Common use of Alternative B – No Action Alternative Clause in Contracts

Alternative B – No Action Alternative. ‌ Under the No Action Alternative, industry, local government and agricultural activities are anticipated to continue at current levels. The potential impacts to the Covered Species are anticipated to occur in the form of loss, modification, degradation, or fragmentation of DSL habitat. Surface disturbance within the Covered Area that may be located in DSL habitat would not be subject to additional conservation measures to avoid, minimize, or offset potential impacts to the Covered Species. In particular, there would be no required disturbance limits in areas of High and Intermediate Suitability DSL Habitat. As a result, there may be a loss of individuals or nests, or avoidance by individuals from areas where surface development activities are occurring in occupied habitat due to the use of heavy machinery and OHV, seismic activities, and other survey and exploration efforts associated with development. Conservation, protection, restoration, and reclamation may not occur or may occur at smaller scales relative to the Proposed Action. There would be no specific avoidance of high and intermediate suitability habitats other than where it overlaps with the TCP habitat definitions. Then it would be subjected to impacts from participants under the authorized impacts within the habitat classifications in the TCP. There would be no well density thresholds or limits on sand mining impacts. Therefore, there would be less happenstance conservation of the meta-populations and the four phylogenetic groups in the covered area identified by Xxxx et. al. (2020). So the impacts on species genetic representation, resilience and redundancy would be anticipated to be greater under this alterative. Conservation activities would be implemented at the discretion of the landowner or user at a project-specific scale for entities not enrolled in the TCP. As a result, long-term, moderate impacts would occur under the No Action Alternative, and any short- to long- term benefits that would occur under the No Action Alternative as a result of the TCP or conservation activities implemented by individual landowners or users might not be offset. Under the No Action Alternative, industries and landowners would operate and manage lands as they currently do with no additional requirements or incentives to minimize their impacts on the DSL beyond those that currently exist or are voluntarily implemented. Any beneficial effects or reduction of negative impacts on the DSL that may result from the implementation of the 2020 DSL CCAA would not occur under this alternative. The No Action Alternative would likely result in short- to long-term moderate to major impacts do to habitat loss and fragmentations and impacts on the genetic representation. The No Action Alternative is likely to provide minor, short- to long-term benefits through the TCP and ongoing land management actions of property owns.

Alternative B – No Action Alternative. ‌ Under the No Action Alternative, industryall Underlying Activities would continue engaging in surface disturbing activities, such as construction, oil well pad development and drilling, sand mining, linear infrastructure construction and operation, local government activities, and agricultural activities agriculture and ranching, within the Covered Area. Voluntary conservation measures would continue under the existing TCP (Service et al. 2011) to avoid and minimize impacts on soils. Participants enrolled in the TCP would limit surface disturbance of soils on up to 2,125 acres. These participants would implement voluntary conservation measures including avoidance of soils suitable for the Covered Species, restoration, rehabilitation and erosion control measures to avoid, minimize, and mitigate the loss and degradation of soils (Service et al. 2011). Activities conducted by non-participants in the TCP are anticipated to continue at current levels. The potential impacts to the Covered Species are anticipated to occur in the form of loss, modification, degradation, or fragmentation of DSL habitat. Surface and surface disturbance within the Covered Area that may be located in DSL habitat would not be subject to additional conservation measures to avoid, minimize, minimize or offset potential avoid impacts to soils. As a result, up to 34,690 acres may be disturbed over the term of the CCAA, resulting in the loss and alteration of soils from non-participant activities including vegetation clearing, grading, use of heavy machinery, construction of facilities, excavation, mining, application of caliche or other materials onto the surface, and application of herbicide to vegetation. As described in Section 3.3, soils within the Covered SpeciesArea demonstrate moderate to very high wind erosion potential. In particularSurface disturbance under the No Action Alternative would result in the removal of vegetation that would indirectly subject soils to increased wind erosion, there leading to the loss of soils, particularly the fine xxxxx particulates (Xxxxxxxxxx 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020). Industry sectors would not be no required subject to the implementation of conservation measures to avoid surface disturbance limits in areas of categorized as High and Intermediate Suitability DSL HabitatHabitat contained in the 2020 DSL CCAA. As a resultRemoval of vegetation in dunelands, there which are more susceptible to wind erosion from vegetation removal, may be a loss result in increases or decreases in acreage of individuals or nestsdunes, or avoidance by individuals from these dunes may shift in location across the landscape over short-term and long-term timeframes (Machenberg 1984; Muhs and Xxxxxxxx 1995, 2001; Xxxxxxx et al. 2013). Similar impacts of alteration in geomorphology of the dunes, including those in areas where surface development activities are occurring in occupied habitat due to extending beyond the use of heavy machinery and OHVactivity area, seismic activities, and other survey and exploration efforts associated with development. Conservation, protection, restoration, and reclamation may not occur or may occur at smaller scales relative to the Proposed Action. There would be no specific avoidance of high and intermediate suitability habitats other than where it overlaps with the TCP habitat definitions. Then it would be subjected to impacts from participants under the authorized impacts within the habitat classifications in the TCP. There would be no well density thresholds form of pile up of sand near structures or limits on removal of sand mining impacts. Therefore, there would be less happenstance conservation during the removal or alteration of the meta-populations and the four phylogenetic groups in the covered area identified by Xxxx et. al. vegetation (2020Machenberg 1984). So Winds carrying loose sand may harm adjacent vegetation via abrasion and sandblasting, thereby hindering plant recolonization in disturbed areas (Machenberg 1984). While these changes may occur under either Alternative, the impacts on species genetic representation, resilience and redundancy would be anticipated to be potential for greater dune vegetation disturbance under this alterative. Conservation activities would be implemented at the discretion of the landowner or user at a project-specific scale for entities not enrolled Alternative may result in the TCP. As a result, long-term, moderate impacts would occur under the No Action Alternative, and any short- to long- term benefits that would occur under the No Action Alternative as a result of the TCP or conservation activities implemented by individual landowners or users might not be offsetincreased erosion. Under the No Action Alternative, industries and landowners impacts to soils would operate and manage lands as they currently do with no additional requirements or incentives continue at current levels. Surface disturbance from participants enrolled in the TCP would continue but would be limited to minimize their impacts on the DSL beyond those that currently exist or are voluntarily implementedup to 2,125 acres. Any beneficial effects or reduction of negative impacts on the DSL that may result Surface disturbance from the implementation non-participants of the 2020 DSL CCAA TCP would not continue to occur under this alternativewithout conservation measures to avoid or minimize the loss or alteration of soils. The As a result, the No Action Alternative would likely result in short- to long-term moderate term, minor to major widespread impacts do to habitat loss as described above and fragmentations and impacts on the genetic representation. The No Action Alternative is likely to provide minor, minor short- to long-term term, localized benefits through the due to disturbance limits on TCP and ongoing land management actions of property ownsparticipants.

