Agenda packet — Redondo Beach City Council, October 6, 2026 (part 6 of 7)

responsible for the safety of residents and should rely on its own analysis. Provided for discussion purposes.

TECHNICAL HAZARD MEMORANDUM
TO: City of Redondo Beach City Council, Planning Department & Permitting Departments FROM: M.E. Nelson, Public Record Technical Review
DATE: September 23, 2026
SUBJECT: Offsite Consequence & Heavy Gas Dispersion Analysis: Bulk Cryogenic Argon Tank Failure at 2477 Manhattan Beach Blvd

EXECUTIVE SUMMARY & SOFTWARE DECLARATION
This memorandum provides a formalized Offsite Consequence Analysis (OCA) regarding a potential catastrophic release from a 12,000-gallon bulk liquid argon (LAR) storage tank at 2477 Manhattan Beach Blvd. Graphics are provided of dispersion from the federal models. Red areas are potentially fatal. Orange areas are potentially severe enough to limit the ability to evacuate. Yellow areas have transient health impacts. On a typical weather day, all three zones exist in the event of a rupture of a liquid argon tank.

Despite repeated requests, the City has elected to ignore asphyxiation safety. LA County Fire’s recent email was clear, that safety analysis is the responsibility of Redondo Beach Planning & Safety and RBFD. LA County offered to help Redondo Beach, but the City has demonstrated no interest in safety analysis for surrounding neighborhoods.

To evaluate offsite hazards, this analysis utilizes the federal government’s integrated CAMEO® (Computer-Aided Management of Emergency Operations) software suite, developed jointly by the U.S. Environmental Protection Agency (EPA) Office of Emergency Management and the National Oceanic and Atmospheric Administration (NOAA) Emergency Response Division:
● CAMEO Chemicals (https://cameochemicals.noaa.gov) (Accessed September 23, 2026):

Used to establish physical-chemical constants and Protective Action Criteria (PAC) exposure thresholds for Argon.
● ALOHA® (Areal Locations of Hazardous Atmospheres), Version 5.4.7 (https://www.epa.gov/cameo/aloha-software): Used to model biphasic liquid release, puddle evaporation, and heavy gas dispersion dynamics.
● MARPLOT® (Mapping Application for Response, Planning, and Local Operational Tasks), Version 5.1.1 (https://www.epa.gov/cameo/what-cameo-software-suite): Used to map spatial hazard footprints over local parcel and transportation geography.

By contrasting a baseline Average Annual Weather Scenario against a legally mandated Worst-Case Weather Scenario (EPA Risk Management Program standards), this analysis highlights the critical uncertainty and operational risk associated with heavy gas slumping in dense urban corridors.
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responsible for the safety of residents and should rely on its own analysis. Provided for discussion purposes.

SCENARIO SPECIFICATIONS & SOURCE STRENGTH
● Chemical: Argon (MW: 39.95 g/mol; Boiling Point: -302.6°F) ● Thresholds (Protective Action Criteria):
○ PAC-1 (Yellow): 65,000 ppm (Mild/transient health impacts / asphyxiation awareness) ○ PAC-2 (Orange): 230,000 ppm (Irreversible health effects / impaired escape) ○ PAC-3 (Red): 400,000 ppm (Life-threatening / severe oxygen depletion) ● Vessel & Leak Geometry: 12,000-gallon vertical cylinder (7.33 ft diameter × 38 ft length), 83% full (58.8 tons liquid mass). A catastrophic 5-foot circular opening located 19 feet from the bottom causes a 47,040 lb liquid spill in 1 minute onto concrete, forming a 41- yard evaporating cryogenic puddle.

COMPARATIVE ANALYSIS: AVERAGE VS. WORST-CASE PLUMES

1. Average Annual Weather Case
● Parameters: Air Temp 66°F, 60% Relative Humidity, Wind 3 knots from West, Cloud Cover 3/10, Atmospheric Stability Class B (unstable/moderate mixing), Building Air Exchange Rate 0.32 ACH.
● Dispersion Dynamics: Strong solar radiation and daytime convective turbulence carry the evaporating argon gas downwind toward the east.
● Hazard Footprint:
○ PAC-3 (Red): 100 yards downwind
○ PAC-2 (Orange): 145 yards downwind
○ PAC-1 (Yellow): 314 yards downwind
See AnnualAvgWeatherCasePlume-Marplot.jpg below:
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responsible for the safety of residents and should rely on its own analysis. Provided for discussion purposes.

YELLOW: PAC-1 : Mild, transient health effects (Shaded=predicted, Outline=uncertainty) ORANGE: PAC-2 : Irreversible or other serious health effects that could impair the ability to take protective action.

RED: PAC-3 : Life-threatening health effects.

2. Worst-Case Scenario (EPA RMP / CalARP Standard)
● Parameters: Air Temp 95°F, 50% Relative Humidity, Wind 3 knots from West (1.5 m/s), Cloud Cover 0/10, Atmospheric Stability Class F (extreme night/stagnant inversion override), Building Air Exchange Rate 0.49 ACH.
● Dispersion Dynamics: The heated concrete ground causes rapid boiling of the -302.6°F liquid pool. Because Stability Class F eliminates vertical mixing, gravity forces the dense cloud to slump radially outward faster than the weak 3-knot breeze can push it. ● Hazard Footprint:
○ PAC-3 (Red): Threshold (400,000 ppm) not exceeded beyond immediate spill pool due to rapid initial radial expansion and dilution.
○ PAC-2 (Orange): Expands to 160 yards, pushing upwind and crosswind across Manhattan Beach Blvd and Inglewood Ave.
○ PAC-1 (Yellow): Expands to 316 yards, creating a blunt 360-degree radial footprint that engulfs adjacent commercial parcels (e.g., Havana Mania) and residential homes to the south and west.
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responsible for the safety of residents and should rely on its own analysis. Provided for discussion purposes.

See WorstCasePlume-Marplot.jpg below:

PLANNING & POLICY IMPLICATIONS

1. Uncertainty & The Prevailing Wind Fallacy: Relying solely on average prevailing westerly winds creates a false sense of security. Under worst-case nocturnal inversion conditions (Stability Class F), heavy gas slumping drives dangerous asphyxiant concentrations upwind into areas typically assumed safe.

2. Emergency Response Invalidations: Standard hazmat protocols dictate approaching a chemical release from upwind. As demonstrated in the Worst-Case MARPLOT overlay, first responders approaching from the west along Manhattan Beach Blvd would unknowingly enter a PAC-2 (230,000 ppm) asphyxiation zone.

3. Regulatory Precedent: Municipal reviews that issue Mitigated Negative Declarations (MNDs) without requiring formal Offsite Consequence Modeling deviate from standard practices established by the U.S. Department of Energy (DOE) and California Accidental Release Prevention (CalARP) frameworks.

4. Understanding the Risks: The Worst-Case scenario is dictated by regulation. In Redondo Beach, the typical, average weather is much cooler and would cause the liquid 918

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responsible for the safety of residents and should rely on its own analysis. Provided for discussion purposes. to return to its gas state more slowly. That creates a localized zone of unbreatheable gas mixture. Due to the 95 degree F temperature required for the Worse-Case scenario, the liquid gasifies more quickly as it hits the air and the built environment, mitigating the most dangerous impacts. Counterintuitive, but correct.
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responsible for the safety of residents and should rely on its own analysis. Provided for discussion purposes.

