Common use of Alternative A – Proposed Action Clause in Contracts

Alternative A – Proposed Action. ‌ The total maximum surface disturbance associated with the Covered Activities in the Covered Area is 34,940 acres. Surface disturbance during restoration, reclamation and re-grading would temporarily result in the disturbance of localized soils. Surface disturbance associated with the Covered Activities would be subject to Conservation Measures to reduce direct impacts to the soils and increase conservation of soils in the Covered Area. All Participants for all Covered Activities except the agriculture and ranching sectors would implement Conservation Measures to avoid new surface disturbance through coordination on use of existing infrastructure, access roads, and ROWs. Reduced development footprints are intended to reduce the amount of surface disturbance on Enrolled Properties. Implementing site specific plans to maximize use of existing infrastructure, access roads and ROWs and minimize the footprint of development, traffic and use of OHV would reduce the direct adverse impacts on soils pertaining to their removal and disturbance. Conservation Measures would be implemented to restore ROWs, reclaim abandoned oil well pads and roads, and re-grade disturbed areas. These activities would minimize the loss and alteration of soils in the Covered Area. The reduction of surface disturbance would also reduce wind erosion and vegetation removal (by preserving sand dune stabilizing vegetation), thereby indirectly reducing the loss and alteration of soils (Xxxxxxxxxx 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020). Under the Proposed Action, all Participants would be required to avoid High and Intermediate Suitability Habitat of the Covered Species for all Covered Activities subject to a set of sector-specific exceptions, and shift their operations out of DSL Habitat to areas categorized as Low Suitability Habitat or to areas with existing development (e.g., where oil well pad densities are greater than 13 xxxxx pads/mi2). Dynamic dunelands, which are more susceptible to wind erosion from vegetation removal, are found in the High and Intermediate Suitability Habitat. By shifting activities away from dunelands to relatively flatter and more stable areas less susceptible to wind erosion (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020), soil losses and alterations would be reduced. Conservation Measures would be implemented for Covered Activities related to sand mining including limiting annual surface disturbance to 60 acres, total disturbance per mine on enrolled parcel to 1,380 acres, and total surface disturbance for the entire sector to 16,560 acres for the term of the proposed 2020 DSL CCAA. Caps on new surface disturbance would limit to new surface disturbance in the Covered Areas to less than 6% (16,560 acres) of DSL Habitat in the Covered Area (287,327 acres). All new surface disturbances would be subject to offsets either through payment of fees that would be used for Conservation Actions including restoration and reclamation of disturbed areas or through conservation of areas similar to those subject to disturbance at a 1:1 acre ratio. Conservation Measures to reduce and manage use of groundwater for the sand mining industry would reduce the amount of water used and help maintenance of ground water needed to stabilize sand deposits beneath the dunes and supply water for vegetation on the dunes, thereby indirectly reducing impacts to soils in these areas (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; Xxxxxxxx and Xxxx 1998). Soil loss and alteration from the Covered Activities would be reduced under the Proposed Action through avoidance and conservation of High and Intermediate Suitability Habitat containing dynamic dunelands and through reduced surface disturbance. In addition, a portion of the fees collected for participation in the proposed CCAA may be used to purchase conservation easements to preserve DSL habitat and its associated vegetation communities in large, continuous blocks for at least the life of the 2020 DSL CCAA, thereby reducing the areas of soil disturbance and the conservation of existing soils if utilized by the administrator. As a result, the Proposed Action is likely result in short to long-term, minor to major impacts from disturbance of surface soil and removal of sand sediments in the dunes by disturbing the dynamics of the dunes geomorphology; and minor short- -term benefits to soils in the Covered Area will occur through implementation of minimization measures and caps on annual surface disturbance by mine participants.

