12 



Peer revfew of reports is often utilized by FWS, although it is by no 

 means mandatory. All respondants severely criticized the many conclusions 

 with little or no supporting data. Thus, at the public meetings in late 

 January, FWS representatives were disturbed at the way the report of 

 Springer and Gallaway (1979) had been used against the listing; at the 

 same time, LGL was disturbed that FWS had sent their draft report to 

 specialists when it had thought clear that FWS knew the report preliminary. 

 FWS was not aware that LGL knew nothing of the circulation of its report 

 marked "final." And since the report had been put to Congressmen as a 

 final report which should be used as evidence of FWS incompetency, FWS 

 felt obligated to have the report strictly scrutinized. Thus developed 

 an aura of hard feelings between FWS and LGL. 



In February and March, Monsanto continued to lobby to have the 

 listing withdrawn. In a letter dated March 3, 1980, Monsanto submitted 

 extensive comments to FWS in which they reiterated their position that 

 the turtle did not warrant federal protection. They again took a point 

 by point issue with nearly every statement in Brown and Moll (1978) 

 concerning Big Sand Mound and praised the LGL work, but this time devoted 

 extensive criticism of John Iverson's and OES' objectivity and credibility. 

 The letter also stated that electrophoretic work involving analyses of 

 proteins of heart, liver, kidney, and eye tissues had been investigated 

 although the results were not completely analyzed. This letter is 

 interesting because it first broaches the idea of an independent review 

 panel. The letter states: 



"Further, we are concerned about the disparity of treatment 

 given LGL's Final Report as opposed to the status report 

 prepared by Drs. Brown and Moll. We think it only fair that 

 LGL's Final Report, together with the addendum and supportive 

 data being supplied to the Service, be submitted to a blue- 

 ribbon panel of disinterested scientists for critical evalua- 

 tion. This same panel should also critically review the 

 status report and the data Drs. Brown and Moll submitted to 

 support the conclusions contained therein. We are prepared 

 to accept the decision of that panel as to what constitutes 

 the 'best scientific data' available as required by Section 

 4(b)(1) of the Endangered Species Act of 1973, as amended." 



On March 6, 1980, representatives of FWS and LGL met to discuss the 

 morphometric work conducted by John Bickham and his students. Copies of 

 the report on the taxonomic work (Bickham and Gallaway, 1980) were sub- 

 mitted for the administrative record; this report only contained morpho- 

 metric and karyological results. 



Iowa-Illinois Gas and Electric Co., owner of 80% of Big Sand Mound, 

 had been relatively neutral concerning the proposal and resulting contro- 

 versy. On March 7, they submitted additional comments in which they 



