## FINDING OFNO SIGNIFICANT IMPACT AND DECISION FOR SUPPLEMENTALENVIRONMENTAL ASSESSMENT ORAL VACCINATION TO CONTROL SPECIFIC RABIES VIRUS VARIANTS IN RACCOONS, GRAY FOXES, AND COYOTES IN THE UNITED STATES

The U.S. DepartmentofAgriculture (USDA), Animal and Plant Health Inspection Service, Wildlife Services (APIDS-WS) program completed an environmental assessment (EA) and Decision/Finding ofNo Significant Impact (FONSI) (USDA 2001) on July 30, 2001 (66 FR45835-45836, August 30, 2001) that analyzed the potential environmental effects ofaproposal to continue and expand the involvement ofthe APHIS-WS program in oral rabies vaccination (ORV) programs in a number ofstates. Since that time, APIDS-WS determined the need to expand the ORV program to include the states ofTennessee and Kentucky to effectively stop the westward spread ofraccoon rabies

. A DecisionIFONSI (USDA 2002) was published in the Federal Register (67 FR44797-44798, July 5, 2002)to document the potential effects ofthis expanding program. Next, a supplemental EA (USDA 2003a) was prepared as a result ofthe need to further expand the program to include the states ofGeorgia and Maine to effectively prevent the westward and northward spread ofthe rabies virus across the U.S. and into Canada. A DecisionIFONSI was published in the Federal Register on July 30, 2003 (68 FR 38669-38670). APIDS-WS, in cooperation with the USDA-Forest Service (USFS), prepared an EA (USDA 2004b) to expand the ORV program to combat the raccoon strain ofthe rabies virus on National Forest System lands (excluding Wilderness Areas) in the eastein U.S. A DecisionIFONSI was published in theFederal Registeron February 20, 2004 (69FR 7904-7905). hi 2004, APHis-ws determined that further NEPA documentation was needed as a result of: I} increased federal \ involvement in ORV progtains in recent years; 2)the current proposal to continue or expand federal involvement in such programs in additionalstates; and 3) the need for expanded monitoring and surveillance in the event contingency actions must be implemented. Thus, APIDS-WS prepared a supplemental EA (USDA 2004a) to include 26 states (Alabama, Connecticut, Delaware, Florida, Georgia, Indiana, Kimtucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Mississippi, New Hampshire, New Jersey, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, South Carolina, Tennessee, Texas, Vermont, Virginia, and West Virginia) and the DistrictofColumbia in the proposed action. AnotherDecisionIFONSI was published in the Federal Register (69 FR 56992-56993, September 23, 2004). APIDS-WS also supplemented the EA (USDA 2006) to cover ORV program activities on National Forest System lands (excluding Wilderness Areas) in the eastern U.S. located in states that were not previously covered. A DecisionIFONSI was published in the Federal Register on December 8, 2005 (70 FR 72977-72978). In 2007, a new DecisionIFONSI (USDA 2007c) was published in the Federal Register (72 FR 20984-20986, April 27, 2007) that clarified a term used in the 2004 supplemental EA, "contingency actions," to facilitate planning and interagency coordination in the event ofrabies outbreaks and clearly communicate to the p-ublic the actions involved in the CRY program. .In addition, a type ofcontingency action called ttaP"'vaccinate· release (TVR) was analyzed 

### in the 2007 DecisionIFONSI as it was not analyzed as part ofthe proposed action in the 2004 supplemental EA. As a result ofa February 2007 outbreak ofgray fox variant rabies in coyotes west ofthe original gray fox ORV zone in Texas toward the New Mexico border, and an ongoing outbreak ofgray fox variant rabies in western New Mexico and eastern Arizona, APIDS-WS has determined the need to further expand the ORV program to include the states ofNew Mexico and Arizona to effectively combat the gray fox variant ofthe rabies virus. The states where APIDS-WS involvement would be continued or expanded include Alabama, Arizona, Connecticut, Delaware, Florida, Georgia, Indiana, Kentucky, Louisiana, Maine. Maryland, Massachusetts, Michigan, Mississippi, New 

### Hampshire, New Jersey. New Mexico, New York

. North Carolina, Ohio, Pennsylvania. Rhode Island, South Carolina, Tennessee, Texas, Vermont, Virginia, and West Virginia. The program's primary goals are to stop the**spr~ad** 

### ofspecific raccoon (eastern states), coyote (Texas), and gray fox (Texas, New Mexico, and Arizona) rabies vanants to new areas. The EA analyzed the proposed action and a number ofalternatives with respect to a number ofenvIronmental and other issues raised by involved cooperating agencies and the public. Based**o~** 

### the analysis in**~e** 

### EA, I have**dete~ined** 

### that there will not be a significant impact, individually or cumuiallvely, on the qualIty ofthe human enVIronment as aresult ofthe proposed action. This EA is now available in its final form. 

### Primary Need for Action Ifnew.rabies strains such 

### as those transmitted 

### by raccoons, gray foxes, and 

### coyotes are not prevented from spreadong to new areas ofthe U.S., the health threats and costs associated with rabies 

### are expected to increase substantially as broader geographic areas ofthe U.S. are affected

. Public 

### Involvement Several EAs have been prepared previously to analyze the environmental effects ofAPIDS-WS' continued and expanded participation with an ORV program in the eastern and southwestern United States. Issues related to the 

### proposed action were identified through involvement and planning/seoping meetings with numerous federal (Le., Centers for Disease Control and Prevention), state (i.e., health, agriculture, and natural resource deparl1nents), and 

### local government agencies, academic institutions, and Canadian provincial government agencies (Le., Ontario MinistrY ofNatural Resourccs). 

