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Public Comment - Agenda Item 10B

Torrance City Council
January 14, 2025

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Public Comment - Agenda Item 10B
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January 14, 2025
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Torrance City Council
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10. ADMINISTRATIVE MATTERS
10B.Community Development – Discuss and Consider Amendment to the Torrance Municipal Airport Ordinance, Determine California Environmental Quality Act (CEQA) Exemption, and Adopt an ORDINANCE Amending the Torrance Municipal Code as Related to Enforcement of the Airport Ordinance. Expenditure: None.

Name
City of Torrance
Agenda Team
Comment ­ 01/13/2025 05:36 PM : (No Vote)
The following emails were received by [email protected]. Thank you.

PUBLIC COMMENT FOR ITEM 10B
AS OF 01/13/25
From: Jim Gates <
Sent: Friday, January 10, 2025 11:39 AM
To: Poirier, Rebecca <
Subject: Public comment on agenda Item 10B 1/14/2024 Council meeting

--
Jim Gates

TO: Torrance City Council
(via "OneMeeting" link and e-mail to
DATE: 1/1012025
SUBJECT: Public Comment: Issues with the Airport Noise Hearing Board FROM: Jim Gates
COPIES TO: Airport Commission

Hon Mayor Chen and Members of the City Council:

There are serious issues with the Airport Noise Hearing Board for the reasons noted below. 1) Pending litigation:

Federal litigation in two cases are currently pending that challenges the City's unsupported position that Torrance Municipal Code ("TMC") Sections 51.2.3e and 51.5.5 through 51.5.7 are valid, enforceable and not preempted by the Federal Aviation Administration's (“FAA”) exclusive authority to regulate aviation safety and the efficient use of the airspace by aircraft in the U S. Any City actions involving these sections of the TMC must be deferred until resolution of this litigation is complete.

2) No authority:

Substantial air safety issues are implicated when state or local governments attempt to regulate the operation of aircraft. The general balance between Federal and state or municipal authority in the context of aviation regulation is well established. The FAA has the exclusive authority to regulate aviation safety and the efficient use of the airspace by aircraft. Attempts by state and local governments to regulate in those fields are preempted. Courts across the country have confirmed that the FAA has exclusive jurisdiction over matters involving aviation safety. A small sampling of these court rulings is contained in the attachment.

3) Preemption:

A state or local law dealing with aviation will be preempted if it conflicts with FAA regulations. Such laws are preempted if, as with the TMC Sections 51.2.3e and 51.5.5 through 51.5.7, it makes compliance with FAA regulations impossible or frustrates the purposes and objectives of such regulations. These ordinances conflict with FAA's exclusive authority involving takeoffs, landings, touch and go’s, stop and go’s, and low approaches.

4) Wrong purpose:

These hearings are purportedly being held “as provided in TMC Section 51.7." However, that section, by its plain text, applies only to persons charged with causing an aircraft to exceed the sound limits set forth in Section 46.8.8, or 46.8.9. It does not address TMC Sections 51.2.3e, 51.5.5, 51.5.6, or 51.5.7 at all, nor do those sections reference an Administrative Hearing Board.

5) No judicial review:

The entire Hearing Board scheme, which provides for an appeal only to the City Council, is impermissible under the California Constitution, as it does not allow for judicial review.

This violates the separation of powers contemplated by the California Constitution, as well as the judicial powers clause. The City is effectively the policeman, investigator, prosecutor, judge, jury and executioner.

6) Lack of impartiality:

There are serious questions concerning the impartiality of the composition of the Administrative Hearing Board, which is also required under California law.

Any hearings must be cancelled or, at the very minimum, delayed pending resolution of the outstanding litigation and of the other issues noted above. Previous communications noting many of these issues have been ignored.

ATTACHEMENT

A sample of court decisions confirming FAA has exclusive authority over matters involving aviation safety

The Supremacy Clause:

The Supremacy Clause of the Constitution of the United States (Article VI, Clause 2) establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "Supreme Law of the Land", and thus take priority over any conflicting state or local laws.

