APPENDIX K 

CONSERVATION STRATEGY FOR THE 

GOPHER TORTOISE AND EASTERN INDIGO SNAKE 
1.0 CONSERVATION STRATEGY FOR THE GOPHER TORTOISE AND EASTERN 

INDIGO SNAKE 

The following conservation strategies are designed to minimize potential impacts to 

gopher tortoises and Eastern indigo snakes that occur in the vicinity of the proposed Southeast 

Expansion Project (Project) as well as methods for handling unanticipated discoveries or 

encounters of either species. The strategies detailed below are common to many of the 

projects which have recently been granted by the US Fish and Wildlife Service (FWS) and the 

Federal Energy Regulatory Commission (FERC). 

 Gulf South has determined the location of gopher tortoise burrows within and adjacent to 

the construction right-of-way during field surveys. Gulf South will use this information as a 

baseline for gopher tortoise occupation of the right-of-way. Gopher tortoise surveys methods 

used by Gulf South are presented in Appendix A of this Conservation Strategy. 

1.1 Construction Personnel Education 

All Project construction personnel will be provided comprehensive training with respect 

to gopher tortoises and eastern indigo snakes based on the personnel’s individual level of 

involvement with the proposed Project. This training will include gopher tortoise and Eastern 

indigo snake identification methods, and training on the measures to be implemented in the 

event that an individual or burrow is encountered during Project activities. The training will 

emphasize that any contact or handling of a gopher tortoise and Eastern indigo snake is 

prohibited, unless under the direction of the contract qualified biologist or that either species is 

in a position of imminent harm. 

Training will include: 

1. Reasons for species protection and its protection status; 

2. Penalties for killing, injuring, harassing, or otherwise disturbing a gopher tortoise or 

its burrow, or an Eastern indigo snake; 

3. Discussion of the conservation strategy detailed herein and noncompliance with; and 

4. Procedures for contacting qualified biologists should an individual gopher tortoise or 

Eastern indigo snake be encountered. 

1.2 Pre-Construction Surveys 

Prior to any construction activity commencement, work areas where gopher tortoises 

were identified during field surveys will be resurveyed by qualified personnel to determine if 

dispersion or movement has occurred. Previously unidentified gopher tortoise burrows will be 

documented and mapped using GPS devices. Efforts will be made to inspect all active and 

inactive burrows using a remote infrared video camera system that enables a determination of 

occupancy by tortoises or commensals such as the Easter indigo snake. 

Upper Respiratory Tract Disease (URTD) has been detected in an increasing number of 

gopher tortoise populations in the southeast over the past decade. In order to prevent the 

potential spread of this disease while handling gopher tortoises, latex gloves will be worn, and 

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all equipment (including guide pole, scope, scale, measuring equipment, shovels, etc.) will be 

thoroughly cleaned with a ten percent bleach solution following each contact with an individual 

gopher tortoise or burrow. 

Burrows will be identified using a unique numbering system to facilitate proper 

monitoring. Following completion of the initial re-surveys of the proposed right-of-way and 

before construction, a report will be submitted to the FWS and the Mississippi Museum of 

Natural Science (MMNS) containing information on any gopher tortoise individuals that will 

require capture and relocation. Gopher tortoises and burrows in area adjacent to the 

construction right-of-way will be excluded from the construction zone by barricading silt fencing 

or orange construction fencing erected along the edge of the right-of-way to prevent accidental 

contact with and damage from construction equipment. 

1.3 Collection of Gopher Tortoises for Relocation 

Collection of gopher tortoises from the work areas will be determined on an individual 

basis and will be constrained as follows: 

1. Any personnel involved with the relocation of a gopher tortoise will have experience 

in working with gopher tortoises and be under the supervision of the qualified 

biologist; 

2. Any activities resulting in the capture/relocation of a tortoise will occur only from April 

1 to October 15; 

3. A qualified biologist will determine whether any burrows show signs of nesting. If 

determined that a burrow may have eggs buried within the apron, they will be hand 

excavated, carried without rotation, and reburied at a suitable location. Egg 

relocation sites will be protected using two-inch mesh to enable hatchlings to escape, 

while predators are excluded; 

