10 



"In fact, the accumulation of 'scientific evidence' was 

 so sparce and unsupportable that Monsanto undertook, with 

 great financial expense, to create a truly scientific 

 research program. This was done to study not only the 

 habitat of the turtle, but also to observe the migratory 

 and living habits of the turtle. Further, to determine 

 if this turtle had any genetic relatives in other parts 

 of the country, chemical determinations and other 

 scientific evaluations were conducted on specimens of the 

 turtles to further identify generic similarities or dis- 

 similarities. 



A very complete research report is being prepared for 

 Monsanto which should give us a real indication as to true 

 facts in the case. 



Hugh, when we have our complete report, because of 

 your personal interest, I will see to it that you have 

 access to the information as I believe there may be other 

 proposed species on the endangered list that have been 

 placed there with insufficient data to support such a 

 proposal ." 



Monsanto made a substantial number of contacts to local officials in 

 Iowa and Illinois and the U.S. Senators and Representatives making similar 

 statements and implying that the U.S. Fish and Wildlife Service was ignoring 

 scientific data (an example is a letter dated January 16, 1980, to U.S. 

 Senate staffer Clarence Thomas). By mid-January 1980, the Service had 

 received a number of letters from U.S. Congressmen, including Senators John 

 Culver (Iowa) and John Danforth (Missouri), and Representative J. Leach 

 (Iowa), questioning FWS' activities with regard to the Illinois mud turtle. 

 Danforth chided the Service for its "apparently shabby treatment" of 

 Monsanto and stated that Monsanto had informed him that they had made 

 available to FWS data which "refuted" the conclusions of the study on 

 which the listing proposal was based. On February 4, 1980, Senator 

 R. Jepsen (Iowa) met with then Interior Department Secretary Cecil Andrus 

 in an attempt to dissuade the Department from proceeding with the listing. 



Prior to October 1979, biologists at the Office of Endangered Species 

 (OES) had received bi-weekly synopses of Monsanto's contractees work, but 

 these reports represented raw unanalyzed data. They were examined as 

 they were received and filed, but since a final report was due in October 

 which would summarize all work, no decisions were made concerning future 

 listing activities. No final report was received by FWS until January 1980. 



The question of the timing of LGL's final report eventually became 

 the focus of much misunderstanding. The following chronology is taken 

 from a letter dated February 29, 1980, from B. Rallaway of LOL to Harold J. 

 O'Connor of FWS. The first draft of the report detailing the results of 