Alternative A – Proposed Action. ‌ The total maximum surface disturbance associated with Under the Proposed Action, Participants engaged in Covered Activities would implement Conservation Measures (see Section 2.1.4) to reduce the impacts of the Covered Activities in the Covered Area is 34,940 acres. Surface disturbance during restoration, reclamation and re-grading would temporarily result in the disturbance of localized soils. Surface disturbance associated with the Covered Activities would be subject to Conservation Measures to reduce direct impacts to the soils and increase conservation of soils in within the Covered Area. All Participants for all Covered Activities except the agriculture and ranching sectors would implement The Conservation Measures are designed to provide a net conservation benefit by reducing and eliminating threats to the Covered Species through avoiding and offsetting the amount of anticipated take of the Covered Species, which is represented by the acreage of disturbance or loss of DSL Habitat. Under the Proposed Action, the Participants would avoid or minimize new surface disturbance through disturbances including coordination on between the 2020 DSL CCAA Administrator and non-Participants to maximize use of existing infrastructure, access roads, and ROWs. Reduced development footprints are intended to reduce the amount of surface disturbance on Enrolled Properties. Implementing site specific plans to maximize use of existing infrastructure, access roads and ROWs rights-of-way (ROW) and minimize the footprint of development, traffic traffic, and use of OHV consistent with the terms of the CCAA. The Participants engaging in Covered Activities associated with oil and gas, sand mining operations, renewable energy operations, and linear infrastructure would reduce avoid new surface disturbance in areas categorized as High or Intermediate Suitability DSL Habitat under the direct adverse impacts on soils pertaining Texas State University model (Hardy et al. 2018), subject to their removal certain exceptions and disturbance. requirements including disturbance limits, payment of Habitat Conservation Measures would be implemented to restore ROWsFees, reclaim abandoned feasibility constraints, and specified thresholds of oil well pads and roads, and re-grade disturbed pad densities. Participants conducting seismic activities would refrain from using heavy machinery in these areas. These activities Participants conducting agriculture or ranching Covered Activities would minimize the loss also refrain from initiating new or increased levels of agricultural and alteration of soils ranching in the Covered Areaareas categorized as High or Intermediate Suitability DSL Habitat. The reduction of Sand mining Participants would implement an annual limit on new surface disturbance would also reduce wind erosion on their Enrolled Properties and vegetation removal (by preserving sand dune stabilizing vegetation), thereby indirectly reducing the loss and alteration of soils (Xxxxxxxxxx 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020). Under the Proposed Action, all Participants would be required to avoid High and Intermediate Suitability Habitat of areas where site-specific surveys for the Covered Species for all Covered Activities subject to a set indicate potential presence based on ground cover types or detection of sector-specific exceptionsindividuals, and shift their operations out of DSL Habitat to areas categorized unless that new surface disturbance can be offset as Low Suitability Habitat or to areas with existing development (e.g., where oil well pad densities are greater than 13 xxxxx pads/mi2). Dynamic dunelands, which are more susceptible to wind erosion from vegetation removal, are found described in the High and Intermediate Suitability Habitat. By shifting activities away from dunelands to relatively flatter and more stable areas less susceptible to wind erosion (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020), soil losses and alterations would be reduced. Conservation Measures would be implemented for Covered Activities related to sand mining including limiting annual surface disturbance to 60 acres, total disturbance per mine on enrolled parcel to 1,380 acres, and total surface disturbance for the entire sector to 16,560 acres for the term of the proposed 2020 DSL CCAA. Caps on new surface disturbance The 2020 DSL CCAA Administrator would limit to new surface disturbance in the Covered Areas to less than 6% (16,560 acres) of DSL Habitat work with Participants and non- Participants in the Covered Area (287,327 acres)to limit disturbance to 34,940 acres of DSL Habitat, or approximately 12% of the Covered Area, over the CCAA and permit term. All new surface disturbances would be Although avoidance is subject to certain exceptions, and there may still be loss, modification, and fragmentation of habitat, the disturbance limits and offsets either through payment are still anticipated to reduce threats to the Covered Species by