4. If an individual is captured outside or near the entrance of a burrow, the burrow will 

be examined with a remote infrared video camera system. If no additional tortoises 

or commensal species are present, the burrow will be excavated with a backhoe to 

verify that the burrow is unoccupied and then filled in to prevent reoccupation; 

5. Small sub-adult and hatchling burrows will be shovel excavated. Small flexible 

tubing (PVC, HDPE) will be entered into the burrow to determine depth and shape of 

the burrow and will be used as a guide for digging the burrow. This tubing will be 

graduated to aid in determining burrow depth. As shovel digging approaches the 

end of the burrow, hand digging will replace shoveling until completion of the burrow 

is reached. Following removal of the tortoise, backfilling can occur; 

6. Backhoe digging of adult burrows will occur using the same steps as shoveling. 

Backhoe buckets will have their teeth removed or a metal plate welded over the 

teeth. A flexible tubing will be inserted into the burrow to be used as a guide for the 

backhoe operator and to ensure the path is maintained. A qualified person will 

inspect the progress of the digging. The last one or two feet of the burrow path are 

to be hand dug. Following extraction of the tortoise, backfilling can proceed; 

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7. Captured tortoises will be sexed, aged, permanently marked using standard marginal 

scute numbering (Cable, 1944); 

8. Sick or injured tortoises will be brought to a local veterinarian for treatment by a 

qualified person with FWS and MMNS approval to move tortoises. If injuries are 

critical, it will be euthanized. Documentation for all tortoises brought to a veterinarian 

will be submitted to the FWS and the MMNS; 

9. All materials used to capture, dig, relocate gopher tortoises will be sanitized using a 

ten percent bleach solution after each use to prevent spread of disease; and 

10. Handling of gopher tortoises will be by qualified personnel wearing latex gloves and 

gloves will be changed after handling each turtle to prevent spread of disease. 

1.4 Relocation of Gopher Tortoises 

As has been shown with previous pipeline projects (Wester and Kolb, 1999; Thomas, 

2001), gopher tortoises temporarily displaced from the construction corridor will likely remain in 

the immediate vicinity of their capture and will be able to reoccupy their original home range 

once construction and re-vegetation activities are completed. Therefore, Gulf South proposes to 

temporarily relocate directly impacted individuals from the proposed right-of-way into nearby 

burrows within their normal range. In locations where nearby burrows do not exist, starter 

burrows will be dug for release of displaced tortoise following the guidelines outlined in Gulf 

South’s Gopher Tortoise Standard Operating Procedures for Protecting Gopher Tortoise Along 

Existing Rights-of-Way (Appendix B of this Conservation Strategy). All relocations will be within 

the same colony and will be supervised and directed by the qualified biologist approved for such 

activity and with proper permits. 

The relocation of individuals from the construction areas will be conducted in accordance 

with the following guidelines: 

1. Relocations will occur only between April 1 and October 15; 

2. Relocation will take place immediately to previously selected inactive/abandoned 

burrows of similar size and in the same general area; 

3. All tortoises to be relocated will be examined for Upper Respiratory Disease (URD). 

Systematic tortoises will be separated from other tortoises and reported to the FWS 

and the MMNS. Blood samples will be taken by qualified personnel and sent to the 

University of Florida for testing in accord with methodologies provided by the 

University of Florida and as required by the FWS and the MMNS; 

4. All recipient burrows will be scoped to determine activity status prior to releasing 

captured individuals; and 

5. A report will be prepared to detail the relocation efforts to both the FWS and the 

MMNS. 

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1.5 Construction Monitoring 

An environmental inspector (EI) thoroughly trained in the procedures included in this 

Conservation Strategy will be on-site at all times to ensure compliance with all aspects of this 

plan, environmental permits, the FERC Certificate, and the Endangered Species Act (ESA). A 

qualified biologist with all necessary state and federal endangered species permits will be 

available at all times during construction to handle any gopher tortoise or eastern indigo snake 

issues as they arise. This biologist will provide continued training on listed species throughout 

construction to all construction personnel as needed. 

