Scott Comings is the Associate State Director of The Nature Conservancy in Rhode Island. In his role at The Nature Conservancy, he has worked with and facilitated hundreds of scientific research projects in the state, participated in multiple statewide habitat assessments and overseen stewardship of all of the Conservancy’s Rhode Island lands since 2009. Previous to joining The Nature Conservancy staff in 1997, Scott worked as a field ornithologist for Brown University, University of California Davis, Smithsonian Migratory Bird Center, and Louisiana State University. He lives on Block Island.
One of the hallmarks of The Nature Conservancy is its pursuit of non-confrontational, pragmatic solutions to conservation challenges. For this reason, the Conservancy rarely takes a public position on a specific development project. However, Invenergy’s proposed Clear River Energy Center would do such harm to Rhode Island’s ecology, its biodiversity, and its resilience to climate change that we are compelled to oppose this new power plant.
In my testimony to the Energy Facility Siting Board on behalf of the Conservation Law Foundation, I describe the unique habitat of the Rhode Island Borderlands (extending to the northwest corner of the state), the role that habitat corridors play in allowing wildlife to adapt to climate change, and the consequences of cutting off critical pathways of connectivity.
Invenergy’s permit application and wetlands addendum correctly note the impact that the power plant would have on the immediate site. But they omit the important, regional context. The relationship between the proposed location and the surrounding natural areas is fundamental to assessing the impact of development. Some locations provide more essential ecological services than others.
A few maps tell the story. NASA’s satellite image of lights visible at night (shown above) powerfully illustrates how distinctly the Borderlands stand out in the coastal corridor from Washington, D.C., to Boston. The area of dark green running along the Rhode Island–Connecticut border contains tens of thousands of acres of relatively unfragmented forest. There are very few places like it on the East Coast.
The area includes Rhode Island’s northwest corner, which The Nature Conservancy called out as biologically significant and worthy of conservation 20 years ago. Forest fragmentation is the major threat to its integrity.
The second set of maps focuses on connectivity – the degree to which animals can move freely across the landscape. Such movement is critical in maintaining genetic diversity in a population of plants or animals. Additionally, wildlife may need to escape a natural disaster, avoid encroaching human development, or adapt to seasonal changes in the availability of food, water, and shelter. Animals require reliable pathways to find those resources. When habitat connectivity is cut off, species that are unable to migrate or adapt to local conditions will not survive.
Connectivity becomes even more important as our climate changes. As temperature and precipitation patterns shift, many species will need to adjust their range to find suitable habitat. Warming temperatures are already driving many plants and animals to higher altitudes and higher latitudes.
The Nature Conservancy has mapped habitat connectivity corridors for the eastern United States to help identify priority areas for land protection. On the maps below, the green areas show where animals are able to move about freely. The blue areas show areas of concentrated flow. These blue bottlenecks or pinch points are especially important for conservation because of their irreplaceable nature. They are often the only pathway for a species to find new, suitable habitat.
The Clear River Energy Center would be built right on top of an essential pinch point for wildlife habitat connectivity. Invenergy’s proposal for a new power plant – and the associated pavement, light and noise pollution, wetland destruction and deforestation – at this pivotal junction would irreversibly disrupt one of the region’s healthiest ecosystems.
The state statute that created the Energy Facility Siting Board provides that the Board may only grant a license when an applicant has shown that “the proposed facility will not cause unacceptable harm to the environment.”
Our research and that of others indicates that the proposed power plant would cut off the ability of plants and animals to adapt to a changing climate, and undermine important ecological functions across an area that stretches far beyond the physical footprint of the facility. In my opinion, that is an unacceptable harm to the environment.