### 2

Forthe previous EA and supplemental EAs, additional · efforts to determine further issues that the public might have with this action were made through Federal RegisterNotices (66 FR 13696-13700, March 7, 2001 and 66 FR27489, May 17,2001)and making the EA available to the public for review and comment prior to an agency decision. A letter was sent to potentially affected or interested American Indian Tribes to assure their opportunity to be involved 

### in the EA process. Comments received were reviewed to identity any substantive new issues or alternatives not already identified for analysis. A third Federal RegisterNotice (66 FR 45835-45836, August 30, 2001) was published announcing the availability ofthe EA and Decision/ FONS!. In 2002, a Notice ofAvailability for a subsequent DecisionIFONSI was published through a Federal RegisterNotice (67 FR44797-44798, July 5, 2002). In 2003, a Notice ofAvailability for a supplemental EA and DecisionIFONSI was published through a Federal RegisterNotice (68 FR 38669-38670, June 30, 2003). In 2004, a Notice ofAvailability for an EA and DecisionIFONSI was published through a Federal RegisterNotice (69 FR 7904-7905, February 20, 2004) in cooperation with the USFS to expand ORV program assistance to National Forest System lands, excluding Wilderness Areas, in several eastern states
. Also in 2004, a Notice ofAvailability for another supplemental EA and DecisionIFONSI was published through a Federal Register Notice (69 FR 56992-56993, September23,2004)to document the expansion ofthe rabies management program to include 26 states and the District ofColumbia. In response to the expanded program area, anotherNotice ofAvailability for a supplemental EA and DecisionIFONSI was published through a Federal RegisterNotice (70 FR72977-72978, December 8, 2005) in 2005 to document additional National Forest System·lands within the expanding program. 

### In 2007, a Notice ofAvailability for a subsequent DecisionIFONSI was published through a Federal RegisterNotice (72 FR 20984-20986, April 27, 2007). 

### These previous analyses and reviews indicated that the ORY program would 

### have no significant effects. To document the expansion ofthe ORV program into Arizona and New Mexico and to streamline the NEPA process, this EA has been made available to the public by directly mailing notices ofairailability ofthe EA to all 

### people who have expressed an interest in this or similar APHIS-WS activities, 

### by posting this document and notice ofits availability On the APIDS'WS website http://www.aphis.usda.gov/wildlife damage/nepa.shtml, and by issuing a notice ofavailability in the Federal Register on November 24, 2009 (74 FR 61319-61321). The public comment period was open for 30 days and APIDS-WS received 102 comments. APIDS-WS' responses to the pertinent issues raised in the comments can be found in Appendix A. 

### Monitoring The APIDS-WS rabie- s management program annually reviews its ORV program impacts on target '(raccoons, gray foxes, and coyotes) and nontarget**~pedes** to ensure that APHJS-WS activities do not adversely affect the viabilitY of

### wild!ife po!'ulations. The EA is also reviewed annually to confirm that the OR V program continues to have 

### neghglble Impacts 

### on humans. pets, 

### other domestic animals. and the environment and to ascertain whether analysis and dataprovided in the EA are sufficient. Affected Environment 

### 3

The area ofthe proposed action encompasses 25 eastern states and the District ofColumbia where raccoon rabies 

### outbreaks currently occur or aTe 

### expected to occur and Texas where gray fox and coyote rabies strains occur, includingNational Forest System and BLM lands, but excluding Wilderness Areas. Additionally, due to the recent spread ofgray fox variant rabies west ofthe original ORV zone in Texas toward theNew Mexico border with a possible host shift from gray faxes to coyotes and an ongoing outbreak ofgray fox variantrabies in western New 

### Mexico and eastern Arizona. program activities 

### will be expanded to include New Mexico and Arizona, including National Forest System and BLM lands, but excluding Wilderness Areas. New Mexico and Arizona would participate in and assist with the ORV program to control gray fox variant rabies. APffiS-WS involvement would therefore be continued orexpanded in the following states: Arizona, Alabama, Connecticut, Delaware, Florida, 

### Georgia, Indiana, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Mississippi, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, South Carolina, Tennessee, Texas, Vermont, Virginia, and West Virginia

. ORV baiting programs are conducted or are planned to be 

### conducted in most ofthe 

### aforementioned states. 

### Currently. cooperative rabies surveillance activities are conducted in most ofthe aforementioned states and would likely 

### be expanded to include all listed states. 

### Major ISsues Based on the previous ORV EAs and considerable experience by cooperating agencies and APffiS-WS in 

### addressing concerns expressed by the public in past DRV programs, the following issues were identified for consideration in detail in theEA:

• Potential for adverse effects on target wildlife species populations. 

### • Potential for adverse effects on nontarget wildlife species, including threatened or e' ndangered species. • Potential for adverse effects on people, pets, and livestock that arc exposed to or consume the vaccine laden baits. 

### • Potential for the recombined V·RG virus to "revert to virulence" or re-combine with other viruses and result in a virus that could cause disease in humans or animals. • Potential for aerially dropped baits to strike' and injure people or domestic animals. • Costofthe program in comparison to 

### perceived benefits. ; 

### • Humaneness-of methods used to coHeel wild animal specimens critical for timely program evaluation or to reduce local populations oftarget species under state contingency plans.

. 

### In addition to the identified major issues considered in detail, eleven other issues were considered but not in detail with rationale and further analysis. Alternatives Analyzed in Detail 

### Five potential alternatives were developed to address the issues identified above. Three additional alternatives were considered, but not analyzed in detail. A detailed discussion ofthe anticipated effects ofthe alternatives on each 

### issue considered in detail can be found in Chapter4 ofthe EA. The following summary provides abriefdescription ofeach alternative and its anticipated impacts. Alternative 1. Current Action (the No Action Alternative). The "No Action" alternative is a procedural NEPA requirement (40 CFR 1502), is a viable and reasonable alternative that could 

### be selected, serves as a basis for 

### comparison with the other alternatives and can 

### be defined as the continuation of current management prn.ctices (CEQ 1981). 

### This alternative wou}d involve the continued or expanded use offederal funds by APIDS-

### WS to purchase V-RG

### , oral vaccine baits and to participate in their distribution under the authorities ofthe 

### appropriate state agencies in selected



## --.:.--.-- .... . -

### 4

areas ofthe several states listed in Section 1.2 ofthe·EA, not including New Mexico and Arizona, to stop orprevent

### racc~n, gray fox, and

### coyot~ rabies, and to assist with monitoring and surveillance efforts by capturing and releasmg or killing target species for purposes ofobtaining biological samples

. APHIS-WS assistance could also 

### include participation in implementing state contingency plans that involve target species popUlation reduction or concentrated ORV baiting in localized areas if rabies outbreaks occur beyond the designated ORV vaccination barriers to stop such outbreaks from spreading. 