1.5.1 Burrow Adjacent to Construction Corridor 

Individual gopher tortoises, or gopher tortoise colonies located adjacent to, and outside 

of the construction corridor, will be protected from impacts by installation of silt fence or orange 

barricade type fencing. To prevent tortoises from wandering into construction areas, fencing will 

be placed on the outer edge of the proposed construction corridor and buried to a minimum 

depth of 6 inches below grade. Additionally, fencing will help to prevent inadvertent impacts 

from construction equipment and personnel to these areas by clearly demarcating these areas. 

The exact location and placement of fencing will be determined by a qualified biologist and be 

appropriate for the habitat being affected. Signage will be posted to clearly demarcate these 

areas. The EI will monitor all installed fencing at a frequency determined by the qualified 

biologist to insure proper functioning. Following construction, all gopher tortoise fencing will be 

removed and the flora and fauna allowed to re-inhabit the area. 

1.5.2 Access Roads 

All access roads in the general vicinity of areas where there are known populations of 

gopher tortoises or Eastern indigo snakes will be resurveyed prior to construction. Additionally, 

the following guidelines will be adhered to further protect individual species; 

1. Signs will be placed on unimproved access roads where there are known colonies of 

gopher tortoises and speed limits restricted to 10 MPH. 

2. If a burrow is located within 50 feet of an unimproved road, it will be barricaded with 

exclusion silt fencing or orange construction fencing, with a minimal length of 150 

feet. 

3. All unimproved access roads in the vicinity of known gopher colonies or burrows will 

be examined daily for the presence of wandering individuals. 

1.5.3 Right-of-Way Surveying Throughout Construction 

In order to further minimize impacts to gopher tortoises and Eastern indigo snakes, Gulf 

South will conduct regular surveys throughout the duration of construction. The following is a 

listing of proposed re-surveys to be conducted during construction: 

1. Re-survey the right-of-way as necessary to document any new locations or activities 

of gopher tortoises or Eastern indigo snakes; 

2. Survey all open trenches for individual tortoises or Eastern indigo snakes daily and 

before backfilling. Should a tortoise be found during these surveys, the qualified 

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biologist should be contacted so that it may be removed in accord with proper 

handling procedures; and 

3. All spoil piles within the general vicinity of known gopher tortoise populations will be 

surveyed daily by a qualified biologist to ensure that no tortoises have colonized the 

spoil piles. If a burrow is located in a spoil pile, it will be excavated in accord with 

this plan and under instruction of the qualified biologist. 

1.5.4 Construction Monitoring 

All monitoring of the terms and conditions of the biological assessment and conservation 

strategy will be carried out by the EI under instruction of the qualified biologist. Roles and 

responsibilities with respect to this biological assessment include: 

1. At all times the qualified biologist will be available to the EI; 

2. The EI will have stop work authority and direct contact with the environmental project 

manager and construction superintendent should a burrow or individual gopher 

tortoise be located with potential to be impacted by the proposed Project; 

3. Except in the event that a gopher tortoise or Eastern indigo snake is in immanent 

danger that might lead to the injury or mortality, no personnel, other than a qualified 

biologist, shall handle or disturb a tortoise; 

4. Any violations of the conditions or terms of this document, the FERC Certificate, or 

the ESA shall be reported to the environmental project manager who will contact the 

FWS and the MMNS; 

5. Monitoring will continue until deemed complete by the FWS and the MMNS. 

1.6 Operation and Maintenance 

Gulf South is proposing a 60-foot wide permanent right-of-way; however, we have 

recommended a permanent right-of-way of 50 feet. The area will be planted with grasses that 

normally occupy such rights-of-way such as dallis, Bermuda, and Bahia grasses. Gulf South 

will follow the Standard Operating Procedures for Protecting Gopher Tortoises for the Project as 

summarized below and included as Appendix B of this Conservation Strategy. Gulf South will 

also follow the guidelines outlined in their Unanticipated Discoveries/Encounters with Eastern 

indigo snakes that is included in Appendix C of this Conservation Strategy. 

1.6.1 Training 

Qualified personnel will be used to determine if gopher tortoises or Eastern indigo 

snakes are present on a construction site before work begins. These personnel will be Gulf 

South employees or contracted mowing personnel that have been trained to identify gopher 

tortoises, their habitat, and/or burrows, as well as eastern indigo snakes. A training module, 

including gopher tortoise and Eastern indigo snake identification keys and habitat information 

will be provided to personnel who will be responsible for the right-of-way clearance. Maps 

showing the locations of known active/inactive burrows on the right-of-way will be provided to 

mowing personnel, as needed. A list of personnel who have completed training will be provided 

upon FWS request. 

