the environment and airspace around the Airport.

The final agreement between the successful Proposer and the City will incorporate the successful Proposer’s proposal submitted in response to this RFP and all related materials, including all attachments, exhibits, etc.

Proposers shall conduct their own independent investigation and due diligence to make their own assessments, judgments, and decisions regarding this RFP.

4.3. Preparation of Proposals
Proposals must be complete, accurate, and free from ambiguity or irregularities of any kind. In case of conflict between words and numerals, the words, unless obviously incorrect, shall govern. Proposer is cautioned to verify and confirm all aspects of its proposal prior to submittal. No claim for adjustment shall be honored after the proposal has been submitted by the Proposer on the grounds that the Proposer was not fully informed and/or did not fully understand this document or any other documents or any related data, information, and other material. The City shall not, under any circumstances, be responsible for any costs or expenses associated with the proposal submitted, including research, investigation, development, preparation, duplication, production, collation, packaging, delivery, transmittal, or presentation of the proposal or any other related information and other material. All costs and expenses incurred by the Proposer in connection with the proposal submitted shall be the sole responsibility of the Proposer.

4.4. Questions
Any questions, comments, or requests concerning this RFP (and any of the attachments to this RFP) must be submitted in writing to David Malewitz, Assistant City Manager, via email to [email protected], prior to 5:00 p.m. PDT on July 3, 2026 (Proposer’s Question Submission Deadline). Proposers are strongly encouraged to submit questions, comments, or requests as early as possible in the process.

The City’s responses to questions, comments, or requests will be provided in the form of a written addendum to the RFP. Any addendum issued by the City will be provided via e-mail to all entities that have completed a request for receiving addenda.

Oral communications from the City or its representatives shall not be binding on the City and shall in no way modify any provision of the RFP document. Only written responses in the form of a written addendum to the RFP issued by the City shall be binding on the City.

All addenda must be acknowledged by Proposers in the proposal Cover Letter.

Attachment 8

PROPOSER INSTRUCTIONS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 12 City of Paso Robles, California (JUNE 12, 2026)

4.5. Anticipated Schedule
The anticipated schedule for this RFP process (which is subject to change) follows:

RFP Schedule (subject to change)
Milestone Date
Issue date of RFP 6/12/2026
Optional Pre-Proposal Meeting and Site Visit (online option upon request) 1:00 PM at 4900 Wing Way, Paso Robles, CA 6/24/2026 Proposers’ Question Submission Deadline 7/3/2026
City’s Response Deadline for Answering Questions 7/15/2026 Proposal Submission Deadline 8/3/2026
Interviews (if necessary) 8/18/2026
Anticipated City Council Award 9/1/2026
Anticipated Project Start Date 10/1/2026

4.6. Delivery of Proposals
One digital copy of the proposal and any additional supporting information must be submitted electronically (in a PDF format) to David Malewitz, Assistant City Manager, via email to [email protected] prior to 5:00 p.m.

PDT on August 3, 2026 (Proposal Submission Deadline) with a subject line stating “Proposal – Spaceport Consultant Services at Paso Robles Municipal Airport.” Email submissions must be confirmed by a returned email. Facsimiles will not be accepted. One hard copy of the proposal will also be delivered to David Malewitz postmarked prior to 5:00 p.m. PDT on August 3, 2026, at the Paso Robles City Hall, 1000 Spring Street, Paso Robles, CA 93446.

Proposers should anticipate the time required for email submissions to be received. As such, the proposal shall be submitted as early as possible to ensure receipt prior to 5:00 p.m. PDT on August 3, 2026 (Proposal Submission Deadline). The City is not responsible for delays in transmission or technical issues related to the submission of a proposal. Proposers’ internal networks may have limits on the size of email attachments. Therefore, it is incumbent on the Proposer to ensure the proposal can be transmitted by the Proposer’s network and accepted by the City network. If attachments exceed these limitations, the City will accept proposals in multiple emails, provided all applicable emails (and attachments) are received prior to 5:00 p.m. PDT on August 3, 2026 (Proposal Submission Deadline).

Under these circumstances, the respondent shall note in the email description that the proposal will be provided in multiple parts, and include the total number of components and which component of the total the attachment represents.Any proposal and all additional supporting information received after the Proposal Submission Deadline, regardless of the reason for the delay, will not be accepted and will be returned to the Proposer. Proposals must conform to the requirements stipulated in the RFP. By submitting a proposal, the Proposer agrees that the proposal represents a genuine interest in the opportunity at the Airport. Further, Proposer agrees that all materials submitted by Proposer in response to this RFP will become the property of the City and shall not be returned to the Proposer.

