CEI Hub Testimony

Photo: Alex Milan Tracy

A Critical Moment for Portland’s Critical Energy Infrastructure Hub

By: Kate Murphy, Senior Community Organizer

We are in a pivotal moment to reduce risks and improve safety at Portland’s CEI Hub.

Let’s make the Critical Energy Infrastructure (CEI) Hub safer for people, our economy, the Willamette and Columbia Rivers, Forest Park, and wildlife!

Important Dates: September 17 and 24!

September 24 is a critical opportunity for public input. We need you to speak up and tell the Portland City Council we must increase safety and reduce risks at the CEI Hub.

For folks who are interested in learning more and supporting panelists who will be giving detailed presentations about this issue, a work session is scheduled for September 17. 

When: September 17 from 2:00-5:00 p.m
What: City Council Work Session – CEI Hub Legislation: no public testimony on this day. Invited presenters will share the community-supported amendments. The work session will include a presentation by City staff followed by a City Council question and answer session. The work session will take place in the Council Chambers at City Hall. 
Where: Portland City Hall Council Chambers, 1221 SW Fourth Avenue Portland
*Council Chamber doors open to the public 15 minutes before the meeting starts.
*A link to the live stream and recorded video can be found here.
*Wear red

The day for public testimony is September 24, and we need all hands on deck. Join us to demand the Portland City Council prioritize the health and safety of our communities and reduce risks from the CEI Hub.

When: September 24 from 2:00-5:00 p.m.
What: City Council hearing with public testimony
City Council will hear testimony on both the Recommended Draft and the Bulk Fuel Terminal Capacity Reduction Regulations. The hearing will be held in a hybrid format with options to participate either in person at City Hall or virtually using a computer, mobile device, or telephone. You must sign up in advance to testify. Registration for virtual testimony closes one hour prior to the Council meeting. In-person testifiers must sign up before the agenda item is heard. You can register online or over the phone by calling 311. The agenda and a link to the oral testimony registration will be available the Friday before the hearing at this link. 
Where: Portland City Hall Council Chambers, 1221 SW Fourth Avenue Portland
*Wear red
*Arrive at 1:30pm to grab a snack and screen printed art while supplies last!

Submit written testimony by Sept. 24. 

See below for talking points.

Written testimony for the Recommended Draft and the Capacity Reduction Program will be accepted separately.

• Submit written testimony for the Recommended Draft
• Submit written testimony for the Capacity Reduction Program 
• Support Green-Clark-Koyama-Lane-Kanal amendments developed in collaboration with the community

Background

What is the CEI Hub?

The Critical Energy Infrastructure (CEI) Hub is a six-mile stretch of dangerous fuel tanks located in Northwest Portland that nearly 90% of Oregon’s fuel passes through, up to 350 million gallons. The tanks are owned by climate villains like Zenith Energy, BP, and Chevron. They are unsafe for people, the rivers, Forest Park, and wildlife.

The tanks are located on the banks of the North Reach of the Willamette River, at the foot of Forest Park, and across the river from the Portland Harbor Superfund site. The CEI Hub tanks were built on unstable soil without seismic safety requirements. A disaster at the CEI Hub would devastate our city and region: when the big earthquake hits, more than 200 million gallons of fuel at the CEI Hub could spill into the Willamette River, which, according to a PSU study, “could result in more than 330,000 irritation level exposures, 17,000 potential injuries, and more than 2,500 potential deaths.”

Elected officials have a moral responsibility to prevent harm and increase safety. Portlanders stopped the Mount Hood Freeway and turned another freeway into Tom McCall Waterfront Park. Oregonians made our beaches public and free. We can and must make the CEI Hub safe.

What’s happening now?

In 2025, the City of Portland received a federal grant to create a policy to make the CEI Hub safer. This is a once-in-a-generation opportunity to make meaningful changes to increase CEI Hub safety and decrease risk. 

The goals and objectives of the CEI Hub Policy Project include protecting life, reducing injuries, minimizing damage to property, essential infrastructure, and services resulting from natural hazards, and helping Oregon’s economy bounce back from the effects of natural hazard events. 

In other words, the main purpose of the grant is risk reduction and increasing safety by amending the natural hazard policies and adopting zoning code restrictions on fossil fuel terminals in Portland’s Comprehensive Plan.

