1
REVIEW
of the
Sea Turtle Science and Recovery Program
Padre Island National Seashore
Recommended: Patrick Malone, Regional Chief, Natural Resources
Reviewed and concurred: Jennifer Carpenter, Associate Regional Director,
Resource Stewardship and Science
Signed:_____ ______approved 6/8/2020; amended 5/7/2021
Michael T. Reynolds
Regional Director, NPS Regional Office serving DOI Regions 6,7,8
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Top: Kemp’s ridley in water; Lower left: Female Kemp’s laying eggs; Lower right: Kemp’s hatchlings at
release (NPS photos)
Cover photo: Shoreline of the barrier island known as North Padre Island, home of Padre Island National
Seashore. (NPS photo)
Editor’s Note: The report was first approved on 6/8/20. Requests for information correction under the
Information Quality Act were received on 7/16/20 and 12/31/20. Minor information corrections were
completed, along with footnotes and appendices added to provide clarifying information, on 12/2/20 and
5/7/21. A record of these actions can be found at https://www.nps.gov/aboutus/information-quality-
corrections.htm.
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EXECUTIVE SUMMARY
The Padre Island National Seashore (PAIS or park) Sea Turtle Science and Recovery (STSR)
program has been operating for over 40 years. Begun in the late 1970s to aid in the recovery of
the Kemp’s ridley sea turtle, the most endangered sea turtle in the U.S., a secondary nesting
colony was successfully established at PAIS to prevent species extinction. The park has been
relocating sea turtle eggs, incubating them in an NPS facility, and releasing hatchlings on park
beaches to mitigate potential effects from any source of environmental, natural, or human
caused mortality ranging from tidal inundation, predation, and recreational beach driving. The
program has grown tremendously during this time and now has an annual operating budget of
nearly $2M ($1.3 ONPS base and $700k project funds), which funds nest monitoring and
management, research, and stranding response. In 3-5 years, the program is projecting a
budget shortfall. A program review was requested to evaluate the financial sustainability of the
program, including reviewing program operations, staffing, interagency relationships, and
consistency with conservation principles and agency policy.
From 1978 to present, the worldwide population of Kemp’s has grown, but is still tenuous. The
epicenter for Kemp’s nesting is in Mexico. Kemp’s ridley nesting in Texas and at PAIS
represents about 1% of the worldwide total. Nationally and internationally, those agencies with
authority over species recovery have emphasized reducing threats and impacts to the species,
including focusing recovery efforts on primary nesting areas in Mexico and reducing egg
harvesting and bycatch in fishing gear (mostly shrimp trawling). The STSR program has
contributed significantly to sea turtle science over the years through research and dozens of
professional publications. The park’s sea turtle nest protection/relocation/egg incubation
program can be credited for improving the science and techniques for hatchling production.
However, the program does implement very intensive and invasive techniques to reduce
potential egg and hatchling mortality on only one percent of the worldwide population. Other
influences, such as sea level rise and increases in coastal nuisance flooding, contribute to the
concern over the long-term suitability and availability of sea turtle nesting habitat at PAIS and
indicate a need to determine if other suitable nesting habitat exists along U.S. beaches outside
of PAIS.
Program findings and recommendations are included on the topics of mission and program
focus, interagency relations, sustainable funding, program staffing and operations, and safety.
This report includes many recommendations intended to update the program to better align with
current NPS practices, which includes continuing to contribute to sea turtle recovery and
protecting and managing the many other significant natural and cultural resources in the park.
The park has achieved establishment of a secondary nesting colony of Kemp’s and evidence
indicates the imprinting and return of offspring to PAIS beaches. This strategy was a key
component of the 1978 interagency Kemp’s action plan, but has not been identified as a primary
recovery action in subsequent FWS/NMFS recovery plans, including the most recent 2011 plan.
The park has an opportunity to scale STSR program operations and to pilot alternate nest
management strategies, which will require engaging other agencies and partners in planning for
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the future, including Endangered Species Act consultation. The 5-year species status review for
Kemp’s (to be conducted in 2020) will be an opportunity to initiate these discussions with the
Recovery Team and other partners.
Sea turtle management of Kemp’s ridley requires international and domestic coordination and
partnerships that promote shared stewardship. The STSR was universally praised for raising
public awareness for sea turtle conservation. NPS funding, particularly PAIS funding, for
Kemp’s recovery is disproportionately high compared to the number of partners involved and
the percentage of the turtle population being addressed. The NPS should request additional
funding and support from the FWS for current recovery actions and nest location, egg collection,
and hatchling release at PAIS. The NMFS currently supports PAIS for the role of State
Coordinator of the Sea Turtle Stranding and Salvage Network for Texas. The park should
engage the national Kemp’s Recovery Team and the FWS in determining and evaluating
additional and alternative locations for nesting sites outside of PAIS boundaries.
For a sustainable program operations funding model, the park should transition the sea turtle
program to one that operates on existing park base that accounts for and incorporates existing
permanent salaries and other fixed costs (e.g. fuel use, supplies, equipment, all vehicle
maintenance and replacement, and additional utility costs). The program should not rely on
additional parkwide base fund allocations or short-term project funding to cover long-term
operational costs.
Alternative staffing and operations recommendations include greatly reducing overtime from
over $200,000 per year to approximately $16,000 per year (the NPS Scorecard standard for
resource programs), elimination of administratively uncontrollable overtime (AUO), and hiring
additional seasonal staff to accomplish priority work. A reorganization of the staffing structure is
proposed to reduce supervisory span of control issues and provide for more direct interaction of
permanent staff with the division chief. Additional operational recommendations include
focusing staff work and activities (e.g. nest management and egg collection, turtle stranding,
recovery, and salvage) to within PAIS boundaries. To reduce employee burnout and provide for
adequate work-rest ratios for normal operations, tours of duty should be limited to 8-hour days
or 10-hour days (40 hours per week) and additional seasonal staff should be hired for days or
times where coverage is demonstrated as critical.
The Regional Safety Officer recently completed a safety review in December 2019, which
included a corrective action plan for beach travel. A Standard Operating Procedure (SOP)
should be developed defining when the beach is closed to the public, and STSR staff should be
held to that standard. The park should implement an incident command system (ICS) for
management of large and unpredictable turtle stranding events to improve accountability for
tasks, safety, and finances. Operational Leadership (OL) training should be provided each year
to all staff and OL principles and activities (e.g. GARs) should be conducted regularly to
evaluate conditions and risks unfavorable for field work and any mitigations needed.
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Table of Contents
1. Program Review Purpose, Scope, and Objectives……………………………………………7
2. Assessment Methods…………………………………………………………………………….7
3. Program History and Context……………………………………………………………………7
4. Findings, Discussion, and Recommendations
a. Mission Functions……………………………………………………………………...10
i. Nest Management…………………………………………………………….11
ii. Strandings……………………………………………………………………..17
iii. Research……………………………………………………………………….19
b. Funding…………………………………………………………………………………20
c. Staffing………………………………………………………………………………….29
d. Safety……………………………………………………………………………………31
e. Interagency Relationships…………………………………………………………….33
5. Program Successes……………………………………………………………………………..36
6. References……………………………………………………………………………………….37
7. Report Preparers and Reviewers………………………………………………………………38
8. List of Agencies, Organizations, and Individuals Interviewed………………………………38
List of Figures and Tables
Figure 1. Map of Padre Island National Seashore…………………………………………………....6
Figure 2. Distribution and relative abundance of Kemp’s ridley nesting……………………………9
Table 1. Kemp’s ridley sea turtle nests……………………………………………………………….43
Table 2. Green sea turtle nests for select areas of North Atlantic Population……………………43
List of Appendices
Appendix A: Park Purpose, Significance, Fundamental Resources and Values…………………40
Appendix B: Nests Detected of Kemp’s ridley and Green Sea Turtles&ESA Recovery Criteria.43
Appendix C: PAIS STSR Organizational Chart (FY20)……………………………………………..44
Appendix D: PAIS STSR Organizational Chart (recommended)………………………………..…45
Appendix E: PAIS SRM Organizational Chart (FY19)…………………………………………...….46
Appendix F: PAIS STSR Current and Future Funding……………………………………………...47
Appendix G: STSSN Roles and Responsibilities…………………………………………………….48
Appendix H: Corrective Action Plan - PAIS Beach Travel………………………………………….52
Appendix I: Interview Questions……………………………………………………………………..54
Appendix J: Superintendent E-mail…………………………………………………………………..57
Appendix K: NMFS E-mail…………………………………………………………………………….58
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Figure 1. Map of Padre Island National Seashore.
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1. Program Review Purpose, Scope, and Objectives
Prior to his retirement in fall 2019, the former Superintendent, Padre Island National Seashore
(PAIS or park), requested a review of the park’s sea turtle science and recovery (STSR)
program. This request was based on several factors: the Management Review completed in
July 2018 for PAIS and Palo Alto National Battlefield called for a more in-depth review of the
STSR program; the Superintendent was preparing to address a future funding shortfall for the
program and for staff succession planning; the STSR program had not been reviewed in its 40-
year existence (other than for safety and internal controls); and, the program review would be a
valuable resource for the new incoming Superintendent.
The scope of the review includes functional areas and operations of the STSR program. Five
objectives were established:
1. Identify appropriate mission functions of the program, including the role of
science/research.
2. Evaluate program staffing and identify positions and functions necessary to meet
mission requirements.
3. Evaluate program funding and determine financial resources required to meet mission
functions.
4. Evaluate interagency relationships and determine appropriate roles/responsibilities for
shared resource stewardship.
5. Document program successes and highlight practices that should be continued and
shared.
2. Assessment Methods
The program review consisted of three parts: 1) evaluation of plans and documents, 2) personal
interviews with all permanent STSR staff (two were interviewed by phone) and all members of
the park management team conducted on December 12, 2019, and 3) phone interviews with
other Federal and State agencies and partner organizations conducted during January-February
2020. Information from these sources was incorporated into the findings, discussion, and
recommendations included in section 4.
3. Program History and Context
PAIS was established in 1962, primarily for recreational purposes. The park’s Foundation
document (NPS, 2016), articulates the park’s purpose, significance, fundamental resources and
values (see Appendix A). The PAIS STSR program has a long history of success, having been
established more than 40 years ago in 1978 to aid in the recovery of the Kemp’s ridley sea turtle
(hereafter referred to as “Kemp’s”). The Kemp’s was listed as endangered in 1970, under the
Endangered Species Conservation Act, and subsequently listed endangered under the
Endangered Species Act of 1973, as amended (ESA or Act) throughout its range in Mexico and
in the U.S. This species is co-managed by the National Oceanic & Atmospheric Administration
(NOAA)- National Marine Fisheries Service (NMFS) in the marine environment and the U.S.
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Fish and Wildlife Service (FWS) in the terrestrial (coastal) environment. Primary threats to
Kemp’s include: 1) bycatch in fishing gear, 2) harvest and destruction of eggs, and 3) ocean
pollution/marine debris.
Bycatch in Fishing Gear
The major ongoing threat to Kemp's is bycatch in fishing gear. Kemp’s are primarily caught
in shrimp trawls, but also in recreational fishing gear, gill nets, traps and pots, and dredges
in the Gulf of Mexico and northwest Atlantic.
Harvest of Eggs
Almost the entire Kemp’s population nests along the coast of the state of Tamaulipas,
Mexico on the Gulf coast of Mexico, just south of the U.S.-Mexico border. Historically, egg
collection was an extreme threat in this area, but since nesting beaches were afforded
protection in both Mexico and the United States, this threat no longer poses a major
concern.
Ocean Pollution/Marine Debris
Marine turtles may die after ingesting fishing line, balloons, or plastic bags, plastic pieces, or
other plastic debris which they can mistake for food. They may also become entangled in
marine debris, including discarded or lost fishing gear, and can be killed or seriously injured.
A Bi-National Recovery Plan for Kemp’s was completed in 2011 (NMFS, 2011) as a second
revision of the original 1984 Recovery Plan. Dr. Donna Shaver of the NPS was a member of
the Recovery Team. A recovery plan is a guidance document, not a regulatory document. The
ESA envisions a recovery plan as the central organizing tool for guiding the FWS/NMFS and
their partners in efforts to recover a species – it identifies the actions necessary to support
recovery of the species, and identifies goals and criteria by which to measure progress.
In 2015, FWS/NMFS completed a 5-year status review of Kemp’s which assessed whether
recovery/downlisting criteria included in the revised Recovery Plan (2011) were met or progress
was made, as well as assessing the current status of the species. It concluded that identified
downlisting and demographic criteria have not been met and endangered status was
maintained.
Kemp's nesting is essentially limited to the beaches of the western Gulf of Mexico, primarily in
Tamaulipas, Mexico. Nesting also occurs in Veracruz, MX and a few historical records exist for
Campeche, MX. In the U.S., nesting occurs primarily in Texas (especially PAIS), and
occasionally in Florida, Alabama, Georgia, South Carolina, and North Carolina (see Figure 2).
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Figure 2. Distribution and relative abundance of Kemp’s ridley nesting. (NMFS/FWS, 2015).
Kemp’s Status at PAIS
In 1977 there were estimated to be around 200 Kemp’s nesting females left in the world (NPS et
al., 1978). A record low number of nests (702) was produced rangewide in 1985. The primary
nesting site, where 99% of the rangewide nesting occurs, is in Mexico. In 1978, a ten-year
interagency action plan was developed, which included a goal for establishing a Kemp’s nesting
colony at PAIS. The park has been actively working since the 1980s to establish and maintain a
satellite population at PAIS that could contribute to global recovery of the species.
