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Attachment 9 – Public Comments

Redondo Beach City Council
October 6, 2026

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Attachment 9 – Public Comments
Meeting
October 6, 2026
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Redondo Beach City Council
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Text extracted from the city's file for reading and search. Open the original on redondo.legistar1.com. That file is the official record.

CITY OF REDONDO BEACH CITY COUNCIL APPEAL RECORD
October Appeal to CC -
Public Comments
2477 Manhattan Beach Boulevard
Case No. 2026-0595

COMPLETE PUBLIC-COMMENT RECORD
45 distinct email submissions
Chronological by original public sender within each meeting section AUGUST 20 PLANNING COMMISSION 16 comments
SEPTEMBER 17 PLANNING COMMISSION 18 comments
OCTOBER CITY COUNCIL APPEAL 11 comments
Duplicate source files excluded; supporting materials retained with the parent email October 2026 CITY OF REDONDO BEACH AUGUST 20 PLANNING COMMISSION
Planning Commission Public
Comments
Meeting Date: August 20, 2026
Agenda Item J.1 - Case No. 2026-0595

PUBLIC COMMENT COMPILATION
16 distinct email submissions
Original public-sender dates: August 6 - August 20, 2026 Emails are arranged by the original public sender's date and time. Non-government email addresses and personal phone numbers are permanently redacted. 2477 Manhattan Beach Boulevard Case No. 2026-0595
PUBLIC COMMENT 01 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Roxanne Ferebee

ORIGINAL SENT
Thursday, August 6, 2026 at 4:34 PM

SUBJECT
Re: IMPULSE INDUSTRIES
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.

From: Roxanne Ferebee
To: Marc Wiener
Cc: Scott Behrendt; James Light; Mike Witzansky; Quality of Life; Steven Giang Subject: Re: IMPULSE INDUSTRIES
Date: Thursday, August 6, 2026 4:34:27 PM
Attachments: image001.png
You don't often get email from Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

August 6/2026,
Good Afternoon,
I would like to follow up on your offer of scheduling a meeting, to go over some current concerns that are happening across the street from our homes.

There seems to be a lot of activity regarding Impulse Industries with no community outreach, information or any contact information.

I have looked at past City Council meetings and I can not find any early discussions on this project that appeared in our area.

It would be nice to have some knowledge and answers when we reach out to the city, when this type of construction and development is going to happen in our neighborhood. For several months I have been reaching out to the city and have been told to call/email this person, that person, and just recently I was advised to NOW reach out to the planning department. I approached our planning commissioner in district 5, and he was not aware of this project. Who in the planning department has the answers and why couldn't I have been advised to reach out to that contact months ago?
This is not just a simple business moving in after a similar business moved out.

These are major changes to the structure of the current property - walls, windows, doors, lighting and the change of the type of work that will be done at the property.

Impulse Industries clearly states they will do their hot testing (Rocket engines) in the Mojave desert, however, they also state that they will be doing testing at the new Redondo Beach 60,000 square-foot facility
The site discusses:
-Vibration testing
-Heat testing (not rocket boosters) but products being assembled to withstand extreme heat -Cooling testing for products to withstand extreme freezing temperatures.

What about the installment of a half dozen new electrical transformers, and new grotesquely large AC units across the rooftops, visibly noticeable to accommodate the electrical surge for extreme heat and cooling testing of products. What liquids will be stored over there.

With 3 Major warehouse fires in the last few months, what precautions are being made for safety?
Warehouse fire and Garden Grove scare test CA chemical safety Garden Grove chemical leak plant faces lawsuits, supply disruption - Los Angeles Times And with the notice of an increase (several hundred employees), how are they going to accommodate the parking for workers.

We are now daily having numerous employees parking in the neighborhood at astonishing numbers.

As a 25 year resident, seeing 30+ extra cars parking on your residential street and dozens of strangers walking by our yards is a high alert safety concern.

Too much has been going on over at the location, with little information from the city.

Roxanne
On Mon, Jul 20, 2026 at 1:07 PM Marc Wiener <[email protected]> wrote:

Hi Roxanne,
The City has been working closely with Impulse Space on this project. The activities at this facility will primarily consist of product and component assembly, similar to their existing facility in Redondo Beach. The rocket testing occurs at their facility in Mojave Desert and will not take place at the facility in Redondo Beach. Impulse Space is working on an information brochure that they will be circulating to the neighborhood soon. I am happy to speak with you sometime this week about the project.

Marc Wiener, AICP
Community Development Director
310.697.3185
[email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From: Lorena Soules <[email protected]>
Sent: Monday, July 20, 2026 9:36 AM
To: Roxanne Ferebee
Cc: James Light <[email protected]>; Mike Witzansky <[email protected]>; Marc Wiener <[email protected]>; Scott Behrendt <[email protected]>; Daisy Canales <[email protected]>
Subject: RE: IMPULSE INDUSTRIES
Good morning Roxanne,
Thank you for your follow-up email and for taking the time to share your concerns regarding the construction activity and the Impulse Industries project. I appreciate your patience while I gathered information.

Regarding your concerns about employee parking and whether the project is providing adequate parking, these matters fall under the City's Planning Division and are governed by the Redondo Beach Municipal Code parking regulations. For questions regarding parking requirements, land use approvals, or conditions of approval associated with this project, please contact the Project Planner:

Steven Giang, Senior Planner
Email: [email protected]
Phone: (310) 697-3696
Mr. Giang will be able to discuss the applicable parking requirements, any planning-related approvals associated with the project, and answer questions regarding the approved land use.

If you are interested in learning more about the project, the approved construction plans are public records and are available for review at City Hall. Mr. Giang can review the approved plans with you and discuss the project, including the approved use and any applicable Planning conditions.

With respect to your concern regarding construction activity beginning at approximately 6:00 a.m., the City's permitted construction hours are enforced through Code Enforcement and the Police Department. If you observe construction occurring outside the permitted hours, I recommend contacting the Redondo Beach Police Department Non-Emergency Dispatch at (310) 379-2477 while the activity is occurring. Reporting it at the time of the occurrence allows the incident to be documented and investigated appropriately.

Regarding the construction signage, the City does require that construction projects post signage identifying the contractor and providing contact information. I appreciate your feedback that it would also be helpful for nearby residents to have contact information for the project owner or owner's representative. I will reach out to the project team and request that the primary project contact, in addition to the contractor's information, be included on the project signage to improve communication with the surrounding neighborhood.

I understand the neighborhood's interest in learning more about the future operations of the business. Questions regarding the approved use of the property, operational activities, and any Planning approvals are best directed to the Planning Division, as they oversee the land use entitlements and conditions associated with the project.

Thank you again for bringing these matters to the City's attention. We appreciate residents taking the time to report concerns so they can be directed to the appropriate department for review.

Sincerely,
Lorena Soules, CBO, CASp
Building Official
310.697.0636
[email protected]
For further assistance contact [email protected] or call 310-318-0636.

Please take our short survey so that we can understand how to better serve you (click here).

From: Roxanne Ferebee
Sent: Friday, July 17, 2026 4:45 PM
To: Lorena Soules <[email protected]>
Cc: James Light <[email protected]>; Mike Witzansky <[email protected]>; Marc Wiener <[email protected]>; Scott Behrendt <[email protected]>; Daisy Canales <[email protected]>
Subject: Re: IMPULSE INDUSTRIES
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello,
I am checking back for a follow up regarding my email.

There remain numerous concerns about the ongoing construction and development across the street with the business Impulse Industries.

We remain concerned about the lack of information regarding the business, what their operations will be, the parking issues for the employees, and the massive changes to the nature of the warehouses across the street from Redondo Beach residential homes, to accommodate "space industries operations"
We still have construction being done in violation of city codes. Yesterday 7/16/2026, we had jack hammering and other construction work start at 6am. My neighbor physically walked over to the site at 615 am, looking for a supervisor. None was able to be found. She approached the security guard at the gate and asked about the sign that states "Construction hours" and she states they just shrugged their shoulders.

The work stopped until she left the site, then they started right back up.

We also are continuing to have our streets being impacted with Impulse employees parking here.

We would also like to have a better understanding what type of work will be done across the street close to our homes.

Residents here are concerned by - what we see being done to the warehouse site and the changes being made to a simple storage warehouse -to accomodate what Impulse Industries manufactures and the types of testing that is needed for their business.

Why have the residents in this neighborhood not been advised of what the situation is.

I can find no discussion to the community of this, by the city, or of any notice to the residents.

We have reached out to the city a few times and are still waiting for some information on how we can be assured we will not be victims of a massive toxic warehouse fire, as seen in the latest news, or be exposed to toxic waste, heat, vibrations and noise.

Impulse Industries own websites discusses the "testing" they will be doing at their "new RB location", and it is unclear how all the changes being done to that location and the inhouse testing expected to be done, is not going to affect the homes across the street.

Please help provide some follow up information.

Thank you
Roxanne
On Wed, Jul 1, 2026 at 4:05 PM Lorena Soules <[email protected]> wrote:

Roxanne,
Your email is received, I will respond soon.

Thank you,
Lorena Soules, CBO, CASp
Building Official
310.697.0636
[email protected]
For further assistance contact [email protected] or call 310-318-0636.

Please take our short survey so that we can understand how to better serve you (click here).

From: Roxanne Ferebee
Sent: Wednesday, July 1
To: Lorena Soules <[email protected]>
Cc: James Light <[email protected]>; Mike Witzansky <[email protected]>; Marc Wiener <[email protected]>; Scott Behrendt <[email protected]>; Daisy Canales <[email protected]> Subject: IMPULSE INDUSTRIES
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good Afternoon,
I have an additional concern regarding the ongoing process of Impulse Industries located on Manhattan beach blvd in North Redondo beach.

We have begun to notice a number of additional vehicles parking in our neighborhood that are not in - anyway - associated with the residents who live here. This is an immense concern.

It was known that on the Manhattan Beach "front street" that runs east / west between Gibson and Mcbain - had become a huge parking lot for the Impulse employees located across the street at 2651 MBBLVD.

Six months ago myself and a neighbor counted the cars parked on that side street and as a homeowner 25+ years of living and daily walking our neighborhood, we have a very strong "knowing' of who's cars belong to which houses on our streets. We counted 27 cars parked there that were not from the homes on that street.

With Impulse expanding over to the new area at 2425 MBBLVD we are NOW seeing Impulse employees parking on Sebald and walking over to the warehouses. I asked the workers if there was a problem with parking due to the ongoing construction and they said - There just is not enough parking and to contact the CEO Tom Mueller.

Doesn't the city and planning assess this during the application and permitting process. I have watched and attended enough city council meetings and watched the city express concerns and guidelines with new construction and the parking requirements.

While our streets are public, this is a safety and quality of life issue impacting our homes in Redondo Beach.

Does Impulse have no obligation to provide adequate parking for its employees and are not getting the grilling and scrutiny regarding parking concerns like many other applicants are forced to abide by.

If this is a temporary matter due to ongoing construction / remodeling work, over there - we can be patient, but 5 cars turn into 10, then 20, then 30, then 40.

Also curious why are they not obligated to put some contact information up to call, like a construction manager? owners rep?)
Also is there any information on when we can expect the construction process to be close to being somewhat completed?
Thanks for your help
Roxanne
Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email.

Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email.

PUBLIC COMMENT 02 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Roxanne Ferebee

ORIGINAL SENT
Thursday, August 6, 2026 at 5:46 PM

SUBJECT
Fwd: neighbors concerned about Impulse Industries
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.

From: Jamaal Brown
To: ‘Sean Scully Cc: ‘Mare Wiener Subject: FW: neighbors concerned about Impulse Industries Date: Thursday, August 6, 2026 5:51:28 PM Attachments: imaaeQO1.ona
Jamaal Brown
Planning Analyst
310.697.3142
Please complete our short Customer Service Survey if you would like to share your experience with management and help us improve our services! @%& REDONDO == BEACH Business Hours: 7:30AM-5:30PM
Please note: City Hall is closed holidays and every other Friday From: Roxanne Fereh:>
Sent: Thursday, August 6, 2026 5:46 PM
To: Jamaal Brown <[email protected]>
Subject: Fwd: neighbors concerned about Impulse Industries You don't often get email {rom III Lcarn why this is important | reached out to the city this am for information on how to email our Planning Commisioner / District 5 Roger Light.

He lives several blocks from us in North Redondo (TRW) tract and | spoke to him regarding some concerns and he asked that | send him some information. | called the Planning office and was told to reach out to you? lam forwarding an email for him, please advise if this is the correct process to have this information sent to him.

To Dr. Light,
We spoke last week regarding some concerns about Impulse Industries and the building and expansion of the business located on MBBLVD.

There were a number of issues you asked me to send to you - but - there is no direct RBemail for you (per the Planning office - and | was advised to email this person as a liaison?)
| have many concerns, and NOW...
we just received a public hearing notice on this matter coming to you at the next Planning commission meeting.

Please reach out to me via email, | would love to come by and discuss this - and say hello to Dr. Lori.(it's been awhile, | cc'd an old email address) Roxanne
text a
weseeenn= Forwarded message ---------
From: Roxanne Ferebee is
Date: Thu, Aug 6, 2026 at 5:24 PM
Subject: Fwd: neighbors concerned about Impulse Industries To: Scott Behrendt <[email protected]>
cece ncnne Forwarded message ---------
From: Roxanne Ferebee
Date: Thu, Aug 6, 2026 at 5:22 PM
Subject: neighbors concerned about Impulse Industries
To: <[email protected]>
For several months, | have reached out to the city and elected officials regarding Impulse Industries.

There has been an unsatisfactory response on providing the information to residents when they need to know when a large business corporation is embarking on a massive restructuring of the building area and the change of day to day operations, directly across the street from an entire residential community.

Of all the questions and inquiries sent to the city with minimal answers, TODAY our neighborhood received the "city of redondo beach notice of public hearing" that will be held on THIS months planning commission meeting to review a request for “a variance to exceed the 30 foot maximum height requirement:

For the installation of three 3 BULK cryogenic storage tanks with a proposed height of 38 feet at the existing facility" ie: they want to go to 4 stories.

This ?? 300 ft. from our homes? How long was the city aware of this and why was this not disclosed?
Warehouse fire and Garden Grove scare test CA chemical safet After all the inquiries, emails and calls to the city and code enforcement, related to construction without approved permits, violations of construction hours (3 am, 11pm, 5am, Sundays etc.) and violations of construction rules on the ground, digging, dust control, parking issues, and even being shut down due violations, why is this just now becoming public knowledge.

Again,
How long was the city aware of this and why was this not disclosed by anyone when we asked?
This is ridiculous, so unsafe and how did the city do this? Roxanne
Understanding Cryogenic Liquids and Storage Safety Near Residential Areas Cryogenic liquids are gases that remain in liquid form only at extremely low temperatures — below about -150 °C (-238 °F) — such as liquid nitrogen (-196 °C), liquid oxygen (-183 °C), liquid argon (-186 °C), and others like hydrogen or methane Environment, Health & Safety+1.

They are odorless, colorless, and expand into large volumes of gas when they warm to room temperature, which can create significant pressure and safety hazards.

Key Hazards
Extreme cold: Can cause frostbite or cold burns on contact with skin or equipment Environment,
Health & Safety+1.

Oxygen deficiency: Large volumes of gas released can displace oxygen, leading to asphyxiation in enclosed or poorly ventilated spaces
Environment, Health & Safety.

Pressure build-up: Rapid vaporization in sealed containers can rupture tanks Air Products.

Material embrittlement: Cold temperatures can make metals, plastics, and rubber brittle Air Products.

Flammability: Some cryogens (e.g., hydrogen, methane) are flammable; others (e.g., oxygen) can make nearby flammable materials more combustible Environment, Health & Safety.

Storage Tank Design
Cryogenic storage tanks are engineered to minimize heat transfer:

Inner vessel: Holds the liquid, made from materials strong at cryogenic temperatures.

Outer jacket: Encloses the inner vessel, often with a vacuum and multi-layer insulation to reduce boil-off www.cryogenictank.com+1.

Pressure relief systems: Valves and rupture discs prevent over-pressurization www.cryogenictank.com+1.

Ventilation: Tanks are typically located in well-ventilated areas to prevent oxygen depletion Linde.

Should They Be Near Residential Areas?
No — cryogenic storage tanks should not be located close to residential areas without strict safety controls.

Nearby homes or occupied spaces increase the risk of:

Asphyxiation if gases leak into air.

Cold injury from splashes or leaks.

Fire or explosion if flammable cryogens are involved.

Unnoticed leaks because cryogens are odorless and colorless Environment, Health & Safety+1.

Best practice:

Store cryogenic liquids in dedicated, well-ventilated, and isolated facilities away from public access.

Maintain buffer zones and perimeter controls to limit exposure.

Conduct hazard assessments and install gas detection and ventilation systems Environment, Health & Safety+1.

Follow local, state, and federal regulations for hazardous material storage.

In summary: Cryogenic liquids are essential in many industries but pose serious health and safety risks. Storage tanks should be kept away from residential ar with engineering an ministrative controls in pl. to protect ni PUBLIC COMMENT 03 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Saturday, August 15, 2026 at 7:25 PM

SUBJECT
Public Comment - Planning Commission - Permit
Application Defects - 2425/2477 Manhattan Beach Blvd
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.

From: Mark Nelson (Home Gmail)
To: CityClerk; Sean Scully
Ce: Fire-HHMDCERS@fire,Jacounty.gov
Subject: Public Comment - Planning Commission - Permit Application Defects - 2425/2477 Manhattan Beach Blvd Date: Saturday, August 15, 2026 7:25:47 PM
Attachments: RB Cryogenic Tank Permit Record Deficiency Memo,odf Planning Commission, Planning Department, RBFD, RBPD, City Attorney On behalf of a resident approximately 1000 feet or less from the permit action property, | file the following analysis and defect list of the application and materials. This application has not had proper QA/QC and must be corrected prior to wasting any more of the public's time. LA County Fire has been noticed as well. As a process note, the City should have had the public materials posted concurrent with the signage. The public was forced to waste significant time, effort and analysis guessing what the permit request entailed. As is, the current permit package and record is filled with contradictions and has lacks significant disclosures. See below. Ata minimum, the proponent and the City need to complete the punch list at the end of the memo.

Mark Nelson
Expert Witness

MEMORANDUM
TO Redondo Beach Planning Commission; Redondo Beach
Fire Department; Redondo Beach Police Department;
Redondo Beach City Attorney; Community
Development Department; Building & Safety Division
CC/ OTHER JURISDICTIONAL Los Angeles County Fire Department Health Hazardous REVIEW Materials Division / CUPA, as applicable; other
hazardous-materials and emergency-response
agencies having jurisdiction
FROM Interested public / permit-record review
DATE August 15, 2026
RE 2477 Manhattan Beach Boulevard — Case No. 2026-
0595 / PC26-1012 — Cryogenic Storage Tank Variance
SUBJECT Inconsistencies, informational shortfalls, public-safety deficiencies, and items that should be remedied before
approval

EXECUTIVE SUMMARY
The submitted package is not presently a coherent, site-specific safety record for the proposed installation. It contains material contradictions about the number of tanks, the products to be stored, and even the project address. It also omits basic information needed to evaluate the relationship between the tanks and the immediately adjacent residential neighborhood.

The most consequential defect is the absence of a readable vicinity/context map showing street names, property boundaries, surrounding land uses, residences, tank-to-property-line distances, tank-to-residence distances, emergency access, delivery routes, and the applicant's own emergency isolation distances. The Administrative Report expressly recognizes R-1 residences south of the site across Manhattan Beach Boulevard, while the safety presentation instructs responders to establish a 330-foot isolation zone for a large release or vessel damage and a one-half-mile isolation distance for a fire involving a tank. Those facts should be shown together on a single scaled map before the Commission makes findings concerning safety, neighborhood impacts, or CEQA.

The record also does not disclose the capacity, inventory, operating pressure/MAWP, manufacturer/model, relief-device discharge configuration, or U-1/nameplate data for each proposed vessel. The applicant's safety presentation repeatedly states that such vessel-specific documentation exists or is available to the Authority Having Jurisdiction, but it is not included in the public packet. Without the quantities and design data, staff and the public cannot independently verify NFPA 55 quantity-dependent requirements, setbacks, emergency planning assumptions, delivery frequency, or the consequences of a credible release.

These deficiencies do not establish that the proposed tanks are unsafe. They establish that the present record is insufficiently consistent and site-specific to support the broad safety conclusions stated in the Administrative Report and draft findings. The appropriate remedy is to require a corrected, consolidated submittal and documented review by the agencies having jurisdiction before final approval or, at minimum, before the tanks may be installed or filled.

1. Documents Reviewed
« Administrative Report, File No. PC26-1012, meeting date August 20, 2026.

Attachment 1 — Draft Planning Commission Resolution No. 2026-08-PCR-11.

Attachment 2 — Site Plan, including revision notation “Tank Relocation 8/12/26.” Attachment 3 — Project Renderings.

Attachment 4 — Bulk Cryogenic Storage Safety & Compliance Presentation, prepared by Matheson, dated June 9, 2026.
e Attachment 5— CEQA Exemption Declaration, dated August 20, 2026. e Attachment 6 — Public Comment and City correspondence.

