From: Mark Nelson ( Home Gmail)
To: CityClerk
Subject: Blue Folder for Impulse Variance - Catalog of STANDARD Tanks Date: Tuesday, October 6, 2026 6: 05: 13 PM
Attachments: Linde Cryo Tanks. pdf
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
The 38-foot tank comes in 28-foot as well. NO REQUIREMENT FOR CUSTOM DESIGN.
NONE.
Cryogenic
Standard Tanks
LITS 2
Title- page: The Linde standard tanks
2 3 Introduction
4 Standard vacuum-insulated tanks
5 Quality standards for cryogenic tanks
Optional standards for enhanced quality
6 Technical data - tanks for air gases LIN, LOX, LAR
7 Technical data - tanks for carbon dioxide
8 Features
Highly effective operation
Safety
Easy operation
Ergonomical position of controls and instruments
Non- corroding transport and lifting devices
10 Flow diagram - tanks for nitrogen, oxygen, argon
11 Flow diagram - tanks for carbon dioxide
12 Clip-on standard design
Special VAP - Quality for specific use
14 SHEQ - safety, health, environment and quality police 15 Service and guarantee
16 Contact
Contents.
3 To an increasing extent, industrial gases such as
oxygen, nitrogen and argon are delivered to customers in liquid form at cryogenic temperatures and stored by the customer in tanks before further use.
The pressure ratings and sizes of these tanks have
been standardised in accordance with the requirements of distribution logistics and economical series production.
3 Introduction.
Arrangements of valves, pipes and instrumentation
The vacuum- insulated double wall tanks consist
of two concentric vessels, an austenitic steel
inner tank and an outer jacket in carbon steel
with an anti- corrosion primer and a special environmentally friendly top coat. The interspace between inner and outer tank is evacuated and
filled with insulating powder ( perlite). An adsorbent is also added to maintain the vacuum in the insulation interspace.
The standard tanks come in gross nominal water
capacities from 3,160 litre to 61, 620 litre. The
maximum allowable working pressure for the
inner vessels is 18, 22 or 36 bar gauge for design
temperatures ranking from - 196° C up to 20° C.
All standard tanks have vertical configuration,
requiring little space for installation.
The pressure vessels are manufactured and tested in accordance with the Pressure Equipment Directive EU 97/ 23/ EC and EN 13458. These codes are internationally accepted. Consequently, it will
be much easier than before to install and use
these tanks in and outside of the European Union.
The Linde quality management system satisfies
all elements of the ISO 9001 program. All produced tanks are subjected to inspection and quality control under supervision of independent inspection bodies.
The operating pressure may be set up to 90 % of
the maximum allowable working pressure and is
automatically maintained constant by the regulator and pressure building coil fitted to the tank.
Each tank can also be equipped with a tank
mounted ( clip- on) air- heated vaporiser to
supply product in gaseous form at ambient
temperatures and flow rates up to 120 Nm3/ h.
Standard tank features are various fittings for
transportation and installation. Vaporisers up
to 1,000 Nm3/ h are installed separately.
Based on the standard design, Linde offers additional features depending on client´ s requirements.
Standard carbon dioxide tanks are very similar
to the tanks for air gases. As a function of the
application and customer’ s request you have
here the choice between an inner vessel either
manufactured from a low temperature resistant
austenitic steel or a fine grain carbon steel. The
insulation system is equal to the system which
is used for the air gas tanks.
CO2- tanks, equipped with an inner vessel made
out of a low temperature resistant austenitic
steel can therefore also be used as multi- purpose storage for other industrial gases.
Linde owns long standing experience in handling other liquefied gases such as for example LNG and hydrogen. Tanks for these gases are
engineered and manufactured according to customers specifications, therefore quotations will be elaborated from case to case.
4 Standard vacuum insulated tanks.
Quality management and inspection is based
on the following guiding principles:
Quality management and inspection is an indispensable part of our corporate strategy and therefore a managerial responsibility carried
out at all levels of the company. We consider the
improvement of our product quality and the continued development of our quality management system as a permanent challenge.
The Schalchen Plant is certified according to:
EN ISO 9001/ 2000
ASME ( U, U2, R- Stamp)
Manufacture license of special equipment
People‘ s Republic of China and others
Acceptance inspection is carried out by the
experts of the Notified Body acc. to the valid
international) laws and further by Linde´ s
own specialists.
5 Quality standards for cryogenic tanks.
Optional standards for enhanced quality
Depending on customer requirements the tanks are
available in two enhanced quality degrees:
Quality degree Technical detail Applications
HQ
Degree for media – Inner vessel stainless steel High demands in semiconductor with purity > 5.0 – Inner vessel and pipes pickled industry and research Stainless steel cryogenic valves
below sealed
IQ
Degree for corrosive – Inner vessel stainless steel Corrosive environment industrial environment – Stainless steel cryogenic valves with stuffing box
Technical data - tanks for air gases LIN, LOX, LAR.