minimizing the threat of habitat loss. The CCAA as written does not address the genetic components of the species identified in the populations identified by Xxxx et al 2020. Prior to new disturbance of DSL Habitat, Participants would pay fees that would be used for Conservation Actions Actions, including restoration and reclamation of disturbed areas areas, or through conservation of areas would conserve lands similar to those subject to disturbance at a 1:1 acre ratioratio (see Chapter 8.4 of the 2020 DSL CCAA). Fees would be used to protect, restore, reclaim, and re-grade existing and newly disturbed areas. Participants conducting Covered Activities in the Covered Activities would also restore, reclaim and re-grade disturbed areas, as determined by participation requirements of the 2020 DSL CCAA. During restoration, reclamation and re-grading activities, the Covered Species may be inadvertently killed through use of heavy equipment during ground disturbing activities. Prioritizing avoidance of High or Intermediate Suitability DSL Habitat throughout the Covered Area would temporarily and permanently benefit populations of the Covered Species by not curtailing movement and distribution of individuals present in those habitat areas (Xxxxxxxx et al. 2013; Xxxxxxx et al. 2016; Xxxx and Xxxxx 1998; Xxxxx et al. 2018). Fragmentation of habitat may be reduced through incentives and prioritization of Covered Activities outside of areas used by Covered Species and into areas of existing disturbance. These measures and other measures to exclude entry or allow escape of the Covered Species into or from areas of disturbance may also reduce potential loss of individuals or of nests that would be avoided as a result of the Conservation Measures. There is no consideration specifically in the CCAA for reducing fragmentation or habitat loss to the point where meta-populations and the four phylogenetic groups in the covered area identified by Chan et. al. (2020) can be maintained. While the general avoidance of high and intermediate suitability habitats may reduce these impacts, the exceptions to this avoidance reduces the effectiveness of these conservation measures in maintaining genetic representation, resilience and redundancy need to ensure the species long term survives. Conservation Measures designed to reduce and manage conserve groundwater may indirectly benefit the Covered Species if use of groundwater for negatively affects the sand mining industry would reduce vegetation or dune structure of occupied or potentially suitable habitat of the amount of water used and help maintenance of ground water needed to stabilize sand deposits beneath the dunes and supply water for vegetation on the dunes, thereby indirectly reducing impacts to soils in these areas Covered Species (Machenberg Xxxxxxxxxx 1984; Muhs and Xxxxxxxx 1995, 2001; Xxxxxxxx and Xxxx 1998). Soil loss However, the pumping of subsurface ground water from sand mines is likely to result in impacts to surrounding vegetation, especially when exasperated by drought conditions. Information on groundwater supply and alteration from use is limited in the Covered Activities would be reduced Area; therefore, the extent of benefits this measure may have on the Covered Species is unknown. Loss, modification, and fragmentation of habitat may occur under the Proposed Action through Action; however, avoidance of priority habitat, disturbance limits, and conservation of High offsets would temporarily and Intermediate Suitability Habitat containing dynamic dunelands permanently reduce impacts to the Covered Species and through reduced surface disturbanceminimize habitat loss. In addition, a portion Implementation of the fees collected for Conservation Measures as feasible may result in temporary and permanent protection, conservation, and restoration of DSL Habitat throughout the Covered Area and may result in an increase in likelihood of use by the Covered Species relative to the amount of participation in the proposed CCAA may be used to purchase conservation easements to preserve DSL habitat and its associated vegetation communities in large, continuous blocks for at least the life of the 2020 DSL CCAA, thereby reducing the areas of soil disturbance and the conservation of existing soils if utilized by the administrator. As a result, the Proposed Action is likely to result in short short- to long-term, minor term moderate to major impacts from disturbance habitat loss, fragmentation, and impacts on the genetic representation. It is likely to have minor to moderate, short- to long-term benefits may be realized depending on the level of surface soil enrollment, consistency of avoidance and removal of sand sediments in the dunes by disturbing the dynamics of the dunes geomorphology; and minor short- -term benefits minimization to soils in the Covered Area will occur through implementation of minimization measures and caps protect habitat as it cannot be restored on annual surface disturbance by mine participantshuman timeframe.