2. Principal Record Inconsistencies
A. Tank count is inconsistent
The CEQA Exemption Declaration describes three tanks. The Administrative Report and title of the draft Resolution describe four tanks, with three initially. The Resolution's conditions attempt to reconcile this by authorizing three initially and a fourth in the future. A CEQA determination and project description should address the same project that is being approved, including the reasonably contemplated fourth tank.

Record references: Attachment 5 describes “three bulk cryogenic storage tanks”; Administrative Report describes “four (three initially)”; Draft Resolution authorizes three initially and a future fourth.

The record is sloppy and convoluted.

B. Stored products are inconsistent — and liquid oxygen appears in the safety record The Administrative Report first states that the tanks will store liquid nitrogen (LIN) and liquid argon (LAR). Its Safety section then states that the proposed storage includes liquid nitrogen, liquid argon, and liquid oxygen (LOX). The Matheson presentation is titled for LIN/LAR, but its Executive Summary and emergency instructions also refer to liquid oxygen. By contrast, the submitted site plan labels two LN2 tanks, one LAR tank, and a future LAR/LN2 tank.

This is not a clerical detail. LOX is an oxidizer with a materially different fire-risk profile from inert LIN/LAR. The approved product for each tank must be unambiguous, and any future product conversion should require prior Fire/CUPA review and any necessary land-use or environmental review.

C. Project address is inconsistent
The Planning documents identify 2477 Manhattan Beach Boulevard. The Matheson AHJ safety presentation identifies the site as “2425 Manhattan Beach.” Public correspondence also refers to 2425. The safety document therefore should be corrected and reissued for the exact parcel and installation being approved.

D. The safety presentation makes site-specific claims without supplying the site-specific proof The presentation states that NFPA 55 requirements are met or exceeded, that secondary containment will hold 110% of the largest vessel, that an emergency shutoff is accessible outside the exclusion zone, and that a site map identifies exclusion zones and emergency access. Those items are either not shown in the Planning packet or cannot be verified from the submitted plan. A conclusion of compliance should be supported by a code matrix and drawings demonstrating the applicable distances and features.

3. Missing Site Context — Critical Mapping Defect
The packet lacks a usable vicinity map with street names and surrounding uses. Attachment 2 is essentially an internal facility plan. It does not give the Planning Commission or first responders a clear neighborhood-scale depiction of the hazard source relative to the public.

At minimum, a corrected scaled exhibit should show:

Manhattan Beach Boulevard and all surrounding streets by name; the project parcel boundary and adjoining parcel boundaries; all adjacent zoning and actual land uses, with the R-1 residential area prominently identified; the location of the nearest residences and measured distances from each tank, fill connection, vent/PRV discharge point, and property line; e the 100-meter/330-foot isolation radius cited by the applicant for a large release or vessel damage;
e the 800-meter/one-half-mile isolation radius cited for a fire involving a tank, preferably as a separate emergency-planning exhibit;
¢ prevailing access points, Fire Department apparatus access, hydrants/FDC, emergency shutoff location, staging area, and HAZMAT access;
¢ cryogenic delivery truck route, on-site maneuvering/turning, unloading location, and whether a delivery vehicle blocks emergency access;
topography, drainage direction, low areas, pits, trenches, storm drains, and other locations where cold argon or nitrogen gas could accumulate;
the location and height of walls/fences and any structures that may channel or confine a vapor cloud.

4. Vessel and Inventory Information Is Missing
The public record should identify each tank as an actual engineered vessel, not merely as a 38-foot generic cryogenic tank. The Matheson presentation itself says the AHJ can review Form U-1, nameplate photographs, National Board registration, manufacturer certificates, and inspection information. Those records should be submitted before a finding of site-specific compliance. e Manufacturer, model, serial number, National Board number and ASME U-stamp. documentation for each vessel.
¢ Gross and usable capacity of each vessel in gallons and pounds; maximum inventory of LIN, LAR and any LOX.
e Normal operating pressure, design pressure, MAWP, design temperature, and relief-device set pressures/capacities.
e Exact tank diameter and overall height, foundation/anchorage design, center of gravity, and seismic design criteria.
¢ Fill connection, piping, vaporizers, valves, emergency shutoffs, relief devices, rupture discs, vent outlets and discharge elevations/directions.
¢ Product-specific Safety Data Sheets and a definitive tank/product assignment. ¢ Maximum delivery-truck inventory and transfer hose location during filling. e Expected consumption rate and substantiation for the stated approximately weekly delivery frequency.

5. Emergency Planning Is Not Adequately Connected to the Residential Setting
The applicant's own safety presentation classifies a release greater than 10 gallons as a life-safety emergency, directs evacuation and HAZMAT response, cites 330 feet as an initial isolation/downwind planning distance for LIN/LAR, and cites one-half mile for a fire involving a tank. Yet the Planning packet contains no neighborhood emergency plan, no overlay showing how many residences fall within those distances, and no documented evacuation/shelter protocol for the surrounding neighborhood.

The emergency contact page is also incomplete: the product supplier, tank manufacturer service contact, local Fire Department, and local HAZMAT team are left blank. Those blanks are inconsistent with the document's representation that it provides complete first-responder coordination.

6. Conditions of Approval Omit Several Measures Claimed in the Safety Presentation
The safety presentation lists several measures as site-specific safeguards, but the draft Resolution does not clearly make all of them enforceable conditions. Examples include:
secondary containment berm/dike sized to 110% of the largest vessel; minimum two-person rule for filling and transfer;
pre-operation checklist for every delivery/fill;
emergency shutoff accessible from outside the exclusion zone; fixed atmospheric monitoring in enclosed or semi-enclosed areas and portable monitoring where gas may accumulate;
¢ annual emergency-response training and annual cryogenic-release drill; ¢ daily visual inspections and maintenance/recordkeeping requirements; ¢ annual review/update of the safety packet upon changes in storage area, product or quantity.

If staff relies on these measures to support the safety finding, they should be incorporated expressly into enforceable conditions or into an approved safety plan incorporated by reference.

7. Fire Department / HAZMAT / CUPA Review Should Be Documented, Not Merely Described
The Administrative Report says staff consulted the Redondo Beach Fire Department and that Fire's assessment is consistent with staff's safety conclusion. The packet does not include a written Fire Department plan-review memorandum, code analysis, approval, conditions, or sign-off. For a large cryogenic installation adjacent to residences, the record should contain the actual written technical review.

Los Angeles County Fire Department is the Certified Unified Program Agency (CUPA) for most incorporated areas of Los Angeles County, with Redondo Beach identified as a participating agency in County materials. County guidance requires hazardous-material handlers above reporting thresholds to submit hazardous-material inventory, a site map, emergency response/contingency information, and training information through CERS. The City should identify on the record which agency is administering each applicable hazardous-material program for this site and document required permits/submittals before operation.

8. CEQA Documentation Contains a Material Template/Error Issue and an Incomplete Project Description
Attachment 5 states that the project is exempt under CEQA Guidelines section 15301 because it is a “negligible expansion of the existing residence.” This is an industrial aerospace manufacturing facility, not a residence. That language appears to be an uncorrected template error in the operative exemption document.

More importantly, the Exemption Declaration describes only three tanks while the proposed entitlement contemplates a fourth. It also does not discuss the unusual site circumstance that single-family residences are immediately across Manhattan Beach Boulevard, even though the applicant's emergency materials identify substantial isolation distances for large releases and tank fires. The City Attorney should review whether the exemption record adequately defines the whole project and addresses applicable exceptions to categorical exemptions before the exemption is adopted.

9. Variance Findings Need Better Evidentiary Support
The draft findings state that the tank height/location cannot be materially reduced or relocated, that no feasible location exists, that nearby facilities have comparable taller tanks, and that a lower tank configuration would cause significantly more frequent deliveries. The packet does not provide the engineering alternatives analysis, tank-sizing calculation, delivery-frequency comparison, or mapped comparison facilities needed to evaluate those assertions.

The draft Resolution also states that strict adherence to the 30-foot height limit would “eliminate the ability of the property owner to use the property for the existing manufacturing facility.” That is substantially broader than the evidence shown in the packet. At most, the materials indicate that the proposed bulk-storage configuration supports operations; they do not demonstrate that the entire 250,600-square-foot manufacturing facility cannot be used without these particular 38-foot tanks.

10. Noise and Operational Impacts Are Deferred
Staff concludes that noise is not expected to impact adjacent properties, but the Resolution requires the applicant to provide a tank-operation noise report later and allows additional mitigation after measured violations. Given the acknowledged residential frontage, the better sequence is to establish baseline and predicted noise from filling, transfer equipment, venting/PRV events, truck idling and nighttime/off-hour scenarios before operation. The condition allowing “very limited” offhour deliveries as a minor change should also define objective limits and require Fire/Planning review.

11. Public Comment Identifies Broader Operational Context That Is Not Fully Resolved
The public correspondence raises construction-hour violations, employee parking spillover, substantial facility modifications, increased electricaV/mechanical equipment, testing activities, and uncertainty about materials stored on site. City correspondence directs several of these matters to Planning and acknowledges the need for better project contact information. The Administrative Report reduces the public correspondence to concerns about employee numbers and public safety.

The Commission should receive a clearer response matrix identifying which concerns are within this variance, which are governed by existing permits, and which require separate enforcement or entitlement review.

12. Recommended Agency Responsibilities
Agency / Office Recommended documented action
Planning Commission / Planning Division Require a corrected, internally consistent project description; neighborhood context map;
substantiation of variance findings; definitive
tank count/products; and conditions
incorporating relied-upon safety measures.

Redondo Beach Fire Department Issue written plan-review findings addressing adopted Fire Code/NFPA 55, quantities,
setbacks, separation, venting, vehicle
protection, access, monitoring, emergency
shutoffs, delivery operations and emergency
response.

Redondo Beach Police Department /
Emergency Management
Review traffic/access and neighborhood
evacuation or perimeter-control implications for
the applicant's 330-foot and one-half-mile
emergency planning distances; coordinate
public warning/traffic control roles.

City Attorney Review variance findings, CEQA project
description and exemption language, including
the “existing residence” error and the
contemplated fourth tank; confirm that deferred
safety measures are enforceable.

Building & Safety Verify structural foundation/anchorage, seismic design, electrical/mechanical work, barriers,
grading/drainage and consistency of final
construction drawings with approved plans.

Los Angeles County Fire Department HHMD /
CUPA and applicable Participating Agency
Confirm hazardous-material handler status,
CERS/HMBP inventory and site-map
requirements, emergency response/contingency
plan, applicable Unified Program permits,
inspections and any CalARP applicability.

PUNCH LIST — ITEMS TO REMEDY BEFORE APPROVAL / OPERATION The following is intended as a concise completion checklist for the Planning Commission and reviewing agencies. Items marked “before approval” affect the adequacy and consistency of the entitlement record; operational items should be completed and verified before any tank is filled.

Required correction Minimum remedy

1. Correct the project description Reconcile three versus four tanks in the Administrative Report, Resolution, CEQA
Exemption and drawings. Define whether the
fourth tank is part of the present project.

2. Definitively identify tank contents State the authorized product in each tank.

Resolve all references to LOX versus LIN/LAR.

Prohibit product substitution without prior
agency review.

3. Correct the project address Reissue the Matheson safety document for 2477 Manhattan Beach Boulevard or explain the
relationship of 2425 to the project parcel.

4. Provide a neighborhood-scale vicinity map Show street names, parcel boundaries, actual surrounding uses, R-1 residences, tank locations
and measured tank-to-home/property-line
distances.

5. Overlay emergency planning distances Map the applicant's 330-foot largerelease/vessel-damage isolation area and onehalf-mile tank-fire isolation area relative to residences, streets and neighboring facilities.

6. Provide complete vessel specifications For each tank: manufacturer/model, serial/National Board number, capacity,
maximum inventory, dimensions, operating
pressure, MAWP, design temperature and
product assignment.

7. Submit vessel certification records Provide ASME U-1 data reports, nameplate photographs, U-stamp/National Board
information, certificates of conformance and
applicable inspection records.

8. Submit a site-specific NFPA/Fire Code
compliance matrix
Identify the adopted code provisions, quantity
thresholds, required setbacks/separations, and
drawing references demonstrating compliance.

9. Provide complete engineered site drawings Show foundations/anchorage, seismic design, bollards, piping, fill points, vaporizers,
emergency shutoffs, PRVs/rupture discs, vent
discharge locations, walls, fencing, drainage and
containment.

10. Resolve secondary containment
discrepancy
The safety presentation promises 110%
containment; the Administrative
Report/Resolution largely reduce this to
grading/drainage. Show the actual design and
make it enforceable if relied upon.

11. Provide gas-dispersion / oxygen-deficiency
evaluation
Evaluate credible release scenarios using actual
inventories and site geometry, including low
areas, structures, wind and potential off-site
migration toward residences.

12. Address LOX separately if LOX is
contemplated
Provide oxidizer-specific code analysis,
separation from combustibles/flammables,
oxygen-enrichment monitoring/controls, fire
exposure analysis and emergency procedures.

13. Complete the emergency-response plan Include neighborhood interface, incident comman4d, isolation/evacuation/shelter criteria,
public notification, staging, responder access,
shutdown, re-entry and recovery.

14. Complete emergency contacts Fillin product supplier, tank manufacturer/service, local Fire Department and
local HAZMAT team contacts in the safety plan.

15. Obtain written RBFD technical review Place a signed/dated Fire Department review, conditions and approval in the public record
rather than relying solely on a staff statement
that Fire was consulted.

16. Confirm CUPA/CERS/HMBP requirements Identify the administering CUPA/participating agency and document required hazardousmaterial inventory, site map, emergency/contingency plan, training and
permits.

17. Verify emergency responder access Demonstrate apparatus access, hydrants/FDC, gate access, Knox/emergency access as
applicable, staging, and access during cryogenic
deliveries.

18. Provide delivery route and transfer plan Show truck route, turning, unloading position, transfer hose, duration, frequency, traffic
conflicts, emergency access and limits on offhour deliveries.

19. Substantiate weekly delivery claim Provide tank-sizing/consumption calculations and compare delivery frequency for the
proposed 38-foot tanks versus code-compliant
alternatives.

20. Provide alternatives analysis supporting
the variance
Document why shorter tanks, different
capacities, multiple smaller vessels, or alternate
on-site locations are infeasible or materially
inferior.

21. Correct and supplement the CEQA
Exemption Declaration
Remove the erroneous “existing residence”
language; reconcile tank count/products;
accurately describe the industrial project;
document City Attorney review of categoricalexemption applicability and exceptions.

22. Tighten the variance findings Remove or substantiate the assertion that the 30-foot limit would eliminate use of the entire
manufacturing facility. Cite evidence for claimed
physical hardship and comparable properties.

23. Make relied-upon safety measures Add conditions for two-person filling, pre-fill enforceable checklist, emergency shutoff, atmospheric
monitoring, training/drills,
inspections/maintenance and annual safetyplan updates if these measures support the safety finding.

24. Complete noise analysis before operation | Measure/model filling, transfer, venting/PRV and truck noise at the residential property line; define
objective mitigation and off-hour delivery limits.

25. Provide a public-comment response Address parking, construction hours, operational matrix testing, mechanical/electrical expansion,
hazardous materials, project contacts and
enforcement responsibility; distinguish issues
inside and outside this variance.

26. Require final interagency sign-off before No cryogenic product should be introduced until first fill Planning, Building & Safety, RBFD and the
applicable hazardous-materials/CUPA authority
confirm completion of their conditions.

Source Notes
e Administrative Report, PC26-1012 (Aug. 20, 2026): project description, zoning/residential adjacency, LIN/LAR and LOX references, safety/noise discussion, Fire Department consultation statement, variance findings, CEQA conclusion.
e Draft Resolution No. 2026-08-PCR-11: four-tank title, three-initial/fourth-future condition, construction and operational conditions, site-map/noise/delivery requirements. e Attachment 2 Site Plan: tank labels LN2, LN2, LAR, future LAR/LN2; internal layout; tank relocation revision dated Aug. 12, 2026.
e Matheson Bulk Cryogenic Storage Safety & Compliance Presentation (June 9, 2026): address 2425 Manhattan Beach; LIN/LAR title; LOX references; vessel documentation; hazards; 330-foot and one-half-mile emergency planning distances; site-specific safeguards; incomplete emergency contact fields.
e CEQA Exemption Declaration (Aug. 20, 2026): three-tank project description and statement that project is a negligible expansion of an “existing residence.” e Attachment 6 Public Comment: neighborhood concerns regarding operations, parking, construction activity, testing, materials and communication. e External jurisdictional check: Los Angeles County Fire Department CUPA/Hazardous Materials Program materials and California Cal/OSHA pressure-vessel materials were consulted only to identify potential reviewing agencies and program responsibilities; final applicability should be confirmed by the City/CUPA for the specific vessels and inventories.

PUBLIC COMMENT 04 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Roxanne Ferebee

ORIGINAL SENT
Sunday, August 16, 2026 at 4:57 PM

SUBJECT

IMPULSE SPACE ASKING FOR EXEMPTION ON SAFETY
STUDIES ETC.

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.

From: ‘Sean Scully To: Sean Scully Subject: FW: IMPULSE SPACE ASKING FOR EXEMPTION ON SAFETY STUDIES ETC. Date: Thursday, August 20, 2026 12:16:25 PM From: Roxanne ere <<
Sent: Sunday, 16 August 2026 16:57:34
To: Brad Waller <[email protected]>; Chadwick B. Castle <[email protected]>; Paige Kaluderovic ee Zein Obagi <[email protected]>; Scott Behrendt <Scott. Behrendt @redondo.or:

Subject: IMPULSE SPACE ASKING FOR EXEMPTION ON SAFETY STUDIES ETC.

You don't often get email from [i Lam why this is
important
Hello City Council,
This Notice of Public Hearing was posted on the fence of the business property last week.

Many, many many (one household received a notice) neighbors have stated this was not received by residents across the street of this business.

Residents have been concerned about the retrofitting and construction activity at the site for over 8 months and have received very little data from the city when residents asked about the operations, filed complaints of violations, and are concerned of the lack of transparency and notice.

The Planning Commission will be asked on this Thursday 8/20/2026 to grant a height variance request - and- states the business is exempt from a number of important environmental, safety, fire, and other requirements due to its zoning (light industrial) and is compared to the Northrop G Space campus.

NG is a purpose built - facility - built to specifically meet the required needs of its operations.

While this warehouse is in light industrial zoning - its use has NOT been for this type of manufacturing or operations.

There has been a multitude of odd businesses throughout the years at this location. Auto parts storage, delivery and pickup (DHL, Dol&co?) furniture storage, office space, TV productions(e-ball) and NG temporarily while doing major remodeling projects to their other sites in the area. They used it for office space, mail & delivery, Trash and garbage storage, and a small design/think tank center.

Impulse Space is in the process of a major remodeling and restructuring of the entire area to accommodate their needs and has not been required to follow the guidelines most applicants are asked to meet.

We understand Impulse Space will remain in our neighborhood, and we support this business into our community but they need to meet the most stringent of requirements based on the nature of operations and be held accountable to the safety of the area.

We feel the city is being too lenient and is placing this whole area in a disaster zone.

We are asking the Planning Commissioners for a continuance on this project (as they have just received the 52+page staff report to consider action on this Thursday 8/20/2026) and to direct staff and the applicant to address the safety concerns and make safeguards enforceable.

We feel more time is needed to address the many concerns residents have been inquiring about. (The staff report will recommend an approval) Yet the report has errors, inconsistent data, lack of precise data, mapping defects, public safety deficiencies and items that should be remedied before approval.

This is an exciting and welcoming time for Redondo to have Impulse Space come to our area - BUT - the City better make sure everything is done properly, safely and wisely and not hastily.

The residents of Redondo Beach are not wanting to be impacted by something that looks negligent at this time.

Roxanne
8/16/2026
PUBLIC COMMENT 05 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Alicia Evans

ORIGINAL SENT
Monday, August 17, 2026 at 6:44 PM

SUBJECT
Public Comment RB Planning Commission Mtg 8/20 -
DEFECT LIST Impulse Space - Case No. 2026-0595
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.

Sean Scully
From: alicia evans [is
Sent: Monday, August 17, 2026 6:44 PM
To: CityClerk; Sean Scully; alicia evans
Subject: Public Comment RB Planning Commission Mtg 8/20- DEFECT LIST Impulse Space- Case No. 2026-0595
[Some people who received this message don't often get email from in Learn why this is important at https://aka.ms/LearnAboutSenderldentification ] CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello All,
| wanted to make sure that the residents of North Redondo are heard! Impulse Space has & continues to be a nuisance to the neighborhood residents and community of NRB.