APPENDIX: REGULATORY REFERENCES & CASE STUDIES
● Lucas County Emergency Management Agency (OH): Formally catalogs industrial cryogenic storage and utilizes ALOHA modeling to map offsite vulnerability zones for bulk liquid argon and nitrogen. (Reference: Matheson-Holland Emergency Plan, https://www.co.lucas.oh.us/DocumentCenter/View/92444/Matheson-Holland) ● U.S. Department of Energy (Lawrence Livermore National Laboratory EIS):

Mandates heavy gas dispersion modeling using PAC thresholds for large-scale asphyxiants to establish site safety perimeters. (Reference: Final Site-Wide Environmental Impact Statement (EIS) for Continued Operation of LLNL, DOE/EIS-0547, https://www.energy.gov/nepa/articles/doeeis-0547-final-environmental-impact-statement) ● AIDIC Hazardous Materials Hazard Analysis (2014): Confirms that biphasic spillage and heavy gas evaporation of cryogenic inert liquids present significant offsite oxygen depletion risks requiring mapped spatial buffers. (Reference: Chemical Engineering Transactions, Vol. 36, https://www.aidic.it/cet/14/36/093.pdf) 920

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responsible for the safety of residents and should rely on its own analysis. Provided for discussion purposes.

AVERAGE DAY OF THE YEAR SCENARIO
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responsible for the safety of residents and should rely on its own analysis. Provided for discussion purposes.

WORST CASE SCENARIO
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PUBLIC COMMENT 02 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, September 24, 2026 at 9:12 AM

SUBJECT
Public Comment: A mere 1% value diminution from
Impulse Space's Variance is a $10M property value
loss

SUPPORTING MATERIALS INCLUDED
- One Billion Property Value Immediately South of Impulse Space The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
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From: Mark Nelson (Home Gmail)
To: CityClerk; Mike Witzansky; Joy Ford; Sean Scully; Scott Behrendt; Andrew Winje; Marc Wiener; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Nick Biro; Zein Obagi Subject: Public Comment: A mere 1% value diminution from Impulse Space"s Variance is a $10M property value loss Date: Thursday, September 24, 2026 9:12:43 AM
Attachments: One Billion Property Value Immediately South of Impulse Space.pdf One Billion Property Value Immediately South of Impulse Space.pdf CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

The residential neighborhood directly south of 2477 Manhattan Beach Blvd has an estimated property value of over $1B. Yet, Impulse Space is seeking a variance in the "buffer" area zoned IC-1 that according to the peer-reviewed literature will likely damage property values.

There has been no consideration by the City of either the safety or property value impact as part of the record in the variance proceeding. Yet, even a small 1% impact by the variance is $10M of property value.
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MEMORANDUM
DATE: September 21, 2026
SUBJECT: Residential Inventory Count & Market Valuation Analysis — Neighborhood South of Impulse Space Property Value Estimated to Exceed $1 Billion Executive Summary
An analysis was conducted to estimate the total residential property value for the neighborhood situated immediately south of Manhattan Beach Boulevard / Impulse Space facilities in North Redondo Beach (ZIP 90278). Based on visual lot mapping and recent Redfin transaction data (past 3 years), the neighborhood comprises approximately 580 residential single-family lots. With an average sale price of $1,850,038, the total estimated residential market value for this enclave is $1.073 billion.

1. Neighborhood Map & Inventory Count
The provided map delineates the single-family residential tract bounded by Manhattan Beach Blvd to the north, Inglewood Ave to the east, Robinson St to the south, and Johnston Ave / May Ave to the west.
● Street-by-Street Parcel Distribution:
○ Johnston Ave / White Cir / Pinckard Ave / May Ave Corridor: ~115 homes ○ Sebald Ave, Burritt Ave, Spurgeon Ave, Thomas Ave, Hawkins Ave: ~145 homes ○ Dow Ave / Gibson Pl Spine: ~80 homes
○ 159th St, 160th St, Vargas Way, Faber St, Carlsbad St: ~90 homes ○ Beland Blvd, Blaisdell Ave, Perkins Ln, Barkley Ln: ~150 homes ● Total Visual Parcel Count: ~580 single-family residential homes

2. Historical Sales Data Analysis (Redfin - Past 3 Years) Analysis of the 46 valid single-family home transactions in this immediate neighborhood over the past 3 years reveals the following price dynamics:

Metric Value
Total Qualified Sales 46 homes
Average Sale Price $1,850,038.04
Median Sale Price $1,595,000.00
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Minimum Sale Price $950,000.00
Maximum Sale Price $4,300,000.00
Standard Deviation $740,851.30
Average Price / Sq. Ft. ~$980 – $1,100 / sq. ft.

Note: The spread between the median ($1.595M) and average ($1.850M) reflects recent luxury infill/new construction modern builds (such as multi-million dollar rebuilds on Johnston Ave and Timothy Ave).

3. Estimated Total Neighborhood Value
Applying the market metrics to the neighborhood housing stock yields the following valuation scenarios:
● Baseline Valuation (Mean Price):
$$\text{Total Market Value} = 580 \text{ homes} \times \$1,850,038.04 = \mathbf{\$1,073,022,065.22}$$
● Conservative Valuation (Median Price):
$$\text{Conservative Value} = 580 \text{ homes} \times \$1,595,000.00 = \mathbf{\$925,100,000.00}$$
● Sensitivity Range (550 to 620 Homes):
○ 550 Homes @ Average Price: $1.018 Billion
○ 600 Homes @ Average Price: $1.110 Billion
○ 620 Homes @ Average Price: $1.147 Billion
Conclusion
The residential community directly south of the proposed Impulse Space tanks contains roughly 580 homes representing over $1.07 Billion in total residential real estate value. 926
PUBLIC COMMENT 03 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, September 24, 2026 at 3:02 PM

SUBJECT
Public Comment: 38-foot industrial gas tanks in a
transitional-by-design area will diminish residential
property values

SUPPORTING MATERIALS INCLUDED
- The Negative Impact of Visible Industrial Facilities - Application to the Impulse Space Variance
- Addendum Industrial Visibility Property Value Study Summaries Revised 09212026 (vF)
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
927
From: Mark Nelson (Home Gmail)
To: CityClerk; Mike Witzansky; Joy Ford; Sean Scully; Scott Behrendt; Andrew Winje; Marc Wiener; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Nick Biro; Zein Obagi Subject: Public Comment: 38-foot industrial gas tanks in a transitional-by-design area will diminish residential property values
Date: Thursday, September 24, 2026 3:02:12 PM
Attachments: The Negative Impact of Visible Industrial Facilities - Application to the Impulse Space Variance.pdf Addendum_Industrial_Visibility_Property_Value_Study_Summaries_Revised_09212026 (vF).pdf CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Through literature review of peer-reviewed studies, it is generally accepted that proximity to manufacturing and industrial facilities reduces property values. Even in the cases where the statistical evidence is not significant, it demonstrates a negative impact on property values.

