APPENDIX A 

Summary of Public Comments and Responses 

Based on our request for public comments on the draft Environmental Assessment (EA), we received 13 

comments from various international and state agencies, organizations, and private individuals. Nine of 

these were fully supportive of APHIS-WS’ Oral Rabies Vaccination (ORV) programs and the proposed 

field trial and two were supportive of the program, but had concerns or suggested corrections to the EA, 

as described below. Two of the comments submitted were opposed to APHIS-WS’s proposal; one 

suggested that APHIS-WS had not properly informed the public of the intended field trial and the other 

thought the field trial was a waste of money. Three of the comments brought up issues that required a 

response. The comments and APHIS-WS’ responses to those comments are below. 

Comment 1 

Unintentional human exposure will occur, especially when the product is used in high density population 

hand baiting areas. Twenty percent of calls from individuals to the toll free number printed on the 

packets, reported human contact with open packets. And the number of calls from areas with high hand 

baiting was significantly higher than those from predominately air baited areas. At a minimum, a system 

to appropriately identify, advise, diagnose, and provide appropriate medical care for individuals with 

significant exposure (open wounds, bites, mucous membranes) to the vaccine should be put in place. 

Response 1 

APHIS-WS will undertake several measures to mitigate potential bait/vaccine exposures. All ORV 

programs, including this field trial, are widely advertised and public outreach is employed to inform the 

affected public of measures to take in the event that they find a bait (i.e. don’t touch the bait or move it; if 

bait must be moved, pick it up with a shovel, etc.; do not remove a bait from a pet’s mouth). The ORV 

baits are labeled with a toll-free number to call for further information or guidance if a bait is found. 

Aerial distribution of baits will occur in rural areas only. In urban and more developed areas, baits will be 

distributed by hand by WS personnel. These measures further reduce the potential of baits being placed in 

areas frequented by humans and pets. 

APHIS-WS recognizes the need for an established protocol to triage callers in the event of a vaccine 

exposure or unlikely adverse health event. APHIS-WS has established a Field Trial Oversight Committee 

to oversee the development of this EA and to address potential concerns regarding the AdRG1.3 field 

trial, including those outlined in this comment. The committee consists of officials from APHIS-WS, 

Veterinary Services-Center for Veterinary Biologics, Ontario Ministry of Natural Resources (OMNR), 

Quebec Ministry of Natural Resources and Wildlife (QMNR), and the Centers for Disease Control and 

Prevention (CDC). Both the OMNR and QMNR were able to provide expertise and experience with the 

use of the AdRG1.3 rabies vaccine in field trials in their respective Provinces (there have been no reports 

of adverse events resulting from these field trials). APHIS-WS and the CDC have worked closely to 

establish a response protocol and develop a SOP flow chart to assist Health agency personnel in assessing 

the potential risk to callers who report contacting a bait. Additionally, this SOP for bait contacts also 

includes guidance for working with the CDC and following up with callers at specified intervals 

depending on the risk level. 
Comment 2 

The National Park Service (NPS) should be added to the list of cooperators in Section 1.9 of the EA. 

Additionally, the commenter requested that Section 1.9.2 of the EA be corrected to reflect the fact that 

even though states exercise their authorities under state law to propose or approve the distribution of ORV 

baits onto lands owned by other entities, the ultimate authority with jurisdiction over distribution of ORV 

baits on NPS lands is NPS. 

Response 2 

Regarding the first suggestion to add NPS to the list of cooperators in Section 1.9, APHIS-WS has 

decided not to change the current wording in the EA. Section 1.9 reads: “The APHIS-WS National Rabies 

Management Program (NRMP) cooperates and coordinates closely with the United States Forest Service 

(USFS) and the Bureau of Land Management (BLM). Additionally, the APHIS-WS NRMP consults with 

the United States Fish and Wildlife Service (USFWS), the Tennessee Valley Authority (TVA), the United 

States Army Corps of Engineers (USACE), the United States Coast Guard (USCG), the Department of 

Defense (DoD), the National Aeronautics and Space Administration (NASA), the Federal Bureau of 

Investigation (FBI), the Bureau of Indian Affairs (BIA), and other agencies when necessary and as 

appropriate. Finally, the NRMP cooperates closely with state agencies such as the State Health and 

Wildlife Departments.” APHIS-WS has a specific Memorandum of Agreement with both the USFS and 

BLM and, therefore, these agencies are official cooperators regarding several APHIS-WS programs. A 

similar Memorandum of Agreement is not in place with the NPS and NPS lands are not specifically 

analyzed in this EA as the field trial does not occur on NPS land. However, APHIS-WS does work 

closely with NPS and, in fact, has several separate EAs in place with NPS for ORV activities that occur 

on NPS units. Regarding the commenter’s second suggestion, APHIS-WS will make the requested 

change to the language of the EA to improve its clarity. APHIS-WS agrees that a State cannot make the 

decision to distribute ORV baits on NPS lands without NPS approval. 

Comment 3 

Commenter suggested that APHIS-WS had not properly informed the residents of West Virginia of the 

proposed field trial. This commenter also thought that the comment period should be extended to allow 

time for the public to submit comments. 

Response 3 

APHIS-WS and State and local officials have been conducting outreach activities, which have included 

meetings, televised information sessions, and one-on-one contact with area residents since 2010. 

A Notice of Availability was published in the Federal Register, (Docket No. APHIS-2011-0089) on 

August 8, 2011, that informed the public of the availability of the draft EA and allowed for a 30-day 

comment period. The commenter provided no justification why the comment period should be extended 

so this suggestion was not considered further.