During the 1980s, a period of accelerating species decline, eggs from the primary Kemp’s
nesting beach in Mexico were relocated to PAIS to establish a secondary nesting colony in
order to safeguard against species extinction. In 1980, the park also began coordinating the
Sea Turtle Stranding and Salvage Network (STSSN), eventually expanding to include all
species of sea turtles in Texas. The STSSN is a cooperative effort of federal, state, and private
partners working to document causes of morbidity and mortality in sea turtles to inform
conservation management and recovery. In the 1990s, the park continued to develop, test, and
implement techniques to protect nests, incubate eggs, and produce hatchlings for continued
recovery of Kemp’s.
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In the 2000s, the park expanded their beach patrol operations, incubation capacity, and actively
pursued sea turtle research. In 2002, the park expanded its incubation facility and sea turtle
program offices, and eventually developed a separate laboratory. From 2005-2007 the park
conducted a study to evaluate the potential for impacts to in situ nests from predators, tidal
inundation, human tampering, and vehicle driving (Walker and Shaver, 2008). From 2008-2010
a study was conducted to evaluate techniques for the use of corrals to incubate Kemp’s eggs
(Walker and Shaver, 2011). Corrals are temporary enclosures constructed in suitable areas on
the beach using fencing, which mimic natural processes because they allow eggs to incubate on
the beach under natural conditions while protecting nests from poaching and predation.
More recently (2010-2019), sea turtle strandings (vast majority being greens) have increased
dramatically in the Gulf of Mexico, especially in Texas, and have become a larger part of the
program’s work. The park’s nest patrol and management operations also increased during this
period.
A record high number of Kemp’s nests were recorded in 2017 (24,586 in Mexico; and 353 in
Texas, of which 219 were recorded at PAIS). Currently, the number of Kemp’s nests
documented at PAIS is about 1% of the rangewide total (see Appendix B). Nesting dropped in
2018 and 2019, which is typical due to the reproduction biology of the species (females nest
approximately every 2-3 years). For the 10-year period 2010 and 2019, an average of 110
nests were recorded annually at PAIS. A large nest production year is expected in 2020.
Unique management challenges exist in Texas at PAIS, including year-round beach driving
along all 61 miles of beach (except for 4 ½ miles that are closed) and the fact that Kemp’s nest
during the day. These circumstances present challenges for sea turtle conservation (even in a
“protected” national park unit) that are not present in other coastal NPS units. The park’s
intensive sea turtle nest monitoring and management program has continued to be implemented
to allow unrestricted public beach driving with motor vehicles and in response to reported beach
inundation that may be associated with ongoing erosion and sea level rise.
4. Findings, Discussion, and Recommendations
a. Mission Functions
Before we discuss findings of the STSR program functions, it is important to review the
responsibilities of Federal agencies under the Endangered Species Act (ESA), since it
serves as a guiding principle for Kemp’s management actions in PAIS. First, we are
required to aid and participate in the recovery of listed species by using our authorities to
conserve (recover) listed species (ESA section 7(a)(1)). This is often referred to as the
“proactive mandate”. Specifically, we must utilize our authorities in furtherance of the
purposes of the Act by carrying out programs for the conservation of endangered and
threatened species. Secondly, we must ensure that our actions (or those under our
authority) do not jeopardize the continued existence of the listed species. This is sometimes
referred to as the “reactive mandate”. Specifically, under section 7(a)(2) of ESA each
Federal agency shall, in consultation with and with the assistance of the Secretary, insure
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that any action authorized, funded, or carried out by such agency is not likely to jeopardize
the continued existence of any endangered or threatened species. Lastly, it is illegal to
“take” a Federally listed species (section 9 of ESA). “Take” is defined to harass, harm,
pursue, hunt, shoot, wound, kill, trap, capture, or collect, etc. (section 3 of ESA). The
FWS/NMFS can authorize take that is incidental to actions that are funded, authorized, or
carried out by a Federal agency under this section of the Act in the section 7 consultation
process and intentional take with a section 10 permit as applicable.
In short, under the Act our responsibilities are to provide for both the continued survival and
the recovery of Federally listed species, essentially a two-prong mandate. Below we
discuss important aspects of sea turtle management at PAIS and how they might apply to
our responsibilities under ESA and NPS policy.
As stated previously, the FWS/NMFS identified three major threats to Kemp’s: bycatch in
fishing gear, harvest of eggs, and ocean pollution/marine debris. None of these threats
directly apply to PAIS operations or are within the discretion of park management.
However, as discussed above, legal mandates under ESA call for the NPS to utilize our
authorities to develop proactive programs to conserve (recover) listed species and ensure
our actions do not result in jeopardizing the continued existence (survival) of the species.
The park’s sea turtle program focuses on three primary components: nest monitoring and
management, stranding response, and research. The park’s sea turtle program was
originally designed with a single-species focus on Kemp’s ridley, driven by the 1978
interagency Kemp’s action plan; although the STSR program has evolved over the years to
include other sea turtle species listed under the ESA that are present in the park, namely
green and loggerhead sea turtles.
i. Nest Management
Findings and Discussion
Kemp’s ridley sea turtle
Sea turtles are found in all warm and temperate waters throughout the world and
undergo long migrations, some as far as 1,400 miles, between their feeding grounds
and the beaches where they nest. That said, 95% of worldwide Kemp’s ridley nesting
occurs in the state of Tamaulipas, Mexico. The three main nesting beaches in
Tamaulipas are Rancho Nuevo, Tepehuajes, and Barra del Tordo. Nesting also occurs
in Veracruz, Mexico, and in Texas, but on a much smaller scale. Occasional nesting
has been documented in Alabama, Georgia, North Carolina, South Carolina, and
Florida (Figure 2).
While there is some documentation that suggests occasional and limited nesting of
Kemp’s historically occurred at PAIS (likely opportunistic), there is nothing in the
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scientific literature that suggests PAIS ever hosted robust or even sustainable
populations of Kemp’s.
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The park has carried out a voluntary, intensively managed
program to proactively propagate Kemp's ridley sea turtles that originated from the
1978 interagency action plan.
In the 1970s and 80s, Kemp’s were considered at risk of extinction, and emergency
actions (including nest relocation, incubation, and head starting) were necessary to
address the dramatic population loss that was occurring elsewhere in the listed
population in Mexico. Included among these actions was the goal of establishing a
secondary nesting population at PAIS, per the 1978 interagency action plan, which has
been achieved. This action was successful in increasing the number of Kemp’s
hatchlings at PAIS during the 1990s and 2000s. Recent evidence (Frey et al., 2020)
demonstrates that offspring of PAIS nesting females are returning to the park; however,
the majority of nesters at PAIS are from wild stock. Whether this level of intensive
wildlife management is still necessary is a legitimate scientific question now that
Kemp’s numbers have increased from the low identified in the 1970s that prompted
intervention.
In addition to the ESA, NPS Management Policies (NPS, 2006) require NPS units to
protect rare, threatened, or endangered species (4.4.2) and also actively work to
recover and restore all species native to parks listed under the ESA (4.4.2.3). The NPS
was a member of the Kemp’s Recovery Team that developed the original action plan
(NPS et. al., 1978), which called for the establishment of a secondary nesting colony at
PAIS. This was achieved in the 1990s and continues to be a major conservation
success. The work conducted in the 1980s and 1990s demonstrates that PAIS can
serve an important role as an alternate nesting site for a segment of the population in
the event of a catastrophic population crash in Mexico. The relative contribution that
PAIS makes to Kemp’s nesting is about 1% of the total nests. The park continues to be
an active member of the Recovery Team and a contributor to sea turtle conservation
science. Rangewide population recovery actions are now guided by the 2011 Bi-
National Recovery Plan for Kemp’s (NMFS, 2011).
The practice of nearly 100% nest relocation (removal and relocation of, or incubation of,
eggs to produce hatchlings) at PAIS has been, and is, precedent setting for the NPS.
Generally, the collection of all eggs to eliminate potential mortality due to beach driving,
predation, or ocean inundation is inconsistent with NPS Management Policies (Chapter
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On page 11 of the PEER letter it noted an internal contradiction and possible error concerning the
historic evidence of Kemp’s nesting at PAIS. Although it appears that that there is not a robust record of
evidence of historic Kemp’s nesting at PAIS; some planning documents refer to the park as a major
nesting site of the Atlantic Ridley Turtle (PAIS Natural Resources Management Plan, 1974), while others
indicate sporadic nesting (Action Plan, Restoration and Enhancement of Atlantic Ridley Turtle
Populations, 1978). Definitive, place-based evidence is available for the primary nesting beach in Mexico,
while the anecdotal information noted by PEER provides the basis for PAIS. The 1978 Action Plan
included the goal of establishing a secondary nesting colony of Kemp’s at PAIS.
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4), which requires natural processes to occur uninhibited to the degree possible. These
actions, however, in the context of an endangered population and sea level rise, may
be warranted to allow for the persistence of a small nesting population of Kemp’s at
PAIS, if that is still deemed necessary for the overall success of the species as it was in
1978. In order to determine the future of sea turtle nesting and suitable habitat along
coastal areas within National Parks, the following questions need to be addressed:
• Is it appropriate or beneficial in the long-term to completely bypass the natural
nesting process for all sea turtles?
• What long-term impacts may be caused by eliminating environmental factors that
affect natural selection through the relocation and laboratory incubation of all
nests?
• As sea level rise increases and inundation pressures make beach nesting more
and more difficult, will nest relocation and laboratory incubation be the only way
for the species to persist? And, if so, is PAIS the most logical place to do that?
• Does an intensive nest detection program detract from focus on addressing other
environmental or human caused mortality that recent recovery plans and species
status documents have identified as far more substantial to Kemp’s recovery?
From a larger NPS perspective, other coastal parks focused on allowing natural nesting
may face increasing pressure to relocate eggs to avoid potential or perceived impacts
that could be caused by recreational activities, predation, and inundation due to rising
sea levels.
The 2011 Kemp’s Bi-National Recovery Plan does not commit an agency to any action
within the plan, nor are those actions identified mandatory in nature, rather it identifies
goals and voluntary measures as a road map to species recovery. The plan focuses on
the core population in Mexico and reducing threats to the species. PAIS is included as
a “lead” agency for a variety of actions related to protecting and managing nesting
beaches. The Recovery Plan on pages I-24 to 25 includes PAIS STSR beach patrolling
and sea turtle nesting protection activities, including incubation and rearing of young, as
well as their educational programs. Additionally, the plan addresses how the park
manages oil and gas exploration and development as related to protecting park
resources, especially Kemp’s (page I-27).
The Recovery Plan does not include the PAIS nesting colony or hatchling production as
part of the downlisting criteria (see Appendix B). Nesting beaches and individuals at
PAIS are included as part of the delisting criteria, which includes Mexico and the U.S.
The plan does not require or prescribe the continuation of egg incubation and hatchling
release at PAIS, rather it focuses on “hatchling production necessary to achieve
recovery goals.” The plan includes an action (#214) for PAIS to assist with the
development of a nesting beach management plan for the three primary Mexico nesting
beaches. Similarly, the NPS does not have a beach management plan for PAIS.
The program review found two ESA section 7 consultations and associated biological
opinions (BO) related to Kemp’s at PAIS, which were prepared for the park’s beach
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driving environmental assessment and the proposed construction of cabins to house
beach patrollers (both in 2011). The review found no programmatic BO exists for the
park’s sea turtle program. The NPS holds a take permit issued by the FWS
(TE840727-2, valid 7/15/19-1/31/23) that authorizes annual take of five species of sea
turtles (Kemp’s: 450 animals and 45,000 eggs/hatchlings; green: 3,000 animals and
300,000 eggs/hatchlings; loggerhead: 68 animals and 6,750 eggs/hatchlings). Take is
permitted for authorized research and management activities identified in the permit
(such as tagging, removing and incubating eggs, releasing hatchlings, etc.). There is
no analysis, BO, or authorized incidental take for impacts from public beach driving in
the park. According to FWS Ecological Services Office staff who were interviewed, the
PAIS sea turtle program is considered part of the ESA baseline for the Kemp’s listed
population, due to the longevity of the park’s program, and has been used as a static
part of the analysis to assess the effects of and authorize take by other agencies and
project proponents. Therefore, FWS asserts that any changes to the park’s sea turtle
program would require consultation under section 7 of the ESA (Dawn Gardiner, FWS
Biologist, personal communication, Feb. 18, 2020). FWS staff in the local Corpus
Christi office stated that over 20 BOs (for other agencies’ projects) would need to be re-
evaluated if PAIS were to change their sea turtle management program.
Green sea turtle
The green sea turtle (hereafter referred to as “greens”) was listed as endangered in
1978 under the ESA and was later reclassified by NMFS/FWS (North Atlantic Distinct
Population Segment (DPS)) to threatened in 2016 (NOAA, 2015). Factors contributing
to the green’s decline worldwide is the commercial harvest for eggs and meat; disease;
loss or degradation of nesting habitat; disorientation of hatchlings by beachfront lighting;
nest predation by native and non-native predators; degradation of foraging habitat;
marine pollution and debris; watercraft strikes; and channel dredging and commercial
fishing operations.
Four regions support nesting concentrations of particular interest in the North Atlantic
DPS: Costa Rica, Mexico, Cuba, and the U.S. (Florida). By far the most important
nesting concentration for green turtles in this DPS is Costa Rica. In the U.S., more than
53,000 green sea turtle nests were documented in Florida in 2019 (see Table 2,
Appendix B). The Texas coast and PAIS beaches support a relatively small number of
green sea turtle nests - only 97 since 1979 (23 of these nests occurred in 2017).
Recent evidence shows that the green sea turtle population continues to rebound
(Valdivia et al., 2019).
The most recently revised recovery plan for the U.S. Atlantic population was published
in 1991 (NMFS and FWS, 1991). The revised recovery plan focuses on Florida and
actions primarily by State and Federal agencies in Florida. The plan does not require
any specific PAIS actions; however, the NPS is included as one of many “responsible
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agencies” under action #35 as it is recommended to post educational and informational
signs on important nesting beaches, as appropriate.
