A04_-_Turtle_Pilot_Project_SOW_06_16_26-_final_1.pdf

U.S. Fish and Wildlife Service

International Affairs

Scope of Work – Housing, Care, Testing, Data Management for Confiscated U.S. Native

Turtles to Support Repatriation

1. INTRODUCTION AND OVERVIEW

Summary: The United States contains more species of turtles than any other country – accounting for approximately 20% of turtle species richness globally. These species face increasing pressures, particularly from illegal collection and international trade. Demand for U.S.

turtles remains high in East Asian markets for use as pets, food, and medicinal ingredients. While federal and state law enforcement agencies are skilled at intercepting trafficked turtles, a critical limiting factor remains: the lack of sufficient capacity to house, evaluate, and safely return confiscated turtles to the wild. This project addresses that need by piloting a structured turtle management system in partnership with U.S. States and Tribes, with the goal of responsibly repatriating turtles to the wild. This effort will enhance the long-term conservation resilience of native turtle populations and help stop the loss of American wildlife to illegal markets abroad.

Overview: Wildlife professionals broadly agree that U.S. native turtle trafficking volumes have escalated to crisis levels over the past decade. Large-scale seizures involving hundreds of turtles are now common. U.S. species most frequently encountered include box turtles, spotted turtles, and mud and musk turtles, along with other high-risk species such as wood turtles, bog turtles, and diamondback terrapins. Not only does trafficking undercut domestic conservation efforts to protect our native wildlife, but it removes important ecological engineers from our landscapes, responsible for seed dispersal and nutrient cycling.

Federal and state law enforcement agencies devote substantial resources to combating illegal turtle trafficking. However, seizures involving live turtles require immediate access to appropriate housing, animal husbandry, and veterinary care. Insufficient space and resources often force officers to delay seizures, divert operational time to animal placement, or temporarily house turtles in unsuitable office environments. This gap significantly limits optimal enforcement.

Short-term care is challenging, but long-term management has become nearly untenable. The

U.S. Fish and Wildlife Service (Service) Office of Law Enforcement (OLE) created an action plan, aligned with international guidance, to address immediate turtle care by coordinating a

Wildlife Confiscation Network of zoos, aquaria, and other conservation focused partners. These institutions, however, are designed to serve only as temporary holding facilities until investigations conclude and generally lack the capacity to house long-lived species like turtles for extended periods.

This limitation directly constrains the Service’s ability to address illegal and biologically unsustainable turtle trade. As a result, there is an urgent need to develop alternative long-term placement options, including evaluating opportunities for repatriating eligible confiscated native turtles to the wild.

https://cites.org/sites/default/files/documents/COP/20/resolution/E-Res-17-08-R20.pdf

2. BACKGROUND

International wildlife trafficking generates billions of dollars in criminal profits annually. This illegal activity not only depletes wildlife but deeply affects our own communities. Wildlife trafficking undermines the rule of law, funds transnational criminal organizations, and erodes profits for legal and sustainable trade. Wildlife trafficking of live animals especially presents risks for the spread of infectious diseases and invasive species. Further, losing our native species means weakening the ecosystem services they provide. For turtles, this includes their roles in nutrient cycling, habitat creation, seed dispersal, and regulation of small vertebrate and invertebrate populations. Confronting and reducing wildlife trafficking benefits human communities, including with positive health outcomes for people and animals – consistent with the principles of an integrated approach to wildlife conservation and human.

Turtles are among the U.S. species most targeted for illegal international trade. The U.S. has long demonstrated global leadership in turtle conservation, including strong adherence to legal international trade. As a Party to CITES (the Convention on International Trade in Endangered

Species of Wild Fauna and Flora), the U.S. strives to ensure international wildlife trade is not detrimental to species in the wild, including turtles. In terms of international protections, 47 of the 61 turtle species native to the U.S. are included in the CITES Appendices. In terms of domestic protections, 14 native turtle species are listed under the Endangered Species Act, and many receive further protections under state law.