Preemption Doctrine:

The Preemption Doctrine is based on the Supremacy Clause of the U.S. Constitution. It holds that certain matters are of such a national (as opposed to local) character that federal laws preempt or take precedence over state or local laws. As such, a state or local government may not pass a law inconsistent with the federal law. A state or local law may be struck down, even when it does not explicitly conflict with federal law, if a court finds that Congress has legitimately occupied the field with federal legislation. Congress has long vested the FAA with exclusive authority to regulate airspace use and air traffic control. In simple terms, this means that ordinances passed by state and local governments that attempt to do so are invalid and unenforceable.

 Local governments cannot regulate control of aircraft or airspace, or any aspect of aviation navigation. City of Burbank v. Burbank-Glendale-Pasadena Airport Authority, 72 Cal. App. 4th 366, 85 Cal. Rptr. 2d 28 (2d Dist. 1999).  Limitations on aircraft taking off and use of the airport runway involve air safety, which is field preempted by the Federal Aviation Act. Restrictions that conflict with the Federal Aviation Act or sufficiently interfere with federal regulation of air safety are preempted.

Tweed-New Haven Airport Authority v. Tong, 930 F.3d 65 (2d Cir. 2019). •  Municipal ordinances cannot prohibit flights of aircraft at altitudes (i.e. low approaches, missed approaches). Only the federal government has the right to regulate safe altitudes of flight at any elevation and take-off and landing patterns. Allegheny Airlines v. Village of Cedarhurst, 238 F.2d 812, 17 Pub. Util. Rep. 3d (PUR) 244 (2d Cir. 1956).  An airport cannot restrict the number of planes flying, as it constitutes an attempt to regulate air navigation which is exclusively within the jurisdiction of the federal government. Gary Leasing, Inc. v. Town Bd. of Town of Pendleton, 127 Misc. 2d 194, 485 N.Y.S.2d 693 (Sup 1985).
 Aviation commerce and safety are governed by pervasive federal regulations, and applicable local standards are field preempted. The Federal government, not city, controls the airspace above city limits. Noise regulation ordinances, flight-pattern controls, restrictions on operations, air safety regulations, and pilot drug-testing provisions are all impliedly preempted by the Federal Aviation Act (FAA). International Aerobatics Club Chapter 1 v. City of Morris, 76 F. Supp. 3d 767 (N.D. Ill. 2014).

 In May of 2015, the Torrance City Attorney stated: "Congress has tasked the Secretary of Transportation, via the FAA, with the task of "assigning, maintaining, and enhancing safety and security as the highest priorities in air commerce," as well as "controlling the use of the navigable airspace and regulating civil and military operations in that airspace in the interest of the safety and efficiency of both of those operations." (49 U.S.C. 44718, subd. (d).) The United States Court of Appeals for the Ninth Circuit recognizes that, "federal law occupies the entire field of aviation safety." Montalvo v. Spirit Airlines (9th Cir. 2007) 508 F.3d 464,473.)
 California state courts note that the Ninth Circuit's position is consistent with the positions taken by the Second, Third, Sixth and Tenth Circuits. {Citizens Opposing a Dangerous Env't v. Cnty. Of Kern 2014) 228 Cal.App.4th 360, 364 [noting that the aforementioned Circuits of the Federal Court of Appeals have concluded that Congress intended to occupy the entire field of aviation safety).

From: Winston Abdul <
Sent: Saturday, January 11, 2025 1:18 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance.

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From: Danrihn <
Sent: Saturday, January 11, 2025 1:20 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance.

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-----Original Message-----
From: Ammar Pasta <
Sent: Saturday, January 11, 2025 1:28 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

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Please vote against approval of this Ordinance.

From: Don T <
Sent: Saturday, January 11, 2025 4:21 PM
To: CityCouncil <
Subject: Support for Stronger Enforcement and a Better Future for Torrance

Dear City Council Members,

Thank you for your ongoing efforts to address the impact of pilots and flight schools on our community by holding them accountable for their behavior. Your commitment to enforcing existing ordinances is vital to ensuring a livable environment for residents.

