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• There is currently a lack of reliable information on the amount of deposited mercury and <br /> selenium that eventually enters occupied and critical habitat and becomes available to be <br /> taken up by the four endangered fish species. <br /> • The analysis is confounded by other sources of selenium. <br /> • The analysis is especially confounded by other sources of mercury, a global pollutant, <br /> which also contribute to the amounts available to be taken up by the four endangered fish <br /> species. <br /> • There is currently a lack of information regarding the specific effects of elevated mercury <br /> and selenium on any of the four endangered fish. Assumptions can be drawn only from <br /> information relative to other fish species. <br /> These limitations make it difficult to precisely describe the effects to individuals of the four <br /> endangered fish species. To satisfy Congress's direction in 7(a)(2)regarding ensuring that an <br /> action not jeopardize the species, OSMRE and the Service must use the best available <br /> information and basic conservation biology principles to explore the overall impact to the <br /> populations that are likely to occur and how those effects relate to the likelihood of Jeopardy. <br /> The OSMRE has committed to a conservation action--an analysis of mercury concentrations in <br /> fish tissue in the Yampa and White Rivers--as described above. The results of this effort will <br /> help to fill information gaps noted above and to provide data to inform the reasonableness of <br /> assumptions that have to be made to move the analysis forward. And, as provided for in the <br /> regulations, reinitiation of this consultation is triggered if new information reveals effects to the <br /> species in a manner or to an extent that was not considered in this analysis. <br /> In the discussion below we describe the effects of the action on the four endangered fish. There <br /> are many uncertainties and unanswered questions,however, leading us to necessarily make some <br /> reasonable assumptions. Some of these unanswered questions will be addressed through the <br /> mercury fish tissue analysis as described above. As OSMRE states in the BA, the primary <br /> impact from coal combustion to threatened and endangered species and their critical habitats is <br /> the emission and subsequent deposition of mercury and selenium. We agree, and discuss these <br /> effects below. <br /> 4.1 Emissions from the Craig Generating Station <br /> 4.1.1 Mercury <br /> Mercury is a naturally occurring element. It can be found in soils and the atmosphere, as well as <br /> water bodies. Mercury is contained in coal and can be released upon combustion. Atmospheric <br /> transport and deposition is an important mechanism for the global deposition of mercury (EPRI <br /> 2014), as it can be transported over large distances from its source regions and across continents. <br /> It is considered a global pollutant. Atmospheric mercury is primarily inorganic and is not <br /> biologically available. However, once this mercury is deposited to the earth, it can be converted <br /> into a biologically available form, methylmercury (MeHg),through a process known as <br /> 43 <br />