Loggerhead sea turtle
The loggerhead sea turtle was listed by NMFS/FWS as a threatened species
throughout its worldwide range in 1978. Like other sea turtle species, identified major
threats to this species include bottom trawl, pelagic longline, demersal longline, and
demersal large mesh gillnet fisheries; legal and illegal harvest; vessel strikes; beach
armoring; beach erosion; marine debris ingestion; oil pollution; light pollution; and
predation by native and exotic species (NMFS and FWS, 2008). Since listing, its status
has been periodically reviewed several times, with the most recent status review
completed in 2009. Currently, a new 5-year review is underway to update the status
and biology of this DPS. In the U.S., loggerhead sea turtles nest predominantly in
Atlantic coastal states as well as Florida and Alabama in the Gulf of Mexico. Total
estimated nesting in the U.S. is approximately 68,000 to 90,000 nests per year. 80-
90% of all loggerhead nesting in the U.S. occurs in Florida. Only 70 nests have been
documented in Texas since 1979. PAIS is within the Northern Gulf of Mexico Recovery
Unit which is the western extent of the U.S. nesting range. There are no specific
demographic recovery criteria or measures for PAIS, or populations within Texas,
identified in the most recent recovery plan for this species.
In addition to all Kemp’s ridley nests, the park protects, collects, and incubates eggs
from all green and loggerhead sea turtles. Green and loggerhead sea turtle eggs
collected at PAIS, and those collected elsewhere along the Texas coast and sent to the
park, are incubated at the park and the hatchlings are released on park beaches.
There seems to be no conservation reason to maintain this practice, and no EA, BO, or
other directive exists to support this management action. The majority of organizations
interviewed suggested that this practice should stop.
Hawksbill and leatherback sea turtles
Two other species of listed sea turtles occur at PAIS: hawksbill and leatherback, both of
which are endangered. Hawksbill nest mostly in the Caribbean and occur in the U.S.
primarily in Florida and Puerto Rico. One hawksbill nest was recorded in Texas at PAIS
in 1998. Leatherbacks nest mostly in the Virgin Islands and southeast Florida. PAIS
recorded one leatherback nest in 2008.
Recommendations
• The STSR program should transition to a sea turtle management program that is
more aligned with the 2011 Kemp’s Bi-national Recovery Plan and current practices.
The program should establish a formal 5-year strategic plan, with the assistance of a
professional facilitator, that is developed with input from the park’s management team
16
and includes other sea turtle experts from within the NPS. The STSR strategic plan
should identify appropriate roles for NPS, NMFS and FWS with respect to endangered
species management and recovery (with input from these agencies and other partners).
The focus of the program should be constrained to Kemp’s ridley nest protection,
followed by efforts to save stranded adult Kemp’s and green sea turtles (and other turtle
species), given that these individuals are important contributors to reproduction and this
activity is part of the STSSN that NMFS currently funds.
o The collection, incubation, and release of green and loggerhead eggs
should eventually be discontinued. Requests for project funding for sea
turtle research and management should favor Kemp’s ridley at PAIS.
• The park should begin to implement and test alternate management strategies
that better align with NPS policy, NMFS and FWS recovery goals, and biological
resource management principles that consider the entire Gulf of Mexico turtle
populations. A phased pilot program is recommended, with section 7 consultation
under the ESA, as necessary, to test in situ nest management and increased use of
corrals. In situ nest management, the practice used at all other NPS units with nesting
turtles, is most consistent with NPS policies and would allow for natural nesting of
turtles: thereby, subjecting the species to the biotic and abiotic factors that shape
populations and allow for their long-term persistence. A phased strategy could include
implementing and evaluating different nest management techniques in different
stretches of the beach. Implementation of this phased strategy could include near-,
mid-, and long-term management objectives. It is recognized that a strategy of this
form would need to be highly managed (identification, marking, and protection of nests)
to avoid and minimize impacts from beach driving, and would likely require an EA to
comply with the National Environmental Policy Act.
Near-term (1-2 years):
• Implement refined safety protocols (see Appendix H).
• Engage in the upcoming 5-year species status review of Kemp’s.
• Identify park-specific “measure(s) of success” for nest detection and
relocation, incubation at the facility versus corrals, and hatchling production and
release.
• Focus the STSR program on Kemp’s management and evaluate the
appropriate scaling of beach patrol and other program operations. Consider the
following strategies:
o MM60-30: In down island areas that receive less beach driving,
reductions in nest relocation should be the desired condition, including in
situ nest protection where nests are marked, fenced, and traffic is
diverted around them; similar to typical sea turtle nest management
performed on beaches elsewhere in the country. Pilot nest management
actions should be identified and evaluated. If nests must be moved in
this area, preference should be given to relocation to corrals.
▪ Patrols on down island stretches should be reduced to five
days per week (e.g. Thursday through Monday), 8- or 10-hour
17
days, and one or two patrols per day (as was done in the past).
Patrols can focus on protecting nests from beach driving and
monitoring to assess the potential impacts of inundation and
predation.
o MM30-17.5: A more intensive strategy of nest protection via relocation of
all nests and eggs to corrals.
o MM17.5-0: Front country areas could include continued relocation of
eggs to the incubation facility. Continue to utilize volunteers to patrol
front country beach and focus reduced staff resources on down island
areas.
Mid-term (3-5 years):
• Implement and monitor pilot actions described above and evaluate
species response.
• With federal and other partners, evaluate the long-term availability of
suitable Kemp’s nesting habitat at PAIS (and elsewhere along the Texas coast)
(e.g. National Wildlife Refuges and South Padre Island).
• Engage the State (and other partners) in dialogue about beach driving
management alternatives that maximize beach access but offset the need for, and
intensity of, beach patrol and nest relocation/incubation.
• Develop a long-term nest management strategy / beach management
plan.
Long-term (5-10 years):
• Continue implementation of the above strategies and work with partners
on species recovery actions, including public education, and management
planning that may need to be adapted due to sea level rise and continued loss of
habitat.
• The park should develop a strategy that establishes goals and objectives for
managing the entire portfolio of natural and cultural resources in the park, including sea
turtles. The strategy should address the entire suite of habitats and species within the
park and identify short-term priorities.
• Integration of the sea turtle program within the resource management and
science division would allow the park Superintendent to ensure that all priority
ecosystem programs are addressed, modify the program as needed to implement
adaptive management, address emerging priorities and issues, prioritize and allocate
limited resources, and implement efficiencies by having staff work across programs
based on seasonality and workload.
ii. Strandings
Findings and Discussion
18
The park has been functioning as the Texas coordinator for the STSSN since 1980.
Activities include: maintaining a network of permitted responders, training responders,
coordinating response to stranding events, collecting and transferring live and injured
turtles to approved rehabilitation facilities, necropsy of dead turtles and recording
associated data, maintaining data and reporting to NMFS. Park staff report that over
the last 10 years there has been a significant increase in the number of sea turtle
strandings that occur in the Gulf of Mexico and, in particular, in Texas at PAIS. Sea
grass, kelp beds, and algae in the Laguna Madre (inside the park) are a food source for
juvenile greens, and thus when stranding events occur, the park can see large numbers
of greens. The park indicates that the demands of these duties far exceeds the
capacity they have internally, which NMFS financially supports.
Most of the strandings on the Texas coast occur in PAIS or nearby; consequently, park
stranding staff are directly involved in the response. However, it also appears that NPS
staff routinely respond and provide assistance outside of the park boundary, rather than
relying on other STSSN responders. To date, it appears that the NPS has carried a
disproportionate burden on behalf of other jurisdictions.
Texas appears to perform a large number of necropsies of stranded sea turtles. NMFS
reports that about 200 necropsies are conducted for the Gulf Coast of Florida in one
year versus 400 per annum for Texas.
2
NMFS indicated that the park is performing
more necropsies than is required for large cold-stun events, and that they have
communicated to park staff that a reduction (sub-sample) is appropriate.
3
Other
suggestions from NMFS included not completing the full stranding form, measurements,
or tagging each animal during mass stranding events.
4
The park should evaluate the
relative cost-benefit of the data collected from performing large numbers of necropsies
in their overall management of the species versus the time and staffing costs that take
away from other natural resource monitoring and management activities.
Recommendations
• Transition from the park’s current stranding response and management model to
more of a coordination role in the state of Texas. The park’s necropsy activities and
protocols should be reviewed with NMFS to ensure that they do not go beyond what is
necessary to meet NMFS’ monitoring and research objectives for the necropsy program
and can be justified in light of the extraordinary time and resources spent to maintain
that level of activity.
o Stranding response should be focused to inside the boundaries of PAIS and
partners and other agencies should respond to non-NPS locations. This
should be based on an assessment of NPS resources and capacity to carry
2
Correction made based on information provided by NMFS (see Appendix K).
3
Correction made based on information provided by NMFS (see Appendix K).
4
Correction made based on information provided by NMFS (see Appendix K).
19
out these activities. See section c. (Staffing) for additional recommendations
on stranding response.
o Submit a funding request proposal to NMFS for additional support for cold
stun response in 2021. Requests are due in August 2020 when the mid-year
STSSN report must be filed.
o Consult with NMFS on STSSN necropsy requirements and lab operations.
o The stranding coordinator is meant to be a facilitator of the response.
Response activities should be delegated to other volunteers and entities rather
than PAIS being solely responsible. If PAIS continues as stranding
coordinator, a more robust response network should be developed; NMFS
indicated they are willing to assist with this.
iii. Research
Findings and Discussion
The park has an active research program and staff have authored or co-authored
dozens of scientific publications over the last 20 years. Nearly all of the STSR
permanent staff members are actively engaged in manuscript production and
publishing. Conducting and facilitating research is among the primary goals of the
program, according to the park’s website. Park staff’s significant production of science
via peer reviewed publications represents an exceptional contribution to the state of
knowledge on sea turtle biology, ecology, and coastal biological resource management.
It is clear that PAIS has made substantial contributions to the overall body of research
and scientific knowledge of sea turtles. This review did not address whether the
research substantially contributed to, addressed, or guided park management actions
related to sea turtle management or other park activities at PAIS.
Recommendations
• Focus research towards efforts that directly improves management of the
species within the park.
• Any Kemp’s ridley research needs or projects should be closely coordinated with
the national Kemp’s Recovery Team and the defined needs of the recovery
plan/program. Sea turtle research that is focused on impacts, ecology, and other topics
outside the park, or of a more academic nature, may be supported but should be
carefully balanced with the costs and tradeoffs associated with an inability to monitor,
manage, and study the other myriad natural and cultural resources at PAIS.
• Contributing to scientific publications is appropriate and admirable, however,
publishing should not be a driver of STSR program or individual success. The park
should actively work with outside partners to identify and conduct future research that
has in the past been conducted by NPS staff.
• Research conducted in the park (whether by a cooperator or by NPS personnel)
should be analyzed and authorized through the issuance of a research permit and
20
tracked in the Research Permit Reporting System (RPRS). All requests for research in
the park should be evaluated by an interdisciplinary team and approved by the
Superintendent.
• When considering and refining what additional science and research is needed to
address park management issues, the park should consider developing a natural
resource science plan or prospectus. The plan would need to identify management
goals and targets and key uncertainties that would benefit from potential research
projects. Those research projects should then be prioritized and conducted in a
manner so that the results would directly inform key management questions and assist
with adaptive management. Preliminary areas of study may include:
o Climate change modeling/scenario planning to evaluate impacts to sea turtle
nesting habitat and to investigate alternative nesting sites.
o Beach erosion and accretion studies to evaluate and model future sea turtle
nesting habitat.
• To assist in prioritizing and focusing future research related to sea turtles, the
park could request a cooperator to conduct a literature search to develop a summary of
the program’s research that focuses on the extent to which PAIS STSR-funded
research and publications have: a) provided information applicable to park
management, b) leveraged existing work of other researchers, c) been utilized by other
authors, and d) fostered international collaboration.
• Ensure research follows NPS and Department of the Interior (DOI) policies,
including: NPS Director’s Order 79: Integrity of Scientific and Scholarly Activities; DOI
Scientific Integrity Policy; and DOI Scientific Integrity Procedures Handbook.
b. Funding
Based on current operational activities and organizational structure, PAIS leadership and
staff in and outside of the sea turtle program have identified potential future funding
shortfalls as early as 2025 and should be commended for their foresight in identifying the
issue. In the next 3-5 years, the STSR program may be unable to support current
operations and discretionary activities considering workloads of existing staff and the current
staffing organization. Since inception, the turtle program has and continues to rely on
several short-term funding streams (e.g. Natural Resource project funding, donations, and
several varied short-term funding projects related to the Deepwater Horizon Natural
Resource Damage Assessment settlement). Current ONPS funds that PAIS directly
controls for daily operations are insufficient, given the existing activities and programs of the
STSR division. Several areas of support or subsidy continue to be provided to the STSR
program from umbrella Parkwide ONPS allocations and are not tracked, accounted, or are
only partially incorporated into budget and planning of the STSR program (e.g. the Facilities
Management employee dedicated for about half the year to repair and maintain the large
fleet of traditional and UTV vehicles). The sea turtle program also assumes several
activities well outside of park boundaries and the park’s primary responsibility. Interviews
with representatives from FWS and Texas Parks and Wildlife Department (TPWD) indicate
that neither the FWS nor the State of Texas provide funding support to the PAIS STSR
21
program (though Texas has provided substantial support, in-kind, boats and other
equipment, during stranding events). Without additional funding the park still conducts sea
turtle management and recovery activities (e.g. collection of turtle eggs, hatching and
release) which serve as mitigation measures that are presumably related to BOs issued by
the FWS for projects along the entire Texas coast and well beyond the boundaries and
administrative responsibilities of PAIS and the NPS.
Several areas of business and program risk have been identified, including some identified
as early as April 2016, that are largely unaddressed, most notably overtime well outside of
Bureau policy and authority.