Unfortunately, the Bureau of Planning and Sustainability’s amendments have weak guiding language and allow for expansion at the Hub into a major West Coast export hub. This would increase risk to Portlanders due to an increase in the amount of fuel moving through Portland Harbor, but it is not likely to benefit Portland’s economy much.

We must act now. The CEI Hub is a ticking time bomb. Urge the City Council to support amendments to the CEI Hub Policy Proposal, developed by councilors in partnership with community advocates, to make the CEI Hub safer. 

How we want to improve the CEI Hub Policy Proposal

A draft policy was written by Portland’s Bureau of Planning and Sustainability and recently submitted to the City Council. We support the amendment package designed in collaboration with community advocates and sponsored by Councilors Green, Clark, Koyama Lane, and Kanal. The Green-Clark-Koyama-Lane-Kanal amendment package has three parts: amendments to the Comprehensive Plan, amendments to the Zoning Code, and a plan to reduce toxic fuel stored at the CEI Hub.

(1) Comprehensive Plan Amendments

The overall goal is to call for stronger language that is actionable and enforceable:

1. Create clear goals and monitor progress to increase safety and to protect human health and the environment from CEI Hub dangers.
2. Recognize the dangers associated with the fuel terminals sitting on unstable land in a liquefaction zone — vulnerable to natural hazards such as seismic events, fire, landslides, or floods.
3. Prohibit addition of new fuel terminals and reduce the huge volume of flammable, combustible, toxic materials in natural hazard risk areas.
4. Create safety and evacuation plans and engage affected communities in preparedness and planning efforts.
5. Become a regional leader to advance the transition to a decarbonized economy, without falling prey to greenwashing tactics that prolong the use of methane “natural” gas or a transition to “renewable” or “sustainable” fuels that are still toxic, flammable, and harmful to the planet.

(2) Zoning Code Amendments

The overall goal is to use clear, directive language to:

1. Prohibit expansion of flammable, combustible, toxic liquid fuel storage capacity to increase safety and reduce risk.
2. Not support exemptions for aviation fuel, “renewable” fuels, or methane “natural” gas.
3. Create one inclusive set of criteria for a single process for new construction, upgrades, retrofits, or expansions. This process requires the company to show evidence of reduced risk, increased safety, and public benefit for the requested changes.
4. Create stronger neighborhood notification processes for new developments, demolition of tanks, changes to transloading facilities, or any discretionary review process.

(3) Fuel Reduction Program Amendments

The goal is a phased decrease in the volume of fuels in the tanks. Risk can be reduced by decreasing the amount of fuel that is on site before a catastrophe happens. Fuel reduction targets must not create Oregon shortages of transportation fuels.

1. Phased drawdowns of volume could start next year and not wait a decade; they could occur every 3 years and align with documented usage and Oregon’s climate goals for reduction. This data should be reported to City Council every three years.
2. The Fuel Reduction proposal requires CEI Hub facilities to report tank fill data. This data should be used in calculating potential fuel reductions, not simply reported.
3. A well-defined fuel reduction plan must be based on actual data, not on estimates or forecasts.
4. Since fuel reduction can be based on actual usage data for every type of fuel,
   no exemptions for specific fuel types are necessary. If the demand is documented, this will be presented to City Council.
5. Penalities for non-compliance must be mandatory.

How you can help

Now is a critical moment for you to use your voice to demand that City Council take action to improve safety and reduce risks at the CEI Hub!

1. Attend the Sept. 17 work session and Sept. 24 public hearing

We expect the proposal to be heard by the Committee of the Whole on Thursday, Sept. 17 and at a hearing of City Council on Thursday, Sept. 24. The larger the group, the more we can show councilors that the community supports our presenters and stands against industry testifiers. Let’s pack the room for both sessions, and wear red!

• Thursday, Sept. 17, Committee of the Whole work session, 2:00–5:00 pm, no public testimony, instead support the invited presenters who will share the community-supported amendments.
• Thursday, Sept. 24, City Council hearing with public testimony, 2:00–5:00 pm.
  • *Arrive at 1:30pm to grab a snack and screen printed art while supplies last!

2. Submit written testimony and/or sign up to testify verbally by Sept. 24

Submitting written or verbal testimony has a higher impact if you use your own voice and speak personally to your concerns. Submitting something is better than submitting nothing, however, and your testimony can be as short as a few sentences.

