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be required of an already large number of permits. A list of these permits 

 was requested in the hopes of quantifying economic burden, but careful 

 review revealed that none would have been impacted by the determination of 

 critical habitat. 



The significance of the controversy surrounding the proposal to list 

 K. f_. spooneri does not involve the failure to list one particular sub- 

 species in need of protection. Instead, it involves the recognition of the 

 precarious nature and foundation of laws designed to protect and preserve 

 genetic diversity on a species by species approach. The Endangered Species 

 Act of 1973 is a laudatory attempt to balance societal values with the 

 tendency to view "non-significant" plants and animals as undeserving of 

 much attention. However, by focusing attention on individual species, the 

 ecosystems on which they depend, so dramatically emphasized in the purposes 

 section of the Act, are ignored or at least overlooked. 



The sand prairie, exemplified by the assemblage of plants and 

 animals at Big Sand Mound, is indeed a unique ecosystem fast disappearing 

 in the face of modern agricultural practices. As such, it is this ecosystem 

 that is worth protecting, not just the Illinois mud turtle which depends 

 on it. During the extensive deliberations between industry and the 

 government, this idea seems to have been overlooked. 



Almost the entire controversy focused on one particular area. Big Sand 

 Mound, and indeed, only on ?.0% of Big Sand Mound. Regardless of motivations, 

 this emphasis shifted focus from habitats containing far fewer numbers of 

 turtles which are imminently threatened with modification. Unless attempts 

 are made soon to halt this destruction, these island ecosystems will be 

 lost. Methods for protection could include outright purchase, as the State 

 of Missouri is contemplating at Rose Pond, cooperative management agreements 

 between landowners and state and private conservation agencies such as The 

 Nature Conservancy, tax incentives for not destroying wetland habitats, and 

 education as to their importance. State and private agencies are free to 

 pursue these goals without listing by the federal government, but additional 

 incentive and priority would have been provided by doing so. 



The controversy involving Big Sand Mound not only slighted the 

 biological aspects of listing an endangered species, but also slighted 

 another company's efforts on behalf of an ecosystem approach to management 

 of unique areas. In all the press releases, newspaper and magazine 

 articles (for instance, Berman, 1981), and testimony presented before the 

 various committees of the U.S. Congress, the only company ever mentioned 

 in Monsanto. This is in spite of the fact that Iowa-Illinois Gas and 

 Electric Co. became involved in the conservation of Big Sand Mound, both 

 by declaring it a reserve and by funding numerous biological studies, as 

 soon as they had purchased the area and prior to any state or federal 

 concern for the Illinois mud turtle. This commitment continues even 

 though the subspecies has been withdrawn from consideration. To hear 