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1.6.2 Reporting 

Reporting of findings will be made by trained personnel on all jobs in affected 

counties/parishes. Inspection report forms will be retained for inclusion in reporting under the 

FERC blanket or for any reporting requested by the FWS under the terms of their approval of 

this plan or subsequent consultations. 

1.6.3 Small Excavations 

Small excavations are routinely necessary for replacing valves, sections of pipe or small 

appurtenance construction. Prior to the excavation, the area within which work will be 

conducted (including the area to be excavated and the path that equipment will be traveling) will 

be surveyed for tortoise burrows and individual tortoises. If an individual tortoise or Eastern 

indigo snake is encountered, they will be allowed to leave the area without contact from any 

Gulf South staff or its contractors. If maintenance activities are required within 50 feet of 

tortoise burrows, the burrows will be clearly marked for avoidance, and the FWS will be 

contacted for consultation. If an active burrow cannot be avoided, then Gulf South will initiate 

formal consultation with the FWS. 

Except for travel on existing roads and paths, routine maintenance activities will be 

restricted to areas beyond at least 50 feet from tortoise burrows. Where these maintenance 

activities require work be performed closer than 50 feet from burrows, only hand-held equipment 

will be used, and maintenance personnel will avoid the burrow apron, entrance and area 

immediately behind the entrance. 

If excavations are to be left unattended in areas where gopher tortoises have been 

identified, the area will be fenced to prevent gopher tortoises from entering the excavation area. 

Small excavation projects such as those applicable to this management plan are unlikely to 

exceed two days from the initial date of ground disturbance. Excavation areas within 100 feet of 

tortoise burrows will be surrounded by a fence with a minimum 2-inch mesh to exclude tortoises 

during construction. Attention should be paid to the bottom of the fence to make sure that it is 

secured to prevent tortoises from going underneath the fence. Enough area should be fenced 

to allow work to proceed within the enclosure with minimal limitations on tortoise foraging habitat 

as practical. Fencing should remain in place until the excavation is backfilled. 

All excavated trenches and underneath vehicles will be checked daily for tortoises before 

commencing work. All maintenance debris that could hinder tortoise movement will be removed 

at the completion of construction activities. 

1.3.4 Right-of-Way Mowing 

The mowing of rights-of-way is a necessary and regulated practice. Since gopher 

tortoises and Eastern indigo snakes have been documented to utilize existing rights-of-way, 

special attention should be given before and during mowing activity. The right-of-way should be 

walked before mowing begins to determine areas of occupied habitat and potentially occupied 

habitat. When mowing in these areas, a “tortoise monitor” will verify that the right-of-way is 

clear immediately ahead of the mowers. Individual tortoises should be allowed to move out of 

the path of the mowers. Gopher tortoises are active year round; however their activity slows 

down in the winter months. When possible, mowing should be conducted in the winter (between 

November 1st and March 1st) to reduce the likelihood of encountering gopher tortoises. If 

practical, mowing should be planned for cloudy days when the temperature is below 50oF. This 

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will further reduce the probability of encountering a tortoise. Mowing will be conducted at a 

frequency sufficient to maintain suppression of woody growth, and in accord with FERC and US 

Department of Transportation (DOT) standards. In addition, no herbicides will be used to control 

vegetation within areas occupied by tortoises. 

Maintenance personnel will use hand-held power equipment to mow vegetation 

surrounding the burrows. Hand-pushed mowers and hand-held equipment will be used within 

50 feet of tortoise burrows, and maintenance personnel will avoid mowing across the burrow 

apron, burrow entrance, and the area immediately behind the entrance. 

1.3.5 Pipeline Leaks and Emergencies 

In case of emergency such as a pipeline leak or blowout, it may be necessary to initiate 

repair work immediately. If this occurs in an area inhabited by gopher tortoises, every effort will 

be made to protect the burrows and individuals. Gulf South will contact qualified personnel to 

address any and all impacts to gopher tortoises. This will include immediate assessment of the 

potential effects of the situation, and every effort will be made to minimize or avoid such any 

potential adverse effects. Any such events will be reported to appropriate FWS Field Offices 

and state agencies. 