Due to their decades-long life span, turtles present law enforcement with a uniquely complex and resource-intensive challenge. Large-scale turtle seizures require both immediate action to rapidly secure appropriate housing and veterinary care, and long-term management capacity. The current network of institutions that support confiscated wildlife lacks the resources to provide both sustained care for seized turtles and temporary holding space for new confiscations while investigations proceed and forfeiture determinations are made. Under U.S. regulations (50 CFR

Part 12 on seizure and forfeiture procedures), the preferred disposition of confiscated live wildlife—when safe and appropriate—is release into suitable habitat within the species’ historical U.S. range. Release requires landowner and State approval and may not occur if disease or public‑health risks exist. Adequate quarantine and comprehensive genetic and pathogen testing are essential to support informed decision‑making on disposition of these confiscated specimens.

The Service International Affairs seeks a contractor to provide housing, husbandry, veterinary services, genetic and infectious disease testing, and data management for up to 500 confiscated native turtles and tortoises, with the goal of carefully assessing animals for return to the wild when it is safe and appropriate. The contractor must maintain adequate facilities and possess expertise in animal care, reptile veterinary medicine, sample collection, genetic and pathogen analysis, project management, and data administration.

3. WORK TO BE PERFORMED BY CONTRACTOR

3.1 WORK RESPONSIBILITIES

The contractor will work closely with the Service’s International Affairs Program and partners—including OLE and State and Tribal wildlife agencies—to implement established best practices for triage, testing, genetic and pathogen analysis, and disposition decision-making.

Where gaps in best practices exist, the contractor will collaborate with program partners to develop and provide recommendations to the Service. The Service retains full approval authority over all management practices for turtles held pursuant to this contract. Additional partners may include the Collaborative to Combat the Illegal Trade in Turtles (CCITT), the Southern

California Wildlife Confiscation Network (SCWCN), and other zoological institutions. The contractor is expected to maintain regular communication with partners and incorporate their technical expertise as directed by the Service.

The project includes turtles originating from federal, State, or Tribal enforcement actions. The contractor shall manage turtles according to their legal status (e.g., seized evidence, abandoned, or forfeited) and comply with all Service-issued guidance.

The contractor will collect required data at each critical stage, ensure entry into approved data systems, and provide complete datasets to the Service and designated partners. The contractor must maintain rigorous data quality controls and manage data in accordance with Service-issued guidance.

The Service, in coordination and consultation with the respective State or Tribal wildlife agency, will be responsible for releasing suitable candidates into appropriate habitat within the species’ historical U.S. range when it is safe and appropriate to do so. The Service will require logistical support from the contractor to facilitate repatriations of suitable candidates or long-term placement of turtles that must remain in captivity. All turtles that remain in the contractors' care at the end of the period of performance shall be returned to the Service or the respective state or

Tribal wildlife agency.

Specific Tasks and Objectives:

Contractor Qualifying Criteria:

Contractor shall:

• Have and maintain appropriate federal, state or tribal licenses and permits required to house and care for live animals, including any species-specific requirements.

• Be trustworthy and demonstrate ability to maintain confidentiality regarding sensitive case related information.

• Demonstrate ability to sufficiently maintain all relevant records pertaining to acquisition, possession, transfer, transportation, health and welfare, breeding, trade, and disposal.

• Utilize safe and appropriate handling techniques and equipment for live turtles

(e.g., using personal protective equipment; minimizing stress and environmental exposures).

• Be compliant with all relevant partner government agency requirements (e.g., USDA, CDC, NOAA, State agencies).

• Have a veterinarian on staff (or immediate/prompt access to a veterinarian) specialized in triage, diagnosing, and treatment of live animals, including species-specific expertise.

• Have health and welfare standard operating procedures and guidance documents available to all staff involved in the care of the turtles.

• Document handling and care training or certification for staff.

• Have emergency response procedures and facility contingency plans in place.

• Provide a central point of contact who is reliably available to the U.S. Fish and

Wildlife Service and designated partners, including outside normal business hours.

Contractor shall not have:

• A conviction, or entry of a plea of guilty or nolo contendere, for a felony violation involving wildlife, including but not limited to the Lacey Act, the Migratory Bird

Treaty Act, the Bald and Golden Eagle Protection Act or the Animal Welfare Act.

• Misdemeanor charges (including Violation Notices) for conservation, wildlife, or animal welfare law violations in the last five (5) years.

• Civil penalties assessed for violations of the Endangered Species Act, the lacey

Act, the Migratory Bird Treaty Act, the Bald and Golden Eagle Protection Act or the Animal Welfare Act.in the last five (5) years.