However, it’s apparent the city desperately wants their business. It doesn’t care about the residents of North Redondo Beach at all. Impulse Space has clearly been a nuisance with the noise pollution of large semi trucks very early in the morning, dust and other particles polluting the air during construction and renovations, congestion of traffic, parking issues and employees parking in residential neighborhoods. The three 40 foot tanks of who knows what material is just the icing on the cake. It’s clear the city continues to sweep all of this under the rug and doesn’t even give notice to those neighborhoods involved.
limplore you to take the necessary steps & precautions regarding these tanks and not just push this through. See checklist on file below.
https://gcc02.safelinks.protection.outlook.com/?url=https%3A%2F%2Fdrive.google.com%2Ffile%2Fd%2F1RImyE9CE4 Wd FQO108R306BiVOkUVO9pg%2Fview&data=05%7C02%7CSean.Scully%40redondo.org%7C4b7022f139bf4893 fod608defc ca34c4%7C08ea6101a7cb4984aff676e3d00172d'%7C0%7C0%7C639226142769150954%7CUnknown%7CTWFpbGZsb3d 8eyJFbXBOeU1hcGkiOnRydWUsIIYiOilwLjAUMDAWMCISIIAiOUXaW4zMilsIkFOljoiTWFpbClslldUIjoyfQ%30%3D%7C80000 %7C%7C%7C&sdata=V%2FGWMi1LOFQw8P8m0%2B%2B3jmiBv4ckhSOxp1UfYVyRouPE%3D&reserved=0 Regards,
Alicia Evans
Sent from my iPhone
DEFECT LIST — ITEMS TO REMEDY BEFORE APPROVAL
The following is intended as a concise completion checklist for the Planning Commission and reviewing agencies. Items marked “before approval” affect the adequacy and consistency of the entitlement record; operational items should be completed and verified before any tank is filled.

Required correction Minimum remedy
T. Correct the project description Reconcile three versus four tanks in the Administrative Report, Resolution, CEQA Exemption and drawings, Define whether the fourth tank is part of the present project.

2. Definitively identify tank contents State the authorized product in each tank. Resolve all references to LOX versus LIN/LAR. Prohibit product substitution without prior agency review.

3. Correct the project address Reissue the Matheson safety document for 2477 Manhattan Beach Boulevard or explain the relationship of 2425 to the project parcel 4, Provide a neighborhood-scale vicinity map Show street names, parcel boundaries, actual surrounding uses, R- I residences, tank locations and measured tank-to-home/propertyline distances.

3. Overlay emergency planning distances Map the applicant's 330-foot large-release/vessel-damage isolation area and one-half-mile tank-fire isolation area relative to residences, streets and neighboring facilities.

6. Provide complete vessel specifications For cach tank: manufacturer/model, serial/National Board number, capacity, maximum inventory, dimensions, operating pressure, MAWP., design temperature and product assignment
7, Submit vessel certification records Provide ASME U-I data reports, nameplate photographs, U- stamp/National Board information, certificates of conformance and applicable inspection records.

8. Submit a site-specific NFPA/Fire Code compliance matrix Identify the adopted code provisions, quantity thresholds, required setbacks/separations, and drawing references demonstrating compliance

9. Provide complete engineered site drawings Show foundations/anchorage, seismic design, bollards, piping, fill points, vaporizers, emergency shutoffs, PRVs/rupture discs, vent discharge locations, walls, fencing, drainage and containment.

10. Resolve secondary containment discrepancy The safety presentation promises 110% containment; the Administrative Report/Resolution largely reduce this to grading/drainage. Show the actual design and make it enforceable if relied upon.

TI. Provide gas-dispersion / oxygen-deficiency evaluation Evaluate credible release scenarios using actual inventories and site geometry, including low areas, structures, wind and potential off-site migration toward residences.

12. Address LOX separately if LOX is contemplated Provide oxidizer-specific code analysis, separation from combustibles/flammables, oxygen-enrichment monitoring/controls, fire exposure analysis and emergency procedures.

13. Complete the emergency-response plan Include neighborhood interface, incident command, isolation/evacuation/shelter criteria, public notification, staging, responder access, shutdown, re-entry and recovery.

14. Complete emergency contacts Fill in product supplier, tank manufacturer/service, local Fire Department and local HAZMAT team contacts in the safety plan.

15. Obtain written RBFD technical review Place a signed/dated Fire Department review, conditions and approval in the public record rather than relying solely on a staff statement that Fire was consulted.

16. Confirm CUPA/CERS/HMBP requirements Tdentify the administering CUPA/participating agency and document required hazardous-material inventory, site map, emergency/contingency plan, training and permits.

17. Verity emergency responder access Demonstrate apparatus access, hydrants/FDC, gate access, Knox/emergency access as applicable, staging, and access during cryogenic deliveries.

18. Provide delivery route and transfer plan Show truck route, turing, unloading position, transfer hose, duration, frequency, traffic conflicts, emergency access and limits on off-hour deliveries.

19. Substantiate weekly delivery claim Provide tank-sizing/consumption calculations and compare delivery frequency for the proposed 38-foot tanks versus code- compliant alternatives.

20. Provide alternatives analysi upporting the variance Document why shorter tanks, different capacities, multiple smaller vessels, or alternate on-site locations are infeasible or mater inferior

21. Correct and supplement the CEQA Exemption Declaration Remove the erroneous “existing residence” language; reconcile tank count/products; accurately describe the industrial project:
document City Attorney review of categorical-exemption applicability and exceptions.

Tighten the variance findings Remove or substantiate the assertion that the 30-foot limit would eliminate use of the entire manufacturing facility. Cite evidence for claimed physical hardship and comparable properties. 23, Make relied-upon safety measures enforceable ‘Add conditions for two-person filling, pre-fill checklist, emergency shutoff, atmospheric monitoring, training/drills, inspections/maintenance and annual safety-plan updates if these measures support the safety finding. 24, Complete noise analysis before operation Measure/model filling, transfer, venting/PRV and truck noise at the residential property line; define objective mitigation and off- hour delivery limits.

25. Provide a public-comment response matrix ‘Address parking, construction hours, operational testing, mechanical/electrical expansion, hazardous materials, project contacts and enforcement responsibility; distinguish issues inside and outside this varianee.

26. Require final interagency sign-off before first fill No cryogenic product should be introduced until Planning, Building & Safety, RBFD and the applicable hazardousmaterials/CUPA authority confirm completion of their conditions.

PUBLIC COMMENT 06 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Gary Mlynek

ORIGINAL SENT
Tuesday, August 18, 2026 at 10:24 AM

SUBJECT
Re: Planning commission meeting 8-20-2026
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.

From: ‘Sean Scully
To: “gary mlynek"
Cc: Marc Wiener; Daniel Besinaiz Subject: RE: Planning commission meeting 8-20 -2026 Date: Tuesday, August 18, 2026 11:40:00 AM Attachments: image001.ona
Hello Mr. Mlynek,
You are very welcome. | do understand your concerns. We worked very hard with our Fire Department and the applicant to ensure the project is safe.

These projects can seem like a “surprise” sometimes. The City’s Zoning Ordinance and State Laws are very specific concerning when a project is “noticed” to the public prior to a public hearing. The “public noticing” is one of the last steps before the actual public hearing. It’s set up this way because sometimes we’re not sure the project will advance until very late in the review process and we don’t want to send out public notices on a project that may change significantly or not happen at all.

In this case the Planning Commission is the approval authority for the Variance. The only way the City Council would rule on this project is if the decision of the Planning Commission is appealed.
| hope this answers all your questions. Thank you.

Sean Scully
Planning Manager
310.697.3194
[email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
a REDONDO
= BEACH
From: gory ck
Sent: Tuesday, August 18, 2026 10:24 AM
To: Sean Scully <[email protected]>
Cc: Mare Wiener <Marc.Wiener @redondo.org>; Daniel Besinaiz <[email protected]> Subject: Re: Planning commission meeting 8-20 -2026
Thank you for the response and the good info. Greatly appreciated.

I can not attend the meeting this week but do know a few people who say they will be there. Some of the folks here in Dow/Johnson area just feel
like it was sort of a quick & secretive decision. Doesnt it have to go to City Council before a final decision is reached ? Thanks again.

On Tuesday, August 18, 2026 at 09:08:12 AM PDT, Sean Scully <[email protected]> wrote:

Good morning Mr. Mlynek,
You absolutely have a say in the proposed tank installation. I'm providing a link below to the Planning Commission Agenda Packet which includes City staff's analysis (Community Development and Fire Department) of the proposed project (Height Variance) that includes a "safety analysis". These tanks are proposed to be filled with liquid Argon and Nitrogen. Both of these gasses are chemically non-flammable inert noble gases that will not ignite and cannot undergo a chemical combustion explosion. That said, we've extensively reviewed this project with our Fire Department and they will be available to answer questions concerning the safety of the proposed tanks and any potential hazards at the public hearing scheduled for Thursday night at 6:30 PM. I've also included a link to register and attend the meeting by Zoom.

If you wish to discuss the project further after reviewing the staff report or have any additional questions please call me at the number below.
https://redondo.legistar.com/LegislationDetail.aspx?ID=8 173340&GUID=0F5901BE-0C57-44FD-BC2AAZ540F5988C6 htt dondo.zoomgov.com/webinar/register/WN_GikHDB7kQBKhf_sQY4PWai Thank you.

Sean Scully
Planning Manager
310.697.3194
sean,[email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
-----Original Message-----
From: gary mlynek
Sent: Monday, August 17, 2026 10:07 PM
To: Sean Scully <[email protected]>
Subject: Planning commission meeting 8-20 -2026
[You don't often get email from’ Learn why this is important at https://aka.ms/LearnAboutSenderldentification ]
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Dont the citizens get a say in the 4 tanks that will be placed across the street from the Dow-Johnson triangle. ? | think we should.

The gasses & chemicals could be & probably are dangerous & deadly if they escape. Seems like this decission is putting us in this area in a very precarious situation.

W.Gary Mlynek Dow Ave R.B.

Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email.

PUBLIC COMMENT 07 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Nick Biro

ORIGINAL SENT
Tuesday, August 18, 2026 at 12:48 PM

SUBJECT
Re: PC Agenda Item 2026-0595
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.

From: Nick Biro
To: Daniel Besinaiz
Cc: ‘Sean Scully; Marc Wiener; Rox Ferebee; Scott Behrendt; Lorena Soules Subject: Re: PC Agenda Item 2026-0595 Date: Tuesday, August 18, 2026 12:48:52 PM | You don't often get email from [NNN Learn why this is important Hi Daniel,
Thank you - my e-comment is below.

Please continue the hearing and direct staff to complete, publicly circulate, and obtain written agency approval of the missing project-specific safety and environmental record before taking final action. Require a written Community Development Director and City Attorney determination under RBMC §10-2.1020 identifying the proper entitlement path, including whether CUP review must supplement the height variance. This request does not ask the City to prejudge or deny the project; it asks for an informed decision and enforceable residential protections.

Material gaps:
e Three versus four tanks: the CEQA declaration and original notice describe three; the staff report and resolution approve four, with the fourth deferred to a later installation.
e Gas identity: the project description says nitrogen and argon, while the safety discussion also refers to liquid oxygen. Oxygen would present a materially different oxidizer hazard and code pathway.
e Wrong/template text: the safety presentation names 2425 Manhattan Beach Boulevard and labels itself a boilerplate to be verified before AHJ submission; the CEQA declaration says the project expands an “existing residence.” © Moving design: the site plan bears “Tank Relocation 8/12/26,” but the record does not explain the change, provide a full parcel plan, or show exact distances to residential property and dwellings.
© Deferred verification: the draft requires Fire notification, a noise report and possible mitigation after approval rather than written agency approval and predictive analysis before the land-use decision.
e Emergency planning distance: the applicant’s own safety presentation cites an initial 330-foot isolation/downwind planning distance for a large nitrogen or argon spill—approximately the reported separation to residences—yet no neighborhood protective-action analysis is provided.

No approval should rest on future studies or undefined phrases such as “normal business hours,” “very limited,” “may be required,” or “as required.” Each condition should identify the duty, responsible reviewer, deadline, objective standard, required evidence, inspection method, public record, correction period and consequence of noncompliance On Tue, Aug 18, 2026 at 12:32 PM Daniel Besinaiz <[email protected]> wrote: Hi Nick, I'm sorry to hear you're having difficulty with the e-comment system. I've forwarded your contact information to the City Clerk's Office so they can look into the issue.

In the meantime, if you would like, you are more than welcome to submit your public comment directly to me by email. Comments submitted this way will also become part of the public record.

LT hope this helps. | will keep you updated on what the City Clerk's Office may suggest for your e-comment account. Please feel free to reach out if you have any other questions.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | daniel [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From:

Sent: Tuesday, August 18, 2026 11:26 AM
To: Daniel Besinaiz <[email protected]>
Ce: Sean Scully <[email protected]>; Mare Wiener <Mare. [email protected]>; Rox Ferebee Subject: PC Agenda Item 2026-0595
[You don't often get email a Learn why this is important at me — https://aka.ms/Lea: enderldentification | CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good morning Daniel,
I am trying to post an e-comment for the subject agenda item and I have not received the email authentication required to confirm my account in order to submit the comments.

Could you please let me know if there is an issue with the system or can you help me with creating an account?
Thanks,
Nick
Sent from my iPhone
Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email. icholas J. Biro
PUBLIC COMMENT 08 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Alicia Evans

ORIGINAL SENT
Tuesday, August 18, 2026 at 1:31 PM

SUBJECT
Issues leaving a comment for meeting on August 20th
regarding 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.
fod Outlook
RE: Issues leaving a comment for meeting on August 20th regarding Impulse Space (North Redondo Beach Residents want to be HEARD)!!. Fwd: Your Granicus Support Case #08472010 Has Been Created
From Daniel Besinaiz <[email protected]>
Date Wed 8/19/2026 9:54 AM
To alicia evans i James Light
<[email protected]>; Planning Redondo <[email protected]>; Sean Scully <[email protected]>
Hi Alicia,
Thank you for your comments and interest in this project. Staff is working to address the issue is with the e-comment system. In the meantime, all public comment received via email is being entered into the public record and will be added to the agenda for the public to have access to.

Please let me know if you have any questions.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | daniel. besinaiz(@redondo.org
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Sent:

From:

Tuesday,
alicia evans
August
ia
18, 2026 1:31 PM
To: Daniel Besinaiz <[email protected]>; alicia evans James Light <[email protected]>; Planning Redondo <[email protected]>; Sean Scully <[email protected]> Subject: Issues leaving a comment for meeting on August 20th regarding Impulse Space (North Redondo Beach Residents want to be HEARD)!!. Fwd: Your Granicus Support Case #08472010 Has Been Created Some people who received this message don't often get email from [III [cam why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello All,
| want to make sure that our voices are represented & some of the neighbors are having issues with the website. They can’t access it to leave a comment. Some will be unable to physically attend the meeting and want to be able to have a say in North Redondo Beach.

I'm asking for a continuation as a Redondo Beach resident. | want a continuance from the Planning Commission. As more time is needed to read, understand these impacts and have safety measures, noise measures, traffic measures, parking measures, and evacuation concerns addressed by The City of Redondo Beach as well as Impulse Space.

The proposed installation is not adequately defined or reviewed in the public packet. | do not support this, because there are no current environmental reviews and safeguards in place.

Regards,
Alicia Evans
Sent from my iPhone
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To:

Subject: Your Granicus Support Case #08472010 Has Been Created Ld
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PUBLIC COMMENT 09 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Katherine

ORIGINAL SENT
Wednesday, August 19, 2026 at 10:23 AM

SUBJECT
Public Comment: OPPOSE/CONTINUE Item 2026-0595 -
Impulse Space Cryogenic Tanks
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.

From: Katherine
To: Daniel Besinaiz
Cc: ‘Sean Scully; Marc Wiener; Ferebee; Rox Scott Behrendt; Lorena Soules Subject: Public Comment: OPPOSE/CONTINUE Item 2026-0595 - Impulse Space Cryogenic Tanks (Manhattan Beach Blvd) Date: Wednesday, August 19, 2026 10:23:45 AM You don't often get email ror III carn why this is important Dear Chair and Members of the Redondo Beach Planning Commission, My name is Katherine Strohlein, and I am a 31 year resident of Redondo Beach. I am speaking tonight regarding the proposal by Impulse Space to install three (or four) bulk cryogenic storage tanks at their Manhattan Beach Boulevard facility.

While we support technological innovation, our neighborhood is already bearing a massive industrial burden. Directly across the street, Northrop Grumman operates enormous industrial gas storage tanks that are regularly filled and vented.

Surrounding residents know firsthand how incredibly loud and disruptive that highpressure gas venting noise is. Furthermore, Northrop operates extremely bright industrial lighting that bleeds directly into our neighborhood, disrupting our sleep and our quality of life. And their facility is located further away from our homes than what is being proposed tonight.

What is deeply alarming is that Impulse Space is slating these new cryogenic tanks to be 38 feet high and positioned even closer to local homes—literally a matter of mere yards away from families’ backyards. Tanks of this height and volume pose unique structural and chemical hazards. We cannot look at this application in a vacuum. The City must evaluate the cumulative impact of adding three more highcapacity infrastructure units directly adjacent to a residential zone.

The operational safety of this facility is paramount to our neighborhood. Therefore, I request that the Planning Commission continue this item tonight and direct city staff and the applicant to return only after they have fully addressed three critical concems with legally binding Conditions of Approval that can be strictly enforced by the city:

First, regarding Physical Safety and Hazard Zones:

A 38-foot vertical tank acts as a top-heavy lever in a seismic zone, and an insulation failure can trigger a catastrophic pressure explosion or unleash heavy asphyxiation clouds mere yards from our families’ yards. As an enforceable condition of approval, will the city mandate a formal Quantitative Risk Assessment to map the blast and oxygen-displacement radiuses, and require an independent Seismic Bracing Audit to guarantee that a 38-foot structural failure cannot breach the residential property line?
Second, regarding Bulk Truck Deliveries and Operations: Filling these tanks requires massive, multi-axle industrial semi-trucks that bring heavy diesel idling, backup beeps, and low-frequency rumbling. Furthermore, the transfer of cryogenic liquids involves high-pressure open-valve venting that generates a sustained, loud roaring and hissing noise. Because industrial gas suppliers often run 24/7 to avoid highway traffic, our neighborhood faces the reality of sleep-disrupting deliveries at 3 AM. We request a strict, enforceable condition of approval banning all cryogenic truck deliveries, transfers, and related operations between the hours of 6 PM and 7 AM.

Third, regarding Cumulative Noise and Environmental Proximity:

Given that residents are already subjected to the disruptive venting from Northrop Grumman, what will the combined acoustic impact be once Impulse adds three more towering tanks? We request an enforceable condition requiring continuous, real-time noise monitoring with automatic fines if they violate the Redondo Beach Noise Ordinance during overnight hours.

Fourth, regarding Light Trespass and Security Illumination:

Because our neighborhood is already blinded by Northrop’s bright lights, we request an explicit condition of approval mandating zero light trespass at the residential property line, requiring fully shielded downward, north-facing fixtures, and prohibiting any direct glare from shining over into our neighborhood.

Commissioners, please do not approve this blanket permit tonight. Please continue this meeting and require staff to draft airtight, enforceable conditions of approval that protect our community's safety, peace, and health.

Thank you for your time, leadership, and dedicated service to Redondo Beach.

Sincerely,
Katherine Strohlein
PUBLIC COMMENT 10 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Alexander Hawkins

ORIGINAL SENT
Thursday, August 20, 2026 at 11:29 AM

SUBJECT
Cryogenic Storage Tank approval
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.

From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Cryogenic Storage Tank approval Date: Thursday, August 20, 2026 11:47:17 AM Attachments: image001.pnq Hi Jamaal,
See below public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected] daniel
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From: Alexander Hawkins (i
Sent: Thursday, August 20, 2026 11:29 AM
To: Daniel Besinaiz <[email protected]>
Subject: Cryogenic Storage Tank approval
You don't often get email from II Lear why this is importa attachments or links.

Dear Planning Commission,
lam a Redondo Beach resident in District 5, writing regarding Agenda Item J.1 and the proposed cryogenic storage tanks at 2477 Manhattan Beach Boulevard. | request that the Planning Commission continue this item rather than take final action today, August 20. This will allow residents and the Commission sufficient time to fully understand the proposal and address several inconsistencies and unanswered questions in the current materials.

While the staff report and attachments contain extensive technical information, they were released shortly before the hearing. They also appear to contain errors and leave important project-specific questions unresolved.

Before final approval, | ask the Commission to direct staff to:
- Correct and clarify the approval documents and inconsistencies in the record. - Complete and publicly provide the project-specific safety and environmental information needed to understand the impacts of this installation. - Obtain the appropriate written agency and Fire Department review of the final proposal.
- Clearly identify the substances and quantities that will be stored, ensuring the approval is limited to what is actually being considered. - Make the safety measures and operating safeguards relied upon in approving the project enforceable conditions, rather than simply statements in supporting materials. - Address impacts on the immediately adjacent residential neighborhood, including safety, emergency response, noise, deliveries, traffic, and parking.

Installing large bulk cryogenic storage tanks next to a residential neighborhood warrants aclear, complete, and internally consistent public record before the City grants the requested variance. A continuance will allow all parties to resolve outstanding questions and make an informed decision with appropriate protections in place.

Thank you for your consideration and for allowing residents to participate in this process. Please confirm receipt of this comment.

Regards,
Alexander Hawkins
Alexander Hawkins
PUBLIC COMMENT 11 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Janet

ORIGINAL SENT
Thursday, August 20, 2026 at 12:58 PM

SUBJECT
Public Comment - Impulse Facility
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.