• See the detailed talking points below for ideas for your written or verbal testimony. 
• Consider focusing on one or two amendments, but also include some of the more general talking points and why this is important to you. 
• When commenting on the Fuel Reduction Amendments, make sure to mention you want a significant drawdown of toxic fuels at the CEI Hub as soon as feasible based on real data. 

This policy requires two pieces of testimony specific to the various sections:

• Submit written testimony for the Recommended Draft
• Submit written testimony for the Capacity Reduction Program 
• Sign up for verbal testimony on Sept. 24 when the council agenda becomes available 

3. Call, Write, Email, and Lobby Your Councilors!

It’s important that Councilors hear from us in a variety of ways. This section below contains all you’ll need to call your Councilors, send them an email, write them a postcard, or talk in person at City Hall or at events you may see them at. 

Please personalize this script by sharing why this matters to you, and make it fit for the medium you’re using. Handwritten postcards/letters are regarded with more weight than emails, and written or verbal testimony makes an outsized impact. Your postcards, letters, and emails will make a greater impact if you write in your own voice and briefly explain why this is important to you.

Hi this is <<YOUR NAME>>. I am a resident of District <<YOUR DISTRICT>>. Please support the CEI Hub amendment package sponsored by Councilors Green, Clark, Kanal, and Koyama-Lane. We need changes to the Bureau of Planning and Sustainability proposal in order to increase safety at the CEI Hub. As it stands now, the BPS proposal allows for expansion and that does not reduce risks or increase safety. That’s not good enough. Vote for safety. Thank you.

(Not sure what district you’re in? Check this map to find out.)

We also recommend asking councilors questions at their forums and events. Here are a few questions we suggest:

1. Will you support an amendment to the CEI Hub Policy Proposal that will reduce the volume of fuel in the tanks instead of fuel storage capacity?
2. Will you support a phased, significant drawdown of toxic fuels at the CEI Hub beginning in 2027 and based on real data, with additional reductions every three years thereafter, in line with state climate goals?
3. Will you support an amendment to the CEI Hub Policy Proposal that will remove the exemption for aviation fuel?

4. Write letters to the editor 

Here’s how to send a letter to the editor to The Oregonian.
Here’s how to send a letter to the editor to the North Peninsula Review.

Detailed Talking Points

Submit written testimony before September 24th. Consider testifying in person as well, or being there to support others!

This policy requires two pieces of testimony specific to the various sections:

• Submit written testimony for the Recommended Draft
• Submit written testimony for the Capacity Reduction Program 

When submitting comments:

• Write in your own voice. 
• Highlight a few of the most critical amendments and why they are important to you.  
• Add some points from the more generalized talking points below, rewritten in your own words and emphasizing increased public safety and health.  
• For the Fuel Reduction Amendments, it is critical to prioritize starting a significant phased fuel reduction as soon as possible instead of waiting until 2036 (as BPS is proposing).  

Comprehensive Plan Amendments

Goal: stronger language that is actionable and enforceable and that reduces actual risk

• Reduce the amount of fuel stored at the CEI Hub.
  • Prohibit new bulk fuel terminals (while allowing for maintenance and safety upgrades).
  • Reduce storage volume at existing terminals. 
  • Require infrastructure and safety improvements to prepare for earthquakes, fire, landslides, or floods.
• Ensure that this policy helps the Comprehensive Plan goals by: enhancing emergency preparedness, supporting environmental and human health, and increasing community resilience.
  • Improve and restore air and water quality.
  • Protect the Willamette River Watershed and recognize the many functions the river plays as a natural, recreational, cultural, and economic resource. 
• Increase safety and reduce risk in the Critical Energy Infrastructure (CEI) Hub.
  • Mitigating risk to community and environmental resilience posed by the storage of fuel in a natural hazards risk area should be a main priority.  
  • We demand risk reduction, not just risk minimization.
    • Set actionable targets to reduce the risk to community, the environment, the economy, public health and safety, and resilience.
    • The storage of flammable, combustible, and/or toxic materials in natural hazard risk zones is inherently risky to people and the environment.
  • Safety first. The Comprehensive Plan should direct the creation and implementation of safety and evacuation plans for area residents, businesses, and institutions in consultation with affected communities.
• Lead our region in advancing a just transition to a decarbonized economy.
  • Collaborate with other local, state, and federal agencies on mitigation and emergency response around the CEI Hub. 
  • Engage impacted communities in planning and project development.

