CITY OF REDONDO BEACH
APPLICATION FOR APPEAL
TO THE CITY COUNCIL
RE: 2026-0595 Impulse space vanance
(case number and name
Address/Location of subject Property 2417 Manhattan Beach BIrd (if applicable)
Decision-making body that made the decision which is the subject of the appeal:
Planning Commission
Harbor Commission SEP 28 2026 PM4:59
• RECD CITY CLERKS OFF.
Public Amenities Commission
Planning Director
Board of Appeals/Uniform Code
Date of decision: 9/17/25 Appealing: • Approval f Denial Name of Appelant Impulse space, inc.
seen rice 2651 manhattan Beach Bled kedondo each it
(805) 467-8573
Telephone Number of Appellant
Email Adress of Appellat. [email protected] moh
Signature
For office use only:
Appeal Fee Paid $ Date Received by.
Notice to: City Council City Manager City Attorney _ _Planning Department Harbor Department
Other
RETURN TO:
Office of the City Clerk
415 Diamond Street
Redondo Beach, CA 90277
(310) 318-0656
This appeal is made pursuant to the following Redondo Beach Municipal Code Section(s) (see page 3 for a partial listing of City's municipal code appeal provisions):
RBMC 0/0-2.2510(9) vanances
Ground(s) for Appeal:
Please specify the grounds for this appeal. Where an approval /denial involves multiple entitlements/actions, please specify which entitlements/actions are contested in this appeal (e.g. Conditional Use Permit) and the specific grounds for contesting each entitlement/action.
Appellant is responsible for reviewing and complying with the relevant appeal procedures contained in the City's municipal code or state law, which may contain additional substantive and/or procedural requirements depending upon the nature of the appeal. It may be necessary for appellant to supplement this form with additional pages/information to fulfill these requirements. Issues not raised here will not be considered by City Council.
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The following list provides a brief overview of some of the City's Municipal Code Appeals (to City Council) by topic area. This is not intended to be an exhaustive list. Potential appellants are advised to review the Municipal Code Sections to determine applicability of these sections and for additional appeal procedures and appeal content requirements.
For example, California Environmental Quality Act (CEQA) Appeal Procedures are contained within Redondo Beach Municipal Code, Title 10, Chapter 3, Section 10-3.901. CEQA Appeals (1) must be filed within ten [10] days of the decision-making body's action and contain specific information described in 10-3.901, (2) require the appellant to notify the project applicant of the appeal within ten [10] days of the City's action by certified mail (and provide the City a copy of the mail receipt), (3) require appellants to file any additional documentation (such as presentations) with the City Clerk no later than seven [7] days before the public hearing, and (4) require appellant to mail a copy of any additional documentation (such as presentations) to the applicant no later than seven [7] days before the public hearing by certified mail (and provide the City a copy of the mail receipt at the public hearing).