The research also distinguishes the industrial impacts into effectively the mere presence of industrial and the visibility of the industrial in the viewshed.

In the case of Impulse Space's IC-1 zoning, the City deliberately selected a 30-foot height limit for the transitional area as it was the same as residential height limits. As such, the industrial with 110-foot limits is distant, the adjoining IC is 30-foot and the residential is 30- foot, putting the IC zone out of sight.

The request for a variance to 38-feet will make the large white industrial tanks clearly visible into the neighborhood. The research shows that visibility is a separable component of the value decline in adjoining neighborhoods. A CalTech study showed that the further residences suffer less devaluation, as expected, ranging to 11% value loss directly adjacent to the industrial to a 2% value loss at about 1000-feet distance. In the over $1B property value adjoining neighborhood, each 1% of value decline represents $10M of resident-voter wealth loss.

The IC-1 zone height limit must be enforced. The area was designed as a buffer, it should not be allowed to diminish property values further from erecting large, industrial tanks that will clearly extend the plant's impacts by viewshed hundreds of feet further into the neighborhood, amplifying the loss percentage of property values.

Attachments: Memo with research addendum
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MEMORANDUM
DATE: September 21, 2026
SUBJECT: Impact of Visible Industrial Facilities on Residential Property Values and Enforcement of IC-1 Zoning Height Restrictions
Introduction
This memorandum outlines the economic impacts of visible industrial structures on adjacent residential properties, drawing upon the findings detailed in the addendum. It also examines the policy intent of the Redondo Beach Municipal Code and General Plan concerning the Industrial-Commercial (IC-1) zone's function as a buffer designed to protect surrounding residential neighborhoods.

The Negative Impacts of Visible Industrial Facilities
on Residential Values
The review of peer-reviewed real estate and spatial economic literature demonstrates that the visibility of industrial facilities—particularly those protruding above standard development heights—constitutes a measurable residential disamenity. The research synthesis highlights several key findings regarding structural height and viewsheds:
● The studies support the proposition that what is actually visible can matter independently of simple distance.
● Distance to an industrial site has a statistically significant negative effect on residential values, with the research expressly identifying the obstruction of view among industrial externalities.
● Industry can be treated as an explicit component of the visible scene and valued separately from mere proximity.
● There is strong methodological support for separating the condition where a facility exists nearby from the condition where a facility is visible above intervening development.
● The height of a vertical structure can materially alter the viewshed. 929
● A relatively small height exceedance can change which residences enter the viewshed.
● For the Redondo Beach fact pattern, the economically relevant change is not merely that an industrial use exists nearby, but rather the change from an industrial use substantially contained within a common 30-foot development envelope to vertically prominent equipment at roughly 38 feet or higher.
● This vertical prominence may cause the equipment to become visible and identifiable from residences where the industrial use otherwise would not be apparent.

IC-1 Zoning as a Protective Buffer Under the Redondo
Beach Municipal Code
Under the Redondo Beach Municipal Code (Title 10, Chapter 2), the specific purposes of the industrial and industrial-commercial zone regulations—including I-1, I-2, and IC-1—are explicitly crafted to ensure compatibility with the community.

Among these stated purposes are the mandates to "minimize the impact of industrial and commercial uses on adjacent residential zones" and to "ensure that the appearance and effects of industrial and commercial uses are compatible with the character of the area in which they are located."
The IC-1 (Industrial Commercial) zone operates as a vital transitional hybrid area.

It is intended to buffer heavier industrial operations (such as those in the I-1 zone) from abutting Single-Family Residential (R-1) zones. A critical mechanism for achieving this buffer is the strict regulation of development envelopes, notably the 30-foot maximum building height requirement present in local industrial development standards.

When variances are requested to exceed this 30-foot height limit—such as recent proposals for 38-foot bulk cryogenic storage tanks—the core buffering intent of the municipal code is compromised. As the research demonstrates, it is the tall industrial object, not the underlying parcel, that determines distant industrial identification. Approving height variances allows industrial infrastructure to pierce the visual skyline, transforming an otherwise screened industrial use into a 930
recognizable disamenity for neighboring homes. To uphold the integrity of the General Plan and protect residential property values, the city must enforce the IC-1 height limits and prevent industrial uses from visually encroaching on residential viewsheds.

Summary and Conclusion
The City of Redondo Beach is obligated by its foundational municipal and planning documents to provide specific protections to its residents. These mandated protections require the City to:
● Promote the economic stability of existing land uses (Redondo Beach Municipal Code Title 10, Chapter 2).
● Maintain a high level of quality and character in residential neighborhoods (Redondo Beach Municipal Code Title 10, Chapter 2).
● Ensure land use compatibility by minimizing the impact of commercial and industrial uses on adjacent residential zones (Redondo Beach Municipal Code Title 10, Chapter 2).
● Protect the public health, safety, and general welfare of the population when considering zoning variances and land use changes (Redondo Beach Municipal Code Administration).
● Preserve community character, proactively protect neighborhoods, and ensure a high quality of life (Redondo Beach General Plan Guiding Principles).

Granting a variance that allows the IC-1 zone to abrogate its transitional nature and exceed established height limits actively undermines these mandated protections.

Based on the peer-reviewed research establishing that the visual prominence of vertical industrial facilities constitutes a measurable residential disamenity, permitting such a variance will ultimately fail to protect the general welfare of the surrounding neighborhoods and fail to protect residential property values. ● The literature review of studies provided directly supports that premise that increasing the visibility of the IC-1 Impulse Space will have a further negative impact on the already reduced residential property values to its south.
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The CalTech working paper by Grether and Mieszkowski (1980) examined the effects of nonresidential land uses on adjacent housing prices. In their statistically significant West Haven Industrial (1) experiment, they found a severe negative value relationship associated with proximity to industrial property. The study established that homes located directly at the industrial boundary suffer up to an 11% property value diminishment compared to unimpacted neighborhood homes located 1,420 feet away.

Distance from Industrial
Boundary
Property Value Impact Value Recovery
Adjacent (0 feet) 11% Diminishment Baseline
760 feet 5% Diminishment 6% Recovery
1,090 feet 2% Diminishment 9% Recovery
1,420 feet 0% Diminishment 11% Recovery (Full Value)
This devaluation operates on a localized gradient: moving away from the devalued boundary, residential property values recover by 6% at 760 feet, by 9% at 1,090 feet, and reach their full expected value (an 11% recovery) at a distance of 1,420 feet. For the IC-1 Impulse Space facility, this establishes a clear, measurable diminishment zone extending outward to 1,420 feet from the industrial edge, with the maximum 11% devaluation falling squarely on adjacent property owners. 932
Industrial Visibility and Residential Property Values
Study-by-Study Summaries from the Prior Research Workbook Focus: industrial visibility, vertical structures, viewsheds, proximity effects, and reported property-value diminution How to Read This Review
This document summarizes the retained Industrial Visibility / Residential Property Value research, focusing on direct industrial/view evidence, vertical-structure/viewshed methodology, general industrial-proximity evidence, and contrary/boundary evidence.