The City shall have the right to copy, disclose, publicize, and dispose of the proposal and all other material. In addition, the City shall be free to use as its own ideas, concepts, recommendations, techniques, or plans provided by the Proposer without obligation for compensation or liability of any kind.

Attachment 8

PROPOSER INSTRUCTIONS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 13 City of Paso Robles, California (JUNE 12, 2026)
The City is subject to the open record requirements of California law (California Public Records Act, Cal. Gov. Code § 7920.000 et seq.), and all materials submitted by Proposer to the City are subject to disclosure. All information given as part of any proposal will remain confidential only to the extent permitted by law and expressly agreed by the City in writing. Proposer specifically waives any claims against the City related to the disclosure of the proposal and any material submitted in response to a public records request.

The City’s Evaluation Committee will not disclose any part of any proposal before announcing a recommendation for award, and the City will not disclose any part of any proposal before announcing an award, on the grounds that there is a substantial public interest in not disclosing submittals during the evaluation process. After the announcement of a recommended award, all proposals received in response to this RFP will be subject to public disclosure. If the Proposer believes there are portions of the proposal that are exempt from disclosure under the California Public Records Act, the respondent must identify them as such and state the specific provision in the California Code that provides the exemption, as well as the factual basis for claiming the exemption.

4.7. Withdrawal of Proposal
Unless the Proposer makes a request for withdrawal in writing and the request is received by the City prior to the Proposal Submission Deadline, proposals may not be withdrawn for a period of 180 calendar days.

4.8. Prohibition Against Lobbying
Neither Proposer nor its representatives shall lobby, either on an individual or collective basis, either directly or indirectly, the City, its Council, employees, or advisors, or any federal, state, or local elected or public officials or staff members regarding this RFP or the Proposer’s anticipated or actual proposal. Neither Proposer nor its representatives shall contact the City, its Council, employees, or advisors, or any federal, state, or local elected or public officials or staff members or take any action to influence the outcome of the process. Violation of this provision, by or on behalf of a Proposer, intentionally or unintentionally, will result in disqualification of the Proposer and/or rejection of the proposal.

4.9. Contact with the City and Others
Except for submitting written questions concerning this RFP to David Malewitz, Assistant City Manager, which is specifically authorized by the City in this RFP, Proposers shall not contact the City, its Council, Airport Commission, employees, or advisors, or any federal, state, or local elected or public officials or staff members regarding this RFP.

Violation of this provision, by or on behalf of a Proposer, intentionally or unintentionally, shall be cause for disqualification of the Proposer and/or rejection of the proposal.

4.10. Discrimination
In its evaluation of proposals, the City shall not discriminate on the grounds of race, color, national origin, religion, sex (including pregnancy and gender identity), genetic information, age, disability, or sexual orientation.

4.11. Disqualification of Proposal and/or Rejection of Proposal A Proposer may be disqualified and/or a proposal may be rejected by the City for any of the following reasons:

1. Submission of proposal after the Proposal Submission Deadline;

2. Submission of more than one (1) proposal by any entity under the same or a different name;

3. Collusion among Proposers;

4. Existence of any unresolved claim between the Proposer and the City; Attachment 8

PROPOSER INSTRUCTIONS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 14 City of Paso Robles, California (JUNE 12, 2026)

5. Proposer (or the proposed operation) does not fully meet the qualifications, requirements, or standards, including, but not limited to, the Minimum Standards established by the City;

6. Proposer provides inaccurate, misleading, or false information or other material or misrepresents any material fact;

7. Proposer fails to make full disclosure;

8. Proposer (or an officer, director, agent, representative, shareholder, or employee of the Proposer) has a record of violating federal, state, or local regulatory measures, including, but not limited to those established by the FAA, the State of California, the City, or any other airport owner/operator;

9. Proposer (or an officer, director, agent, representative, shareholder, or employee of the Proposer) has defaulted in the performance of any agreement;

10. Proposer fails to demonstrate that it possesses adequate financial resources or that it can conduct the required services detailed herein;

11. Proposer (or an officer or director of the Proposer) has been convicted of a felony or a crime involving theft, fraud, or dishonesty;

12. Violation of any provision of this RFP, including Section 4.9 or 4.10 of this RFP;

13. Proposer cannot demonstrate its ability to obtain insurance as required by the City;

14. Proposer seeks terms and conditions which are inconsistent with this RFP and/or the policies and practices of the City.

