Alternative B – No Action Alternative. Under the No Action Alternative, all 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 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, and surface disturbance within the Covered Area would not be subject to additional conservation measures to minimize or 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 Area demonstrate moderate to very high wind erosion potential. Surface disturbance under the No Action Alternative would result in the removal of vegetation that would indirectly subject soils to increased wind erosion, 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 subject to the implementation of conservation measures to avoid surface disturbance in areas categorized as High and Intermediate Suitability DSL Habitat contained in the 2020 DSL CCAA. Removal of vegetation in dunelands, which are more susceptible to wind erosion from vegetation removal, may result in increases or decreases in acreage of dunes, or 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 extending beyond ...
Alternative B – No Action Alternative. Under the No Action Alternative, all Covered Activities would continue to engage in surface disturbing activities, such as construction, oil well pad development and drilling, sand mining, linear infrastructure construction, maintenance and operation, local government activities, and 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 vegetation. Participants enrolled in the TCP would limit surface disturbance of on up to 2,125 acres, thereby limiting disturbance or removal of vegetation. These participants would implement voluntary conservation measures including avoidance of areas suitable for the Covered Species, restoration, rehabilitation and erosion control measures to avoid, minimize, and mitigate the loss and degradation of vegetation (Service et al. 2011). Activities conducted by non-participants in the TCP are anticipated to continue at current levels, and surface disturbance within the Covered Area would not be subject to additional conservation measures to minimize or avoid impacts to vegetation. As a result, up to 34,690 acres may be disturbed over proposed duration of the CCAA, resulting in the disturbance or removal of vegetation 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 4.3, the removal of vegetation would indirectly subject soils to increased wind erosion, leading to the loss of soils, particularly the fine xxxxx particulates (Xxxxxxxxxx 1984; Muhs and Xxxxxxxx 1995, 2001; NRCS 2020). As described in Section 3.4, vegetation within the Covered Area was historically threatened by overgrazing (Xxxxxxxx and Xxxx 1998). Under the No Action Alternative, participants of the TCP would implement conservation measures to minimize impacts to vegetation from grazing, brush management, fence, water facilities and windmill construction and maintenance (Service et al. 2011). However, non- participants in the TCP would not be subject to the implementation of conservation measures activities to reduce potential impacts to vegetation. Under the No Action Alternative, conservation measures are discretionary, and impacts to vegetation from sectors not covered in the TCP or from non-participants not interested i...
Alternative B – No Action Alternative. Under the No Action Alternative, private, commercial and industrial activities, such as Covered Activities including construction, oil well pad development and drilling, sand mining, linear infrastructure construction, maintenance and operation, agriculture and ranching, and local government activities would continue within the Covered Area without the conservation benefits of the 2020 CCAA. Groundwater conservation for the Ogallala Aquifer would continue to be managed by the Llano Estacado Underground Water Conservation District; groundwater conservation for the Pecos Valley and Dockum Aquifers would continue to be implemented at the discretion of the landowner. Voluntary conservation measures would continue under the existing TCP (Service et al. 2011) to avoid and minimize impacts to surface disturbance would continue; however, there are no conservation measures in the TCP aimed at the reduction of water use or the protection or management of water resources. Therefore, the No Action Alternative would result in fewer voluntary conservation measures for groundwater resources barring any required reporting of water use to the state of Texas, and may lead to more groundwater use within the Covered Area compared to the Proposed Action Alternative.
Alternative B – No Action Alternative. Land ownership frequently changes as a result of population and development growth and is expected to continue to change under the No Action Alternative. Under the No Action Alternative, developers would continue their operations without limitation for purposes of DSL conservation. Development associated with the Covered Activities would not be restricted or precluded by Conservation Measures under the 2020 DSL CCAA. Restrictions to development would occur through other regulatory mechanisms (e.g., permits) and developers may choose to pursue other voluntary conservation programs. The extent and duration of development on new surfaces may result in temporary or permanent and localized or widespread changes or restrictions to land use, depending on the activity. Permanent conversion of existing land uses under the No Action Alternative may occur but would be limited to the extent allowed by the responsible agency and in accordance with applicable land use policies or regulations. Temporary and permanent changes to land use may result in delays for obtaining permits or leases due to additional agency involvement and expanded necessary approvals. As a result, impacts on land use and ownership under the No Action Alternative would be short- to long-term and minor to moderate. Under the No Action Alternative, there would not be the implementation of Conservation Measures that encourage or incentivize non-Participants to become Participants or to cooperate with Participants. As a result, stratification of lands within the Covered Area would continue, and there would be no cooperation between split estate surface and mineral owners or lessees to minimize new disturbances or develop approaches to development that avoid, minimize, or offset impacts from development on severed properties. The benefits provided under the Proposed Action related to addressing stratification issues would not be experienced under the No Action Alternative.