However, without consistent enforcement, flight schools and pilots will continue to disregard the rules, as they did until 10 p.m. nightly in 2020, when the absence of noise monitoring left residents vulnerable to their actions. Strong enforcement is necessary to prevent history from repeating itself.

I urge the City to take a bold step forward and eliminate the liability that Torrance Airport has become. Replacing it with a development that directly benefits residents—such as parks, housing, or community amenities—would better serve our city and its future.

Thank you for prioritizing the well-being of Torrance residents.

-----Original Message-----
From: Bob Ryker <
Sent: Sunday, January 12, 2025 6:52 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

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Please vote against approval of this Ordinance.

Sent from my iPad

Bob Ryker
C (415)

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From: Carl Indriago <
Sent: Sunday, January 12, 2025 8:39 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Dear Honorable Members of the Torrance City Council,
I am writing to express my strong opposition to the proposed Ordinance change (Item 10B) that would replace the three-member Hearing Board with a single "fair and impartial Hearing Officer" appointed by the City Manager. This change is not only wrong but also un-American, as it would concentrate too much power in the hands of one individual who is not accountable to the community.

The proposed Hearing Officer would serve as the sole arbiter of "guilt" without requiring any specific qualifications, such as aviation or legal experience. This lack of expertise would undoubtedly lead to arbitrary and uninformed decisions that could have far-reaching consequences for individuals and businesses affected.

Furthermore, this change comes at a time when our community needs to support and expand our aviation capabilities, not hinder them. The recent fires in the Los Angeles County area have highlighted the critical importance of having more pilots, aircraft, and infrastructure within our county perimeter to respond quickly and efficiently. By replacing the Hearing Board with an unaccountable Hearing Officer, we risk deterring the development of aviation personnel and aircraft that our community desperately needs.

I urge you to consider the long-term implications of this proposed Ordinance change and reject it.

Our community deserves a fair and transparent process that takes into account the expertise and input of multiple stakeholders, not a single individual with unclear qualifications.

Thank you for your time and consideration. I look forward to hearing your thoughts on this critical matter.

Sincerely,CARL INDRIAGO | | M:

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From: Alexander Romero <
Sent: Sunday, January 12, 2025 8:50 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance.

Alexander Romero

From: BEN HOLM <
Sent: Sunday, January 12, 2025 9:07 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Dear Torrance City Council,
Item 10B please vote against approval of this Ordinance.

As a private pilot, I strongly oppose the proposed ordinance changes targeting flight schools, aircraft rentals, and operations at Torrance Airport. These rules make flying and learning to fly unnecessarily difficult, harming the aviation community and threatening historic aircraft that are a vital part of our heritage.

The enforcement process outlined is also deeply flawed, allowing unqualified decision-makers and anonymous complaints to dictate penalties. Punishing aircraft for violations without considering the pilot in command is unfair and discourages airport use.

Torrance Airport is a valuable community resource, and these changes jeopardize its future. Please reconsider this ordinance to ensure a fair and balanced approach.

Sincerely,

Ben Holm

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From: Richard Shaw <
Sent: Sunday, January 12, 2025 9:32 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Dear City Council-

Please vote against approval of Public Comment Item 10B.

I’ve been flying out of Torrance airport since 1971 and am astounded at the number of draconian measures being taken by the Council to destroy the aviation community at Torrance.

I guess it’s not even obvious during these tragic Los Angeles fires how important it is preserve an airport in your community. Torrance airport provides an space for aircraft and helicopters to operate during natural disasters to evacuate people and bring in relief assistance.

During my long career in aviation flying both military transports and airliners, I’ve flown numerous military missions for relief during hurricanes and other disasters, to include relief during the Rwandan war. In all of these cases the fundamental relief system hinges on having an airport for collecting and evacuating the wounded, and bringing in relief supplies (including fresh water, to prevent cholera).