Redondo Beach Municipal Code Section General Topic Area for Appeal RBMC § 3-14.04 Encroachment permits
RBMC § 3-7.1906 Temporary Street Closure
RBMC § 4-11.146 Oil Wells-Notices to Comply
RBMC § 4-15.07 Registration of Canvassers, Solicitors, itinerant Merchants, Salesmen, and Peddlers
RBMC § 4-17.12 Amusement and Entertainment Permits
RBMC § 4-18.11 Removal of Abandoned, Wrecked, Dismantled, or Inoperative Vehicles from Private or Public Property
RBMC § 4-26.09 Bingo Games for Charitable purposes-Appeals of revocations to the Council
RBMC § 5-2.206 Weeds, Rubbish, and Stagnant Water
RBMC § 8-2.10 Uniform Transient Occupancy Tax
RBMC § 10-1.506 Subdivisions
RBMC §S 10-1.906(a), 10-1.1011 Subdivisions
RBMC § 10-2.2500(g) Administrative Design Review
RBMC § 10-2.2502(g) Planning Commission Design Review
RBMC § 10-2.2504(f) Zoning Amendments
RBMC § 10-2.2505(f) General Plan and Specific Plan amendments RBMC § 10-2.2506(g) Conditional Use Permits
RBMC § 10-2.2507(f) Administrative Use Permits
RBMC § 10-2.2508(I)
RBMC § 10-2.2510(g)
RBMC § 10-2.2514(i) Planned Development Review
RBMC § 10-2.2520(f)
RBMC § 10-3.901 California Environmental Quality Act
RBMC § 10-4.601 Certificate of Appropriateness by the Preservation Commission RBMC § 10-5.2500(g) Administrative Design Review [Coastal Zone] RBMC § 10-5.2502(g) Planning Commission Design Review [Coastal Zone] RBMC § 10-5.2504(f) Zoning Amendments [Coastal Zone]
RBMC § 10-5.2505(f) General Plan and Specific Plan amendments [Coastal Zone] RBMC § 10-5.2506(g) Conditional Use Permits [Coastal Zone] RBMC § 10-5.2507(f) Administrative Use Permits [Coastal Zone] RBMC § 10-5.2508(I) Modifications [Coastal Zone]
RBMC § 10-5.2510(g) Variances [Coastal Zone]
RBMC § 10-5.2514(i) Planned Development Review [Coastal Zone] RBMC § 10-5.2520(f) Temporary Use Permits [Coastal Zone] RBMC § 10-5.2222 Coastal Development Permit
RBMC § 11-2.10(d) Public Utilities
RBMC § 11-3.608(b) Cable TV-Liquidated damages
RBMC § 1-4.01 General Appeal Procedures* only applicable if there are no specific appeal procedures provided for the challenged action.
RBMC § 2-9.712 General Appeal Procedures [Harbor Commission]* only applicable if there are no specific appeal procedures provided for the challenged action.
2026-0595 Impulse Space Variance: Appeal Justification
About Impulse Space:
Impulse Space was founded in 2021 with the mission to accelerate our future beyond Earth.
Impulse builds spacecraft that pick up where launch providers drop off-delivering payloads between orbits. This includes delivering cargo from lower Earth orbit (LEO) to deep space orbits, Moon, Mars, and beyond. Our spacecraft are paving the way to a robust orbital economy and unlocking the true space age with reliable, affordable, fast, and easy in-space mobility.
Impulse Space was founded by Tom Mueller, the first employee and CTO of Propulsion at SpaceX and is led by a deep bench of highly experienced engineers from NASA, JPL, the United States Space Force, the United States Air Force, and wide range of commercial aerospace companies. Impulse has been operating in Redondo Beach since 2023 in a 60,000 sq/ft facility.
We are grateful for the City's welcoming of us over the last three years - we are proudly carrying forward this City's tradition of aerospace engineering.
Impulse Space has been using cryogenic storage of Liquid Nitrogen and Liquid Argon in Redondo Beach since 2023, in compliance with local, state, and federal regulations. As our business grows, our consumption of these materials will necessarily increase leading to the request before the Council. Impulse Space respectfully submits this appeal of the Planning Commission's denial of our requested 8-foot height land use variance, to exceed the 30-foot height limit for the installation of four cryogenic bulk storage tanks at 2477 Manhattan Beach Boulevard.
The requested variance is justified per the variance criteria in section RBMC § 10-2.2510(b) given the unique circumstances of the property, the consistency of this request with the authorized use of the property, and the alignment of the variance request with the objectives of the City's General Plan. A denial of this variance would result in an undue burden on Impulse's core operations, directly affecting its ability to grow while functioning safely and in accordance with established development standards.
Impulse Space's request for this variance is driven by the technical, operational, and regulatory requirements, rather than convenience or preferred design, of the 38-foot tanks. The proposed 38-foot tanks are standard industrial equipment whose dimensions are determined by required storage capacity, engineering requirements, and safety standards associated with bulk cryogenic systems as set by the manufacturer in accordance with the local, state, and federal requirements.
