L.1 BLUE FOLDER — Redondo Beach City Council, October 6, 2026

BLUE FOLDER ITEM
Blue folder items are additional back up material to administrative reports and/or public comments received after the printing 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

PROCEDURES

1. Open the public hearing, receive and file all documents and correspondence on the proposed project;

2. Accept all testimony from staff, the applicant, and the public and deliberate;

3. Close the public hearing;

4. Adopt the attached Resolution by title only, and waive further reading.

ADOPT BY TITLE ONLY RESOLUTION CC-2610-083 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
CONTACT: MARC WIENER, COMMUNITY DEVELOPMENT DIRECTOR
• Updated Presentation and Appeal Justification Letter from Impulse Space
• Public Communications
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 1 Impulse Space
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 2 2021 30+ contracts signed
3 4
650+
Company

FOUNDED MISSION BACKLOG

VEHICLES LOCATIONS

HEADCOUNT
By Tom Mueller
SpaceX CTO of Propulsion
From both commercial and government bookings
Redondo Beach, HQ — 300,000 ft
Colorado, GNC — 20,000 ft2
Mojave, Testing – 80 acres
Washington DC — Govt. Relations and BD
Helios – Distance vehicle
Mira – Responsive
spacecraft
Lander — Moon and beyond
150+ open positions
48 months

ON ORBIT
LEO Express 1 – Most successful OTV debut ever
LEO Express 2 – In Space
LEO Express 3 – In Space
LEO Express 4 – Launching Q4 ‘26
GEO Express 1 – Launching Q1 ‘27
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 3 Vehicles
Helios
A high-energy kick stage to rapidly, reliably,
and affordably deliver payloads from LEO to
MEO, GEO, and beyond
FlIGHTS STARTING 2027
Mira
A flight-proven high-thrust, highly
maneuverable space vehicle for payload
hosting and deployment across any orbit
FLYING SINCE 2023
Lander
Combines the Helios kick stage and an
Impulse-made lunar lander to deliver more
mass on the Moon
STARTING IN 2029
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 4

SOLENOID VALVES, PRESSURE

TRANSDUCERS

STORABLE BI-PROPELLANT IGNITORS
THRUSTERS (6 LBF, 26 N)

STORABLE BI-PROPELLANT
THRUSTERS (200 LBF, 800 N)

TURBOPUMP
S

CRYOGENIC BI-PROPELLANT
ENGINES (15,000 LBF, 67 KN)
ELECTRIC PROPULSION (IMAGE:

NASA)
COLD-GAS THRUSTERS 3D PRINTING & MACHINING

PROPULSION

STRUCTURES & MECHANISMS AVIONICS & RF

SOLAR ARRAY STRUCTURES

AND MECHANISMS

X- AND S- BAND RADIOS AND

ANTENNAS

REACTION WHEELS COMPOSITE OVERWRAPPED HARNESSING

PRESSURE VESSELS (COPVS)
PRIMARY STRUCTURES SECONDARY STRUCTURES & PCB’S AND CONTROLLERS

PLATE DISPENSERS

BATTERIES AND POWER

MANAGEMENT

FLIGHT SOFTWARE (FSW) GUIDANCE, NAVIGATION, AND AUTOMATION MISSION MANAGEMENT

CONTROL (GNC)

STAR TRACKERS SUN SENSORS GPS RECEIVERS SPACECRAFT OPERATIONS MISSION PLANNING

GNC & SOFTWARE SPACE OPERATIONS
Vertically Integrated

ASSEMBLY, INTEGRATION & TEST

SPACECRAFT PAYLOAD INTEGRATION VIBRATION TESTING TVAC TESTING EMI/EMC TESTING TEST-LIKE-YOU-FLY LAUNCH CAMPAIGNS DAY-IN-THE-LIFE

ASSEMBLY

COMPONENT TESTING
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 5 Variance Request
We respectfully ask the City Council to overturn the Planning Commission's denial of our requested 8-foot height variance 30 FT
Current Height Limit
38 FT
Proposed Tank Height
8 FT
Requested Variance
8 FT
Requested Variance
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 6 Variance Request: Background
• Impulse Space is an aerospace manufacturing
company. This is consistent with our I-3 designated use in the City's General Plan and our IC-1 zoning status.
• Liquid Nitrogen and Liquid Argon are necessary to
aerospace manufacturing and have been present in
large volumes in Redondo Beach for decades.
• Impulse Space has been using cryogenic storage of
Liquid Nitrogen and Liquid Argon in the City of Redondo Beach since 2023, consistent with local, state, and
federal regulations.
• As our business grows, our consumption of these
materials will increase.
• Given the special circumstances of our property, we
have one location where these tanks could be installed. • We are proposing the least impactful path forward while prioritizing the safety of our employees, facilities, and community.
30ft
38ft
2477 Manhattan Beach
Blvd.

Granting this variance request enables the safest, industry-proven, and operationally sound path forward for our operations and community.

IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 7 Manhattan Beach Blvd & Redondo Beach Ave looking North Manhattan Beach Blvd looking East Manhattan Beach Blvd & Dow Ave looking West
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 8 Alternative Considerations
Alternate Size: Smaller tanks would significantly impact Impulse’s manufacturing and site operations. • 38 ft tanks are the industry standard. The 30-foot custom tanks are costly, have a significant lead time, and lie outside of the manufacturer's recommendation for this type of operation.
• Using our current 12 ft smaller tanks is unsustainable for our business’s growth. • A smaller tank would require more frequent refilling which would cause noisier operations with a multitude more trucks in and out of the property. • Because it would require a multitude more tanks, smaller tanks would put 50+ existing parking spots at risk for Impulse employees, forcing more employees to park off campus and in the local neighborhood.
• Smaller tanks would bring in additional, unnecessary cost and risk to Impulse operations.

Alternate Locations:
• Alternative locations on the property are not
possible based on the unique circumstances of the
size, shape, location, and surroundings of the property.

Alternate Orientation:
• Alternative orientations, stacking, or burying the
tanks are not consistent with the tank manufacturer’s
recommendations for safe operations.

Impulse Space has evaluated alternatives to requesting an 8-foot variance from the City including alternative tank size, location, and orientation. Each instance is either not possible based on the physical characteristics of the property or poses unnecessary increased risk and undue burden to Impulse’s operations and ability to grow.

IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 9 Variance Criteria & Impulse Space's Position
Redondo Beach Municipal Code
10-2.2510 Variances
(b) Criteria. Variances from the standards and regulations of this chapter shall be granted only when:
(1) 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; (2) Any 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; and (3) The granting of a Variance shall not be contrary to the objectives of the Comprehensive General Plan.

Impulse's Position:

Impulse Space respectfully requests that the City Council overturn the Planning Commission’s denial and grant the 8-foot height variance necessary for continued successful, safe, compliant, and scaling operations at 2477 Manhattan Beach Boulevard.

The requested 8-foot height variance fully satisfies every required finding under RBMC Section 10-2.2510(b), and Impulse Space respectfully asks the City Council to overturn the Planning Commission’s land-use variance request denial. The special circumstances and authorized use of the property, the consistency of the request with established industrial uses in the surrounding area, and the clear alignment with the City’s General Plan collectively demonstrate that approval of this variance is both warranted and appropriate.

IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 10 Criteria #1: Special circumstances of the property
• The property size, location, and surroundings
create a unique circumstance.
• Alternative locations on the property are not
possible based on the unique circumstances of
the size, shape, location, and surroundings of
the property.
• There is a fire lane along the backside of the
property that must remain clear.
• There is a bordering business on the Eastern
side of the property which does not allow room
for tanks.
• Impulse’s proposal places the tanks in the sole
location on our property that could
accommodate the required tanks.
• The strict application of the zoning provisions
deprives Impulse Space from growing under the
authorized use case of our property.

Redondo Beach Blvd
2425 Manhattan Beach
Blvd.

Designated Fire Lane
Shared
property
line
Manhattan Beach Blvd
There are special circumstances applicable to this property based on size, shape, location, and surroundings that the strict application of the zoning provision deprives Impulse from privileges enjoyed by the other properties in the vicinity with an aerospace manufacturing authorized use.

IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 11 Criteria #2: This variance would not constitute a grant of special privilege:
• Impulse Space is an aerospace manufacturing company,
consistent with our authorized uses for I-3 land
designations in the City's General Plan.
• This variance is consistent with our designated use, as Liquid Nitrogen and Liquid Argon are necessary materials to aerospace manufacturing.
• A rejection of this variance would be inconsistent with our authorized use under the City's General Plan.
• Our neighboring facilities on both the East and West
operate larger tanks with the same materials. Our
neighboring facility to the West has been operating 50+ ft liquid Nitrogen tank for +30 years in addition to operating tanks that are <150ft from residential homes.
• The strict application of the zoning provisions restricts Impulse Space from privileges already enjoyed by other
properties in the vicinity with the same “aerospace
manufacturing” authorized use. In this specific instance, the General Plan and zoning use designations for height illustrate a unique inconsistency.
• Upholding this variance request denial would force Impulse into costly custom equipment with long lead times and
avoidable, unnecessary safety risks.

The variance does not constitute a special privilege, as it is consistent with the existing industrial use and maintains compliance with the intent of the zoning district; these conditions support granting the 8-foot variance request. 2024 City of Redondo Beach General Plan
Table 2.1 General Plan Land Use Designations
Zoning View
IC-1
I-1 I-A1
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 12 Criteria #2: This variance would not constitute a grant of special privilege:

Liquid Nitrogen Tank
Liquid Argon Tank
Impulse Space Property
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 13 Criteria #3: The Variance is aligned with the objectives of the Comprehensive General Plan:
• Impulse Space's variance is aligned with the City's General Plan:
• Maintaining existing employers within the North Redondo Tech District (SPA-1)
• Responsible economic development (Policy LU-6.1)
• Business retention and expansion (Policy LU-6.2)
• Key considerations, including "Embrac[ing] creativity, innovation, and technological advances to attract cutting edge industries" (Sect. 2.2.2)
• As a growing employer within the North Redondo Tech District, we cannot grow without the standard industrial infrastructure required for necessary materials. Our request is directly aligned with the City's stated goals for a thriving jobs center of innovation The variance is fully consistent with the General Plan’s goals for supporting economic growth, industrial innovation, and sustaining employment in designated industrial districts.

IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 14 Safety, the regulatory process, and next steps
1 Zoning Building & 2 Structural 3 Fire 4 HazMat Pressure 5 Vessel Workplace 6 Safety
Redondo Beach
Planning Commission
Heigh Variance
30ft.  38ft.

Redondo Beach
Building Division
Building permit & plan
review
Foundation, structural
design, seismic/wind,
anchorage,
construction
Redondo Beach Fire
Department
Fire Code
Construction
Tank location,
separation, venting,
protection, access,
emergency response,
cryogenic hazards
LA County CUPA

CERS / HMBP / CUPA
Requirements
Chemical inventory,
emergency planning,
site information,
inspections
CalOSHA
Pressure Vessel
requirements
Pressure-vessel
design, construction,
inspection, applicable
registration/operation
requirements
CalOSHA
Title 8 regulations
Employee exposure,
cryogenic handling,
oxygen-deficiency
hazards, PPE,
procedures, training
A height variance does not waive or replace any applicable safety, fire, building, hazardousmaterial, pressure-vessel, or occupational-safety requirement.

IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 15 In Conclusion
We respectfully ask the City Council to overturn the Planning Commission's denial of our requested 8-foot height variance 30 FT
Current Height Limit
38 FT
Proposed Tank Height
8 FT
Requested Variance
8 FT
Requested Variance
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 16 Additional Materials
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 17 Economic Impact in the City of Redondo Beach
• Recruiting a highly skilled workforce in the
City of Redondo Beach and the South Bay
• Driving the local economy forward with
significant investment in the City.
• Growing rapidly in size.
• Planting roots in Redondo Beach.

Over 40% of Impulse employees currently
live in the South Bay, with more than 10%
living in the City of Redondo Beach.
• Offering moving bonuses and incentive
packages for current and prospective
employees to move to the South Bay.

IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 18 Supporting Our Community – Mitigation Efforts
Addressing the visual impact of operations:
• Working with the city to build a wall at the
perimeter of the property.
• Would be happy to work with the City to plant
more trees on Manhattan Beach Blvd to
benefit both our employees and our
community.

Providing additional parking:
• Expansion planned for a dedicated parking lot
• Currently providing assisted parking services
for current employees to mitigate parking
impacts in the neighborhood
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 19 Current Structures on Manhattan Beach Blvd & Potential Areas for Additional Mitigation Efforts (photos facing South)
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 20 Visual of Impulse HQ from Dow Ave. (photos facing North) IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 21 Visual of Impulse HQ on Sebald, Burritt, and Spurgeon Ave (photos facing North)
IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 22 Community Outreach
• Initiated a partnership with the Redondo Beach Unified School District (RBUSD) to support the City's STEM Programs • At the request of the community, Impulse provided a sponsorship to our neighborhood Block Party • Impulse has set up an FAQ website to get broad distribution of questions and Impulse’s response • Redondo Beach Community FAQ - https://www.impulsespace.com/redondo-beach/faq • Invited neighbors to submit questions via [email protected] QR Code for the FAQ page IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 23 Community Outreach: Impulse Space's Responsive Actions
Expressed Issue Action Taken by Impulse
Flashing blue lights on security cameras Turn all flashing blue lights off. Lights not required for operation of cameras or for prevention of criminal activity
Car alarms sounding without action Actioned the security team to identify cars, and post pictures of cars on internal messaging ap for all employees
Safety lights from security booths shining towards neighbors’ homes
Re-positioned lights to be turned down towards ground as much as possible while assuring functionality/purpose
Parking Lot Street Sweeping after 5pm on a weekend Reinforced with construction teams that street sweeping must conclude by 5pm Audible back-up alarms from personnel lifts before 7am Reinforced with contractors that all hardware deliveries need to be done after 7am, during normal construction hours. Informed security to prohibit this activity.

Audible back-up alarms from trucks before 7am
Reinforced with contractors that while parking is permitted before 7am, we need to limit reversing or any other noise generation as much as possible. Informed security to prohibit this
Audible back-up alarms going on for extended time during work hours
Reinforced with construction teams to not leave the lifts in a state of alarm for any lengthy period
Jack hammering-like noise before 8am Reinforced with construction teams that jack hammering before 8am is prohibited.

Informed security to prohibit this activity.

IMPULSE SPACE, INC. PROPRIETARY & CONFIDENTIAL INFORMATION 24 Zoning View
IC-1
I-1
I-1A
General Plan View
City of Redondo Beach, Redondo Beach Internet GIS Mapping Portal 1 2026-0595 Impulse Space Variance: Appeal Justification About Impulse Space:

Impulse Space was founded in 2021 with the mission to accelerate our future beyond Earth.

Impulse builds spacecraft that pick up where launch providers drop off – delivering payloads between orbits. This includes delivering cargo from lower Earth orbit (LEO) to deep space orbits, Moon, Mars, and beyond. Our spacecraft are paving the way to a robust orbital economy and unlocking the true space age with reliable, affordable, fast, and easy in-space mobility.

Impulse Space was founded by Tom Mueller, the first employee and CTO of Propulsion at SpaceX and is led by a deep bench of highly experienced engineers from NASA, JPL, the United States Space Force, the United States Air Force, and wide range of commercial aerospace companies. Impulse has been operating in Redondo Beach since 2023 in a 60,000 sq/ft facility.

We are grateful for the City’s welcoming of us over the last three years – we are proudly carrying forward this City’s tradition of aerospace engineering.

Impulse Space has been using cryogenic storage of Liquid Nitrogen and Liquid Argon in Redondo Beach since 2023, in compliance with local, state, and federal regulations. As our business grows, our consumption of these materials will necessarily increase leading to the request before the Council. Impulse Space respectfully submits this appeal of the Planning Commission’s denial of our requested 8-foot height land use variance, to exceed the 30-foot height limit for the installation of four cryogenic bulk storage tanks at 2477 Manhattan Beach Boulevard.

The requested variance is justified per the variance criteria in section RBMC § 10-2.2510(b) given the unique circumstances of the property, the consistency of this request with the authorized use of the property, and the alignment of the variance request with the objectives of the City’s General Plan. A denial of this variance would result in an undue burden on Impulse’s core operations, directly affecting its ability to grow while functioning safely and in accordance with established development standards.

Impulse Space’s request for this variance is driven by the technical, operational, and regulatory requirements, rather than convenience or preferred design, of the 38-foot tanks. The proposed 38-foot tanks are standard industrial equipment whose dimensions are determined by required storage capacity, engineering requirements, and safety standards associated with bulk cryogenic systems as set by the manufacturer in accordance with the local, state, and federal requirements.

The height, orientation, and location of these vessels cannot be materially reduced or relocated without impacting their intended function, required access, and compliance with applicable safety requirements.

Impulse Space has evaluated alternatives to requesting an 8-foot variance from the City including alternative tank location, size, and orientation. Each instance is either not possible 2 based on the physical characteristics of the property or pose unnecessary increased risk and undue burden to Impulse’s operations and ability to grow.

The 38-foot tank is an industry standard, and there is not a standard alternative 30-foot tank because of the specific technical and operational needs of the tank as designated by the manufacturers. Requiring Impulse to order 30-foot tank would require Impulse to order specialized, custom equipment that lies outside of the manufacturer's recommendations for this type of operations. Further, with significant strains on the aerospace supply chain, Impulse estimates a significant lead time for this item. Requiring specialized, smaller tanks would also lead to an increased number of refilling cycles. While each cycle is conducted safely under established procedures, a higher number of operations naturally introduces additional safety considerations. As we make continuous effort to support our neighboring community, we offer that smaller tanks would lead to noisier operations requiring more frequent refilling, with more trucks coming in and out of our facility. Each of these instances increase the risk portfolio and are inconsistent with the best technical, operational, and safety requirements that guide our company. Alternative orientations of the tanks are not consistent with the manufacturer’s recommendation for tank operations around filling. Put another way, we offer to City Council that we are requesting this 8-foot variance because the safest option for scaling our operations is aligned with the best technical, operational, and regulatory requirements.

At Impulse Space, our mission relies on an unwavering commitment to the safety of our employees, our facilities, and our community. Safety is fundamental to who we are as a company, to our success as a business, and to our responsibilities as a proud aerospace manufacturer in Redondo Beach. Our success to date has been possible only because of a strong safety culture, and we cannot reach our next stage of growth, or uphold the proud tradition of aerospace manufacturing, without sustaining that commitment to the daily safety of our employees, facilities, and community.

In keeping with this commitment, our proposed installation will undergo rigorous, multi-layered review by the relevant authorities, which we have outlined here: Before the tanks are cleared for operations, the Redondo Beach Building & Safety Division and Fire Department will conduct a detailed plan review process in which staff will evaluate the proposed installation for compliance with the California Building and Fire Codes and applicable National Fire Protection Association (NFPA) standards and certifications, including site conditions, structural foundations and attachment details/requirements for the tanks, required clearances, tank specifications, pressurerelief systems, and emergency shutoffs. The Building & Safety Division and Fire Department will note any deficiencies and return the plans to the applicant for corrections.