Key Issues
There are many issues related to funding that surfaced during the PAIS STSR program
review and many of them are intertwined or overlap with other issues that are addressed in
other sections of this report. Consequently, the review team chose to focus on the following
three issues because a.) they rose to the top in terms of impacts (both direct and indirect
and short term/long term), and b.) were broad enough to allow other important issues to
logically nest under them.
i. Overtime and other staffing costs.
ii. Short-term project funding was used to create long-term funding obligations.
iii. The funding level of the STSR program is not aligned with overall park priorities.
i. Overtime and other staffing costs
Findings and Discussion
Following an April 2016 Internal Controls Audit of several PAIS programs and operations,
the audit team noted that the STSR program paid $162,320.10 in overtime for FY2015
and had seven employees that exceeded 250 hours of overtime, including two that
exceeded 600 hours. NPS policy requires that “Bureau heads must approve overtime
pay for non-emergency situations involving: … Overtime pay in excess of 600 hours in a
fiscal year for an employee at any grade level.” (Personnel Management Letter (PML) No.
88-5, May 16, 1988). The supplemental report on overtime also indicated that alternative
forms of overtime (e.g. compensatory time) also need be accounted for as if they were
overtime in any bi-weekly pay limitations. In FY2016 when the internal audit and
recommendations were developed, the turtle program recorded a total of $127,580 of
overtime and that amount has increased every year to a FY2019 total of $201,232 of
regular overtime for 44 employees and Administratively Uncontrollable Overtime (AUO)
for two employees. The number of employees that worked over 250 hours of overtime
has not decreased. In FY2016, seven employees had over 250 hours overtime. In
FY2019, 27 employees had between 100 and 249 hours of overtime, eight employees
had between 250 and 399 hours of overtime, and two employees recorded 433 hours and
569 hours, respectively.
22
Approximately 7,845 hours of regular overtime were recorded in FY19. Based on the
overtime pattern that has occurred for at least five years, the work attributed to these
hours is assumed to be a critical need and should be addressed by additional personnel,
rather than significant amounts of overtime being incurred over a long period of time.
This represents approximately seven seasonals (at 1040 hours/season) or
10 seasonals (for the nesting season of 720 hours). If additional staff were hired to cover
the above hours, total costs would be less than what was paid out of overtime since these
staff would presumably be accomplishing the hours of extra work deemed critical at
standard pay rates.
In FY2019, $35,978 was paid out as AUO. This amount is equivalent to two GS-5 6-
month seasonals ($18,889/season or $37,778) or three GS-4 nesting season seasonals
($10,857/season or $32,571).
Overall, in FY2019, $201,232 was paid out in overtime and AUO (14.6% of the STSR
base budget). This represents nearly 19 additional GS-4 seasonals ($10,858/ 720-hour
seasonal) or 11 additional GS-5 six-month seasonals ($18,889/1040-hour seasonal).
Prior to obtaining a minimum 332% increase in ONPS funds between FY2008 and
FY2019 ($413,850 ONPS in FY2008 to $1,443,000 in FY2010 to $1,374,902 in FY2019),
the STSR program consisted of two permanents and two GS-5 term employees and 24
GS-4 seasonal employees (with four seasonal employees identified as vacant) in
FY2008. By 2019, the program had one GS-13 permanent-full-time (PFT), one GS-11
PFT, three GS-7 PFT, one GS-6 PFT, one GS-7 permanent career seasonal (PCS), one
GS-5 PCS, and as many as 35 to 41 seasonals. In addition, five PFT and PCS positions
were listed as vacant but are included in the latest signed organization chart (Appendix
C). Statements from park staff have indicated a need to hire more staff to assist in
accomplishing program activities, as developed by the Division Chief and approved by
the Superintendent.
The current fixed cost commitment of seven permanent employees is $482,901. Two
additional permanent employees (one GS-7 PFT and one GS-5 PCS) are paid out
of NOAA Restoration Stranding funds (currently funded at $112,000/year) and currently
cost $104,286. In FY2019, approximately 35 seasonals worked for the program with 29
working primarily around the nesting season (April through mid-July
equating approximately 640-720 hours) and six employees working about the full six
months (1040 hours). The seasonal costs during the nesting season were estimated
at $314,770 and the 6-month seasonal costs were estimated at $113,334. Total
personnel services for a year (not including STSSN permanent salaries) are estimated
at $912,105 with the above personnel configuration. This figure represents
approximately 66% of the current allocated ONPS base funds. Total personnel services
costs would be $1,016,391 or 74% of the current base allocation when the two
23
permanent personnel, currently working on STSSN project funds, are included in
personnel services costs.
Recommendations
The 2016 overtime audit recommended 11 different actions for the park and program to
undertake. Specifically, the audit recommended: “After discussion with park
management and regional staff, a cohesive effort in regard to overtime should be made to
consider employee well-being, employee safety, staff morale, ensuring all mandated laws
and NPS policies are followed, and ensure the park establishes effective controls over
overtime and premium pay.” To date, we are only aware of one recommendation, AUO,
that was pursued. Specific recommendations from the 2016 report are included
and are again recommended:
• “(a) Reassigning work to other employees,
• (b) Rescheduling tours of duty,
• (c) Using flexible and compressed work schedules,
• (d) Establishing work priorities,
• (e) Discontinuing low priority activities, and
• (f) Seeking other more cost-effective alternatives.”
Other recommendations include:
• Supervisors should pre-schedule, and per NPS and other policies, supervisors
must pre-approve all overtime deemed essential to carry out critical program activities.
o Unless an actual emergency response is required (e.g. human health and
safety), personnel should not be allowed or authorized to work overtime (including
compensatory time) without prior written or documented approval. Overtime
requests should clearly state the nature and justification for the overtime.
• The Division Chief should develop a staffing plan and prioritize work to
immediately reduce all overtime to 1.2% of the turtle program’s ONPS base allocation
(based on NPS Scorecard standards).
o Based on a FY2019 ONPS Base allocation of $1,374,902, overtime should not
exceed approximately $16,500.
o Stand-by pay and AUO should not be authorized.
o In three years, an objective should be that overtime and compensatory time
are only used for short-term emergency response activities.
• Hire additional seasonal staff and implement shift tour of duties, reassign and
redistribute work responsibilities to other staff, with particular emphasis to address those
critical duties and critical times where nighttime work is essential for Kemp’s egg care.
o Other more cost-effective administrative solutions and staffing solutions are
available and should be fully explored and implemented. In the case of AUO, in
addition to other considerations, these administrative options must be explored
before implementing AUO…“In such a situation, the hours of duty cannot be
controlled by such administrative devices as hiring additional personnel;
rescheduling the hours of duty (which can be done when, for example, a type of
24
work occurs primarily at certain times of the day); or granting compensatory time
off duty to offset overtime hours required.” (5 CFR, Ch 1§550.153).
ii. Short-term project funding was used to create long-term funding obligations.
Findings and Discussion
The park has been very successful in obtaining project funding to maintain and grow its
nest detection and patrol program (over $14M in project funds since 1994). Funding from
several internal NPS sources [USGS-Natural Resource Preservation Program (USGS-
NRPP), Natural Resource Fund Source (NRFS), and Southwest Border Resource
Protection Program (SWBRPP)] have been used to fund STSR operations and have
enabled the expansion of the program. Unlike “programs”, projects are typically defined
as “a temporary undertaking to create a unique product or service.” A project has a
defined start and endpoint and specific objectives that, when attained, signify completion.
PMIS records show that the STSR program has been receiving these project funds
annually for nearly 20 years; often with small changes to project scope and title.
From 2019 through 2026, total projected funding allocated to the sea turtle program
averages approximately $1,996,000/year. Total projected annual soft (project) funding
from 2019 through 2026 averages about $621,000/year with approximately
$519,900/year coming from Deepwater Horizon (DWH) restoration related funding. One-
time event soft funds, in this case DWH funds, currently comprise an annual average
of 26% of the program. Other competitive NPS funds over the 8-year period average
approximately 5% of the program.
Beginning in FY2017, NMFS has been providing approximately $112,000 to support the
STSR program in carrying out duties related to serving as the Texas state coordinator of
the STSSN.
5
Beginning in FY2018, the park also started receiving approximately
$139,000 in stranding support funds from the DOI Deepwater Horizon Trust Fund.
Despite nearly $250,000/year in project fund support for stranding activities, the park
indicates that response needs exceed available funds. NMFS staff indicated that when
the Texas STSSN mid-year report (for the period Jan.-June) is due in August 2020,
additional funds could be requested for the next fiscal year.
6
While the park does not track individual fuel usage by program or division, interviews
indicated that possibly as much as half of the parkwide fuel used in a season might be
5
The DWH Sea Turtle Early Restoration Project provides support to each of the state stranding networks
in the Gulf of Mexico annually. These funds are explicitly intended for enhancement of the five state
stranding networks in order to achieve restoration benefits. See Appendix K.
6
These proposals must be for stranding network enhancement projects. The DWH Sea Turtle Early
Restoration Project funds are explicitly intended for enhancement of the STSSN in order to achieve
restoration benefits. To date, PAIS has received an additional $129,000 (2018-2019) for two seasonal
stranding response positions at Packery Channel, two SCA interns for stranding response, and necropsy
facility improvements. See Appendix K.
25
attributed to the STSR program. The turtle program reported patrolling 229,220 km
(142,431 mi), 234,787 km (145,890 mi) and 251,022 km (155,978 mi) of beach during the
turtle nesting season from 2016 through 2018, respectively. An analysis of fuel usage for
nest patrol activities was completed using an estimate of 10 miles per gallon for all
vehicles, which results in fuel costs of about $32,000/year.
Recommendations
• Ensure that ongoing STSR program operations (recurring, permanent work) is
funded by park base (or other reliable and dedicated funding) and not by special project
funding that is meant to fund specific projects. Project funds should not be used to fund
permanent personnel (except for Career Seasonal employees during their non-core
season), activities, or purchases that create ongoing or future costs/obligations of any
kind.
o Requests for project funding for sea turtle research and management should
favor Kemp’s ridley at PAIS. PMIS#248312, which focuses on night-time
protection and collection of green sea turtle eggs (FY21-23), should be cancelled
and WASO notified. Similarly, SWBRPP funds should not be awarded to and
used by PAIS for ongoing research and management activities for green sea
turtles (PMIS#305534 for FY21). Projects must not support continuation of
existing or operational activities and recurrent monitoring and surveys.
• The park should begin planning for what critical activities must be accomplished
with a 30% reduction in funding resources available.
o One-time event or recovery funding like DWH should not be used to build
programs. Restoration funding like DWH is intended to recover from damages
caused by disasters (or provide for compensatory restoration) to a baseline that
existed prior to the event. This funding expires in 2025, and the park should
have no expectation other funds will become available to fill this perceived
shortfall.
• Personnel services costs for this program should not exceed about 80% of the
ONPS base allocations (based on NPS best practice and Budget Office guidance).
o Annual position management should be discussed with the Superintendent,
particularly when any permanent position becomes vacant. Replacing a vacant
position in-kind should not be assumed.
o Seasonal staffing strategies should be developed to reduce overtime needs that
reflect 1.2% of ONPS base funding.
o New staffing configurations must be developed along with scaling back currently
configured patrol efforts to stay within current ONPS allocations and reduce the
reliance on additional parkwide ONPS funding and unreliable soft funding sources.
o Two staffing plans should be developed with the above constraints,
a minimal staffing plan emphasizing minimal and critical work requirements
and an optimal or desired staffing plan (that includes discretionary activities).
• Develop STSR annual work plans that specify tasks, budget and staffing that are
approved by the Superintendent and monitored and tracked regularly. Ideally this would
26
incorporate measures to document and verify that expenditures (including staff time) are
made consistent with fund source purposes and requirements.
• All capital expenditures over $10,000 should be approved by the Superintendent,
after budget forecasting analysis has been completed by the Division Chief.
• Generate philanthropic support. There are abundant opportunities for the STSR
program to leverage the high public support for sea turtle protection. The sea turtle
program at PAIS is well regarded and the species are charismatic and generally beloved
by the American public. The park could work with partners to develop a "friends group" or
philanthropic support organization that could raise funds for priority sea turtle
management and research. Similarly, many non-governmental organizations (NGOs)
have existing and well-funded programs that support sea turtle conservation worldwide
that the park could tap into by establishing new relationships. Additionally, a significant
amount of public environmental education may be accomplished through a philanthropic
support work plan that would be implemented by a friends group.
• Implement a pilot user fee for cost recovery. The park may consider a permit
program to recover costs associated with implementation of the unrestricted off-road
vehicle (ORV) program. A permit program could generate substantial cost recovery
associated with the needs to protect sea turtles and other wildlife species while allowing
for recreational beach driving. Other NPS units, such as Cape Cod National Seashore,
Cape Hatteras National Seashore, and Assateague Island National Seashore, implement
cost recovery permit programs for implementation of their ORV and protected species
management programs. These programs can generate revenue to offset costs
associated with management activities that are conducted to allow the ORV use. Cost
recovery permit programs are a widely used practice throughout the NPS system.
o A reasonable approach would be to require a beach vehicle driving permit for the
period April 1-July 15, which is the Kemp’s nesting season, when potential
impacts to nesting turtles and eggs could occur. Fees collected should be
commensurate with the cost of the NPS operating the mitigation program.
• Program personnel should stop conducting management activities that occur
outside PAIS boundaries and evaluate elimination of some duties that take park staff
away from higher priority activities in PAIS.
o Documents and interviews with staff and other agencies indicate STSR
personnel are conducting field activities (e.g. turtle stranding recovery, egg
collection, beach surveys, etc.) outside PAIS boundaries. This is a liability
concern for the NPS. Other agencies or groups should assume these duties or
activities outside PAIS boundaries. If others (for example, FWS, TPWD,
NMFS) cannot or do not assume these activities then this would indicate a lower
priority to those groups and thus not relevant to PAIS priorities.