The height, orientation, and location of these vessels cannot be materially reduced or relocated without impacting their intended function, required access, and compliance with applicable safety requirements.
Impulse Space has evaluated alternatives to requesting an 8-foot variance from the City including alternative tank location, size, and orientation. Each instance is either not possible 1 based on the physical characteristics of the property or pose unnecessary increased risk and undue burden to Impulse's operations and ability to grow.
The 38-foot tank is an industry standard, and there is not a standard alternative 30-foot tank because of the specific technical and operational needs of the tank as designated by the manufacturers. Requiring Impulse to order 30-foot tank would require Impulse to order specialized, custom equipment that lies outside of the manufacturer's recommendations for this type of operations. Further, with significant strains on the aerospace supply chain, Impulse estimates a minimum 1+ year lead time for this item. Requiring specialized, smaller tanks would also lead to an increased number of refueling cycles. While each cycle is conducted safely under established procedures, a higher number of operations naturally introduces additional safety considerations. As we make continuous effort to support our neighboring community, we offer that smaller tanks would lead to noisier operations requiring more frequent refueling, with more trucks coming in and out of our facility. Each of these instances increase the risk portfolio and are inconsistent with the best technical, operational, and safety requirements that guide our company. Alternative orientations of the tanks are not consistent with the manufacturer's recommendation for tank operations around filling. Put another way, we offer to City Council that we are requesting this 8-foot variance because the safest option for scaling our operations is aligned with the best technical, operational, and regulatory requirements.
At Impulse Space, our mission relies on an unwavering commitment to the safety of our employees, our facilities, and our community. Safety is fundamental to who we are as a company, to our success as a business, and to our responsibilities as a proud aerospace manufacturer in Redondo Beach. Our success to date has been possible only because of a strong safety culture, and we cannot reach our next stage of growth, or uphold the proud tradition of aerospace manufacturing, without sustaining that commitment to the daily safety of our employees, facilities, and community.
In keeping with this commitment, our proposed installation will undergo rigorous, multi-layered review by the relevant authorities, which we have outlined here: Before the tanks are cleared for operations, the Redondo Beach Building & Safety Division and Fire Department will conduct a detailed plan review process in which staff will evaluate the proposed installation for compliance with the California Building and Fire Codes and applicable National Fire Protection Association (NFPA) standards and certifications, including site conditions, structural foundations and attachment details/requirements for the tanks, required clearances, tank specifications, pressure- relief systems, and emergency shutoffs. The Building & Safety Division and Fire Department will note any deficiencies and return the plans to the applicant for corrections.
Following approvals, the Building & Safety Division and Fire Department will conduct field inspections to verify that the installation complies with the approved plans and applicable fire and life-safety requirements. During the inspection, the Fire Department will verify that the cryogenic tank's capacity, manufacturer information, and certifications match the approved plans 2 and that the tank has no visible damage, corrosion, or leaks. Staff will also verify required separation distances from buildings, exits, air intakes, and property lines. In addition, the business must submit a hazardous materials business plan to the California Environmental Reporting System (CERS), which triggers a notification to the local Certified Unified Program Agency (CUPA). Upon notification, the CUPA Agency (Los Angeles County Fire Department) will conduct a hazardous materials inspection within 30 days to verify compliance with all applicable hazardous materials requirements.
1. Special Circumstances Applicable to the Property
There are "special circumstances" applicable to this project are created by the property's unique physical characteristics.
Due to the unique circumstances of the property, no alternative location on Impulse's property could accommodate the required tanks. Impulse's property is positioned on the corner of Manhattan Beach Boulevard and Redondo Beach Boulevard. There is a fire lane along the backside of the property that must remain clear and a bordering business on the Eastern side of the property which does not allow room for tanks. Accordingly, Impulse's proposal places the tanks in the sole location on our property that could accommodate the required tanks.
2. The Variance Does Not Constitute a Grant of Special Privilege The variance does not constitute a special privilege, as it is consistent with the existing industrial use and maintains compliance with the intent of the zoning district; these conditions support granting the 8-foot variance request.