4.12. Evaluation Criteria
Proposals will be evaluated based on a combination of qualifications, experience, technical approach, and cost.

Evaluation criteria will include: (1) the qualifications, relevant experience, and availability of the proposed project team and key personnel; (2) the firm's demonstrated experience successfully completing Part 420 PreApplication and related airport environmental planning projects; (3) the quality, responsiveness, and completeness of the proposed scope of services and project approach; (4) the firm's experience with environmental review, permitting, compliance, and coordination requirements applicable to airport development projects; (5) the reasonableness and competitiveness of the proposed fee and overall project cost; and (6) the overall quality, organization, and completeness of the proposal. The City reserves the right to consider the firm's demonstrated ability to successfully perform similar assignments and provide services in a timely, cost-effective, and professional manner.

4.13. Evaluation Committee
An Evaluation Committee, which may be comprised of City staff, Airport stakeholders, and other invited evaluators as determined by the City, will review and evaluate qualified proposals received based on the Evaluation Criteria identified in this RFP. After completing the evaluation process, the Evaluation Committee will select the proposal that best fulfills the City’s requirements and seek approval by the City Council to enter into negotiations with that institution to determine final pricing and enter into a contract.

4.14. Interviews
Proposers may be required to interview (by telephone, web-based meeting software, and/or in-person) with the Evaluation Committee and/or the City Manager, with date, time, and location to be determined.

Attachment 8

PROPOSER INSTRUCTIONS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 15 City of Paso Robles, California (JUNE 12, 2026)
Note: An interview and/or provision of additional information or other materials shall not be construed as an acceptance of the Proposer’s proposal.

4.15. Additional or Supplemental Information
Proposers may be required to provide additional or supplemental information or other material to the City.

The City has the right to conduct such investigations as the City considers appropriate with respect to the qualifications, experience, competencies, capacities, abilities, or reputation of the Proposer or the information or other material provided by the Proposer.

The City has the right to consider, in its evaluation and selection process, additional information or other material obtained from the Proposer or obtained by the City through its own independent investigation.

4.16. Selection and Negotiation
Upon approval by the City, the selected Proposer(s) shall receive notice of intent to award a Professional Services Agreement (Agreement) and negotiations will be initiated by the City. The City may negotiate with one or more Proposers before awarding an Agreement. The City may discontinue negotiations with any Proposer and/or withdraw any proposed Agreement at any time before the Agreement has been executed by both parties.

All Proposers will be notified in writing if selected or rejected for negotiation.

4.17. Award of Professional Services Agreement
Following agreeable negotiations, the Agreement will be executed and returned to the selected Proposer by the City. The Agreement will only be binding when executed by both parties. In the event of a conflict between the Agreement and the RFP or the Proposer’s proposal, the Agreement shall control or prevail. The City reserves the right to terminate negotiations at any time without liability, provided that the Agreement has not been executed by both parties.

4.18. Failure to Execute Agreement
If the selected Proposer refuses or fails to execute the Agreement, the Proposers understand and acknowledge that the City will incur costs and damages as a result of the selected Proposer’s refusal or failure to execute the Agreement and that such costs and damages are difficult to determine. Upon such refusal or failure to execute the Agreement, the City may accept the proposal of any other Proposer or withdraw the RFP and not proceed with this procurement.

4.19. Failure to Meet and/or Perform Related Obligations If the selected Proposer fails to meet and/or perform related obligations in a diligent and timely manner, the City may: (i) withdraw the notice of intent to award the agreement to the selected Proposer and issue a notice of intent to award the agreement to another Proposer, (ii) reject all proposals (i.e., not award the agreement to any Proposer), or (iii) take such other action as the City deems appropriate.

4.20. Reservation of Rights
The City reserves the right, in its sole discretion and without liability, to take any action it determines to be in the best interests of the City, including, but not limited to, the right to: withdraw, cancel, suspend, modify, or reissue this RFP, in whole or in part; amend the schedule or other terms of this RFP; reject any or all proposals; waive any minor irregularities, informalities, or defects in any proposal; request clarifications, revisions, additional information, or best and final offers from one or more Proposers; conduct interviews or decline to Attachment 8

PROPOSER INSTRUCTIONS
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 16 City of Paso Robles, California (JUNE 12, 2026)
conduct interviews; negotiate with one or more Proposers; award an Agreement to the Proposer determined by the City to best meet the City’s needs, which may not be the lowest-cost proposal; award all, part, or none of the services described in this RFP; divide or phase the scope of services; award separate agreements for different portions of the work; or elect not to proceed with the procurement or the project.