The prior research conclusion was that no strong peer-reviewed transaction-price study was located that isolates above-ground storage tanks or silos as a visual-only residential disamenity. The strongest remaining evidentiary chain is therefore: direct industrial-view studies + general viewshed/vertical-structure methodology + general industrial-proximity studies, with contrary studies retained. 1 - Direct industrial/view

1. The Impact of Industrial Sites on Residential Property Values: A Hedonic Pricing Analysis from the Netherlands
Authors: Friso de Vor; Henri L.F. de Groot
Publication: Regional Studies 45(5):609-623 (2011)
Study setting: Industrial sites; Netherlands residential sales Method: Hedonic pricing; distance to industrial sites; paper expressly identifies obstruction of view among industrial externalities
Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Distance to an industrial site has a statistically significant negative effect on residential values; effect is largely localized and varies with industrial-site size.

Relevance to the 38-ft tank / skyline issue: Core industrial evidence. Supports treating visible industrial character/obstruction of view as a residential disamenity. Useful benchmark for the maximum 'industrial identified' effect.

Important limitation: Does not separately estimate the coefficient attributable only to visual recognition or protruding equipment.

Primary source: https://doi.org/10.1080/00343401003601925 Additional source: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1398803

2. Estimation of the Influence of View Components on High-Rise Apartment Pricing Using a Public Survey and GIS Modeling
Authors: Ian D. Bishop; Eckart Lange; Alani Muhammad Mahbubul Publication: Environment and Planning B: Planning and Design 31(3):439-452 (2004) Study setting: Views containing parks, water, industry and high-rise buildings Method: GIS determines what is visible and the proportion of each land use/structure in the view; survey estimates willingness to pay
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Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Demonstrates that industry can be treated as an explicit component of the visible scene and valued separately from mere proximity.

Relevance to the 38-ft tank / skyline issue: Direct support for the proposition that 'industrial visible in the viewshed' is a measurable housing attribute.

Important limitation: Willingness-to-pay/view study rather than transaction-price study of detached R-1 homes.

Primary source: https://doi.org/10.1068/b3042

3. A Sight for Sore Eyes: Assessing the Value of View and Land Use in the Housing Market Authors: Andrea Baranzini; Caroline Schaerer
Publication: Journal of Housing Economics 20(3):191-199 (2011) Study setting: 13,000 Geneva dwellings; natural and built environment Method: 3-D GIS view measures at dwelling level plus hedonic rental model Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Both land use and what is actually visible significantly affect rents; working-paper version reports natural views raise rents while views of built environment lower rents.

Relevance to the 38-ft tank / skyline issue: Strong methodological support for separating 'facility exists nearby' from 'facility is visible above intervening development.' Important limitation: Rental/apartment market; not specifically tanks or industrial equipment.

Primary source: https://doi.org/10.1016/j.jhe.2011.06.001 Additional source: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=981189

4. A varying coefficient approach to estimating hedonic housing price functions and their quantiles
Authors: Alan T.K. Wan; Shangyu Xie; Yong Zhou
Publication: Journal of Applied Statistics 44(11):1979-1999 (2017) Study setting: Hong Kong housing; multiple view attributes including industrial-plant view Method: Hedonic housing-price/quantile modeling with view variables Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Study includes an industrial-plant-view variable; reported results indicate negative effects for industrial-plant views in portions of the market.

Relevance to the 38-ft tank / skyline issue: One of the closest studies to the proposition that seeing an industrial facility is itself a negative housing attribute.

Important limitation: High-density Hong Kong housing market; effect is not a transferable percentage for Redondo Beach.

Primary source: https://doi.org/10.1080/02664763.2016.1238053

5. Viewshed effects and house prices: Identifying the visibility value of the natural landscape Authors: Authors as listed by publisher
Publication: Landscape and Urban Planning 238:104818 (2023) Study setting: Repeated house sales; Haifa, Israel
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Method: Automated GIS viewsheds; spatial hedonic/panel models; separates visibility from proximity Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Shows that visibility can be econometrically identified separately from proximity and that results depend on range of visibility.

Relevance to the 38-ft tank / skyline issue: Methodological foundation for a before/after viewshed variable:
hidden industrial use versus vertically protruding, recognizable industrial equipment.

Important limitation: Studies natural amenities, not industrial disamenities.

Primary source: https://doi.org/10.1016/j.landurbplan.2023.104818

6. Gulf Views: Toward a Better Understanding of Viewshed Scope in Hedonic Property Models
Authors: Paul Hindsley; Stuart E. Hamilton; O. Ashton Morgan Publication: Journal of Real Estate Finance and Economics 47(3):489-505 (2013) Study setting: Residential sales; Pinellas County, Florida Method: LiDAR-based continuous measures of total view, continuous view segment and proximity to view content
Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Larger and more continuous visible view segments have measurable value; proximity to the viewed content also matters.

Relevance to the 38-ft tank / skyline issue: Supports quantifying how much of a tank/stack is exposed above the skyline rather than using only a binary distance measure.

Important limitation: Positive water view rather than industrial disamenity.

Primary source: https://doi.org/10.1007/s11146-012-9365-0 Additional source: https://ideas.repec.org/a/kap/jrefec/v47y2013i3p489-505.html

7. Heights and locations of artificial structures in viewshed calculation: How close is close enough?
Authors: Authors per publisher record
Publication: Landscape and Urban Planning (2008)
Study setting: Artificial structures and GIS viewshed accuracy Method: Examines structure height/location in viewshed calculation; reviews property-value literature Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Notes prior findings that views of buildings and industrial areas decrease property values and emphasizes that structure height materially affects calculated visibility.

Relevance to the 38-ft tank / skyline issue: Directly relevant to the 30-ft versus 38-ft-plus geometry: a relatively small height exceedance can change which residences enter the viewshed.

Important limitation: Primarily a viewshed-methodology paper, not a tank-specific hedonic estimate.

Primary source: https://www.sciencedirect.com/science/article/pii/S0169204607000692

8. GIS Generated Viewshed of an Incinerator Chimney (research described in environmentaleconomics proceedings) Authors: Ian Bateman / Andrew Lovett research described in proceedings 935
Publication: Environmental Economics workshop proceedings (1994) Study setting: Incinerator chimney located in a valley
Method: GIS viewshed compared with simple distance
Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Example notes homes <1 km away may not see the stack while homes up to 10 km away may have an unimpeded view; distance alone can mask a chimney's visual effect.

Relevance to the 38-ft tank / skyline issue: Conceptually close to the screening issue: the tall industrial object, not the underlying parcel, determines distant industrial identification.

Important limitation: Not treated as peer-reviewed final evidence; retained as methodological/supporting source.

Primary source: https://www.outdoorrecreation.org.uk/wp-content/uploads/2017/02/CRN-WORKSHOP-1994- ENVIRONMENTAL-ECONOMICS.compressed.pdf
3 - General industrial proximity

9. Effects of Location Elements on Home Purchase Prices and Rents in San Francisco Bay Area Authors: Kara Maria Kockelman
Publication: Transportation Research Record 1606:40-50 (1997) Study setting: San Francisco Bay Area residential values; industrial land use among neighborhood variables Method: Hedonic models controlling for housing structure, accessibility, travel costs and local land-use patterns Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: After controlling for travel costs, high proximity to industrial land uses and very local commercial activity depresses land and dwelling-unit values, often substantially.