2.0 POST-CONSTRUCTION MONITORING, COORDINATION AND REPORTING 

The pipeline right-of-way will be monitored for three years following the initial relocations 

of gopher tortoises to assess the success of relocation efforts. Surveys will be conducted 

during the active periods of the year. Burrows located within the right-of-way will be identified 

and located with GPS coordinates. The status of starter and relocation burrows will also be 

assessed during surveys. Using GIS technology, these burrows will be mapped and compared 

to pre-construction and yearly post-construction data. 

Gulf South will compile the findings of this monitoring efforts into an annual summary 

report and present its findings to the FWS and the MMNS beginning one year after construction 

completion and site restoration. 

3.0 References 

Cox, J., D. Inkley, and R. Kautz. 1987. Ecology and habitat protection needs of gopher tortoise 

(Gopherus polyphemus) populations found on lands slated for large-scale development 

in Florida. Florida Game and Freshwater Fish Commission Nongame Wildlife Program 

Technical Report 4, Tallahassee, Florida. 74 pages. 

Thomas, D.P. 2001. Recruitment of Gopher Tortoises to a newly constructed pipeline corridor in 

Mississippi. Proceedings of the Seventh International Symposium on Environmental 

Concerns in Right-of-Way Management, Calgary 2000. Elsevier Science Ltd. London. 

Wester, E.E. and J.W. Kolb. 1997. Conservation of the gopher tortoise and associated species 

during construction of the Florida Gas Transmission Company Phase III Expansion 

Project. Pp. 330-34- in J.R. Goodrich-Mahoney, J.R. Wisniewski, and J. Wisniewski eds. 

Elsevier Sci. New York. X+511pp. 

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APPENDIX A 

SURVEY METHODOLOGY FOR GOPHER TORTOISES 

AND EASTERN INDIGO SNAKES 
1.0 SURVEY METHODOLOGY 

Areas of suitable gopher tortoise habitat, as described in the following section, as well as 

areas considered to be of marginal quality will be “100 percent” surveyed for the presence of 

tortoise burrows. Survey sites will be divided into consecutive “site distance” strip transects, 

each of which will be traversed, on foot, by a member of the survey team across the entire width 

of the survey corridor as required. The width of each transect will be determined by ground 

visibility within the site. In other words, a site composed of pasture, recent timber clear-cut, or 

other forms of open land will have a greater transect width than that of a very thick timber stand 

with reduced sight distance. Transect widths may range from 10 to 50 feet, depending on 

ground visibility within the site. 

If a tortoise burrow is found, the coordinates for the burrow will be documented, a photo 

taken, and the location and activity status will be documented as active, inactive, or abandoned. 

The classification for activity status is defined below and is based on the appearance of the 

burrow apron and entrance at the time of survey. 

1. Active – most likely occupied by a tortoise; as evidenced by presence of tortoise, 

freshly dug sand, tortoise tracks, or tortoise scat. 

2. Inactive – used by a tortoise as part of a home range with other burrows, but is not 

currently occupied. Evidence includes absence of active burrow signs listed above 

and/or the presence of debris in burrow entrance. 

3. Abandoned – most likely not occupied by a tortoise for many years; as evidenced by 

deteriorated nature of burrow entrance, (i.e. burrow collapsed, lack of maintained 

apron, sand washed in, etc.) Old burrows are in such a condition that they are not 

considered to be good candidates for future use by tortoises. 

Gopher tortoises occupy a wide range of upland habitat types. The general physical and 

biotic features thought to characterize suitable adult tortoise habitat are: 

1. Presence of well-drained, sandy soils, which allow easy burrowing; 

2. Abundance of herbaceous ground cover; and 

3. Generally open canopy and sparse shrub cover, which allows sunlight to reach the 

ground floor (Cox et al., 1987). 

1.1 Soils 

Soil conditions are responsible for the nature of habitats preferred by tortoises. The U.S. 