From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Public Comment - Impulse Facility Date: Thursday, August 20, 2026 1:31:57 PM Attachments: image001.pnq
Hi Jamaal,
See below for public comment. I’m about to send you two more after this.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
ar REDONDO
== BEACH
From: Janet cy
Sent: Thursday, August 20, 2026 12:58 PM
To: Daniel Besinaiz <[email protected]>
Subject: Public Comment - Impulse Facility
You don't often get email from III [carn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good Afternoon,
My name is Janet Scully, and I have been a North Redondo Beach resident in District 5 for more than 30 years.

I am asking the Planning Commission to continue this hearing to allow additional time for the Commission, staff, and the community to fully review and understand the staff report and the proposed project.

Given that this facility is proposed within 500 feet of an established residential neighborhood, I believe the project warrants careful and thorough review. There appear to be issues and inconsistencies in the current report, as well as questions about whether all appropriate environmental studies and safety considerations have been adequately addressed. These issues should be resolved before any approval is granted.

I am also asking that City staff engage directly with the local community so residents have a clear understanding of what is being proposed and how the facility will operate so close to their homes. Residents deserve to understand the potential risks, applicable safety requirements, environmental reviews, monitoring, and regulations that will govern this facility.

A continuance would provide the necessary time for a more complete review and meaningful community understanding of the proposal.

Thank you for considering this request.

Janet Scully
as
PUBLIC COMMENT 12 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Tala Schwindt

ORIGINAL SENT
Thursday, August 20, 2026 at 1:17 PM

SUBJECT
Public comment for today's agenda
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.

From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Public comment for today’s agenda Date: Thursday, August 20, 2026 1:32:02 PM Attachments: imaqe001.pnq Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
a REDONDO
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From: Tala Schwindt
Sent: Thursday, August 20, 2026 1:17 PM
To: Daniel Besinaiz <[email protected]>
Subject: Public comment for today’s agenda
You don't often get email from II Lear why this is important To whomever it may concern,
My name is Tala Schwindt and | live in North Redondo Beach in district 5. | would like to ask the planning commission to please ask for a continuance of the meeting regarding the approval of Impulse’s request to add the cryogenic storage tanks. We believe there are inconsistencies in the existing report and not adequate environmental reviews considering the impact it will have on our community. There are a few measurable enforcements that |’d like to see in place before we blanket approve the report as is. It is across the street from so many young families and we must ensure their safety. Thank you for your consideration!
Tala
Sent from Gmail Mobile
PUBLIC COMMENT 13 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Janine Villa Sison

ORIGINAL SENT
Thursday, August 20, 2026 at 1:25 PM

SUBJECT
Comments for Public Hearing

SUPPORTING MATERIALS INCLUDED
- FILE PC26-1012 - Written Public Comment
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.

From: Daniel Besinaiz To: Jamaal Brown Subject: FW: Comments for Public Hearing Date: Thursday, August 20, 2026 1:32:17 PM Attachments: FILE PC26-1012.pdf
image001.pnq
Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
ar REDONDO
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From: Janine Villa Sison [is
Sent: Thursday, August 20, 2026 1:25 PM
To: Daniel Besinaiz <[email protected]>
Subject: Comments for Public Hearing
You don't often get email from [MM Learn why this is important Hi Daniel,
We were instructed to send comments your way regarding PC26-1012, since the E comments are not working properly. I've attached my comments for tonight's meeting.

Our neighbors also have a list of questions that we feel are unanswered by the packet released. | want to submit these, in addition to the comment, in case they can either be answered tonight, or by the commission in the coming weeks. -Can we have tank contents clarified? Administrative report mentions Oxygen, but the Impulse safety report and site map only show Argon and Nitrogen. -Can the contents change in the future? If so, is Impulse required to notify anyone, and whom?
-Will/can any CEQA exemptions and variances granted tonight be used as precedent for future decisions regarding Impulse or other companies zoned IC? -Has SCE been notified or surveyed the site? Are they required to be? They have large equipment operating less than 150 ft from the proposed tank installation. -Safety level of this project is mentioned in several places as "subject to compliance".

Who is monitoring this compliance?
-When does Impulse expect vibration testing, that is being supported by these tanks, to begin?
-Who do we reach out to for tank certification information mentioned in the safety presentation?
-Where is the secondary containment site being located? -Why does the site plan say "Tank Relocation". Are there already tanks onsite? -How will the community be alerted in the event of an emergency? -No mention of plans or safety regarding seismic events were included in the presentation. Do we have that information?
-How are lost parking spaces being replaced during construction and long term? Thank you.

Best,
Janine
Janine M Villa Sison
Cl ae
FILE PC26-1012
Aug, 20th 2026
We are requesting a stay of approval re: height variance and environmental exemption for 30 days to allow the Planning Commission time to consider greater community input, clarify all and any questions, and reevaluate potential impact of this project on the neighborhood. We are also requesting facilitation for a community meeting between Impulse and the community at large to allow for a Q&A session. We acknowledge the commission’s resolutions in Section 2, but ask for quantified/qualified limits to be included for clearer enforcement (ie. normal business hours, acceptable decibel of noise, etc.) We would like to see application and clerical errors corrected before any approvals or exemptions are made, as would be expected of any other application (Safety presentation has a different location listed, public hearing notice listed 3 tanks and proposal is actually 4, Site plan is missing many of the required measurements and annotations, included required safety grading, measurements to street and residential neighborhoods, location of required impact barriers, location of secondary containment site, etc)

CEQA EXEMPTION
Our view on the ruling is that the logic is loose and largely interpretive. Literal interpretation of the text, “The key consideration is whether the project involves negligible or no expansion of use”, bears consideration, as it was used as recently as June 2026 by the CA Supreme Court in the case of Sunflower Alliance v. Department of Conservation (2024) to overturn CEQA exemptions granted. The planning commission reasons that Impulse cannot continue use of their facilities without allowing a variance for the 38 foot tanks. How were they in business for 2+ years at the same location without these tanks? One could reason it is because the tanks are a new requirement for operation, and therefore an expansion of use (addition of vibration testing). Site plans show 25ft subterranean ancillary equipment for the tanks, and a secondary containment site for 110% of stored materials is also required. Plus the addition of potential sound wall construction and the tanks themselves. One could reason this is not “negligible”.

HEIGHT VARIANCE
We understand the case made for this project to be granted the same privilege as Northrop Grumman, and many of the Planning Commission points are valid. If these comparisons continue to be made as grounds for approvals, we ask to city to hold Impulse accountable to the same standards as Northrop, including issues regarding CEQA exemptions and adherence to zoning characteristics listed in 10-2,100 of city code, including: (f) Minimize the impact of industrial and commercial uses on adjacent residential zones; (g) Ensure the provision of adequate off-street parking and loading facilities.

Regardless of your decision, it needs to be stated that it shouldn’t matter that I-1 businesses nearby are less strict in zoning. Residents purchased properties knowing they are adjacent to an I-C zone, not an Industrial Zone. The burden should not be on the community to accommodate an Industrial business that CHOSE to move into a zone that cannot accommodate or sustain their business activities, regardless of what “type” of business they are. Similar zoning, is not the same zoning.

We urge you to consider the balance of the needs of the community with the needs of Impulse in a more thoughtful way. We know they’ve already paid the city more than a quarter million dollars in permitting fees since 2025, but that does not absolve them from proper proceedings.

Janine and Michael Villa Sison
North Redondo Beach residents
PUBLIC COMMENT 14 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Hilary Nash

ORIGINAL SENT
Thursday, August 20, 2026 at 1:50 PM

SUBJECT
Continuance requested for cryo storage tanks for
Impulse
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.

From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Continuance requested for cryo storage tanks for Impact Date: ‘Thursday, August 20, 2026 1:58:25 PM Attachments: image001.pnq Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | daniel [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
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From: Hilary N2sh
Sent: Thursday, August 20, 2026 1:50 PM
To: Daniel Besinaiz <[email protected]>
Subject: Continuance requested for cryo storage tanks for Impact You don't often get email from [iE Learn why this is important Hello,
| live at [IY Redondo Beach CA 90278 and I’m requesting a continuance for the cryogenic storage tanks at IMPACT on Mb Blvd and Dow Ave.

We as residents need more time to learn about these tanks and see if there are risks to our health and safety.

Thank you,
a
Hilary Nash
PUBLIC COMMENT 15 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
Cherise

ORIGINAL SENT
Thursday, August 20, 2026 at 2:15 PM

SUBJECT
Request for Continuance and Public Safety and
Environmental Records
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.

From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Request for Continuance and Public Safety and Environmental Records Date: Thursday, August 20, 2026 3:13:31 PM Attachments: imaqe001.pnq Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
@%& REDONDO => BEACH
Sent:

From:

Thursday, August
Cherise 10 i
20, 2026 2:15 PM
To: Daniel Besinaiz <[email protected]>
Subject: Request for Continuance and Public Safety and Environmental Records You don't often get email from [BE Learn why this is important Dear Planning Commission,
lam writing regarding the requested variance for the installation and use of approximately 40-foot cryogenic storage tanks containing liquid oxygen, liquid nitrogen, and argon.

Given the nature, size, and proposed contents of these tanks, | respectfully request that consideration of this variance be continued to a later hearing date so that the public has a meaningful opportunity to review the safety and environmental information associated with the proposal before any decision is made.

Before the variance is considered for approval, | request that all relevant safety and environmental records be made publicly available and circulated sufficiently in advance of the continued hearing, including, as applicable:

1. Site plans and specifications identifying the size, capacity, location, setbacks, and intended use of each cryogenic tank;

2. Hazardous-materials and hazardous-substance documentation;

3. Fire and life-safety evaluations;

4. Emergency response, spill, leak, venting, and evacuation plans;

5. Applicable environmental studies, reviews, determinations, and supporting documents;

6. Risk analyses addressing potential releases, oxygen-enriched or oxygen-deficient atmospheres, fire hazards, pressure-related incidents, and impacts to neighboring properties;

7. Applicable building, fire, mechanical, hazardous-materials, and cryogenic-storage code evaluations;

8. Correspondence, comments, conditions, approvals, or determinations from the Fire Department and any other agency having jurisdiction over these installations; and

9. Any permits or agency approvals that would be required for the proposed tanks and their operation.
| further request that the variance not be approved until the Fire Department and all other relevant safety, environmental, and regulatory agencies have reviewed the proposal and provided whatever approvals, clearances, conditions, or determinations are required within their respective jurisdictions.

The public should not be asked to comment on, nor should the decision-making body be asked to approve, a variance involving large-scale storage of cryogenic oxygen, nitrogen, and argon without first having access to the information necessary to evaluate the associated risks and regulatory requirements.

Acontinuance would allow adequate time for agency review, public disclosure of the relevant records, and informed public participation. Please include this correspondence in the administrative record for the project and provide notice of any continued hearing date.

Thank you for your consideration.

Sincerely,
Cherise Ho
PUBLIC COMMENT 16 AUGUST 20 PLANNING COMMISSION

ORIGINAL SENDER
G. P. Suddeth

ORIGINAL SENT
Thursday, August 20, 2026 at 3:12 PM

SUBJECT
Planning commission hearing regarding IMPULSE
height variance request
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.

From: Daniel Besinaiz
To: Jamaal Brown Subject: FW: Planning commission hearing regarding IMPULSE height variance request Date: Thursday, August 20, 2026 3:14:40 PM Attachments: imaqe001.pnq Hi Jamaal,
See below for public comment.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).
@%& REDONDO => BEACH
Sent:

From:

Thursday, August
G P Suddeth i
20, 2026 3:12 PM
To: Daniel Besinaiz <[email protected]>; [email protected] Subject: Planning commission hearing regarding IMPULSE height variance request You don't often get email from [III Learn why this is important To the Commission:

Please continue the meeting/discussion of this request to allow citizens to become better aware of what is being proposed at this site.

My neighbors and | are concerned because of a woeful lack of outreach from IMPULSE to residents whose homes are just feet away from where this installation is proposed to occur. The only notice my neighbors on Sebald and other nearby streets got about this height variance request was via a photo of an 8 x 11 note posted on the fence surrounding the Impulse property that one of my neighbors shared on the Dow-Johnston Triangle Neighborhood Watch website.

This is not "good neighbor" behavior on the part of Impulse, and it would be a mistake for the Planning Commission to reward this misbehavior by rubber stamping Impulse's plan.

The residents of this area need time and information to better understand exactly what is being proposed, and what would be this project's potential impacts on the neighborhood.

Voting approval for Impulse's proposal at this time would be premature.

Thank You --
G P Suddeth
ME Redondo Beach, CA 90278
CITY OF REDONDO BEACH SEPTEMBER 17 PLANNING COMMISSION
Planning Commission Public
Comments
Meeting Date: September 17, 2026
Agenda Item K.1 - Case No. 2026-0595

PUBLIC COMMENT COMPILATION
18 distinct email submissions
Original public-sender dates: August 21 - September 17, 2026 Emails are arranged by the original public sender's date and time. Non-government email addresses and personal phone numbers are permanently redacted. 2477 Manhattan Beach Boulevard Case No. 2026-0595
PUBLIC COMMENT 01 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Friday, August 21, 2026 at 1:55 PM

SUBJECT
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.

You don't often get email from [email protected]. Learn why this is important From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:35:41 PM
Attachments: image001.png
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Raquel Doom <[email protected]>
Sent: Thursday, August 27, 2026 5:31 PM
To:

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]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Mark N Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]>
Subject: RE: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).

Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation. Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail [email protected] Website: www.fire.lacounty.gov/health-hazardous-materials-division From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 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 <[email protected]>; [email protected] <[email protected]>; CAUTION: External Email. Proceed Responsibly.

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, 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 hazardous-materials/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, [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
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 oxygendeficiency/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 oxygendeficiency/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
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
PUBLIC COMMENT 02 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Wednesday, August 26, 2026 at 8:15 PM

SUBJECT
Fwd: 2477 Manhattan Beach Blvd. - Request for HHMD
Review of Cryogenic Tank Emergency Planning

SUPPORTING MATERIALS INCLUDED
- 2477 HHMD Single-Tank Catastrophic Release Memorandum 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.

From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:36:26 PM
Attachments: 2477_HHMD_Single_Tank_Catastrophic_Release_Memo.docx Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Wednesday, August 26, 2026 8:15 PM
To: [email protected]; [email protected]; Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Mark N
Subject: Fwd: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

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]>, <[email protected]>, <[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, 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 hazardous-materials/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 oxygendeficiency/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 oxygendeficiency/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
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 — Case No. 2026-0595 — Single-Tank Catastrophic Release / HHMD Review Request

MEMORANDUM
TO: County of Los Angeles Fire Department
Health Hazardous Materials Division
5825 Rickenbacker Rd
Commerce, CA 90040
CONTACT: General: (323) 890-4045 | Data Ops/CERS: (323) 890-4000 | Fax: (323) 890-4046 [email protected] | [email protected] SUBJECT: 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 — Case No. 2026-0595 — Request for Review of Off-Site Oxygen-Deficiency Consequences from a Single-Tank Catastrophic Cryogenic Release DATE: August 21, 2026
Purpose. This memorandum requests HHMD/CUPA review of the emergency-planning implications of the proposed bulk cryogenic storage installation at 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 (City of Redondo Beach Case No. 2026-0595). The principal concern is not routine filling or normal operation, but the low-probability, high-consequence catastrophic loss of containment from a single full cryogenic vessel—especially liquid argon (LAR)— and the potential for an oxygen-deficient atmosphere to extend off site toward the R-1 residential neighborhood immediately south of Manhattan Beach Boulevard.

1. Project and Tank-Size Bounding Assumptions
The City project record describes four bulk cryogenic tanks approximately 38 feet high for liquid nitrogen (LIN) and liquid argon (LAR). To establish reasonable source-term bounds before the actual vessel specifications are available, this memorandum uses Linde's published standard cryogenic tank data. Linde's Size 300 and Size 490 air-gas tanks are both 11.55 m high (37.9 ft), closely approximating the proposed 38-ft height.

The Linde catalog lists Size 300 at 30,205 L gross / 28,700 L net and Size 490 at 49,020 L gross / 46,570 L net. At the catalog's 18-bar, 95% filling condition, the Size 300 holds 23,190 kg LIN, while the Size 490 holds 64,965 kg LAR.

Parameter Smaller 38-ft class
(Size 300)
Larger 38-ft class
(Size 490)
Significance
Overall height 11.55 m / 37.9 ft 11.55 m / 37.9 ft Both closely match proposed height
Diameter 2.40 m / 7.87 ft 3.00 m / 9.84 ft Site-plan diameter can narrow actual capacity
Gross capacity 30,205 L / ~7,980 gal 49,020 L / ~12,950 gal ~62% capacity difference Net capacity (18 bar) 28,700 L / ~7,580 gal 46,570 L / ~12,300 gal Usable liquid inventory Relevant mass LIN: 23,190 kg / ~51,100 lb LAR: 64,965 kg / ~143,200 lb
Source term for release
analysis

2. Single-Tank Catastrophic Release Scenario and Inventory Context For emergency-planning purposes, the principal scenario recommended for detailed analysis is catastrophic loss of one full maximum-capacity LAR vessel. Four-tank inventory cases may be retained only as broad inventory context; simultaneous catastrophic failure of all four tanks is not relied upon as the primary credible emergency-planning scenario.

Scenario Cryogenic inventory Approx. ambient inert-gas
equivalent*
Use
A. One large LAR tank 64,965 kg LAR; ~12,300 gal
net
~38,450 m³ / 1.36 million ft³ Primary case
recommended for detailed
HHMD off-site
consequence analysis
B. Four smaller tanks, all
LIN
92,760 kg LIN; ~30,300 gal
net total
~78,300 m³ / 2.76 million ft³ Inventory context only; not proposed as primary
2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 — Case No. 2026-0595 — Single-Tank Catastrophic Release / HHMD Review Request
credible failure scenario
C. Four larger tanks, all LAR 259,860 kg LAR; ~49,200
gal net total
~153,800 m³ / 5.43 million ft³ Absolute inventory
envelope only; not
proposed as primary
credible failure scenario
* Ambient-gas equivalents are approximate inventory conversions at about 1 atm and 15°C. They are not plume volumes, hazard-zone areas, or predictions of actual dispersion.

3. Why Liquid Argon Warrants Off-Site Consequence Review Argon is chemically inert and nonflammable, but it is an asphyxiant because it displaces oxygen. At ordinary temperature argon gas is denser than air; immediately after a cryogenic release, the vapor is also extremely cold. A major release can therefore initially behave as a dense gas, with dispersion affected by wind, atmospheric stability, ground heating, buildings, walls, depressions, drainage features, and local grade.

Accordingly, a generic circular isolation distance does not by itself establish whether the R-1 neighborhood is protected.

The relevant question is the predicted oxygen concentration at off-site receptors following a credible major or catastrophic release.

4. Screening Calculation — Not a Dispersion Model
A deliberately simplified perfect-mixing/ground-layer screening calculation was used only to test whether neighborhoodscale oxygen depletion is physically plausible. Assuming a uniform 2-m-deep mixed layer, the approximate equivalent radii are:

O₂ endpoint One large LAR tank 4 small LIN tanks 4 large LAR tanks

19.5% O₂ ~990 ft ~1,415 ft ~1,980 ft
18% O₂ ~690 ft ~980 ft ~1,380 ft
15% O₂ ~480 ft ~690 ft ~970 ft

12.5% O₂ ~405 ft ~580 ft ~810 ft
Important limitation. These radii are not predictions and should not be used as evacuation zones. A real cryogenic release is neither uniformly mixed nor circular. The screening result merely demonstrates that the inventories are sufficiently large that off-site oxygen-deficiency at neighborhood-scale distances cannot be excluded by inventoryvolume reasoning alone. A site-specific dense-gas/cryogenic dispersion analysis is needed.

5. Regulatory Emergency-Planning Context
California's Hazardous Materials Business Plan regulations require emergency response procedures for a release or threatened release to be scaled to the size and nature of the business, the damage potential of the hazardous materials, and the facility's proximity to residential areas and other populations. 19 CCR §5030.9 includes notification, appropriate emergency medical assistance, mitigation/prevention/abatement, evacuation, and earthquake-related inspection/isolation provisions.

Los Angeles County HHMD states that businesses handling reportable quantities must submit hazardous-material inventory, a site map, and emergency response/contingency and employee-training information through CERS. HHMD also states that its emergency responders perform hazard analysis, technical advising, multi-agency coordination, and evacuation and re-occupancy determinations. These functions make HHMD/CUPA review particularly relevant to the off-site residential consequence issue.

6. Requested HHMD/CUPA Review

1. Confirm the maximum permitted/reported LIN and LAR inventory for each vessel and for the installation as a whole, including the quantities reported or to be reported in CERS. 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 — Case No. 2026-0595 — Single-Tank Catastrophic Release / HHMD Review Request

2. Identify the actual vessel manufacturer/model, gross and net capacity, maximum fill quantity, operating pressure, and product assignment for each tank.

3. Confirm whether HHMD has reviewed, or will require, a site-specific oxygen-deficiency/dense-gas dispersion analysis for a major or catastrophic LAR release.