Relevance to the 38-ft tank / skyline issue: California evidence for the upper-bound concept: once a neighborhood is visibly/readily identifiable as industrial, industrial proximity is a negative market attribute.

Important limitation: Does not isolate visual identification from other industrial externalities.

Primary source: https://doi.org/10.3141/1606-06
Additional source: https://www.caee.utexas.edu/prof/kockelman/public_html/homepric.pdf

10. Disentangling property value impacts of environmental contamination from locally undesirable land uses
Authors: Laura O. Taylor; Daniel J. Phaneuf; Xiangping Liu Publication: Journal of Urban Economics 93:85-98 (2016) Study setting: Twin Cities residential sales near contaminated and uncontaminated commercial properties Method: Difference-in-differences and repeat-sales models Reported diminution: About 2.5% near clean commercial properties versus about 8% near contaminated sites in cross-sectional results.

Principal finding: Cross-sectional results: proximity to clean commercial properties reduced neighboring home values about 2.5%, versus about 8% for contaminated sites; after remediation the remaining discount was largely indistinguishable from clean commercial land-use effect.

Relevance to the 38-ft tank / skyline issue: Demonstrates a negative land-use effect even without contamination—the commercial/industrial condition itself can carry a discount. 936
Important limitation: Commercial properties are broader than industrial and study does not isolate skyline visibility.

Primary source: https://doi.org/10.1016/j.jue.2016.03.004

11. Smelly Local Polluters and Residential Property Values: A Hedonic Analysis of Four Orange County (California) Cities
Authors: Jean-Daniel Saphores; Ismael Aguilar-Benitez
Publication: Estudios Económicos 20(2):197-218 (2005)
Study setting: Four Orange County, California cities; auto shops and polluting plants Method: GIS plus hedonic regression
Reported diminution: Residential price reductions up to 3.4% associated with local air/odor pollution.

Principal finding: Statistically significant residential price reductions up to 3.4% associated with local air/odor pollution.

Relevance to the 38-ft tank / skyline issue: Southern California evidence that relatively local industrial activities capitalize into nearby housing prices.

Important limitation: Mechanism is odor/air pollution, not primarily visual; secondary rather than core evidence for the tank argument.

Primary source: https://www.jstor.org/stable/40311503

12. Environmental Health Risks and Housing Values: Evidence from 1,600 Toxic Plant Openings and Closings
Authors: Janet Currie; Lucas Davis; Michael Greenstone; Reed Walker Publication: American Economic Review 105(2):678-709 (2015) Study setting: 1,600 U.S. toxic industrial plant openings/closings Method: Quasi-experimental openings/closings; housing-market data Reported diminution: About an 11% decline in housing values within 0.5 mile following toxic-plant openings.

Principal finding: Plant openings led to about an 11% decline in housing values within 0.5 mile.

Relevance to the 38-ft tank / skyline issue: Useful as an industrial 'fully identified facility' upper-context study, not as a direct estimate of visual tank effects.

Important limitation: Dominant mechanism includes toxic emissions/health risk; should not be used to attribute a visual-only percentage.

Primary source: https://doi.org/10.1257/aer.20121656
Additional source: https://pmc.ncbi.nlm.nih.gov/articles/PMC4847734/

13. Industrial Land Use, Externalities, and Residential Location Authors: James D. Burnell
Publication: Urban Studies 22(5):399-408 (1985)
Study setting: Industrial land use and residential location Method: Empirical analysis distinguishing localized and nonlocalized industrial externalities Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Addresses both localized and nonlocalized externalities associated with industrial land use.

Relevance to the 38-ft tank / skyline issue: Supports examining the geographic footprint created when an otherwise screened industrial use becomes identifiable at a distance. 937
Important limitation: Not a direct visibility or tank study.

Primary source: https://ideas.repec.org/a/sae/urbstu/v22y1985i5p399-408.html 4 - Contrary / boundary evidence

14. The Effects of Nonresidential Land Uses on the Prices of Adjacent Housing: Some Estimates of Proximity Effects
Authors: David M. Grether; Peter Mieszkowski
Publication: Journal of Urban Economics 8(1):1-15 (1980) Study setting: 16 neighborhood experiments near industry, commercial, high-density housing and highways Method: Hedonic price indices; distance from nonresidential use Reported diminution: Results are mixed rather than uniformly null. In West Haven Industrial (1), the distance variables were jointly significant at the 0.01 level. Table 3 estimates values about 6% higher at the sample mean distance, 9% higher at mean + 1 SD, and 11% higher at mean + 2 SD, relative to the industrial boundary (D = 0).

The other two industrial samples did not have jointly significant distance effects.

Principal finding: Across all 16 experiments, the authors found no systematic relationship between nonresidential land use per se and housing prices. However, the industrial results are more informative when separated by statistical significance: one of the three industrial experiments produced a strong, statistically significant proximity gradient, while two did not.

Relevance to the 38-ft tank / skyline issue: The statistically significant West Haven result is directly relevant as evidence that an industrial/residential boundary can produce a localized capitalization effect. The authors describe this site as light industry bordering a middle-class housing development, with some tree buffering. The paper also expressly identifies traffic and visual externalities as rationales for separating industrial/commercial activity from single-family neighborhoods. This does not isolate tank visibility or an 8-ft height exceedance, but it supports testing whether making industrial equipment perceptible from adjacent residences changes market value.
938
Statistically significant industrial result
West Haven Industrial (1): The distance terms were jointly significant at p < .01. The fitted distance function implies progressively higher values away from the industrial boundary. Table 3 reports approximately +6% at the mean sample distance, +9% at mean + 1 standard deviation, and +11% at mean + 2 standard deviations, using the boundary (D = 0) as the reference. The authors state that this result is sensible and that the data support treating the West Haven industrial zone as a disamenity.

Industrial results that were not statistically significant but indicated a negative value impact coefficient sign West Haven Industrial (2): The joint distance test was not significant. The fitted coefficients were distance = -0.030 and distance-squared = +0.0023. Those signs describe a curved fitted relationship, but because the distance terms were not jointly significant, they should not be presented as evidence of a measurable industrial discount.

Milford Industrial: The joint distance test was also not significant. The fitted coefficients were distance = -0.084 and distance-squared = +0.0031. Again, the point estimates initially slope in the direction of lower values with greater distance before curvature changes the fitted relationship; statistically, however, the study could not distinguish the distance effect from zero.

Interpretation of significance and coefficient signs
The useful distinction is therefore not “industrial proximity was negative but insignificant” across the study. The more accurate statement is that the three industrial experiments were heterogeneous: one showed a statistically strong adverse proximity effect, while two produced non-significant quadratic distance relationships whose individual coefficient signs should be treated as descriptive point estimates, not demonstrated market effects. This distinction preserves both the affirmative evidence and the contrary/boundary evidence.

Primary source: https://doi.org/10.1016/0094-1190(80)90052-2 Additional source: https://authors.library.caltech.edu/records/bscpz-3xy50 Synthesis of the Prior Analysis
The studies do not support assigning a single percentage diminution to the proposed tanks. They do support several narrower propositions: (1) industrial proximity can be capitalized negatively into residential values; (2) what is actually visible can matter independently of simple distance; (3) the height of a vertical structure can materially alter the viewshed; and (4) measurable effects can be highly localized. Grether and Mieszkowski add an important boundary condition: nonresidential land use per se did not produce a systematic price effect across all 16 experiments, yet one of their three industrial sites showed a statistically significant p < .01 distance gradient, with estimated values roughly 6%-11% higher at increasing distances from the industrial boundary. Their other two industrial samples were not statistically significant.