### Alternative 2. Proposed Action'(the Preferred 

### Alternative). This alternative would involve the expansion of Alternative I (Proposed Action) to include additional areas where APHIS-WS would conduct the ORV Program and Alternative 3 (Live-Capture-Vaccinate-Release Only) from the 2004 supplemental EA. The former proposed action included the use of several**continge~cy** actions as part ofthe ORV program; however, it did not address trap

### vaccmate-release as one ofthem. ThiS new proposed 

### action better defines and 

### identifies the types of

### contingency actions that may be used as part ofthe 

### ORV program. Therefore, this alternative would involve the continued and expanded use of federal funds by APHIS-WS to purchase V-RG oral vaccine baits and to participate in their 

### distribution under the authorities of the appropriate state agencies in selected areas ofthe several states listed 

### in Section 1.2 ofthe EA, including Arizona and New Mexico, to stop or prevent raccoon, gray fox,'and coyote rabies, and to assist with monitoring and surveillance efforts by capturing and releasing or killing target species for purposes of obtaining biological samples. APHIS·WS assistance could also include participation in the implementation ofone or more ofthe five state contingency actions as described in Section 1.2.1 ofthe EA ifrabies outbreaks occur beyond the designated OR V vaccination barriers to stop such outbreaks from spreading. 

### Alternative 3. Live-Capture..Vaccinate-Releas' e Alternative. This alternative would involve the live capture of species being targeted (e.g., raccoon, gray fox, coyotes) followed by administration ofrabies vaccines by injection and release back into the wild. 

### Alternative 4. No Animal Su' rveillance or Monitoring or Lethal Removal Programs Alternative. Under this alternative, APHlS-WS would provide resources for and assistance in ORV bait distribution only and would not engage in or provide funds for the collection ofwild animal specimens by APHIS-WS for monitoring and project 

### evaluation purposes or for implementation of localized lethal removal actions under state contingency plans. The states could still conduct these activities withoutAPHIS-WS assistance. Alternative 5. No Federal ORV Program. This alternative would consist ofno involvement by APHIS-WS in rabies prevention or control in the states identified in Section 1.2 in the EA. Under this alternative, no APHIS-WS funds would be available for purchasing ORV baits. The states would likely still fund ORV programs to some degree without APHIS-WS' assistance. Alternatives ConSidered, but Not Analyzed in Detail 

### Three alternatives were considered, but not in detail, and are described as follows with rationale: Depopulation ortarget species. This alternative would result in the lethal removal ofraccoons, gray foxes, and 

### coyotes throughout the zones where outbreaks ofthe targeted strains ofrabies are occurring or are expected to occur. The goal would be to achieve elimination ofthe rabies strains by severely suppressing populations oftbe target 

### anima1 species over broad areas so that the specific strains ofrabies could not be transmitted to susceptible members ofthe same species. This could theoretically stop the forward advance ofthe disease and potentially result in elimination ofthe particular rabies variants as infected animals die from rabies before they could transmit it to other 

### members ofthe 

### same species. This altemative was not considered in detail because ofthe 

### cost and effort that would be involved and because it would also undoubtedly be opposed by most members ofthe public

. Population controltbrough birth·control. Underthis alternative, APHIS-WS would provide funds oroperational 

### assistance to implement one or more methods to 

### control populations ofthe 

### target species by reducing reproduction. Such methods could involve live capture and surgical sterilization,the use ofchemical reproductive inhibitors placed out in baits or delivery devices, or the application ofim"ml;lnocontraception 

### strategies (Le
., 

### vaccines that can cause infertility in treated animals). This alternative was not considered in detail because ofthe 

### extreme**expen~e** 

### and difficulty inv.olved, the greater effectiveness ofvaccination 

### alternatives, and because no contraceptive agents are currently registered for use in the target species.

### S

Employ othertypes ofORVin.stead oftheV-RG vaccine. Under this alternative, APHIS-WS would provide

### ~unds to purchase and use "modIfied-live-virus" (Le., "attenuated"

## or weakened strains that have been shown to have httle chance.ofcausing rabies in treated animals) or perhaps "kilJed-virus" (i.e., "inactivated" virus) oral vaccines instead ofthe 

### Y-RG vaccine in DRY 

### baits. This alternative was not considered in detail because some ofthe 

### vaccines involved have the potential to cause rabies (e.g., "live" virus vaccines), others would be cost-prohibitive to produce in DRV form (e.g., "killed" virus vaccines), and none are currently licensed or approved for any such use in the U.S. Finding ofNo Significant Impact The analysis in the 2001 EA, 2003 supplemental EA, 2004 supplemental EA, 2007 DecisionIFONSI, and this new 2009 EA indicates that there will not be a significant impact, individually or cumulatively, on the quality ofthe 

### human environment as a result ofcontinuing and expanding the rabies management program to New Mexico and Arizona and implementing the proposed action (Alternative 2). I agree with this conclusion and, therefore, find that an Environmental Impact Statement (EIS) need not be prepared. As defined in 40 CFR §IS08.27, significance is determined by examining both the context and intensity ofan action. The EA examined the significance ofthe proposed action in a variety ofcontexts including the society as a whole, the affected regions, and the affected interests. The proposed action will take place in 28 states (Alabama, Arizona, 

### Connecticut, Delaware, Florida, Georgia, Indiana, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Mis'sissippi, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, South Carolina, Tennessee, Texas, Vennont, Virginia, West-Virginia) in the eastern and southwestern U.S. and the District ofColumbia. Although the ORV program encompasses regional areas, decisions to implement 

### ORV activities are based on local responses to rabies outbreaks. This localized decision making process ensures the ORV program considers the context and location of

### ORVactivities prior to implementing those activities. As described more fully in the EA, ifAPHIS-WS decides to implement ORV activities, ituses SOPS and mitigation 