Torrance airport has served us as a military flight training base in WWII, and a vital transportation and training facility since that time. Please don’t forget that it also would be a critical focal point to save our community during a disaster.

Sincerely,
Richard Shaw
West High, Class of ‘72

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-----Original Message-----
From: John Goldasich <
Sent: Sunday, January 12, 2025 9:45 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

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No Please vote against approval of this Ordinance.

Sent from my iPhone

-----Original Message-----
From: David Palacios <
Sent: Sunday, January 12, 2025 10:07 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

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Please vote against approval of this Ordinance.

Regarding item (10B)on the agenda I vote against this proposal for the following reasons:

It is obviously purposed by authoritarian, power hungery parties. Reminiscent of nazyism.

Giving absolute power to one individual, who will be undoubtedly biased in the favor of the one who will appoint him / her. This proposal will hinder the ones that are bringing revenue to the city. In the long run it will be harmful to the airport and in turn the city of torance.

In a word the proposal is asinine !!

From: John Kaminski <
Sent: Sunday, January 12, 2025 10:12 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance.

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From: Russell Ingham <
Sent: Sunday, January 12, 2025 11:12 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance.

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-----Original Message-----
From: Mike <
Sent: Sunday, January 12, 2025 2:11 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

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Tothe Torrance City Council:

Please vote against approval of this Ordinance. What the City is doing, is catering to all these homeowner, anti-airport tactics and so called complaints, will be a fatal blow to the Torrance airport community. We contribute directly into the Airport Funds that now go to the city general funds. Noise abatement "police & eviction dept. " . Landing fees even for tenants that contribute at least $300,000 per month in hanger and tie-down rents. Plus all the car dealers Torrance tax on car sales that are basically "leases-es" on Torrance Airport land. Your actions show that you'd rather have low-income homeless housing and another shopping center here instead of an airport.

Putting in a "Noise Czar" to be in charge is not being fair to all that use this airport.

M. McCluskey ... a Torrance resident, tax paying home owner and hanger rent paying pilot.

.

From: Michael Cannata <
Sent: Sunday, January 12, 2025 3:52 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

City Council;

Please vote against approval of this Ordinance. The Torrance Airport has been and should continue to be a good member of the community. Please do not be short sighted and influenced by a few members of our community or financial interests.

michael cannata

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From: Dale <
Sent: Sunday, January 12, 2025 4:02 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance. We the tenants should to be charged landing fees when we pay property taxes etc on top of the highest rent rates in the country.

-----Original Message-----
From: MARK J SWANEY <
Sent: Sunday, January 12, 2025 8:43 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

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I’m sending this email to urge you to please vote against approval of Ordinance Change item 10B.

I’ve lived in many localities around the U.S.during my 30 years of active service in the U.S. Navy. I retired from the Navy as a Captain, having been the Commander of Naval Test Wing Pacific and Vice Commander, Naval Air Warfare Center Point Mugu and China Lake. During that time I was an active FAA flight instructor in the SOCAL Area, so I’m very familiar with operating general aviation aircraft to and fromTorrance. I’ve also been an active civilian pilot for 54 years and a flight instructor for 45 years. I've been exposed to the rules and regulations at many different airports in California and across the country. I’m currently working with Ventura County Department of Airports in implementing a successful approach to dealing with aircraft noise at both Camarillo and Oxnard Airports. Based on my experience, and reading the proposed changes to the ordinance, I see many problems with the proposed implementation. It appears to have been drafted without understanding of the operations regulations mandaated by the FAA and the local control tower operating procedures. More work should be devoted to developing or changing the local ordinance that are fair and balanced.

Again, I urge you to reject the proposed changes to the ordinance (time 10B) and to further study the issue with some aircraft noise experts in the FAA and the SOCAL region.