• Other fixed costs should be identified and included in the STSR program budget.
o Itemize and incorporate line item budgets for actual high capital equipment
costs and repairs (e.g. vehicles, UTVs, etc.), fixed fuel costs (at least
$30,000/year), building utility and maintenance costs, anticipated other supplies
and equipment costs and support costs needed for other Divisions, such as when
public releases are planned.
27
o The STSR program should immediately begin building in and accounting for fuel
costs, not only for nest patrol, but for other important programs like the STSSN
program. For the near term a figure of $30,000/year can be used for FY20 and
FY21, which is consistent with a line item identified in the park’s original OFS
budget increase request to the Regional Director for approximately $1.2 million
for the turtle program.
o Install a fuel metering system to track fuel usage by vehicle and/or Division. This
will allow all Divisions and the park to plan for future fixed costs. Electronic fuel
metering is a best practice for all parks.
• The current personnel and position configuration for the STSSN coordination
program should remain as is until 2025 and incorporate those personnel services from
that program into the STSR ONPS base by FY2026.
o Nearly six years of outside funding is available to support the STSSN activities,
which is sufficient time to recalibrate work efforts to operate within the provided
funding level and to further develop the network, contacts, procedures, training
program, and cadre of outside entities needed for responding to strandings outside
the park. If after 2025, PAIS chooses to maintain the Texas STSSN
coordination role, the program and duties should be scaled back to focus
and emphasize coordination, training, and reporting; and with limited use of ONPS
funds.
o The STSSN funds ($112,000) that NMFS provides currently pay for these
personnel and they should be allowed to only focus on the many duties the STSSN
requires for in-park strandings (see Appendix G, section on State Stranding
Coordinators and Stranding Responders). If these personnel are occasionally
needed for other critical duties, then NMFS should be consulted and other funding
allocated for that work, particularly for the Career Seasonal employee.
7
o After 2025, the one permanent full time and one permanent career seasonal total
salary of $104,286 (FY2019) will need to be incorporated into ONPS base funds,
should PAIS choose to remain as the Texas Coordinator.
o By FY2021, the park should begin working with other partners (e.g. FWS,
volunteer groups, etc.) so that other partners are responsible for and patrol the
beach outside of PAIS boundaries, particularly during the Kemp’s nesting season
(see Appendix G, Stranding Responders).
• The park management team should discuss how they want to address significant
support (staffing or monetary) provided by other divisions for turtle program operations,
including turtle release events.
o The number of public hatchling release events is a discretionary activity
and should be reduced. Total actual costs of these events (all personnel and
time) should be tallied in FY20 so the Division Chief and Park Superintendent can
7
Personnel supported with DWH Sea Turtle Early Restoration Project funds are intended to support the
TX STSSN as a whole in order to enhance the network effectiveness across the state (e.g., additional
training, statewide data entry/data management, necropsy support). If these personnel work on other park
projects/activities then their time spent on those activities must be paid with other funding sources. See
Appendix K.
28
identify how many public events can be planned in relation to budget availability to
support these events and other park priorities and needs. Another possibility
would be to identify one week of the year where turtle releases and related public
events would occur (“Turtle Week!” or “Turtle Daze!”), thereby allowing staff to
effectively plan for and conduct outreach and education activities.
iii. The funding level of the STSR program is not aligned with overall park
priorities.
Findings and Discussion
The park's current (FY20) budget for the sea turtle program is $2,196,055 (see Appendix
F). The sea turtle program’s annual base funding (ONPS) is $1,374,902. As such, the
STSR base budget is equal to nearly one quarter (23.8%) of the park’s ONPS budget. In
addition, the program typically secures between $500,000 - $1,000,000 in project funds
each year.
The Science and Resources Management (SRM) division’s budget ($248,670 in FY20),
which is used to manage all other natural and cultural resources science and
stewardship, planning and compliance, and Native American relations, is only 4.3% of the
park’s base budget. The Regional average of park base budget for resource
management programs (which includes cultural and natural resources) was 12.5% in
2018. The STSR percent of park base is about twice the Regional average. Conversely,
the SRM program is funded at a small fraction of the regional average. The park’s
Scorecard shows zero staff, zero labor spending, and zero base funds being applied to
cultural resource stewardship responsibilities, and no use of volunteers in the program
(NPS, 2019). The perception of some park staff is that most natural and cultural resource
management programs have been largely ignored as a result of the intense and
disproportionately high allocation of financial and staff resources applied to the sea turtle
program.
The park’s Foundation document includes a variety of other park resources and values
that warrant study, management, and protection, including nine other listed species. The
resources (funding and staffing) available for protecting, restoring and interpreting those
other resources is much less than the funding levels for the STSR program and in some
cases completely non-existent.
The park has many important and internationally significant natural and cultural resources
that are not being monitored, studied, or managed. For example, the park provides
habitat for more than 300 bird species, it contains 16th century Spanish shipwrecks, and
there are thousands of acres of prairie, dune habitat, and freshwater marshes. The
Laguna Madre within PAIS is considered one of only about 6 hyper-saline lagoons in the
world, where close to 80% of all redhead ducks winter in the U.S., about 80% of all
seagrass beds occur in the entire state of Texas, and where Federally- and State-listed
29
migratory bird species find important habitat. The park’s natural resource condition
assessment documents that a majority of ecological communities and resources in the
park have insufficient information to establish their current condition and trend (Amberg
et. al., 2014). These unique and sensitive resources may be threatened by visitor, and
adjacent land uses.
Members of the review team were shocked at the volume and extent of trash on the PAIS
beaches; in some areas, the entire sandy beach was covered by trash. Close inspection
of the sand indicated large numbers of small plastic particles (microplastics) that were
interspersed with the sand along the entire beachfront. Although the cause of this
situation is outside of the park’s control, more attention should be raised so that progress
can be made to reduce adverse impacts to wildlife and beach aesthetics.
The park’s visitor understanding scores are significantly lower than the Regional and NPS
averages (NPS, 2019).
Recommendations
• The park management team should identify annual park priorities; these one or
two top priorities should be readily known by the division chiefs and budget allocations
should reflect what is required to achieve them.
• The park would benefit from closer coordination and resource sharing between, if
not a full integration of, the STSR and SRM divisions. For example, Biotech positions
may be shared or employment periods extended to accomplish other resource
management work. Funding shortfalls for general natural and cultural resource
stewardship can be addressed by identifying and instituting measures for leveraging
STSR staff capacity to address other park natural resource priorities such as bird
strandings, habitat restoration, and trash cleanup (particularly outside of the Kemp’s
nesting season).
• The SRM division is grossly understaffed and underfunded. We recommend that
the park management team support the hiring of the two permanent FTEs that are
currently in classification.
• Expand beach cleaning (marine debris removal) to improve visitor conditions and
to limit impacts to wildlife; consider developing a parkwide/visitor recycling program and
an interpretive program around it to reduce trash on the beach.
c. Staffing
Findings and Discussion
The program includes a large permanent staff (7-8 FTEs) and approximately 25-35 seasonal
staff during the summer nesting season (see Appendix C for current organization chart).
During the interviews with PAIS staff, several personnel management and work culture
issues were observed including supervisory span of control, staff morale, inappropriate
30
authorization of overtime, telework arrangements that may not match with position
descriptions and work requirements, and lack of effective workload management.
In FY2018, 30 STSR biotechs patrolling the beach in PAIS logged 13,383 hours (during the
nesting season April 1-July 15), covering 155,978 miles – this level of effort equates to 103
staff hours spent per nest detected (130 nests were detected in 2018). A similar level of
effort was expended in 2016 and 2017, where 142,431 and 145,890 miles of beach were
patrolled, respectively (NPS, 2017). The number of hours patrolled at PAIS has steadily
increased over the last 20 years. By contrast, 42 miles of beach on South Padre Island are
patrolled by six staff members from Sea Turtle, Inc. Approximately 30% of Kemp’s and
green sea turtle nesting in Texas occurs on South Padre Island.
Interviews with STSR staff indicated that the two employees paid for with the NMFS
stranding funds are regularly relied upon to work on the nest management program. Not
only does this detract from identified STSSN work needs, but this regular practice could
become a source of staff conflict, burnout, and morale issues. Observations and
discussions suggest that sufficient regular operational work exists for assistant coordinators
(e.g. reporting, compiling data, necropsy, providing updates to NMFS, coordinating activities
throughout Texas, training of others, pre-November coordination meetings with other area
coordinators, rehabilitation facilities, and local and agency partners, etc.). Interviews also
indicated that workload allocation was often not commensurate with grade level. For
example, it is not uncommon for higher graded employees to take shifts monitoring the
incubation rooms.
While the STSR division employs up to eight permanent FTEs and between 24-40
seasonals, the park’s SRM division, which has responsibility for all other natural resources
including nine other endangered species, compliance, external review, park planning, and
cultural resources, has only three permanent FTE (see Appendix E).
Recommendations
● Identify and institute measures for leveraging STSR staff capacity to address other park
natural resource priorities such as bird strandings, habitat restoration, and beach cleanup
(particularly outside of the Kemp’s nesting season). Also, the STSR administrative assistant
can likely help other park divisions outside of the turtle nesting season.
● The NMFS-funded STSSN positions should be used only for work specifically identified
for stranding response. Management and accounting practices that clearly distinguish these
activities from those related to the nesting program should be implemented.
● All new employees should receive an orientation to the park and an understanding that
STSR is one division within the park. The orientation should describe the park priorities and
mission and how the STSR division contributes.
● Continue to utilize volunteers to patrol front country beach to MM17.5 and focus NPS
staff resources on down island areas.
31
● Reduce the number of public sea turtle release events to reduce costs and reduce the
impact on staff from other divisions. Proactively and directly contact other division staff
assisting with releases so those staff do not have to continually call into the hotline to see if
they are working early in the morning.
● News releases and other media contact should be handled by the Park Public
Information Officer (PIO). After consultation with the Park PIO, and in accordance with
Superintendent guidance/policy, STSR staff members may do interviews with media.
● Consider developing and cost-sharing a seasonal Biotech/Interpreter position that could
participate in beach patrolling and attend turtle release public events to provide interpretive
messages.
● A recommended organizational chart for the current STSR program is included in
Appendix D. It includes a structure that can be utilized for the near- to mid-term and can be
scaled according to needs and funding availability. In the longer term the STSR program
should become part of a reconfigured resource management division, which would allow
appropriate supervisory controls and more easily facilitate the leveraging of staff expertise
and resources.
Supervisory
● Improve oversight, direction, and communication provided to the GS-7 Biotechs by
having them report directly to the Division Chief.
● Ensure annual continuing supervisory training for all supervisors regardless of level.
● Evaluate telework agreements (remote duty station employees) to ensure compliance
with NPS and DOI telework requirements. Further agreements should only be allowed for
duties that can be effectively accomplished and the arrangement is to the benefit of the
government and not for the convenience of the employee.
● Focus on staff retention and morale.
● Hold the Division Chief accountable for ensuring that requests for overtime and
compensatory time must be approved in advance and should be rare.
● Consider hiring permanent career seasonals as an option to retain experienced
personnel and reduce administrative/supervisor time and burden of hiring each season.
● Ensure higher graded staff are not performing activities that could be accomplished with
hiring additional lower graded staff or assigned to existing lower graded staff.
d. Safety
Findings and Discussion
As a result of discussions with STSR staff and a thorough review of program
accomplishments, it is clear that the park and all other divisions have an exceptional
commitment to sea turtle management and research activities. There is a potential in any
organization for passionate employees to take unnecessary risks to accomplish the mission.
Discussions with some staff indicated that this potential exists at PAIS. Additionally, the
nature of the STSR program’s compressed turtle nesting season and high workload to
32
monitor, relocate, excavate, incubate, and release turtles, may result in staff burnout and
fatigue. Fatigue and burnout were mentioned as a concern by some staff.
Recommendations
8
● The program should evaluate work requirements and operational plans to reduce and
manage risk - risk avoidance and risk mitigation are recommended strategies.
● The program should implement all safety action items included in Appendix H as part of
the safety review on beach travel conducted in December 2019.
● Implement a standard operating procedure (SOP) for beach entry. This SOP would
define the conditions and parameters for when the beach is closed to the public and to NPS
staff. STSR staff should not be allowed to patrol on the beach when it is closed to the
public.
● The park should review overtime costs and evaluate scheduling and staffing options to
reduce overtime and compensatory time. This would reduce potential fatigue and mitigate
risks associated with working long hours or days without breaks.
● Work-rest ratios should be closely monitored, particularly during turtle nesting season
and stranding events.
o The park should limit the number of employees that work more than 10
hours/day, particularly for routine, operational field activities like nest patrols.
Nesting season activities and patrols are predictable, planned, and an
operational function of the program.
9
Additionally, these patrols occur outside in
hot and humid environmental conditions that may contribute to fatigue.
o Nesting season patrols and activities should be appropriately staffed to provide
beach patrol coverage necessary to:
▪ Ensure that field leaders and subordinates are working no more than 10
hours per day or 40 hours per week.
▪ The workdays are set and predictable such that staff can plan their
workdays and plan for other life demands on non-workdays.
▪ For the remote work at Base Camp (MM30), consider a staffing plan to
implement 4/10-hour days Thursday through Monday or a 5/4/9 schedule
(presumably during the highest visitation during the week) and overtime
only authorized and approved for observed arribada events (when in
PAIS’s case, perhaps 5 or more females observed nesting) to respond to
the extra effort needed for data collection, egg protection, and transport of
eggs to remote corrals.
8
Some of these recommendations are general, best practices and the STSR program may have
implemented one or more of them in the past. STSR program managers and supervisors, and the park
safety officer, should review these to verify they are in place.