### measures to minimize local impact. The following was considered in evaluating the intensity ofthe proposed ORV program:
1. Impactsthat may be both beneficial and adverse. The ORV vaccine and bait that is used has been found 

### safe for raccoons, gray foxes, coyotes, and other animal s'pecies; has alow risk ofcausing adverse affects to humans; is readily consumed by target animal species; and does not cause bioaccumulation in the environment. A limited number ofbaits are distributed one or two times per year, thereby minimizing the potential for persons to be exposed to an ORV bait orto bait distributing equipment. The TVRtype of 

### contingency action involves the use ofaparenteral (injectable) vaccine on the specific animal that is trapped. Injectable vaccines can be used "offlabel" under the direction ofveterinarians 

### to vaccinate healthy wildlife. Thus, vaccinated animals should exhibit no effect other than becoming immunized against rabies. In addition, positive health benefits to the public and target and nontarget animal populations likely 

### occur through decreased risk ofexposure to rabid animals. 2. Degree ofeffect on public-health or safety. The proposed action poses minimal adverse impact to public health and safety. Ofmore than 77.7 million baits distributed since 1990, few (10) minor injuries and no 

### significant injuries to any member ofthe 

### public are known to have resulted from ORV programs. Adverse health'effects from vaccinia associated with ORV have been minimal with no significant long-tenn effects expected. 

### 3. Unique

### chara~teristics ofthe geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. As described in the 2001 EA, 2003 supplemental EA, 2004 supplemental EA, 2007 DecisionIFONSI, and this 

### new 2009 EA no effects to natural or cultural resources were identified for the preferred alternative. There are no prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas affected.

### 6

4. Degreeto which effects on the quality ofthe human environment are likely to be highly controversial. The

### e~f~cts on the

### ~uality ofthe human environment are not highly controversial. Although there is some**OP~OSltIon ~o**  

### certam methods used to 

### collect animal specimens for monitoring purposes and contingency actIOns; their use under the proposed action is not 

### highly controversial in terms ofsize, nature, or effect. 5. Degreeto which the possible effects on the quality ofthehuman environment arehighly uncertain or involve unique or unknown risks. Based on the analysis documented in the 200I EA. 2003 supplemental EA, 2004 supplemental EA, 2007 DecisionIFONSI, and this new 2009 EA, the effects ofinvolvement by 

### APHIS-WS 

### in ORV 

### programs, including contingency actions, on the human environment is not significant. The effects ofthe 

### proposed activities are not 

### highly uncertain and do not involve unique or unknown risks. 6. Degree to which the action may establish a precedent for futufe 

### actions with significant effects or represents a decision in principle about a futufe consideration. The proposed action does not establish a precedent forany future action with significant effects. 7. Whetherthe action is related to other actions with individuallyinsignificant butcumulatively 

### significant impacts. No significant cumulative effects on the quality ofthe 

### human environment were identified through this assessment. 

### 8. Degree to which the action may adversely affect districts, sites, highways, structures, orobjects listed on National Register ofHistoric Places ormay cause loss or destruction ofsignificant scientific, cultural, or historical resources. The proposed activities do not affect districts, sites, highways. 

### structures, or objects listed in or eligible for listing in the National Register ofHistoric 

### Places, nor are they likely to 

### cause any loss or destruction ofsignificant scientific, cultural, or historical resources. 9. Degree to which the action may adversely affect an endangered orthreatened 

### species or its critical habitat. An evaluation ofthe proposed action and its effects on T&E species concluded that no significant adverse effects will occur to such species, norwill there be any impact on critical habitat for any listed 

### species. Since ORV 

### program inception, significant adverse effects have not occurred to such species or their habitat. In fact, sensitive species may benefit from areduced risk ofencountering arabid animal and dying from rabies. 

### to. Whether the action threatens a violation 

### offederal, state, orlocal environmental protection law. 

### The proposed action is in compliance with all federal, state, and local laws 

### imposed for the protection ofthe 

### environment. Decision I have carefully reviewed the 200lEA, 2003 supplemental EA, 2004 supplemental EA, associated DecisionIFONSls, this new 2009 EA, and the inputresulting from the public involvement process. I believe the issues and objectives identified in the 2001 EA, 2003 supplemental EA, 2004 supplemental EA, associated DecisionIFONSls and this new 2009 EA would be best addressed through implementation ofAlternative 2 (Proposed Action). Alternative 2 is therefore selected because it offers the greatest flexibility in achieving 

### effectiveness while minimizing cumulative adverse impacts on the quality ofthe 

### human environment with respect to the issues raised for consideration in this process. The APHIS-WS program will implement the proposed action as described in this new 2009 EA and in compliance with aI! applicable mitigation measures listed as components of standard operating procedures in Chapter 3 ofthe EA. 

### For additional infonnation regarding this decision, please contact Dennis Slate, National Rabies Program Coordinator, APHIS-Wildlife Services, 59 CheneI! Drive, Suite 7, Concord, NH 03301-8548; phone (603) 223- 9623.

William Clay, Deputy Admi APHIS-WS 

### _.-J.

__ Date

## APPENDIX A RESPONSES TO COMMENTS
One

### h~ndred and two

### com~ents were received regarding the draft EA. One hundred and one ofthe commenters were either

### ~holly supportive ofAPHIS-WS' proposed ORV program; were supportive ofthe program, buthad further questIOns or concerns: or

### wer~ s,"pportive ofORV and TVR methods, butremain opposed to any lethal methods. One commentervOiced SuspICIOn ofthe ORVprogram and disapproval ofAPHIS-WS' programs in 

### general. This appendix contains pertinentissuesraised in the comments and the agencies' responses to 

## each ofthose issues. Issues raised from the public comments are numbered and in bold text. The agencies' response to each comment follows and is written in plain text.
1. The overwhelming majority ofthe comments were from individuals who are supportive of OVR and TVR programs, but do not snpport lethal population control methods. Additional comments snggest that removing populations ofanimals opens up new niches for adjacent animals to move in and thus exacerbate the problem. Many comments expressed coricern overgovernment sponsorship oflethal control campaigns or eradication programs to control rabies. WS' proposed alternative involves the continued or expanded use offederal funds to purchase V-RG oral vaccine baits, to participate in their distribution, and to assist with monitoring and surveillance efforts. WS' assistance could also include participation in state contingency plans. WS is not proposing lethal population eradication programs to control rabies. Section 