6 LIN = liquid nitrogen; LOX = liquid oxygen; LAR = liquid argon Size 30 60 110 200 300 490 610 800
Max. allowable working pressure air gases: 18 bar, 36 bar for LIN only Gross capacity approx. litre 3,160 6,365 11,535 20,355 30,205 49,020 61,620 80,360 Net capacity approx. litre 18 bar 3,000 6,050 10,960 19,340 28,700 46,570 58,540 76,340 36 bar 2,840 5,730 10,380 18,320 27,180 44,120 55,460
Pressure stage
18 bar, kg LIN 2,425 4,890 8,855 15,630 23,190 37,630 47,300 61,680 filling ratio 95 %, 1 bar kg LOX 3,425 6,910 12,530 22,090 32,885 53,180 66,850 kg LAR 4,185 8,440 15,290 26,980 40,040 64,965 81,660
36 bar, kg LIN 2,300 4,630 8,390 14,800 21,970 35,650 44,810 filling ratio 90 %, 1 bar kg LOX 3,250 6,540 11,850 20,920 31,050 50,390 63,340 kg LAR 3,970 7,990 14,480 25,560 37,920 61,550 77,370
Boil- off rate %/ d LIN 0.67 0.58 0.44 0.31 0.30 0.21 0.20 0.19 1 bar, 15° C A.T. %/ d LOX 0.42 0.37 0.29 0.20 0.19 0.13 0.12 referred to total capacity %/ d LAR 0.46 0.40 0.32 0.21 0.21 0.15 0.14 vacuum < 2 x 10-2 mbar
Discharge capacity with standard pressure building
coil at 0,7 x MAWP and 8 hours operating time
pressure stage
18 bar m3/ h (1 bar, 15° C) LIN 150 300 300 600 600 600 m3/ h (1 bar, 15° C) LOX 190 380 380 750 750
m3/ h (1 bar, 15° C) LAR 190 380 380 750 750
36 bar m3/ h (1 bar, 15° C) LIN 140 140 140 280 280
m3/ h (1 bar, 15° C) LOX 180 180 180 360 360
m3/ h (1 bar, 15° C) LAR 180 180 180 360 360
Capacity of one safety valve at 1.1 x MAWP/ cold condition pressure stage
18 bar kg/ h LIN 1,090 1,070
kg/ h LOX 1,010
kg/ h LAR 1,240
36 bar kg/ h LIN 5,610
kg/ h LOX 2,260
kg/ h LAR 2,850
Insulation insulating powder ( perlite), vacuum < 5 x 10-2 mbar ( tank in operation), status of delivery: 5 mbar Main material inner vessel: low temperature resistant austenitic steel outer vessel: carbon steel
Main dimensions overall diameter 1,600 1,600 2,000 2,400 2,400 3,000 3,000 3,000 overall hight 4,150 7,150 7,350 8,350 11,550 11,550 14,150 18,050 Weight empty, kg 18 bar type 2,510 4,910 5,940 9,840 13,920 19,300 23,370 29,650 36 bar type 2,600 5,220 7,180 12,310 17,090 24,570 30,260 Technical data - tanks for carbon dioxide.
Size 30 60 110 200 300 490 610
Max. allowable CO2 : 22 bar
working pressure
Gross capacity approx. litre 3,160 6,365 11,535 20,355 30,205 49,020 61,620 Net capacity approx. litre 2,940 5,920 10,730 18,930 28,090 45,590 57,310 Filling ratio 93 %, 1 bar kg CO2 3,120 6,280 11,370 20,065 29,780 48,330 60,740 Boil- off rate
1 bar, 15° C A.T. %/ d CO2 0.22 0.19 0.14 0.10 0.10 0.07 0.06 referred to total capacity
vacuum < 2 x 10-2 mbar
Discharge capacity with standard
pressure building coil at 0.7 x MAWP
and 8 hours operating time
pressure stage
22 bar kg/ h (1 bar, 15° C) CO2 70 140 140 280 280
Capacity of one safety valve
at 1.1 x MAWP/ cold condition
pressure stage
22 bar kg/ h, CO2 975
Insulation insulating powder ( perlite),
vacuum < 5 x 10-2 mbar ( tank in operation)
status of delivery: 5 mbar
Main material inner vessel: low temp. resistant austenitic steel outer vessel: carbon steel
Main dimensions overall diameter 1,600 1,600 2,000 2,400 2,400 3,000 3,000 overall hight 4,150 7,150 7,350 8,350 11,550 11,550 14,150 Weight empty, kg 22 bar Type 2,510 4,910 6,300 10,250 14,500 20,500 24,800 7 Highly effective operation
Two service valves provide an exchange possibility for the filling valves even if the tank is filled.
Integrated pressure building coil for standard
discharge capacities ( service valves see flow
diagrams: valve 2 pressure building and valve
13 gas shut- off). The tank also has an optimized
design to reduce ice formation.
Easy operation
All valves required for operation are set in one line
Safety
In case that the safety valves will release product,
the medium will be blown off to a safe place.
Features.
8 Ergonomical position of controls
and instruments
The tank controls and instruments are set
in two lines.
Operation line:
Operation controls and instruments
Service line:
Service controls and instruments
Weather protection for instruments
The operation controls and instruments can be
operated by the user. A white handwheel is
fixed on top of this instruments and will be used
for filling or extraction.
The service controls and instruments will be
used by trained employees of the gas supplier
only. These valves are marked with a green
handwheel.
Non- corroding transport and lifting devices
Stainless steel transport legs
9 Additional vent valve ( for T.. V110 - T.. V610)
Lifting lugs with stainless steel inlay
Instrumentation and equipment, standard
C/ 1 Fill coupling
C/ 4, C/ 6 Connection add. transmitter
C/ PI Test connection pressure indicator
D Pressure building coil
I Inner vessel
IN Insulation
LI Level indicator
L/ 11-1 Pipeline discharge
L/ 11-2 Pipeline discharge ( plugged)
L/ 11-3 Pipeline discharge ( plugged)
NRV Non return valve
O Outer vessel
PC Pressure controller
PI Pressure indicator
RV/ O Relief valve- outer vessel
SV1, SV2 Safety valve
1) only T ... V110 - T ... V800
2) only T18 V200 - T18 V800
Valves, standard
1 Filling
2 Pressure building valve
3 Vent valve
4 Bottom gauge (+)
5 Gauge bypass
6 Top gauge (-)
9-1 Evacuation connection
11 Discharge
12 Top filling
13 Gas shut- off
18 Change over
21 Trycock
Options
SAA Safety shut- off valve,
control line for SAA
LI( T) Level indicator Samson Media 6
incl. instrument panel and standard
programming,
extra programming of Samson Media 6
acc. to customer requirements
LI( T) Level indicator WIKA with transmitter
output 4 - 20 mA
Flow diagram - tanks for nitrogen, oxygen, argon.
10 Instrumentation and equipment, standard
C/ 3 Vent coupling
C/ 4, C/ 6 Connection add. transmitter
C/ PI Test connection pressure indicator
D Pressure building coil
I Inner vessel
IN Insulation
LI( T) Level indicator
L/ 11-1 Pipeline discharge
L/ 11-2 Pipeline discharge ( plugged)
NRV Non return valve
O Outer vessel
PC Pressure controller
PI Pressure indicator
RV/ O Relief valve- outer vessel
SV1, SV2 Safety valve
Valves, standard
1 Filling
2 Pressure building valve
3 Vent
4 Bottom gauge (+)
5 Gauge bypass
6 Top gauge (-)
9-1 Evacuation connection
11 Discharge
12 Top filling
13 Gas shut- off
18 Change over
21 Trycock
26 Pressuring
Options
SAA Safety shut- off valve,
control line for SAA
LI( T) Level indicator Samson Media 6
incl. instrument panel and standard
programming,
extra programming of Samson Media 6
acc. to customer requirements
LI( T) Level indicator WIKA with transmitter
output 4 - 20 mA
Flow diagramm - tanks for carbon dioxide.