Zoning Code Amendments

Goal: prohibit expansion, remove loopholes, one process for making changes

• Close loopholes that leave the door open for expansion of fuel storage facilities in the Type III discretionary reviews for new construction, retrofits, expansion of transloading facilities, exemption requests, or fuel transfers.
  • The Zoning Code Amendments establish one review protocol with a clear set of criteria.
  • These criteria require demonstrated evidence of reduced risk, increased safety, and public benefit.
• One definition of fuel: 
  • Avoid confusion.
  • Align with state regulations.
  • Acknowledge that current “renewable” and “sustainable” fuels are also toxic to the river ecosystem and combustible; they remain a safety risk and should be subject to the same rules as fossil fuels.
• Neighborhoods on the frontlines of the CEI Hub are already disproportionately impacted, and would be at immense risk in the event of an emergency. They should have a stronger say in what happens.
  • Emergency alerts: Strengthen the neighborhood notification process to ensure early, accessible, and multilingual notice.
  • Permit decisions should require public City Council hearings where decision-makers are required to respond to frontline community concerns before making decisions.
  • Formal inclusion of community concerns in the public record.

Fuel Reduction Program Amendments

Goal: a phased decrease in the volume of fuels while retaining the volume needed by Oregonians

• In addition to the risk of climate change, the fuels stored at the CEI hub pose a risk to public health and the river.
  • We need a phased transition to a low carbon economy.
  • The less fuel there is at the CEI Hub when an earthquake or other natural or human caused disaster happens, the less the risk to the community and the region.
• The drawdown plan as drafted does not reduce fuel levels over the next 10 years.
  • It is unacceptable to wait another decade to reduce the risk to Portlanders, our rivers, and the other species who live here.
  • The Fuel Reduction Program Amendments begin a phased drawdown plan in 2027. 
  • According to BPS’s estimates, there is already enough “excess capacity” at the Hub for a drawdown larger than what they are proposing. 
• Base the drawdown on actual measurements of average daily fill levels.
  • The current proposal is based on speculative estimates of average capacity.
  • Facilities are required to report monthly throughput and fill levels. This data is not used to determine the drawdown — but it should be!
• All types of liquid fuels including fossil fuels, so-called “renewable” fuels, and “sustainable” aviation fuel are combustible and toxic.
  • Switching to “renewable” fuels does not solve the problem of risk to human and environmental health and safety.
• The BPS drawdown proposal needs to be expanded, with a concrete plan that will reduce risk and harm at the CEI Hub starting now.

Human Health & Safety

• Human health is one of the five guiding principles of Portland’s Comprehensive Plan.
  • The CEI Hub fuel storage poses catastrophic risks to public and environmental health due to natural or human caused disasters, such as earthquakes, floods, or accidents.
• The continued burning of fossil fuels is an existential threat to humanity and other species due to climate change.
  • Public health and safety are already impacted by climate change, and it will only get worse until we transition away from fossil fuels.
• An aggressive and science-based drawdown is necessary in order to protect:
  • Neighboring communities, 
  • The complex ecosystems in Forest Park,
  • The Willamette and Columbia Rivers, 
  • And our global climate.
• 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. 
• Modern safety standards for building and fire codes should be required in the CEI Hub for existing pipelines and tank farms:
  • Automatic shutoff valves, 
  • Real-time leak detection, 
  • Seismic and flood upgrades, 
  • Robust secondary containment, 
  • Increased setbacks between industrial zones and neighborhoods, 
  • And enforceable emergency-response and evacuation requirements for all CEI Hub facilities.

