The City of Portland’s Bureau of Planning and Sustainability (BPS) is updating the Comprehensive Plan land use policies and zoning code to regulate bulk fuel facilities in the Critical Energy Infrastructure (CEI) Hub. BPS is accepting public comments right now on the CEI Hub Policy Project Discussion Draft. We have an opportunity to tangibly reduce the dangerous health and safety risks of the CEI Hub!

Submit your comment by Friday, October 17, 2025!

You can find the link to the CEI Hub Policy Project Discussion Draft here: https://www.portland.gov/bps/planning/cei-hub/documents

Talking Points

• HEALTH
  • The proposed alternatives continue to ignore the catastrophic risks to public and environmental health posed by the fuel stored at the CEI hub, as well as the existential threat the continued burning of fossil fuels represents. For the neighboring communities, the complex ecosystems in Forest Park and the Willamette River, and the protection of our climate, an aggressive and science-based drawdown is the only viable option.
  • Corporate lobbyists are already pressuring the city for weak rules. We need to make sure community health is the top priority.
  • An incident in the CEI Hub would be costly to our economy and our health. The health costs of exposure to toxins as a result of an earthquake or another catastrophic event in the CEI Hub is approximately $121 million to $249 million. 
  • An incident in the CEI Hub would release harmful air pollutants like particulate matter, benzene, toluene, and more that are disastrous to air quality and people’s health. 

• SAFETY
  • The risk is the sheer volume of hazardous material concentrated in a liquefaction zone. Alternatives 1-2 increase risks to human health and the climate. Alternative 3 maintains the status quo. In a major earthquake, a tank holding renewable fuel is just as likely to rupture and spill as a tank holding fossil fuel. 
  • The only path toward real safety is to reduce the amount of fuel and toxic materials stored at the hub on an aggressive timeline.
  • The proposed alternatives are minor adjustments to a fundamentally broken system. They do not meet the urgency of the crisis identified in the city’s own reports, which state that over 90% of the tanks were built before modern seismic standards and are highly vulnerable to failure in a Cascadia earthquake.
  • The proposed 17% reduction by 2035 (Alternative 4) is based on market projections, not public safety science. It is a timid response to a catastrophic threat. We need a more aggressive, science-based drawdown schedule that prioritizes the safety of nearby residents, the climate, the Willamette and Columbia Rivers, and Forest Park over corporate convenience.

• LEGACY FOR FUTURE GENERATIONS
  • How we handle the CEI Hub will define Portland’s commitment to climate action, environmental justice, and community safety for decades to come. We must choose a path that future Portlanders will thank us for.
  • The City has not engaged in meaningful Tribal Consultation on this issue.
  • Oregonians made big choices in the past to make our state and city great. We stopped the Mt. Hood Freeway, turned a freeway into Tom McCall Waterfront Park, declared all beaches free to the public, and much more. This decision could shape the future of our city in the right way for generations to come. 

• CLIMATE
  • The fossil fuel industry has adopted the term “renewable” fuels to describe fuels produced from feedstocks that are not petroleum based. These fuels often carry the same risks as traditional fossil fuels. They are also often blended with large quantities of fossil fuels and are still referred to as “renewable”.
  • According to the National Farmers Union, “Sustainable Aviation Fuels (SAFs) are not feasible decarbonization solutions, but they are very likely a food-price problem, a soil health problem, a clean energy and green hydrogen demand problem, and a cause of accelerating extinctions and warming.” The land use changes from producing SAFs may be extensive and produce a large amount of greenhouse gas emissions. SAF must be blended with a minimum of 50% jet fuel.
  • Renewable naphtha is a highly volatile product and chemically equivalent to gasoline. Not only is it toxic to aquatic life with long lasting effects, exposure to renewable naphtha has numerous detrimental health effects.
  • Studies have shown that the agricultural activities involved in creating biofuels can actually increase NOx emissions, a potent greenhouse gas that may offset any carbon dioxide reductions. This is especially concerning when carbon intensive feedstocks like corn and soybean oil are used. 
  • Alternatives 1 and 2 use the promise of expansion for “green” fuels as a “carrot” (incentive). This is a false solution. It encourages building new tanks in a high-risk area instead of mandating a reduction of the existing threat. Building new tanks does not solve the climate problem of emissions from creating and burning fossil and “renewable” fuels.

• CORPORATE POLLUTER INFLUENCE
  • We cannot let the companies that profit from this dangerous status quo dictate the terms of their own regulation. The voices of frontline communities and safety experts must prevail.
  • The economic impact of a major spill and fire—contaminating the rivers, destroying ecosystems, and devastating communities—would be immeasurable. 
  • The city’s plan must prioritize preventing this cost, not accommodating industry business plans.

SAMPLE EMAIL (Feel free to personalize)

Dear CEI Hub Policy Project Team,

I am writing to comment on the CEI Hub Discussion Draft. The current proposals do not adequately address the grave risks to our community, our river, and our climate.

I strongly oppose Alternatives 1, 2, and 3. Allowing any expansion of fuel storage capacity in a known liquefaction zone is irresponsible and ignores the clear scientific warnings.

Alternative 4 is the only viable path forward because it begins to reduce the existing danger. However, the proposed 17% drawdown by 2035 is insufficient. We need a much more aggressive and scientifically-grounded plan to reduce fuel storage capacity as quickly as possible.

This is a historic decision that would literally shape the future of this city and the region for better or worse. Do not let corporate influence dictate a plan that puts our community and the region at risk. I urge you to strengthen Alternative 4 into a policy that truly centers community safety and creates a legacy of resilience for Portland and our neighbors.

Sincerely,
[your name]