11 12
The vaporisers are suitable for a design overpressure = max. allowable working pressure ( PS) of 40 bar and an allowable operating temperature
range ( TS) of -269° C/+ 50° C.
Design and testing was carried out in accordance with the directive 97/ 23/ EC concerning pressure equipment, AD 2000- Merkblätter and
DIN EN.
The Linde finned tubes and connecting flanges
are made of aluminium alloy and the seals are
formed according to Linde Standards.
Clip- on standard design means the vaporiser
without frame. Upon customer request, a mounting kit for installation on a cryo- tank is available.
Explanation of type designation:
L = air heated
40 = max. permissible working overpressure:
40 bar
8 F = number of Finned tubes: 8
2,5 = length of single finned tube: 2,5 m
Type L 40 - 2 F 2,5
vaporiser type dimensions approx. weight empty Linde ident- no. depth [ m] widht [ m] height[ m] [ kg] N2 [ Nm³/ h] [ mm] L 40 - 8 F 2,5 1,67 0,516 2,733 140 120 J34895
L 40 - 4 F 2,5 1,67 0,276 2,733 74 60 I32740
L 40 - 2 F 2,5 0,69 0,276 2,709 37 30 I32631
The capacity is based on an ambient temperature of 20°C, 70 % rel. humidity, 15°C temperature difference between ambient and gas outlet temperature at a continuous 8-hours- operation screwed: M40 x 2
pipe: DN 15 (21,3 x 1,5)
socket welding end: ø18, 2
material: stainless steel
nominal
capacity*)
connections
inlet/ outlet)
Type L 40 - 4 F 2,5
Mounting kit
Special VAP - Quality for specific use.
Clip- on standard design.
13 14
At the Engineering Division, we do not want to
harm people or the environment. We will comply with all applicable legal, regulatory, internal and industry requirements.
We strive to be leading in SHEQ to meet safe,
secure and healthy working conditions and
supplying safe, compliant and environmentally
responsible products and services for our
customers.
SHEQ is a key part of The Linde Group’ s overall
strategy and we will also require our contractors
and partners to manage in line with this policy.
SHEQ - safety, health, environment
and quality police.
To achieve this vision,
SHEQ is 100 % of our
behaviour,
100 % of the time.
15 Welcome to the Engineering Division
The Linde Schalchen Plant is located 100 km
east of Munich, Germany. 700 engineers and
skilled workers design and manufacture components and complete modules for the application in process plants.
Backed up by more than 100 years of production
know- how, highly developed plant modules are
manufactured. Our innovative technologies and
our competitiveness open the door to participation in prestigious plant projects worldwide.
Linde provides complete services on field installation and operation. A specialised service crew is available for immediate and professional
repair services.
Do you need further and more
detailed information?
Just ask us – we will be pleased to help you.
Linde AG
Engineering Division
Schalchen Plant
Carl- von- Linde- Strasse 15
83342 Tacherting/ Germany
Phone: + 49.8621. 85- 6434
Fax: + 49.8621. 85- 6622
E- Mail: plantcomponents@linde- le.com
Internet: www.linde. de
Production area
of standardised equipment:
Advice and sale
Phone: + 49.8621. 85- 6777
After sales service, guarantee, spare parts
Phone: + 49.8621. 85- 6279
Other products by production area
of standardised equipment:
Static vacuum insulated cryogenic vessels
Spiral welded pipes
Service and guarantee.
P/
3 3
e
1 2
Linde´s Engineering Division continuously develops extensive process engineering know- how in the planning, project management and construction of turnkey industrial plants.
The range of products comprises:
Petrochemical plants
LNG and natural gas processing plants
Synthesis gas plants
Hydrogen plants
Gas processing plants
Adsorption plants
Air separation plants
Cryogenic plants
Biotechnology plants
Furnaces for petrochemical plants and refineries
More than 4,000 plants worldwide document the leading position of the Engineering Division in international plant construction.
Designing processes – constructing plants.
For further informations please contact:
Linde AG
Engineering Division, Schalchen Plant
Carl- von- Linde- Strasse 15, 83342 Tacherting, Germany Phone + 49.8621. 85- 6434, Fax + 49.8621. 85- 6622
E- Mail: plantcomponents@linde- le.com, www.linde- plantcomponents. com Aluminium plate- fin heat exchangers as
single units or as manifolded assemblies
Cold boxes with aluminium plate- fin heat
exchangers, columns and vessels
Coil- wound heat exchangers and isothermal reactors for chemical and petrochemical plants Columns and pressure vessels in aluminium
for cryogenic plants
Spiral- welded pipes in aluminium
Storage tanks for liquefied gases
Steam- heated waterbath vaporisers as well
as air- heated vaporisers for liquefied gases
Production facilities. Product range.
At Linde Engineering Schalchen Plant over 700
skilled engineers and workers design and manufacture components and complete modules for numerous applications in process plants such as
ethylene plants, hydrogen and synthesis gas
plants, LNG plants and air separation plants. Production capacity totals approx. 1.3 million hours per year.
In addition, the plant offers services for field installation and advice on operation. A specialised service crew is available for immediate and professional repair services.
BLUE FOLDER ITEM
Blue folder items are additional back up material to administrative reports and/ or public comments received after the printin g and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
OCTOBER 6, 2026
L.1. PUBLIC HEARING FOR CONSIDERATION OF AN APPEAL OF A DENIAL BY THE PLANNING COMMISSION OF AN EXEMPTION DECLARATION AND VARIANCE TO EXCEED THE 30 -
FOOT MAXIMUM BUILDING HEIGHT REQUIREMENT FOR THE INSTALLATION OF FOUR
THREE INITIALLY) BULK CRYOGENIC STORAGE TANKS WITH A PROPOSED HEIGHT OF APPROXIMATELY 38 FEET AT AN EXISTING MANUFACTURING FACILITY ON PROPERTY LOCATED WITHIN AN INDUSTRIAL- COMMERCIAL ( IC-1) ZONE
CONTACT: MARC WIENER, COMMUNITY DEVELOPMENT DIRECTOR
Staff is providing an updated draft resolution with an expanded comparative analysis with other IC-1 Zoned properties in the vicinity of the subject property.