### 3.2.1 oftheEA discussed depopulation oftarget species as an alternative considered, but not in detail with rationale. This alternative was not considered in detail because it would be impractical to obtain approval from the many hundreds ofthousands of landowners on whose properties the lethal control methods would have to be conducted. The greatest difficulty with population reduction as a strategy for reducing or eliminating rabies is that a high level ofeffort, on the part ofthe agencies involved, must be maintained almost indefinitely and would also undoubtedly be opposed by most members ofthe public (MacInnes 

### 1998). Population suppression can be a challenge to maintain in many situations due to immigration (ofothermembers ofthe same species from surrounding populations) and possibly compensatory reproduction (Le., larger litters and greater percentages offemales breeding following population reduction) (Clark and Fritzell 

### 1992, Connolly and Longhurst 

### 1975). These factors can mean local populations can recoverto their previous levelsl within a year, thus requiring annual or more frequent suppression efforts to maintain such populations at low levels. Although it has been theorized that large scale population reduction strategies may create a vacuum effect, a study completed by Rosatte et al. 

### (2006) concluded that recolonization ofpopulation reduction areas with raccoons niarked in TVR areas was very low. In fact, only 1.8% ofthe raccoons captured in the population reduction areas of the treatment areas had emigrated from TVR areas outside ofthe population reduction zones as evidenced by eartags. Although raccoons may have immigrated from areas beyond the treated zones, substantial immigration is unlikely, because generally raccoons are fairly sedentary and have home ranges ofabout 4 km2 and movements generally 

### <50 km (Rosatte 

### 2000). In summary, there was no mass exodus ofmarked raccoons from TVR areas into population reduction areas during the 

### 1999-2000 study (Rosatte et al. 

### 2006). Temporary localized population suppression activities could be conducted in an integrated program ofORV used as part ofthe proposed action, but such activities, ifconducted at all, would be expected to occuras a part of contingency actions in response to a breach in a vaccination barrier. These actions would be site specific and limited in scope, thus not creating large vacuum areas. Contingency actions, as defined in Section 1.2.1 ofthe EA, are responses to emergencies. In the event that the targeted rabies strains advance beyond the barriers created by the ORV zones, contingency plans may be implemented by the involved states. Rabies emergencies requiring contingency actions may be categorized as: Type 1) index rabies case(s) that occurwell beyond (e.g., raccoon rabies is detected greaterthan 80 km [50 miles] west ofits known current distribution) ORV barriers (likely due to translocation ofarabid animal); Type 2) rabies case(s) that occurjustbeyond established ORV wnes; Type 3) 

### 7

### 8

rabies case(s) that occurwhere no ORV zone has been created; Type 4) persistence 

### Ofrabies cases within ORV zones created as

### ~mergency treatm.ents (e.g., northeastOhio); Type 5) rabies hotspots found within the ORV zones that

### ~epresent a hIgh rIsk ofspreadmg; and Type 6) aggressive epizootics (large numbers ofinfected animals in a relatIvely small area) approaching an established ORV zone that potentially could spread through the treatmentarea. Depe.nding on the type(s) ofrabies emergency(ies), contingency actions may employ one or more ofthe following 

### practIces:

. 

# • •
• 

# •
• Enhanced surveillance, which may include capture and release or euthanasia oftarget and specific nontarget animals for rabies testing. Treatment with increased bait density (e.g., 75 baitslkm' is considered the standard bait density for raccoons) to ensure sufficient baits for high density oftarget species or to bolster antibody response under "Donnal" target species densities. Increase baiting frequency more than once/year. A trap-vaccinate-release (TVR) program could be conducted for specific targets, primarily canids with high populations such as skunks and feral cats that are known to harbor and transmit rabies. Localized target species population reduction. Additionally. some lethal sampling is necessary to obtain samples in orderto detennine the presence orpossible progression ofpositive rabies cases and in orderto evaluate post ORV serology for canids. Section4.1.1.1 ofthe EA discusses the effects ofmonitoring and surveillance programs on raccoons, gray foxes, and coyotes. This topic is further addressed in the response to comment

### # 10

.

.2. A "reduction oflocal target species" means killing offthe wildlife and

### WS should be more truthful about what we intend to do. TheEA analyzes localized target species reduction as a possible contingency action in response to an identified emergency. Rabies emergencies requiring contingency actions are described in section 1.2.1 ofthe EA as well as in 

### response to comment #1. Emergencies may be addressed 

### by one or more contingencies actions including Contingency Action 1 (enhanced surveillance, which may include capture and release or euthanasiaoftarget and specific nontarget species for rabies testing) and Contingency Action 5 (localized target species population reduction) involve the possible removal of raccoons, gray foxes, or coyotes. As discu'ssed in the EA, APHIS-WS and cooperating state and local agencies expect to lethally remove less than 1% ofthe lowest estimated numberofraccoons in all states combined. To date, lethal removal has accounted for less than 0.006%·0.12% ofthe lowest estimated raccoon population annually (USDA 2008b, 2007a, 2005, 2004c, 2004d, 2003b). The APHIS-WS rabies management program's lethal removal offar less than 1%ofraccoons did not reduce statewide orregional densities ofraccoons. Gray fox populations can generally be expected to withstand harvest rates ofabout 25% or more annually (USDA 2007b). The ORV program in Arizona, New Mexico, and Texas targets coyote and gray fox variants ofthe rabies virus. The number ofgray foxes removed annually by the APHIS-WS ORV program equates to an average of0.03% oftheir estimated population (USDA 2009c, 2008b, 2007a, 2005, 2004c, 2004d, 2003b). The APHIS-WS rabies management program's lethal removal ofless than 1 % ofgray faxes did not reduce the statewide densities ofgray faxes and, if contingency actions are utilized, lethal re,moval is not expected to result in an appreciable increase in the number of gray fox taken by the rabies program. Coyote populations can generally be expected to withstand harvest rates indefinitely ofup to 60% or more annually (USDA 2007b). The ORV program in Arizona, New Mexico, and Texas targets coyote and gray fox variants ofthe rabies virus. The number ofcoyotes removed annually in Texas by the APHIS-WS ORV program equates to an average of0.\3% oftheir estimated population (USDA 2008b, 2007a,. 2005, 2004c, 2004d, 2003b). The APHIS-WS rabies management program's lethal removal oflessthan 1% of coyotes did not reduce the statewide densities ofcoyotes. As a result ofthe review ofpossible impacts to raccoons, gray foxes, and coyotes, the potential for cumulative impacts continues to be negligible. In the absence ofthe ORV program, it is highly likely that substantially greater numbers ofraccoons, gray foxes, and coyotes would succumb to the invariably fatal rabies virus than are removed