Alternative A – Proposed Action. ‌ The total maximum surface disturbance associated with Under the Proposed Action, Participants engaged in Covered Activities would implement Conservation Measures (see Section 2.1.4 above) to reduce the impacts of the Covered Activities in the Covered Area is 34,940 acres. Surface disturbance during restoration, reclamation and re-grading would temporarily result in the disturbance of localized soils. Surface disturbance associated with the Covered Activities would be subject to Conservation Measures to reduce direct impacts to the soils and increase conservation of soils in within the Covered Area. All Participants for all Covered Activities except the agriculture and ranching sectors would implement The Conservation Measures are designed to provide a net conservation benefit by reducing and eliminating threats to the Covered Species through avoiding and offsetting the amount of anticipated take of the Covered Species, which is represented by the acreage of disturbance or loss of DSL Habitat. Under the Proposed Action, the Participants would avoid or minimize new surface disturbance through disturbances including coordination on between the 2020 DSL CCAA Administrator and non-Participants to maximize use of existing infrastructure, access roads, and ROWs. Reduced development footprints are intended to reduce the amount of surface disturbance on Enrolled Properties. Implementing site specific plans to maximize use of existing infrastructure, access roads and ROWs rights-of-way (ROW) and minimize the footprint of development, traffic traffic, and use of OHV consistent with the terms of the CCAA. The Participants engaging in Covered Activities associated with oil and gas, sand mining operations, renewable energy operations, and linear infrastructure would reduce avoid new surface disturbance in areas categorized as High or Intermediate Suitability DSL Habitat under the direct adverse impacts on soils pertaining Texas State University model (Hardy et al. 2018), subject to their removal certain exceptions and disturbance. requirements including disturbance limits, payment of Habitat Conservation Measures would be implemented to restore ROWsFees, reclaim abandoned feasibility constraints, and specified thresholds of oil well pads and roads, and re-grade disturbed pad densities. Participants conducting seismic activities would refrain from using heavy machinery in these areas. These activities Participants conducting agriculture or ranching Covered Activities would minimize the loss also refrain from initiating new or increased levels of agricultural and alteration of soils ranching in the Covered Areaareas categorized as High or Intermediate Suitability DSL Habitat. The reduction of Sand mining Participants would implement an annual limit on new surface disturbance would also reduce wind erosion on their Enrolled Properties and vegetation removal (by preserving sand dune stabilizing vegetation), thereby indirectly reducing the loss and alteration of soils (Xxxxxxxxxx 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020). Under the Proposed Action, all Participants would be required to avoid High and Intermediate Suitability Habitat of areas where site-specific surveys for the Covered Species for all Covered Activities subject to a set indicate potential presence based on ground cover types or detection of sector-specific exceptionsindividuals, and shift their operations out of DSL Habitat to areas categorized unless that new surface disturbance can be offset as Low Suitability Habitat or to areas with existing development (e.g., where oil well pad densities are greater than 13 xxxxx pads/mi2). Dynamic dunelands, which are more susceptible to wind erosion from vegetation removal, are found described in the High and Intermediate Suitability Habitat. By shifting activities away from dunelands to relatively flatter and more stable areas less susceptible to wind erosion (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020), soil losses and alterations would be reduced. Conservation Measures would be implemented for Covered Activities related to sand mining including limiting annual surface disturbance to 60 acres, total disturbance per mine on enrolled parcel to 1,380 acres, and total surface disturbance for the entire sector to 16,560 acres for the term of the proposed 2020 DSL CCAA. Caps on new surface disturbance The 2020 DSL CCAA Administrator would limit to new surface disturbance in the Covered Areas to less than 6% (16,560 acres) of DSL Habitat work with Participants and non- Participants in the Covered Area (287,327 acres)to limit disturbance to 34,940 acres of DSL Habitat, or approximately 12 percent of the Covered Area, over the 23-year CCAA and Permit term. All new surface disturbances would be Although avoidance is subject to certain exceptions, and there may still be loss, modification, and fragmentation of habitat, the disturbance limits