The material enclosed in the box below is released via the Open Game License.
While this beastie has a ton of hit points, it is a noncombative herbivore, which reduces its combat ability significantly.
For an aggressive, predatory giant turtle, make the following adjustments:
Armor Class: 21 (-2 size, +13 natural), touch 8, flat-footed 21
Base Attack/Grapple: +7/+22
Attack: bite +12 melee (2d6+10)
Full Attack: bite +12 melee (2d6+10)
Special Attacks: Improved Grab
Fort +13, Ref +7, Will +4
Feats: Alertness, Great Fortitude, Improved Initiative, Endurance
Challenge Rating: 6