9
The timing and duration of sea turtle nesting is variable, which creates operational challenges for the
STSR program. Based on its many years of experience, the STSR program can proactively estimate work
requirements, structure work shifts, and hire seasonals to reduce the amount of overtime hours expended
by the program. However, extraordinary circumstances necessitating overtime may arise from time to
time.
33
▪ Some PAIS staff indicated that the majority of visitors conduct beach
driving within the first 17.5 miles of beach. Consider developing a staffing
plan and tour of duty of 40 hours/week (with no reliance on overtime) to
only provide 7 day patrol for nesting turtles for this beach stretch during
the nesting season (April to mid-July) and during time periods when
beach driving is highest and is the highest risk to nesting turtles.
● Each day, field leads (with subordinate input) should evaluate current and predicted field
conditions and staff fitness and be empowered and supported in determining a go/no-go for
nesting patrol operations (e.g. lightning and weather forecast, tidal flooding/tide level,
equipment issues, etc.).
● Field supervisors and field leads should regularly conduct a green-amber-red (GAR) risk
analysis with subordinates that specifically discuss and address each of the 8 GAR
categories, indicate overall group discussion and team rating, and discuss and document
mitigations to be employed to mitigate mission risk.
o Train staff in the use of GARs and support and ensure their routine
implementation.
o New GARs should be initiated when the planned mission, environmental, or other
conditions change from that discussed and evaluated in the weekly GAR.
● The park should implement an incident command system (ICS) for the management of
large or unpredicted stranding events. The ICS system can be used to manage and
improve accountability for tasks, safety, and finances.
● When full radio communications are unavailable (e.g. repeater is down), all beach patrol
operations for turtles should be discontinued and suspended until communications are
restored. Staff should carry spot devices or other satellite communication devices to provide
a backup for emergency communications in remote areas with unreliable connectivity.
● For remote employees, regular check-in/check-out (on-duty/off-duty, periodic checks)
radio calls and status update should be implemented and recorded at Dispatch.
● Establish written procedure for safety check-ins for staff working after hours tied to either
entrance station closing times (i.e., stranding response after hours and working solo), Visitor
Center closing times, or when Emergency Services personnel go off duty for the day.
● Establish limits and procedures for STSSN Asst. Coordinator and team to physically
respond to stranding calls. Unless a true emergency, the stranding team should not work
more than a standard 40-hour week. The stranding hotline is available and can be used to
follow up on after-hours calls.
● Ensure at least two permanent STSR staff has Operational Leadership (OL) instructor
certification so that OL training can be provided regularly and each year to all patrol staff.
● Adopt the OL principles that empower employees and respect and support their decision
to determine when conditions are not favorable for field work.
● Review the agreement PAIS signed after the fatal accident in 2007 to ensure all safety
recommendations are being addressed, implemented, and met.
e. Interagency Relationships
Findings and Discussion
34
Sea turtle management requires international and domestic coordination. In the U.S.,
jurisdiction for sea turtles is shared among the FWS, NMFS, federal land management
agencies (NPS for PAIS), and the various states that have sea turtle habitat. Consequently,
sea turtle conservation by necessity is an international, interagency, collaborative effort
among many partners including states, academia and NGOs working together.
This review evaluated interagency relationships for their effectiveness, to assess the
appropriateness of PAIS’ role in interagency partnerships, and to promote shared
stewardship. To gain full understanding of the STSR program, the review team interviewed
(by phone) 12 individuals representing seven different organizations (see section 8 for the
list of interviewees). For every interview, two to four members of the review team were on
the call. Each call began with introductions and a brief discussion of the program review
objectives. Relevant questions were then asked depending on the expertise and jurisdiction
of the interviewee.
All the interviewees stated they hold the STSR program in high regard and respect how far
the program has come in 40 years. Texas partners stated that the STSR program staff are
leaders in the sea turtle community. Throughout the calls the review team heard about the
history of the program and how it has transitioned through the years. The STSR was also
praised for raising public awareness for sea turtle conservation. The STSR program has a
very close and good working relationship with FWS Region 2 Ecological Services, Houston
Field Office, for Kemp’s recovery. STSR works closely with the Texas State Aquarium and
Sea Turtle, Inc. on sea turtle stranding response efforts.
NMFS and TPWD expressed their gratitude for PAIS STSR staff taking on the role of the
state stranding coordinator and confirmed no other entity has the capacity to assume the
role. They also praised the early detection and identification of the recruitment pulse of
juvenile greens and threats to areas such as the Packery Channel.
In general, agencies and organizations outside of Texas disagreed with the intensity of sea
turtle management practices at PAIS and how to best protect and recover the species;
however, they understood the unique challenges that PAIS faces with impacts from public
beach driving. Multiple partners interviewed expressed their scientific concerns over the
highly manipulative measures utilized in the recovery efforts at PAIS and recommended
even though there may be some mortality (either of adults or nests) that the program
transition to less manipulative actions that allow for natural processes. No mandates, ESA
or otherwise, exist for such intensive management of the species. Sea turtles have loss
built into their reproductive strategy and not every egg requires intensive management.
Concerns were also expressed about the fitness of hatchlings incubated in a facility.
Overall, the professional recommendation was to encourage actions to remove human
threats and impacts to sea turtle nests and to allow for natural, in situ nesting whenever and
wherever possible.
35
Discussions were had with various partners on the effectiveness of rescuing cold stun turtles
and whether this is a natural phenomenon or if anthropogenic factors have led to an
increase in these events. Modeling predicts increased cold stun events in the future,
including at PAIS (Putnam et. al., 2019).
NPS funding for Kemp’s recovery is disproportionately high compared to the number of
partners involved and the percentage of turtle population being addressed.
The STSR program partners with FWS, NMFS, the State of Texas and many academic
institutions and NGOs. However, the NPS contributes a disproportionate share of funding for
these “collaborative” turtle conservation efforts in Texas. This occurs even though there is
broad consensus among partners and among STSR staff that the number of Kemp’s nests
at PAIS represents just 1% of the worldwide number of nests. Furthermore, funding and
staff time are regularly used for activities related to the role of the Texas Coordinator STSSN
that occur outside the park’s boundaries. The time and money spent on these activities
outside park boundaries is not tracked or monitored separately (that the review team could
determine) and therefore appears co-mingled with and treated as part of the park’s general
STSR program functions. While the population and nesting numbers for Kemp’s have
increased dramatically since establishment of the secondary nesting population, according
to the FWS (website) “the recent nesting increase can be attributed to full protection of
nesting females and their nests in Mexico, and the requirement to use turtle excluder
devices in shrimp trawls both in the United States and Mexico.” From web documents and
recent and revised recovery plans, the FWS does not consider the PAIS nest relocation
program the most important factor that would contribute to overall recovery of Kemp’s. Even
if the costs and staffing levels necessary for such intensive management can be supported
from a scientific and policy perspective, all partners, particularly the FWS, should share in
the costs more equitably.
If FWS believes the current management activities conducted at PAIS are critical and must
be maintained for successful Kemp’s recovery, then FWS should provide funding to assist in
this intensive patrol, nest detection, egg relocation and hatching, and release effort.
Otherwise, a thorough assessment of management activities that are critical to recovery
(e.g. the 2011 Recovery Plan) should be the guide for determining appropriate
management.
Recommendations
● Continue to serve on the Kemp’s Recovery Team and provide data and input as
requested.
● Critically evaluate the efficacy of the nest relocation policy and program given the
predictions and consequences of sea-level rise and loss of suitable nesting habitat at PAIS.
NPS climate change policy requires parks to evaluate potential impacts to park resources,
infrastructure, and operations. The NPS should engage the Kemp’s Recovery Team in
discussions about alternative locations for other nesting sites and strategies to address
rangewide changes to nesting.
36
● Request $300,000 from FWS to support Kemp’s recovery actions.
● Partner with U.S. Coast Guard, FWS, NMFS, and TPWD to use drones to monitor beach
nesting, to monitor for stranded turtles, and to assist with enforcement in remote areas.
● Partner with NMFS and TPWD to more actively and stringently enforce poaching of
ESA-protected species and other activities related to sea turtle conservation in Texas.
● Engage with the State to establish limits on beach driving during sea turtle nesting
season (seasonal closures or other protective measures). Consider implementation of a
temporary or trial ORV permit and evaluate the success and challenges.
● If Texas were to pass a state law that allows ATV/UTVs to utilize public roadways open
to street legal vehicles, then the beach at PAIS (currently open to street legal vehicles) could
be subject to increased use by a new form of vehicle. Therefore, the park should monitor
this issue and determine if the Compendium and/or a special regulation must be
promulgated to manage the activity.
5. Program Successes
PAIS has a long history of dedication and success with respect to the sea turtle program. Much
of this success rests with, and relies upon one individual, Dr. Donna Shaver, who has led the
program since the 1980s. A number of program successes and highlights are included below:
● A secondary nesting colony of Kemp’s ridley sea turtles was established at PAIS in the
1980s, through successful translocation of eggs from Mexico, as a safeguard against species
extinction. The population has grown since then, resulting in a record number of documented
nests rangewide and at PAIS in 2017. In 2017, nesting records indicate about 27,000 nests in
total: 353 in Texas (219 of which were at PAIS), 24,586 at Tamaulipas in Mexico where the
primary nesting occurs, and about 2,000 at Veracruz in Mexico.
● The park has conducted the longest continuous mark-recapture study in the U.S. for
Kemp's ridley. These data, along with STSSN data, have been included in numerous scientific
publications, most of which appear in the peer-reviewed literature.
● PAIS became the Texas Coordinator for the STSSN in 1980 and has continued to
manage stranding data and train partners in stranding response for four decades.
● The program has been very successful in obtaining outside funding, over $14M in
project funds since 1994.
● STSSN data aided the State of Texas with adopting a 5-mile oceanic protective zone in
2000 for shrimping operations, which greatly benefited sea turtle protection.
● The STSR program facility complex (administrative offices, incubation facility, necropsy
lab) was built with funds from DOI in 2002 as one of the Top 12 Projects to Restore America’s
Parks. The incubation lab has a hatchling success rate of 85%.
● The sea turtle program at PAIS has greatly influenced the success of Kemp’s ridley sea
turtle conservation in Texas and in the Gulf of Mexico. Research conducted at the park has
been included in many peer-reviewed publications and former PAIS STSR seasonal staff have
become prominent researchers and managers working on marine conservation.
37
● Sea turtle releases are a popular event, which have led to engagement, education, and
support from the public. This program, as stated by the park management team, has “floated all
boats” with its popularity and success.
● Partnerships with universities and others have contributed to growth in knowledge and
capacity for rehabilitation of sea turtles. For example, in November 2019, KIII TV 3 featured a
story about operating on injured green sea turtles. This project is a partnership between NPS,
Texas State Aquarium, and Texas A&M University - Kingsville Veterinary Technology program.
Partnerships like this are contributing to endangered species recovery and to public education
and support for conservation.
6. References
Amberg, S., A. Nadeau, K. Kilkus, S. Gardner, and B. Drazkowski. 2014. Padre Island National
Seashore: Natural Resource Condition Assessment. Natural Resource Report
NPS/PAIS/NRR—2014/747. National Park Service, Fort Collins, Colorado.
Frey, A., P. Dutton, J. Walker, C. Rubio, H. Frandsen, D. Shaver. 2020. Using genetic kinship
analysis to census nesting Kemp’s ridley (Lepidochelys kempii) in Texas, USA. Poster.
National Marine Fisheries Service and U.S. Fish and Wildlife Service. 1991. Recovery Plan for
U.S. Population of Atlantic Green Turtle. National Marine Fisheries Service, Washington, D.C.
National Marine Fisheries Service and U.S. Fish and Wildlife Service. 2008. Recovery Plan for
the Northwest Atlantic Population of the Loggerhead Sea Turtle. Second Revision.
National Marine Fisheries Service and U.S. Fish and Wildlife Service. 2015. Kemp’s Ridley Sea
Turtle (Lepidochelys kempii) 5-year Review: Summary and Evaluation.
National Marine Fisheries Service, U.S. Fish and Wildlife Service, and SEMARNAT. 2011. Bi-
National Recovery Plan for the Kemp’s Ridley Sea Turtle (Lepidochelys kempii), Second
Revision. National Marine Fisheries Service. Silver Spring, Maryland 156 pp. + appendices.
National Oceanic and Atmospheric Administration, National Marine Fisheries Service. 2015.
Status Review of the Green Turtle (Chelonia mydas) under the Endangered Species Act.
National Park Service. 2006. NPS Management Policies.
National Park Service. 2011. Beach Vehicle Environmental Assessment, Padre Island National
Seashore.
National Park Service. 2016. Foundation Document, Padre Island National Seashore.
National Park Service. 2017. Kemp’s ridley turtle nesting report, Padre Island National
Seashore. Early Restoration.
38
National Park Service. 2018. Management Review, Padre Island National Seashore and Palo
Alto National Battlefield.
National Park Service. 2019. NPS Scorecard for Padre Island National Seashore.
National Park Service, Fish and Wildlife Service, National Marine Fisheries Service, Texas
Parks and Wildlife Department, Instituto Nacional de Pesca. 1978. Action Plan: Restoration and
Enhancement of Atlantic Ridley Turtle Populations, 1978-1988.
Putnam, F. et. al. 2019. Predicted distributions and abundances of the sea turtle ‘lost years’ in
the western North Atlantic Ocean. Ecography 42:1-12, 2019.
Valdivia A, Wolf S, Suckling K. 2019. Marine mammals and sea turtles listed under the U.S.
Endangered Species Act are recovering. PLoS ONE 14(1): e0210164.
Walker, J.S., and D.J. Shaver. 2008. Protecting Endangered Kemp’s Ridley Sea Turtle from
Vehicular Traffic at Padre Island NS. Final completion report for PMIS#97096, funded by NRPP.