## --------

### ~urin~ contingency actions orother

### ra~ies**m~agement** activities. These activities are integral to preserving the IntegrIty ofthe ORV program, preventmg rabIes spread among raccoons to areas not infected with this fatal virus and for monitoring effectiveness. • 

### 3. Trapping, vaccinating, and releasing is highly stressful and will kill animals. 9

Species which are targets for a trap-vaccinate-release (TVR) contingency action are captured in live-catch cage traps
. WS personnel comply wIth all applicable state trappmg regulations, as well as, the National Rabies

### Manageme~t**Pr~gram** 

### protocol which**ens~res** 

### that all traps are checked, at a minimum, once every 24 hours. Trap placement IS deSigned to keep captured ammals comfortable and safe, such as away from bodies ofwater and out of direct.s' unlight.

.Capture anim.als

### a~e**.** released at

### th~ site ofcapture and immediately upon vaccination thereby reducmg behaVioral and phYSiologIcal stress resultIng from the conditions ofcaptivity. Such methods are consistent with those established by the American Society ofMarnmalogists (Gannon et al. 2007) and ensure minimal stress on the captured animal. A licensed parenteral (injectable) vaccine, such as [MRAB" 3 (MERIAL LTD), rather than the oral rabies .vaccine isthen administered to captured animals. After being vaccinated against the rabies virus, healthy target SpeCIes would 

### be released at the site ofcapture. Therefore, injectable vaccine use would have no adverSe effects on raccoons. Beneficial impacts include bolstering target species population immunity and preventing further rabies spread. Injectable vaccines, such as IMRAB®3, are killed virus rabies vaccines recommended for the vaccination ofhealthy pets and other domestic animals (e.g., cats, dogs, horses, sheep, cattle, and ferrets). They contain the same virus strain that is used in the PasteurMerieux Connaught human vaccine. TVR. has been used successfully in various locals in Canada (i.e., New Brunswick, St. LaWrence river region, Ontario, etc.) as part ofan integrated rabies management program to eHrninate ofstop the spread ofspecific variants ofthe rabies virus in raccoons and skunks (Rosatte et al. 1990, 1992,2001). Although targeted species include raccoons in the eastern U.S. and coyotes and gray foxes in Texas, some nontargets have a propensity for contracting, harboring, and spreading the rabies virus which complicates rabies control. Therefore, some nontarget wildlife species, such as skunks, may be vaccinated ifincidentally captured during TVR activities. Captured nontarget animals will be treated with the same methods described above to minimize stress. Healthy nontarget animals that are vaccinated should exhibit no effect other than becoming immunized against rabies. The majority ofnontargets would be released at the site ofcapture, whether vaccinated or not. As described above in Contingency Action 1, nontargets would·be euthanized for rabies diagnostic testing, if they appear sick, injured, or are demonstrating strange behavior symptomatic ofthe rabies virus. 

### 4. How safe is this medicine? Currently the 

### ORV program utilizes two vaccines. The oral rabies vaccine used is the recombinant vaccine-rabies gylocprotein (RABORAL V-RG®, Merial, inc., Athens, GA). This vaccine is currently licensed for use in raccoons, and coyotes in the U.S. and Canada and is approved for experimental use in gray foxes. It remains

. the only licensed oral vaccine for rabies control in wild carnivores in the U.S. (CDC 2000). Ithas been used extensively and successfully in Europe to combatfox rabies and has been found safe for use in a number ofanimal species with no known adverse effects. This vaccine is contained in baits which are distributed by aircraft and ground placement, and then are picked up and consumed by targeted species. There is n6 possibility ofvaccine induced rabies with V-RG because the vaccine only contains the non-infective surface protein ofthe rabies virus; none ofthe viral nuclear material (Le., RNA) which would be required for the rabies virus to replicate is present in the vaccine. As discussed in the EA, large numbers ofraccoons have been inoculated with orhave consumed baits containing the vaccine without 

### ill effects, with most being successfully immunized against rabies (USDA 1991 , p. 25; Rupprecht et a1.l986) without showing adverse effects. Tests showed that the V-RG virus did not invade the CNS or the cerebrospinal fluid oftreated raccoons which indicated no adverse effects on the CNS are likely (USDA 1991, p. 25; Hanlon et al. 1989b). Other tests showed that the V-RG vaccine did not cause any lesions or viremia (i.e., presence ofthe virus in the blood) in tissues sampled from treated raccoons (Rupprecht et a!. 1988). These studies, in addition to the absence ofreports ofadverse effects in free-ranging wildlife in ORV program areas, have10

demonstrated the safety and

### effectiv~ness ofthe V-RG vaccine in raccoons. ORV baits containing the V-RG vaccme would thus have no adverse 

### Impact on raccoon 

### populations. Artois et al. (1990) evaluated the safety ofV-RG oral vaccine in coyotes and found no evidence ofvaccinia 

### virus infecti?ns or other complications. IRupprecht et al. (1992a) reported no adverse effects in gray faxes tested. Also, 

### extensive**expen~e~tal** 

### field**test1~g** 

### orv-RG vaccine 

### with subsequent collections and necropsies ofgray foxes and 

### coyotes for monltonng purposes to 

### Texas have not produced any observed pathological signs ofdisease or other adverse effects on this species (E. Oertli, TX Dept. ofHealth, pers. comm. 2001 as cited in USDA 2001)

. Extensive laboratory and field testing ofV-RG vaccine in many nontarget species, including otherclosely related members of the canid (dog) family (Rupprecht et al. 1992a), indicates virtually no risk oforal baits containing V-RG adversely affecting gray fox or coyote popUlations. 

