1 David Yakobson
From: Alan Levenson <[email protected]>
Sent: Monday, November 17, 2025 2:30 PM
To: councilmtgitems
Cc: Oliver Chi; Lana Negrete; Caroline Torosis; Dan Hall; Barry Snell; Jesse Zwick; Natalya Zernitskaya; Ellis Raskin; Andrew Wilder; [email protected]; Diane Reynolds; Geoffrey Neri; Margaret Griffin
Subject: item # 4B Fuel Tank Removal
EXTERNAL
Dear Mayor, Council Members, City Manager, and Airport Commissioners First, I want to acknowledge that the removal of the aging underground fuel tanks is an important and positive step.
Community members have raised concerns about their condition and safety for many years, and I appreciate that the State Water Resources Control Board has ordered their removal. This is long overdue and necessary.
As the City moves forward, I respectfully request transparency and public process regarding what will replace the existing tanks. The selection of a new fuel-storage and dispensing system is not ministerial. It is a discretionary decision, and different choices have different operational, environmental, and community impacts.
From what is publicly known, the City will need to evaluate whether to implement above-ground fuel tanks or a truck-to-truck fueling system. Each option requires coordination with the Fire Marshal and Public Works, and each carries different implications for emissions, soil disturbance, truck traffic, and neighborhood exposure. While truckto-truck transfers may function as a temporary bridge solution, they are not typically used as a long-term fueling method at airports of this size, especially under a remediation mandate. And whichever option is selected will likely remain in place for several years.
The City’s own Minimum Standards (2018) make clear that the replacement fueling system is a discretionary choice. Under these standards, a fuel farm may only be installed by an FBO with advance written approval of the Airport Director, and in some cases City Council authorization is required. If an FBO wishes to build its own fuel farm, it must lease the land, construct above-ground tanks, and meet all environmental and spill-containment requirements. The Minimum Standards also state that fuel-delivery trucks may not be used as long-term storage facilities, meaning a sustained truck-to-truck system would require an affirmative approval or a modification of the standards.
It is also important to note that neither FAA regulations nor the 2017 Consent Decree require the City, as airport sponsor, to provide fuel tanks or construct a fuel farm for Atlantic Aviation or any FBO. FAA rules require that aeronautical services be available on reasonable terms, but they do not obligate the City to supply or install fuelstorage infrastructure. This gives Santa Monica full discretion to evaluate options through a community-informed and environmentally sound process, rather than assuming any particular facility is federally required.
Because the choice of a replacement fueling system is discretionary, CEQA applies. Under CEQA, the removal of the existing tanks and the selection and implementation of a new fueling method together constitute a single project and should not be piecemealed into separate actions to avoid or minimize environmental review. Fueling infrastructure decisions affect hazardous materials handling, traffic, noise, air quality, soil disturbance, and public safety — exactly the types of impacts CEQA was designed to evaluate.
To be clear, I am not asking for any delay in the removal of the old tanks. That work is mandated by the State and should proceed. I am only asking that the subsequent decisions about the fueling system not be made internally or treated as predetermined without public process and the appropriate environmental review.
Item 4-B
November 18, 2025
Item 4-B
November 18, 2025
2 By placing this on the record now, the City can help ensure clarity, accountability, and community trust as this transition moves forward.
Thank you for your attention and for your work on this issue.
Alan Levenson
Founder NoJets
Resident of Sunset Park
Item 4-B
November 18, 2025
Item 4-B
November 18, 2025