For the Redondo Beach fact pattern used in the prior analysis, the economically relevant change is not merely that an industrial use exists nearby. The proposed analytical exposure is the change from an industrial use substantially contained within a common 30-ft development envelope to vertically prominent equipment at roughly 38 ft or higher that may become visible and identifiable from residences where the industrial use otherwise would not be apparent. The combined literature therefore supports testing a project-specific visibility/proximity effect, but not importing a percentage from another facility or market. A defensible local estimate would require sales/comparable data combined with distance and viewshed variables. 939
PUBLIC COMMENT 04 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, September 24, 2026 at 3:31 PM

SUBJECT
Fwd: FW: 2477 Manhattan Beach Blvd. - Request for
HHMD Review of Cryogenic Tank Emergency Planning
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
940
From: Mark Nelson (Home Gmail)
To: CityClerk; Mike Witzansky; Joy Ford; Sean Scully; Scott Behrendt; Andrew Winje; Marc Wiener; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi Subject: Fwd: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Thursday, September 24, 2026 3:31:43 PM
Attachments: image001.png
2477_HHMD_Single_Tank_Catastrophic_Release_Memo.docx
Public Notice This 2477 Manhattan Beach Blvd Redondo Beach CA 90278 Exhibit is Defective.eml.msg CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

The following correspondence demonstrates that the City cannot defer its permitting process on fire and safety to LA County Fire for the Impulse Space variance. The City is obligated to determine the hazards along with mitigations prior to permitting or providing a variance. ---------- Forwarded message ---------
From: Fernando Florez <[email protected]> Date: Mon, Sep 14, 2026 at 3:00 PM
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cry 6-0595)
To:

Cc: do.org>, Mario Tresierras
<[email protected]>, Mauricio Nunez Florez <[email protected]>
Good afternoon, Mr. Nelson.

The Los Angeles County Fire Department Health Hazardous Materials Division is the Certified Unified Participating Agency (CUPA) that has the inspection and enforcement authority over businesses that handle hazardous materials and/or generate hazardous waste in the city of Redondo Beach. However, the installation and permitting of new or proposed Aboveground Storage Tanks is under the authority of the Redondo Beach Fire Department’s Fire Prevention Office and the City of Redondo Beach Building and Safety Office. I copied Deputy Fire Marshal Jasen Brown of the Redondo Beach Fire Department on this email.

Once the permitting and installation process is complete, the Health Hazardous Materials Division’s Inspection Section inspects the business to ensure that the chemical inventory, site map, and business plan have been updated, uploaded, and are accurate in the California Electronic Reporting System (CERS).
941
Our Health HazMat’s Emergency Operations Section can assist with conducting an off-site consequence plume modeling for the proposed Argon gas.

If you have any questions, please feel free to contact me by phone at 818-534-7633.

Sincerely,
Fernando Florez, Assistant Chief
Community Risk Reduction Bureau
Health Hazardous Materials Division
Emergency Operations Section
5825 Rickenbacker Road
Commerce, CA 90040
(323) 890-4085 – Office
(818) 534-7633 – Cell
CONFIDENTIALITY NOTICE: This e-mail communication and any attachments, from the Los Angeles County Fire Department, may contain confidential and privileged information for the official use of the designated recipients. If you are not the intended recipient, (or authorized to receive for the recipient) you are hereby notified that you have received this communication in error and that any review, disclosure, use, dissemination, distribution, saving, or reproduction of this email or its contents is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail and destroy this message and any attachments. This e-mail communication is covered by the Electronic Communications Privacy Act, 18 U.S.C. § 2510-2521, and may be legally privileged.

From: Mark Nelson (Home Gmail)
Sent: Wednesday, August 26, 2026 8:15 PM
To: Fire-Hhmdcers <[email protected]>; FIRE-AskHHMD <[email protected]>; Cc: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully 942
CAUTION: External Email. Proceed Responsibly.

Reminder: Potentially hazardous physical situation that does not have any reported HAZMAT/HHMD Review. Basic mass transfer equations have a significant rupture of a 12,000 gallon tank of LAR rolling into the neighborhood. Residents deserve to know the plan and the City of RB/RBFD is pointing squarely at LA County Fire. Please advise. We are sending a certified communication since time is wasting before the next Redondo Beach permitting meeting.
---------- Forwarded message ---------
From: Mark Nelson (Home Gmail)
Date: Fri, Aug 21, 2026 at 1:55 PM
Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
To: <[email protected]>, <[email protected]> Cc: Scott Behrendt <[email protected]>, Mike Witzansky <[email protected]>, Andrew Winje <[email protected]>, Joy Ford <[email protected]>, Marc Wiener <[email protected]>, Sean Scully <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, org>, <[email protected]>, Mark N
Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
County of Los Angeles Fire Department
Health Hazardous Materials Division
cc: Redondo Beach Councilmember Behrendt, Mr. Witzansky, Ms. Ford, Mr. Wiener, and Members of the Planning Commission:

I am transmitting the attached memorandum on behalf of myself and interested residents in the neighborhood surrounding 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, regarding the proposed bulk liquid-nitrogen and liquid-argon storage tanks.

The August 20 Planning Commission hearing was useful in identifying both the issues of concern to nearby residents and several questions of interest to the Commissioners. Among the subjects discussed were tank capacity, <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Mark N Subject: Fwd: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
943
separation from the residential neighborhood, oxygen displacement, emergency isolation and evacuation distances, and the consequences of a major vessel failure. The proposed tanks are approximately 222 feet from the nearest residential property.

The hearing also helped clarify the respective regulatory roles. Redondo Beach Fire Department indicated that it does not maintain its own hazardous-materials team and that Los Angeles County Fire performs the hazardousmaterials/CUPA inspection function for facilities of this type.

I do not interpret the questions raised at the hearing as establishing that the proposed tanks are unsafe. Rather, my takeaway was that some of the specific technical questions being asked by Commissioners and residents could not be answered in detail at the hearing and appear more appropriately directed to HHMD/CUPA.

That is the purpose of the attached memorandum.

In particular, I believe a useful and reasonably bounded question is the consequence of catastrophic failure of one full liquid-argon vessel. Argon is nonflammable and chemically inert, but a sufficiently large release can create an oxygen-deficient atmosphere. Because argon is denser than air—and a cryogenic release initially produces a very cold, dense gas—the proximity of the R-1 neighborhood immediately south of Manhattan Beach Boulevard makes the off-site consequence question worth resolving quantitatively.

The attached memorandum therefore does not assume simultaneous failure of all four vessels and does not attempt to establish an evacuation zone. It asks whether the appropriate reviewing agency has evaluated, or will evaluate, a credible single-vessel catastrophic release using the actual tank inventory and site conditions, and determine the resulting oxygen-deficiency/protective-action distances.