Captain Mark J Swaney, USN(retired)

From: Peter Anninos <
Sent: Monday, January 13, 2025 1:21 AM
To: CityCouncil <
Subject: Item 10-B

Dear Torrance City Council,

Nobody at the airport wants to deliberately violate the noise restrictions and we all want to be good neighbors because we love this airport. We all know noise is an issue but there are a number of reasons that I hope is that you do not approve item 10-B.

This seems like yet another attempt to, bit by bit, drive a stake through the heart of this community asset. The primary reason is safety. Making pilots take even more extreme measures to avoid a noise complaint will eventually result in a decrease in safety by forcing pilots to adopt profiles that are unsafe at low altitudes and airspeed. We are already not allowed to perform such training as a touch and go or a go-around. This is something that is important to do especially at one's home airport. If there is an obstacle on the runway and one must perform this maneuver we have to be able to properly adjust the aircraft for a go around and developing a "sight line" for this at one's home airport is important.

How is this noise even measured? I asked to see it and was told I could not. Certain meteorological conditions can cause aircraft noise to be reflected back to the ground and in such cases, no matter how one operates an aircraft, they will be over the already very low noise threshold which is lower than most airports.

I would suggest that all this looks like work to damage pilots and training at TOA, eventually leading to airport destruction. The recent fires proved the absolute necessity for local airports as service and rescue locations. As training for the next generation of pilots fighting fires, if such a situation were to arise in this local area, what would the residents do? Just today there was a brush fire in a park area here in Torrance. In an emergency, locations to land aircraft, should/when emergencies occur (since everywhere else is so densely populated) off airport operations for emergency relief efforts would endanger the lives of those on the ground as well as the relief workers.

Thank you
Peter Anninos

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From: Paul Storaasli <
Sent: Monday, January 13, 2025 8:28 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance. There should not be a single person without defined qualifications with the power to make rulings for noise board items.

The rules of evidence for items brought before the board are not defined, and therefore the defendants will be at a loss to respond heresay testimony.

Paul Storaasli

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From: Cameron LaFont <
Sent: Monday, January 13, 2025 9:24 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance. Our local airports are integral to the safety of our communities.

Cameron LaFont
Marvel Investments

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From: Gary Palmer <
Sent: Monday, January 13, 2025 9:45 AM
To: CityCouncil <
Subject: Reject agenda item 10B, it's not a reasonable solution

Please reject item 10B on your 14-Jan agenda.

The test to consider if any new law is fair is the application to anyone and everyone.

Usually, the best assessment is to apply it to yourself and see if you think it fair and just.

Regarding item 10B, let's consider a scenario applied to a car instead of an airplane.

I don't like my neighbor driving his sports car on the street, I write a noise complaint.

The noise complaint office takes my complaint, anonymizes it. and decides unilaterally to act.

The accused receives a letter to appear and does.

The accused brings documentation that his car is very quiet.

The (all powerful) noise complaint officer, who may be a bit jealous of the sports car, decides to summarily reject all the data and facts provided by the accused.

The accused does not know the complaint author in order to challenge the complainant as being a disgruntled neighbor.

The noise complaint officer decides the accused is guilty and issues a violation.

The accused, now convicted, does not have any appeal recourse because the new law prohibits it; the noise complaint officer is all powerful.

I complain 2 more times with the exact same results.

The now 3 times convicted neighbor is told he is no longer permitted to drive his car on Torrance streets and would be considered a criminal if he does so.

THAT is the scenario envisioned by item 10B.

If this was applied to any group other than pilots, would you accept it thinking it fundamentally constitutional?

--
Gary Palmer
Permission to reprint, after redacting my email address, is granted.

From: Bruce Ellison <
Sent: Monday, January 13, 2025 11:05 AM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Please vote against approval of this Ordinance. My name is Bruce Ellison. I own SEVEN Properties in the city and have been a pilot and tenant of the Torrance Airport since 1964. I don't really like the commercial operations at our airport, however the revenue does benefit the airport and we have a constant need for new pilots for the airline industry.