Fish and Wildlife Service has assigned each soil series as either a priority, suitable, marginal, or 

unsuitable type for the gopher tortoise. US Department of Agriculture Natural Resources 

Conservation Service (USDA-NRCS) county soil survey maps can be obtained either from the 

NRCS website (if available) or from the local NRCS office. 

1. Priority soils are humus poor, excessively well-drained, relatively deep to deep sandy 

soils, without fragipans. These soils typically occur on the highest upland positions 

1
and adjacent side slopes. Priority soils include Lakeland, Alaga, Eustis, and 

Troup/Waldey. 

2. Suitable soils consist of deep, well drained, loamy sands, without fragipans. Suitable 

soils, in comparison to priority soils, have horizons with a greater portion of clay. 

Suitable soils usually occupy topographically adjacent and lower positions when 

associated with priority soils. Suitable soils include Benndale, McLaurin, Smithdale, 

and Ruston. 

3. Marginal soils are deep, moderately well drained soils, with a greater amount of clay 

or plinthite, which may include fragipans. Marginal soils are not classified as hydric 

or wetland soils. Marginal soils include Poarch, Saucier, Susquehana, Freest, and 

Lucy types. 

All other soil series are considered unsuitable soils. These soils frequently are classified 

as hydric, or they occur on stream terraces and floodplains. 

1.2 Vegetation 

The vegetation characterizing gopher tortoise habitats varies with geography, soil type, 

and past and present land use. Long-leaf pine (Pinus palustris) , loblolly, slash pine(loblolly) 

and/ or hardwood trees (i.e. turkey oak, blackjack oak, wax myrtle, etc) can often be found at 

such sites. Herbaceous vegetation tends to be composed of species tolerant of dry conditions 

(i.e. wiregrass, prickly pear, reindeer moss, gopher apple, blackberry, and several grasses of 

the genera Andropogon and Panicum). 

Tortoise burrows also can be found along powerline and pipeline rights-of-way, road 

rights-of-way, and ruderal habitats; including fence rows, orchard edges, golf course roughs and 

edges, old fields, and pasturelands. Tortoises are often pushed into these areas due to 

adjacent habitat becoming unsuitable (i.e. thick under and mid story canopy, residential and 

commercial development, etc). 

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APPENDIX B 

GULF SOUTH’S STANDARAD OPERATING PROCEDURES FOR 

PROTECTING GOPHER TORTOISES 

ALONG EXISTING RIGHTS-OF-WAY 
January, 2007 

Before any tortoise can be handled, moved, harassed, etc., Gulf South must first obtain 

a federal incidental take permit from the FWS and a state permit from the MDWFP. 

This Standard Operating Procedure (SOP) is to be included into all future biological 

assessments submitted to the FWS during formal consultation per Section 7 the Endangered 

Species Act (ESA) of 1973, as amended (16 U.S.C. 1531 et seq.). This SOP will be considered 

part of the “proposed action” for that particular project. 

This SOP is intended to cover the majority of tortoise relocation issues. Additional 

information may need to be included on a project by project basis such as specific relocation 

site information, additional monitoring and reporting, etc. 

Contact Information 

Cale LeBlanc 

Environmental Specialist 

111 Park Place, Suite 100 

Covington, LA 70433 

Office: 985-898-1051 

Cell: 985-791-8395 

David Felder, Biologist 

U.S. Fish and Wildlife Service 

6578 Dogwood View Parkway 

Jackson, MS 39213 

Office: 601-321-1139 

Cell: 601-720-6458 

Tom Mann, Tortoise Biologist 

MS Department of Wildlife, Fisheries, and Parks 

2148 Riverside Drive 

Jackson, MS 39202 

Office: 601-354-7303 

1.0 COLLECTION OF TORTOISES FROM PROJECT AREA 

a) Gopher tortoises will only be captured and relocated during the active season (April 1 

to October 1). 

b) All burrow excavation efforts will be directly supervised by a biologist with experience 

excavating gopher tortoise burrows. All active burrows will be fitted with wire have-ahart traps. All traps should be clearly marked “Do not disturb”. Traps will be 

sufficiently shaded to prevent overheating of a trapped tortoise and will be checked 

twice daily, once in late morning and once in late afternoon. Hatchling and subadult 

burrows will be hand excavated, using shovels. Backhoes may be used to excavate 

adult burrows if have-a-hart traps fail to trap tortoises. 

