Finished! The only other change I'd make is that I would stuff the turtle after round 4 of the bellyunless you have small hands, which I do not. With my suggested changes, I would text the pattern to others.
Instead of sc2tog, I prefer the invisible decrease done in two front loops. It looks cleaner and does the same thing.
At round 10 of the shell. it doesn't make sense. The pattern indicates crocheting in the FLO, but then there's a note below that saying to crochet it all in the BLO and mark the FL for the frill. Based on other patterns, I'm going to do round 10 in the BLO.