Alternative B – No Action Alternative. ‌ Under the No Action Alternative, industry, local government and agricultural activities are anticipated to continue at current levels. The potential impacts to the Covered Species are anticipated to occur in the form of loss, modification, degradation, or fragmentation of DSL habitat. Surface disturbance within the Covered Area that may be located in DSL habitat would not be subject to additional conservation measures or commitments to avoid, minimize, or offset potential impacts to the Covered Species. In particular, there would be no required disturbance limits in areas of High and Intermediate Suitability DSL Habitat. As a result, there may be a loss of individuals or nests, or avoidance by individuals from areas where surface development activities are occurring in occupied habitat due to the use of heavy machinery and OHV, seismic activities, and other survey and exploration efforts associated with development. Conservation, protection, restoration, and reclamation may not occur or may occur at smaller scales relative to the Proposed Action. There would be no specific avoidance of high and intermediate suitability habitats other than where it If disturbance overlaps with the TCP habitat definitions. Then , then it would be subjected to impacts from participants under the authorized impacts within the habitat classifications in the TCP. There would be no well density thresholds or limits on sand mining impacts. Therefore, there would be less happenstance conservation of the meta-populations and the four phylogenetic groups in the covered area Covered Area identified by Xxxx et. al. (2020). So , and the impacts on species genetic representation, resilience resilience, and redundancy would be anticipated to be greater under this alterative. Conservation activities would be implemented at the discretion of the landowner or user at a project-specific scale for entities not enrolled in the TCP. As a result, long-term, moderate impacts would occur under the No Action Alternative, and any short- to long- term benefits that would occur under the No Action Alternative as a result of the TCP or conservation activities implemented by individual landowners or users might not be offset. Under the No Action Alternative, industries and landowners would operate and manage lands as they currently do with no additional requirements or incentives to minimize their impacts on the DSL beyond those that currently exist or are voluntarily implemented. Any beneficial effects or reduction of negative impacts on the DSL that may result from the implementation of the 2020 DSL CCAA would not occur under this alternative. The No Action Alternative would likely result in short- to long-term moderate to major impacts do to associated with habitat loss and fragmentations fragmentation and impacts on the genetic representation. The No Action Alternative is likely to provide minor, short- to long-term benefits through the TCP and ongoing land management actions of property ownsowners.