c) Before beginning hand or backhoe excavation, a flexible tube, with length 

graduations marked, will be inserted into the burrow to ensure that the burrow path is 

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not lost and to indicate the distance to the end of the burrow or to the 

tortoise/commensal. Throughout the excavation process, the burrow will be 

frequently inspected to ensure that the tortoise/commensal has not moved to a 

position where it might be injured by the backhoe or shovel. The last one - two feet 

of the burrow will be excavated by hand using shovels and small hand spades. 

Following removal of the tortoise/commensal, all excavated burrows will be refilled. 

d) Captured gopher tortoises will be photographed (dorsal, ventral, and anterior views 

for tortoises), measured, weighed, sexed (if possible), aged (if possible), and marked 

using a standard marginal scute numbering scheme. 

e) All relocated gopher tortoises will be examined for visual signs of upper respiratory 

tract disease (URTD). A blood sample will be collected for each tortoise and sent to 

the University of Florida for an ELISA test for URTD antibodies. Because of the 

specialized expertise needed for this sampling effort, field personnel should have 

experience extracting blood for URTD analysis according to the protocol established 

by the Gopher Tortoise Council. Immediately following data/blood sample collection, 

each tortoise will be given an opportunity to drink water. 

2.0 RELOCATION AND MONITORING OF TORTOISES FROM PROJECT ROW 

a. If available, release burrows will be inspected with a remote video system to ensure 

that they are unoccupied. In areas with limited numbers of existing unoccupied 

burrows, starter burrows will be dug for release of displaced tortoises. Starter 

burrows will be dug at a 20-30 degree angle with shovels/post hole diggers/power 

augers to the greatest distance possible (minimum 3-4 feet). Starter burrows should 

have a size and shape similar to the burrow being replaced. 

b. All colonies will remain intact and starter burrows for each colony will be located 

within 600 feet of each other. Starter burrows and tortoises will be temporary 

penned using silt screen fencing material for seven days. Individual pens will be a 

minimum of 40 feet in diameter and round in construction to eliminate corners in 

which tortoises will tend to dig. 

c. To minimize the risk of disease transmission, all material used during the 

displacement of gopher tortoises from the construction corridor (e.g., traps, shovels, 

backhoe buckets, remote video cameras, etc.) will be disinfected with a dilute 

chlorine solution after each use. Tortoises will be handled with disposable latex 

gloves. 

3.0 CONSTRUCTION PERSONNEL EDUCATION 

Before any construction activities, Gulf South will require all construction personnel to 

attend an educational presentation, conducted by trained personnel, to acquaint them with 

gopher tortoise ecology, their protected status, and Gulf South’s conservation /mitigation efforts. 

Such a presentation will include: 

a) An overview of the terms and conditions of the FWS’s biological opinion and 

penalties for noncompliance. 

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b) Legal penalties for killing, injuring, harassing, or otherwise disturbing a gopher 

tortoise or its burrow. 

c) Procedures for coordinating with and contacting the Project biologist. 

4.0 MONITORING OF CONSTRUCTION ACTIVITIES 

a) Any new burrows found within the construction corridor or spoil piles will be 

inspected for occupancy using a remote video system. Occupied burrows will be 

trapped or excavated and the tortoises/commensals handled, data collected and 

released into designated unoccupied/starter burrow following preconstruction 

procedures. Unoccupied burrows will be collapsed. 

b) Except in emergencies, only gopher tortoise Project biologists and specifically 

trained environmental inspectors will be allowed to handle tortoises. Tortoise 

biologists and inspectors will have access to radios or cellular phones while in the 

field. 

c) If a gopher tortoise is encountered by construction personnel within the construction 

corridor, all activities that might harm these species will cease and a Project biologist 

or environmental inspector will be summoned. The USFWS will be contacted to 

determine where the tortoise should be released. 

d) If a gopher tortoise is found dead during construction activities, the Project biologist 

will be notified, who will then report the incident to the USFWS. 