and offsets either through payment are still anticipated to reduce threats to the Covered Species by minimizing the threat of habitat loss. Prior to new disturbance of DSL Habitat, Participants would pay fees that would be used for Conservation Actions Actions, including restoration and reclamation of disturbed areas areas, or through conservation of areas would conserve lands similar to those subject to disturbance at a 1:1 acre ratio. Conservation Measures to reduce and manage use of groundwater for the sand mining industry would reduce the amount of water used and help maintenance of ground water needed to stabilize sand deposits beneath the dunes and supply water for vegetation on the dunes, thereby indirectly reducing impacts to soils in these areas ratio (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; Xxxxxxxx and Xxxx 1998). Soil loss and alteration from the Covered Activities would be reduced under the Proposed Action through avoidance and conservation of High and Intermediate Suitability Habitat containing dynamic dunelands and through reduced surface disturbance. In addition, a portion of the fees collected for participation in the proposed CCAA may be used to purchase conservation easements to preserve DSL habitat and its associated vegetation communities in large, continuous blocks for at least the life see Chapter 8.4 of the 2020 DSL CCAA). Fees would be used to protect, thereby reducing the areas of soil disturbance restore, reclaim, and the conservation of re-grade existing soils if utilized by the administratorand newly disturbed areas. As a result, the Proposed Action is likely result in short to long-term, minor to major impacts from disturbance of surface soil and removal of sand sediments in the dunes by disturbing the dynamics of the dunes geomorphology; and minor short- -term benefits to soils Participants conducting Covered Activities in the Covered Area will occur Activities would also restore, reclaim and re-grade disturbed areas, as determined by participation requirements of the 2020 DSL CCAA. During restoration, reclamation and re-grading activities, the Covered Species may be inadvertently killed through implementation use of minimization measures and caps on annual surface disturbance by mine participantsheavy equipment during ground disturbing activities.

Alternative A – Proposed Action. ‌ The total maximum surface disturbance associated with the Covered Activities in the Covered Area is 34,940 acres. Surface disturbance during restoration, reclamation and re-grading would temporarily result in the disturbance of localized soils. Surface disturbance associated with the Covered Activities would be subject to Conservation Measures to reduce direct impacts to the soils and increase conservation of soils in the Covered Area. All Participants for all Covered Activities except the agriculture and ranching sectors would implement Conservation Measures to avoid new surface disturbance through coordination on use of existing infrastructure, access roads, and ROWs. Reduced development footprints are intended to reduce the amount of surface disturbance on Enrolled Properties. Implementing site specific plans to maximize use of existing infrastructure, access roads and ROWs and minimize the footprint of development, traffic and use of OHV would reduce the direct adverse impacts on soils pertaining to their removal and disturbance. Conservation Measures would be implemented to restore ROWs, reclaim abandoned oil well pads and roads, and re-grade disturbed areas. These activities would minimize the loss and alteration of soils in the Covered Area. The reduction of surface disturbance would also reduce wind erosion and vegetation removal (by preserving sand dune stabilizing vegetation), thereby indirectly reducing the loss and alteration of soils (Xxxxxxxxxx 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020). Under the Proposed Action, all Participants would be required to avoid High and Intermediate Suitability Habitat of the Covered Species for all Covered Activities subject to a set of sector-specific exceptions, and shift their operations out of DSL Habitat to areas categorized as Low Suitability Habitat or to areas with existing development (e.g., where oil well pad densities are greater than 13 xxxxx pads/mi2). Dynamic dunelands, which are more susceptible to wind erosion from vegetation removal, are found in the High and Intermediate Suitability Habitat. By shifting activities away from dunelands to relatively flatter and more stable areas less susceptible to wind erosion (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020), soil losses and alterations would be reduced. Conservation Measures would be implemented for Covered Activities related to sand mining including limiting annual surface disturbance to 60 acres, total disturbance per mine on enrolled parcel to 1,380 acres, and total surface disturbance for the entire sector to 16,560 