### The vaccinia virus por:tion ofthe 

### V-RG vaccine has been recognized as having the potential to cause infections in persons exposed to the vaccine, either through direct contact 

### with the liquid or through contact 

### with the mouth ofan animal that has recently ingested the oral vaccine (USDA 1991 , p. 39). Because the vaccinia virus used in the V-RG 

### vaccine is the same type ofvirus 

### that was used in smallpox eradication, although more attenuat ed

### or weakened, persons who have been immunized against smallpox would likely not experience any adverse reaction to the vaccinia virus, but would likely experience at worst a "booster" in immunity against vaccinia virus. However, the routine administration ofsmallpox**vaccinatiOI~s** 

### was discontinued aftersmallpox was eradicated,Thus. a large percentageofthe population (particularly younger individuals) has not been vaccinated against vaccinia. Vaccinia 

### virus rarely poses much risk ofserious health effects - even when it was direct lyapplied

### (via "scarification"or by scratching the skin) to many hundreds ofmillions ofpeople during smallpox eradication campaigns, the numberthat 

### developed vacciniavirus-related illness was only afew per million, More severe complications involving the central nervous system can occur with vaccinia virus and the nafure of these complications is generally thought to be allergic in nature (USDA 1991 , p. 39). Central nervous system 

### complications occurred at an average rate ofthree 

### permillion among persons vaccinated with vaccinia virus (e.g., to prevent smallpox) with about 10 to 30 percent ofthose cases resulting in death (USDA 1991, p. 39). Thus, the 

### chance ofaperson dying from direct application of

### ahigh dose ofvaccinia virus via scarification would be about I 

### in ami.llion cases or less. With ORV baits distributed in the wild, people would run far less risk ofbeing 

### exposed to vaccinia virus or the V-RG vaccine in a way similar to deliberate smallpox vaccinations, but would primarily only

. run the risk ofskin contact by handling broken baits or coming into contact with the oral regions ofpets that hadjust 

### consumed a bait. For that type ofexposure, the chance ofadverse effects from human infection with vaccinia virus would be far less than 1in a million. Another highly important characteristic ofthe V-RG vaccine is that itis weaker (more "attenuated") than the original parent vaccinia strain used in making it, and this has been proven in laboratory tests with mice (USDA 1991, p. 18-19). This characteristic even further reduces the risk ofV-RG vaccine causing vaccinia-related illness in 

### humans. However,persons with immune system deficiencies (e.g., AIDS) run arelatively greater risk of experiencing adverse effects ifdirectly exposed to the vaccinia virus than would persons with n ormal immune systems (USDA 1991, p. 40; USDA 1995a; USDA 

### undateda, undatedb). Experiments in mice suggest that 

### immune-deficient people would be at minimal risk ofadverse effects when exposed to V-RG vaccine (Hanlon et aI
. 1997; USDI 1991, p. 41 and Appendix E therein). To aid in further minimizing the potential for adverse effects on humans because ofcontact with V-RG vaccine, each ORV bait contains a warning label and telephone number advising persons who make contact with baits orthe vaccine liquid to call the number for further guidance. McGuili et al. (1998) conducted a retrospective four-year survey ofdirectors ofsix ORV programs using V-RG vaccine that were conducted from 1992-1996 to evaluate the potential for human health problems

. The programs occurred in Florida, Massachusetts, New Jersey, New York, and Texas. Altogether, they involved a total of 109,276 km' (42,181 mi') oftreated area and a total ofnearly six million baits distributed. Human contacts with the baits totaled 316, ofwhich 53 resulted in contact with the actual vaccine liquid. The directors ofall programs reported 

### that human contact was minimal aitd that there were no reported adverse reactions in people exposed to the baits. The authors concluded that, based on their**survey~** 

### major concerns about puhlk health risks from V-RG vaccine were unfounded. Out ofapproximately 76.6 million baits disbursed since APHlS-WS program inception in 1995, only 1128 people 

### reported contacting or potentially c' ontacting abait (Le" 

### picking up bait, finding a bait in yard, or removing bait or

### II

### saC,~et**fro~ ~~t's**  m?uth, feces, or vomit

- any type ofcontact with a bait is also 

### d, efined throughout the document as an exposure )

. Th,s equates to onehuman exposure per 74,278 baits distributed (0.0013 percent contact cases) (USDA 2008a)

.. In addItIon, exposure cases were generally insignificant as most involved finding an intact bait. Very few cases

### Involve~ touching

.a broken bait, sachet, or liquid vaccine. Furthermore, ofthe 0.0013 perent of contact cases reported SInce APHIS-WS ORV program inception in 1995, only two known adverse reactions have occurred (USDA 2oo4a, 2008a; CDC 2009c). The second vaccine usedby**~e pro~ram**  is the licensed parenteral (injectable) vaccine, such as IMRAB" 3 (Meria!, Inc.). Currently, no vaccme IS specIfically hcensed for thIS type ofuse (CDC 2000). However, certain injectable vaccines may be used "off-label" underthe direction ofveterinarians to 

### vaccinate wild animal species in certain situations (1. Mitzel, APHIS-Veterinary Services, pers. comm. 2001 as cited in USDA 2001a). Injectable vaccines, such as IMRABe 3, are killed-virus rabies vaccines recommended for the vaccination ofhealthy pets and other domestic animals (e.g., cats, dogs, horses, sheep, cattle, and ferrets). They contain the same virus strain that is used in the PasteurMeneID< Connaught human vaccine. Further information on safety studies as well as program data regarding the safety and effectiveness ofV-RG can be found in the EA. 

### 5. I think we all need to see the research that proves this is 

### safe for America

. TJte EA contains extensive research and references to documentthe safety ofthe program. 