Following approvals, the Building & Safety Division and Fire Department will conduct field inspections to verify that the installation complies with the approved plans and applicable fire and life-safety requirements. During the inspection, the Fire Department will verify that the cryogenic tank's capacity, manufacturer information, and certifications match the approved plans 3 and that the tank has no visible damage, corrosion, or leaks. Staff will also verify required separation distances from buildings, exits, air intakes, and property lines. In addition, the business must submit a hazardous materials business plan to the California Environmental Reporting System (CERS), which triggers a notification to the local Certified Unified Program Agency (CUPA). Upon notification, the CUPA Agency (Los Angeles County Fire Department) will conduct a hazardous materials inspection within 30 days to verify compliance with all applicable hazardous materials requirements.

1. Special Circumstances Applicable to the Property
There are “special circumstances” applicable to this project are created by the property’s unique physical characteristics.

Due to the unique circumstances of the property, no alternative location on Impulse’s property could accommodate the required tanks. Impulse's property is positioned on the corner of Manhattan Beach Boulevard and Redondo Beach Boulevard. There is a fire lane along the backside of the property that must remain clear and a bordering business on the Eastern side of the property which does not allow room for tanks. Accordingly, Impulse’s proposal places the tanks in the sole location on our property that could accommodate the required tanks.

2. The Variance Does Not Constitute a Grant of Special Privilege The variance does not constitute a special privilege, as it is consistent with the existing industrial use and maintains compliance with the intent of the zoning district; these conditions support granting the 8-foot variance request.

The authorized use in Redondo Beach’s General Plan for Impulse Space’s property is “aerospace manufacturing.” This is the same as the surrounding industrial properties, including one aerospace manufacturing facility which has been in operation for 60+ years. The General Plan land use designation for Impulse Space’s property is I-3 and the Zoning is characterized as Industrial-Commercial (IC-3). The adjacent property immediately west of the subject property and also fronting Manhattan Beach Boulevard and the properties immediately adjacent to and north are zoned Industrial (I-1 and I-1A.

But in this unique instance, the zoning development standards for Impulse Space (IC-1) are significantly more restrictive than those of all the surrounding neighboring industrial properties.

Nearby properties with the same authorized uses, including a competing aerospace manufacturer, utilize bulk cryogenic storage tanks with Liquid Nitrogen and Liquid Argon that exceed 100 feet in height, more than triple the existing 30-foot limit being applied to Impulse Space.1These larger nitrogen tanks have been in operation for decades, and do not represent a new burden or danger 12024 PLANredondo; Land Use Element, City of Redondo Beach General Plan 4 to the neighbors. The strict application of the zoning provisions therefore deprives Impulse Space from privileges already enjoyed by other property in the vicinity for the same “aerospace manufacturing” authorized use. In this specific instance, the General Plan and zoning use designations illustrate a unique inconsistency.

Liquid Nitrogen and Liquid Argon are necessary materials across aerospace manufacturing and are commonly stored in large tanks in the neighboring vicinity. Accordingly, granting an 8-foot variance does not constitute a special privilege because it would not grant development rights unavailable to other similarly situated properties with similar General Plan and Zoning designations.

3. The Variance Supports, and Does Not Conflict With, the General Plan Granting this variance supports the General Plan’s objectives of responsible economic development (Policy LU-6.1) and business retention and expansion (Policy LU-6.12). Liquid Nitrogen and Liquid Argon are necessary materials to aerospace manufacturing, and we are scaling our consumption of these materials as we grow. By allowing Impulse Space to install the proposed bulk cryogenic storage tanks, the City is allowing the standard industrial support infrastructure necessary to expanding our operations.

Further, the granting of this variance supports the General Plan’s objective to maintain existing employers within the North Redondo Tech District (SPA-1). As a growing employer within the North Redondo Tech District, our request is aligned with the City’s stated objectives to support a thriving jobs center of innovation.

Thus, the variance aligns with and does not conflict with the City’s General Plan. The variance is fully consistent with the General Plan’s goals for supporting industrial innovation and sustaining employment in designated industrial districts.

Conclusion:

Granting this variance is not a special privilege. It simply enables Impulse Space to operate under the same conditions afforded to neighboring industrial users with similar authorizes uses.

Approving this appeal supports an established employer in the North Redondo Tech District, supports responsible economic development, and helps sustain the City’s tradition of aerospace 5 innovation, which Impulse Space is proud to uphold. Impulse is committed to the safety of our employees, facilities, and community, and an approved 8-foot height variance does not waive or replace any applicable safety, fire, building, hazardous-material, pressure-vessel, or occupational-safety requirements. Impulse has met these standards throughout our existing operations and will continue to do so as a committed partner of Redondo Beach.

For these reasons, Impulse Space respectfully requests that the City Council overturn the Planning Commission’s denial and grant the 8-foot height variance necessary for continued successful, safe, compliant, and scaling operations at 2477 Manhattan Beach Boulevard.

From: Gay De Liefde Swaine
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Chadwick B. Castle; Brad Waller; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: 4-40ft Cryogenic Tanks
Date: Sunday, October 4, 2026 3:39:12 PM
[You don't often get email from [email protected]. 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.

To all who should be concerned,
As a 44 year resident of North Redondo Beach, I am well aware of my part of town being treated as the ignored “step-sister” of Redondo Beach.

Being the main entry from the major freeways in the area to this wonderful beach town, it has always mystified me as to why the main streets and businesses leading to the beach were not cared for or managed like those in the south and central areas. I was sad to see the urban decay progress for so many years.

However, I have been happy to see some recent improvements to our part of town, such as the landscaped sidewalks and mediums in the middle of the road that not only have improved the attractiveness of our area, but made it safer for pedestrians and individuals shopping and dining at local businesses.

In some ways I have enjoyed being such a close neighbor to Northrop Grumman, specifically for the reduction of traffic and noise in the area.

However, the recent situation “supposedly" up for discussion concerning the installation 4-40ft Cryogenic Tanks adjacent to their property facing Manhattan Beach Boulevard is very disconcerting to me. I only recently learned about this at a neighborhood friend's party.

My belief is that they will not only negatively impact the look of the entry to our beautiful city, they could possibly pose a health and safety risk to myself and my neighbors if there were ever an accident concerning them. In addition, their presence would certainly devalue our properties, and open the door to more undesirable development.

I am strongly opposed to approving these 4-40ft Cryogenic Tanks being installed facing Manhattan Beach Boulevard, and hope that my City representatives will join me in opposing their installation.

Sincerely,
Gay D. Swaine
2002 Dufour Avenue
Redondo Beach, CA 90278

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:

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
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.

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.

From: Andre Shih
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; [email protected]; [email protected]; Chadwick B. Castle; Zein Obagi; Scott Behrendt
Subject: As a property owner in North Redondo I strongly oppose the installation of Cryogenic tanks by Impulse Date: Saturday, October 3, 2026 4:58:08 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I urge the City Council to vote to deny Impulse the installation of those tanks 1 Daniel Besinaiz
From: [email protected]
Sent: Monday, October 5, 2026 12:33 PM
To: Daniel Besinaiz
Subject: Impulse 40-foot Cryogenic Tanks
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I’m a Redondo Beach resident close to the site and I OPPOSE allowing the increase of the height variance.

I am very concerned about the city allowing 4 or possibly more - 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities.

There are still many unanswered concerns, misinformation, inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents. These tanks are too close to residential homes, are not compatible with the community. The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life. Please Oppose the request and go back to the drawing board.

Please Do Not Allow This!

Carolyn Kinahan

You don't often get email from [email protected]. Learn why this is important Impulse Space — City Record Analysis | August–September 2026 City Record Analysis — Impulse Space Height Variance
Redondo Beach Planning Commission — August 20 and September 17, 2026 2477 Manhattan Beach Boulevard | IC-1 | Proposed 38-foot cryogenic tanks Scope and Method
This report answers the requested questions from the embedded record of the August and September 2026 Redondo Beach Planning Commission hearings. The evidentiary basis is limited to statements by City planning staff, Fire Department staff, City counsel where identifiable, and Planning Commissioners. Applicant and public statements are not used as evidence for the answers. Commissioner questions are included because they are part of the requested City-side record, but a question is not treated as proof of the proposition embedded in it.

Transcript timestamps are approximate and are provided for verification against the City video.

For Question 9 only, the report distinguishes the oral hearing record from the City's proposed resolution: the phrase ―critical infrastructure‖ appears in the proposed resolution, but the transcript review did not identify a City speaker using or defining that term during the two hearings.

Executive Summary
Question Bottom line

1. City says 38-ft tanks required for
operation?
No explicit City statement. Staff says 38 ft ―really met their needs,‖ while acknowledging a 30-ft configuration would not require this variance.

2. City information on ≤30-ft
operation?
Limited. Staff says it explored 30 ft with Impulse and confirms additional 30-ft-orsmaller tanks could proceed without this variance, but provides no operating plan, capacity, delivery-frequency calculation, or comparative analysis.

3. Traffic study of tank deliveries? No City-side statement identifies a traffic study.

4. Study showing delivery traffic
significant?
No. Staff gives delivery frequency/duration and later says fewer refills reduce potential impact, but identifies no traffic-impact study or significance calculation.

5. Visual-damage analysis? No study identified. Staff shows renderings and says nearby equipment/structures make the tanks ―not unusual in the area,‖ but provides no visual-impact, view, aesthetic, or property-value damage analysis.

6. Any neighborhood damages
analysis?
No quantified damages analysis identified. Staff addresses noise qualitatively and safety/process review, but not economic, property-value, visual, vibration, traffic, or comparative neighborhood damages.

7. Analysis of 38 ft in 30-ft transitional
IC-1?
Only partially. Staff compares the site to adjacent industrial zones allowing up to 110 ft and similar uses. The oral record does not identify an analysis of the policy/design purpose of the 30-ft IC-1 transition itself or the effect of piercing that limit next to R-1.

8. Other IC-1 height variances? None identified in the two-hearing City-side record. Staff cites nearby tanks/equipment exceeding 30 ft and properties with higher height limits, but does not identify a prior IC-1 height variance, address, approval, height, findings, or conditions.

9. City asserts tanks are ―critical
infrastructure‖?
Not orally in the reviewed City-side transcript. The proposed resolution does use ―critical infrastructure.‖

10. City defines ―critical
infrastructure‖?
No definition is provided in the two-hearing City-side record.

1. Does the City ever assert that the 38-foot tanks are required for Impulse operation? Answer: No. No City staff, counsel, or commissioner statement identified in the two hearings says that Impulse cannot operate, or cannot continue its manufacturing use, without 38-foot tanks.

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 hearing, approx. 01:43:20
Impulse Space — City Record Analysis | August–September 2026 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.‖ Staff: ―That’s correct.‖ — August hearing, approx. 01:43:51–01:44:15
Record assessment: Staff's formulation is that 38 feet met Impulse's needs and justified seeking a variance. That is materially different from a City finding that 38 feet is required for operation. The City-side oral record also expressly recognizes a 30-foot-or-smaller configuration as one that would not require this variance.

2. Does the City provide or request information about how Impulse would operate with 30-foot or shorter tanks?
Answer: Only to a limited extent. Staff says it explored the 30-foot issue with Impulse, and commissioners directly raise additional shorter tanks. The City-side record does not provide a complete compliant-alternative operating case.

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: ―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?‖ Staff: ―I would defer to the applicant on that….‖ — August, approx. 01:44:45–01:45:27
Record assessment: The City asks the relevant alternative question but does not itself supply tank capacities, number of compliant tanks, footprint, parking effect, annual LIN/LAR demand, delivery frequency, truck size, or an operating comparison between 38-foot and compliant tanks.

3. Does the City indicate if any traffic studies of tank delivery have been conducted? Answer: No traffic study is identified by City staff, counsel, or commissioners in the reviewed record.

Staff: ―Deliveries are anticipated once per week and will last about 1 hour, in which case typical delivery noise is to be expected.‖
— August, approx. 00:37:59
Staff: the larger size/number ―reduces the overall … number of times that the tanks have to be refilled‖ and therefore reduces ―potential impact on the adjacent residences.‖
— September, approx. 00:47:06–00:47:43
Record assessment: These are operational assumptions and qualitative impact statements, not an identified traffic study. No City speaker cites traffic counts, turning analysis, truck-trip analysis, level-of-service analysis, collision analysis, route study, or neighborhood traffic study.

4. Does the City provide studies indicating whether gas-delivery traffic will be significant to Manhattan Beach Boulevard or local neighborhood traffic?
Answer: No such study is identified in the City-side statements.

Staff refers to ―existing traffic, commercial and industrial noise along Manhattan Beach Boulevard‖ when concluding noise impacts to neighbors are not expected.
— August, approx. 00:37:59–00:38:29
Staff says fewer refills reduce ―the potential impact on the adjacent residences.‖ — September, approx. 00:47:06–00:47:43
Record assessment: The City-side record does not quantify baseline traffic, proposed delivery trips, a complianttank alternative, incremental truck trips, delivery routes, peak-hour effects, or a significance threshold. The record therefore contains qualitative assertions about delivery effects, not a demonstrated traffic-significance analysis.

5. Does the City provide any analysis of visual damages to surrounding neighborhoods? Answer: No visual-damage study is identified. Staff provides renderings and a qualitative comparison to nearby industrial equipment and structures.

Staff: a Google Street View image and rendering were shown ―so you can kind of visualize how these tanks will present from the road.‖
— August, approx. 00:36:28
Impulse Space — City Record Analysis | August–September 2026 Staff: ―The adjacent or nearby properties with similar general plan designations and zoning districts also use storage tanks and other equipment that exceed 30 ft in height,‖ and nearby structures can use height limits over 100 feet, ―to make these tanks not unusual in the area.‖
— August, approx. 00:38:29–00:38:55
Record assessment: The record shows visual exhibits and a qualitative contextual assertion. It does not identify a viewshed analysis, line-of-sight study, visual-simulation study from affected residences, aesthetic-impact analysis, appraisal, hedonic/property-value analysis, or quantified visual damages.

6. Does the City provide any damages analysis of any kind regarding surrounding neighborhoods? Answer: No quantified neighborhood-damages analysis is identified in the City-side record.

Staff: ―with the existing traffic, commercial and industrial noise along Manhattan Beach Boulevard, impacts [on] neighbors related to noise are not to be expected.‖
— August, approx. 00:37:59–00:38:29
Fire Marshal: ―This height variance does not diminish or deviate from fire code requirements… This is strictly just height variance related to the planning and zoning department.‖ — August, approx. 00:39:56–00:40:23
Record assessment: The City discusses safety review, expected noise, setbacks, and delivery frequency. It does not identify a quantified analysis of property-value effects, visual damages, vibration, traffic damages, nuisance effects, economic effects, or a comparative neighborhood-impact analysis of the 38-foot proposal versus a compliant alternative.

7. Does the City analyze consistency of a 38-foot variance with a 30-foot IC-1 area that is transitional by design?
Answer: Only partially. Staff addresses the variance through comparison with surrounding industrial zoning and permitted uses, but the reviewed oral record does not identify an analysis of the purpose of the IC-1 30-foot transition or the consequence of exceeding that transition adjacent to R-1.

Staff identifies the subject site as IC-1 with a 30-foot maximum and notes R-1 single-family residential immediately to the south across Manhattan Beach Boulevard.
— August, approx. 00:35:22–00:36:28
Staff: adjacent zones ―allow a height up to 110 ft‖ and have ―the exact same list of permitted uses‖ while the subject property's height limit is 30 feet; Staff calls those the ―special surrounding circumstances‖ supporting the variance. — September, approx. 00:47:43–00:48:23
Record assessment: The analysis stated on the record is essentially comparative: same/similar industrial uses nearby, but different height limits. No City-side statement identified in the two hearings explains why IC-1 has the lower 30-foot limit, evaluates its transition/buffer function next to R-1, or analyzes whether allowing 38 feet is consistent with that function.

8. Does the City provide information regarding height variances requested or granted to any other party in IC-1? If so, provide details.

Answer: No prior IC-1 height variance is identified in the reviewed City-side record.

Staff says nearby properties with ―similar general plan designations and zoning districts‖ use storage tanks and other equipment exceeding 30 feet and notes structures on ―similar properties‖ with height limits over 100 feet. — August, approx. 00:38:29–00:38:55
Staff compares the subject property's 30-foot limit with adjacent zones allowing up to 110 feet. — September, approx. 00:47:43–00:48:23
Record assessment: Those are comparisons to existing equipment and to different/similar zoning circumstances; they are not examples of a prior variance in the same IC-1 zone. The record does not identify another applicant, address, requested height, approval/denial, findings, conditions, or precedent for an IC-1 height variance.

9. Does the City assert that the proposed tanks are critical infrastructure? Answer: Not in an oral City staff/counsel/commissioner statement identified in the two transcripts. The City's proposed resolution does use the term ―critical infrastructure.‖ Impulse Space — City Record Analysis | August–September 2026 Staff repeatedly describes the equipment orally as ―storage tanks,‖ ―standardized and specialized equipment,‖ ―infrastructure,‖ and a ―standard tank size and height.‖ — August approx. 00:38:29 and 01:43:20; September approx. 00:46:25–00:47:06 Record assessment: Because this report's evidentiary answers are limited to City-side hearing statements, the oral record does not establish the ―critical infrastructure‖ characterization. Separately, the proposed resolution contains that characterization; thus the phrase appears in the City's proposed finding without an identified oral explanation of why these privately operated LIN/LAR tanks qualify as ―critical infrastructure.‖

10. Does the City define critical infrastructure?
Answer: No. No City-side statement in the reviewed August or September transcript defines ―critical infrastructure.‖
Record assessment: The oral record does not identify a municipal-code definition, General Plan definition, emergency-management definition, federal definition, or other adopted definition being applied to these tanks. This leaves the meaning of the phrase in the proposed resolution unexplained by the City-side hearing testimony.

Additional Record Questions

11. What evidence supports the proposition that a compliant alternative would cause “significantly more frequent deliveries”?
The City-side record does not identify a quantitative comparison. Staff says larger/fewer tanks reduce refills, but no compliant-tank capacity, annual consumption, tanker capacity, or trips-per-year calculation is supplied.

12. What evidence supports treating additional deliveries as the greater neighborhood impact than the 38-foot visual intrusion?
No comparative impact analysis is identified. Staff asserts fewer refills reduce potential impact; it does not compare that effect against visibility, aesthetics, property values, massing, or other neighborhood effects of exceeding the 30-foot limit.

13. Does Staff's own testimony establish that 38 feet is a necessity rather than a preferred configuration? No. Staff says the 38-foot size ―really met their needs‖ and that Impulse considered the variance worthwhile. Staff also confirms that 30-foot tanks would not require the variance and that additional compliant tanks could avoid this hearing.