Walker, J.S., and D.J. Shaver. 2011. Establish New Techniques to Protect Increasing Numbers
of Endangered Kemp’s Ridley Sea Turtle Eggs at Padre Island NS. Final completion report for
PMIS#129487, funded by NRPP.
7. Report Preparers and Reviewers
Preparers:
● Dave Hallac, Superintendent, National Parks of Eastern North Carolina
● Kristen Kneifl, Chief, Resource Management, Canaveral National Seashore
● John Mack, Biological Resources Program Manager, NPS Regional Office, DOI Regions
6,7,8
● Patrick Malone, Regional Chief of Natural Resources, NPS Regional Office, DOI
Regions 6,7,8 (review team leader)
● Karen Trevino, Chief, Natural Sounds and Night Skies Division, Natural Resource
Stewardship and Science, NPS
Reviewers:
● Jennifer Carpenter, Associate Regional Director, Resource Stewardship and Science,
NPS Regional Office, DOI Regions 6,7,8
● Pat Kenney, Acting Deputy Regional Director - Protection, Partnerships and
Interpretation, NPS Regional Office, DOI Regions 6,7,8
● Mike Wrigley, Branch Chief-Wildlife Conservation, Biological Resources Division, Natural
Resource Stewardship and Science, NPS
8. List of Agencies, Organizations, and Individuals Interviewed
39
Padre Island National Seashore
Eric Brunnemann, Superintendent
Donna Shaver, Chief, Sea Turtle Science and Recovery (STSR)
Oralia Fernandez, Chief, Administration
Brian Slate, Chief, Facility Management
Charles Lassiter, Chief, Interpretation
Joe Roberts, Chief, Visitor and Resource Protection
Shelley Todd, Chief, Science and Resource Management
Cynthia Rubio, Supervisory Biologist, STSR
Jennifer Shelby Walker, BioTech, STSR
Hilary Frandsen, BioTech, STSR
Cameron “Mac” Purvin, BioTech, STSR
Martha Villalba-Guerra, BioTech, STSR
Christian Gredzens, BioTech, STSR
Jennifer Smith, Administrative Assistant, STSR
National Fish and Wildlife Foundation
Michelle Pico, Program Director, Marine Conservation
National Oceanic and Atmospheric Administration – National Marine Fisheries Service
Stacy Hargrove, Sea Turtle Early Restoration Project Coord, Office of Protected Resources
Barbara Schroeder, National Sea Turtle Coordinator
Sea Turtle, Inc.
Jeff George, Executive Director
Mariana Devlin, Conservation Coordinator
Texas A&M University, Galveston
Dr. Christopher Marshall, Professor and Director, Gulf Center for Sea Turtle Research
Texas Parks and Wildlife Department
Lance Robinson, Deputy Division Director, Coastal Fisheries Division
Texas State Aquarium
Jesse Gilbert, Senior Vice President and Chief Operating Officer
U.S. Fish and Wildlife Service
Dawn Gardiner, Asst. Field Supervisor, Texas Coastal Ecological Services Field Office (R2)
AnnMarie Lauritsen, Sea Turtle Coordinator, Southeast Region (R4)
Earl Possardt, Program Office for the Marine Turtle, Division of International Conservation
(national lead for Kemp’s ridley recovery plan)
Mary Kay Skoruppa, Biologist, Texas Coastal Ecological Services Field Office (R2) (sea turtle
coordinator for Texas)
40
Appendix A: Park Purpose, Significance, Fundamental Resources and Values
Park Purpose
Padre Island National Seashore was established when the enabling legislation adopted by
Congress was signed into law on September 28, 1962. The enabling legislation reads:
“…That in order to save and preserve, for purposes of public recreation, benefit, and inspiration,
a portion of the diminishing seashore of the United States that remains undeveloped, the
Secretary of the Interior shall take appropriate action in the public interest toward the
establishment of the following described lands and waters as the Padre Island National
Seashore…”
A park purpose statement identifies the park’s interpretation of the specific reason(s) for
establishment of a park unit. The purpose statement for Padre Island National Seashore was
drafted through a careful analysis of its enabling legislation and the legislative history that
influenced its development.
The park purpose statement included in its Foundation document (NPS, 2016) includes the
words “and scientific understanding,” which were not included in the enabling legislation passed
by Congress. It reads: “Located on the Texas coast, Padre Island National Seashore preserves,
protects, and interprets the outstanding natural, cultural, and recreational resources of the longest
undeveloped barrier island in the United States and its surrounding water for public benefit,
inspiration, and scientific understanding.”
Significance
Significance statements express a park manager’s explanation of why a park’s resources and
values are important enough to merit designation as a unit of the national park system. These
statements are linked to the purpose of the park, and are supported by data, research, and
consensus.
● Padre Island National Seashore is the longest section of undeveloped barrier island in
the United States, protecting the majority of remaining Texas coastal prairie, a dynamic
environment constantly sculpted by wind and sea, and the Laguna Madre, one of the
few hypersaline lagoon environments left in the world.
● As the largest stretch of undeveloped barrier island in the United States, Padre Island
National Seashore provides unobscured views and diverse recreational opportunities
such as beachcombing, swimming, picnicking, camping, sunbathing, fishing, kayaking,
and bird and wildlife viewing in a pristine and solitary environment. Laguna Madre is
an internationally recognized windsurfing area.
● The waters and lands of Padre Island National Seashore provide important habitat
for marine and terrestrial plants and animals, including a number of rare, threatened,
and endangered species. Geography, gulf dynamics, rare coastal prairie and pristine
wetlands, wind tidal flats, biodiversity, location along multiple migration routes, and
41
lack of development make the park an ideal place for natural communities and species
associated with barrier islands.
● Five species of threatened and endangered sea turtles occur in the Gulf of Mexico, and
Padre Island National Seashore is the only area on the Texas coast where nests from all
five of these species have been documented. More Kemp’s ridley sea turtle nests are
found at the park than at any other location in the United States, making it the most
important nesting beach in the United States for this endangered species. Park waters
of the Gulf of Mexico, Laguna Madre, and Mansfield Channel also provide important
foraging and migratory habitat for these species.
● Padre Island National Seashore is critical for bird species including more than 380
documented migratory, overwintering, and resident bird species. The island is
designated as a Globally Important Bird Area by the American Bird Conservancy and
was the first NPS unit to be recognized as a Site of International Importance by the
Western Hemisphere Shorebird Reserve Network.
● Padre Island National Seashore includes important archeological resources relating
to American Indian occupation, the era of early Spanish exploration, maritime history
and shipwrecks, and a robust military history from the US war with Mexico through
World War II. The Novillo Line Camp and associated historic resources of Padre Island
National Seashore include some of the last remaining structures relating to barrier
island open-range cattle ranching in the United States.
Fundamental Resources and Values
Fundamental resources and values are those features, systems, processes, experiences,
stories, scenes, sounds, smells, or other attributes determined to warrant primary consideration
during planning and management processes because they are essential to achieving the
purpose of the park and maintaining its significance. Fundamental resources and values are
closely related to a park’s legislative purpose and are more specific than significance
statements.
● Recreational Opportunities. Created in 1962 “for purposes of public recreation,
benefit, and inspiration,” Padre Island National Seashore is recognized as an
outstanding recreation destination. The park’s beaches, flora, fauna, and surrounding
waters, as well as its cultural sites, present opportunities for a broad array of interests
and recreational pursuits that are uniquely suited and appropriate to the park’s
resources. Big Shell Beach is known for its fishing and shelling. Bird Island Basin
attracts the avid birdwatcher and is one of the nation’s most popular windsurfing
spots. The Laguna Madre is a popular aquatic playground for boating, kayaking,
and fishing. From a highly social beach environment where driving is allowed, to
beachcombing along isolated stretches closed to vehicles, the island provides a diverse
range of opportunities for visitors.
● Barrier Island Ecosystem. From the gulf to the lagoon, the width of land varies along
the island from 0.5 to 3.0 miles, and the park’s landscape changes from beaches to
the primary dune line, then to grasslands broken by scattered small dunes, hardwood
42
hammocks, ponds, and wetlands, and finally to transitional back-island dunes and
mudflats that merge with the waters of the Laguna Madre. These habitats, rich in biotic
diversity, provide important sanctuary for hundreds of species of plants and animals,
including many threatened and endangered species. These habitats also provide rich
opportunities for scientific research.
● Sea Turtles. Sea turtles have become a major natural resource and major visitor draw
because the park offers one of the few places the public can go to witness Kemp’s
ridley sea turtles nesting on the beach and the release of their hatchlings. In recent
years, Padre Island National Seashore has documented nests of all five sea turtle
species found in the Gulf of Mexico and has played an active role in species protection
and conservation research. Since the 1970s, the park has been active in a major,
international research and conservation project to save the most endangered of all sea
turtles, the Kemp’s ridley. These efforts have been expanded to include ongoing patrol
programs aimed to detect, study, and protect sea turtle nests with the help of the local
community, a variety of partners and donors, and a large and active volunteer force.
● Undeveloped Barrier Island. The park protects one of the largest portions of
undeveloped barrier island in the world, providing a wide variety of flora, fauna, and
recreational opportunities. Padre Island is a dynamic system, formed and continually
being reshaped by the action of wind, waves, and tide. Sixty-five and one-half miles
of the island habitat have been set aside for future generations to experience the sites,
natural sounds, and seemingly unending vistas and dark night skies that comprise this
dynamic barrier ecosystem. The 4-1/3-mile section of beach that is closed to beach
driving provides an excellent opportunity for scientific research. This may be the only
stretch of Texas shoreline protected to preserve its natural state while also being easily
accessible to research scientists.
● Collective History. The cultural resources of Padre Island National Seashore include
archeological sites, cultural landscapes, and historic structures. Prehistoric sites show
that Karankawa Indians inhabited the island prior to the arrival of the first Europeans,
using the barrier island and ocean waters for hunting, gathering, and fishing. The park
also protects remnants of historic ranching structures, a campsite dating from the
Mexican-American war, shipwrecks from the days of the Spanish fleet, as well as plane
wrecks and other artifacts from the use of the island as a World War II bombing area.
43
Appendix B: Nests Detected of Kemp’s ridley and Green Sea Turtles & ESA Recovery
Criteria
Table 1. Kemp's ridley Sea Turtle Nests
Average Number of Nests/Year by Decade
Location
1980-1989
1990-1999
2000-2009
2010-2019
Mexico
791
2,014
10,993
17663*
Texas
0.4
5
79
196
PAIS
0.2
3.4
44
110
* For Mexico data in 2010-2019 column, average only includes nest numbers from 2010-2018.
Table 2. Green Sea Turtle Nests for Select Areas of North Atlantic Population DPS*
Year
Location
2015
2016
2017
2018
2019
Florida
37,341
5,393
53,102
4,545
53,015
PAIS
4
0
23
4
11
* Primary nesting location for this DPS is in Costa Rica.
ESA Recovery Criteria
Kemp’s ridley
Downlisting (applies to Mexico only; there are no criteria for U.S.)
10,000 nesting females per season (~25,000 nests) in Mexico (Tamaulipas)
300,000 hatchlings released per season in Mexico
Delisting
6-yr. average of 40,000 nesting females per season (~100,000 nests) in Mexico and the U.S.
6-yr. average of hatchlings is enough to sustain 40,000 nesting females per season in Mexico
and the U.S.
Green
Downlisting
There are no specific criteria included for downlisting in the 1991 recovery plan. However, the
species was reclassified and downlisted to threatened in 2016.
Delisting
1) The level of nesting in Florida has increased to an average of 5,000 nests per year for at
least six years.
2) At least 25% (105km) of all available nesting beaches (420km) is in public ownership and
encompasses greater than 50% of the nesting activity.
3) A reduction in stage class mortality is reflected in higher counts of individuals on foraging grounds.
4) All priority one tasks (listed in the recovery plan) have been successfully implemented.
44
Appendix C: PAIS STSR Organizational Chart (FY20)
45
Appendix D: PAIS STSR Organizational Chart (recommended)
46
Appendix E: PAIS SRM Organizational Chart (FY19)
47
Appendix F: PAIS STSR Current and Future Funding
Division of Sea Turtle Science and Recovery Budget Projection FY2019 - FY2029
Type PMIS
Account Name Authorized FY2016 FY2017 FY2018 FY2019 FY2020 FY2021 FY2022 FY2023 FY2024 FY2025 FY2026 FY2027 FY2028 FY2029
PAIS
Division of Sea Turtle Sciene
and Recovery - Base Funds
$1,374,902 $1,374,902 $1,374,902 $1,374,902 $1,374,902 $1,374,902 $1,374,902 $1,374,902 $1,374,902 $1,374,902 $1,374,902
DON
WCCR/Green Turtle
Tracking
$18,625
PMIS 2E+05
SWBRPP: Conservation of
green turtles
$50,000
PMIS 3E+05
SWBRPP: Conservation of
green turtles
$50,000
PMIS 2E+05
NRPP SCC: Investigating
Kemp's ridley decline
$147,000 $147,000 $147,000
PMIS 2E+05
NRPP SCC: Assess and
Protect Green Turtles at PAIS
$80,000 $80,000 $80,000
PMIS 3E+05
Emergnecy Funds for
Stranded Endangered Sea
Turtles at PAIS
$14,000
WASO
DOI RESTORATION
NESTING (phase1)
$1,558,423 ####### $69,250 $377,649 $362,862 $275,983 $105,000 $44,700
WASO
DOI RESTORATION
NESTING (phase2)
$1,026,197 $205,239 $205,239 $205,239 $205,239 $205,239
WASO
DOI RESTORATION
STRANDING
$1,016,874 $0 $0 $81,174 $101,112 $139,098 $139,098 $139,098 $139,098 $139,098 $139,098
WASO
NOAA RESTORATION
STRANDING
$1,114,437 $0 $106,135 $112,151 $112,151 $112,000 $112,000 $112,000 $112,000 $112,000 $112,000 $112,000
WASO
NOAA RESTORATION
PACKERY CHANNEL
$15,357 $47,072
WASO
Restoration, Sea Turtle
Cabin Construction
$600,000
WASO/
TEXAS
Restoration, Sea Turtle
Nesting Texas, Patrol
Supplies
$50,000 $50,000 $50,000 $50,000 $50,000 $50,000 $50,000
WASO/
TEXAS
Restoration, Sea Turtle
Restoration CABIN building
supplies
$100,000
TOTAL PROJECT FUNDS $2,346,009 $2,196,055 $2,213,239 $2,005,939 $1,961,239 $1,881,239 $1,881,239 $1,486,902 $1,374,902 $1,374,902 $1,374,902
crubio 2 3/10/2020
SWBRPP = IMR- Southwest Border Re source Protection Progra m
WCCR = Texas State Aquarium- Wildlife Ca re, Conservaiton and Reseach Grant Fund
48
Appendix G: STSSN Roles and Responsibilities
SEA TURTLE STRANDING AND SALVAGE NETWORK (STSSN)
PURPOSE/MISSION STATEMENT
The Sea Turtle Stranding and Salvage Network (STSSN) is a cooperative effort to inform causes of
morbidity and mortality in sea turtles by responding to and documenting sea turtles, found either dead
or alive (but compromised), in a manner sufficient to inform conservation management and recovery.