The updated language further explains the “ special circumstances” applicable to the property that deprives the subject property of privileges enjoyed by other property in the vicinity with an identical zoning designation.
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 1
STAFF REVISED 10/6/26
RESOLUTION NO. CC-2610-083
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
REDONDO BEACH GRANTING AN APPEAL AND APPROVING AN
EXEMPTION DECLARATION AND VARIANCE TO EXCEED THE 30 -
FOOT MAXIMUM BUILDING HEIGHT REQUIREMENT FOR THE
INSTALLATION OF FOUR BULK CRYOGENIC STORAGE TANKS
WITH A PROPOSED HEIGHT OF APPROXIMATELY 38 FEET AT
AN EXISTING MANUFACTURING FACILITY ON PROPERTY
LOCATED WITHIN AN INDUSTRIAL-COMMERCIAL (IC-1) ZONE.
WHEREAS, a Variance is requested under Redondo Beach Municipal Code Section 10-2.2510 to allow the proposed cryogenic storage tanks to exceed the 30-foot maximum building height requirement with a proposed height of approximately 38 feet in the IC-1 Zone; and
WHEREAS, the subject lot is approximately 4.43 acres in area with approximate dimensions of 501 feet in width and 385 feet in depth with an existing ±250,000 square foot manufacturing structure consisting of office, storage, IT infrastructure, restrooms, manufacturing (aerospace), kitchen space, and walkways/hallways; and WHEREAS, the surrounding industrial uses west, north, and east have similar industrial zoning and General Plan land use designations and allow for the same uses, including aerospace manufacturing ( use on the subject property), however these adjacent industrial areas allow for significantly higher development than the subject property; and
WHEREAS, the project is Categorically Exempt from CEQA under Section 15301 Existing Facilities) of the CEQA Guidelines; and
WHEREAS, the Planning Commission conducted a duly noticed public hearing on August 20, 2026 and continued the public hearing on the application to a date certain on September 17, 2026. The Height Variance application was continued to September 17, 2026 to address concerns from commissioners regarding the safety of the materials stored; and
WHEREAS, the Planning Commission of the City of Redondo Beach considered evidence presented by the applicant, the Planning Division, the Redondo Beach Fire Department, and other interested parties at the public hearings held on the 20th day of August and the 17th day of September, 2026, with respect thereto and on September 17, 2026, the Height Variance application was denied (vote 4 -3); and RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 2
WHEREAS, the project applicant, Impulse Space, filed an appeal of the Planning Commission’s denial for a de novo hearing with City Council in accordance with RBMC 10-2.2510(g); and
WHEREAS, notice of the time and place of the public hearing where the Exemption Declaration and the appeal of the Planning Commission’s denial of the Height Variance application would be considered by the City Council was given pursuant to State law and local ordinances by publication in the Easy Reader, by posting the subject property, and by mailing notices to property owners within 300 feet of the exterior boundaries of the subject property; and WHEREAS, the City Council of the City of Redondo Beach has considered evidence presented by the applicant, the Planning Division, and other interested parties at the public hearing held on the 6th day of October, 2026, with respect thereto.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF REDONDO BEACH DOES HEREBY RESOLVE:
SECTION 1. That the above recitals are true and correct and are incorporated herein by reference as if set forth in full.
SECTION 2. That based on the findings below, the City Council hereby grants the appeal and approves the Exemption Declaration and the Variance pursuant to the plans and applications considered by the City Council at its meeting on the 6th day of October, 2026.
SECTION 3. In accordance with Section 10-2.2510(b) of the Redondo Beach Municipal Code, the applicant's request for a Variance is consistent with the criteria set forth therein for the following reasons:
a) There are special circumstances applicable to the property, including size, shape, topography, location, or surroundings, such that the strict application of the zoning provisions deprives such property of privileges enjoyed by other property in the vicinity and under identical zone designation.
The subject property’s current use, and General Plan and Zoning land use designation are consistent with other industrial parcels in the surrounding industrial neighborhood. The subject property’s zoning designation (IC -1) allows for the same “ industrial uses” as the surrounding I -1 ( Industrial) designation.
Furthermore, the use on the subject property, aerospace manufacturing, is the same as the uses of many of the surrounding Industrial properties.
The “special circumstances” applicable to this project are based on the fact that the development standards for the subject property are significantly more RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 3
restrictive than those of the surrounding industrial-zone properties which, as noted above, allow for the exact same manufacturing/industrial uses.
Additionally, the surrounding industrial uses are allowed at heights of over 100 feet while the subject property’s uses are limited to a height of 30 feet. Strict adherence to the zoning district’s 30-foot height limit would eliminate the ability of the property owner to use the property for aerospace manufacturing purposes.
The surrounding industrial properties have been allowed to install numerous similar storage tank structures which are similarly required for their manufacturing needs.
Accordingly, relief from the standard height restriction to afford this property some of the development privileges provided to the nearby properties with the same uses is justified. Additionally, the technical requirements in support of this aerospace manufacturing operation cannot be accommodated at a lesser height without resulting in the fabrication of customized tanks that do not have the same track record of safety, and would also require more frequent supply deliveries.
The subject property’s zoning designation is Industrial ( IC-1) and allows for industrial and limited commercial uses. There are two other locations within the City that are zoned as IC-1, including the area northeast of Interstate 405 between Marine and Inglewood Avenues, consisting of three parcels, and the area on the north side of 182nd Street between Kingsdale and Hawthorne Boulevards, also consisting of three parcels. These other IC -1 properties are occupied by commercial businesses and a public utility (SoCal Gas). The subject property at 2477 Manhattan Beach Boulevard is the only property within the IC -1 Zone that contains an industrial/manufacturing use and has unique circumstances that distinguish it from the other properties located in the IC -1 Zone.
Specifically, the “special circumstances” applicable to this project are based on the shape of the subject property, which is of a lesser depth ( 385 feet) in comparison to many other IC-1 Zoned properties in the vicinity with depths of over 400 and 500 feet. Adding to the lesser depth of the subject property is a required 20-foot-wide fire lane along the rear of the property and with the placement of the existing structure, due to the shallow depth, this lot is constrained in its ability to accommodate required employee parking and accessory equipment necessary for the permitted aerospace manufacturing use in comparison to many other IC-1 Zoned properties in the vicinity.