Facility Requirements

The contractor must operate a year-round facility equipped to house up to 500 confiscated native turtles and tortoises. The facility must meet or exceed Association of Zoos and Aquariums

(AZA) care standards. The facility should include:

• Climate control with backup systems.

• Secure, species-specific enclosures with proper space, retreat areas, enrichment, sanitation, veterinary care, and suitable habitat conditions (lighting, humidity, ventilation, temperature).

• Independent quarantine sections for new arrivals or animals with pathogens.

• Equipment and controls for safe brumation management.

• Turtle care area closed to the public.

Intake and Species Management

The contractor shall accept turtles under the direction of the Service’s International Affairs and

OLE. The facility must be equipped to accommodate a range of terrestrial and aquatic turtle species. Priority species will include: Terrapene spp., Clemmys guttata, Glyptemys insculpta, Malaclemys terrapin, Glyptemys muhlenbergii, Kinosternon spp., Sternotherus spp, and other species. Species of low conservation concern that are commonly encountered in the domestic pet trade (e.g., Trachemys scripta, Graptemys pseudogeographica) are unlikely to be included in this project.

Veterinary Care and Husbandry

The contractor shall provide daily husbandry from trained animal care staff and routine veterinary evaluation by licensed veterinarians. Care requirements should be consistent with guidelines in the AZA Taxonomic Advisory Group (TAG) Animal Care Manual (ACM) and include:

• Species‑appropriate diets and supplementation.

• Regular health monitoring and disease screening.

• Treatment of ill animals for reasonably treatable conditions using current best veterinary practices.

• Humane euthanasia, when necessary, in consultation with the Service.

Identification and Marking

The contractor shall implant sterile passive integrated transponder (PIT) tags in all turtles of suitable size and health, following established professional protocols.

Genetic and Pathogen Testing

In coordination with the Service, the contractor shall establish an adaptable pathogen screening protocol, including a plan for pathogen testing using appropriate detection methods. The contractor is responsible for conducting or subcontracting comprehensive pathogen and genetic testing and delivering timely, accurate results to the Service. Subcontractor costs shall be borne by the contractor. Repeated testing may be required for certain pathogens.

Data Management

The contractor shall collect, maintain, and promptly report data to partners identified by the

Service. Data must be managed in accordance with Service data‑quality standards and stored securely. All data produced under this contract is the sole property of the U.S. government and cannot be used by the contractor or others without the expressed, written consent of the Service.

DATA OWNERSHIP, ACCESS, USE, AND DISPOSITION

1. Government Ownership of All Data All data, records, information, photographs, test results, analyses, metadata, facility documentation, specimen information, genetic and pathogen testing results, and any other materials produced, collected, generated, derived, or otherwise obtained under this

Contract (“Project Data”) are and will remain the exclusive property of the Service). The

Contractor obtains no ownership, license, interest, or rights of any kind in the Project

Data.

2. Restrictions on Contractor Use The Contractor shall use Project Data solely for the purpose of fulfilling the requirements https://northeastparc.org/docs/NEPARC-Turtle-PIT-Tagging.pdf of this Contract and for no other purpose. The Contractor is expressly prohibited without written Service authorization from:

• using Project Data for independent research, commercial activity, publication, or external communication,

• sharing Project Data with any party other than FWS designated partners,

• aggregating, analyzing, or deriving new data for any non-FWS purpose, or

• entering Project Data into any nonapproved system or database. This restriction applies to all raw and derived data, including genetic, pathogen, health status, and facility development information.

3. Data Handling and Access Controls The Contractor shall maintain strict controls to ensure that Project Data is accessible only to personnel authorized in writing by Service International Affairs. The Contractor must implement secure storage, transmission, and backup procedures consistent with applicable federal data security requirements.

4. Prohibition on Secondary Use or Disclosure The Contractor shall not disclose, disseminate, publish, distribute, transfer, or sell any

Project Data. The Contractor shall not permit subcontractors or partners to access Project

Data unless expressly authorized in writing by USFWS, and any authorized subcontractor must be bound by data handling requirements at least as stringent as those in this

Contract.

5. Government Rights in Derivative Information Any derivative materials—such as data summaries, dashboards, analyses, or draft reports created by the Contractor—are considered Project Data and are owned exclusively by

USFWS. The Contractor may not retain, reuse, or replicate derivative materials.