14. Does the City identify an “identical zone designation” comparator enjoying the requested height privilege?
Not in the reviewed oral record. Staff speaks of ―same or similar‖ zones and emphasizes adjacent zones allowing up to 110 feet. The record does not identify an IC-1 comparator with the same 30-foot limit that received the same height privilege.

15. Does the City analyze the consequence that the variance runs with the land? The City confirms that the variance runs with the land. No further City-side analysis is identified regarding the longterm effect of granting an eight-foot height exception independent of Impulse's continued occupancy.

16. Does the City distinguish evidence relevant to safety-code compliance from evidence required to justify the zoning variance?
Yes, and this distinction is important. In September Staff expressly says safety is not part of the variance criteria and urges the Commission to focus on the variance criteria. This means safety-code compliance, standing alone, is not the stated basis for satisfying the zoning findings.

Impulse Space — City Record Analysis | August–September 2026 Overall Record Assessment
The City-side hearing record contains substantial discussion of tank safety, standardization, setbacks, anticipated weekly deliveries, and the presence of taller industrial development nearby. It contains much less support for several propositions that are central to the proposed variance findings. In particular, the oral record does not establish that 38-foot tanks are necessary for Impulse to operate; does not provide a quantified compliant-tank alternative; does not identify a traffic study or comparative delivery-impact analysis; does not identify visual, property-value, or other neighborhood-damages analysis; does not identify a prior IC-1 height-variance comparator; and does not define or orally substantiate the proposed resolution's characterization of the tanks as ―critical infrastructure.‖
Two City-side statements are especially relevant to evaluating the support for the resolution. First, Staff states that a 30-foot tank configuration would not require the variance and confirms that additional tanks at 30 feet or less could avoid this proceeding. Second, Staff characterizes the 38-foot size as one that ―really met their needs,‖ rather than stating that it is technically indispensable. Those statements should be read alongside any resolution language asserting necessity, inability to accommodate the infrastructure at a lesser height, or significant comparative impacts from a compliant alternative.

Source Note
Primary sources reviewed: City YouTube transcript extracts for the August 20, 2026 and September 17, 2026 Redondo Beach Planning Commission meetings, as preserved in Aug2026RBPCMtg_Transcript(2).docx and sep2026RBPCMtg_Transcript(1).docx. The report intentionally excludes applicant and public statements as evidentiary support for its answers. The proposed resolution is referenced only to distinguish its use of ―critical infrastructure‖ from the oral City-side record.

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.

From: Farah K
To: Brad Waller; Zein Obagi; Chadwick B. Castle; Paige Kaluderovic; CityClerk; Daniel Besinaiz; Khatirah Nazif Subject: Concern with possible 40-foot cryogenic tanks
Date: Saturday, October 3, 2026 8:20:55 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I’m a Redondo Beach resident close to the site And I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

These tanks are too close to residences, and are not compatible with the community. The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life.

Thank you,
- Farah Kreutz, M. Ed.

From: Mark Nelson (Home Gmail)
To: Brad Waller
Cc: CityClerk
Subject: Council Members were all on this LA County Memo from the 14th Date: Tuesday, September 22, 2026 8:29:36 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

FYI - LA County states that safety on permitting is RBFD and RB Planning & Safety. Also, LA Co Hazmat has offered to do plume modeling (I had it done already also) since it's clear that RBFD isn't trained in that modeling, however, RBFD is required to make the call - PRIOR TO LA COUNTY INVOLVEMENT - whether there needs to active drainage, walls or sumps. The process is mixed up based on the LA County memo I'm pasting:

Fernando Florez <[email protected]>
Sep 14, 2026, 3:00 PM (8 days ago)
to [email protected], Mario, Mauricio, me
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.

From: Mark Nelson (Home Gmail)
To: CityClerk; Joy Ford; Mike Witzansky; Marc Wiener; Sean Scully; Paige Kaluderovic; Brad Waller; Chadwick B.

Castle; Garth Meyer; Scott Behrendt; Zein Obagi; James Light Subject: CPRA - Impulse Variance to 38-feet
Date: Friday, October 2, 2026 3:58:42 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

CC: Mayor and Council as Public Comment
California Public Records Act Request — Impulse Space Cryogenic Tanks Re: 2477 Manhattan Beach Boulevard / Impulse Space Height Variance / Resolution CC2610-083 Pursuant to the California Public Records Act, please provide electronic copies of all records in the City's possession supporting or analyzing the following statement in proposed Resolution CC-2610-083:
“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.” R 2026-2610-083 GRANTING AN APP…
Specifically, please provide:

1. All analyses, specifications, correspondence, calculations, comparisons, manufacturer information, applicant submissions, staff analyses, or other records comparing the proposed approximately 38-foot cryogenic tanks with standard commercially available tanks below the City's 30-foot height limit, including any analysis of capacity, operating pressure, discharge/flow capacity, boil-off, safety characteristics, delivery frequency, or suitability for Impulse Space's LIN and LAR requirements.

2. All records supporting the assertion that a tank complying with the 30-foot height limit would have to be custom fabricated, rather than using an existing commercially available standard cryogenic tank.

3. All records supporting the assertion that such a custom tank would “not have the same track record of safety” as the proposed approximately 38-foot tanks, including any safety-history, failure-rate, engineering, certification, manufacturer, insurer, firesafety, or risk comparison.

For reference, Linde's published Cryogenic Standard Tanks literature identifies the following standard LIN/LOX/LAR tanks in the same product series: Linde Cryo Tanks Characteristic Standard Size 200 Standard Size 300
Overall height 27.4 ft 37.9 ft
Overall diameter 7.87 ft 7.87 ft
Gross capacity ~5,377 US gal ~7,980 US gal
Net capacity, 18 bar ~5,109 US gal ~7,582 US gal
Maximum working
pressure
18 bar (~261 psi); 36 bar LIN option
(~522 psi) Same
LIN discharge capacity, 18
bar 600 m³/hr (~353 SCFM) 600 m³/hr (~353
SCFM)
LIN boil-off 0.31%/day 0.30%/day
LAR boil-off 0.21%/day 0.21%/day
Construction Vacuum/perlite; austenitic-steel inner
vessel Same
Linde describes these as standardized tanks and states that its standard tanks use common vacuum-insulated construction, pressure regulation and pressure-building systems. Linde Cryo Tanks Linde Cryo Tanks
Please include records held by Community Development/Planning, Fire Department, Building & Safety, City Manager, City Attorney (excluding properly privileged material), consultants, and records received from Impulse Space or its representatives.

Electronic production is requested. If no responsive records exist supporting any one of the three assertions above, please identify that portion of the request as having no responsive records.

From: Jenny Bullen
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Scott Behrendt
Subject: Cryogenic Tanks - Please Vote No
Date: Sunday, October 4, 2026 8:11:38 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

DISTRICT CITY COUNCIL MEMBERS:

I'm a Redondo Beach resident close to the site
and I OPPOSE allowing the increase of the height variance for Impulse Space. I am very concerned about the city allowing 4 or possibly more - 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families' backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation, inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents. These tanks are too close to residential homes, are not compatible with the community. The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life.

Please support your North Redondo residents and vote NO on this granting this privilege.

Jenny Bullen
Redondo Beach Resident
From: Kerry Stitt
To: CityClerk
Cc: Khatirah Nazif; Daniel Besinaiz; Brad Waller
Subject: cryogenic tanks
Date: Monday, October 5, 2026 11:15:40 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hi
I am a resident district 1.,
And I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

Thank you,
Kerry Stitt
310-261-0433
From: Paul Grogan
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Scott Behrendt; Zein Obagi Subject: Cryogenic Tanks
Date: Sunday, October 4, 2026 1:05:37 PM
[You don't often get email from [email protected]. 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.

Hi Paul Grogan,
I live on 2406 Gates Avenue in Redondo Beach, District 5, and I am writing to firmly oppose the height variance for Impulse Space's cryogenic tanks at 2477 Manhattan Beach Boulevard.

Allowing four large cryogenic tanks to rise well above the height limit — outdoors, visible to neighborhoods, families' backyards, and everyone driving into the beach cities — puts heavy industrial equipment far too close to homes. The Planning Commission denied this variance on September 18 for good reason: unanswered safety concerns, and information from the city and Impulse that has been inconsistent and, at times, misleading.

The light industrial area was created as a buffer to separate larger industrial uses from homes. Granting a special exception for one company invites every company to expect the same, and District 5 residents would bear the cost in safety risk and quality of life.

I urge the Council to deny this appeal at Tuesday's hearing and uphold the Commission's decision.

Thanks,
Paul Grogan
Noise Impact Assessment | 1
Cryogenic Tank Refilling Noise Impact Assessment
Proposed Nitrogen and Argon Storage Tanks
2477 Manhattan Beach Boulevard | Redondo Beach | September 17 2026 Preliminary Conclusion
Noise from nitrogen and argon deliveries and tank filling could reach adjacent residences and exceed Redondo Beach residential noise limits. The risk is greatest when transfer operations last more than 15 minutes, involve high-idle truck engines or transfer pumps, include unsilenced venting, or occur during nighttime hours. The current application materials do not establish compliance because they contain no equipment-specific sound ratings, pump model, delivery duration, vent-flow data, property-line measurements, or acoustical model.

This assessment is a preliminary screening analysis rather than a stamped acoustical study. Final compliance depends on the actual equipment, tank and vent locations, intervening structures, measured ambient conditions, operating duration, and measurements at the nearest residential property lines.

Likely Noise Sources
Nitrogen and argon do not create materially different neighborhood noise merely because of the product stored. The principal variables are the delivery truck, pump or power-take-off equipment, pressure and flow rate, piping and valves, vent design, and the duration of each operation.

Activity Potential Noise Character Screening Consideration Truck arrival and
positioning Engine, air brakes and backup alarm Intermittent peaks Stationary truck and PTO Engine at idle or elevated RPM Approximately 75 to 85 dBA at 50 feet for screening
Transfer pump and piping Mechanical hum, pump whine and possible vibration
May be tonal and subject to a 5 dB code
correction
Tank filling Sustained pump and fluid-flow noise Duration determines the applicable code threshold
Hose clearing and
disconnect Brief high-pressure hiss Short-duration peak Routine or relief venting High-velocity gas discharge Potentially dominant unless properly silenced Source Level Benchmarks
Federal highway-noise guidance identifies 85 dBA at 50 feet as the EPA maximum for a stationary, in-use heavy truck engaged in interstate commerce. That value is an upper screening benchmark, not a prediction of the applicant's particular delivery truck. The same guidance uses approximately 6 dBA of reduction for each doubling of distance for an unobstructed point source.

A documented cryogenic-cylinder filling operation measured 111.4 dBA before installation of a vent-line silencer and 67.8 dBA afterward. That facility and filling arrangement are not equivalent to this project, and the measurement distance was not clearly identified. The example nevertheless demonstrates that vent configuration and silencers can change the source level dramatically. The applicant must provide projectspecific data rather than relying on generic descriptions.

Noise Impact Assessment | 2
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
Noise Impact Assessment | 3
Source at 50 Feet Distance to 60 dBA Distance to 55 dBA Distance to 50 dBA 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 lowdensity 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 post-installation 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.

Noise Impact Assessment | 4
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.

References
• Redondo Beach Municipal Code Chapter 24 Noise Regulation • RBMC Section 4-24.201 Noise Measurement Procedure
• RBMC Section 4-24.301 Exterior Noise Limits
• RBMC Section 4-24.401 Interior Noise Standards
• RBMC Section 4-24.504 Vibration
• Federal Highway Administration Noise Guidance
• Cryogenic Refilling Vent Silencer Case Study
From: Mark Nelson (Home Gmail)
To: CityClerk; Joy Ford; Mike Witzansky; Paige Kaluderovic; Brad Waller; Chadwick B. Castle; Scott Behrendt; James Light; Zein Obagi; Garth Meyer; Andrew Winje; Marc Wiener; Sean Scully; Gale S. Hazeltine; Jason Conroy; Wayne Craig; Douglas Boswell; Roger K. Light; Robert Gaddis; Julie Young Subject: Detailed Public Comment: The proposed resolution to approve the 38-foot variance was full of misstatements Date: Monday, September 21, 2026 8:08:58 AM
Attachments: Material Defects in Staff Proposed Resolution to Approve Impulse Variance.pdf CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

More than once, I notified the Planning Commission and the City Council that the proposed resolution that was included in the public notice for the September Planning Commission meeting was full of errors. Here's the detailed analysis with each cite attached below.

The record clearly contradicted statements that were asserted as facts in the Resolution.

Serious issues, such as, the 38-foot tanks be REQUIRED for operations. That statement contradicted the proponent. Or making statements about "significant" impacts from using smaller tanks on the neighborhood. That too was directly contradicted by the proponent. And claims that the 110-foot zoned I-1 and the 30-foot zoned IC-1 were similarly situated. That's contradicted by the transitional nature of the IC-1 and its requirements such as the height.

If Impulse thinks so little of the community effort and appeals instead of installing more, shorter tanks, then their appeal MUST BE REJECTED on the "FACTS". Because the "FACTS" in the proposed resolution contradicted the City's own muni code as well as the direct statements of the proponent.

You don't often get email from [email protected]. Learn why this is important From: Khatirah Nazif
To: Emily Bodkin
Subject: FW: Impulse 40-foot Cryogenic Tanks
Date: Monday, October 5, 2026 12:36:07 PM
Attachments: image001.png
Khatirah Nazif
Program Coordinator
City Clerk's Office
415 Diamond Street | Door 1 | Redondo Beach, CA 90277
[email protected]
From: [email protected] <[email protected]>
Sent: Monday, October 5, 2026 12:35 PM
To: Khatirah Nazif <[email protected]>
Subject: Impulse 40-foot Cryogenic Tanks
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I’m a Redondo Beach resident close to the site and I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing 4 or possibly more - 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation, inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents. These tanks are too close to residential homes, are not compatible with the community. The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life. Please Oppose the request and go back to the drawing board.

Please Do Not Allow This!
Carolyn Kinahan
From: Khatirah Nazif
To: Emily Bodkin
Subject: FW: No Tanks on Manhattan Beach Blvd
Date: Monday, October 5, 2026 11:58:08 AM
Khatirah Nazif
Program Coordinator
City Clerk's Office
415 Diamond Street | Door 1 | Redondo Beach, CA 90277
[email protected]
-----Original Message-----
From: Jim Walter <[email protected]>
Sent: Sunday, October 4, 2026 3:51 PM
To: Khatirah Nazif <[email protected]>
Subject: No Tanks on Manhattan Beach Blvd
[You don't often get email from [email protected]. 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.

Sent from my iPhone
From: Khatirah Nazif
To: Emily Bodkin
Subject: FW: Tanks on Ma Beach Vlvd . Don’t break law. No no no no Date: Monday, October 5, 2026 11:55:08 AM
Please see below public comment. Thank you.

Khatirah Nazif
Program Coordinator
City Clerk's Office
415 Diamond Street | Door 1 | Redondo Beach, CA 90277
[email protected]
-----Original Message-----
From: Mary Parsons <[email protected]>
Sent: Sunday, October 4, 2026 9:42 PM
To: Khatirah Nazif <[email protected]>
Subject: Tanks on Ma Beach Vlvd . Don’t break law. No no no no [You don't often get email from [email protected]. 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.

Mary Ann Parsons
Sent from my iPhone
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 3:31:41 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 Cryogenic Tank Emergency Planning (Case No. 2026-0595)
To: [email protected] <[email protected]>
Cc: [email protected] <[email protected]>, Mario Tresierras <[email protected]>, Mauricio Nunez Florez <[email protected]>
Good afternoon, Mr. Nelson.

Our Health HazMat’s Emergency Operations Section can assist with conducting an off-site 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.

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) <[email protected]>
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 <[email protected]>
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 <[email protected]> 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 From: cindy ogle
To: CityClerk; Zein Obagi
Subject: Height Variance Vote
Date: Tuesday, October 6, 2026 7:43:04 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hi,
I am a 59 year resident of District 4, North Redondo Beach. I strongly OPPOSE allowing the height variance increase. I am extremely concerned about the City allowing 40 foot cryogenic tanks. This would not only be ugly, but could lead to disastrous chemical leaks and fires, as recently happened in Garden Grove.

North Redondo has traditionally been given the short end of the stick. Please, let's not add 40 foot tall cryogenic tanks, destroying our small town beauty and the quality of residents lives.

PLEASE VOTE NO to save North Redondo.

Thank you
Cynthia Ogle
From: Yolanda Jordan
To: CityClerk
Cc: [email protected]; Chadwick B. Castle; Paige Kaluderovic; Brad Waller; [email protected]; Khatirah Nazif
Subject: I OPPOSE allowing IMPULSE the increase of the height variance Date: Sunday, October 4, 2026 2:40:01 PM
Attachments: I OPPOSE allowing IMPULSE the increase of the height variance .msg [You don't often get email from [email protected]. 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.

From: Meriah Doty Treviño
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: I OPPOSE allowing the increase of the height variance re: L.1. 26-1233 Date: Sunday, October 4, 2026 10:11:22 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hi,
As a North Redondo resident and the mother of a seven-year-old elementary student, I strongly oppose the appeal and urge the City Council to deny the variance for these 38-foot bulk cryogenic storage tanks.

North Redondo is a densely populated neighborhood where potentially hazardous tests and industrial gas storage should never be considered in the first place. The light industrial zone was intended to act as a safe buffer, not a staging ground for towering cryogenic tanks placed dangerously close to families' backyards.

The Planning Commission already evaluated the evidence regarding the risks of accidental gas releases and rightly denied this project due to the severe health and safety hazards it poses to our community. I urge the City Council to respect that ruling. Granting this height variance sets a dangerous precedent that prioritizes corporate interests over the safety, health, and quality of life of the residents who live here.

Please uphold the Planning Commission's denial and prioritize the safety of our children and our neighborhoods.

Regards,
Meriah Doty Trevino
MERIAH DOTY TREVIÑO
Content Designer, Strategist
www.meriah.rocks
meriah@gmail
310.804.5207

DRAFT WORK PRODUCT- MEMORANDUM
TO: Redondo Beach City Council and Planning Commission
FROM: Mark Nelson
DATE: September 30, 2026
SUBJECT: Economic Impact of Impulse Space IC-1 Height Variance on Adjacent Residential Property Values

OBJECTIVE
To analyze and quantify the net impact of increased visibility of industrial development using peer reviewed studies—specifically for the proposed Impulse Space IC-1 38-foot height variance—on the property values of the adjacent North Redondo Beach residential neighborhood south of 2477 Manhattan Beach Blvd, 90278.

METHODOLOGY
The analysis utilizes property value diminution models based on CalTech literature study references regarding industrial-adjacent locations. Impact zones were mapped for two scenarios:

1. AS-IS Case (30-foot IC-1 height limit viewshed)

2. Variance Case (34-foot conservative height case - which requires a MINIMUM of 4-feet of the 38-foot tank to be visible
The net impact of 30-feet to 34-feet altitude using the de facto viewshed standard of Google Earth Pro is a visual recognition of the industrial Impulse Space facility from 600-feet further away within the south adjoining neighborhood.