4. Evaluate at minimum catastrophic loss of one full maximum-size LAR vessel. If a different credible worst-case release scenario is used, identify the technical basis.

5. Identify the oxygen-concentration endpoints and meteorological conditions used to establish protective-action distances, including 19.5%, 18%, and 15% O₂ contours where technically appropriate.

6. Include actual site geometry and receptors: tank location, buildings/walls, grade, streets, storm/sewer drains or depressions, and the R-1 residences south of Manhattan Beach Boulevard.

7. Identify the technical basis for the 330-ft major-release/vessel-damage isolation distance presented in the applicant's safety materials and state whether it is site-specific or generic guidance.

8. State the planned protective actions for the R-1 neighborhood for a major inert-cryogen release, including notification, evacuation versus shelter-in-place criteria, incident command, monitoring, and re-occupancy.

9. Confirm coordination among HHMD/CUPA, Redondo Beach Fire Department, the tank owner/supplier, and the facility operator, including which agency has responsibility for off-site hazard assessment and public protectiveaction decisions.

10. Provide or identify the applicable HMBP/CERS emergency response and contingency materials, site map, inventory information, and HHMD review/inspection records, subject to applicable disclosure restrictions.

7. Requested Technical Question
For catastrophic loss of one full maximum-capacity liquid-argon vessel at 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278 (Case No. 2026-0595), 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?

8. References
 Linde AG, Cryogenic Standard Tanks LITS 2, Technical Data — Tanks for Air Gases LIN, LOX, LAR, p. 6. The catalog identifies LIN as liquid nitrogen and LAR as liquid argon and provides capacities, fill masses, diameters and heights for the Size 300 and Size 490 tanks.
 California Code of Regulations, Title 19, Division 5, Chapter 1, §5030.9, Emergency Response Plans and Procedures (CalEPA publication).
 CalEPA, Hazardous Materials Business Plan FAQ — emergency response plans/procedures and site-map requirements.
 County of Los Angeles Fire Department, Health Hazardous Materials Division — Hazardous Materials Program; CERS Information; Haz Mat Emergency Operations; HHMD Contact Information.  City of Redondo Beach project record, Case No. 2026-0595 / PC26-1012, 2477 Manhattan Beach Boulevard, Redondo Beach, CA 90278, including the proposed approximately 38-ft bulk cryogenic storage tanks and adjacent R-1 zoning south of Manhattan Beach Boulevard.

PUBLIC COMMENT 03 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Wednesday, August 26, 2026 at 11:09 PM

SUBJECT
Public Notice: This 2477 Manhattan Beach Blvd.

Exhibit is Defective
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.

CAUTION: External Email. Proceed Responsibly.
https://redondo.legistar.com/View.ashx?M=F&ID=15770496&GUID=13D082F2-8474- 44DF-9249-E2F88B8D2C8E
The drawing fails to label tank size, volume or content. The drawing has no streets. The drawing has no surrounding land uses. The drawing has no as-is location despite being a purported "relocation" drawing. In short this does not meet the evidentiary requirements of any permitting or emergency response use.

As of today, LA County Fire has not responded to local neighborhood concerns regarding tank safety and rupture planning of the heavier than air Liquid argon. cc: Redondo Council
From: Mark Nelson (Home Gmail)
To: CityClerk; Sean Scully; Fire-Hhmdcers; CALFIRE State Fire Marshal Subject: Public Notice: This 2477 Manhattan Beach Blvd, Redondo Beach, CA 90278 Exhibit is Defective Date: Wednesday, August 26, 2026 11:09:58 PM
PUBLIC COMMENT 04 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, August 27, 2026 at 6:43 PM

SUBJECT
Re: 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.

From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:35:26 PM
Attachments: image001.png
Tamworth liquid nitrogen explosion December 14 2021 The Northern.mp4 Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Thursday, August 27, 2026 6:43 PM
To: Raquel Doom <[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]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]>; [email protected]; Holly J. Mitchell <[email protected]> Subject: Re: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Here's a rupture of 20-foot tank of liquid nitrogen. Without dispute, it would have carry well into surrounding neighborhoods and displace oxygen. Also, had it been argon, it would be heavier than oxygen and be even more of a hazard. Yet, no agency cares.

Surrounding neighbors should be furious.

On Thu, Aug 27, 2026 at 5:51 PM Mark Nelson (Home Gmail) wrote:

Thank you for your response. My response is not aimed at you, but rather, a failed process.

I'm going to paraphrase:

I think we all agree that in a catastrophic rupture, the residents 200 to 500-feet away (depending on wind speed and direction) could be snuffed out by oxygen displacement, especially from argon, but also from nitrogen. If we aren't in agreement, I'll be happy to provide the engineering analysis of a 12,000 gallon catastrophic liquid Ar release event under perfect mixing - the best possible life preserving case.

Apparently, under state and federal law, that's ok that residents might be killed without any analysis - and no analysis is required because they are non-flammable.

Hypothetically, a million gallon tank that could saturate one-half mile radius would not require any analysis either.

However, the emergency agency does voice concerns about the life and safety of first responders in the exact same situation, as it recognizes the asphyxiation properties of N2 and Ar.

This is truly unacceptable to the surrounding neighborhoods and at the minimum, the Planning Commission needs to deny the variance and the City should not cooperate with this flawed process.

On Thu, Aug 27, 2026 at 5:31 PM Raquel Doom <[email protected]> wrote:

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).

Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation.

Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail Fire-HHMDDOU[email protected] Website: www.fire.lacounty.gov/health-hazardous-materials-division From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 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 <[email protected]>; [email protected] <[email protected]>; CAUTION: External Email. Proceed Responsibly.

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, 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 hazardous-materials/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 [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
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 hazardousmaterials 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 oxygendeficiency/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
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
PUBLIC COMMENT 05 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Friday, August 28, 2026 at 4:23 PM

SUBJECT
Re: 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.

From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:35:03 PM
Attachments: image001.png
LN2_Catastrophic_Release_Screening_2477_MBB.docx
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Friday, August 28, 2026 4:23 PM
To: Raquel Doom <[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]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]> Subject: Re: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

The attached engineering screening analysis demonstrates that a rupture of single 12,000 gallon, 38-ft tank would have sufficient product to impact the residential area to the south of the site. Absent detailed modeling, which the agencies refuse to conduct, the safety analysis is incomplete.

On Thu, Aug 27, 2026 at 5:31 PM Raquel Doom <[email protected]> wrote:

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).

Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation.

Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail Fire-HHMDDOU[email protected] Website: www.fire.lacounty.gov/health-hazardous-materials-division CAUTION: External Email. Proceed Responsibly.

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, 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 hazardous-materials/CUPA inspection function for facilities of this type.

From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 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 <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
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 oxygendeficiency/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
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
PUBLIC COMMENT 06 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Stop BCHD

ORIGINAL SENT
Monday, August 31, 2026 at 4:50 PM

SUBJECT
TRW Tract Neighbors Need a Safety Analysis Prior to
Any Tank Installations
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.

From: Sean Scully
To: Jamaal Brown
Subject: FW: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations Date: Friday, September 11, 2026 4:34:13 PM
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Stop BCHD
Sent: Monday, August 31, 2026 4:50 PM
To: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>
Subject: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Subject: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations City Council, City Manager, City Attorney, Planning Commissioners:

The residents surrounding 2477 Manhattan Beach Blvd deserve a fair analysis of the shrapnel and gas hazards from the proposed Argon and Nitrogen tanks. This link shows the explosion of a 20-foot tall tank.

The proposal is for four 38-foot tall tanks which provides much more potential damage and oxygen displacing gas release.

The explosion and shrapnel video is at https://www.youtube.com/watch?v=CHXU07zyKRA Nitrogen gas will displace oxygen and could result in asphyxiation as the level of nitrogen in the local air rises well above 80%. Argon is heavier than oxygen, so it will create a layer of unbreathable gas and potentially asphyxiate residents and pool in low lying spaces, like stairwells, underground parking, etc.

All we ask is a fair, honest analysis. You've seen the video. The proponent lost its credibility when it claimed that an explosion was impossible. It's possible and it happens periodically. 200-feet from homes is well within the range of 12,000 gallons of liquid argon to travel and for large equipment to land after an explosion.

The City needs to build its own credibility and assure a transparent analysis is conducted and made public. This is a small "ask" to avoid a tragic outcome. No tanks before a SAFETY analysis. Simple. Fair.

Thank you.
--
StopBCHD.com is a Neighborhood Quality-of-Life Community concerned about the quality-of-life, health, and economic damages that BCHDs 110- foot above the street, 800,000 sqft commercial development will inflict for the next 50- 100 years. Our neighborhoods have been burdened since 1960 by the failed South Bay Hospital project and have not received the benefit of the voter-approved acute care public hospital since 1984.Yet we still suffer 100% of the damages and we will suffer 100% of the damages of BCHDs proposal.

PUBLIC COMMENT 07 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Marcio Nava

ORIGINAL SENT
Monday, August 31, 2026 at 8:06 PM

SUBJECT
TRW Tract Neighbors Need a Safety Analysis Prior to
Any Tank Installations
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.

Some people who received this message don't often get email from Learn why this is important From: Sean Scully
To: Jamaal Brown
Subject: FW: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations Date: Friday, September 11, 2026 4:33:58 PM
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: M. Nava
Sent: Monday, August 31, 2026 8:06 PM
To: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>
Subject: TRW Tract Neighbors Need a Safety Analysis Prior to Any Tank Installations CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

City Council, City Manager, City Attorney, Planning Commissioners:

The residents surrounding 2477 Manhattan Beach Blvd deserve a fair analysis of the shrapnel and gas hazards from the proposed Argon and Nitrogen tanks. This link shows the explosion of a 20-foot tall tank.

The proposal is for four 38-foot tall tanks which provides much more potential damage and oxygen displacing gas release.

The explosion and shrapnel video is at https://www.youtube.com/watch?v=CHXU07zyKRA Nitrogen gas will displace oxygen and could result in asphyxiation as the level of nitrogen in the local air rises well above 80%. Argon is heavier than oxygen, so it will create a layer of unbreathable gas and potentially asphyxiate residents and pool in low lying spaces, like stairwells, underground parking, etc.

All we ask is a fair, honest analysis. You've seen the video. The proponent lost its credibility when it claimed that an explosion was impossible. It's possible and it happens periodically. 200-feet from homes is well within the range of 12,000 gallons of liquid argon to travel and for large equipment to land after an explosion.

The City needs to build its own credibility and assure a transparent analysis is conducted and made public. This is a small "ask" to avoid a tragic outcome. No tanks before a SAFETY analysis. Simple. Fair.

Thank you.

Marcio Nava
PUBLIC COMMENT 08 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mina Amirzai

ORIGINAL SENT
Tuesday, September 1, 2026 at 11:40 AM

SUBJECT
Public Comment - Neighbors Deserve a Full Safety
Analysis of the Four 38-foot Cryogenic Tanks
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.

You don't often get email from Learn why this is important From: Sean Scully
To: Jamaal Brown
Subject: FW: Public Comment - Neighbors Deserve a Full Safety Analysis of the Four, 38-foot, Cryogenic Tanks at Impulse Space Date: Friday, September 11, 2026 4:33:03 PM
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: mina amirzai
Sent: Tuesday, September 1, 2026 11:40 AM
To: Scott Behrendt <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Joy Ford <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]> Subject: Public Comment - Neighbors Deserve a Full Safety Analysis of the Four, 38-foot, Cryogenic Tanks at Impulse Space CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Council Members, Commissioners, City Manager, City Attorney:

Please view the video of the explosion from 2 failed emergency discharge valves of a 20-foot liquid nitrogen tank. It is catastrophic.

Tamworth liquid nitrogen explosion December 14 2021
Mark N
youtube.com
At the recent Planning Commission meeting, we were told that liquid Nitrogen and liquid Argon are not explosive and not toxic. We were also told by RBFD that they cannot conduct any analysis of the gasses because they do not have a HAZMAT unit. We were then told that LA County HAZMAT would conduct the analysis.

In an email from August 27 by Specialist Doom of LACoFD, the City and the Residents were informed by LA County that no analysis would be conducted for residents of a catastrophic rupture of any of the tanks. LA County did make it clear that there was an asphyxiation risk from both Argon and Nitrogen and that they would have their teams analyze the health and safety impacts on first responders.

So neighbors are in a position where we know:
1) the tanks can explode,
2) the liquids inside are at -300 degrees F,
3) the liquids will roll out over the neighborhoods after a tank explosion, 4) the liquids will re-gasify to Argon or Nitrogen gas, both of which displace oxygen required for life, 5) LA County sees risk to first responders from the gas and the risk of asphyxiation, and 6) NO AGENCY WILL CONDUCT ANY SAFETY ANALYSIS FOR THE NEIGHBORHOOD RESIDENTS' SAFETY.

That is unacceptable.

The City is obligated to protect resident health and safety. Until a full analysis and mitigations are completed to protect the neighbors, we demand that no permits are issued.

If any tanks are relocated, they must be required to have safety walls that will stop a catastrophic release from flowing off the Impulse Space property. If Impulse won't allow that, then this is clearly an unsafe situation for residents also.

Please act quickly as this situation is stressing residents who are in the blast and gas zone.

Sincerely,
Mina Amirzai
(Concerned parent and resident of TRW tract neighborhood) PUBLIC COMMENT 09 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
L. A. Stone

ORIGINAL SENT
Tuesday, September 1, 2026 at 12:08 PM

SUBJECT
Public Comment - Neighbors Deserve a Full Safety
Analysis of the Four 38-foot Cryogenic Tanks
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.

You don't often get email from Learn why this is important From: Sean Scully
To: Jamaal Brown
Subject: FW: Public Comment - Neighbors Deserve a Full Safety Analysis of the Four, 38-foot, Cryogenic Tanks at Impulse Space
Date: Friday, September 11, 2026 4:33:37 PM
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: L. A Stone
Sent: Tuesday, September 1, 2026 12:08 PM
To: Joy Ford <[email protected]>; Mike Witzansky <[email protected]>; Andrew Winje <[email protected]>; Marc Wiener <[email protected]>; Sean Scully <[email protected]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Scott Behrendt <[email protected]>
Subject: Public Comment - Neighbors Deserve a Full Safety Analysis of the Four, 38-foot, Cryogenic Tanks at Impulse Space
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Members, Commissioners, City Manager, City Attorney:

Please view the video of the explosion from 2 failed emergency discharge valves of a 20-foot liquid nitrogen tank. It is catastrophic.
https://youtu.be/CHXU07zyKRA
At the recent Planning Commission meeting, we were told that liquid Nitrogen and liquid Argon are not explosive and not toxic. We were also told by RBFD that they cannot conduct any analysis of the gasses because they do not have a HAZMAT unit. We were then told that LA County HAZMAT would conduct the analysis.

In an email from August 27 by Specialist Doom of LACoFD, the City and the Residents were informed by LA County that no analysis would be conducted for residents of a catastrophic rupture of any of the tanks. LA County did make it clear that there was an asphyxiation risk from both Argon and Nitrogen and that they would have their teams analyze the health and safety impacts on first responders.

So neighbors are in a position where we know:
1) the tanks can explode,
2) the liquids inside are at -300 degrees F,
3) the liquids will roll out over the neighborhoods after a tank explosion, 4) the liquids will re-gasify to Argon or Nitrogen gas, both of which displace oxygen required for life,
5) LA County sees risk to first responders from the gas and the risk of asphyxiation, and 6) NO AGENCY WILL CONDUCT ANY SAFETY ANALYSIS FOR THE NEIGHBORHOOD RESIDENTS' SAFETY.

That is unacceptable.

The City is obligated to protect resident health and safety. Until a full analysis and mitigations are completed to protect the neighbors, we demand that no permits are issued.

If any tanks are relocated, they must be required to have safety walls that will stop a catastrophic release from flowing off the Impulse Space property. If Impulse won't allow that, then this is clearly an unsafe situation for residents also.

Please act quickly as this situation is stressing residents who are in the blast and gas zone.

Sent from my iPhone
PUBLIC COMMENT 10 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Wednesday, September 2, 2026 at 9:12 AM

SUBJECT
Re: 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.

From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:30:52 PM
Attachments: image001.png
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Wednesday, September 2, 2026 9:12 AM
To: Raquel Doom <[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]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]>; [email protected]; [email protected]; [email protected]
Subject: Re: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Also public comment LA County Board of Supervisors - Non-Agenda Item for Next Available Meeting
To LA County Fire and Hazard:

Provide a time and place to review all of your legally required analysis of the 2477 Manhattan Beach Blvd liquid N2 and liquid argon storage tanks. The following delineation of delegated responsibilities from the City of Redondo Beach Fire Department to LA County demonstrate the safety reports that we plan to inspect.

A 12,000-gallon liquid argon tank for a welding operation in Redondo Beach shifts the regulatory path directly to the Los Angeles County Fire Department (LACoFD) Health Hazardous Materials Division (HHMD), which acts as the Certified Unified Program Agency (CUPA) for areas where local departments do not retain hazmat jurisdiction.

LACoFD CUPA & Hazardous Materials Requirements
Threshold Triggers: Liquid argon is stored as a cryogenic liquid and transitions to a compressed gas. Because a 12,000-gallon vessel vastly exceeds state threshold quantities (500 pounds or 55 gallons for compressed/cryogenic gases), it mandates full oversight.

California Environmental Reporting System (CERS): You must submit a comprehensive Hazardous Materials Business Plan (HMBP), including emergency response plans, facility layout maps, and exact inventory quantities, through CERS.

Aboveground Tank and Cryogenic Review: LACoFD HHMD will review the installation for compliance with safety standards regarding physical stability, pressure relief venting, and accidental release prevention.

Redondo Beach Building & Safety Integration
Local Plan Check: While hazmat goes to the county, the physical construction, foundation, and utility hookups are permitted locally through the City of Redondo Beach Building Division.

Zoning and Setbacks: The local planning division will verify that the tank meets industrial zoning restrictions and property-line setbacks. Because argon is heavier than air and displaces oxygen, strict safety clearances from building egress points, operable windows, and air intakes are heavily enforced during plan check.

Engineering & Safety Mandates
Seismic Design: Southern California building codes require site-specific structural calculations stamped by a California Professional Engineer (PE). The 12,000-gallon vessel, its concrete pad, anchoring system, and vaporization/piping infrastructure must be engineered to withstand major seismic events.

NFPA 55 & CGA Standards: The system must strictly adhere to the Compressed Gas Association (CGA) guidelines and NFPA 55 for cryogenic fluid storage, including proper placarding, security fencing, and bollards to protect against vehicle impact.

On Fri, Aug 28, 2026 at 4:23 PM Mark Nelson (Home Gmail) wrote:

The attached engineering screening analysis demonstrates that a rupture of single 12,000 gallon, 38-ft tank would have sufficient product to impact the residential area to the south of the site. Absent detailed modeling, which the agencies refuse to conduct, the safety analysis is incomplete.

On Thu, Aug 27, 2026 at 5:31 PM Raquel Doom <[email protected]> wrote:

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).

Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation.

Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail Fire-HHMDDOU[email protected] CAUTION: External Email. Proceed Responsibly.

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 Website: www.fire.lacounty.gov/health-hazardous-materials-division From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 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 <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
of concern to nearby residents and several questions of interest to the Commissioners.

Among the subjects discussed were tank capacity, 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 hazardous-materials/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 hazardousmaterials 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
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
PUBLIC COMMENT 11 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Wednesday, September 2, 2026 at 9:16 AM

SUBJECT
Re: 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.

From: Sean Scully
To: Jamaal Brown
Subject: FW: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
Date: Friday, September 11, 2026 4:30:29 PM
Attachments: image001.png
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Wednesday, September 2, 2026 9:16 AM
To: Raquel Doom <[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]>; Gale S. Hazeltine <[email protected]>; Jason Conroy <[email protected]>; Wayne Craig <[email protected]>; Douglas Boswell <[email protected]>; Roger K. Light <[email protected]>; Robert Gaddis <[email protected]>; Julie Young <[email protected]>; Charlene Lomeli <[email protected]>; Mathias Mekasha <[email protected]> Subject: Re: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
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City of Redondo Beach with Interdepartmental Coordination as Required:

Provide a time and place to review all of your legally required analysis of the 2477 Manhattan Beach Blvd liquid N2 and liquid argon storage tanks. The following delineation of responsibilities of the City of Redondo Beach demonstrate the safety reports that we plan to inspect.

A 12,000-gallon liquid argon tank for a welding operation in Redondo Beach shifts the regulatory path directly to the Los Angeles County Fire Department (LACoFD) Health Hazardous Materials Division (HHMD), which acts as the Certified Unified Program Agency (CUPA) for areas where local departments do not retain hazmat jurisdiction.

LACoFD CUPA & Hazardous Materials Requirements
· Threshold Triggers: Liquid argon is stored as a cryogenic liquid and transitions to a compressed gas. Because a 12,000-gallon vessel vastly exceeds state threshold quantities (500 pounds or 55 gallons for compressed/cryogenic gases), it mandates full oversight. · California Environmental Reporting System (CERS): You must submit a comprehensive Hazardous Materials Business Plan (HMBP), including emergency response plans, facility layout maps, and exact inventory quantities, through CERS.
· Aboveground Tank and Cryogenic Review: LACoFD HHMD will review the installation for compliance with safety standards regarding physical stability, pressure relief venting, and accidental release prevention.