One difficulty apparent from the hearing is that responsibility for this installation is distributed among several regulatory functions. Planning is addressing the height variance; Building and RBFD have their respective responsibilities; and hazardous-materials review appears to reside principally with LA County Fire/HHMD-CUPA.

That division of responsibility may be entirely appropriate, but from the standpoint of the surrounding residents it makes it difficult to determine which agency evaluates the off-site consequences of a catastrophic cryogenic release and how that analysis becomes part of the overall safety review.

Accordingly, I would appreciate HHMD's assistance in answering the questions in the attached memorandum, particularly:

For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, what analysis establishes the distance and direction at which oxygen concentrations remain above applicable oxygen-deficiency/protective-action criteria under reasonably conservative meteorological and site conditions, including at the R-1 residences south of Manhattan Beach Boulevard?
I am copying the City and Planning Commission because these questions arose directly from the public hearing and the answers should be useful to Commissioners, City staff, the applicant, and the surrounding residents. The hearing itself reflected substantial interest in obtaining additional information concerning these issues; one Commissioner specifically raised the possibility of continuing the matter to allow additional information and public outreach.

Thank you for your assistance. Our objective is straightforward: to identify the agency with the relevant technical responsibility, obtain the appropriate analysis, and give the surrounding residents and City decision-makers a clear factual basis for understanding the off-site emergency implications of the proposed installation.

Regards,
Mark Nelson
944
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request 945
PUBLIC COMMENT 05 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, September 24, 2026 at 4:55 PM

SUBJECT
Public Comment: The City has an Obligation to
Consider Surrounding Property Value Diminution
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
946
From: Mark Nelson (Home Gmail)
To: CityClerk; Mike Witzansky; Joy Ford; Sean Scully; Scott Behrendt; Andrew Winje; Marc Wiener; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Nick Biro; Zein Obagi Subject: Public Comment: The City has an Obligation to Consider Surrounding Property Value Diminution Due to Zoning Variance at Impulse Space
Date: Thursday, September 24, 2026 4:55:46 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

The City of Redondo Beach has expressly made the protection of property values, neighborhoods, and public health, safety and welfare purposes of its land-use regulations—not merely matters of resident preference. The Municipal Code states that Planning Commission Design Review exists to “protect property values,” prevent neighborhood blight and deterioration, promote sound land use, and protect the City’s health, safety and welfare; it further requires review of a project's relationship to its surroundings and its integration and compatibility with the neighborhood. RBMC §10-2.2502.

The Code likewise provides that conditional uses are reviewed to ensure that they do not adversely affect surrounding uses and properties, RBMC §10-2.2506, and a variance may be granted only upon the specific findings required by §10-2.2510—including circumstances particular to the property and assurance that the variance does not confer a special privilege unavailable to similarly zoned properties.

Accordingly, where these provisions apply, the City cannot properly treat a demonstrated adverse effect on neighboring residential property values as legally irrelevant: protection of those values is an expressly stated objective of the City's own development-review framework and must be considered together with neighborhood compatibility, surrounding-property impacts, and health, safety and welfare in making the findings required for approval. This does not mean that the City guarantees any homeowner a particular market value or that evidence of diminution, standing alone, necessarily requires denial of a project; rather, it means that where the applicable Code makes protection of property values and surrounding properties part of the governing purpose or approval criteria, credible evidence of such impacts is relevant evidence that the decision-maker should address in applying those standards and making the required findings. 947
PUBLIC COMMENT 06 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Friday, September 25, 2026 at 8:01 AM

SUBJECT
Public Comment - LA County Fire on Redondo Beach's
obligations for permitting hazard review
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
948
From: Mark Nelson (Home Gmail)
To: CityClerk; Mike Witzansky; Joy Ford; Sean Scully; Scott Behrendt; Andrew Winje; Marc Wiener; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Nick Biro Subject: Public Comment - LA County Fire on Redondo Beach"s obligations for permitting hazard review Date: Friday, September 25, 2026 8:01:50 AM
Attachments: image001.png
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I intended to forward the original reply from LA County, however, Gmail placed artifacts after it. This demonstrates that the LA County Fire post permitting process requires the safety analysis to be conducted PRE-PERMITTING by RBFD and RB health and safety. The City cannot defer its permitting process on fire and safety to LA County Fire for the Impulse Space variance. The City is obligated to determine the hazards along with mitigations prior to permitting or providing a variance.
---------- Forwarded message ---------
From: Fernando Florez <[email protected]> Date: Mon, Sep 14, 2026 at 3:00 PM
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cry 6-0595)
To:

Cc: do.org>, Mario Tresierras
<[email protected]>, Mauricio Nunez Florez <[email protected]>
Good afternoon, Mr. Nelson.

Our Health HazMat’s Emergency Operations Section can assist with conducting an off-site 949
consequence plume modeling for the proposed Argon gas.

If you have any questions, please feel free to contact me by phone at 818-534-7633.

Reminder: Potentially hazardous physical situation that does not have any reported HAZMAT/HHMD Review. Basic mass transfer equations have a significant rupture of a 12,000 gallon tank of LAR rolling into the neighborhood. Residents deserve to know the plan and the City of RB/RBFD is pointing squarely at LA County Fire. Please advise. We are sending a certified communication since time is wasting before the next Redondo Beach permitting meeting.
---------- Forwarded message ---------
From: Mark Nelson (Home Gmail)
Date: Fri, Aug 21, 2026 at 1:55 PM
Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
To: <[email protected]>, <[email protected]> Cc: Scott Behrendt <[email protected]>, Mike Witzansky <[email protected]>, Andrew Winje <[email protected]>, Joy Ford <[email protected]>, Marc Wiener <[email protected]>, Sean Scully <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, org>, <[email protected]>, Mark N
@redondo.org; [email protected]; [email protected]; [email protected] rg; [email protected]; Mark N
Subject: Fwd: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
951
PUBLIC COMMENT 07 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Friday, September 25, 2026 at 10:11 AM

SUBJECT
Public Comment - Neither Impulse Space nor City Staff
Met the Burden of the Requested Variance

SUPPORTING MATERIALS INCLUDED
- Impulse Proposed Resolution and Process Defects
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
952
From: Mark Nelson (Home Gmail)
To: CityClerk; Mike Witzansky; Joy Ford; Sean Scully; Scott Behrendt; Andrew Winje; Marc Wiener; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Nick Biro; Zein Obagi Subject: Public Comment - Neither Impulse Space no City Staff Met the Burden of the requested Variance and it Must be Denied
Date: Friday, September 25, 2026 10:11:27 AM
Attachments: Impulse Proposed Resolution and Process Defects.pdf CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

The facts are quite clear. The resolution prepared by staff was largely rebutted by the proponents sworn testimony. Other assertions assume that IC-1 should deserve all the privileges of I-1, which is clearly not true. See attached exhibit. 953
Material Evidentiary Defects in Proposed Resolution No. 2026-09-PCR-11
Assertion from City's Resolution
(Staff Proposed Findings)
Rebuttal / Evidentiary Defect
(Hearing Record)
Point I: Strict adherence to the zone district’s 30-foot height limit would "eliminate the ability of the property owner to use the property for the existing
manufacturing facility."
Impulse testified that smaller tanks were feasible
and already in use. Denial of the variance would
mean using "more tanks" and doing an impact
assessment, not an inability to operate.