Using identical satellite imagery and a 500-foot scale, the geographical areas for four impact tiers (Zone 1 through Zone 4) were measured. Each Zone moves further from the industrial facility, using measures derived by a CalTech study of real estate value impact by distance from industrial facilities. The AS-IS Zones are lot-line adjacent on the south side of Manhattan Beach Blvd. The Variance Case scenario shifts Zone 1 600-feet southward, creating a larger group of homes that face maximum devaluation. The other zones are likewise shifted south by the same amount.

An average density of 8 homes per acre was applied to estimate the number of affected properties. Because the southern boundary of the base map imagery artificially truncates the extended impact boundaries of the Variance case, the full geographical areas for Zone 3 and Zone 4 were valued by spatial simulation, assuming consistent neighborhood width and lot density. The financial impact was calculated by determining the average percentage value loss within each tier and applying it to a conservative baseline property valuation derived from recent (last 3 years) neighborhood sales data.

PROPERTY VALUATION BASELINE
Based on a recent (3 year) dataset of 46 qualified single-family home sales in the neighborhood, the following property values /were established:
● Minimum Sale Value: $950,000
● Average Sale Value: $1,850,038
● Maximum Sale Value: $4,300,000

CONSERVATIVE ECONOMIC IMPACT
Applying the conservative minimum home value of $950,000 as a strict lower-bound baseline yields the following comparative economic impact model.

Industrial
Devaluation
Average Value
Loss
Conservative
Loss per
Home
AS-IS Total
Res. Value
AS-IS Total
Value Loss
Variance Total
Res. Value
Variance Total
Value Loss
Net Impact of
Increased
Visibility
Zone 1 (Red,
Maximum
Devaluation)

11.85% $112,575 $28,500,000 $3,377,250 $331,550,000 $39,288,675 + $35,911,425 Zone 2
(Orange)

10.00% $95,000 $61,750,000 $6,175,000 $81,700,000 $8,170,000 + $1,995,000 Zone 3 (Blue)
- Simulated

7.50% $71,250 $161,500,000 $12,112,500 $161,500,000 $12,112,500 $0 Zone 4
(Green, Min.

Devaluation) -
Simulated

3.00% $28,500 $152,000,000 $4,560,000 $152,000,000 $4,560,000 $0 Total — — $403,750,000 $26,224,750 $726,750,000 $64,131,175 + $37,906,425
*Note: The $0 net impact for Zones 3 and 4 reflects the spatial simulation holding the east and west neighborhood boundaries constant as the zones shift south. Because the total acreage and home counts for these specific bands remain identical in both scenarios, the net financial damage is driven purely by the expansion of Zones 1 and 2.

CONCLUSION
Even when applying the most conservative residential valuation floor to the model, the data demonstrates that granting the height variance and expanding the sightlines subjects an additional $323 million of residential property to industrial devaluation. Ultimately, this is predicted to directly degrade total neighborhood property values by an additional $37.9 million compared to the AS-IS baseline.

From: Cheri Deland
To: Daniel Besinaiz; CityClerk; Khatirah Nazif; Scott Behrendt Subject: Impulse
Date: Monday, October 5, 2026 7:15:16 PM
Some people who received this message don't often get email from [email protected]. Learn why this is important
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello -
I am a resident of district 5 and a Redondo Beach resident. I live close to impulse, which is located on Manhattan Beach Blvd and Dow/Vail Ave.

I OPPOSE Impulse’s request for height variance / special privileges. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents. Questions such as 40ft. Cryogenic Tanks to be installed; The safety of redondo beach residences; commuters and visitors.

Thank you.

Cheri DeLand
Sent from my iPad
From: [email protected]
To: CityClerk
Subject: Impulse 40-foot Cryotgenic Tanks
Date: Monday, October 5, 2026 12:31:41 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Please Do Not Allow This!
Carolyn Kinahan
From: Shellinda
To: CityClerk
Cc: Brad Waller; Daniel Besinaiz; Khatirah Nazif; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Impulse and city safety
Date: Saturday, October 3, 2026 10:32:36 PM
[You don't often get email from [email protected]. 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.

Hello
I’m a Redondo Beach resident who lives very close to the Impulse site and I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing 4 or possibly more - 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation, inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents. These tanks are too close to residential homes, are not compatible with the community. The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life.

Shellinda Barre
From: Alyssa Round
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt; Alyssa Medina
Subject: Impulse concern
Date: Sunday, October 4, 2026 5:04:15 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I'm a Redondo Beach resident close to the site.

And I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families' backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

From: Christine Marie
To: CityClerk
Cc: Khatirah Nazif; Daniel Besinaiz; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Impulse Cryogenic Tank Concerns
Date: Monday, October 5, 2026 10:23:17 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Dear Mayor and Members of the Redondo Beach City Council, I am a resident of Council District 5 and live on Dufour Avenue, a few blocks from the Impulse Space facility on Manhattan Beach Boulevard. I understand the request to install four approximately 40-foot cryogenic tanks is now before the City Council following its consideration by the Planning Commission.

I support responsible business development and understand the value that companies like Impulse Space can bring to Redondo Beach. My concern is not the appearance of the tanks.

My concern is public safety, the potential impact on neighboring homeowners, and what this approval could mean for future expansion of hazardous-material storage at this location.

Before approving the height variance, I believe residents deserve clear answers to several important questions:
• What exactly will be stored in these tanks, and in what quantities? What gases or other materials will be stored, what is the capacity of each tank, and what will be the maximum aggregate amount permitted on the property? • What protections are in place for surrounding residents? What monitoring, leak detection, automatic shutoff, pressure relief, fire protection and airquality safeguards will be required? What happens in the event of a leak, equipment failure or other emergency?
• What is the emergency response plan for the surrounding neighborhood? What are the evacuation or shelter-in-place procedures? How would residents be notified? Have the Fire Department and other emergency responders reviewed the facility's specific hazards and response requirements?
• What are the enforceable limits on future expansion?
My concern is not only the four tanks proposed today. If this variance is approved, could additional tanks or substantially greater hazardous-material storage be added later as Impulse Space expands? Will there be firm limits on the number, size, height, type and aggregate capacity of cryogenic storage on the property? Would future expansion require another public review?
There is also an economic concern for the homeowners immediately surrounding the facility.

TThese homes are significant financial assets. The introduction of large-scale cryogenic storage and associated industrial activity in close proximity to residential properties could affect the desirability and marketability of those homes, regardless of whether an incident ever occurs. I believe that potential impact deserves consideration as part of this land-use decision.

I respectfully ask the City Council to ensure that these questions are answered publicly and on the record before approving the variance, and that any approval include clear, enforceable limits on hazardous-material storage and future expansion.

I am not asking the City to prevent Impulse Space from operating in Redondo Beach. In fact, I think the work they are doing is innovative and fascinating. I am simply asking the City to make sure that this development does not shift potentially significant safety risks or economic costs onto the homeowners who live immediately next to the facility.

Thank you for your time and consideration.

Sincerely,
Christine Cliver
Resident, Council District 5
N. Redondo Beach
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.

From: Dixie Duncan
To: CityClerk
Cc: Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Impulse Space -- Agenda Item -- Variance Requested for 38 Ft. Storage Tanks Date: Monday, October 5, 2026 4:52:16 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Good afternoon,
I write to make a comment on the variance requested by Impulse Space for 38 Ft. storage tanks, which would be 8 feet higher than what is currently allowed.

I understand the appeal will be discussed at the City Council Meeting on Tuesday, October 6, 2026.

I have seen multiple Facebook and Nextdoor comments from nearby residents who strongly oppose the storage tanks.

Although I do not live very close to the facility, I am a very long term Redondo Beach resident and home owner (District 3).

I think granting the variance for the storage tanks is a reasonable thing to do.

I read some statements from the Impulse Space on the city’s agenda (page 698 of the appeal) and their statements for the requirement of 38 ft. tanks sounded reasonable to me.

I looked at the website for Impulse Space, and the business seems to be a very good addition to our city with good growth potential.

It is space oriented, and they partner with some excellent companies, including SpaceX.

They seem like a growing company that could greatly enhance the economy and revenue in Redondo Beach.

I would imagine a lot of the local small businesses would be happy to have more new customers as well.

Thank you,
Dixie Duncan
2132 Havemeyer Ln.

Redondo Beach, CA 90278
Email:[email protected]
Phone: (310) 487-9660
From: Rebecca Minas
To: CityClerk
Cc: [email protected]; [email protected]; Brad Waller; [email protected] Subject: Impulse space Cryogenic Tanks _No
Date: Sunday, October 4, 2026 8:37:03 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello,
I was born and raised in Redondo Beach and my family still lives there And I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

Thank you for your attention and consideration of this matter.

Sincerely,
Rebecca Minas
Yahoo Mail: Search, Organize, Conquer
From: Cecilia Ball
To: CityClerk; Daniel Besinaiz; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Impulse Space cryogenic tanks - 2nd attempt
Date: Sunday, October 4, 2026 12:21:22 PM
[Some people who received this message don't often get email from [email protected]. 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.

I just sent the email below. However, my computer is on its way out and did some weird spacing on the email so here is a second attempt. Hopefully my computer does not decide to take "poetic license" this time around.

Original note:

I am a resident of Manhattan Beach and have recently learned that Impulse Space is in the process of installing 40 foot cryogenic tanks in Redondo Beach. This is occurring without any input from residents of Redondo Beach,including those whose homes are closest to the tanks.

In light of the recent explosion of a tank at GKN Aerospace in GardenGrove and of the CA legislation that was signed into law at the end of September regarding new storage facilities of this type, it was the responsibility of Redondo Beach City Council to get input from all Redondo Beach residents, especially those living closest to the tanks, BEFORE construction was approved and begun. It is unbelievable that the Redondo Beach City Council did not do this.

There is a hearing scheduled for this week and I hope it isn’t “just for show”. Redondo Beach City Council should put an immediate halt to the construction until residents are thoroughly informed and have an opportunity to decide whether the construction should proceed and, if so, with what safeguards. It isn’t too late to correct this mistake.

Should a disaster occur, it would most certainly affect a large portion of the South Bay and those who chose to approve the project without public approval should be held personally liable. -----Original Message-----
From: Cecilia Ball <[email protected]>
Sent: Oct 4, 2026 12:06 PM
To: <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>, <[email protected]>
Subject: Impulse Space cryogenic tanks
Iam a resident of Manhattan Beach and have recently learned thatImpulse Space is in theprocess of installing 40 foot cryogenic tanks in Redondo Beach. Thisis occurring without any input from residents of Redondo Beach,including those whose homes are closest to the tanks.

Inlight of the recent explosion of a tank at GKN Aerospace in GardenGrove and of the CA legislation that was signed into law at the endof September regarding new storage facilities of this type, it wasthe responsibility of Redondo Beach City Council to get input fromall Redondo Beach residents, especially those living closest to thetanks, BEFORE construction was approved and begun. It isunbelievable that the Redondo Beach City Council did not do this.

Thereis a hearing scheduled for this week and I hope it isn’t “justfor show”. Redondo Beach City Council should put an immediate haltto the construction until residents are thoroughly informed and havean opportunity to decide whether the construction should proceed and,if so, with what safeguards. It isn’t too late to correct thismistake.

Shoulda disaster occur, it would most certainly affect a large portion of the South Bay and those who chose to approve the project withoutpublic approval should be held personally liable.

From: Paul Raph Lopez
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Scott Behrendt
Subject: Impulse space Cryogenic tanks
Date: Monday, October 5, 2026 12:09:36 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello,
I am a resident district 5. Paul Lopez, 2910 Blaisdell Ave., close to the site) and I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed at Impulse Space, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities.

There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

These tanks are too close to residences, and are not compatible with the community.

The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life.

Thank you,
Paul Lopez
From: Barbara
To: CityClerk
Cc: Daniel Besinaiz; Scott Behrendt; [email protected] Subject: Impulse Space Cryogenic Tanks
Date: Monday, October 5, 2026 6:23:49 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I am a District 5 resident, a concerned Redondo Beach resident close to the site. I have lived here since 1973. I am very concerned about the city allowing 4 or more, 40 ft cryo tanks to be installed, outside, visible to neighborhoods. families backyards and all commuters coming into this area.

These tanks are too close to residential homes and are not compatible with the community.

The site Impulse leased if for LIGHT industrial and has been historically used for warehouses and storage. Impulse is asking to change the rules and asking for special privileges at the expense of sacrificing our area and safety.

There are still may unanswered concerns, misinformation and inconsistencies that need to be answered and resolutions have not been provided to residents by our elected City Council.

I OPPOSE this variance and the placement of these tanks without full disclosure by our City Council.

Thank you.

Barbara Giba
From: Susan Cunningham
To: CityClerk
Cc: [email protected]; Khatirah Nazif; Scott Behrendt; Zein Obagi; Chadwick B. Castle; Brad Waller; Paige Kaluderovic
Subject: Impulse Space L.1. 26-1233
Date: Sunday, October 4, 2026 11:16:05 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

As residens of North Redondo, we are seriously Opposed to this agenda item . L.1. 26-1233

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
Dist. 5 representative We request voting against this.

We would consider this an extreme detriment to our neighborhood and community. Not to mention the health risks this would bring upon our residents.

Thank you
Susan and Eric Cunningham
From: Michelle DeLand
To: CityClerk
Cc: Khatirah Nazif; Daniel Besinaiz; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Impulse Space site/cryogenic tanks
Date: Sunday, October 4, 2026 8:05:06 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I am a Redondo Beach resident who lives near the Impulse Space site, and I strongly oppose the proposed increase in the height variance.

I am deeply concerned about allowing four or potentially more 40-foot cryogenic tanks to be installed outdoors in close proximity to residential neighborhoods. These structures would be highly visible from nearby homes, backyards, streets, and surrounding areas.

There are still significant questions and concerns regarding the proposed tanks, their placement, safety, visual impact, and compatibility with the surrounding residential community. Residents deserve clear, consistent, and complete information from both the City and Impulse Space, as well as meaningful responses to the concerns that have already been raised.

The existing light-industrial area serves an important purpose as a buffer between larger industrial operations and nearby residential neighborhoods.

Allowing structures of this scale and height so close to homes would change the character of the area and set a precedent for future requests of a similar nature.

I respectfully urge the City to deny the requested height variance and to protect the character, safety, and quality of life of the District 5 community.

Always hopeful always believing
Michelle DeLand
310-849-4390
From: Gary Wild
To: CityClerk
Cc: Daniel Besinaiz; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Impulse Space-Installing 40ft cryogenic tanks
Date: Sunday, October 4, 2026 4:31:07 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

I’m a Redondo Beach resident close to the site (2404 Thomas Ave, RB) And I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents. These tanks are too close to residences, and are not compatible with the community. The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life. Please DON'T APPROVE THE INWSTALLATION.

Gary Wild
2404 Thomas Ave
Redondo Beach CA 90278
From: Frank Lacey
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Paige Kaluderovic; Scott Behrendt
Subject: Impulse
Date: Monday, October 5, 2026 4:12:46 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello,
My wife and I are residents living directly across the street from the ‘Impulse‘ site and we OPPOSE allowing the increase of the height variance.

We are very concerned about the city allowing four, or possibly more, 40- foot cryogenic tanks to be installed outside, visible to my neighborhood, families' backyards and all commuters coming to our beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

These tanks are too close to residences, and are not compatible with the community. It will make our neighborhood look like it’s next to Chevron. The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life.

With all the recent beautification along Manhattan Beach Boulevard, allowing huge gas tanks opposite to my neighborhood is a “Giant Leap Backward for Redondo Beach”.

Because the City cannot make all mandatory findings from the present record, the Council should deny the appeal and uphold the denial of the height variance.

Thank you for your attention to the concerns of the residents of the Dow Triangle.
-------------------------------------
Frank Lacey and Lori Vaughan
310.963.2392
3503 Johnston Avenue
Redondo Beach, CA 90278
[email protected]
Impulse Space Appeal Testimony Review | Page 1
Review of the Impulse Space Appeal Against Planning Commission Testimony
2477 Manhattan Beach Boulevard | Planning Commission Item K1 | Prepared October 3, 2026 Executive Conclusion
The most significant discrepancy is that the appeal says alternatives were evaluated and no feasible alternative exists, while the applicant acknowledged that at least one structural alternative had not been investigated. The appeal also changes the explanation for rejecting horizontal tanks, describes neighboring cryogenic tanks as exceeding 100 feet when the testimony separately referred to tanks over 30 feet and structures over 100 feet, and inconsistently identifies the subject property's zoning.

Recommended treatment. These discrepancies should be presented as credibility and evidentiary issues, not as an accusation of perjury or intentional misrepresentation. The transcript is unofficial and edited, and some appeal assertions could reflect information developed after the hearing. If the Council intends to rely on those new assertions, it should require the underlying documentation and allow public review.

Principal Findings
• The written appeal converts incomplete or unquantified testimony into categorical conclusions that all alternatives were evaluated and that no feasible alternative exists.
• Several key appeal assertions - including manufacturer recommendations, the absence of a standard 30-foot tank, a one-year lead time, and neighboring tanks exceeding 100 feet - were not established by supporting evidence at the hearing. • The appeal does not directly rebut the Commission's adopted findings concerning height, residential compatibility, special privilege, precedent, and General Plan consistency.
• The subject zoning and the comparison properties must be corrected and verified before the Council relies on the special-privilege argument.

Scope and Caution
This review compares the September 17, 2026 unofficial edited transcript with the appeal application and justification. Transcript timestamps are approximate. The City's official recording, final minutes, executed resolution, and original exhibits control if they differ. This review identifies inconsistencies, shifts in explanation, unsupported new assertions, and omissions; it does not determine intent or make a legal finding concerning the truthfulness of any witness.

Impulse Space Appeal Testimony Review | Page 2
Issue Comparison Table
Priority reflects the significance of the issue to the variance findings and the need for supporting evidence.

Issue and Priority Planning Commission Record Appeal Argument Assessment and Evidence Needed Alternatives
evaluation
HIGH
At 01:08:58, the applicant acknowledged that
a structural support alternative raised by a
commissioner was "something we did not look
into," although the applicant believed the
engineering would be extensive.

PDF pages 4 and 7 state that Impulse
evaluated alternative locations, sizes, and
orientations and conclude that no feasible
alternative exists.

This is the strongest record inconsistency. The appeal
presents the alternatives review as complete, while the hearing testimony identifies an alternative that was not investigated. Require a dated alternatives matrix, the
preparer's qualifications, engineering criteria, and
supporting calculations.

Horizontal tank
rationale
HIGH
At 01:07:42-01:08:30, the stated reasons for
rejecting horizontal tanks were the need for
pumps, pump noise, and the assistance
provided by gravity flow. The witness said
gravity "helps."
PDF page 5 states that alternative orientations
are inconsistent with the manufacturer's
recommendation for tank operations around
filling.