Additionally, because the subject property is located immediately adjacent to SCE Transmission Towers, additional setbacks eliminate location options along the eastern property line. Impulse Space has estimated that using the shorter tanks of 30 feet or less would eliminate roughly 50 parking spaces, which would impact the surrounding neighborhood and business operations. There is limited RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 4
area on the property where the cryogenic tanks, which are essential to the permitted aerospace manufacturing use, can be located, which is why Impulse Space is requesting a Height Variance of 8 feet. Strict adherence to the zoning district’s 30-foot height limit would limit the ability of the subject property to effectively conduct aerospace manufacturing and comply with the parking requirements. The property occupied by Impulse Space does not share the privileges and benefits enjoyed by other properties in the vicinity and within the IC-1 Zone, which have greater depth and land area configurations and capacity to accommodate required parking under the Municipal Code, and installation of accessory structures throughout their properties and the ability to effectively conduct business, which are the privileges that have been granted to other properties within the vicinity and in the IC-1 Zone that are not provided for the subject property.
There is one property designated in the IC-1 Zone that enjoys a higher height privilege. Specifically, the property located at 2500 Marine Boulevard contains a cell tower that was permitted at a height of 47 feet, which exceeds the 30 -foot height limit. It was entitled through the Conditional Use Permit process, which is a separate process for granting height exceptions to cell towers. This comparison property with an identical zoning designation (IC-1 Zone), which is in the vicinity of the subject property, was granted a structure with a height of 47 feet.
In addition to providing a comparison of properties exclusively in the IC -1 Zone, staff has also compared the IC-1 to the I-1 (Industrial) Zone. Both zones allow for the same industrial uses, while the IC-1 also allows for some additional commercial uses. The IC-1 and I-1 are both listed in the Municipal Code under the identical “Industrial” zoning classification and are identified under the same Purpose Section RBMC 10-2.1000.
The height standard for the subject property in the IC-1 is significantly more restrictive (30 feet) than the surrounding I-1 Zone (100 feet) in the vicinity. Again, strict adherence to the zoning district’s 30 -foot height limit would limit the ability of the subject property to effectively conduct aerospace manufacturing. The surrounding industrial properties have been allowed to install numerous similar storage tank structures which are similarly required for their manufacturing needs, which is a privilege that has been granted to other properties within the vicinity, specifically Northrup Gruman, and is not provided for the subject property.
b) The Variance granted shall be subject to such conditions as will assure that the adjustment thereby authorized shall not constitute a grant of special privileges inconsistent with the limitations upon other properties in the vicinity and zone in which such property is situated.
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 5
The variance does not constitute a special privilege, as it allows development that is consistent with the existing industrial uses in the vicinity, including parking requirements, and maintains compliance with the intent of the zoning district.
Strict adherence to the zoning district’s 30-foot height limit would limit the ability of the subject property to effectively conduct aerospace manufacturing and compliance with parking requirements. The property occupied by Impulse Space does not share the privileges and benefits enjoyed by other properties in the vicinity and within the IC-1 Zone, which have greater depth and land area configurations and capacity to accommodate required parking under the Municipal Code and accessory structures throughout their properties which are privileges that have been granted to other properties within the vicinity and in the IC-1 Zone that are not provided for the subject property. Parking is a necessary requirement of the business operation and depriving the applicant of the ability to provide parking would be a deprivation of privileges enjoyed by other IC-1 zoned properties.
Further, Tthe adjustment (Variance) allows for critical infrastructure with technical requirements that cannot be significantly altered and that are common for the allowed industrial use and required for many aerospace manufacturing operations without significantly reducing required parking. The adjustment Variance) does not grant development rights unavailable to other similarly situated properties with similar General Plan and Zoning designationsIC-1 properties that have adequate area to accommodate critical business needs., many of which utilize comparable cryogenic storage tanks. c) The granting of a Variance shall not be contrary to the objectives of the Comprehensive General Plan.
Granting this Variance supports the General Plan’s Goal of Economic Sustainability LU-6, and specifically Responsible Development Policy LU-6.1, Business Retention and Expansion Policy LU-6.12, and Job/Housing Balance Policy LU-1.4. Further, the granting of this variance supports the General Plan’s objective to maintain existing employers within the North Redondo Tech District SPA-1). The requested Variance is vital to the operations of Impulse Space and helps support and execute these critical General Plan policies and objectives.
Impulse Space is unable to conduct their manufacturing operations without these tanks. By allowing the existing business to install the proposed bulk cryogenic storage tanks, the City is facilitating the specialized industrial infrastructure necessary for the business to conduct their permitted industrial activities.
SECTION 4. That the proposed development is exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15301 (Existing Facilities) of the CEQA Guidelines.
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 6
SECTION 5. That this permit shall be void in the event that the applicant does not comply with the following conditions:
1. The approval granted herein is to exceed the maximum height requirement of 30 feet for the installation of 38-foot-tall cryogenic storage tanks at an existing manufacturing facility located within an Industrial-Commercial (IC-1) zone. Four 4) tanks are permitted to be installed as shown on the approved site plan and the renderings. Any additional tanks that exceed the height regulation would require a “Modification” to this “Variance”.
2. A copy of this Resolution shall be copied onto a sheet in the construction plan set submitted to the Building and Safety Division.
3. The site shall be fully fenced prior to the start of construction. The site is currently fully fenced.
4. The site shall be maintained in a clean and orderly condition throughout construction, with reasonable measures taken to prevent the accumulation of litter and debris.
5. Construction work shall occur only between the hours of 7:00 a.m. and 6:00 p.m. on Monday through Friday, between 9:00 a.m. and 5:00 p.m. on Saturday, with no work occurring on Sunday and specified holidays per RBMC Section 9 -1.12.
6. The project developer and/or general contractor shall be responsible for counseling and supervising all subcontractors and workers to ensure that neighbors are not subjected to excessive noise, disorderly behavior, or abusive language.
7. The streets and sidewalks adjacent to the job site shall be maintained free of debris resulting from construction activities.
8. All construction shall strictly conform to the architectural drawings, elevations, and site plan and renderings stamped “ Approved” on October 6, 2026. The Planning Division shall be authorized to approve minor changes.
9. The applicant shall obtain all required demolition, building, grading, electrical, and mechanical permits and shall comply with all applicable provisions of the California Building Code, Fire Code, and City ordinances.