acres for the 23-year term of the proposed 2020 DSL CCAA. Caps on new surface disturbance would limit to new surface disturbance in the Covered Areas to less than 6% (16,560 acres) of DSL Habitat in the Covered Area (287,327 acres). All new surface disturbances would be subject to offsets either through payment of fees that would be used for Conservation Actions including restoration and reclamation of disturbed areas or through conservation of areas similar to those subject to disturbance at a 1:1 acre ratio. As discussed above (see Sections 4.2.1 and 4.3.1), Conservation Measures to reduce and manage use of groundwater for the sand mining industry would reduce the amount of water used and help maintenance of ground water groundwater needed to stabilize sand deposits beneath the dunes and supply water for vegetation on the dunes, thereby indirectly reducing impacts to soils in these areas (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; Xxxxxxxx and Xxxx 1998). . Soil loss and alteration from the Covered Activities would be reduced under the Proposed Action through avoidance and conservation of High and Intermediate Suitability Habitat containing dynamic dunelands and through reduced surface disturbance. In addition, a portion of the fees collected for participation in the proposed CCAA may be used to purchase conservation easements and other protections to preserve DSL habitat and its associated vegetation communities in large, continuous blocks for at least the life of the 2020 DSL CCAA, thereby reducing the areas of soil disturbance and the conservation of existing soils if utilized by the administrator. As a result, the Proposed Action is likely result in short to long-term, minor to major short- term impacts from disturbance of surface soil and removal of sand sediments in the dunes by disturbing the dynamics of the dunes geomorphology; and minor to moderate short- -term to long-term benefits to soils in the Covered Area will occur through implementation of minimization measures measures, best management practices, and caps on annual surface disturbance by mine participants.

Alternative A – Proposed Action. ‌ The total maximum surface disturbance associated with the Covered Activities in the Covered Area is 34,940 acres. Surface disturbance during restorationunder the Proposed Action would occur, reclamation and re-grading would temporarily result resulting in the disturbance or removal of localized soilsvegetation. Surface disturbance associated with the Covered Activities would be subject to Conservation Measures to reduce direct impacts to vegetation, such as limiting the soils amount of acres disturbed and increase encouraging smaller disturbance footprints. Under the Proposed Action, the entire area where surface disturbance would occur would be subject to Conservation Measures to reduce impacts to vegetation and augment conservation of soils vegetation in the Covered Area. All Participants for all Covered Activities except the agriculture and ranching sectors sector and local governments would implement Conservation Measures to avoid new surface disturbance through coordination on use of existing infrastructure, access roads, and ROWs. Reduced development footprints are intended to reduce the amount of surface disturbance on Enrolled Properties. Implementing site specific plans to maximize use of existing infrastructure, access roads roads, and ROWs and minimize the footprint of development, traffic and use of OHV OHV. Implementation of site-specific plans would reduce the direct adverse impacts on soils vegetation pertaining to their removal and disturbance. Conservation Measures would be implemented to restore and reclaim ROWs, reclaim abandoned oil well pads and roads, re-vegetate disturbed areas with native plants, and re-grade disturbed areas. All surface disturbance associated with Covered Activities except the agriculture and ranching sector must be offset as described for soils (Section 4.3.1 above). These activities would reduce and minimize the loss disturbance, removal or modification of vegetation during restoration, reclamation and alteration of soils in re-grading. Over the long-term, these activities would help reestablish vegetation throughout the Covered Area. The reduction Area and would not change the overall viability of surface disturbance would also reduce wind erosion and vegetation removal (by preserving sand dune stabilizing vegetation)plant communities, thereby indirectly reducing the loss and alteration of soils (Xxxxxxxxxx 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020)but it is not clear whether full restoration is likely to occur. Under the Proposed Action, all Participants would be required to avoid High and Intermediate Suitability Habitat of the Covered Species for all Covered Activities subject to a narrow set of sector-specific exceptions, and shift their operations out of DSL Habitat Habitat, to areas categorized as Low