The appeal substitutes or adds a manufacturer-based
justification that was not stated at the hearing. Require the manufacturer's written recommendation, the modelspecific specifications, and a comparative vertical-versushorizontal analysis.

Eastern site
constraint
MEDIUM
At 00:53:26, the applicant described the
eastern area as a Southern California Edison
right-of-way being used by Devil Mountain
under a secondary land-use lease.

PDF page 6 describes the eastern constraint
as a bordering business that leaves no room
for tanks and calls the proposed area the sole
location that can accommodate them.

The written characterization omits the right-of-way and lease circumstances. Require a dimensioned site plan, property and easement boundaries, and evidence that access, lease modification, relocation, or another arrangement was
evaluated.

Height of nearby
tanks
HIGH
At 00:55:02, the applicant distinguished
between storage tanks and equipment
exceeding 30 feet and, separately, several
structures exceeding 100 feet.

PDF page 6 states that nearby bulk liquid
nitrogen and argon storage tanks exceed 100
feet in height.

The appeal materially escalates the hearing statement by converting "structures" over 100 feet into cryogenic tanks over 100 feet. Require addresses, photographs, verified dimensions, tank contents, zoning, approvals, and distances to residences.

Zoning designation
HIGH
Staff repeatedly identified the subject property
as IC-1, including at 00:39:50 and in the
approval motion at 01:48:09.

PDF page 6 identifies the General Plan
designation as IC-3, then refers to the
property's zoning development standards as I3, while identifying surrounding properties as I1.

At minimum, this is a material drafting or classification error in the central variance analysis. The appeal also does not identify an IC-1 comparator receiving the claimed height privilege. The City should correct the record before acting.

Thirty foot tank and
lead time

HIGH EVIDENCE GAP
The hearing included general statements that
the 38-foot configuration was standard and
that a custom configuration might add risk.

The applicant did not present a manufacturer
declaration, quotation, specification, or leadtime documentation.

PDF page 5 adds that no standard 30-foot tank
exists, a custom tank would fall outside
manufacturer recommendations, and
procurement would require at least a one-year
lead time.

These are new, outcome-relevant factual assertions rather than established hearing evidence. Require manufacturer and vendor letters, model options, quotations, fabrication feasibility, lead times, and the applicable safety or
regulatory standards.

Impulse Space Appeal Testimony Review | Page 3
Issue and Priority Planning Commission Record Appeal Argument Assessment and Evidence Needed Deliveries noise and
risk

MEDIUM EVIDENCE
GAP
Staff stated that larger tanks would reduce
refill events, and the applicant stated that
pumps for horizontal tanks would create
noise. No quantified comparison was
presented.

PDF page 5 treats additional deliveries, truck
movements, noise, and risk as consequences
of smaller tanks and as support for the taller
configuration.

The assertion may be plausible, but the record contains no tank-capacity comparison, consumption rate, delivery
frequency, fill duration, truck routing, source noise level, or residential noise analysis. Require calculations and an acoustical study.

Neighborhood
compatibility

HIGH OMISSION
At 02:03:29-02:07:26, the Commission
adopted findings concerning height
compatibility with adjacent residences, failure
to minimize industrial impacts, special
privilege, precedent, and General Plan
inconsistency.

PDF pages 7-8 emphasize similar industrial
uses, business expansion, and economicdevelopment policies. They do not provide verified sight lines, visual simulations,
screening analysis, or a residential heightimpact comparison.

This is a material omission rather than a direct contradiction.

The appeal does not rebut the Planning Commission's
principal land-use findings and does not establish that the additional eight feet are compatible with nearby homes.

Impulse Space Appeal Testimony Review | Page 4
Questions the City Council Should Require Impulse to Answer

1. When was the alternatives analysis performed, who prepared it, and where is the written report?

2. How can the appeal say all alternatives were evaluated when the applicant testified that one structural alternative was not investigated?

3. What manufacturer document states that a 30-foot or horizontal tank is outside the manufacturer's recommendations?

4. Which neighboring cryogenic tanks exceed 100 feet, and what are their addresses, zoning, dimensions, tank types, approvals, and distances from residences?

5. Is the subject zoning IC-1, IC-3, or I-3, and what identically zoned property receives the claimed height privilege?

6. Why does the appeal describe the eastern constraint as a bordering business when the testimony identified an Edison right-of-way and secondary lease?

7. What are the calculated delivery frequencies, fill durations, truck movements, pump requirements, and noise levels for each alternative?

8. Where is the sight-line, screening, and residential-compatibility analysis addressing the Commission's adopted denial findings? Recommended Council Approach
Do not treat the appeal's categorical conclusions as proof. The Council should deny the appeal because the written justification does not supply a reliable evidentiary basis for overturning the Commission's findings. The appeal does not establish a property-specific hardship, an identical-zone comparison, or residential compatibility.

If the Council is not prepared to deny the appeal, continue the matter. Before reconsideration, require a corrected zoning analysis; a dimensioned alternatives study; manufacturer and vendor documentation; verified comparator tank information; quantified delivery and noise analysis; and residential sight-line, screening, and visual-impact evidence. The material should be filed early enough for meaningful public review.

Sources Compared
• Impulse Space Appeal Application and Appeal Justification, City Council File 26-1233, PDF pages 1-8; substantive justification at PDF pages 4-8. • Planning Commission Item K1 Edited Transcript, September 17, 2026, including the focused resolution section and the chronological transcript; timestamps cited in the table are approximate.

IMPULSE SPACE HEIGHT VARIANCE APPEAL

Page 1 ends

Summary Supporting Denial of the Impulse Space
Height Variance Appeal
To Redondo Beach City Council
Property 2477 Manhattan Beach Boulevard
Subject Appeal of the Planning Commission denial of the requested height variance Date
From:

September 24, 2026
Nick Biro, 2423 Sebald Ave. Redondo Beach, CA
Overall Assessment
The City Council has a defensible basis to uphold the Planning Commission's denial because the record does not establish the mandatory findings required for a variance. The controlling question is not whether Impulse Space is a desirable business or whether 38-foot tanks would be more efficient. It is whether this IC-1 property has special circumstances that justify an exception from the applicable 30-foot height limit.

California Government Code Section 65906 permits a variance only when special circumstances applicable to the property would otherwise deprive it of privileges enjoyed by nearby property under an identical zoning classification. The adjustment also may not constitute a grant of special privilege. The applicant's operational preference, cost savings, or desire for fewer deliveries does not by itself satisfy those requirements.

The newly reviewed hazard and noise materials strengthen a narrower procedural conclusion: the Council should not reverse the denial or make affirmative variance findings while material, site-specific effects remain unverified. The hazard memorandum and noise assessment are screening-level public-review documents, not substitutes for City-retained or applicant-funded expert studies. They nevertheless identify concrete questions that should be resolved before the City treats safety, refilling noise, delivery impacts, and mitigation as settled.

Key Findings Supporting Denial

1. No unique physical hardship has been demonstrated
The evidence does not identify a unique condition involving the parcel's size, shape, topography, location, or surroundings that makes compliance with the 30-foot limit infeasible. The asserted hardship arises primarily from the applicant's preferred equipment capacity and operating configuration, rather than from a physical characteristic of the property.

2. The record does not establish that a conforming alternative is infeasible The September 17 transcript does not support the prior statement that Impulse admitted smaller tanks were feasible. Staff stated that the 38-foot configuration was a standard tank size and that a custom size could be riskier. Impulse representatives asserted that altering tank size would compromise safety, technical, operational, and regulatory requirements, and the applicant acknowledged that one structural alternative had not been evaluated. These statements may support the applicant's position, but the cited record does not include a manufacturer comparison or project-specific engineering analysis

IMPULSE SPACE HEIGHT VARIANCE APPEAL

Page 2 ends

demonstrating that every configuration complying with the 30-foot limit is infeasible. Denial of this particular variance also does not prohibit the property's existing permitted industrial use.1

3. Operational preference is not technical necessity
Larger tanks may reduce delivery frequency, operating time, or cost. Those advantages may explain why the applicant prefers the proposed configuration, but they do not prove that approximately 38-foot tanks are technically required. The record distinguishes business efficiency from a zoning hardship.

4. No deprivation relative to identically zoned property has been established Staff principally compared the IC-1 parcel with neighboring I-1 properties that allow substantially greater heights. Similar industrial uses and General Plan characteristics do not create identical zoning classifications or identical development rights. The necessary comparison is with property subject to the same IC-1 standards.

5. Approval could confer a special privilege
Without evidence that comparable IC-1 properties enjoy similar height relief, allowing this parcel to exceed the IC-1 limit based on the standards of differently zoned property risks granting a development privilege unavailable to other IC-1 parcels.

6. Neighborhood compatibility remains unresolved
Residents presented evidence that the additional height would increase the tanks' visibility, industrial massing, and prominence from nearby homes, yards, kitchens, and porches. The City's zoning purposes include maintaining residential neighborhood character and ensuring compatibility between land uses.

The proposed approval findings did not adequately address the effect of the additional eight feet on the adjacent residential area.

7. The evidentiary uncertainty weighs against granting the variance The applicant must provide evidence supporting the findings required for approval. The Council does not need to prove that the tanks are inherently unsafe or that every asserted impact will occur. It may uphold the denial because the affirmative findings necessary to approve the variance cannot be made from the record.

8. The hazard memorandum identifies a need for independent offsite consequence review The Technical Hazard Memorandum models a catastrophic release from a 12,000-gallon liquid argon tank using the federal CAMEO, ALOHA, and MARPLOT tools. Under its stated assumptions, the screening model reports PAC-1 distances of approximately 314 to 316 yards and PAC-2 distances of approximately 145 to 160 yards, with plume behavior varying by weather and atmospheric stability. The memorandum expressly describes its results as indicative and calls for the City to perform its own analysis. It therefore should not be cited as conclusive proof that the project is unsafe. It does, however, identify a material evidentiary gap: the record reviewed here does not contain a City-validated, project-specific offsite consequence analysis addressing oxygen displacement, heavy-gas behavior, release assumptions, drainage or containment, nearby receptors, and emergency access.2 1 Planning Commission Item K1 Edited Transcript, September 17, 2026, pages 6, 9, and 12 (staff discussion of standard and custom tank size; Impulse presentation concerning changes in tank size; and the response at 01:08:58 that a raised structural alternative had not been evaluated). See Appendix C. The transcript does not record an admission that smaller tanks are feasible. 2 M. E. Nelson, Technical Hazard Memorandum, Offsite Consequence and Heavy Gas Dispersion Analysis, September 23, 2026, pages 1-5 and maps at pages 7-8. See Appendix A. The memorandum labels its results indicative and provided for discussion, and calls for the City to perform its own analysis.

IMPULSE SPACE HEIGHT VARIANCE APPEAL

Page 3 ends

9. Refilling noise compliance has not been demonstrated The Cryogenic Tank Refilling Noise Impact Assessment identifies truck engines, power-take-off equipment, transfer pumps, valves, hose clearing, backup alarms, and routine or relief venting as potential sources. Its screening calculations use a range of 75 to 85 dBA at 50 feet and estimate approximately 59 to 69 dBA at an assumed 300-foot receptor distance. Those levels could exceed the City's low-density residential limits depending on duration, tonal characteristics, time of day, and the actual source location. The assessment is preliminary and does not predict the applicant's actual equipment. Its central finding is that compliance cannot be established without manufacturer sound data, a final site plan, ambient measurements, analysis of a full delivery cycle, elevated vent modeling, enforceable delivery and operating hours, and post-installation verification.3 Weaknesses in the Staff Position Supporting Approval
• The earlier characterization that Impulse admitted smaller tanks were feasible is not supported by the September 17 transcript. The defensible weakness is different: staff and applicant representatives asserted that the 38-foot size was standard and that altering size would compromise safety or operations, but the record cited here does not include a comparative manufacturer or engineering analysis demonstrating that a code-compliant configuration is infeasible. • The statement that the infrastructure cannot be accommodated at a lesser height converts a preferred operating configuration into an unsupported claim of technical necessity. • The assertion of significantly more frequent deliveries is not supported by a quantified comparison of gas demand, tank capacity, tanker capacity, annual truck trips, delivery duration, traffic, or noise. • The conclusion that additional deliveries would have the greatest neighborhood impact is comparative, yet no analysis established that those impacts would exceed the visibility, scale, and compatibility effects of taller tanks.
• The applicant itself stated that the effects of an alternative configuration were difficult to quantify and would require an impact assessment. Staff nevertheless presented those unresolved effects as definitive findings.
• Staff relied on the more permissive height standards of neighboring I-1 property to justify relief from the 30-foot limit applicable to the IC-1 parcel. This does not establish a privilege enjoyed by property under an identical zoning classification.
• The proposed post-approval noise study and possible future sound wall indicate that important operational effects had not been measured or resolved before approval. • The proposed approval resolution did not provide an equivalent analysis of the additional eight feet of visual height, industrial massing, neighborhood compatibility, or other land-use effects on adjacent residential properties.
• The rejected staff resolution is evidence of what staff proposed that the Planning Commission find; it is not evidence that those proposed findings were factually established. • The record reviewed here does not contain an independent, project-specific offsite consequence analysis that validates or refutes the submitted ALOHA and MARPLOT screening results. Deferring that question leaves the Council without a complete basis for treating offsite oxygen-displacement risk as resolved.
• The preliminary noise assessment identifies a credible potential for residential exceedances during refilling, particularly for operations lasting more than 15 minutes, tonal equipment, elevated venting, and nighttime activity. A post-approval study does not provide the evidence needed to evaluate those effects before the discretionary decision.
3 Cryogenic Tank Refilling Noise Impact Assessment, September 17, 2026, pages 1-4, especially pages 2-3. See Appendix B. The assessment is a preliminary screening analysis, not a stamped acoustical study, and states that final compliance depends on project-specific equipment and measurements.

IMPULSE SPACE HEIGHT VARIANCE APPEAL

Page 4 ends

Recommended City Council Framing
The Council should uphold the Planning Commission's denial because the required variance findings cannot be supported by substantial evidence in the record. The decision should remain focused on the requested height exception and should not be characterized as opposition to Impulse Space, aerospace manufacturing, or the underlying permitted use.

The final denial resolution should separately address each required finding, quote or accurately paraphrase the September 17 testimony rather than characterize it as an admission concerning smaller tanks, identify the absence of evidence involving comparable IC-1 properties, distinguish operational efficiency from a property-based hardship, and explain the unresolved effect of the additional height on the neighboring residential area.

Safety and noise concerns should be stated carefully. The Council should not conclude from the attached screening documents that cryogenic tanks are categorically unsafe or that a specific code violation is certain. The more defensible finding is that the submitted materials identify plausible, site-specific questions that have not been resolved through qualified analysis. Those unresolved questions do not supply the affirmative evidence required to justify an exception from the zoning standard.

Recommended Core Determination
The applicant has not demonstrated special circumstances applicable to the property, deprivation of privileges enjoyed by property in the vicinity under an identical zoning classification, or that the requested variance would avoid granting a special privilege. Because one or more required findings cannot be made, the appeal should be denied and the Planning Commission's decision should be upheld.

Sources
• Proposed Resolution No. 2026-09-PCR-11 and the Planning Commission hearing record discussed in the memorandum.
• California Government Code Section 65906, Variances.
• Redondo Beach Municipal Code, Title 10, Chapter 2, including Sections 10-2.102 and 10-2.2510. • Planning Commission Item K1 Edited Transcript, September 17, 2026. Appendix C. • Technical Hazard Memorandum, Offsite Consequence and Heavy Gas Dispersion Analysis, September 23, 2026. Appendix A.
• Cryogenic Tank Refilling Noise Impact Assessment, September 17, 2026. Appendix B.

Note: This summary is intended to organize the evidentiary and land-use issues for public decision-making.

The City Attorney should confirm the final findings, appeal procedure, and wording of any resolution.

IMPULSE SPACE HEIGHT VARIANCE APPEAL

Page 5 ends

Appendices
Appendix A Technical Hazard Memorandum - Offsite Consequence and Heavy Gas Dispersion Analysis - 8 pages
Appendix B Cryogenic Tank Refilling Noise Impact Assessment - 4 pages Appendix C Planning Commission Item K1 Edited Transcript - September 17, 2026 - 22 pages Use of appendix materials The technical hazard memorandum and noise assessment are included as submitted screening materials. Their assumptions and conclusions should be evaluated by qualified professionals. The transcript is an edited record and should be checked against the official meeting video if wording is disputed.

Page 1 ends

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

Appendix "A"

Page 2 ends

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

COMPARATIVE ANALYSIS: AVERAGE VS. WORST-CASE PLUMES

Page 3 ends

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

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

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:

PLANNING & POLICY IMPLICATIONS

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

Page 6 ends

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

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

APPENDIX B CRYOGENIC TANK REFILLING NOISE IMPACT ASSESSMENT Consolidated document page 14

APPENDIX B CRYOGENIC TANK REFILLING NOISE IMPACT ASSESSMENT Consolidated document page 15

APPENDIX B CRYOGENIC TANK REFILLING NOISE IMPACT ASSESSMENT Consolidated document page 16

APPENDIX B CRYOGENIC TANK REFILLING NOISE IMPACT ASSESSMENT Consolidated document page 17
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 18
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 19
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 20
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 21
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 22
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 23
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 24
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 25
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 26
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 27
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 28
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 29
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 30
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 31
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 32
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 33
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 34
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 35
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 36
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 37
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 38
APPENDIX C PLANNING COMMISSION ITEM K1 EDITED TRANSCRIPT Consolidated document page 39
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. 1 Daniel Besinaiz
From: Jim Walter <[email protected]>
Sent: Sunday, October 4, 2026 3:51 PM
To: Daniel Besinaiz
Subject: No tanks on Manhattan Beach Blvd
[You don't o
en get email from [email protected]. Learn why this is important at h
ps://aka.ms/LearnAboutSenderIden&fica&on ]
CAUTION: Email is from an external source; Stop, Look, and Think before opening a achments or links.

Sent from my iPhone

MEMORANDUM
To: Redondo Beach Planning Commission; City Council; City Attorney; City Manager; Community Development Department
From: M. E. Nelson
Re: Impulse Space — Material Evidentiary Defects in Proposed Resolution No. 2026-09-PCR11 Property: 2477 Manhattan Beach Boulevard
Date: September 2026
Purpose
This memorandum identifies material factual and evidentiary defects in proposed Resolution No. 2026-09-PCR-11 concerning Impulse Space's request for a variance permitting approximately 38-foot cryogenic storage tanks where the IC-1 zoning standard limits height to 30 feet.

The Planning Commission rejected the proposed resolution by a 4-3 vote. That resolution should not subsequently be recycled as though its proposed findings represented established facts.

Several important findings drafted by staff were either contradicted by testimony in the hearing record, unsupported by an identified quantitative analysis, or dependent upon comparisons with properties governed by materially different development standards.

