Breach Sends Letter to Portland City Council With a Blueprint to Deny Zenith’s LUCS

On January 30, 2025, Breach Collective sent a letter to Portland City Councilors and Mayor Keith Wilson with a blueprint for how the City can deny Zenith’s Land Use Compatibility Statement (LUCS) based on its incompatibility with the 2035 Comprehensive Plan.

[A]n ever-expanding liquid fuel transloading facility with ever-increasing rail throughput — threatening communities of color, under-served, and under-represented communities, other vulnerable populations, and tribal treaty resources — sited on seismically vulnerable site adjacent to a wildfire hazard area and that uses infrastructure on liquefiable soils cannot exist without discord and disharmony with the Plan.

The letter analyzed Zenith’s activities against sections of the Comprehensive Plan and described where they come in conflict.

The Comprehensive Plan is not a checklist of isolated rules but a blueprint for Portland’s future. Zenith’s LUCS application — with its expanded fossil fuel and renewable fuels infrastructure, unmitigated hazards, and harm to vulnerable communities — fundamentally disrupts this vision. Zenith Energy’s facility poses substantial off-site risks to the environment, public health, and critical infrastructure. The facility’s location in a seismically vulnerable area, its proximity to Forest Park and the Willamette River, and its history of regulatory violations make it a ticking time bomb for catastrophic accidents. A major earthquake, wildfire, or oil spill could have devastating consequences, including the destruction of critical fish habitats, widespread environmental contamination, and severe health impacts on nearby residents. By allowing discord with the Plan’s climate, equity, and safety goals, the City would betray its duty to uphold "the health, safety, and general welfare of Portlanders." Accordingly, the LUCS must be denied.

You can read the letter in its entirety here.