6. Data Location and Residency The Contractor shall store Project Data only on secure servers located within the U.S. No

Project Data may be transferred, transmitted, processed, or mirrored outside U.S.

jurisdiction without written approval.

7. Breach Notification Any suspected or confirmed data loss, breach, unauthorized disclosure, or unauthorized access must be reported to USFWS within 12 hours of discovery, followed by a written incident report within 48 hours.

8. Survival of Data Obligations All data ownership, security, and use restrictions survive termination or expiration of the

Contract.

Reporting and Engagement

The contractor will also be expected to develop and deliver quarterly virtual and/or in-person update presentations on the project to Service International Affairs and other designated partners.

The contractor will be expected to travel to a minimum of one meeting to share updates on the development and management of the dedicated facility and the turtles held therein. The contractor must demonstrate appropriate animal care expertise of all contracting and subcontracting staff active throughout the award period.

Evidence Handling

The contractor shall handle all turtles as evidence in an active investigation, unless otherwise instructed by Service Office of Law Enforcement (OLE) or by originating State or Tribal law enforcement agency.

• Turtles shall be accompanied by a Chain of Custody form.

• Turtles shall be marked, tagged, or individually identifiable and associated with accurate seizure tag numbers.

• Breeding confiscated turtles is not allowed. Reasonable measures should be taken to avoid reproduction. Any incidental offspring resulting under this project must also be maintained and handled as evidence and are the sole property of the U.S. government.

• The Contractor shall not place turtles that are under this project on public display without written permission from the Service.

• Mortalities: deceased turtles shall be bagged as evidence, marked with the case number, seizure tag number, date of death, notes that may be relevant for the case, and frozen.

Contractor shall contact the OLE case officer for further instruction.

• The Contractor shall not discuss any case information or turtles that are evidence with anyone, except the staff who are actively involved in their care without the written permission of the OLE.

• The Contractor shall not post or publish any information about the turtles or case on social media or any form of press release, unless approved by the Service OLE

• The Contractor shall not dispose of, transfer, or otherwise remove from their custody any turtles that are evidence, unless authorized by Service OLE.

At the conclusion of the period of performance, all turtles remaining in captivity under this project shall be returned to the Service or to the respective seizing State or Tribal wildlife agency, as directed by the Service. The Service reserves the right, at any time during the period of performance, to direct turtles held under this project to be transferred to another entity or returned to the Office of Law Enforcement (OLE). The contractor shall comply with all such directives promptly and in accordance with applicable Service procedures.

4. GOVERNMENT-FURNISHED MATERIALS/SERVICES

None.

5. SUMMARY OF MILESTONE DUE DATES

The target date for contract commencement is September 1, 2026, with an ability to begin accepting turtles beginning approximately October 1, 2026. Regular contact with USFWS

International Affairs will be required, especially at the beginning of the contract. A comprehensive report on the outcomes of the project will be due two weeks after the end of contract date.

6. DELIVERABLES

Before accepting turtles, the Contractor is required to provide a holding facility report that demonstrates compliance with all facility, veterinary care, and husbandry requirements as specified in the contract. At the conclusion of the contract, the contractor shall provide a comprehensive project report. The project report will detail the numbers and species of turtles held, and for each individual turtle, detail their origins, the status of genetic and pathogen testing, brief health status, and any other relevant information. The report will also document generally the status of the development of the dedicated facility with photos and descriptions of key systems and equipment, proposed protocols and benchmarks for quarantine release and reintroduction, and any additional reporting requested by the Service.

7. PROJECT COMPLETION/DELIVERY SCHEDULE

The deliverables for this contract will be performed on an ongoing basis with all deliverables completed by the end of the contract. USFWS reserves full ownership rights to the deliverables.

8. TRAVEL EXPENSES

The contractor shall travel as required to support program tasks. All travel arrangements and payments are to be made by the contractor. The contractor shall make every effort to keep travel costs to a minimum. The contractor must comply with regulations under the Fly America Act.

Travel arrangements must be approved in advance by the Technical Liaison.

9. PERIOD OF PERFORMANCE

The contract will be active from September 1, 2026, through August 31, 2027.

10. LOCATION OF WORK

Work will be conducted in the United States with some travel to meetings, dialogues, and workshops as needed and appropriate.