The issue is not whether 38-foot cryogenic tanks can safely exist somewhere. Nor is it whether Impulse Space is a desirable business. The issue is considerably narrower: whether substantial evidence supported the particular findings staff drafted to justify granting this particular variance from the 30-foot IC-1 height limitation.

The hearing record reveals substantial problems with those proposed findings.

I. STAFF ASSERTED THAT ENFORCING THE 30-FOOT
LIMIT WOULD “ELIMINATE” IMPULSE'S ABILITY
TO USE THE PROPERTY — THE APPLICANT'S OWN

TESTIMONY CONTRADICTS THAT ASSERTION
The proposed resolution states:
“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....” Staff then characterized relief from the height restriction as necessary to afford the property the same development privileges as nearby properties.

That is not a minor statement. It transforms a preferred equipment configuration into an asserted inability to continue the existing manufacturing use.

But Impulse itself did not testify that it was unable to operate without 38-foot tanks.

To the contrary, at the August 20 hearing the Commission directly asked:
“So, so it is it is feasible to do it smaller tanks. More smaller tanks.” Impulse answered:
“Yeah.”
Impulse then explained why it preferred larger tanks, including operational scale, truck deliveries, preparation and deconfiguration time. It also acknowledged that its existing operations were already using the same gases with smaller tanks.

Staff likewise acknowledged that a compliant configuration had been explored. Staff stated that the proposed tank size “really met their needs” and that Impulse considered it worthwhile to seek the variance. When a commissioner asked whether adding tanks at 30 feet or less would have avoided the variance proceeding entirely, staff answered:
“That's correct.”
The contradiction becomes still clearer when Impulse was asked what denial of the variance would mean. Impulse did not say that operations would be impossible. Instead, it expressly contemplated the possibility of obtaining “many more tanks.” Impulse stated:
“it's hard to quantify exactly what that would be.”
It then said that it would have to:
“come back and do that impact assessment.”
Thus, the hearing record distinguishes between inability to operate and a less desirable alternative configuration.

The proposed resolution erased that distinction.

The finding that enforcement of the 30-foot limit would “eliminate the ability” to use the property for the existing manufacturing facility should therefore not be reused unless new evidence establishes that proposition. The applicant's existing testimony does not establish it and materially contradicts it.

II. STAFF CHARACTERIZED THE 38-FOOT

INFRASTRUCTURE AS TECHNICALLY NECESSARY

DESPITE THE APPLICANT'S EXPRESS CONCESSION

THAT SMALLER TANKS WERE FEASIBLE
The proposed resolution further states:
“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....” This sentence contains several distinct factual propositions:

1. the particular infrastructure is “required”;

2. its technical requirements cannot be accommodated at a lesser height;

3. a lesser-height configuration necessarily produces significantly more frequent deliveries; and

4. those additional deliveries create the relevant neighborhood impact.

The first two propositions are difficult to reconcile with Impulse's testimony.

Impulse expressly agreed that smaller tanks were feasible. It was already using smaller tanks. Its explanation concerned operational consequences of using more smaller tanks—not technical impossibility.

Similarly, staff described the 38-foot tank as a size that “really met their needs”, not as the only technically feasible equipment.

Those are materially different propositions.
“Meets the applicant's needs” is not equivalent to “cannot be accommodated at a lesser height.” The proposed finding should not be reused without technical evidence demonstrating that a compliant configuration is actually infeasible.

III. THE ASSERTION OF “SIGNIFICANTLY MORE
FREQUENT DELIVERIES” WAS NOT SUPPORTED BY

AN IDENTIFIED DELIVERY ANALYSIS
Staff's proposed resolution escalated the delivery issue into a formal finding, asserting that compliant-height infrastructure would result in “significantly more frequent deliveries.” Impulse did testify that more smaller tanks would involve more trucks. It explained that connecting, priming and disconnecting delivery equipment takes time and asserted that neighborhood disruption would increase.

But the record cited here does not contain the quantitative analysis necessary to establish the magnitude asserted in the proposed resolution.

No identified calculation in these hearing transcripts establishes, for example:
 annual nitrogen and argon consumption under the expanded operation;  capacity of the proposed 38-foot vessels;
 capacity of available compliant vessels;
 tanker capacities;
 annual delivery frequency under each configuration;
 additional truck trips attributable to a compliant configuration;  duration of those additional trips;
 traffic effects;
 measured noise effects; or
 resulting quantitative effect upon the residential neighborhood.

Most importantly, when asked about the consequences of using more tanks, Impulse itself said the impact was “hard to quantify exactly” and that an “impact assessment” would have to be performed.

Staff nevertheless drafted a definitive finding concerning “significantly more frequent deliveries.”
A matter that the applicant says remains to be quantified and assessed should not simultaneously be presented as an established evidentiary finding without the missing analysis.

IV. STAFF WENT EVEN FURTHER BY ASSERTING

THAT ADDITIONAL DELIVERIES HAD THE
POTENTIAL FOR THE “GREATEST IMPACT” ON THE

RESIDENTIAL NEIGHBORHOOD
The proposed resolution does not merely assert that additional deliveries could affect neighbors.

It states that they:
“have the potential for the greatest impact on the adjacent residential neighborhood....” “Greatest” is inherently comparative.

To support that assertion, one would expect an analysis comparing the residential effects of alternative configurations, including at minimum:
38-foot tanks: visibility, massing, aesthetics, compatibility, noise, deliveries and other operational effects.
30-foot-or-less tanks: footprint, parking displacement, delivery frequency, truck size, duration, noise and other operational effects.

The hearing record instead shows residents expressly challenging staff's assumption that fewer deliveries were preferable to the visual consequences of larger tanks. One resident asked whether anyone had actually asked the neighborhood whether it preferred larger visible tanks or additional refills and requested the data supporting staff's conclusions.

Another resident specifically complained that she had seen no traffic study establishing the delivery effects.

The proposed resolution identifies no comparative study establishing that additional deliveries constitute the “greatest impact” on those residents.

Accordingly, this proposed finding should not be reused as an established fact absent the comparative evidence necessary to support it.

V. STAFF ATTEMPTED TO USE DEVELOPMENT

RIGHTS OF DIFFERENTLY ZONED PROPERTY TO
CONSTRUCT THE “PRIVILEGE” NECESSARY TO

SUPPORT THE VARIANCE
The proposed resolution itself states the applicable variance criterion:
special circumstances must exist such that strict application of zoning deprives the property of privileges enjoyed by other property in the vicinity “under identical zone designation.” Staff's proposed factual justification then moves away from that formulation.

It states that Impulse's General Plan designation allows the same industrial uses as surrounding I1 properties, that aerospace manufacturing also occurs on surrounding industrial properties, and that surrounding industrial development standards are substantially less restrictive. Staff specifically emphasizes that surrounding industrial uses are allowed heights exceeding 100 feet while the subject property is limited to 30 feet.

Staff then concludes:
“These 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 wording is significant.

The criterion recited by staff says “identical zone designation.” Staff's proposed justification relies upon “similar zoning designation,” common uses, common General Plan characteristics, and the substantially greater height permitted on surrounding industrial properties.

The same theory appeared orally.

In August, staff argued that nearby properties with similar General Plan designations and zoning contained equipment exceeding 30 feet and structures subject to height limits exceeding 100 feet, making the proposed tanks “not unusual in the area.”
By September, staff made the theory more explicit: neighboring zones allow heights up to approximately 110 feet and have the “exact same list of permitted uses.” Staff offered that circumstance as support for the required variance finding.

The proposed resolution therefore did not merely observe the surrounding industrial context.

It affirmatively attempted to use the more permissive development standards of neighboring industrial zoning to establish a development privilege for the IC-1 parcel that the IC-1 development standard itself does not provide.

At minimum, that reasoning requires careful legal scrutiny before it is reused.

VI. SIMILARITY OF USE DOES NOT, BY ITSELF,

ESTABLISH SIMILARITY OF DEVELOPMENT

ENTITLEMENT
A recurring premise in staff's proposed findings is that Impulse and surrounding industrial properties accommodate the same or similar aerospace/manufacturing uses.

The resolution repeatedly emphasizes the similarity of permitted uses.

But the very facts recited by staff demonstrate that the applicable development standards are not identical.

The Impulse parcel is subject to a 30-foot height standard.

The surrounding industrial properties invoked by staff permit heights over 100 feet.

Thus, the distinction at issue is not principally whether aerospace manufacturing is permissible.

It is whether the physical development supporting that use may exceed 30 feet on this particular parcel.

The proposed findings effectively reason:
same industrial use → comparable industrial property → comparable development privilege → justification for exceeding the applicable 30-foot limit.

That chain of reasoning should not be treated as an established fact. It is the rationale staff proposed for granting the variance, and the Planning Commission did not adopt the proposed resolution.

VII. STAFF'S “NO SPECIAL PRIVILEGE” FINDING
RELIED UPON THE SAME “SIMILAR” PROPERTY

COMPARISON
The proposed resolution separately had to find that the variance would not constitute an impermissible special privilege.

Staff drafted:
“The variance does not constitute a special privilege....” Staff then justified that conclusion by asserting that the infrastructure was common to the permitted industrial use and that the variance would not provide development rights unavailable to other:
“similarly situated properties with similar General Plan and Zoning designations.” Again, staff's operative comparison is to similar, rather than necessarily identically zoned, property.

This is especially important because the requested relief is precisely from a development standard that distinguishes the subject property from the surrounding higher-height industrial zoning.

Staff cannot simply assume away that distinction. If the relevant comparator under the applicable variance criterion must be property under the same zoning designation, then evidence concerning what differently regulated I-1 property may build does not automatically establish what constitutes a privilege enjoyed by the IC-1 parcel.

VIII. THE PROPOSED RESOLUTION DID NOT

IDENTIFY AN ADVERSE RESIDENTIAL IMPACT
CAUSED BY ENFORCING THE 38-FOOT LIMIT—
BECAUSE THERE IS NO 38-FOOT LIMIT
Another conceptual distinction should be maintained.

The applicable zoning standard is 30 feet. The applicant requested permission for approximately 38 feet.

Consequently, the burden of the variance findings concerns justification for departing from the 30-foot standard.

Staff instead repeatedly shifted the analysis toward consequences allegedly produced by requiring Impulse to adopt alternative equipment: parking displacement, additional trucks and additional filling events.

Those considerations may be relevant evidence. But they do not eliminate the need to establish the findings necessary to depart from the applicable development standard.

The hearing record also demonstrates that residential consequences of the proposed additional eight feet were raised by residents. Residents described direct visibility of the proposed tanks from homes, yards, kitchens and porches.

Yet staff's proposed findings do not contain a comparable analysis establishing that the additional eight feet would have no material land-use effect on those R-1 properties.

Instead, staff's rationale largely asks why Impulse should be required to remain at 30 feet when surrounding industrial property can develop substantially higher.

Those are different questions.

IX. THE RESOLUTION'S OWN CONDITIONS

UNDERCUT ANY SUGGESTION THAT

NEIGHBORHOOD OPERATIONAL EFFECTS HAD

ALREADY BEEN FULLY ESTABLISHED
The proposed conditions are also informative.

Staff proposed limiting liquefied-gas deliveries to normal business hours.

More significantly, staff proposed requiring Impulse after approval to provide a noise report measuring tank operations, gas delivery, filling and venting, with the possibility of additional mitigation including a solid wall along Manhattan Beach Boulevard.

Thus, at least some important operational effects on the neighboring area were to be measured and potentially mitigated after approval.

That condition should be considered when evaluating how confidently other unmeasured neighborhood impacts could properly be stated as factual findings supporting approval.

X. THE DEFECTS ARE MATERIAL BECAUSE THEY

OCCUR IN THE FINDINGS THAT WERE INTENDED

TO JUSTIFY THE VARIANCE
These statements were not incidental background language.

They appear under the proposed resolution's formal finding that the variance satisfied Redondo Beach Municipal Code §10-2.2510.

Staff relied upon them to establish:
 special circumstances;
 deprivation of development privileges;
 physical hardship;
 technical necessity;
 neighborhood consequences of a compliant alternative; and  absence of special privilege.

The evidentiary problems therefore go directly to the rationale drafted to support approval.

The proposed resolution was not adopted. Its proposed findings should not acquire factual status merely through repetition in a subsequent staff report, appeal, revised resolution, or future proceeding.

CONCLUSION
Proposed Resolution No. 2026-09-PCR-11 should not be reused as a factual template for approval without substantial revision and new supporting evidence.

Most importantly:

1. Staff asserted that enforcing the 30-foot limit would “eliminate” Impulse's ability to use the property for its existing manufacturing facility. Impulse itself conceded that smaller tanks were feasible and contemplated using additional tanks if the variance were denied.

2. Staff asserted that the infrastructure could not be accommodated at a lesser height, although Impulse expressly acknowledged the feasibility of smaller tanks.

3. Staff asserted that a compliant configuration would produce “significantly more frequent deliveries,” but the hearing record identified here contains no quantitative delivery analysis establishing the magnitude of that increase.

4. Staff asserted that those additional deliveries had the potential for the “greatest impact” on neighboring residences without identifying a comparative neighborhood-impact analysis supporting that superlative conclusion.

5. Impulse itself stated that the consequences of an alternative configuration were “hard to quantify” and that an impact assessment would have to be performed. Staff nevertheless converted those unresolved consequences into affirmative proposed findings.

6. Staff repeatedly relied upon the greater-than-100-foot development standards of surrounding industrial zoning to justify relief from the 30-foot standard applicable to the IC-1 parcel, despite reciting a variance criterion framed in terms of privileges enjoyed by property under an “identical zone designation.”

7. Staff's theory repeatedly substituted similarity of industrial use and General Plan designation for identity of zoning development standards, then characterized the resulting difference in allowable height as a “physical hardship.”

8. The proposed resolution did not establish through an identified analysis that the additional eight feet of tank height would have no visual, compatibility, property, or other land-use impact upon the adjacent R-1 neighborhood.

These are not semantic objections. They concern whether the factual predicates drafted to support the variance were actually established by the record.

If the variance is considered again, any proposed findings should identify the evidence supporting each material factual proposition and should distinguish among technical necessity, operational preference, economic convenience, parking considerations, delivery frequency, and actual physical hardship associated with the property.

Most importantly, the City should not carry forward as established facts findings that the applicant's own testimony contradicted or acknowledged had not yet been quantified.

The rejected resolution is evidence of what staff proposed that the Planning Commission find. It is not evidence that those proposed findings were true.

This version is structured so the central attack is record versus finding, rather than motive. That makes the contradictions—particularly “eliminate the ability,” “cannot be accommodated,” “significantly more frequent,” and “greatest impact”—the focus.

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.
1 Khatirah Nazif
From: Mr. Stitt <[email protected]>
Sent: Tuesday, October 6, 2026 12:34 PM
To: CityClerk
Cc: Khatirah Nazif; Daniel Besinaiz; Brad Waller
Categories: Khatirah, Emily
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello City Councilmembers,
I am a resident of District 1 and I STRONGLY OPPOSE allowing the increase of the height variance for Impulse Space. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

These tanks are planned to be installed extremely close to North Redondo residences, and are not compatible with the community. This is an extreme safety issue. This area of North Redondo is zoned for light industrial and as I understand it, this was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company will allow any company the same privilege, destroying the district 5 community and quality of life.

Thank you,
Eric Stitt
C 310.801.3449
E [email protected]
You don't often get email from [email protected]. Learn why this is important From: Anna Pirkl
To: CityClerk
Cc: Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Daniel Besinaiz; Zein Obagi; Scott Behrendt Subject: NO Cryogenic tanks!
Date: Monday, October 5, 2026 3:35:50 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello Redondo Board,
I’m a Redondo Beach resident close to the Impulse site And I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40- foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

Best Regards,
Anna Pirkl, M.A., LMFT BBS#89201, ATR, LAADAC #LR02680117 2100 N Sepulveda Blvd., Suite 27
Manhattan Beach, CA 90266
310-489-5328
The information transmitted is intended only for the person or entity for which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, or dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please delete the material from any computer and notify sender.

From: Deepti Vemuri
To: CityClerk; Daniel Besinaiz; Khatirah Nazif
Cc: Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: No Impulse Tanks in Redondo Beach
Date: Saturday, October 3, 2026 6:04:46 PM
[You don't often get email from [email protected]. 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.

Hi,
I am Deepti Vemuri
I am a resident district 5 and live close to the site. And I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

Thanks,
Deepti
From: Jim Walter
To: CityClerk
Subject: No Tanks on Manhattan Beach Blvd
Date: Sunday, October 4, 2026 3:50:10 PM
[You don't often get email from [email protected]. 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.

Sent from my iPhone

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.

From: katherine mollure
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: OPPOSE cryogenic tanks in RB
Date: Monday, October 5, 2026 8:02:10 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello,
I'm a Redondo Beach resident close to the site for the proposed tanks. I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that needs to answer, and resolutions have not been provided to the residents.

Katherine Mollure
From: hailey ogle
To: CityClerk
Cc: Scott Behrendt; Zein Obagi; Paige Kaluderovic; Chadwick B. Castle; Brad Waller; Daniel Besinaiz; Khatirah Nazif Subject: Oppose Impulse Cryogenic Tanks
Date: Sunday, October 4, 2026 8:36:07 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

City Council and Clerk,
I am writing to express my desire that you vote to deny Impulse's request for approval of special zoning for four 40-foot cryogenic tanks to be placed in the parking lot on Manhattan Beach blvd. North Redondo often gets the short end of the stick, putting us in potential chemical danger if/when those tanks fail, especially in the shadow of all the industrial and chemical disasters that have been happening here in southern California due to a system of failures, is absolutely not ok. There are houses, parks and schools across the street, there are restaurants, markets and gyms next door, and there is a freeway behind them. An approval would change the landscape, lives, and safety of residents.

I understand Redondo governemnt wants to change Redondo, they have a duty to the people to ensure that change is for the betterment of the city and benefit of the residents, an approval would do neither.

Instead it would open up North Redondo to becoming a mass industrial park as allowing the zoning change would then set president for neighboring properties to do the same. This is not what Redondo wants. I can't believe this is what you, our city council, wants for our beautiful city. I believe you want the best for our residents and our city. I believe you want to keep Redondo a beautiful beach city that people want to visit. Becoming an industrial basin with questionable safety is not it.

Again, I request Redondo Beach City Council NOT approve the request for variance for impulse.

Hailey Ogle
From: steve lurie
To: CityClerk; Daniel Besinaiz; Khatirah Nazif
Cc: Zein Obagi; Sharlene Lurie
Subject: Oppose Impulse Proposal
Date: Sunday, October 4, 2026 9:47:18 PM
Some people who received this message don't often get email from [email protected]. Learn why this is important
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hi,
My wife and I are residents in district 4 and we OPPOSE allowing the increase of the height variance. We are very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

Steve and Sharlene Lurie
From: KC
To: Zein Obagi; CityClerk; Daniel Besinaiz; Khatirah Nazif Cc: Brad Waller; Chadwick B. Castle; Paige Kaluderovic
Subject: Oppose increase if height variance
Date: Sunday, October 4, 2026 8:16:02 AM
[You don't often get email from [email protected]. 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.