Issuance of this RFP does not obligate the City to award an Agreement, enter into negotiations, or pay any costs incurred by any Proposer in connection with the preparation or submission of a proposal, participation in interviews or negotiations, or any other activity related to this RFP. No proposal shall be binding on the City unless and until a final Agreement has been approved and executed by the City and the selected Proposer.

Attachment 8

PROPOSAL CONTENT
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 17 City of Paso Robles, California (JUNE 12, 2026)

5. PROPOSAL CONTENT
Proposals must be organized so that each element (identified in this section) is addressed in the order indicated. Proposers must answer all questions completely and accurately and furnish all required information and materials – failure to do so may result in disqualification of the Proposer and/or rejection of the proposal.

Proposals must be typewritten on 8½” by 11” paper using a universally legible font and a minimum 11-point type size. Proposals are limited to 35 pages exclusive of appendices or attachments.

5.1. Cover Letter
The Cover Letter must identify the legal name and business trade name (if different from the legal name) of the proposing entity or entities, as well as the Proposer’s primary office location, local office location, and contact information. The Proposal shall be signed by a representative authorized to make commitments and/or enter into agreements on behalf of the Proposer, along with the representative’s contact information. The Cover Letter shall include an acknowledgment of all addenda.

5.2. Executive Summary
The Executive Summary must summarize the key elements of the proposal in a clear and concise manner, including, but not necessarily limited to, the following:
⮚ Qualifications and experience of the Proposer as it relates specifically to Part 420 Launch Site Operator License requirements and approval processing/protocols at other airports. ⮚ Proposer's understanding of the objectives of the City as it relates specifically to the desired spaceport designation and operations at the Airport.
⮚ Project approach, including a synopsis of a proposed work plan and estimated time required for project completion.
⮚ Statement explaining why the Proposer is the most qualified and best selection.

5.3. Qualifications and Experience
The Qualifications and Experience section will provide a thorough description of the Proposer’s qualifications and experience related to the desired consultant services detailed in this RFP and Part 420 Launch Site Operator License requirements, including, but not limited to:
⮚ Number of years Proposer has been engaged in spaceport-related planning, engineering, and environmental consulting services.
⮚ Bio for each member of the proposed consultant team, including recent experience (with resumes included as an attachment to this Proposal).
⮚ Identification of all clients Proposer has worked for that pertain to spaceport-related services, including the scope of services and the result of the services provided (include client name, airport name, and address).
⮚ If Proposer intends to engage subconsultant(s) or subject matter expert(s) (SME) as teaming partners, identify the name and contact information of the consulting firm/SME, their intended role in the project, and the name(s), bios, and relevant experience of the individuals that will be involved in the project.

Attachment 8

PROPOSAL CONTENT
Request for Proposals, Spaceport Consultant Services, Paso Robles Municipal Airport 18 City of Paso Robles, California (JUNE 12, 2026)
⮚ Provide references from up to five airports (including the airport’s name and contact information) that Proposer has provided spaceport consultant services, including, but not limited to, a Part 420 Launch Site Operator License application.

5.4. Proposed Scope of Services
The proposal must address the following:
⮚ A proposed work plan that includes estimated completion days for each major component as described in Section 2.2 Description of Requested Services and completed project. ⮚ Chart depicting Proposer’s organizational structure.
⮚ Chart depicting the Proposer’s project team.
⮚ Description of the roles and responsibilities of the Proposer’s team members assigned to the project and any sub-consultant/subject matter expert team members. ⮚ Strategic plan to finish what has been done, and what hasn’t been done by previous consulting firm(s) to ensure the work product is still relevant and contemporary. ⮚ Detailed plan explaining how the Proposer will respond to all revisions issued by the FAA.

5.5. Proposer Rates and Fee Schedule
Proposer shall include the rates and fees schedule for accomplishing the proposed tasks as described in Section

2.2, Description of Requested Services. Proposer should identify proposed labor hours for each task by classification and rate. The Proposer should list any direct expenses, travel assumptions, and optional task rates.

5.6. Additional Information
Proposer may include additional information considered useful in helping the City evaluate the qualifications and experience of the Proposer.

Attachment 8