Redondo Beach Building & Safety Integration
· Local Plan Check: While hazmat goes to the county, the physical construction, foundation, and utility hookups are permitted locally through the City of Redondo Beach Building Division.
· Zoning and Setbacks: The local planning division will verify that the tank meets industrial zoning restrictions and property-line setbacks. Because argon is heavier than air and displaces oxygen, strict safety clearances from building egress points, operable windows, and air intakes are heavily enforced during plan check.

Engineering & Safety Mandates
· Seismic Design: Southern California building codes require site-specific structural calculations stamped by a California Professional Engineer (PE).

The 12,000-gallon vessel, its concrete pad, anchoring system, and vaporization/piping infrastructure must be engineered to withstand major seismic events.
· NFPA 55 & CGA Standards: The system must strictly adhere to the Compressed Gas Association (CGA) guidelines and NFPA 55 for cryogenic fluid storage, including proper placarding, security fencing, and bollards to protect against vehicle impact.

On Fri, Aug 28, 2026 at 4:23 PM Mark Nelson (Home Gmail) wrote:

The attached engineering screening analysis demonstrates that a rupture of single 12,000 gallon, 38-ft tank would have sufficient product to impact the residential area to the south of the site. Absent detailed modeling, which the agencies refuse to conduct, the safety analysis is incomplete.

On Thu, Aug 27, 2026 at 5:31 PM Raquel Doom <[email protected]> wrote:

Good Afternoon
In response to your inquiry, the CUPA would not have requirements prior to hazardous material container or tank installation or use.

Scenarios that might require our approval prior to installation or use would be for the installation of Hazardous Waste Treatment Systems and hazardous materials regulated under our California Accidental Release Prevention (CalARP) program.

Argon and liquid nitrogen are not regulated under CalARP (CCR Title 19) or the federal Risk Management Program (RMP) under CAA Section 112(r).

Neither substance is classified as toxic or flammable for purposes of these regulations, and they do not appear to be listed on the EPA Consolidated List of Lists (CERCLA, EPCRA, RCRA, and CWA).

Additionally, there does not appear to be statutory off-site consequence analysis (OCA) requirements or regulatory toxic endpoints applicable to these substances under CalARP (19 CCR § 5080.2) or the EPA RMP regulations (40 CFR Part 68), where the primary hazard associated with these gases would be oxygen displacement and potential asphyxiation.

Given this, using a general air-dispersion model for these gases, such as RMP*Comp, would not be appropriate for conducting an OCA.

That said, the Local Emergency Planning Committee (LEPC) may still want to be informed of the physical location where these gases are stored or used, as an oxygen-deficiency hazard could be a significant consideration for emergency responders.

I hope this clarifies. Please feel free to reach out with any questions.

Best Regards,
Raquel Doom
Hazardous Materials Specialist III
Los Angeles County Fire Dept.

Health Hazardous Materials Division
Inspection Section - Southwest District
24330 S. Narbonne Ave., Lomita, CA 90717
Cell (213)703-4592 | Office (310) 534-6274 | Fax (310) 539-6948 My Regular Day Off is Friday
For CERS Assistance, e-mail [email protected] Para asistencia en Espanol, e-mail Fire-HHMDDOU[email protected] CAUTION: External Email. Proceed Responsibly.

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 Website: www.fire.lacounty.gov/health-hazardous-materials-division From: Mark Nelson (Home Gmail)
Sent: Friday, August 21, 2026 1:55 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 <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; [email protected] <[email protected]>; Mark N Subject: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
of concern to nearby residents and several questions of interest to the Commissioners.

Among the subjects discussed were tank capacity, 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 hazardous-materials/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 hazardousmaterials 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
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request
PUBLIC COMMENT 12 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Alicia Evans

ORIGINAL SENT
Sunday, September 13, 2026 at 5:47 PM

SUBJECT
Public Comment - RB City Council Non-Agenda Items
and Planning Commission Item K.1
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.

From: alicia evans
To: Joy Ford; Mike Witzansky; James Light; Brad Waller; Chadwick B. Castle; Zein Obagi; Planning Redondo; Scott Behrendt; Eleanor Manzano; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Sean Scully; Daniel Besinaiz; Julie Young; Patrick Butler; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: SUBJECT: Public Comment - RB City Council Mtg Non-Agenda Items, RB Planning Commission Mtg Item K1 Impulse Space Tank Variance
Date: Sunday, September 13, 2026 5:47:04 PM
Some people who received this message don't often get email from Learn why this is important
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Council Members, Commissioners, and Others:

Impulse Space Tank Variance: Since time is so short and the City is ignoring resident safety - here's a comment letter that you can send to the email list to request that the safety analysis isn't an afterthought.

The safety analysis should be completed before permitting.

OPTION 1: STOP PROCESSING OF THE VARIANCE NOW AND REQUIRE COMPLETION OF THE SAFETY ANALYSIS IN ADVANCE FOR PUBLIC REVIEW. Public safety should not be an afterthought for review after approval of the permit.

OPTION 2: DENY THE VARIANCE. The proponent was clear, they can and do currently use smaller tanks but they'll need to be refilled more often. NEVER DID IMPULSE EVER CLAIM 38-FT TANKS WERE REQUIRED.

Furthermore, the staff report on the project is again incorrect! Staff states the following required for approval of the variance:
"Additionally, the technical requirements of this required infrastructure in support of this aerospace manufacturing operation (permitted use) cannot be accommodated at a lesser height without resulting in significantly more frequent deliveries which have the potential for the greatest impact on the adjacent residential neighborhood south the subject property"
Neither staff nor proponent provide ANY EVIDENCE that the frequency of refilling poses any "significant" impacts.

Nor, does staff even attempt to determine the High Consequence-Low Frequency rupture impacts vs. the traffic impacts. Without an analysis, the statement is simply conjecture that was reverse manufactured based on the variance need for approval.

This process and the City reports and processing have been haphazard and inaccurate and the City is putting the safety of surrounding residents at risk.

REALITY CHECK…!!!!!!
Safety Systems DO FAIL and Tanks DO EXPLODE
The tank in the video DID EXACTLY what it was supposed to do in the event the pressure relief valves failed - IT RUPTURED.

It launched steel hundreds of feet into the air and left a roughly 1500-foot debris field.

It also sent liquid gas pouring across the landscape for hundreds of feet. The gas itself is not explosive or toxic.

THE GAS IS ALSO NOT BREATHABLE OXYGEN and it will PUSH OXYGEN AWAY and CREATE AN ASPHYXIATION RISK.

The video at https://www.youtube.com/watch?
V=gtS8IVVCmis&pp=ygUJc3RvcCBiY2hk clearly
shows a 20-foot liquid nitrogen tank (about 6,000 gallons) rupturing, sending shrapnel and a non-breathable cloud of nitrogen across hundreds of feet.

The proposed tanks are twice as large with twice the metal and gas. Further, some of the tanks are argon, which is heavier than oxygen, and won't just reduce the amount of oxygen for residents to breath - it will eliminate the oxygen entirely causing asphyxiation.

The cause of the explosion in the video was the failure of the required safety systems to function. So obviously, the risks of Impulse's four, 12,000 gallon,
38-foot tall tanks are very real and a single Impulse proposed tank will have twice the blast zone and gas release as the video's 20-foot tank.

We DEMAND SAFETY first, for our health utmost priority. As well traffic, noise pollution and overall welfare of the community!!
If any of you want to reach out to me feel free! As I have been dealing with Impulse Space on my own. At times with joint effort of neighbors involvement too. We sought out help from Scott Behrendt our D5 representative as well as Joy Ford and other staff with in City of Redondo Beach, but nothing ever came of it.

Sincerely,
Alicia Evans
D5 Resident & Oppose Impulse Space 40 foot Cyro tanks
Sent from my iPhone
PUBLIC COMMENT 13 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Katherine

ORIGINAL SENT
Wednesday, September 16, 2026 at 8:59 AM

SUBJECT
URGENT: Public Comment Opposition to Project
2026-0595 - September 17 Meeting
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.

You don't often get email from Learn why this is important From: Khatirah Nazif
To: Jamaal Brown; Sean Scully; Daisy Canales
Cc: Emily Bodkin
Subject: FW: URGENT: Public Comment Opposition to Project 2026-0595 (Impulse Space) – September 17 Meeting Date: Wednesday, September 16, 2026 11:48:21 AM
From: Katherine
Sent: Wednesday, September 16, 2026 8:59 AM
To: Planning Redondo <[email protected]>; CityClerk <[email protected]>; Eleanor Manzano <[email protected]>; Sean Scully <[email protected]>; Scott Behrendt <[email protected]>; Daisy Canales <[email protected]>; Lorena Soules <[email protected]>; Stephanie Johnson <[email protected]> Cc: Bill Brand <[email protected]>
Subject: URGENT: Public Comment Opposition to Project 2026-0595 (Impulse Space) – September 17 Meeting
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Date: September 16, 2026
To: Redondo Beach Planning Commission
From: Redondo Beach Resident & Coalition of Concerned Neighbors (District 5) Subject: URGENT: Public Comment Opposition to Project 2026-0595 (Impulse Space) – September 17 Meeting
Dear Honorable Commissioners
I am writing to register my absolute and unyielding opposition to Project 2026-0595, which proposes the installation of four outdoor cryogenic storage tanks by Impulse Space at 2477 Manhattan Beach Boulevard. Although I am currently out of town and unable to attend tomorrow’s September 17 meeting in person, this letter stands as a formal request to deny this hazardous project.

The proximity of these 38-foot-tall high-pressure tanks—sitting a mere 200 yards from our residential doorsteps, bedrooms, and families—poses an unacceptable risk to our community. This proposal bypasses critical local protections and introduces severe zoning, safety, and environmental hazards that have not been adequately mitigated:

1. Zoning and Height Violations: The proposed 38-foot height of these tanks severely violates local industrial-residential setback limits and height restrictions designed to protect adjacent neighborhoods. Granting relief for industrial vessels of this massive scale directly adjacent to homes sets a dangerous land-use precedent.

2. Catastrophic Life-Safety Hazards & Historical Precedents: Cryogenic infrastructure is inherently volatile. Recent catastrophic cryogenic liquid nitrogen and gas system failures in states like Georgia and Texas have led to horrific workplace fatalities, rapid asphyxiation clouds, and explosive overpressurization events that leveled surrounding structures. If these tanks leak or explode, people will die—including neighboring families and Impulse Space's own on-site employees.

3. Seismic Vulnerability: Our area is highly susceptible to seismic activity. The city must not approve bulk liquid industrial storage of this magnitude without a transparent, independent Seismic Bracing Audit made available for public review.

4. Environmental and Operational Disruptions: Routine atmospheric venting, highpressure deliveries, and heavy truck traffic will generate ongoing noise pollution and severe light trespass. Furthermore, localized marine layer wind patterns mean that any toxic or asphyxiating vapor clouds will directly pool into residential areas.

Because the current application lacks rigorous, independent oversight, I formally request that the Planning Commission deny this project entirely or issue an indefinite continuance. The city must legally bind and enforce the following conditions before any approvals are considered:

Quantitative Risk Assessment (QRA): Require a comprehensive, independent analysis to model blast and asphyxiation zones.

Fixed Residential Setback: Establish a strict, non-negotiable surveyed setback distance from the residential property line.

Live Public Telemetry: Mandate continuous real-time oxygen and gas monitoring with a live, publicly accessible dashboard.

Enforceable Operational Limits: Set strict decibel limits on routine nighttime venting and delivery operations.

Your primary duty is to protect the safety and zoning integrity of Redondo Beach residents, not to accommodate high-risk aerospace infrastructure at the expense of human lives. We do not want these tanks placed here.

Respectfully submitted,
Katherine Strohlein
2402 Sebald Ave. / District 5
PUBLIC COMMENT 14 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Janet Scully

ORIGINAL SENT
Wednesday, September 16, 2026 at 4:31 PM

SUBJECT
Public Comment on Agenda Item K.1.

PC26-1164/Resolution No. 2026-09-PCR-11
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.

You don't often get email from Learn why this is important From: Daniel Besinaiz
To: Jamaal Brown
Subject: FW: Public Comment on Agenda Item K.1. PC26-1164/Resolution No 2026-09-PCR-11 (Impulse) Date: Tuesday, September 22, 2026 7:28:01 AM
Attachments: image001.png
Hi Jamaal,
This is also a public comment for last week's PC meeting. The height variance for impulse.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From: Khatirah Nazif <[email protected]>
Sent: Monday, September 21, 2026 2:28 PM
To: Daniel Besinaiz <[email protected]>
Subject: FW: Public Comment on Agenda Item K.1. PC26-1164/Resolution No 2026-09-PCR-11 (Impulse)
Final one, thanks!
From: Janet Scully
Sent: Wednesday, September 16, 2026 4:31 PM
To: Khatirah Nazif <[email protected]>; Daniel Besinaiz <[email protected]>; CityClerk <[email protected]>
Subject: Public Comment on Agenda Item K.1. PC26-1164/Resolution No 2026-09-PCR-11 (Impulse) CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good Afternoon,
I am writing to strongly oppose the request by Impulse Space for a variance to install tanks taller than the allowed 30-foot limit.

Taller tanks would compromise the residential character of our neighborhood, making it look like an industrial park, and pose potential safety hazards.

Additionally, I request the following measures to protect our community:
- Hours of Operation: Limit tank refueling to Monday through Friday, between 8:00 AM and 5:00 PM.
- Safety Review: Provide residents the opportunity to review the site-specific Community Emergency Prevention and Mitigation Plan to ensure community safety is prioritized.

Thank you for the opportunity to comment. As a North Redondo Beach resident in District 5 for over 30 years, preserving the safety and character of our neighborhood is deeply important to me.

Sincerely,
Janet Scully
Burritt Ave., Redondo Beach
PUBLIC COMMENT 15 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Nick Biro

ORIGINAL SENT
Thursday, September 17, 2026 at 8:13 AM

SUBJECT
Re: PC Agenda Item 2026-0595
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.

From: Daniel Besinaiz
To: Jamaal Brown
Subject: FW: PC Agenda Item 2026-0595
Date: Thursday, September 17, 2026 10:59:35 AM
Attachments: Cryogenic_Tank_Refilling_Noise_Impact_Assessment.pdf image001.png
Hi Jamaal,
Public comment #2 for variance item tonight.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From: Nick Biro
Sent: Thursday, September 17, 2026 8:13 AM
To: Khatirah Nazif <[email protected]>; CityClerk <[email protected]>; Daniel Besinaiz <[email protected]>; Marc Wiener <[email protected]> Subject: Re: PC Agenda Item 2026-0595
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good morning,
I would like to submit the attached Noise Assessment in reference to Agenda Item K.1 PC26-1164 and its impact to adjacent R1 residential uses. If the proper noise attenuation and controls are not implemented this operation will exceed the residential noise level limits.

Redondo Beach Municipal Code Standards
RBMC Section 4-24.301 applies the higher of the presumed ambient level or the measured ambient level at the receiving property. The presumed exterior limits are shown below.

Receiving District 7 AM to 10 PM 10 PM to 7 AM
Low Density Residential R-1-A R-1 R-2 50 dBA 45 dBA
Medium Density Residential R-3 R-4 55 dBA 50 dBA
High Density Residential R-5 R-6 60 dBA 55 dBA
For a low-density residential receptor with a 50 dBA daytime standard, Section 4-24.301 applies the following time-based allowances. The limits become 5 dB more restrictive if the sound contains a steady audible tone or qualifies as repetitive noise. At a boundary between two land-use categories, the lower category plus 5 dB applies. A higher measured ambient may also increase the applicable standard in 5 dB increments.

Cumulative Duration in One Hour Maximum Daytime Level
More than 30 minutes 50 dBA
More than 15 minutes 55 dBA
More than 5 minutes 60 dBA
More than 1 minute 65 dBA
Any duration 70 dBA
Under Section 4-24.201, exterior measurements are taken at the affected property line closest to the source or where the sound is greatest, generally with the microphone five feet above the ground and away from reflective surfaces. Interior residential standards under Section 4-24.401 are 45 dBA during the day and 40 dBA at night, with windows in their normal seasonal configuration. Section 4-

24.504 separately prohibits perceptible vibration at or beyond the source property boundary.

Estimated Propagation Toward Residences
The following screening calculation assumes an unobstructed point source and 6 dBA reduction for each doubling of distance. It does not include barrier shielding, ground absorption, building reflections, wind, elevated vents, simultaneous sources, or existing traffic noise.

Level at 50 Feet At 200 Feet At 300 Feet At 400 Feet
75 dBA 63 dBA 59 dBA 57 dBA
80 dBA 68 dBA 64 dBA 62 dBA
85 dBA 73 dBA 69 dBA 67 dBA
At an assumed 300-foot separation, a 75 dBA source at 50 feet would reach approximately 59 dBA; an 80 dBA source would reach approximately 64 dBA; and an 85 dBA source would reach approximately 69 dBA. The exact distance from each truck, pump and vent to the closest residential property line must be taken from the final site plan.

Source at 50 Feet Distance to 60 dBA Distance to 55 dBA Distance to 50 dBA 75 dBA 281 feet 500 feet 889 feet
80 dBA 500 feet 889 feet 1,581 feet
85 dBA 889 feet 1,581 feet 2,812 feet
Compliance Assessment at Approximately 300 Feet
·For a transfer lasting more than 30 minutes, all three screening cases would exceed a 50 dBA daytime low-density residential standard.
·
For a transfer lasting more than 15 minutes, all three cases would exceed the 55 dBA allowance.
·
For a transfer lasting between 5 and 15 minutes, the 80 and 85 dBA cases would exceed the 60 dBA allowance.
·
A tonal pump, whine, hum or repetitive sound could lower the applicable limits by 5 dB. ·
Nighttime standards are 5 dB lower, making off-hour filling or deliveries significantly more difficult to accommodate.

A solid barrier may provide approximately 5 to 10 dB of practical reduction when it fully blocks the line of sight between a ground-level source and receiver. A perimeter wall may therefore help with a truck or pump near grade. It may provide little protection from an elevated vent associated with a 38- foot tank unless the barrier design specifically addresses the vent's height and orientation.

Assessment of the Proposed Resolution
The revised draft resolution improves the proposal by requiring vent silencers, limiting deliveries generally to business hours, and requiring a noise report addressing delivery, filling and venting.

These conditions acknowledge that tank-related operations may create a neighborhood noise impact.

The conditions remain incomplete because they do not clearly require the acoustical study before permits or operation, establish the duration and hours to be tested, identify the nearest residential receptors, require actual manufacturer data, define a mandatory pass-fail standard, or require postinstallation testing during a complete delivery. The resolution also allows unspecified off-hour deliveries as a minor administrative change and allows mitigation to occur after a measured violation.

Recommended Conditions
·Require a qualified acoustical consultant to complete the study before installation permits or operation.
·
Use the final site plan and actual manufacturer sound data for the truck, PTO, pumps, valves, vents, silencers and alarms.
·
Measure and model truck arrival, backing, high-idle operation, pumping, filling, pressure equalization, venting, hose clearing, disconnect and emergency relief events. ·
Evaluate the complete operating cycle and cumulative duration, not merely a short spot measurement.
·
Measure existing ambient sound and evaluate every nearest residential property line and representative dwelling interior.
·
Account for elevated vent locations, tonal or repetitive corrections, simultaneous equipment, nighttime limits and downwind propagation.
·
Prohibit routine deliveries, filling and planned venting outside enforceable weekday daytime hours.
·
Require silencers, barriers, equipment enclosures and vibration isolation necessary to demonstrate compliance before operation.
·
Require post-installation testing during an actual full delivery and establish a prompt corrective-action and enforcement procedure.

Overall Finding
The available record does not demonstrate that nitrogen and argon refilling will comply with the Redondo Beach Noise Regulation at adjacent residences. The preliminary calculations show a credible potential for exceedances at approximately 300 feet, particularly for transfer operations lasting more than 15 minutes. Noise compliance should be demonstrated prospectively through a site-specific acoustical study and enforceable operating conditions, rather than determined only after residents experience a violation.

Thanks,
Nick
2423 Sebald Ave.

Redondo Beach, CA 90278
On Wed, Aug 19, 2026 at 1:30 PM wrote:

Hi Khatirah,
Thank you for your response. I was able to locate the email verification response in my Junk folder and I have loaded my e-comment.

Thanks,
Nick
2423 Sebald Ave.