Hi,
I’m a Redondo Beach resident, And I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

From: Mark Nelson (Home Gmail)
To: CityClerk
Subject: OPPOSE VARIANCE FOR IMPULSE SPACE – TALLER LIMITS DAMAGE SURROUNDING PROPERTY VALUES Date: Tuesday, October 6, 2026 2:13:56 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
************************ Mayor, Council, City Attorney, City Manager, Others: The City’s resolution to approve the variance for Impulse Space fails to capture the $38M in surrounding property damages that will be caused by the visibility of the tanks. The negative damages must be explicitly included in any analysis by the City. The current Impulse IC-1 zoned site has the same 30-foot maximum height as the abutting C-1 and R-1 areas to the east and south. The visibility of the industrial property is limited.

By allowing 38-foot tanks, the visibility of the property will be increased to property 600-feet further away. According to nearly all peer-reviewed studies, proximity of residential property to industrial development decreases residential values.

Furthermore, peer-reviewed studies also show that other things equal, the residential value damages increase with visibility of the industrial process. Using a peerreviewed CalTech study, the shift in visual proximity of 600-feet into the neighborhoods reduces property values by $38M. As a direct result of the variance allowing the protruding tanks from the buffer IC-1 land, the residential property to the south will suffer value loss. The City cannot approve the current, incorrect and incomplete Resolution to approve the Impulse variance. The variance must be denied. See details of the value destruction studies:
https://drive.google.com/file/d/1jzPcILVqpROJkgXrhxpx6bKUNkwkpoWx/view? usp=sharing https://drive.google.com/file/d/1gDd2NvSuEKjsjleYF9ld0izWgws8lDu/view?usp=sharing Thank you.

From: Emily Gee
To: CityClerk; Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt
Subject: Opposing Cryogenic Tanks - Public Comment
Date: Saturday, October 3, 2026 8:03:57 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Hello - I am a North Redondo Beach resident and I strongly oppose the allowance for the Cryogenic Tank project due to serious short and long-term environmental and human impacts.

This is a threat to the people, health, quality of life, and safety of North Redondo Beach and should be immediately opposed. The potential risks to our community and environment deserve consideration and protection before moving forward.

Thank you,
Emily
From: Charmie Huynh
To: Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt; CityClerk Cc: Daniel Besinaiz; Khatirah Nazif
Subject: Opposition to Height Variance Request for Impulse Space Cryogenic Tanks Date: Tuesday, October 6, 2026 8:23:18 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Dear City Council Members,
My name is Charmie Huynh, and I am a District 5 resident of North Redondo Beach near Anderson Park. I oppose the requested height variance for Impulse Space's proposed cryogenic tanks.

I am concerned about allowing four, and potentially more, 40-foot-tall cryogenic tanks to be installed outdoors and visible from surrounding neighborhoods, backyards, and major routes through our beach communities.

Important questions about safety, community impacts, and long-term precedent remain unanswered.

Residents continue to receive conflicting information, and these concerns should be fully addressed before any variance is considered.

These tanks are too close to residential neighborhoods and are incompatible with the purpose of this light industrial area, which was intended to serve as a buffer between industrial operations and homes.

Granting this exception would set a precedent for future industrial development and could permanently diminish the character and quality of life of District 5 neighborhoods.

I respectfully urge the City Council to deny the requested height variance and prioritize the interests of Redondo Beach residents.

Thank you for your consideration.

Sincerely,
Charmie Huynh
District 5 Resident, Redondo Beach
From: jeanne nicastro
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Opposition to Impulse Space Cryogenic Tank Height Variance Date: Saturday, October 3, 2026 7:38:43 PM
[You don't often get email from [email protected]. 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.

Hello,
I am a Redondo Beach resident writing to express my opposition to the requested height variance for the proposed cryogenic tanks at the Impulse Space site near Manhattan Beach Boulevard and Dow.

I am concerned about the proximity of these large outdoor tanks to nearby homes and the lack of clear, complete information available to residents about the materials that would be stored, the applicable safety and emergency-response plans, and the potential impact on the surrounding neighborhood.

Given the scale of the proposal and its location so close to residences, I do not believe a special height variance should be approved unless and until the City can demonstrate that the project is fully compatible with the surrounding community and that all safety, fire-response, zoning, and neighborhood-impact concerns have been thoroughly addressed in a transparent way.

I also ask the Council to consider the precedent this type of variance could set for future industrial uses in areas immediately adjacent to residential neighborhoods.

Please vote to deny the requested variance at this time.

Thank you for your consideration and for listening to residents' concerns.

Best,
Jeanne Nicastro
From: Iman Abdeshahian
To: CityClerk; Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt; Niki Ashtiani
Subject: Opposition to Impulse Space Height Variance
Date: Saturday, October 3, 2026 9:21:32 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

My name is Iman Abdeshahian, and I am writing as a local resident to express my opposition to the requested height variance for the proposed cryogenic storage tanks at the Impulse Space facility on Manhattan Beach Boulevard.

I support responsible business development and innovation in Redondo Beach, but I do not believe that development should come at the expense of the surrounding residential community or require zoning exceptions that significantly change the character of the neighborhood.

The proposed installation of four approximately 40 foot cryogenic tanks is particularly concerning given the proximity of the site to homes. Residents deserve complete transparency regarding what will be stored on the property, the quantities involved, safety and emergency response procedures, venting, deliveries, noise, setbacks, and the potential effects on neighboring properties.

The existing height restriction exists for a reason. If a facility cannot operate within the zoning requirements of the property it selected, I do not believe nearby residents should automatically be expected to accept a substantial variance to accommodate that operation.

I am also concerned about the precedent this could establish for future industrial development in this area. North Redondo Beach includes light industrial areas in very close proximity to established residential neighborhoods. Exceptions granted today can influence the character and expectations for development in this area for many years.

I respectfully ask the City Council to deny the requested height variance and encourage Impulse Space and the City to pursue an alternative solution that allows the company to operate while respecting existing zoning requirements and protecting the surrounding residential community.

Thank you for considering the concerns of residents who live near and travel through this area every day.

Sincerely,
Iman Abdeshahian
Redondo Beach Resident
From: k
To: CityClerk; Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Scott Behrendt; Zein Obagi
Subject: Please Deny Impulse Space’s Height Variance
Date: Sunday, October 4, 2026 3:31:25 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Dear Mayor and Councilmembers,
I am a District 5 resident living on Gates Avenue, and I am writing to ask you to deny Impulse Space’s appeal for a height variance at 2477 Manhattan Beach Boulevard.

I support local businesses and good jobs, and I understand that Impulse Space is an important aerospace company. But this request is not simply about allowing a business to operate in Redondo Beach. It asks the City to make a special exception to the 30-foot height limit and approve four outdoor cryogenic tanks approximately 38 feet tall, directly across from a residential neighborhood.

The City’s variance rules require special circumstances related to the property itself. Impulse knew the height limit before choosing this location. The company's preference for larger tanks, or its desire to expand operations, does not appear to be a hardship unique to this property. It is a business and equipment decision.

The information presented also contains a serious conflict. The City’s proposed findings say the larger tanks are necessary and that shorter tanks would not adequately support Impulse’s operation. However, information provided to residents states that shorter, approximately 28- foot tanks are feasible and that Impulse already uses similar tanks. The Council should not approve an eight-foot height exception while such a basic question remains unresolved.

The City’s staff report also relies heavily on nearby taller industrial properties. But those properties are not the same as this site. The proposed tanks would be located on an IC-1 property with a 30-foot height limit, directly across from homes. The fact that other properties under different zoning rules may allow taller structures does not mean this property should be treated the same way.

The proposed tanks would be outdoors, highly visible from Manhattan Beach Boulevard and nearby homes, and approximately 230 feet from the residential neighborhood. I am not suggesting that liquid nitrogen and liquid argon are the same as gasoline or rocket fuel. My concern is that bulk cryogenic storage brings additional industrial hazards, deliveries, venting, noise, and emergency-response requirements into a location immediately next to homes.

The City’s own resolution would require a noise report after approval, including noise from tank deliveries, filling, and venting. That is backwards. The Council should understand the full effect on the neighborhood before granting the variance, not approve the exception first and study the impacts afterward.

Redondo Beach can support aerospace and technology businesses without abandoning the height limit that helps protect the transition between industrial properties and nearby homes.

Granting this request would also create a precedent for other companies to argue that their preferred equipment or expansion plans justify a similar exception.

The Planning Commission denied this variance on September 17. I urge the City Council to respect that decision, deny Impulse Space’s appeal, and require the project to be redesigned to comply with the existing 30-foot limit.

Thank you for your consideration.

Sincerely,
Kara Grogan
District 5 resident
Redondo Beach, CA 90278
From: C Shih
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif
Subject: PLEASE DO NOT APPROVE THE CONSTRUCTION OF CYROGENIC TANKS Date: Sunday, October 4, 2026 5:18:40 PM
Some people who received this message don't often get email from [email protected]. Learn why this is important
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

As residents of Redondo Beach of since 1979 (47 years), our family have treasured the small town feel of the beach cities. We have witnessed the everchanging landscape of the South Bay turning into a crowded and dense urban environment. The last thing we need is more commercialization of the area and inviting further industrialization of a residential area with construction of highly risky cryogenic tanks by Impulse Space. PLEASE, PLEASE, PLEASE consider the potential negative impact on and risk to our lovely residential neighborhood.

We are against any construction of the cryogenic tanks in Redondo Beach.

Sincerely,
Christine Shih
From: Minh Nguyen
To: James Light; Scott Behrendt; Zein Obagi; Paige Kaluderovic; Chadwick B. Castle; Brad Waller Cc: CityClerk; Mike Witzansky; Joy Ford; [email protected] Subject: Please Uphold Planning Commission Denial of Impulse Space Height Variance - from the closest homeowner to the tanks
Date: Friday, October 2, 2026 10:34:49 PM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Dear Mayor and Members of the City Council,
I am writing to respectfully ask you to uphold the Planning Commission’s denial of the requested height variance for Impulse Space. I strongly support denying the height variance and allowing no increase in the permitted height of these tanks.

I am the closest residential neighbor to the proposed tanks, with my home approximately 200 feet away. I have lived in my home for 14 years, so the potential noise, safety, vibration, and quality-of-life impacts are concerns to me. They could directly affect my home and my family.

Noise is a major concern
My primary concern is the lack of an adequate noise analysis for the proposed larger tanks and associated operations.

When I obtained a City permit to install a small mini-split system serving approximately 250 square feet, I was required to obtain a decibel test to demonstrate that the equipment would not adversely affect my neighbors.

I find it difficult to understand why a homeowner installing a small residential mini-split must demonstrate compliance with noise requirements, while a much larger industrial operation proposing larger tanks has apparently not been required to conduct a comparable analysis of the potential noise impacts on the closest neighboring residence—my home, approximately 200 feet away.

Increasing the size and capacity of the tanks could potentially result in changes to refilling, servicing, truck traffic, equipment operation, engines, and other industrial activities. These activities could create recurring noise and disruption for residents living immediately next to the facility.

I believe the City should have a clear understanding of the existing and potential future noise levels before granting any height increase. A professional noise study should evaluate the tanks and associated operations and their potential impact on the closest residential properties.

Safety concerns related to the height variance
My safety concerns are directly related to the requested height variance. The issue is whether there is sufficient information to justify allowing these tanks to be taller and larger than currently permitted.

At the Planning Commission hearing, Impulse Space stated that tanks have failed twice. Concerns were also raised about whether a failure involving the pressure and size of the tanks could create conditions in which nearby people could be unable to breathe or could suffocate.

As the closest residential neighbor, with my home approximately 200 feet from the tanks, I believe the potential consequences of a failure involving larger and taller tanks should be specifically evaluated before granting the variance.

I am also concerned about the nearby Edison power towers and the fact that the tanks are within approximately one-half mile of Lincoln Elementary School and Madison Elementary School. Recent industrial incidents in Garden Grove and La Habra further reinforce the importance of understanding potential failure scenarios in a community near homes and schools.

For these reasons, I believe the City should have adequate technical information addressing these risks before approving any increase in tank height. I support the Planning Commission’s denial and no height variance.

Vibration and neighborhood impacts
I am also concerned about vibration. During Cal Water work on Manhattan Beach Blvd, I personally experienced significant vibration in my home. That experience is one reason I believe potential vibration impacts from the proposed expansion should be evaluated rather than assumed to be insignificant.

Taken together, the potential noise, truck traffic, refilling activity, vibration, and safety impacts deserve careful consideration because my home is the closest residence to the proposed tanks.

As the closest homeowner to the proposed taller tanks, I believe my concerns deserve particular consideration because I would be among the residents most immediately exposed to any consequences arising from the facility or its expansion.

I have lived in my home for 14 years. I want to be able to continue living there without having to worry that an expansion of this facility has been approved without adequately studying the potential risks and impacts on the closest neighboring residents.

Please uphold the Planning Commission’s denial and deny the Impulse Space height variance in full. I support no increase in the permitted height of these tanks.

Sincerely,
Minh Nguyen
Homeowner closest to the tanks and within 200 feet
--
Minh Nguyen :: 310 279 0702 :: [email protected] From: Shirley Howell
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: PROPOSAL TO INSTALL 40 FOOT CRYOGENIC TANKS ON MANHATTAN BEACH BLVD.

Date: Sunday, October 4, 2026 2:30:58 PM
Some people who received this message don't often get email from [email protected]. Learn why this is important
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

To ALL City Council Members:

I am a resident in District 5, and I strongly OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, 40-foot cryogenic tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

Sincerely,
Shirley Howell
Sent from my iPad
From: Ryan Cliver
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Public Comment - Impulse Space Project
Date: Sunday, October 4, 2026 9:06:21 AM
[You don't often get email from [email protected]. 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.

Hi,
I am a resident of council district 5. I live on Dufour in the neighborhood across the street from the proposed installation of four 40-foot cryogenic tanks at Impulse Space. From what I understand there is a vote coming up to approve this. I OPPOSE allowing the increase of the height variance. I am very concerned about the city allowing four, or possibly more, tanks to be installed outside, visible to neighborhoods, families’ backyards and all commuters coming to the beach cities. There are still many unanswered concerns, misinformation and inconsistencies from the city and Impulse that need to be answered, and resolutions have not been provided to the residents.

These tanks are too close to residences, and are not compatible with the community. Let’s prevent another residential catastrophe like the Lineage fire or the GKN leak. The light industrial area was created as a buffer to separate the larger industrial businesses from being too close to homes. Any special privileges granted to one company through spot zoning will allow any company the same privilege, destroying the district 5 community and quality of life. Please vote to protect the residents and the residential buffer zone that your predecessors put in place to preserve the well being and safety of our community.

Thank you for your time today,
Ryan Cliver
From: Bonnie Langner
To: CityClerk
Cc: Daniel Besinaiz; Khatirah Nazif; Brad Waller; Chadwick B. Castle; Paige Kaluderovic; Zein Obagi; Scott Behrendt Subject: Public Comment – Item L.1 / Impulse Space Appeal Date: Tuesday, October 6, 2026 6:52:03 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Dear Mayor and Members of the City Council,
I am a Redondo Beach homeowner who lives directly across from the Impulse Space facility, and I am writing regarding Item L.1 and the requested height variance for the proposed cryogenic storage tanks.

Because my home is immediately adjacent to this industrial area, I am concerned about approving a variance for four approximately 38-foot tanks before the questions raised by nearby residents have been fully addressed.

My concerns include the visual impact from our homes, noise and venting, tanker deliveries and operating hours, emergency response procedures, appropriate setbacks and screening, and the overall compatibility of an industrial installation of this scale immediately adjacent to a residential neighborhood.

I understand that aerospace manufacturing is a permitted use in this industrial zone. However, the City's zoning standards also recognize the importance of compatibility with surrounding areas and minimizing impacts on adjacent residential neighborhoods. That makes the request for an exception to the existing 30-foot height limit particularly important to those of us who live directly across the street.

The Planning Commission considered this variance and voted to deny it. Before that decision is overturned, I believe the questions and concerns raised by the neighboring residents deserve clear answers.

I respectfully ask the City Council to carefully consider whether granting this variance is appropriate given the proximity to our homes and whether sufficient protections are in place for the neighboring residential community.

Thank you for considering the perspective of those of us who live directly across from this facility.

Sincerely,
Bonnie Langner
Redondo Beach Resident
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 8:01:47 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 Cryogenic Tank Emergency Planning (Case No. 2026-0595)
To: [email protected] <[email protected]>
Cc: [email protected] <[email protected]>, Mario Tresierras <[email protected]>, Mauricio Nunez Florez <[email protected]>
Good afternoon, Mr. Nelson.

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

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

Reminder: Potentially hazardous physical situation that does not have any reported HAZMAT/HHMD Review. Basic mass transfer equations have a significant rupture of a 12,000 gallon tank of LAR rolling into the neighborhood. Residents deserve to know the plan and the City of RB/RBFD is pointing squarely at LA County Fire. Please advise. We are sending a certified communication since time is wasting before the next Redondo Beach permitting meeting.
---------- Forwarded message ---------
From: Mark Nelson (Home Gmail) <[email protected]>
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 <[email protected]>
@redondo.org; [email protected]; [email protected]; [email protected] rg; [email protected]; Mark N <[email protected]> Subject: Fwd: Subject: 2477 Manhattan Beach Blvd. — Request for HHMD Review of Cryogenic Tank Emergency Planning (Case No. 2026-0595)
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 10:11:28 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.

From: Nick Biro
To: Scott Behrendt; Zein Obagi; Paige Kaluderovic; Chadwick B. Castle; Brad Waller Cc: Mike Witzansky; Joy Ford; CityClerk; James Light; Marc Wiener; Garth Meyer; Roxanne Ferebee; Minh Nguyen; Katherine; Mark Nelson (Home Gmail)
Subject: Public Comment - Resolution No. CC-2610-083 — 2477 Manhattan Beach Boulevard Date: Saturday, October 3, 2026 10:58:22 AM
Attachments: Cryogenic_Tank_Refilling_Noise_Impact_Assessment.pdf Impulse_Appeal_Testimony_Inconsistency_Review.pdf
Some people who received this message don't often get email from [email protected]. Learn why this is important
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

Dear City Council,
Thank you for your time to review the information below and attached on this important matter.

The applicant's appeal partially responds to the Planning Commission by describing the proposed tanks as standard equipment, identifying some site constraints, and asserting that smaller or custom tanks would create delay, more deliveries, and added operational risk.

Those assertions explain why Impulse Space prefers the 38-foot configuration. They do not cure the deficiencies that led to denial.