Point II: The technical requirements of the required
infrastructure cannot be accommodated at a lesser
height without resulting in significantly more frequent deliveries.

Impulse conceded smaller tanks were feasible.

Staff acknowledged the larger tank simply "met their
needs," which is an operational preference, not a
technical impossibility.

Point III: A compliant-height infrastructure would
result in "significantly more frequent deliveries."
No quantitative delivery analysis (e.g., annual
consumption, delivery frequency, traffic effects) was
provided to support the magnitude of "significantly."
Impulse admitted the impact was "hard to quantify
exactly."
954
Assertion from City's Resolution
(Staff Proposed Findings)
Rebuttal / Evidentiary Defect
(Hearing Record)
Point IV: Additional deliveries have the potential for
the "greatest impact" on the adjacent residential
neighborhood.
"Greatest" is a comparative claim, yet there is no
comparative study evaluating the impacts of
38-foot tanks versus 30-foot tanks. Residents
explicitly requested data and traffic studies, which
were absent.

Point V: Physical hardships justify relief from the
standard height restriction to afford the property the
same development privileges as nearby properties with
a "similar zoning designation."
The applicable variance criterion requires
"identical zone designation," not "similar." The
resolution improperly uses more permissive
development standards of differently zoned I-1
property to invent a privilege for the IC-1 parcel.

Point VI: Because surrounding industrial properties
(with 100+ foot height limits) accommodate the same
aerospace manufacturing uses, this property should be
permitted similar physical development heights.

Similarity of use does not establish similarity of
development entitlement. The distinct zoning
height limits (30 feet vs 100+ feet) mean the
properties are not subject to identical development
standards.

Point VII: The variance does not constitute a special
privilege because similar infrastructure is found on
The standard requires comparison to properties
under the same zoning designation, not a 110-foot
limited I-1.. Comparing to differently regulated I-1
955
Assertion from City's Resolution
(Staff Proposed Findings)
Rebuttal / Evidentiary Defect
(Hearing Record)
"similarly situated properties with similar General Plan and Zoning designations."
property does not establish what constitutes a
privilege for the IC-1 parcel.

Point VIII: (Implied Focus) The focus of the findings
shifted to the adverse effects of the alternative
equipment (e.g., more trucks) rather than justifying the departure from the 30-foot height limit.

The variance must justify departing from the
30-foot standard. The findings fail to establish that
the additional 8 feet of tank height would have no
visual or land-use impact on adjacent R-1 residential
properties.

Point IX: (Implied by Approval) Neighborhood
operational effects from the variance were sufficiently established to justify the factual findings.

Proposed conditions required a post-approval
noise report and potential future mitigation (like a
wall), demonstrating that important operational
effects were unmeasured and not yet established as
factual findings.

Point X: The statements within the resolution's
findings are sufficient to legally justify the variance.

The evidentiary defects go directly to the core
rationale for the variance. The rejected resolution's
findings should not acquire factual status just
through repetition without new supporting
evidence.
956
PUBLIC COMMENT 08 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Friday, September 25, 2026 at 12:16 PM

SUBJECT
Public Comment: Allowing Tanks that Pierce the
30-foot Limit Will Create Industrial Property
Devaluation
The following pages contain the comment as received, followed by any supporting materials.

Non-government email addresses and personal phone numbers have been permanently redacted.
957
From: Mark Nelson (Home Gmail)
To: CityClerk; Mike Witzansky; Joy Ford; Sean Scully; Scott Behrendt; Andrew Winje; Marc Wiener; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Nick Biro; Zein Obagi Subject: Public Comment: Allowing Tanks at Impulse that Pierce the 30-foot Limit Will Create and Industrial Property Devaluation
Date: Friday, September 25, 2026 12:16:23 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Industrial Visibility and Residential Property Values
Study-by-Study Summaries from the Prior Research Workbook Focus: industrial visibility, vertical structures, viewsheds, proximity effects, and reported property-value diminution
How to Read This Review
This document summarizes the Industrial Visibility / Residential Property Value research, focusing on direct industrial/view evidence, vertical-structure/viewshed methodology, general industrial-proximity evidence, and contrary/boundary evidence.

Summary
For the Redondo Beach fact pattern, the economically relevant change is not merely that an industrial use exists nearby. The proposed analytical exposure is the change from an industrial use substantially contained within a common 30-ft development envelope to vertically prominent equipment at roughly 38 ft or higher that will become visible and identifiable from residences where the industrial use otherwise would not be apparent. The combined literature therefore supports testing a project-specific visibility/proximity effect. 1 - Direct industrial/view

Principal finding: Distance to an industrial site has a statistically significant negative effect on residential values; effect is largely localized and varies with industrial-site size.

Important limitation: Does not separately estimate the coefficient attributable only to visual recognition or protruding equipment.

Primary source: https://doi.org/10.1080/00343401003601925 Additional source: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1398803 958

2. Estimation of the Influence of View Components on High-Rise Apartment Pricing Using a Public Survey and GIS Modeling
Authors: Ian D. Bishop; Eckart Lange; Alani Muhammad Mahbubul Publication: Environment and Planning B: Planning and Design 31(3):439-452 (2004) Study setting: Views containing parks, water, industry and high-rise buildings Method: GIS determines what is visible and the proportion of each land use/structure in the view; survey estimates willingness to pay
Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Demonstrates that industry can be treated as an explicit component of the visible scene and valued separately from mere proximity.

Relevance to the 38-ft tank / skyline issue: Direct support for the proposition that 'industrial visible in the viewshed' is a measurable housing attribute.

Important limitation: Willingness-to-pay/view study rather than transaction-price study of detached R-1 homes.

Primary source: https://doi.org/10.1068/b3042

3. A Sight for Sore Eyes: Assessing the Value of View and Land Use in the Housing Market
Authors: Andrea Baranzini; Caroline Schaerer
Publication: Journal of Housing Economics 20(3):191-199 (2011) Study setting: 13,000 Geneva dwellings; natural and built environment Method: 3-D GIS view measures at dwelling level plus hedonic rental model Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.

Principal finding: Both land use and what is actually visible significantly affect rents; working-paper version reports natural views raise rents while views of built environment lower rents.

Primary source: https://doi.org/10.1016/j.jhe.2011.06.001 Additional source: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=981189

Principal finding: Study includes an industrial-plant-view variable; reported results indicate negative effects for industrial-plant views in portions of the market.

Relevance to the 38-ft tank / skyline issue: One of the closest studies to the proposition that seeing an industrial facility is itself a negative housing attribute.

Important limitation: High-density Hong Kong housing market; effect is not a transferable percentage for Redondo Beach.

Primary source: https://doi.org/10.1080/02664763.2016.1238053

5. Viewshed effects and house prices: Identifying the visibility value of the natural landscape
Authors: Authors as listed by publisher
959
Publication: Landscape and Urban Planning 238:104818 (2023) Study setting: Repeated house sales; Haifa, Israel
Method: Automated GIS viewsheds; spatial hedonic/panel models; separates visibility from proximity Reported diminution: No single transferable percentage diminution was reported in the prior workbook summary.