Redondo Beach, CA. 90278
Sent from my iPhone
> On Aug 19, 2026, at 10:43 AM, Khatirah Nazif <[email protected]> wrote:
>
> Hi Nicholas,
>
> I am sorry to hear you are having trouble submitting an eComment. I reached out to our Support and they advised checking your spam/mail inbox first to make sure the email didn't go there. Also, please whitelist the email address and then request the verification email once more.
>
> Please let me know if this works.
>
> Thank you,
>
> Khatirah Nazif
> City Clerk's Office
> 310.318.0656 ext. 3175
> [email protected]
>
> -----Original Message-----
> From:
> Sent: Tuesday, August 18, 2026 11:26 AM
> To: Daniel Besinaiz <[email protected]>
> Cc: Sean Scully <[email protected]>; Marc Wiener <[email protected]>; Rox Ferebee
> Subject: PC Agenda Item 2026-0595
>
> [You don't often get email from Learn why this is
important at https://aka.ms/LearnAboutSenderIdentification ] >
> CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
>
> Good morning Daniel,
>
> I am trying to post an e-comment for the subject agenda item and I have not received the email authentication required to confirm my account in order to submit the comments.
>
> Could you please let me know if there is an issue with the system or can you help me with creating an account?
>
> Thanks,
>
> Nick
> Sent from my iPhone
> Please note that email correspondence with the City of Redondo Beach, along with attachments, may be subject to the California Public Records Act, and therefore may be subject to disclosure unless otherwise exempt. The City of Redondo Beach shall not be responsible for any claims, losses or damages resulting from the use of digital data that may be contained in this email.
--
Nicholas J. Biro
PUBLIC COMMENT 16 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Erica Davis

ORIGINAL SENT
Thursday, September 17, 2026 at 9:39 AM

SUBJECT
IMPULSE: OPPOSE
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.

From: Daniel Besinaiz
To: Jamaal Brown
Subject: FW: IMPULSE: OPPOSE
Date: Tuesday, September 22, 2026 7:27:40 AM
Hi Jamaal,
This is a public comment for last week's PC meeting. The height variance for impulse.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
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-----Original Message-----
From: Khatirah Nazif <[email protected]>
Sent: Monday, September 21, 2026 2:27 PM
To: Daniel Besinaiz <[email protected]>
Subject: FW: IMPULSE: OPPOSE
Hi! Just wanted to make sure this got included in the Planning Commission public comments -----Original Mess
From: Erica Davis
Sent: Thursday, Se
To: CityClerk <[email protected]>
Cc: Daniel Besinaiz <[email protected]>; Khatirah Nazif <[email protected]> Subject: IMPULSE: OPPOSE
[You don't often get email from Learn why this is important at https://aka.ms/LearnAboutSend
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello,
I am opposed to the height variance request and ask the commission to please deny the request until the concerns of the commissioners and residents have been properly addressed.

Residents should not be required to accept permanent impacts first and seek solutions later.

This is more than a request to place equipment above the normal height limit . It is a land use decision affecting families living near the site. A variance is discretionary and should only be granted when the complete plans, noise and visual studies, written fire approval, enforceable operating and delivery hours, and meaningful neighborhood protections are presented publicly.

Residents are concerned about unknown gas deliveries, truck traffic, refilling, venting, alarms, maintenance and recurring noise.

Residents have already been experiencing ongoing construction violations and operations and 100's of Impulse employees parking in the neighborhood, with minimal enforcement from the city or Impulse.

These effects should be independently studied before approval, not after the tanks are installed and operations begin.

The safety presentation describes general practices but does not provide enough site-specific information to give adjacent residents confidence.

Questions remain about the exact tank locations, gas being used, distances from homes, emergency access, response procedures, coordinations with local fire officials.

The wrong address, references to different stored products, blank fields and lack of signatures further weaken confidence in the submission.

Four approx 40foot Large tanks at the proposed height would be highly visible from homes, yards and streets. They would become a permanent feature without a complete site plan or visual study showing effective screening and compatibility with the neighborhood.

We accept Impulse Space as our new neighbor, but not at the expense of deteriorating our neighborhood and our quality of life.

Our SAFETY is paramount and the city and Impulse Space should ensure they are willing to follow the requested guidelines and stop ignoring our requests and work with the community.

Thank you,
Erica Sheerin Davis
PUBLIC COMMENT 17 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
G. P. Suddeth

ORIGINAL SENT
Thursday, September 17, 2026 at 10:03 AM

SUBJECT
Impulse height variance request
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.

You don't often get email from Learn why this is important From: Daniel Besinaiz
To: Jamaal Brown
Subject: FW: Impulse height variance request
Date: Thursday, September 17, 2026 10:56:57 AM
Attachments: image001.png
Hi Jamaal,
Public comment #4 for variance item tonight.

Thanks,
Daniel
Daniel Besinaiz
Associate Planner
310.697.3191 | [email protected]
We value and welcome your feedback! Please take our short survey so that we can understand how to better serve you (click here).

From: G P Suddeth
Sent: Thursday, September 17, 2026 10:03 AM
To: Daniel Besinaiz <[email protected]>
Cc: CityClerk <[email protected]>
Subject: Impulse height variance request
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Regarding Impuse request:

We in the neighborhood nearest to the Impulse location have received a woeful lack of outreach from Impulse. This request has not been sufficiently explained to merit forwarding to the city council.

G P Suddeth
PUBLIC COMMENT 18 SEPTEMBER 17 PLANNING COMMISSION

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, September 17, 2026 at 3:33 PM

SUBJECT
Blue Folder Item - Planning Commission
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.

From: Sean Scully
To: Jamaal Brown
Subject: FW: Blue Folder Item - Planning Commission
Date: Thursday, September 17, 2026 3:36:21 PM
Here’s another to add to the K.1. item
Planning Manager, Community Development Department
415 Diamond Street, Door 2
Redondo Beach, CA 90277
310-697-3194
From: Mark Nelson (Home Gmail)
Sent: Thursday, September 17, 2026 3:33 PM
To: CityClerk <[email protected]>; Sean Scully <[email protected]>; Wayne Craig <[email protected]>; Mike Witzansky <[email protected]>; Scott Behrendt <[email protected]>; Garth Meyer
Subject: Blue Folder Item - Planning Commission
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Planning Commission - DENY Variance for 2477 Manhattan Beach Blvd Liquid Nitrogen and Argon Tanks
The City staff report is substandard and inaccurate. Diagrams lack customary and required markings. The wrong emergency plan and standard is used - and in fact the standard itself (U.S. DOT/PHMSA 2024 Emergency Response Guidebook (ERG 2024)) states that it is intended only for use in “the initial phase of a transportation incident involving hazardous materials/dangerous goods.” In other words, this is a transportoriented emergency-response document — not a stationary bulk-storage emergency plan. City Staff, perhaps City Fire, and Impulse are all citing incorrect references in this Planning Commission report. It is defective and without oversight. This is a fixed, nearly 50,000 gallon total array of asphyxiating gasses with ample range to snuff out surrouding lives in a rupture, as well as catapult a ton of steel shrapnel.

Further, the draft ordinance itself contains inaccuracies, such as a finding of significance in transport of gas refilling by using 20-foot vs 38-foot tanks. There's no accurate statement of WHAT is significant, nor is there any work paper or reference to Staff or Consultant work. In essence, City Staff MADE UP results, published them in the Ordinance, and recommends approval based on at best substandard work and at worst, inaccurate work.

CITY OF REDONDO BEACH OCTOBER CITY COUNCIL APPEAL
City Council Appeal Public
Comments
October 2026 Appeal Record
2477 Manhattan Beach Boulevard - Case No. 2026-0595

PUBLIC COMMENT COMPILATION
11 distinct email submissions
Original public-sender dates: September 24 - September 29, 2026 Emails are arranged by the original public sender's date and time. Non-government email addresses and personal phone numbers are permanently redacted. 2477 Manhattan Beach Boulevard Case No. 2026-0595
PUBLIC COMMENT 01 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Thursday, September 24, 2026 at 8:02 AM

SUBJECT
Public Comment: The City needs to integrate resident
safety into the permitting process

SUPPORTING MATERIALS INCLUDED
- 2477 Manhattan Beach Blvd - Cryogenic Tank Failure Analysis - Public Comment 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.

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 needs to integrate resident safety into the permitting process Date: Thursday, September 24, 2026 8:02:58 AM
Attachments: 2477 Manhattan Beach Blvd - Cryogenic Tank Failure Analysis - Public Comment.pdf CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

As most of you will recall from reading public comments, there's been no safety analysis conducted regarding the tanks proposed at Impulse Space. No safety for 20-foot tanks, or 30- foot tanks or the 38-foot "variance" tanks. The now RBFD fire chief pointed at LACoFD to do conduct that analysis because RBFD doesn't have HAZMAT. I wrote LACoFD and they wrote back and UNEQUIVOCALLY stated that the City Planning Department and RBFD needed to conduct the safety analysis before permitting. LACoFD offered to help the City.

I pulled a few strings at the government based on my NSF committee service. I now possess the federally chartered suite of gas dispersion models, along with simulated 38-foot, 12,000 gallon argon tanks at 2477 Manhattan Beach Blvd. I was trained in model use today, and ran the analysis. Little surprise to me, there's a zone of potentially fatal impacts on a nice, normal Redondo Beach day if one tank has a catastrophic rupture. Given a 2x2 tank array, I'd suspect ruptures might come in pairs, but I ignored that.

The attached memo outlines the hazard on an average day and on the federally specified worst-case day. It seems intuitively obvious from the modeling results that safety analysis should have been conducted prior to any permit approval.

This is a safety issue and not explicitly part of the variance issue, other than for the failure by the City to conduct that safety analysis when it processed the applicant's plan. Nonetheless, now that it's been demonstrated using EPA and NOAA certified gas plume models that there is a safety issue, it needs to be dealt with prior to any variance - because you cannot issue a variance to an unsafe base project that has had poor City processing and lacks basic safety analysis.

See attached.

Page 1 ends

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.

Page 2 ends

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:

Page 3 ends

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.

Page 4 ends

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

See WorstCasePlume-Marplot.jpg below:

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.

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

Page 5 ends

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.

Page 6 ends

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)

Page 7 ends

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

AVERAGE DAY OF THE YEAR SCENARIO

Page 8 ends

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

WORST CASE SCENARIO
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.

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.

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
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.

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.

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

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. ● 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 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.

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.

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
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
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 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.

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.

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.

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.

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.

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).

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 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)
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
Attachment:
2477 Manhattan Beach Boulevard — Single-Tank Catastrophic Cryogenic Release / HHMD Review Request 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.

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.

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.

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.

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).

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 <[email protected]>; [email protected]; [email protected]; wayne.craig 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
@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)
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.

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.

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."
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
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.

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.

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

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
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
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 environmental-economics proceedings)
Authors: Ian Bateman / Andrew Lovett research described in proceedings 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-WORKSHOP1994-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.

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.

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.

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, 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.

PUBLIC COMMENT 09 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

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

SUBJECT
Testimony: Impulse Space Variance Appeal - Impulse
Sworn Testimony is Inconsistent with City Staff
Findings

SUPPORTING MATERIALS INCLUDED
- Memo to File Impulse Variance Findings vs Testimony
- Impulse Space Testimony Analysis Aug Sep 2026
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.

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: Testimony: Impulse Space Variance Appeal - Impulse Sworn Testimony is Inconsistent with City Staff Findings Date: Friday, September 25, 2026 12:25:19 PM
Attachments: Memo_to_File_Impulse_Variance_Findings_vs_Testimony.pdf Impulse_Space_Testimony_Analysis_Aug_Sep_2026.pdf
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

This transmittal email and the two attached documents are submitted in their totality as testimony in the Impulse Space variance denial appeal proceeding. Included is my memo to file regarding Impulse representatives' sworn testimony at the Planning Commission and how it is contrary to Redondo Beach Staff claims or non-supportive. It is based on a Q&A I developed using the transcript of the August and September Redondo Beach Planning Commission.

This work was prepared under my direction and reviewed by myself. I adopt it as my own based on the official City meeting recordings.

MEMORANDUM TO FILE
Re: Impulse Space Height Variance — Resolution Findings Compared with Applicant Testimony Property: 2477 Manhattan Beach Boulevard, Redondo Beach Resolution: Proposed Resolution No. 2026-09-PCR-11
Record: August 20 and September 17, 2026 Planning Commission hearings Purpose. This memo extracts the material variance findings stated in the City's proposed resolution and places next to them the specific applicant testimony that does not agree with, or does not establish, those findings. The testimony quoted below is limited to Impulse Space representatives, with commissioner questions included only where needed to make the applicant's answer intelligible.

1. Finding: the 30-foot height limit would eliminate Impulse's ability to use the property Resolution finding: ―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 did not testify that denial of the 38-foot variance would eliminate its ability to operate. When directly asked about a compliant alternative, Impulse agreed that smaller tanks were feasible:

Commissioner: ―Okay. So, so it is it is feasible to do it smaller tanks. More smaller tanks.‖ Impulse: ―Yeah.‖
— August hearing, approximately 01:54:53
Later, when asked what a denial would do, Impulse described the effect as “pretty impactful,” but expressly contemplated obtaining many more tanks rather than stating that operations would cease:

Commissioner: ―But have you considered the possibility that you get a thumbs down tonight? What does that do?‖
Impulse: ―Yeah, it’s pretty impactful to our business.‖ … ―Yeah, it’s hard to quantify exactly what that would be. You know, whether whether we could do what Commissioner Boswell said and go get many more tanks....‖
— August hearing, approximately 02:14:06–02:14:59
Record comparison: the applicant's testimony describes a less desirable alternative configuration, not an elimination of the manufacturing use.

2. Finding: the required infrastructure cannot be accommodated at a lesser height Resolution finding: ―the technical requirements of this required infrastructure ... cannot be accommodated at a lesser height without resulting in significantly more frequent deliveries....‖ The first clause is inconsistent with Impulse's direct answer that smaller tanks are feasible:

Commissioner: ―So, so it is it is feasible to do it smaller tanks. More smaller tanks.‖ Impulse: ―Yeah.‖
— August hearing, approximately 01:54:53
Impulse also confirmed that it was already operating with smaller tanks at its existing facility:

Commissioner: ―...how long it takes to fill the smaller tanks, although you’re employing smaller tanks right now in your existing operations.‖
Impulse: ―About the same time.‖
— August hearing, approximately 01:55:46
Record comparison: the testimony supports an operational preference for the larger tanks, but not a finding that the infrastructure itself cannot be accommodated at a lesser height.

3. Finding: lesser-height tanks would result in “significantly more frequent deliveries” Resolution finding: lesser-height infrastructure would result in ―significantly more frequent deliveries.‖
Impulse testified qualitatively that more tanks would mean more truck activity, but it did not quantify the alternative. When asked about the consequences of denial, it stated:

Impulse: ―Yeah, it’s hard to quantify exactly what that would be. You know, whether whether we could do what Commissioner Boswell said and go get many more tanks. Certainly the impact is absolutely parking. It is also impacted the neighborhood. It’s just more more trucks. Um so we could look at that as well, but but yeah, we we’d have to come back and do that impact assessment.‖ — August hearing, approximately 02:14:31–02:14:59
Impulse did provide some logistics information: it said each fill involves a truck; smaller tanks at the existing facility use a smaller truck; and the fill process for those smaller tanks takes about the same time.

Impulse: ―every time you fill a tank, it’s a truck.‖ …
Commissioner: ―Oh, it it takes the same amount of time.‖ Impulse: ―About the same time. The primary time that it takes is ... the time to prep as well as deconfigure.‖
Commissioner: ―So, in fact, it would be a smaller truck that comes in to fill the smaller tanks.‖ Impulse: ―Yeah.‖
— August hearing, approximately 01:55:19–01:56:34
Record comparison: Impulse supports the direction of the claim—more/smaller tanks could mean more truck events—but expressly states that the magnitude had not been quantified and that an impact assessment still needed to be performed. The testimony therefore does not itself establish the Resolution's characterization of the increase as “significantly” more frequent.

4. Finding: additional deliveries have the potential for the “greatest impact” on the adjacent residential neighborhood
Resolution finding: the more frequent deliveries ―have the potential for the greatest impact on the adjacent residential neighborhood south [of] the subject property.‖ Impulse asserted that more tanks and trucks would increase disruption, but its testimony also acknowledged that it had not performed the comparative impact assessment needed to quantify that alternative:

Impulse: ―So the disruption to not only the business but more importantly the neighborhood would actually go up with more tanks.‖
— August hearing, approximately 01:55:19
Impulse: ―it’s hard to quantify exactly what that would be.... It’s just more more trucks. Um so we could look at that as well, but but yeah, we we’d have to come back and do that impact assessment.‖
— August hearing, approximately 02:14:31–02:14:59
Record comparison: the applicant testified to a potential increase in truck-related disruption, but did not present a comparative analysis establishing that this would be the “greatest” neighborhood impact relative to the 38-foot-tank alternative.

5. Finding: the tanks are critical infrastructure whose technical requirements “cannot be significantly altered”
Resolution finding under the special-privilege criterion: ―The adjustment only allows for critical infrastructure with technical requirements that cannot be significantly altered....‖ Impulse described the proposed vertical tanks as standard, pre-engineered equipment rather than equipment custom-designed to a fixed Impulse specification:

Impulse: ―when we order these tanks, these are standard size tanks. You know, we’re not asking the provider to re-engineer something and that’s by design.‖ Commissioner: ―So it is off the shelf.‖
Impulse: ―It is off the shelf.‖
— August hearing, approximately 01:20:13
Impulse: ―they are a standard design.‖ … ―If they are currently built and in stock, then they’ll deliver them.‖
— August hearing, approximately 02:02:00–02:02:33
Record comparison: this testimony explains why Impulse prefers the standard vertical product, but combined with its express acknowledgment that smaller tanks are feasible, it does not establish that the relevant infrastructure requirements cannot be significantly altered.

Conclusion
The central conflict is narrow. The proposed Resolution converts Impulse's preference for four standard 38-foot tanks into findings of necessity: that the 30-foot limit would eliminate use of the manufacturing facility; that the infrastructure cannot be accommodated at a lesser height; and that a compliant alternative would produce significantly more deliveries with the greatest neighborhood impact. Impulse's own testimony does not go that far. It expressly agrees that smaller tanks are feasible, acknowledges existing use of smaller tanks, contemplates obtaining many more tanks if the variance is denied, and states that the resulting impacts are “hard to quantify exactly” and would require an impact assessment.

Source note. Resolution language is from proposed Resolution No. 2026-09-PCR-11. Testimony is from the City YouTube transcripts for the August 20 and September 17, 2026 Planning Commission hearings.

Quoted transcript wording is preserved substantially as transcribed; timestamps are included for verification against the video.

Impulse Space Testimony Analysis — August/September 2026 Impulse Space Testimony Analysis
Redondo Beach Planning Commission — August and September 2026 Prepared from the two supplied meeting transcripts
Scope and method. Questions 1–7 are answered using only statements made by Impulse Space representatives in the supplied transcripts. Statements by City staff, commissioners, fire personnel, and members of the public are excluded as evidence for those answers, except that a commissioner’s question is quoted when necessary to make an Impulse answer intelligible. Question 8 necessarily uses the procedural transcript surrounding the applicant testimony. No outside sources or assumptions are used. Transcript timestamps are provided so each finding can be checked against the source video/transcript.

Executive Summary
Question Finding Bottom line

1. 38-ft tanks required for
continued operation?
No explicit
assertion.

Impulse argues the 38-ft configuration is preferred/required by safety, technical, operational and regulatory considerations for the expansion, but never says it cannot continue operating without 38-ft tanks. Its August testimony also acknowledges smaller tanks are feasible.

2. Operation with 30-ft/shorter
tanks?
Yes, partially. Impulse acknowledges more smaller tanks are feasible and explains they would mean more tanks/truck fills; smaller tanks at the existing site use a smaller truck and take about the same fill time. It does not provide a complete 30-ft alternative operating plan.

3. Tanks custom designed? No. Impulse describes them as standard-size/standard-design, preengineered equipment and says it is not asking the provider to re-engineer a custom tank.

4. Owned/supplied by gas
provider?
Yes. Impulse states the tanks are ―owned and operated by the gas supplier.‖

5. Traffic impacts from fills? Qualitative only. Impulse gives fill frequency, approximate duration, trucksize/logistics information, and says more smaller tanks would increase truck activity. It provides no quantified traffic-impact analysis or trip-count comparison.

6. LIN/LAR consumption rate? No quantified
rate.

No gallons/week or separate LIN/LAR consumption rate is given. Fill-frequency estimates and telemetry/usage
monitoring are discussed.

7. Neighborhood safety analysis /
dispersion modeling?
No such analysis
identified.

Impulse discusses safety systems, regulatory review, siting and operational safety, but does not testify that it performed neighborhood dispersion modeling, oxygen-deficiency
modeling, or a quantitative off-site risk analysis.

8. Sworn before testimony? August: Yes.

September: not
re-sworn.

The August applicant representatives expressly answered the oath. In September, the Chair raised re-administering the oath and was told they did not have to; the Impulse representatives then testified without a new oath in the transcript.

1. Does Impulse ever assert that the 38-foot tanks are required for continued operation?
Answer: No. The transcripts contain no Impulse statement that continued operation of the company or facility depends on approval of 38-foot tanks.

Impulse Space Testimony Analysis — August/September 2026 Impulse makes a narrower and materially different claim: the proposed configuration is sized for the expanded facility and is, in its view, the safest and best fit with technical, operational and regulatory requirements. In September it says changing tank size/orientation would compromise those requirements. But it does not say denial of the 38-foot configuration would prevent continued operations. In August, Impulse also agrees that using more smaller tanks is feasible, which undercuts any reading that 38-foot tanks are the only physically possible means of operation.