The appeal still does not establish the findings required by Redondo Beach Municipal Code section 10-2.2510 and California Government Code section 65906. It does not demonstrate that a physical circumstance of this IC-1 parcel makes compliance with the 30-foot height limit infeasible, identify a comparable privilege enjoyed by property under an identical IC-1 zoning designation, or show that the additional height would be compatible with the adjacent residential neighborhood. The City Council therefore has a sound basis to deny the appeal and uphold the Planning Commission's decision through clearer and more complete findings.

The appeal addresses several subjects raised during the hearings, but it does not supply the evidence needed to make the mandatory variance findings. The proposed approval resolution adds some operating conditions, yet those conditions regulate future construction and operations; they do not establish the threshold land-use entitlement.

The appeal explains the applicant's preference for the proposed tanks but does not establish special circumstances applicable to the IC-1 property, deprivation of privileges enjoyed by nearby property under an identical zoning designation, or that the requested exception would avoid granting a special privilege. It also does not rebut the Planning Commission's finding that the additional height is incompatible with the adjacent residential neighborhood.

Because the City cannot make all mandatory findings from the present record, the Council should deny the appeal and uphold the denial of the height variance.

Controlling Variance Standard
A variance may be granted only when special circumstances applicable to the property, including its size, shape, topography, location, or surroundings, cause strict application of the zoning rules to deprive the property of privileges enjoyed by other property in the vicinity under an identical zone designation. Any variance must also avoid granting a special privilege and must not conflict with the Comprehensive General Plan. All required findings must be supportable from the record.

The controlling comparison is therefore not whether nearby I-1 properties conduct similar aerospace operations. The required comparison is whether this IC-1 parcel is denied a privilege enjoyed by other nearby property under the same IC-1 zoning standards.

Applicant position Assessment
The 38-foot tanks are standard
industrial equipment selected for
technical, operational, and regulatory
reasons.

The appeal provides no manufacturer
declaration, specification sheet, engineering
certification, or code citation establishing that
38 feet is required. A preference for
standardized equipment is not itself a
physical hardship affecting the parcel.

A custom 30-foot tank would fall
outside the manufacturer's
recommendations and may require a
lead time of at least one year.

No vendor correspondence, quotation,
fabrication analysis, lead-time documentation,
or safety comparison is included. The appeal
identifies a custom 30-foot tank as an
alternative but characterizes it as
burdensome; it does not document that every
code-compliant alternative is infeasible.

Smaller tanks would require more
refueling cycles, truck trips, noise, and
parking impacts.

The record contains no quantified comparison
of storage capacity, consumption, delivery
frequency, truck duration, noise exposure, or
parking demand. The assertion may be
plausible, but it is not a documented variance
finding.

The proposed location is the only
available location because of a rear fire
lane and adjoining development.

This may explain the preferred location, but it
does not show why the tanks at that location
must exceed 30 feet. No dimensioned
alternatives analysis demonstrates that
compliant tanks, a different number of tanks,
or another arrangement cannot function on
the 4.43-acre site.

Nearby industrial properties contain
much taller cryogenic tanks and
conduct the same authorized use.

The cited properties are principally I-1, not IC1. Similar operations do not satisfy the Code's requirement for a privilege enjoyed under an
identical zone designation. The appeal also
inconsistently labels the subject property IC-3
or I-3, while the staff report and both
resolutions identify it as IC-1.

Future Building, Fire Department, and
CUPA review will ensure safe
installation and operation.

Those reviews address compliance with
building, fire, and hazardous-material
requirements after land-use approval. They
do not establish special circumstances,
identical-zone deprivation, absence of special
privilege, or neighborhood compatibility.

Analysis of the Required Findings

1. No property-based special circumstance has been established The appeal describes constraints created by existing site circulation, a fire lane, adjoining development, and the selected equipment. It does not show that the parcel's size, shape, topography, location, or surroundings require tanks taller than 30 feet. A site constraint must be tied to the requested height exception, not merely to the preferred location or operating plan.

2. No deprivation relative to identically zoned property has been shown The staff report and appeal rely on nearby I-1 properties that permit much greater height. Section 10-2.2510 requires evidence of a privilege enjoyed by property under an identical zone designation. Neither document identifies a comparable IC-1 parcel with a similar height entitlement or explains why the 30-foot standard operates uniquely against this parcel.

3. The special privilege concern remains
Granting relief because neighboring I-1 properties allow taller industrial structures would import I-1 development rights into an IC-1 parcel without a zoning amendment. Without evidence that similarly situated IC-1 properties receive comparable height relief, the variance risks granting this applicant a privilege unavailable to other IC-1 properties.

4. The appeal does not rebut the adopted compatibility finding The Planning Commission found that the additional height is incompatible with adjacent residential properties and does not minimize impacts on the residential zone. The appeal discusses industry practice, economic development, and code compliance, but it does not provide a residential-view analysis, verified sight lines, visual simulations, screening analysis, or an evaluation of the additional eight feet of industrial scale and prominence.

5. Operational burden has not been converted into technical necessity The appeal says compliant alternatives would be customized, delayed, noisier, or less efficient. Those considerations may be relevant to business planning, but the record does not quantify them or show that they arise from a unique characteristic of the land.

The appeal's conclusion that no feasible alternative exists is broader than the evidence supplied.

6. General Plan economic policies do not eliminate compatibility policies Business retention and support for the North Redondo Tech District are legitimate General Plan considerations. They do not by themselves establish a variance. The appeal does not reconcile those policies with the Planning Commission's finding that the added height conflicts with residential compatibility and the IC zone's purpose of minimizing impacts on adjoining residential areas.

Weaknesses in the Staff Recommendation
Staff states that enforcing the 30-foot limit would eliminate the owner's ability to use the property for aerospace manufacturing. The record establishes that aerospace manufacturing is a permitted use and that the variance concerns one proposed equipment configuration. The appeal discusses alternatives that it considers burdensome; it does not demonstrate that denial eliminates all reasonable aerospace manufacturing use of the 250,600-square-foot facility.

Staff treats different development standards on neighboring I-1 land as the special circumstance. The zoning distinction is the rule being applied, not a parcel-specific physical condition. It also does not satisfy the required comparison with property under an identical zoning designation.

Staff repeats the applicant's claims about customized tanks, safety history, deliveries, and parking without supporting manufacturer documentation, calculations, or a comparative alternatives study.

The report characterizes most Planning Commission discussion as safetyrelated and outside the variance. The adopted denial resolution, however, rests on height compatibility, special privilege, and General Plan impacts to the adjacent residential district. Those are land-use findings directly relevant to the variance.

The staff recommendation gives economic policies controlling weight but does not provide an equivalent analysis of the additional height's visual and neighborhood effects.

Deficiencies in the Proposed Approval Resolution
The proposed conditions improve the earlier draft by adding vent silencers, a noise report, delivery limits, emergency information, operating procedures, and a site map. These measures do not cure the entitlement findings, and several remain too indefinite or are deferred until after approval.

Condition What it requires Remaining issue
10 Possible mitigation after a
measured noise violation
Reactive only. It sets no pre-operation
acoustical standard, study protocol,
monitoring location, deadline, or
automatic corrective action.
20 Silencers on cryogenic
venting valves
No performance rating, maintenance
verification, or testing standard is
specified.
21 Deliveries during normal
business hours with limited
off-hour deliveries approved
administratively
Normal business hours and very
limited are undefined. No fixed hours,
frequency cap, notice requirement, or
emergency-only standard is stated.
22 A noise report covering
delivery, filling, and venting
The resolution does not require the
report before permit issuance or
operation, identify a qualified preparer
or City review standard, or require
mitigation before violations occur.
11 through
19 Code compliance, vehicleimpact protection, signage, security, procedures,
emergency contact, and site
map
These are useful operating safeguards,
but most restate later permitting
obligations. They do not independently
verify the site-specific hazard analysis
or establish the variance findings.

Conditions may reduce impacts after a variance is lawfully supported. They cannot substitute for proof that this parcel has a qualifying hardship or that the variance does not grant a special privilege.

Recommended City Council Action
The Council should deny the appeal and uphold the Planning Commission's decision based on independent, complete findings made after the de novo hearing. The Council need not find that cryogenic tanks are categorically unsafe. The stronger and more defensible basis is that the applicant has not supplied substantial evidence for each mandatory variance finding and has not rebutted the adopted height-compatibility concerns.

Find that the property's size, shape, topography, location, and surroundings do not create a demonstrated need to exceed the 30-foot height limit.

Find that no evidence identifies a privilege enjoyed by nearby property under the identical IC-1 zoning designation that is denied to this parcel.

Find that reliance on I-1 height standards and similar industrial uses does not satisfy the identical-zone requirement and would risk granting a special privilege.

Find that the appeal does not adequately address the effect of the additional eight feet on the scale, visibility, and compatibility of the installation next to the residential neighborhood.

Find that assertions concerning standard equipment, lead time, delivery frequency, parking, noise, and safety are not supported by a documented manufacturer and engineering alternatives analysis.

Find that later building and fire-code review, while necessary, does not establish the land-use findings required before granting the variance.

Suggested Council Direction
Deny the appeal and direct staff and the City Attorney to return with a revised denial resolution that clearly states each negative variance finding and cites the supporting evidence. The revised resolution should correct the ambiguity in the Planning Commission resolution, which recites the positive wording of the specialcircumstances criterion before stating incompatibility, and should expressly address the absence of an identical-zone comparison.

Alternative if the Council Is Not Prepared to Deny
The Council should continue the matter rather than grant the appeal on the present record. Before reconsideration, require a final dimensioned site plan and alternatives matrix; manufacturer and engineering documentation for compliant tank configurations; quantified delivery, parking, and noise comparisons; verified residential sight-line and screening analysis; an independently reviewed site-specific safety analysis; and enforceable delivery and operating hours. The studies and required mitigation should be completed before approval, not deferred until after installation or a violation.

Sources Reviewed
City of Redondo Beach Administrative Report, File 26-1233, City Council meeting of October 6, 2026, pages 1 through 6.

Impulse Space Appeal Application and Appeal Justification, pages 1 through 5 of the justification, included as Attachment 1.

Planning Commission Resolution No. 2026-09-PCR-11, adopted September 17, 2026, pages 1 through 3.

Proposed City Council Resolution No. CC-2610-083, pages 1 through 8, including conditions 1 through 22.

Summary Supporting Denial of the Impulse Space Height Variance Appeal, dated September 22, 2026, used as the prior executive summary and corrected where the new appeal record required clarification.

Redondo Beach Municipal Code section 10-2.2510 governing variances and appeals.

California Government Code section 65906 governing zoning variances and special privileges.

Note This summary organizes the record for public participation and decision-making. The City Attorney should confirm the final findings, procedural posture, and wording of any resolution.

Encl/2
Cryogenic_Tank_Refilling_Noise_Impact.pdf
Impulse_Appeal_Testimony_Inconsistencies.PDF
Nicholas Biro
2423 Sebald Ave.

Redondo Beach, CA 90278
less than 200' from a new horizontal tank install at Impulse and under 400' from four 38' proposed tanks.

From: alicia evans
To: Sean Scully; Joy Ford; CityClerk
Subject: PUBLIC COMMENT - THE CITY MUST DENY THE IMPULSE SPACE 38-FOOT HEIGHT VARIANCE Date: Sunday, September 20, 2026 7:42:40 AM
Some people who received this message don't often get email from [email protected]. Learn why this is important
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

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
From: Mark Nelson (Home Gmail)
To: CityClerk; Joy Ford; Mike Witzansky; Marc Wiener; Sean Scully; Paige Kaluderovic; Brad Waller; Chadwick B.

Castle; Garth Meyer; Scott Behrendt; Zein Obagi; James Light; Nick Biro Subject: Public Comment - The Revised Impulse Resolution Lacks Truthful, Supported Justifications and the Council Cannot Approve It As-Is
Date: Friday, October 2, 2026 4:51:29 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

PUBLIC COMMENT — IMPULSE SPACE VARIANCE
Resolution No. CC-2610-083 — 2477 Manhattan Beach Boulevard The revised resolution does not merely draw conclusions. It introduces new factual assertions that appear inconsistent with the record developed before the Planning Commission. Before adopting these findings, the City Council should require Staff to identify the evidence supporting them.

The resolution now states that strict compliance with the 30-foot IC-1 height limit would “eliminate the ability of the property owner to use the property for aerospace manufacturing purposes.”
Where is the evidence for that extraordinary assertion? At the Planning Commission, Staff said something materially different: the proposed tank size “really met their needs and they felt like it was worthwhile to apply for the variance.” Staff also confirmed that 30-foot-or-shorter tanks would not require the variance and that additional shorter tanks were a possible alternative.
“Meets their needs” is not “cannot operate without it.” The revised resolution goes further. It states:
“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.”
That sentence contains three separate factual claims:

1. A lesser-height installation requires custom tanks.

2. Those tanks have an inferior safety record.

3. They would require more frequent deliveries.

Where is the supporting evidence?
The record reviewed to date contains no engineering alternatives analysis establishing that commercially available compliant tanks cannot perform the required function; no comparative safety data establishing that a compliant tank has a poorer safety record; and no calculation comparing annual consumption, tank capacities, tanker capacity, and resulting delivery frequency.

These are not minor details. They are being offered as facts supporting the legal findings necessary to grant a variance.

The resolution also relies repeatedly on surrounding industrial properties whose zoning permits heights exceeding 100 feet. But the statutory finding concerns privileges enjoyed by properties “in the vicinity and under identical zone designation.” The record reviewed before the Planning Commission identified no IC-1 property with the same 30-foot limitation that has been granted the asserted height privilege.

The distinction matters. The 30-foot limit is the development standard the City itself placed on this IC-1 property. The existence of a different height limit in a different zoning district does not, by itself, establish a special circumstance of this property.

Finally, the City has identified no quantitative analysis comparing the asserted effects of additional deliveries against the effects imposed on the adjacent residential neighborhood by allowing industrial equipment to exceed the 30-foot limit. The record contains no identified viewshed analysis, property-value analysis, quantified visual-impact analysis, or comparative neighborhood-impact analysis.

The Council should therefore ask Staff a very simple question before voting:

For each of these new factual assertions, identify the document, analysis, calculation, testimony, or other substantial evidence in the record that establishes it.

If that evidence exists, put it on the record.

If it does not exist, these assertions should not be converted into findings merely by placing them in a resolution.

A variance finding should follow the evidence. The evidence should not be created by the finding.

From: Mark Nelson (Home Gmail)
To: CityClerk; Joy Ford; Mike Witzansky; Marc Wiener; Sean Scully; Paige Kaluderovic; Brad Waller; Chadwick B.

Castle; Garth Meyer; Scott Behrendt; Zein Obagi; James Light Subject: Public Comment and Public Records Request - Impulse Health Variance Resolution Date: Friday, October 2, 2026 2:28:24 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

CPRA Request:

Pre-engineered shorter tanks are CURRENTLY IN USE according to the SWORN Testimony of Impulse executives, and the statements of City Staff. #1 Provide documents demonstrating the custom engineering requirement of other tanks from the Impulse Space LAR and LIN supplier.
#2 Provide documents that custom engineered tanks will inherently be less safe -that assertion is flatly false.

No evidence exists that more frequent deliveries would have any impacts, and certainly not significant impacts.
#3 Provide documents demonstrating the impacts of deliveries from 38-ft tanks vs the impacts from shorter tanks on public health and safety
Public Comment:

Pre-engineered shorter tanks are CURRENTLY IN USE according to the SWORN Testimony of Impulse executives, and the statements of City Staff.

No evidence exists that more frequent deliveries would have any impacts, and certainly not significant impacts.

From: Mark Nelson (Home Gmail)
To: CityClerk; Laura Diaz
Cc: Scott Behrendt; Brad Waller; Paige Kaluderovic; Sean Scully; Mike Witzansky; Chadwick B. Castle; Zein Obagi; Roxanne Ferebee; Minh Nguyen; Katherine; Nick Biro Subject: Public Comment Impulse - Tank Installation at 2425 MBB on 9/26/26 Date: Saturday, October 3, 2026 5:35:38 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

The resolution now states that strict compliance with the 30-foot IC-1 height limit would “eliminate the ability of the property owner to use the property for aerospace manufacturing purposes.” Where is the evidence for that extraordinary assertion? At the Planning Commission, Staff said something materially different: the proposed tank size “really met their needs and they felt like it was worthwhile to apply for the variance.” Staff also confirmed that 30-foot-or-shorter tanks would not require the variance and that additional shorter tanks were a possible alternative. “Meets their needs” is not “cannot operate without it.” The revised resolution goes even further. It states:
“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.” That sentence contains three separate factual claims:

1. A lesser-height installation requires custom tanks. - UNTRUE - STANDARD CRYO TANKS COME IN 28 and 38-foot in the same "series".

2. Those tanks have an inferior safety record. - Meaningless - custom tanks not required

3. They would require more frequent deliveries - No demonstration of signficance Where is the supporting evidence?
The record reviewed to date contains no engineering alternatives analysis establishing that commercially available compliant tanks cannot perform the required function; no comparative safety data establishing that a compliant tank has a poorer safety record; and no calculation comparing annual consumption, tank capacities, tanker capacity, and resulting delivery frequency.

These are not minor details. They are being offered as facts supporting the legal findings necessary to grant a variance.

The Council should therefore ask Staff a very simple question before voting:

For each of these new factual assertions, identify the document, analysis, calculation, testimony, or other substantial evidence in the record that establishes it.

If that evidence exists, put it on the record.

If it does not exist, these assertions should not be converted into findings merely by placing them in a resolution.

A variance finding should follow the evidence. The evidence should not be created by the finding.

On Sat, Oct 3, 2026 at 5:04 PM Mark Nelson (Home Gmail) <[email protected]> wrote:

Provide documents for required permitting to set the tanks at Impulse referred to in the memo. At a minimum, they should have electrical, plumbing and seismic wetstamps. The documents should be provided in advance of the 10/6/26 City Council de novo hearing of Impulse.

On Sat, Sep 26, 2026 at 11:47 AM Nick Biro <[email protected]> wrote:

Additional tank installation is taking place at Impulse today. This looks to be less than 30' tall at 2425 MBB.

Perhaps this answers the issues of incompleteness with the safety plan and site plan as other locations were needed. The 38' variance request is solely at 2477 MBB and there are more than 4 tanks in total at the facility. It's obvious now that smaller tanks work, and a variance is not needed. There is no need to grant a variance request solely on convenience.

We really need safeguards on what is happening and how future refueling operations will impact our homes.

We really need some transparency in this matter.

Thanks
Nick
2423 Sebald Ave.

Redondo Beach, CA 90278
less than 250' from the tanks now...

From: [email protected] <[email protected]> Sent: Saturday, September 26, 2026 11:30 AM
To: Nick Biro <[email protected]>
Subject: Impulse
Sent from my iPhone
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 3:02:24 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
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 9:12:46 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.

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 12:15:51 PM
CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

5. Viewshed effects and house prices: Identifying the visibility value of the natural landscape
Authors: Authors as listed by publisher
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.