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From: Barry Jay <
Sent: Monday, January 13, 2025 1:26 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Dear Mayor and City Council Members,

PLEASE VOTE NO ON Item 10B on tomorrow's agenda. The flight schools have worked very hard to FLY NEIGHBORLY but COTAR seems bent on an irrational attack on all aircraft.

THERE ARE ONLY A HANDFUL OF VIOLATIONS AND THE HEARING BOARD PROCESS IS SERIOUSLY LACKING DUE PROCESS AS IT IS. DON'T MAKE IT WORSE!
• Replacing the three-member Hearing Board with a "fair and impartial Hearing Officer" (not a city employee)--appointed by the City Manager. IS A VIOLATION OF DUE-PROCESS. • Formal rules of evidence shall NOT apply. ALSO CONTRARY TO LEGAL PROCEDURES. • Hearsay evidence may be admitted even if the author is not present at the meeting. VIOLATES THE RIGHT TO FACE ONE'S ACCUSERS..
• Any aircraft involved in three or more violations in three years will be excluded from the airport, regardless of who was the pilot in command. CLEARLY TARGETS THE FLIGHT

SCHOOLS AND IS CONTRARY TO THE EFFORTS THEY'VE MADE TO COMPLY WITH CITY NOISE ORDINANCE.

Sincerely,

Barry Jay - a 49 year Torrance resident and voter!
Brian Ave.

Torrance, CA

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-----Original Message-----
From: Ronald Bishop <
Sent: Monday, January 13, 2025 4:10 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

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I am emailing to ask you to Please vote against approval of this Ordinance. Thank you for your careful consideration. I am a Pilot, and airport Tennant, And resident of an adjacent city with multiple aircraft lights overhead coming to land or taking off and leaving the Torrance area. WHILE airport “noise” is music to me. I fully understand it isn’t for many people —so odd that they would choose to live near airport - If that is their concern. I wish for them to have a peaceful enjoyment of their homes, despite the heavy traffic on PCH, Hawthorne, and Crenshaw, including many noisemakers such as motorcycles and large commercial vehicles, which seem to be almost always present in the area around Torrance airport . I pride myself in flying as quietly as possible given requirements of FAA air traffic control, and safety.

Please strongly consider voting no on amendment 10 B. Thank you for your consideration. Ron Bishop

Sent from my iPhone

From: Don Older <
Sent: Monday, January 13, 2025 4:42 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Airports are an essential element of any community of the size and complexity of Torrance. No other service such as the one that aviation provides can be duplicated. Where would today's world be without aviation? What plans for Torrance could have a higher priority than the necessity of a vital airport? The bottom line is always- Is this constructive or distructive for the community.

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From: Reza Birjandi <
Sent: Monday, January 13, 2025 4:49 PM
To: CityCouncil <
Subject: Public Comment Item 10B 1/14/2025 meeting

Good afternoon Mayor Chen and City Council Members,
I wanted to write to you as a Torrance airport pilot and flight school owner. We have been established for over 15 years as a professional flight school in the community, providing instruction for future recreational and career path students. During this time we have strived to engrain best practices to minimize our noise impact to local residents and provide a commitment to safety. We continue to educate every single student and renter to adhere to the city rules and recommendations to work as a favorable partner.

But Item 10B punishes us as a flight school for any violations that may come from pilots acting on their own behalf, not following published guidelines. The fleet of airplanes that we use come from owners leasing back the airplanes for instruction and rental, even when those owners are not occupying that airplane at the time a renter may cause a violation. Item 10B could result in removing that airplane from our fleet, and in doing so harshly punish not only the owner, but the flight school in need of that equipment to successfully stay in business.

We simply request that the pilot in command, not the airplane, be registered as the person in violation. Otherwise the risk of having as little as three violations in three years time in which that airplane may fly more than 3000 flight hours is insurmountable.

I kindly ask for your consideration of the impact of running our business in the city of Torrance, as we have successfully done for almost two decades.

Thank you,

Reza Birjandi
Owner, Pacific Skies Aviation

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