Key Impulse testimony
“these tanks are engineered and they’re sized for our specific operational needs. That sizing is not the discretion of Impulse.” — August, ~01:12:18
“asking Impulse to make a design-based change … to the tanks would compromise the safety, technical, operational, and regulatory requirements of our business.” — September, ~00:56:27 “So, so it is feasible to do it smaller tanks. More smaller tanks. >> Yeah.” — August, ~01:54:53

2. Does Impulse provide any information about how it would operate with 30-foot or shorter tanks?
Answer: Yes, but only in fragments; it does not present a complete 30-foot-tank operating alternative.

In August, when asked whether smaller tanks/more tanks were feasible, Impulse answered yes. It then explained that more tanks would increase the number of truck connections/fills and that fill preparation/deconfiguration dominates the roughly one-hour process. It said its existing smaller tanks use a smaller truck because of access constraints, while the proposed site can accept larger trucks for the larger tanks. In September it additionally explains why it disfavors horizontal tanks: it says the nitrogen elevation assists flow across the roughly 1,000-foot building and horizontal tanks would require pumps, creating noise. None of this is a detailed design for four/six 30-foot tanks, including capacities, exact fill frequency, footprint, or costs.

Key Impulse testimony
“So, so it is feasible to do it smaller tanks. More smaller tanks. >> Yeah.” — August, ~01:54:53 “we can’t use the same size tanks because every time you fill a tank, it’s a truck.” — August, ~01:55:19 “We also need … a smaller truck that comes in [at the current facility] … With these … we can get bigger trucks into the space to fill these larger tanks.” — August, ~01:56:12–01:56:34 “If we had horizontal tanks, we would need pumps to flow that nitrogen as opposed to letting gravity flow throughout the facility itself. Pumps create noise.” — September, ~01:07:51

3. Does Impulse indicate that the tanks are custom designed? Answer: No. Impulse repeatedly characterizes the proposed tanks as standard or pre-engineered rather than customdesigned for Impulse.

The clearest August testimony is that the tanks are ―standard size tanks‖ and Impulse is ―not asking the provider to reengineer something.‖ Later, Impulse calls them a ―standard design‖ and says availability depends on whether units are already built and in stock. It also says a horizontal version would require a different design and that it would have to ask the company to build one. The testimony therefore distinguishes the proposed tanks from a custom/re-engineered alternative.

Key Impulse testimony
Impulse Space Testimony Analysis — August/September 2026 “these are standard size tanks. You know, we’re not asking the provider to re-engineer something and that’s by design.” — August, ~01:20:13
“they are a standard design.” — August, ~02:02:00
“If they are currently built and in stock, then they’ll deliver them.” — August, ~02:02:33

4. Does Impulse indicate if the tanks are owned or supplied by the liquefied-gas provider?
Answer: Yes. Impulse states that the tanks are owned and operated by the gas supplier.

This is direct applicant testimony during the August questioning. The same exchange also indicates that standarddesign tanks may be delivered if already built and in stock. The testimony does not identify the supplier by name in the passages reviewed.

Key Impulse testimony
“The tanks are … owned and operated by the gas supplier.” — August, ~02:02:00

5. Does Impulse provide any traffic impacts from required fills of either 38-foot or smaller tanks?
Answer: It provides operational/logistics information, but no quantified traffic-impact analysis.

For the proposed tanks, Impulse estimates roughly one-hour fills, initially about monthly and at full production about weekly, generally mornings to early afternoon. It says the proposed site can accept larger trucks. For smaller tanks, it says fill time is about the same, smaller trucks are used at its existing constrained site, and more tanks would mean more truck events/connections. It also states that the planned truck path would not require employees to move parked cars. However, Impulse provides no traffic study, no trips-per-day/week calculation separating LIN from LAR, no roadway level-of-service analysis, and no quantified comparison of 38-foot versus 30-foot alternatives.

Key Impulse testimony
“initially … it’s probably expected to be once a month for an hour … as we go into full production capacity it’s going to be about once a week.” — August, ~01:16:12
“typically … the filling hours is usually in the mornings to the early afternoon.” — August, ~01:16:42 “every time you fill a tank, it’s a truck.” — August, ~01:55:19 “the disruption to not only the business but more importantly the neighborhood would actually go up with more tanks.” — August, ~01:55:19
“we have planned out the parking lot so that we’re not going to put any people’s cars in the path of the truck.” — August, ~01:59:34

6. Does Impulse provide insight into LIN or LAR consumption rates, such as gallons per week?
Answer: No quantified LIN or LAR consumption rate is provided.

Impulse explains the uses of nitrogen and argon and gives expected fill frequency, but does not state gallons per week, gallons per production unit, separate LIN/LAR draw rates, or projected annual consumption. September testimony says Impulse Space Testimony Analysis — August/September 2026 its telemetry detects changes in quantity and ―excess usage,‖ including a recent nitrogen-use event, but gives no numerical consumption rate.

Key Impulse testimony
“liquid nitrogen … [is] a high cleanliness, high purity substitute for compressed air … liquid argon … is a shielding gas [for welding].” — August, ~01:11:09–01:11:43 “if you see excess usage, even if the tank is 90% full, they’re getting an alarm.” — September, ~01:05:28 “there was a case about three weeks ago … where we saw excess usage … it was a normal operation.” — September, ~01:05:54

7. Does Impulse indicate that it has conducted any neighborhood safety analysis, such as dispersion modeling?
Answer: No. The Impulse testimony does not identify any neighborhood dispersion model, oxygen-deficiency model, quantitative off-site risk assessment, or comparable neighborhood consequence analysis.

Impulse testifies extensively about safety: manufacturer recommendations, venting/leak-before-burst concepts, on-site safety personnel, telemetry, fire/CUPA/Cal-OSHA review, siting constraints, and the safety rationale for its preferred tank configuration. Those are not the same as modeling the off-site consequences of a release into the surrounding residential neighborhood. No Impulse representative states that such neighborhood modeling was performed, and no modeled distance, oxygen concentration contour, release scenario, or consequence radius is presented by Impulse in either transcript.

Key Impulse testimony
“we have our own on-site safety team.” — August, ~01:21:57 “part of my job is the safety and regulatory compliance of really any component, tank, whatever it might be, on our site.” — September, ~00:58:05
“we would move on to the building and permit and plan review, followed by fire code … [and] the LA County CUPA.” — September, ~00:58:05–00:59:12

8. Did the Planning Commission require Impulse representatives to be sworn prior to testimony?
Answer: August: yes. September: the transcript shows no new oath was administered before the continued-hearing testimony.

At the August hearing, the Chair expressly called the applicant forward ―to swear you in,‖ administered a truth oath, and received an affirmative response before Michael Gilway and Jeff DeFazio identified themselves and testified. At the September continued hearing, the Chair raised administering the oath ―again,‖ then asked whether it was necessary; the response in the transcript was ―they don’t have to,‖ followed by ―Yeah, I don’t have to.‖ Jeff DeFazio and Mike McDermott then identified themselves and testified. Thus, as a transcript fact, August testimony was expressly sworn and September testimony was not re-sworn on the record. This report does not determine whether the August oath legally carried over to the continued hearing or whether a new oath was legally required.

Key Impulse testimony
Impulse Space Testimony Analysis — August/September 2026 “do you promise to tell the truth, the whole truth, and nothing but the truth? >> Yes, sir.” — August, immediately before Impulse testimony, ~01:06:05
“I’ll ask you to administer the oath again even though I think it’s still continued or do I need to? … they don’t have to. >> Yeah, I don’t have to.” — September, ~00:50:01
Overall Evidentiary Takeaway
The testimony supports a distinction between “preferred/standard configuration” and “necessary to continue operating.” Impulse presents the 38-foot vertical tanks as the standard, safest and operationally preferred configuration for its expansion. At the same time, its August testimony acknowledges that smaller tanks are feasible and describes how their logistics would differ. The record therefore contains operational reasons for preferring the 38-foot tanks, but no Impulse statement that denial of the variance would make continued operation impossible. The record also contains no quantified LIN/LAR consumption rate, no quantified comparative traffic analysis, and no identified neighborhood dispersion or off-site consequence model.

Source Notes
August source: ―Aug2026RBPCMtg_Transcript(2).docx,‖ supplied transcript of the August 2026 Redondo Beach Planning Commission meeting.

September source: ―sep2026RBPCMtg_Transcript(1).docx,‖ supplied transcript of the September 17, 2026 Redondo Beach Planning Commission meeting.

Quoted language follows the automated transcript and may contain transcription errors in names or wording.

Timestamps are the principal locator for verification against the City video.

PUBLIC COMMENT 10 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Mark Nelson

ORIGINAL SENT
Friday, September 25, 2026 at 2:20 PM

SUBJECT
Testimony: Impulse Space Variance Appeal - City Staff
and Commissioners statements are Inconsistent with
City Staff Findings

SUPPORTING MATERIALS INCLUDED
- City Staff Focused-Memo to File Impulse Variance Findings vs Record 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.

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: Testimony: Impulse Space Variance Appeal - City Staff and Commissioners statements are Inconsistent with City Staff Findings
Date: Friday, September 25, 2026 2:20:08 PM
Attachments: City_Staff_Focused-Impulse_City_Record_Analysis_Aug_Sep_2026.pdf City_Staff_Focused-Memo_to_File_Impulse_Variance_Findings_vs_Record.pdf CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

This transmittal email and the two attached documents are submitted in their totality as testimony in the Impulse Space variance denial appeal proceeding. Included is my memo to file regarding statements of City Staff and Commissioners at the Planning Commission and how those statements are contrary to claims and findings made by the City in proposed Resolution 2026-09-PCR-11. The memo is based on a Q&A I developed using the transcript of the August and September Redondo Beach Planning Commission extracting statements of City Staff and Commissioners are relevant.

This work was prepared under my direction and reviewed by myself. I adopt it as my own based on the official City meeting recordings.

Memo to File — Impulse Space Variance Findings vs. Hearing Record

MEMORANDUM TO FILE
Re: Impulse Space Height Variance — Proposed Resolution Findings Compared with Hearing Record Property: 2477 Manhattan Beach Boulevard, Redondo Beach Resolution: Proposed Resolution No. 2026-09-PCR-11
Record: August 20 and September 17, 2026 Planning Commission hearings Purpose. This memo extracts the material factual findings in the City's proposed variance resolution and places immediately below them the specific hearing Q&A or testimony that conflicts with, narrows, or fails to establish the finding. The comparison uses the City's proposed resolution and the August and September Planning Commission hearing record.

1. Finding that the 30-foot limit would eliminate use of the manufacturing facility Resolution finding: “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....” City Staff: ―If it was 30 feet, no. And that was something we did explore with the applicant and … this size tank really met their needs and they felt like it was worthwhile to apply for the variance for this.‖ — August, approx. 01:43:20
Commissioner: ―So basically … this extra eight feet is requiring this additional process, but if they added two more tanks, we would have never heard it probably if there were 30 ft or smaller.‖ — August, approx. 01:43:51–01:44:15
City Staff: ―That’s correct.‖
— August, approx. 01:44:15
Commissioner: ―Okay. So, so it is it is feasible to do it smaller tanks. More smaller tanks.‖ — August, approx. 01:54:53
Impulse: ―Yeah.‖
— August, approx. 01:54:53
Record comparison: The resolution states elimination of the manufacturing use. Staff instead says the 38-foot tanks “really met their needs” and confirms that a 30-foot-or-smaller configuration could avoid the variance.

Impulse separately agrees that smaller/more tanks are feasible. The hearing record therefore describes an alternative configuration, not elimination of the manufacturing use.

2. Finding that the infrastructure cannot be accommodated at a lesser height Resolution finding: “the technical requirements of this required infrastructure in support of this aerospace manufacturing operation (permitted use) cannot be accommodated at a lesser height....” Commissioner: ―Why not six shorter tanks and get it under that 30 foot? … can you buy off-the-shelf tanks … that are 30 feet or shorter and just have more tanks?‖
— August, approx. 01:44:45–01:45:27
City Staff: ―I would defer to the applicant on that….‖
— August, approx. 01:45:27
Commissioner: ―So, so it is it is feasible to do it smaller tanks. More smaller tanks.‖ — August, approx. 01:54:53
Impulse: ―Yeah.‖
— August, approx. 01:54:53
Memo to File — Impulse Space Variance Findings vs. Hearing Record Record comparison: The resolution uses the categorical phrase “cannot be accommodated at a lesser height.” City staff does not establish that proposition when directly asked about shorter tanks; it defers to the applicant.

The applicant then expressly agrees that smaller tanks are feasible.

3. Finding that lesser-height infrastructure would cause “significantly more frequent deliveries” Resolution finding: “[The infrastructure] cannot be accommodated at a lesser height without resulting in significantly more frequent deliveries....”
City Staff: The larger size and number of tanks ―reduces the overall … number of times that the tanks have to be refilled.‖
— September, approx. 00:47:06–00:47:43
Impulse: ―Yeah, it’s hard to quantify exactly what that would be. You know, whether whether we could do what Commissioner Boswell said and go get many more tanks....‖ — August, approx. 02:14:06–02:14:59
Impulse: ―we’d have to come back and do that impact assessment.‖ — August, approx. 02:14:06–02:14:59
Record comparison: The record supports the qualitative proposition that smaller tanks could require more refill activity. It does not establish the resolution's modifier “significantly.” No comparative calculation of tank capacity, gas consumption, tanker capacity, deliveries per month/year, or truck trips is identified; Impulse says the consequence is “hard to quantify exactly” and that an impact assessment would still have to be done.

4. Finding that additional deliveries have the potential for the “greatest impact” on the adjacent residential neighborhood
Resolution finding: Shorter infrastructure would result in deliveries “which have the potential for the greatest impact on the adjacent residential neighborhood....”
City Staff: Fewer refills reduce ―the potential impact on the adjacent residences.‖ — September, approx. 00:47:06–00:47:43
Impulse: ―it’s hard to quantify exactly what that would be.‖ — August, approx. 02:14:06–02:14:59
Impulse: ―we’d have to come back and do that impact assessment.‖ — August, approx. 02:14:06–02:14:59
Record comparison: Staff identifies a potential impact from refill events, but the record cited here contains no comparative analysis establishing that deliveries are the “greatest” neighborhood impact. No comparison is identified against visual effects, visibility of tanks above the 30-foot limit, property-value effects, traffic, noise, vibration, parking, or other neighborhood effects.

5. Finding based on privileges enjoyed by other property under the applicable zoning comparison Resolution finding: The required variance criterion refers to special circumstances such that strict application deprives the property of “privileges enjoyed by other property in the vicinity and under identical zone designation.” The resolution then justifies relief by referring to nearby properties with a “similar zoning designation” and surrounding industrial properties permitted at heights over 100 feet.

City Staff: The subject site is IC-1 with a 30-foot maximum height; the area immediately south across Manhattan Beach Boulevard is R-1.
— August, approx. 00:35:22–00:36:28
City Staff: Adjacent zones ―allow a height up to 110 ft‖ and have ―the exact same list of permitted uses‖ while the subject property has a 30-foot height limit.
— September, approx. 00:47:43–00:48:23
Memo to File — Impulse Space Variance Findings vs. Hearing Record Record comparison: The stated criterion says “identical zone designation.” Staff's oral justification relies substantially on adjacent properties with a different height entitlement — up to 110 feet — and describes the relevant zoning as the “same or similar.” The two-hearing record does not identify another IC-1 property with the same 30-foot limit that has been granted the requested height privilege.

6. Finding that the variance does not constitute a special privilege Resolution finding: “The variance does not constitute a special privilege....” The resolution states that the adjustment allows “critical infrastructure with technical requirements that cannot be significantly altered” without granting development rights unavailable to similarly situated properties.

City Staff: ―If it was 30 feet, no. And that was something we did explore with the applicant and … this size tank really met their needs....‖
— August, approx. 01:43:20
Commissioner: If additional tanks were ―30 ft or smaller,‖ the matter likely would not have come before the Commission.
— August, approx. 01:43:51–01:44:15
City Staff: ―That’s correct.‖
— August, approx. 01:44:15
Record comparison: The record establishes that the requested eight feet is a development right the property does not presently possess and that compliant tanks would avoid the variance. The reviewed City-side hearing record does not identify another IC-1 height variance or an identical-zone property possessing the same privilege.

7. Finding that the tanks are “critical infrastructure” whose technical requirements cannot be significantly altered
Resolution finding: “The adjustment only allows for critical infrastructure with technical requirements that cannot be significantly altered....”
City Staff: Staff describes 38 feet as ―a standard tank size and height‖ and says a custom size ―would actually be a little bit more risky.‖
— September, approx. 00:46:25–00:47:06
City Staff: The 38-foot size ―really met their needs.‖
— August, approx. 01:43:20
Commissioner: ―So, so it is it is feasible to do it smaller tanks. More smaller tanks.‖ — August, approx. 01:54:53
Impulse: ―Yeah.‖
— August, approx. 01:54:53
Record comparison: The oral City record does not define “critical infrastructure.” Staff describes the proposed tanks as standard equipment and as meeting Impulse's needs. The applicant expressly acknowledges a smallertank alternative. Those statements do not establish the resolution's categorical proposition that the technical requirements “cannot be significantly altered.”
Bottom Line
The principal discrepancy is between the categorical language of the proposed resolution and the more limited hearing record. The resolution states that enforcing the 30-foot limit would eliminate the manufacturing use, that the infrastructure cannot be accommodated at a lesser height, that a compliant alternative would produce significantly more deliveries with the greatest neighborhood impact, and that the requested height is critical infrastructure whose technical requirements cannot be significantly altered. The hearing record instead establishes that 30-foot-or-smaller tanks were considered, that such a configuration could avoid the variance, Memo to File — Impulse Space Variance Findings vs. Hearing Record that smaller/more tanks are feasible, and that the delivery consequences had not been quantitatively established. Staff's stated basis also relies on nearby properties with materially greater height entitlements rather than an identified IC-1 comparator with the same 30-foot limit.

Sources
Proposed Resolution No. 2026-09-PCR-11, 2477 Manhattan Beach Boulevard; August 20, 2026 and September 17, 2026 Redondo Beach Planning Commission transcript extracts from the City YouTube meetings.

Timestamps are approximate.

PUBLIC COMMENT 11 OCTOBER CITY COUNCIL APPEAL

ORIGINAL SENDER
Alicia Evans

ORIGINAL SENT
Tuesday, September 29, 2026 at 7:00 PM

SUBJECT
Re: PUBLIC COMMENT - THE CITY MUST DENY THE
IMPULSE SPACE 38-FOOT HEIGHT VARIANCE
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.

From: alicia evans
To: Sean Scully; Joy Ford; CityClerk
Subject: Re: PUBLIC COMMENT - THE CITY MUST DENY THE IMPULSE SPACE 38-FOOT HEIGHT VARIANCE Date: Tuesday, September 29, 2026 7:00:12 PM
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Hello All,
I want to make sure my voice is heard-I oppose any type of variance. I completely oppose the variance for Impulse Space. In addition, more test and compliance is needed! Why are they getting different treatment vs other companies and residents? This isn’t right & you know it!
Regards,
Alicia Evans
Sent from my iPhone
On Sep 20, 2026, at 8:42 AM, alicia evans wrote:

City Council, Planning Commissioners, City Attorney
loppose the Impulse Space variance for 38-foot tanks.

The City's proposed Resolution 2026-09-PCR-11 required specific findings to approve the variance.

The facts in the public record do not support those findings.

1. The Resolution said the 30-foot limit would prevent Impulse from using the property for its manufacturing facility. That directly contradicts Impulse Space's sworn testimony.

2. The Resolution said the required infrastructure
"cannot be accommodated at a lesser height."
The facts directly contradict that finding.

3. The Resolution said shorter tanks would cause
"significantly more frequent deliveries." No quantitative analysis was provided to support that finding.

1. The Resolution said additional deliveries could have the "greatest impact" on the residential neighborhood. No comparative neighborhood-impact study supported that finding.

2. The Resolution required comparison with properties under an "identical zone designation." Staff instead relied on properties with different zoning and much greater height limits.

1. The Resolution treated similar industrial uses as justification for similar development rights.

The zoning facts show otherwise.

2. The Resolution said the variance would not grant Impulse a "special privilege." The facts do not establish that finding.

3. The Resolution did not establish that the additional eight feet would have no impact on the residential neighborhood. No analysis supported such a conclusion.

4. The Resolution proposed approval before some neighborhood impacts had even been measured. The record for granting a variance is incomplete and cannot be used to support a variance.

The conclusion is simple.

The City's proposed Resolution required findings to approve the Impulse variance. The public record does not support several of those findings. Some findings are contradicted by Impulses own sworn testimony. Other findings were made without the studies or calculations needed to support them. And some findings rely on development rights belonging to differently zoned properties.

The Planning Commission rejected this approval
Resolution 4-3. Those unsupported findings should not now be reused as facts.

Based on the City's own proposed Resolution and the evidence in the public record, the Impulse Space request for 38-foot tanks does not meet the requirements stated for approval of the variance.

Sincerely,
Alicia Evans
Sent from my iPhone

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