10. The applicant may be required to install noise mitigation equipment and measures in the event of measured noise violations of the City’s noise ordinance RBMC Title 4, Chapter 24. Noise Regulation).
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 7
11. The design shall be constructed per building and fire code requirements and include measures to minimize risks of vehicle impact.
12. The installation area shall be graded in accordance with the approved engineering design.
13. The applicant shall install and maintain NFPA 704 hazard diamond signage at all applicable access points in accordance with applicable code requirements.
14. The Impulse Space site will be sufficiently secured to prevent unauthorized access to the site and cryogenic storage tanks.
15. The applicant shall develop, maintain, and post written operating procedures for the cryogenic storage equipment at the storage area .
16. The applicant shall notify the local fire department of the cryogenic installation and provide the fire department with a copy of this document.
17. The applicant shall clearly mark the facility address and location of the cryogenic storage equipment to facilitate emergency vehicle access.
18. The applicant shall post and maintain a 24 -hour emergency contact telephone number at the facility entrance in a readily visible location.
19. The applicant shall maintain a current site map at the facility entrance identifying the cryogenic vessel locations, designated exclusion zones, and emergency access routes.
20. The applicant shall install and maintain silencers on venting valves associated with the cryogenic storage tanks to suppress noise generated during tank venting operations.
21. The applicant shall limit deliveries of liquefied gas to normal business hours . Very limited off hour deliveries are permitted as a minor change subject to the approval of the Community Development Director.
22. The applicant shall provide a noise report measuring noise generated by tank - related operations, including delivery of gas, filling of the tanks, and tank venting, to confirm compliance with the City's Noise Ordinance. Additional noise mitigation may be required, including, but not limited to, installation of a solid wall along the Manhattan Beach Boulevard frontage.
SECTION 6. That the approved Variance shall become null and void if not vested within 36 months after the City Council’s approval of the project.
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 8
SECTION 7. That the City Clerk shall certify the passage and adoption of this resolution and shall enter the same in the Book of Original Resolutions.
RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 9
PASSED, APPROVED AND ADOPTED this 6th day of October, 2026.
James A. Light, Mayor
APPROVED AS TO FORM: ATTEST:
Joy A. Ford, City Attorney Eleanor Manzano, CMC, City Clerk RESOLUTION NO. CC-2610-083
2477 MANHATTAN BEACH BOULEVARD
PAGE NO. 10
ATTEST:
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS
CITY OF REDONDO BEACH )
I, Eleanor Manzano, City Clerk of the City of Redondo Beach, California, do hereby certify that the foregoing Resolution No. CC-26XX-XXX was passed and adopted by the City Council of the City of Redondo Beach, California, at a regular meeting of said City Council held on the 6th day of October, 2026, and there after signed and approved by the Mayor and attested by the City Clerk, and that said resolution was adopted by the following vote:
AYES:
NOES: None
ABSTAIN: None
ABSENT: None
Eleanor Manzano, CMC
City Clerk
From: Mark Nelson ( Home Gmail)
To: Joy Ford; CityClerk; Mike Witzansky; Sean Scully; Scott Behrendt; Marc Wiener; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Nick Biro; James Light Subject: Because Redondo Violated Brown Act - Public was UNABLE TO MOUNT A DEFENSE Date: Tuesday, October 6, 2026 8:58:27 PM
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Unbelievable what the City did. This will require an appeal. Further more those were not facts that Impulse provided. Where are the STANDARD 28-foot tanks - 6 tanks instead of 4.
From: Frank Lacey
To: jmdefazio@gmail. com; michael@impulsespace. com; CityClerk Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Scott Behrendt; Zein Obagi; [email protected] Subject: Impulse Space Tank Art/Mural
Date: Wednesday, October 7, 2026 12:24:38 PM
Attachments: Silo Art.png
Scaffold Art. png
Wall Artist. png
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To Whom It May Concern,
My name is Frank Lacey. I was at the Redondo Beach City Council Meeting last night, 10/6/2026, regarding the height variance for the tanks that Impulse needs for doing business. For 25 years my wife and I have lived directly at the end of Johnston Avenue on Manhattan Beach Blvd.
I spoke at the meeting about how I was excited to have you here. The aerospace industry is the future and we need this new tech to grow as a city and community. I spoke about how my wife had her entire career with TRW and then later Northrop Grumman and that Northrop seamlessly integrated themselves into our community. We beautifully coexist. I said I hoped Impulse would also follow that path. I want to make sure Impulse Space connects with our community.
The residential neighborhood across the street is concerned and rightly so. They will have to see these Nitrogen and Argon tanks every day. Are they safe, I don’t like looking at them, they tower over the building like a church steeple, etc. Also, Manhattan Beach Blvd. is a major thoroughfare for anyone traveling or coming to the several beach cities in the Southbay. As tourism is very important, so is Manhattan Beach Blvd. We have just completed a major beautification project including full landscaping to make this a more pleasant journey.
When I spoke, I stated that I understood your needs and your site issues for everything from parking to these storage tanks. I echoed Councilmen Waller’s thoughts about the possibility that you somehow make the tanks blend in and not be so noticeable. There was also talk about trees or a wall. I was happy the different ideas were floated and debated.
I have included a quick graphic I created below to show how this can be achieved to possibly make everyone happy. It is a 3-sided screen covered with a wrap-around image of any number of wonderful space images that the Hubble or the Space Webb telescopes have produced ( NOTE: These NASA images are completely free for the public to use). Or this imagery could be an artist’ s unique creative idea that echos the feeling of Impulse Space’ s vision.
This screen could a be a large vinyl wrap like is used on advertising billboards or it cold be an artist’s painted mural. It could change to a different image periodically to keep our community fresh and vibrant.
There could be a contest to win the opportunity to design this space and could passer’ s by could watch the progress of it being painted. It would not necessarily need to completely hide the tanks as a small bit of white bubbles at the top would not automatically shout Liquid Nitrogen storage tanks. Your mind would be absorbed in the beautiful space image.
This visual exercise has been successfully used in other communities and cities to hide, embellish structures or fool the eye as to what they are seeing.
Silo Art
Scaffolding Art
Mural Artist
Either way, this feels like a win- win. The tanks are hidden and the community is now looking at a beautiful image.
And to reiterate, I am very happy that Impulse Space has come to our community and look forward to their continued presence.