Alternative B – No Action Alternative. Under the No Action Alternative, voluntary conservation measures would continue under the TCP (Service et al. 2011) and other conservation programs (such as NRCS) to avoid and minimize potential impacts to wildlife habitat. However, surface disturbance by non-participants in these programs within the Covered Area would not be subject to additional conservation measures to minimize or avoid impacts to wildlife habitat. Under the No Action Alternative, conservation measures outside those defined in the TCP are discretionary and impacts to vegetation from sectors not covered in the TCP or other conservation programs, or from non-participants not interested in enrolling in these programs would continue at current levels. Surface disturbance from participants enrolled in the TCP would be limited (up to 2,125 acres). However, surface disturbance from non-participants of the TCP would continue to occur without conservation measures to avoid or minimize the disturbance or removal of vegetation. As a result, the No Action Alternative would result in short- to long-term, minor to moderate impacts similar to the Action Alternative, and minor, short- to long-term, benefits due to the disturbance limits under the TCP for its participants.
Alternative B – No Action Alternative. Under the No Action Alternative, voluntary conservation measures would continue under the TCP (Service et al. 2011) to avoid and minimize potential impacts to listed, proposed or candidate species (other than the Covered Species). However, surface disturbance by non-participants in the TCP within the Covered Area would not be subject to additional conservation measures to minimize or avoid impacts to the habitat of these species. Under the No Action Alternative, conservation measures outside those defined in the TCP are discretionary and impacts to habitat from sectors not covered in the TCP or from participants not interested in enrolling in the TCP would continue at current levels. Any potential impacts to habitats of State-listed, proposed, and candidate species would be minimized or avoided in compliance with Texas State law. If the Covered Species becomes Federally listed under the ESA and the Applicant and each potential Participant seek individual ITPs, for which DSL Habitat is used as a surrogate for incidental take, mitigation and avoidance measures may be implemented for listed species. However, these would be implemented on a project-by-project basis and only for areas of each project where a reasonable likelihood of take could not be avoided. As a result, the No Action Alternative would result in short- to long-term, minor to moderate impacts and short- to long-term benefits.
Alternative B – No Action Alternative. Under the No Action Alternative, the Service would not approve the Permit. Thus, the Proposed Action has no potential to affect historic properties. Given these findings, the Proposed Action will have no effect on cultural resources.
Alternative B – No Action Alternative. Under the No Action Alternative, MMC would continue to construct, operate, and close the Marigold Mine as analyzed in the NEPA actions listed in Appendix A and as authorized most recently in the 2019 Mackay Optimization Project (BLM 2019a), May 12, 2020 Minor Modification (BLM 2020b), July 2, 2020 Minor Modification (MMC 2020), 2020 revised Reclamation Permit 0108 (NDEP 2020), January 18, 2022 Minor Modification (BLM 2022a), and July 2, 2022 revised Reclamation Permit 0108 (NDEP 2022). Authorized activities include active mining through 2037 followed by mine closure activities. MMC is authorized to and would continue to conduct surface disturbance associated with the facilities and acreages provided under Existing/Authorized column in Table 4.
Alternative B – No Action Alternative. Under the No Action Alternative the proposed LA CREP II would not be implemented. Lands that would have been eligible for enrollment would remain in agricultural production. The continued use of land for agriculture would increase susceptibility to invasion by exotic species which are adapted to invade highly disturbed environments. Runoff of agricultural chemicals, animal wastes and sediment would also continue to degrade water quality and therefore potentially degrade habitat for native aquatic plants and animals.
Alternative B – No Action Alternative. If the LA CREP II were not implemented lands that could have been enrolled in the program would remain in agricultural production. None of the improvements expected to result from the program would be realized. Agricultural monocultures would remain in place and such homogeneous and highly disturbed habitat would continue to attract a limited number of animal species. The continuation of current agricultural practices is expected to result in runoff of agricultural chemicals and sediment which degrade aquatic habitat by increasing turbidity and contaminants and over-enriching waters, resulting in a reduction in light available to aquatic plants and ultimately less dissolved oxygen available to aquatic animals.
