Oregon Risks

Portland’s Critical Infrastructure Hub (CEI)

Over 90% of Oregon’s fuel is located in the CEI Hub in Northwest Portland. This includes Zenith Energy’s Portland terminal.

 The location of the Hub and inadequate terminal standards put the Hub at risk. An environmental catastrophe at the CEI Hub would devastate the City of Portland.

ESF recommends increasing DEQ oversite, reducing total fuel capacity at the Hub, legislating prudent State, County, and City fuel    terminal Standards. For more information, see the attached PowerPoints on the CEDI Hub and the Zenith Portland Terminal.

CEI Hub  Presentation 

Zenith Terminal Presentation

General Principles

Social Cost of Greenhouse Gases

ESF recommends that the social costs be considered by engineers in their studies and designs. In addition, all government agencies should require consideration of the cost of greenhouse gases in their deliberations.

For carbon dioxide, the social cost of releasing a metric ton (2204.6 pounds) is currently set at $51 by the Biden Administration. The cost assigned to a metric ton of methane is $1500, and $18,000 to a metric ton of nitrous oxide.

By using the cost of greenhouse gas estimates, we can estimate the cost that will be realized by society of releasing these gases into the atmosphere. Fluorinated gases should also be considered.

Best Available Science

ESF advocates that government agencies undertake projects and programs using the best available science.

“Best Available Science” as defined by the Restore Act:

  • Maximizes the quality, objectivity, and integrity of information, including statistical information;
  • Uses peer-reviewed and publicly available data; and
  • Clearly documents and communicates risks and uncertainties in the scientific basis for such projects.


Precautionary Principles

ESF endorses the Precautionary Principle which recognizes that delaying action until there is compelling evidence of harm will often mean that it is then too costly or impossible to avert the threat. Use of the principle promotes action to avert risks of serious or irreversible harm to the environment in such cases.

The Precautionary Principle provides a fundamental policy basis to anticipate, avoid and mitigate threats to the environment.


Climate Change

Transmission System

To facilitate the development of large renewable sources, it is important that the regional transmission system has the capacity to deliver power to load centers. Electrical utilities need to identify potential generation sites and ensure that the surrounding grid has sufficient capacity to receive renewable power. It is also important that generation developers are able to construct transmission lines from the generation site to tie into the electrical grid in a reasonable time.

The inability to deliver power from the generation site to the proposed load center can make many otherwise attractive renewable generation projects impossible to construct. Federal, state, and local laws must recognize this and ensure that laws and regulations are such that transmission interties can be constructed in a reasonable time. We are familiar with attempts to construct transmission lines that have taken up to 15 years because of delays in gaining construction approval.


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