representatives from Monsanto presented testimony at the Endangered 

 Species Act oversight hearings for the subcommittee chaired by Congress- 

 man John Breaux. Prior to that date, Iowa-Illinois Gas and Electric Co. 

 (in a letter dated August 23, 1978) and Monsanto (in a meeting at the 

 Office of Endangered Species, Washington, O.C. , in September) both 

 recommended redrawing the boundaries of the proposed critical habitat to 

 more accurately reflect the biological needs and habitat use of the 

 turtle. As previously noted, Monsanto also outlined a series of manage- 

 ment and research proposals suggested by their consultant, LfiL Ecological 

 Research Associates. The Service concurred with the need to slightly 

 modify boundaries and with the management proposals as set forth. 



Questions concerning data accuracy and taxonomic status were briefly 

 raised, and the Service outlined its sources for listing and requested 

 additional data if available. Representatives from Monsanto then presented 

 a draft copy of Iverson's (1979) taxonomic review, stating that the data 

 clearly showed that K. f_. spooneri was not valid; in fact, this was in 

 direct contrast to tlTe conclusions of the paper. Two important points 

 were made clear to Monsanto at the meeting: 1) that there were more data 

 used in the proposal than sole reliance on the Brown and Moll (1978) 

 report, and 2) that to qualify for listing, species, subspecies, or popu- 

 lations were eligible. Thus, taxonomic status might be an interesting 

 biological problem if questions had been raised prior to proposal, but 

 taxonomic uncertainty is not necessarily a weakness in a proposal, such 

 that it should be invalidated. Disjunct populations of the American 

 crocodile ( Crocodylus acutus ) and Pine Barrens treefrog ( Hyla andersonii ) 

 had previously been listed under provisions of the Act. 



In the Congressional oversight hearings, Monsanto severely criticized 

 the U.S. Fish and Wildlife Service, claiming that documents used in the 

 proposal were unscientific and full of suppositions, innuendoes, and 

 speculation. It called the proposal "deplorable." In addition, Monsanto 

 claimed that their proposals to change boundary lines, reports of work 

 already completed, and their management recommendations, never were 

 acknowledged. Such was not the case. Monsanto concluded their testimony, 

 "It would appear that there should be some way to spend our resources on 

 those problems that are worthy of immediate and long-range solution; the 

 most important ones; and not expend our resources on some fringe matters." 

 The conservation of J<. f^. spooneri was clearly perceived as a fringe 

 matter. 



A letter dated November 14, 1979, from Earl C. Spurrier, nirector of 

 Government Relations for Monsanto, to Hubert L. Harris, U.S. Assistant 

 Director for Congressional Relations, gives the earliest indication that 

 the results of the research of Monsanto's consultants may have been antic- 

 ipated, in spite of the fact that the data were then not fully analyzed 

 (letter dated February 29, 1980, from B. Gallaway, LGL , to Harold J. 

 O'Connor, Acting Associate Director - Federal Assistance, U.S. Fish and 

 Wildlife Service). In this letter, Mr. Spurrier states: 