Frank Lacey
310.963.2392
[email protected]
From: Lisa Griffiths
To: CityClerk
Cc: Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt; Daniel Besinaiz; Khatirah Nazif Subject: Impulse Space Tanks
Date: Tuesday, October 6, 2026 5: 36: 01 PM
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Hello,
My husband and I are home owners and live on Johnston Avenue. We are members of the South Bay community for over 30 years and are writing to oppose the special permit requested by Impukse Soace for Cryogenic tanks near MB Blvd/Dow. These tanks are dangerous if they explode and should not be in an area adjacent to such a busy street and so close to residential homes. Please do not allow this special permit request by Impulse Space.
Sincerely,
Lisa Griffiths
From: Mark Nelson ( Home Gmail)
To: Joy Ford; CityClerk; Mike Witzansky; Sean Scully; Scott Behrendt; Marc Wiener; Garth Meyer; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Nick Biro Subject: Provide the EXACT time that the Resolution was swapped out by the Planning Department Date: Tuesday, October 6, 2026 8:43:36 PM
Attachments: L.1 BLUE FOLDER ( ADDITIONAL). pdf
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The redline STRUCK the entirety of the fact base that was posted. This is clearly illegal and a violation of the Brown Act.
Look at the RED INK and Strike out
From: Mark Nelson ( Home Gmail)
To: Jasen Brown; Mario Tresierras; Mauricio Nunez Florez; Joy Ford; CityClerk; Mike Witzansky; 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 - Redondo" s Material Change of Resolution Terms was Likely ILLEGAL Date: Tuesday, October 6, 2026 8:37:52 PM
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Yes. On the facts you describe, there is a substantial California Brown Act issue. The closest published California case I found is strikingly similar to what happened here.
In Sierra Watch v. County of Placer ( 2021), the posted materials told the public the Board would consider one version of a development agreement. Staff then prepared a materially revised version shortly before the meeting, and the Board considered and approved that revised version instead. The Court of Appeal held that the agenda was inaccurate and misleading, violating Government Code § 54954. 2. Justia Law The court emphasized the purpose of the agenda requirement: the public has to receive a fair opportunity to know what the legislative body is actually going to consider. California courts have said the public must receive more than clues from which it must guess the essential nature of the proposed action. Justia Law
There are potentially two separate problems here
1. The swapped resolution itself had to be disclosed.
Government Code § 54957. 5 specifically addresses documents distributed late. If City staff prepared the replacement resolution and distributed it to a majority of the Council during the meeting, the statute says the writing must be made available for public inspection at the meeting. CounselStack Law
So merely handing Council a new resolution— or electronically substituting it in their packet without simultaneously making it available to the people in the room would appear inconsistent with § 54957. 5(c).
But even if the City did immediately put copies on the table or upload it, that doesn' t necessarily solve the larger issue.
2. A materially different resolution can make the noticed agenda/ materials misleading.
This is where Sierra Watch becomes important.
The County argued, essentially, that the agenda still generally described the same development agreement. The Court of Appeal nevertheless concluded that the public had been told the Board would consider the agreement identified in the publicly available materials, while the Board actually considered a materially revised agreement. That was misleading under § 54954. 2. Justia Law
From: Mark Nelson ( Home Gmail)
To: CityClerk; James Light; Chadwick B. Castle; Brad Waller; Paige Kaluderovic; Zein Obagi; Scott Behrendt; Mike Witzansky; Joy Ford; Garth Meyer
Subject: Public Comment: Because the City Replaced the Impulse Space Resolution while Council was in Session - Residents were denied a good outcome
Date: Tuesday, October 6, 2026 10: 43: 52 PM
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With less than 40 minutes before the open meeting of the Council, and during the Council' s closed session, Redondo Beach staff replaced the Resolution with a 100% changeout of material language. That meant that residents were forced to guess what comments to make in the meeting, because they were denied visibility to the REAL agenda item.
So instead of a WIN-WIN where Impulse used 6 - 28-ft off-the-shelf tanks, the Council swallowed the contention that smaller tanks would fill the parking lot IN reality, 6 - 28-ft tanks likely had the same or a larger capacity than 4 - 38-ft tanks. And they would only have taken up 50% more space
I would love to write that the Council and Staff got what they deserved for their deceitful action toward the public - a lousy outcome. But the truth is, none of the City staff or Council cared about the impact of Impulse on the neighbors at all. If they did, they wouldn' t have hidden the resolution until 40 minutes before the open meeting.
Sadly - the residents got the raw deal from the City. Again.
From: Mark Nelson ( Home Gmail)
To: Garth Meyer
Cc: CityClerk
Subject: Public Comment: The abysmal performance of the City on the Impulse Space Variance Date: Wednesday, October 7, 2026 1: 49: 11 AM
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Worst Imaginable Outcome Happened at the City Council Meeting on 10/6/2026 regarding the Impulse Space Variance
Somehow EVERYBODY LOST on the Impulse variance hearing. It was LOSE- LOSE.
Residents got stuck with 38-foot tanks and Impulse will wind up spending $ 100,000s to install 100+ trees on Manhattan Beach Blvd in special sidewalk embedded planters along with installing and operating irrigation systems. And that doesn' t count the large screen to "hide" the 38-foot tanks - or the fancy fence for 1000-ft, give or take, along their site.
So here' s what went wrong as best we can tell.
While the City Council was in closed session from 4-6PM, the City Staff did a 100% change of the reason for the Variance. City Staff didn't post the changes until the Council open session part of the meeting, Of course City Staff DIDN'T TELL THE PUBLIC THEY CHANGED THE RESOLUTION UNTIL ALL THE COMMENTS WERE FILED.
So when we finally got to the Impulse Variance part of the Council hearing, all the comments made by the public were invalid, because City Staff didn't provide the changes in ADVANCE.
The City Staff took away the Public' s right to participation by HIDING the reason for the Impulse variance until the hearing. Several of us believe it was a BROWN ACT violation by the City and plan to turn it over to a lawyer.
In the end, it looks like the City had Impulse create a made- up plan where Impulse used lots of very small tanks and took up 50 parking spaces with them. That was never going to happen in real life by competent engineers. The solution to stay under 30-feet would be to use 6 28-ft standard tanks instead 4 38-ft standard tanks. Thereby, only losing 4 more parking spaces.
But the City wanted to use the made up 50 lost parking spaces as the reason for the Variance.