Suitability Habitat Habitat, or to areas with existing development development. Honey mesquite is an invasive species (e.g., where oil well pad densities are greater than 13 xxxxx pads/mi2). Dynamic dunelands, which are more susceptible to wind erosion from vegetation removal, are NRCS 2020b) found in the High and Intermediate Low Suitability Habitat. By shifting activities away from dunelands Covered Activities to relatively flatter and more stable Low Suitability areas less susceptible to wind erosion (Machenberg 1984; Muhs and Xxxxxxxx 1995that may contain honey mesquite, 2001; NRCS 2020), soil losses and alterations this invasive species would be reducedremoved as part of development activities. Minimizing disturbance in High and Intermediate Suitability habitat would reduce native vegetation removal, including vegetation that provides habitat for the Covered Species, such as the shinnery oak. Conservation Measures are also aimed at reducing the spread of invasive plant species by avoiding non- native vegetation; using habitat appropriate native vegetation and best management practices, such as cleaning vehicles coming into the area to remove mud and seeds; and identifying and removing any invasive vegetation incidentally introduced during the Covered Activities. These proposed measures may reduce competition of available resources between native and invasive plant species (Xxxxxxxxxx 1984 Xxxxxxxx and Xxxx 1998). Aerial application of herbicides would be avoided to reduce risk of herbicide drift to non-target areas and thus measure and control of invasive plant species. These activities would reduce invasive plant species and would support native vegetation and vegetation communities, including those that provide habitat for the Covered Species. Conservation Measures would be implemented for Covered Activities related to the sand mining including limiting caps on annual surface disturbance and offsets of surface disturbance, as described in Section 4.3, Soils. Limits to 60 acres, total disturbance per mine on enrolled parcel to 1,380 acres, and total surface disturbance for the entire sector to 16,560 acres for the term of the proposed 2020 DSL CCAA. Caps on new surface disturbance would limit to new surface disturbance in minimize or avoid the Covered Areas to less than 6% removal of vegetation. As discussed above (16,560 acres) of DSL Habitat in the Covered Area (287,327 acressee Sections 4.2.1, 4.3.1, and 4.4.1). All new surface disturbances would be subject to offsets either through payment of fees that would be used for Conservation Actions including restoration and reclamation of disturbed areas or through conservation of areas similar to those subject to disturbance at a 1:1 acre ratio. , Conservation Measures to reduce and manage use of groundwater for the sand mining industry could reduce impacts on vegetation and vegetation communities, particularly if they reduce any pumping from perched aquifers. Conservation Measures would reduce the amount minimize or avoid disturbance to or removal or modification of water used vegetation during surface disturbance, restoration, reclamation, and help maintenance of ground water needed to stabilize sand deposits beneath the dunes and supply water for vegetation on the dunes, thereby indirectly reducing impacts to soils re-grading activities. Where surface disturbance would occur in these areas (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; Xxxxxxxx and Xxxx 1998). Soil loss and alteration from the Covered Activities would be reduced under the Proposed Action through avoidance and conservation of High and Intermediate Suitability Habitat containing dynamic dunelands and through reduced surface disturbance. In additionArea, a portion of the fees collected for participation in the proposed 2020 DSL CCAA may could be used to purchase conservation easements and other protections to preserve DSL habitat and its associated vegetation communities in large, continuous blocks for at least the life 23-year term of the 2020 DSL CCAA, thereby reducing the areas of soil surface disturbance and removal of vegetation. Conservation Measures would help minimize disturbance to vegetation and would help support the conservation re- establishment of existing soils if utilized by vegetation communities over the administratorlong-term. As a result, the Proposed Action is would likely result in short to longshort-termterm , minor impacts (i.e., disturbance or change to major impacts from disturbance of surface soil and removal of sand sediments in the dunes by disturbing the dynamics of the dunes geomorphology; vegetation communities) and minor short- -term and long-term benefits to soils vegetation in the Covered Area will occur through implementation of minimization measures and caps on annual surface disturbance by mine participantsArea. Given these findings, the Proposed Action would not result in significant impacts to vegetation resources.