The STSSN accomplishes this through (1) collection of data in accordance with STSSN protocols; (2)
improved understanding of causes of death and threats to sea turtles in the marine environment; (3)
monitoring of stranding trends; (4) provision of initial aid to live stranded sea turtles; (5) provision of sea
turtle samples/parts for conservation-relevant research; and (6) availability of timely data for
conservation management purposes.
STSSN ROLES AND RESPONSIBILITIES
NMFS and USFWS
The National Marine Fisheries Service (NMFS) and U.S. Fish and Wildlife Service (FWS) share federal
jurisdiction for the conservation and recovery of sea turtles. In accordance with the 2015 Memorandum
of Understanding, FWS has lead responsibility on the nesting beaches and NMFS has lead responsibility
in the marine environment. Sea turtle stranding response and rehabilitation has traditionally operated
with a shared jurisdictional responsibility between the two agencies. Both agencies have codified
regulations authorizing each other to respond to stranded sea turtles on land and in the water. All sea
turtle Recovery Plans include a recovery action to maintain and enhance the STSSN with both NMFS and
FWS listed as responsible parties.
In accordance with the MOU:
NMFS shall serve as the lead for and coordinator of the Sea Turtle Stranding and Salvage Network
(STSSN) to attend to dead or distressed turtles in the marine environment or when washed ashore from
the marine environment. Coordination by NMFS of the STSSN may include coordinating placement of
stranded turtles at permitted rehabilitation facilities. Within its capacity, FWS shall provide assistance to
the STSSN, including within the National Wildlife Refuge system. NMFS shall share STSSN information
with FWS to promote the recovery and conservation of sea turtles.
FWS shall serve as the lead for and coordinator of permitted facilities holding sea turtles for
rehabilitation or captive display. FWS shall share information with NMFS on captive sea turtles and
coordinate with NMFS on guidelines and standards for such facilities.
STSSN Network Coordinator
● provide national stranding network protocols, including data collection methods, to ensure consistent
data collection and reporting efforts throughout network
• manage NOAA STSSN Database and maintain user accounts for state data entry
● enter additional stranding data, not entered by states, into the STSSN Database
● code all stranding reports using established notecodes to facilitate data summaries for specific
impacts and anomalies, and enter notecodes into national database
49
● coordinate national response and assist state coordinators (as needed) with local response to unusual
or mass stranding events
● provide assistance to state coordinators and network members, as needed
● participate in scheduled conference calls, meetings, and/or training events and engage in regular
communication with State Coordinators and national coordination team to ensure effective STSSN
implementation
● respond to national-level data requests and refer requests to states appropriately in a timely manner
● ensure consistency in stranding documentation practices
● monitor strandings for unusual events/occurrences and alert/coordinate with relevant entities
● provide real time updates and summaries across the network
NOAA Sea Turtle Veterinary Medical Officer and Mortality Investigation Coordinator
● facilitate/coordinate collection of clinical and necropsy data/samples necessary to identify causes of
strandings
● provide stranding response and necropsy instruction and training to network members, as needed
● provide veterinary assistance to FWS and other agencies for any needs related to live stranded sea
turtles, including animal welfare concerns and compliance with permit conditions
● ensure effective investigation of any unusual or mass stranding/mortality events through direct
involvement, coordination of participating individuals/groups, and/or documentation/reporting of
findings
● ensure data collection efforts are appropriate to inform mortality and morbidity investigations
● provide overarching network guidance on how to investigate mortality events
● participate in scheduled conference calls, meetings, and/or training events and engage in regular
communication with State Coordinators and national coordination team to ensure effective STSSN
implementation
● ensure newly available information is incorporated into network function for mortality investigations
● monitor for unusual events in real time and conduct outreach as near real time as possible to ensure
data are not lost and ensure monitoring is increased if necessary
NOAA National Sea Turtle Coordinator
● coordinate with FWS on issues of joint jurisdiction and interagency coordination
● facilitate national level discussions
● guide STSSN enhancements and program direction to ensure data collection efforts (and data
collected) are meeting conservation and recovery needs
● facilitate/coordinate response to mass/unusual stranding events
● identify/seek/support funding for priority network activities
● participate in scheduled conference calls, meetings, and/or training events and engage in regular
communication with State Coordinators and national coordination team to ensure effective STSSN
implementation
NOAA Greater Atlantic Region Stranding Coordinator
● facilitate communication within network and b/w network partners and FWS/NOAA including running
monthly network meetings
● provide protocols and training (as needed) for stranding response and disentanglement
50
● collate data on stranding, incidental capture, and rehab to produce annual report for FWS and to
provide data to managers
● assist with logistics during stranding events as needed, including organizing transports, working with
municipal, state, and government partners, and media
● provide funding and/or supplies as funds allow and need arises
● data entry and QA/QC
● work with FWS regarding permitting issues such as telemetry and rehabilitation
● investigate unusual stranding trends including engaging national vet and investigating human activities
in the area
● coordinate rehab activities including inspecting new facilities, receiving euthanasia notification,
approving release sites, finding placement for turtles
U.S. Fish and Wildlife Service
● coordinate with NMFS on issues of joint jurisdiction and interagency coordination
● provide Standard Care Conditions (including transport, rehabilitation, and release conditions) for the
Care and Maintenance of Captive Sea Turtles to permitted rehabilitation facilities
● assist where needed on response to mass/unusual stranding events
● engage in regular communication with State STSSN Coordinators and NMFS on rehabilitation facilities
that meet our Standard Care Conditions
● coordinate with the NMFS and State Sea Turtle Stranding Coordinators on the location and timing of
turtle release
● coordinate regarding sea turtle samples that may be transferred out of state for research purposes
State Stranding Coordinators
● oversee and actively coordinate a network of permitted individuals and organizations that participate
as members of the STSSN
● facilitate a response to all reports of stranded sea turtles in their state unless logistically
unfeasible or prohibited by weather or other safety considerations
● organize/provide training to STSSN responders to ensure adherence to STSSN protocols
● establish and maintain a reporting protocol, including the preferred methods of contact for their state
responders
● enter all basic stranding data and photos into the NOAA National STSSN Database weekly (i.e., within
7 days of the stranding event)
● submit completed and QA/QC’d STSSN original forms to the NOAA National STSSN Coordinator
(originals) within one month or sooner from the date of stranding
● provide real-time notification/alert to national coordination team (regarding unusual or mass
stranding events (note: further definition of “unusual” is needed
● participate in scheduled conference calls, meetings, and/or training events and engage in regular
communication with national coordination team to ensure effective STSSN implementation
● assist with analyses/interpretation of data and provide expertise to ensure proper data context
Stranding Responders
● document all strandings in accordance with standard STSSN procedures, including the STSSN reporting
form and digital photographs
51
● report all basic stranding information (date, species, lat/long, condition, injuries) to the state
coordinator within 48 hours of the stranding event and send completed STSSN forms to the state
coordinator within 7 days of the stranding event
● provide real-time notification/alert to State Coordinator regarding unusual or mass stranding events
● regularly communicate with State Coordinator and participate in scheduled training events and/or call
or meetings to ensure effective STSSN implementation
● collect samples and salvage carcasses if requested and permitted
● assist with transport of live animals to rehab and dead animals to point identified, if requested and
feasible
52
Appendix H: Corrective Action Plan - PAIS Beach Travel
Corrective Action Plan
Incident Name:
Beach Travel Review
Unit Name:
Padre Island National Seashore
Date of Accident/Incident
December, 2019
Date of Corrective Action Plan
January 28, 2020
Critical Finding
Action Item
Responsible Party
Due Date
1. Park standards do not provide
guidance to employees on
acceptable levels of risks they
can accept. Specifically, there is
no parkwide guidance on when
beach travel and operations are
acceptable.
1. The park will develop a risk assessment checklist to provide
risk guidance to employees (Similar to fire watch-out criteria).
The document will:
• Apply a risk number to common operational hazards
• Account for the accumulative nature of hazards
• Assign the appropriate management level for acceptance
of risk (Potentially Supt Level)
• Will account for cumulative fatigue
• Operations when communications are compromised
2. The park’s Backcountry SOP
does not address environmental
conditions in terms of
appropriateness for beach travel.
2. The park will establish parkwide conditions acceptable for
beach travel.
3. The park’s Backcountry SOP
does not require employees
traveling down island to
complete daily risk assessment
documents.
3. The park’s Backcountry SOP will require that the Risk
Assessment Checklist described in Finding #1 and SPE/GAR
documents to be completed daily.
4. The park’s Backcountry SOP
does not establish approval
authority level for varying
levels of risk.
4. The park’s Backcountry SOP will establish approval authority
level for varying levels of risk. It will include a “Vocal”
authority with appropriate documentation for down island or
changing conditions.
53
5. The south radio repeater was
not operating on non-Law
Enforcement frequencies
5. When a repeater is not operating, repairs must be a high park
priority.
6. The park has no formal method
of passing general information
to employees; particularly those
staying down island.
6. The park will develop a process for providing an
informational report to all employees (a Morning Report).
This report will be delivered using multiple forms of media
and consists of pertinent information such as weather / tide
forecasts and other significant activities.
7. The park does not provide
employees formal training on
driving the full-size vehicles on
the beach.
7. The park will develop a formal driver training for employees
driving the full-size vehicles on the beach. In addition to
driving techniques, the training will include hazard awareness,
extrication techniques, and for vehicle towing for those
chosen to perform the task.
8. The park does not formally
track minor incidents such as
stuck vehicles or mechanical
malfunctions.
8. The park will establish a parkwide system to track stuck
vehicles and mechanical failures down island.
54
Appendix I: Interview Questions
PAIS STSR Staff
Interviewee’s Name and Title:___________________________________________________
(select questions as appropriate for level/role of individual being interviewed)
What are the priorities of the STSR program?
Has the program’s focus changed over the years?
Is the park’s role in responding to strandings well understood?
How does science and research fit into the program’s priorities?
Is the science that is being funded targeted at park-specific conservation/management needs
OR is it intended to benefit the species at large?
Is there a program implementation plan that defines near-term and long-term needs and
actions?
What are the successes and challenges of the park’s nest management practices?
Are there concerns about safety?
How does the park work with other divisions?
Are there certain functions and duties that could be shared with other divisions? (for example,
administrative support, PIO, seasonals, patrolling)
How does the park work with other agencies (FWS, NMFS, TPWD) and cooperators
(universities, NGOs)?
Are there opportunities for others (other federal agencies, cooperators, partners) to take on
certain stewardship functions?
What suggestions do you have to improve the program?
55
PAIS Management Team
Interviewee’s Name and Title:____________________________________________________
What is your overall impression of the STSR program?
How does the STSR Chief work with you and your Division? Are there areas of concern or
needed improvement? Are there successes? How does the STSR Chief work with the rest of
the Park Mgmt. Team?
Is there a common understanding of Park-wide priorities? How do the STSR priorities fit into
these?
Are there certain functions and duties that could be shared between your divisions? (for
example, administrative support, PIO, seasonals, patrolling)
Should the STSR program remain as a separate division or should it be combined with and fall
under the RM division?
Other:
56
PAIS Cooperators
Interviewee’s Name and Title:___________________________________________________
(select questions as appropriate for role of agency/organization/partner being interviewed)
How does PAIS work with your agency/organization/university?
How does PAIS partner with you on sea turtle science needs? How does PAIS partner with you
on management needs?
Is the science that you are conducting on behalf of NPS/PAIS targeted at park-specific
conservation/management needs OR is it intended to benefit the species at large?
How is the science you are conducting meeting the research priorities of your
agency/organization and those of NPS/PAIS?
What are the successes/challenges/concerns of the park’s nest relocation and management
practices? Are there other nest management practices that should be considered?
What are your thoughts about NPS/PAIS serving as the state coordinator for the STSSN? Are
there other interested/suitable entities?
What are your thoughts about the level of response/action that is appropriate for strandings?
What is the role of your agency/organization in responding to threats to sea turtles, such as
illegal fishing, climate change, etc? What do you feel is the appropriate role for NPS/PAIS?
Are there opportunities for you/your agency to take on certain stewardship activities that PAIS
has historically handled?
What suggestions do you have to improve the PAIS sea turtle program?
What, if any, additional partnerships do you think are needed at PAIS?
57
Appendix J: Superintendent E-mail
58
Appendix K: NMFS E-mail
59
60