Environmental Health 

• Environmental health is one of the five guiding principles of Portland’s Comprehensive plan.
  • Every gallon of flammable, combustible, and toxic material at the CEI Hub is a threat of tank fire, explosion, setting Forest Park and the surrounding neighborhoods ablaze, huge plumes of toxic smoke drifting over near and far communities. 
  • The Willamette and Columbia River ecosystems are threatened by contamination.
  • Reducing the volume of stored fuel is critical to reducing risk. 
• An oil spill at the CEI Hub could be larger than the BP oil spill in the Gulf of Mexico, the country’s largest oil spill.
  • This oil would pollute the Willamette River, Columbia River, and Pacific Ocean. 
  • The toxic fumes could drift for miles in any direction depending on the wind, particularly north and northwest Portland, reaching the Moda Center and beyond City Hall. 
  • A spark could light Forest Park on fire, which can spread up to 14 miles per hour. 
  • Our beloved salmon and local populations of other endangered species would be decimated.
• On an everyday basis, the CEI Hub pollutes the neighborhood and is the core of the largest heat island in Portland.
  • The heat dries Forest Park’s soil and trees, increasing the chance of wildfire. 
  • The heat increases river temperatures and harms wildlife. 
  • People living and working near the tank farms have been exposed to toxic air and pollution-related illnesses for decades. 
• Portland should prioritize reducing overall demand for liquid fuels:
  • Invest in high-quality public transit,
  • Build safe and accessible active transportation,
  • Incentivize building decarbonization that eliminates the need for liquefied methane “natural” gas, alongside widespread electrification supported by publicly owned renewable energy systems. 
• So-called “sustainable” aviation fuels and other “renewable” liquid fuels should not be treated as climate solutions at the CEI Hub.
  • Most deliver limited or uncertain climate benefits while perpetuating reliance on high-risk liquid fuel infrastructure. 
  • They often need specialized tanks and pipes. 
  • The promise to switch to “renewable” fuels is used as a greenwashing tool to continue building out fossil fuel infrastructure (that often cannot be used for “renewable” fuels).
• Make Portland a model for a climate-friendly city prioritizing a well-being economy and a just transition.
  • Vision for the CEI Hub: prioritize community needs for clean air, water, and soil — a place respectful of the environment and wildlife, not contributing to climate chaos.

Economic Prosperity

• Economic prosperity is one of five guiding principles of Portland’s Comprehensive Plan.
• An incident in the CEI Hub would be costly to our economy and our health.
  • The monetized costs of a disaster at the CEI Hub could range up to $2.6 billion. Based on prior spills, total costs and damages would likely be much higher.
  • 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. 
  • The city’s plan must prioritize preventing this cost, not accommodating industry business plans.
• If there was a catastrophe at the Hub because of the Cascadia Subduction Zone earthquake, the state would not have the fuel it needs to recover from such a large-spread disaster.
  • More than 90% of all liquid fuel in Oregon passes through the facilities in the CEI Hub.
• The economic and environmental cost of a CEI Hub disaster could be greater than the Deepwater Horizon spill, when approximately 200 million gallons of oil spilled into the Gulf of Mexico: the cost of the cleanup and damages was $65 billion, and 11 people died. 

Legacy For Future Generations

• Choose a path that protects future generations, wildlife, and our river.
  • How we handle the CEI Hub will define Portland’s commitment to climate action, environmental justice, and community safety for decades to come. 
• 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. 
  • Decisions about the CEI Hub policy could shape the future of our city toward health, safety, and prosperity, or they could keep us on a path toward eventual disaster.
• The CEI Hub already pollutes the nearby air and water and enables a majority of Oregon’s fossil fuel emissions, even if a disaster (miraculously) never occurs at the Hub.

Other Concerns

• The plan needs stronger enforcement consequences for not complying.
  • Fines are necessary, but insufficient, because fuel corporations can pay them as the cost of doing business. 
  • The City needs to implement a retroactive measure that revokes the franchise, business license, or operating ability of repeat offenders of City or State laws or policies at the CEI Hub. 
  • Stronger enforcement measures must be clearly defined in City Code. 
• Prime riverfront land need not be locked into long-term hazardous fuel storage.
  • Portland needs land for housing, good jobs, schools, and riverfront green space. 
  • This policy can help us begin to shift the City’s land-use and workforce planning toward safer, more resilient uses.
  • Focus on lasting community benefits instead of future liabilities.
• The CEI Hub is at risk from multiple natural hazards as well as human accidents:
  • Seismic events from the Cascadia Subduction Zone and Portland Hills fault line,
  • Lightning,
  • Urban wildfires at Forest Park, 
  • Landslides,
  • Flooding,
  • Train derailments,
  • Equipment failure, and 
  • Other human-caused spills and explosions.