CHAPTER 1 Historic and Current Conservation Efforts

Left out that there are three petitions before USFWS for the listing of the gopher tortoise throughout the state of Florida.

Disease

This section is worse than before. Please list the sites with 200-300 shells. Our follow-ups did not find this to be the case. Also, data on Sanibel indicates that 1997 figure is off by a great deal.

This whole section misses the key points on disease that need to be addressed in the management plan. This does not reflect the real world but a Mary Brown bias.

Pg 14 Small developments. If this includes single family homes then this simply is a cop out to avoid handling the greatest impacting development in the state and with the largest potential numbers of TAKE despite permitting.

Last paragraph about entombment. Tom Connley’s information, along with the UF study which provides data on single-family developments in Florida provide a good indication that the lack of permitting and enforcement is leading to a level of entombment of tortoises, far greater than the previous permitted form.

Chapter 4

Ten or fewer permits are basically the same permits generally addressing the Single Family Home Scenario. THIS PERMIT SYSTEM HAS NO CONSEVATION VALUE. It is voluntary because there is no indicated enforcement. Only 7000 of these permits have been let and most of them to consultants, not homeowners. Others can be traced to neighbors complaining and forcing permits. There is good evidence that tortoises are destroyed on these sites during clearing and construction or the tortoise is exposed to a backyard with possible predatory dogs, cats, and lawnmowers. If investigated carefully and it should be by FWC, it appears that this one classification of permitting continues the Take of tortoises per year to more than 25,000. There should be a specific date required by the Commission for this permitting to change to provide conservation value. We recommend no less than 12 months.

Page 50-Current studies on tortoise genetics indicate that a viable population is 2. Viable populations depend on viable habitats that allow the population to grow and diversify.

Page 51- 52.

Is there some reason why the recommendation to study the effects of pollutants including fertilizers on the ground water table (where tortoises live 80% of their lives) continue to be ignored?

GENETICS - Go through the Abstracts of the various 2007 herp conferences to find out the status overall about chelonian, particularly tortoises to see where the science is going. Basically tortoises are so conservative that they can inner breed with parents and siblings for generations (why they were found on most all islands capable of feeding them) still survive with no signs for thousands of years of negative genetic impact. No wonder the current genetic studies on gopher tortoises make little sense.

LATITUDNAL CONCERNS FOR RELOCATION

There are real concerns related to cold temperatures above the Suawnee River north and in the panhandle. Bottom of the burrow temps, data on temps in potential egg sites, etc. all indicate that these should be taken into consideration. What about tortoises from the clay soils moving to islands or costal strands where burrows are quite different as an adaptation to the shell sands? I personally feel they will adapt quickly. However the lower, longer temps in the burrows and in egg chambers may be a negative.

DISEASES

The writer of this document is biased (brain washed) with URTD. Note, papers given this past year indicate that previous seropositive tortoises show no sign of antibodies (N=700). We haven’t published our results either but we don’t have any seropositives any longer her at the Reserve.

NO DISCUSSION WHAT SO EVER ABOUT FORAGE AND OTHER POTENTIAL STRESSORS ON TORTOISES THAT MAY CAUSE ANY NUMBER OF DISEASES.

SUGGEST ELLIOTT JACOBSON REVIEW THIS IMPORTANT POINT.

ENCLOSURES are one of the key elements in the success of relocation. Enclosure size, how long they need to be enclosed are extremely important. We clearly have excellent data that shows that 6 months enclosure retains virtually 100% of the relocated tortoises if it is good habitat. Less than that such as the Tuberville study demonstrated a much lower holding rate and tortoises leaving. However they did not demonstrate whether or not they had high quality forage. You did not review the sites and information in our book including chapter 5 or 10. You did not discuss the importance of forage within the enclosure.

Page 20. 25 FOOT RULE. This rule does not provide proper forage or protection of the resident tortoise. What conservation value does this have when people are raising or dropping the site by a few to many feet? This simply does not work on sites of less than an acre. How many times have FWC staff gone out to see the results of these permits. Turning Hawk Subdivision in Marion County is documents by several hundreds of pages and photos of the total loss of tortoises on single-family homes despite protests of neighbors and the fact that these sites were 10 acres or more. This same scenario is the rule across the state.

Note as well, along right of ways, spray fields, etc. The 25 ft. rule causes take to occur when it does not need to. New technologies or the fact that one can encroach within this area to lay a pipe without disturbing the burrow can be done and save tax payers millions of dollars.

APPENDIX

APPENDIX 4 QUALIFICATIONS

This section really does not indicate any real criteria that demonstrate experience or knowledge about tortoise biology, management or the ability to do the monitoring needed on relocation sites not to mention survey and dig tortoise burrows. Further, being a certified biologists does not demonstrate that a person has the training to know how to do what they need to do. GTCI has provided FWC information on the participants in the courses that we have been conducting now for nearly 8 years. We have had nearly 2000 people participate so I would say we have a good database to evaluate what needs to be done to insure that folks know what they are doing.

You did not mention backhoe operators. This is one group that really needs to have some form of certification. Based on our experience at Silverleaf Training, we had 1 out of 4 wash out (people who never did relocation before). It required at least 2 weeks of training before one could determine if they had the skills and “mind set” to do the job. Further, we had two crews that broke every safety rule (OSHA) and best digging methods and indicated that they had been doing that way for 25 years. We have had the same situation with relocation fences, monitoring sites, etc.

APPENDIX 7 EXAMPLE

Why have this example in there? This assumes that this project is using BMP’s but I do not see where that is the case. First of all each habitat has an average or mean tortoise/Ha so if you have a Scrubh habitat not blessed with a high protein source like Bahia. The average density is about 0.8 tortoises/acre. If scrub has 1.5 tortoises per acre (without bahia) then that scrub probably should be considered high.

GET THE GROUND WATER TABLES. THEY ARE FAR MORE IMPORTANT THAN SOILS, ESPECIALLY IN XERIC AND VERY HYDRIC HABITATS.

MAJOR COMMENT

I do not see the reason for so many methodologies for estimating populations, etc. Are we not wanting to know exactly how many tortoises are on either the Donor Site or the Recipient or Permitted Site? All of this appears to be leading to where we are today, errors of greater than 50%, more than 50% of the time.

Pg. 94. RE: CONVERSION FACTOR. Our investigation that you have the data and analysis of clearly defines that the conversion factor, despite habitat is basically 50% based on excavation of all burrows that were classified and found (100%) on the test sites. Except: In sites of over story take over and other conditions of high stress, the conversion factor is too variable to determine. We have commonly found a range of 7-4 burrows/acre. This has nothing to do with density of palmettos as long are the area is open.

HABITAT/PATCH SIZE

We have attempted to determine if this works and cannot find any justification for 15% sampling area. Who else has actually tested the validity of this method? We have not seen any date to demonstrate that this actually works in the real world with consultants doing the work.

NOTE: Nothing was mentioned about encouraging areas to be burned that are covered with dense vegetation and having an estimation of more than 1.0 tortoises per acres. This is extremely cost effective and leads to a greater accuracy.

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