The authorized use in Redondo Beach's General Plan for Impulse Space's property is "aerospace manufacturing." This is the same as the surrounding industrial properties, including one aerospace manufacturing facility which has been in operation for 60+ years. The General Plan land use designation for Impulse Space's property is Industrial-Commercial (IC-3). The adjacent property immediately west of the subject property and also fronting Manhattan Beach Boulevard and the properties immediately adjacent to and north are all zoned Industrial (I-1).
But in this unique instance, the zoning development standards for Impulse Space (1-3) are significantly more restrictive than those of all the surrounding neighboring industrial properties.
Nearby properties with the same authorized uses, including a competing aerospace manufacturer, utilize bulk cryogenic storage tanks with Liquid Nitrogen and Liquid Argon that exceed 100 feet in height, more than triple the existing 30-foot limit being applied to Impulse Space. These larger nitrogen tanks have been in operation for decades, and do not represent a new burden or danger to the neighbors. The strict application of the zoning provisions therefore deprives Impulse Space from privileges already enjoyed by other property in the vicinity for the same "aerospace '2024 PLANredondo; Land Use Element, City of Redondo Beach General Plan 3 manufacturing" authorized use. In this specific instance, the General Plan and zoning use designations illustrate a unique inconsistency.
Liquid Nitrogen and Liquid Argon are necessary materials across aerospace manufacturing and are commonly stored in large tanks in the neighboring vicinity. Accordingly, granting an 8-foot variance does not constitute a special privilege because it would not grant development rights unavailable to other similarly situated properties with similar General Plan and Zoning designations.
3. The Variance Supports, and Does Not Conflict With, the General Plan Granting this variance supports the General Plan's objectives of responsible economic development (Policy LU-6.1) and business retention and expansion (Policy LU-6.12). Liquid Nitrogen and Liquid Argon are necessary materials to aerospace manufacturing, and we are scaling our consumption of these materials as we grow. By allowing Impulse Space to install the proposed bulk cryogenic storage tanks, the City is allowing the standard industrial support infrastructure necessary to expanding our operations.
Further, the granting of this variance supports the General Plan's objective to maintain existing employers within the North Redondo Tech District (SPA-1). As a growing employer within the North Redondo Tech District, our request is aligned with the City's stated objectives to support a thriving jobs center of innovation.
Thus, the variance aligns with and does not conflict with the City's General Plan. The variance is fully consistent with the General Plan's goals for supporting industrial innovation and sustaining employment in designated industrial districts.
Conclusion:
The requested 8-foot height variance fully satisfies every required finding under RBMC Section 10-2.2510(b), and Impulse Space respectfully asks the City Council to overturn the Planning Commission's land-use variance request denial. The special circumstances and authorized use of the property, the consistency of the request with established industrial uses in the surrounding area, and the clear alignment with the City's General Plan collectively demonstrate that approval of this variance is both warranted and appropriate. Impulse Space has shown that no feasible alternative to the proposed installation exists without imposing an undue burden on safe, compliant operations or compromising required technical, engineering, and safety standards.
Granting this variance is not a special privilege. It simply enables Impulse Space to operate under the same conditions afforded to neighboring industrial users with similar authorizes uses.
Approving this appeal supports an established employer in the North Redondo Tech District, supports responsible economic development, and helps sustain the City's tradition of aerospace innovation, which Impulse Space is proud to uphold. Impulse is committed to the safety of our employees, facilities, and community, and an approved 8-foot height variance does not waive or 4 replace any applicable safety, fire, building, hazardous-material, pressure-vessel, or occupational-safety requirements. Impulse has met these standards throughout our existing operations and will continue to do so as a committed partner of Redondo Beach.
For these reasons, Impulse Space respectfully requests that the City Council overturn the Planning Commission's denial and grant the 8-foot height variance necessary for continued successful, safe, compliant, and scaling operations at 2477 Manhattan Beach Boulevard.