5.0 COORDINATION AND REPORTING 

a) The development of a tortoise relocation plan (i.e. tortoise relocation and monitoring) 

and any significant changes to the proposed Project will be coordinated with the 

FWS. FWS personnel will be invited to visit the construction site and accompany 

Project biologist during all phases of the gopher tortoise conservation effort. 

b) Following the relocation of tortoises, a report documenting the capture and 

displacement of gopher tortoises will include the following information: (1) names and 

qualifications of the investigators; (2) survey dates; (3) area surveyed, including 

mileposts; (4) specific burrow locations, including the milepost, distance from 

roadway centerline, and direction; (5) survey methods; (6) burrow size, condition, 

and activity level; (7) the individual marking used to identify each relocated tortoise or 

snake and their associated original and relocated burrow sites; (8) date of relocation; 

and (9) conclusions. The survey report will be sent to the FWS. 

6.0 POST-CONSTRUCTION ROW MAINTENANCE AND OPERATIONS 

a. Maintenance personnel will be trained in tortoise awareness. Maintenance 

personnel will use power equipment to mow vegetation surrounding the burrows, but 

will reduce their speed within 50 feet of burrows. Maintenance personnel will avoid 

mowing across the burrow apron, burrow entrance and the area immediately behind 

the entrance. 

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b. In case of an emergency (e.g., chemical or fuel leaks and/or spills), a gopher tortoise 

biologist will be called to the site as soon as possible to assess the potential impacts 

of the emergency and repair work on nearby tortoises, and to prevent further impacts 

during ongoing repair work. The FWS will be immediately contacted concerning any 

adverse effects on a gopher tortoise. 

c. All tortoises or burrows found along existing roads will be reported to the Project 

biologist. 

d. When a tortoise is found alive in the road and in danger of being hit by vehicular 

traffic, the tortoise should be moved to one side of the road. If the tortoise appears 

to be heading in one direction, move the tortoise to that side of the road. If unsure, 

then relocate tortoise to closest side. 

e. If a tortoise is found in the road that has been hit by a vehicle, and is still alive, 

contact the Project biologist (Gulf South) or Tom Mann (MMNS), for coordination on 

where injured tortoises can be taken. 

f. Dead tortoises found in Gulf South’s right-of-way should be photographed if possible, 

location recorded (mile marker, north or south bound lane, etc), and reported to the 

Project biologist. 

g. A database will be developed that catalogs the occurrence of tortoises/burrows found 

on Gulf South right-of-way, number of tortoises impacted by vehicles, location, etc. 

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APPENDIX C 

UNANTICIPATED DISCOVERIES/ENCOUNTERS WITH 

EASTERN INDIGO SNAKE 
EASTERN INDIGO SNAKE UNANTICIPATED DISCOVERIES/ENCOUNTERS 

The Eastern indigo snake is a threatened species that occurs throughout peninsular 

Florida. This species is actually characteristic of moist habitats, but inhabits sandy xeric 

habitats in conjunction with gopher tortoises. In the drier habitats, the Eastern indigo snake will 

occupy gopher tortoise burrows. The preferred habitats include pine flatwoods, xeric oak 

stands, palmetto scrub, and tropical hammocks. No Eastern indigo snakes were observed 

within the proposed Southeast Expansion Project study area during any of the field surveys. 

The prevalence of potential habitat within the corridor could potentially involve the Eastern 

indigo snake. However, to minimize any impacts to any individual Eastern indigo snakes during 

construction, the following special provision will be included in the construction contract to 

advise the contractor of the potential presence of this species and its protected status: 

• If an Eastern indigo snake is sighted during construction, the contractor will be 

required to cease all operation(s) which might cause harm to the snake. 

• If the snake does not move away from the construction area, a state or federal 

biologist will be contacted to capture and relocate the snake to suitable habitat 

either adjacent to the proposed Project area or off-site to an acceptable donor 

site. 

• If an Eastern indigo snake is killed or found dead within the construction area, the 

snake should be frozen and the FWS Jackson Field Office [(601) 965-5392] will 

be notified immediately. 

• Due to the condition of the surrounding area, the abundance of habitat in the 

Project area, and the special provisions to protect transient individuals 

encountered during construction, the proposed Project is not anticipated to affect 

the Eastern indigo snake. 

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