But since City Staff hid the changes to the variance from the public, the outcome became bad for the public and expensive for Impulse and GOOD FOR NO ONE.
If Impulse had any common sense, they'd put in 6 of the 28-foot tanks and walk away from the variance completely. No trees, no irrigation, no hassle and only 2 extra tanks.
The next few days will be a flurry of public records act requests to see if any email or voicemail trails were left between the City and Impulse in this debacle.
From: Mark Nelson ( Home Gmail)
To: Joy Ford; Mike Witzansky; CityClerk
Subject: Soon to be filed: DEMAND TO CURE AND CORRECT — GOVERNMENT CODE § 54960. 1 October 6, 2026 Approval of Resolution CC- 2610- 083 / Impulse Space Height Variance Date: Tuesday, October 6, 2026 9:08:04 PM
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If this never before seen Resolution is passed - Demand to Cure and Correct is coming. THIS
WAS UNACCEPTABLE
Given what we know now, the appropriate procedural action is a written Brown Act Demand to Cure and Correct” under Government Code § 54960. 1, served on the City Council/ City Clerk. I would not wait while investigating the remaining facts.
The theory would be quite specific: the Council approved Resolution CC-2610- 083 after City staff replaced the publicly circulated proposed resolution with a materially revised resolution prepared only about 40 minutes before the scheduled open session, adding substantial new factual findings supporting the variance. The original resolution was the document against which the public had prepared its analysis and comments. The replacement added new findings concerning lot depth, fire-lane constraints, SCE setbacks, approximately 50 parking spaces, other IC-1 parcels, a 47-foot cell tower, and comparisons to I-1 properties. R 2026- 2610- 083 GRANTING AN APP… L.1 BLUE FOLDER ( ADDITIONAL) L.1 BLUE
FOLDER ( ADDITIONAL)
That fits unusually well with Sierra Watch v. County of Placer. There, staff materially revised the document shortly before the meeting and the board considered the revised document rather than the version identified to the public. The Court of Appeal held that this rendered the agenda inaccurate and misleading under § 54954. 2. Importantly, the court rejected the argument that agencies are simply free to change an agenda item between posting and final action; it distinguished changes actually made by the legislative body during deliberation from staff presenting the body with a materially different document in the first instance. Justia Law There is also a potentially separate § 54957. 5 issue. Materials distributed to all or a majority of Council less than 72 hours before the meeting generally must be made available to the public when distributed as specified by the statute. Sierra Watch dealt with that issue as well. Justia Law
What I would do now
1. Send the Cure- and- Correct demand promptly. For an open- session violation of the 54954. 2 agenda requirement, the demand must be made within 30 days of the Council action. The Attorney General' s Brown Act guidance confirms the 30-day deadline. California DOJ
The demand should identify the challenged action precisely:
The October 6, 2026 action granting Impulse Space' s appeal and approving Resolution CC-2610- 083 and the variance for four approximately 38-foot cryogenic storage tanks at 2477 Manhattan Beach Boulevard.
Then describe the violation and demand that Council rescind/ nullify that approval and conduct any reconsideration at a properly noticed future meeting after the actual proposed resolution and supporting findings have been made available to the public sufficiently in advance.
I would expressly cite §§54954. 2, 54957. 5 and 54960. 1 and Sierra Watch v. County of Placer.
2. Make prejudice a central factual point. This matters because Sierra Watch actually found a Brown Act violation but refused to invalidate the approval because the plaintiff failed to establish the necessary prejudice for nullification. The court explained that the relevant inquiry is whether the violation deprived the public of a fair opportunity to participate. Justia Law Your facts potentially provide a better prejudice argument than Sierra Watch: you actually analyzed the original resolution and prepared comments specifically attacking its findings. Then staff substituted materially expanded findings addressing the legal weakness you and others were attacking. You consequently had no meaningful opportunity to investigate and rebut those new factual assertions before speaking.
That should be documented, not merely asserted.
3. Send a CPRA request immediately. I would request all records showing:
creation and revision history of both versions;
Word documents/ native files;
emails and Teams/ text communications concerning revisions; communications between staff, City Attorney and Impulse concerning the revised findings;
exact time the revised resolution was transmitted to each Councilmember; exact time it was provided to the City Clerk;
exact time it was uploaded to the City's website/ Legistar/ Granicus; audit logs showing posting/ replacement times; and
communications discussing the new parking, lot-depth, SCE, IC-1, cell-tower and I-1 findings.
That could tell us who wrote the new findings, when they wrote them, why they were added, when Council received them, and when the public received them.
4. Preserve your evidence now. Keep the PDFs exactly as downloaded. The original resolution says, among other things, that strict compliance with 30 feet would “ eliminate the ability” to use the property for aerospace manufacturing and that shorter tanks would require customized tanks and more deliveries. R 2026- 2610- 083 GRANTING AN APP… The revised document substantially expands the City's factual justification rather than merely correcting wording. That's important evidence of materiality.
5. Keep the land- use challenge deadline separately calendared. A Brown Act challenge is procedural. There may separately be a writ/land- use challenge to the actual variance findings.
Those land- use limitations periods can also be extremely short. I would have California land- use counsel determine the applicable deadline immediately rather than assume the Brown Act demand preserves those independent claims.
What happens after the demand
Section 54960. 1 gives the legislative body an opportunity to cure. If it refuses, litigation seeking to invalidate the action proceeds on a very compressed timetable. The Attorney General' s guidance notes that suit generally must be brought within 15 days after the body' s decision not to cure/ correct, or after expiration of its statutory response period, whichever applies. California DOJ
So this isn't something I'd handle as another letter of objection to the Council. I would title it something like:
DEMAND TO CURE AND CORRECT — GOVERNMENT CODE § 54960. 1 October 6, 2026 Approval of Resolution CC-2610- 083 / Impulse Space Height Variance And I would keep it quite clinical— probably 3–5 pages plus the two resolutions as exhibits.
The strongest presentation is a small table showing Original Finding 5:20 PM Replacement Finding Why Material Public Comment/ Analysis Rendered Obsolete.
Given the documents you've now supplied, I think preparing that demand is the appropriate next step. The metadata chronology and a redline of the two resolutions should be Exhibits A–C, with the posting/ distribution evidence added as soon as we obtain it. This is sufficiently time-sensitive that I would also have California municipal/ land- use counsel review it before or immediately after service.