### 6. Aerial or ground-based shooting ofcoyotes in orderto obtain requisite samples for purposes ofmonitoring is unacceptable, as is tbe sbooting ofgray fox samples. Wildlife Services must take samples for rabies in non-baited locations only by capturingmammals of interest, cbecking for antibody titers, and releasing negative animals.
We realize that some members ofthe public will likely remain opposed the any lethal wildlife n;moval, however, in regards to managing rabies in coyote and gray fox populations aerial and grou'nd shooting remain the most effective and practical means ofobtaining samples. Ifnot controlled, many more coyotes and foxes would suffer and ultimately die from rabies virus infection. Additionally. ifnot controBed, the advance afrabies viruses would further negatively impact greater portions ofwildlife populations, humans, and domestic animals

. Testing for the rabies virus requires brain stem tissue and, thus, requires either the opportunistic collection ofdead specimens, the euthanasia ofstrange acting animals, or lethal removal ofspecimens in areas with a critical surveillance neoo. No nonlethal tests for rabies in**wil~life** exist and. theref ore, it is impossible to test for rabies and then release riegative animals. The commenter suggests collectin' g samples from non-baited locations. Conducting monitoring and sUlVeillance activities in non' ·ORV baited areas would be impractical and would not·provide the necessary serology samples needed to monitor program effectiveness. 

### 7. Wildlife Services suspects and is killing far to' Omany animals for testing with onlya small perceittage oftbese animals testing positive for rabies. Wildlife Services mustbe more discerning in carrying oilt its lethal-sampling procedure

. The commenter made reference to contingency actions which occurred in Ohio, Vermont, and Texas in 2007 during which localized target species population reductions were employed to address specific emergency situations or animals were euthanized for enhanced surveillance. The commenterwas concerned that only a small percentage of animals euthanized actually tested positive for rabies. During the Ohio contingency action it was necessary to obtain animal specimens for enhanced surveillance in order to detennine the leading edge ofthe rabies virus in that state. During

# the Texas contingency action grey foxes were euthanized to maintain the integrity ofthe ORY barrier and to preventthe rabies virus from spreading to a broadergeographic area. In 2006 and 2007 the rabies virus made an unprecedented breach ofthe Vennont DRY zone and positive raccoons were identified in Quebec, Canada. During contingency action eifo' rts
. 63 skunks were euthanized and sam'pled-to better understand the rolethatthey

J12

may have played in the maintenance and spread ofthe virus across the VT ORV zone. 

### WS only uses**I~c alize?**  population reduction in response 

### to emergency situations. Emergency situations 

### were further defined ID section 1.2.1 ofthe EA

. !frabies emergencies were not addressed by ORV programs orby one or more ofthe contingency actions analyzed in the EA it is likely that many more animals would suffer and die from rabies. 

### 8. Wildlife Services mustlimitits lethal-sampling procedure. The EA rationalizes that the number ofspecific-species animals thatWildlife Services must kill in the name of surveillance and monitoring is negligible in relation to the nU'mber killed by

# all means orin relation to the total populations orto populations required for sustainability.
How 

### does Wildlife Services determine the number ofindividuals ofa species that it will 

### sllbject to lethal removal in orderto demonstratetbat a variant ofrabies is absentfrom a zone orthat enough ORV

### bait has been distributed?

. , As discussed in the EA, raccoon populations can generally be expected to withstand harvest rates ofabout 49% or more annually (Sanderson 1987, USDA 1997j). The EA states that APHIS·wi;; and cooperating state or local agencies expect to lethally remove less than 1 % ofthe lowest estimated number ofraccoons in all states combined

. Removal would primarily only occur during implementation ofcontingency actions that integrate enhanced surveillance and ORV, and may include the need for localized population reduction. Relative densities, along with age structure and sex ratios, serve as indices to raccoon population status and assist in the evaluation ofOR V efforts to contain the spread ofrabies in raccoons. APHIS-WS has conducted more than 221 raccoon relative density studies since 1997. These studies indicate that density indices, ranging from 0'70 raccoons/km2 (average of 12 raccoons/km2). are wel1 within the documented range ofestimates reported in other studies. The national rabies management program has expanded to cover 25 states in the eastern U.S. and

. thus. includes many different habitats which support varying raccoon densities

. Such habitats include agriculture. forested, urban/suburban, rural, and wetlands. Based on a review ofthese studies, the rabies management program now defines "low" density habitats as those supporting 0-2 raccoonslkm2

, "standard" density as 3-15 raccoons/km2
, and "high" density as**~** 16 raccoonslkm2• To date, 19 studies have, been placed in the "low" density range, 144 studies occurred within the "standard" density range, and 58 studies were within the "high" density range. Several ofthe 19 studies in the "low" density rarige specifically targeted ateas suspected ofsupporting relatively low raccoon densities (e.g., contiguous northern hardwood, spruce-fir, or coastal pine-oak habitats). Raccoon density estimates used by WS are considerably lower than what the density studies and literature indicate for the majority'ofhabitats thatoccur within the states in this program. Conservative population density estimates are used to ensure lethal removal ofless than 1%ofthe population

. Forprogram purposes, the national rabies management program determined the lowest estimated mean density to range from 1.5 

### and 8 raccoonslkrn? Thus, the lowest estimated size ofthe raccoon population totaled from the 15 eastern states is between 2,004,348 and 10,689,847 raccoons (USDA 2009c). Based on these estimates, lethal removal accounted for 0.01%

- 0.05%ofthe total estimated population or a total ofI,036 raccoons in 2007 (USDA 2009c). The ORV program in Texas targets coyote and gray fox rabies. Coyote and gray fox populations can generally be expected to withstand annual harvest rates ofabout 70% and 25%or more, respectively (USDA 2008c)

. 

### In 2007, cumulative take (private harvest rates combined with APHIS·WS management actions including ORV program) in Texas totaled 11.4% ofthe population for coyotes and 1.2% for gray foxes, far below the sustainable harvest level (USDA 2009c). The number ofcoyotes and gray foxes removed by the APHIS-WS ORV program alone equates to 0

.08% and 0.02% ofthe eStimates for these populations, respectively (USDA 2009c). Therefore, the cumulative impacts (i.e., monitoring and surveillance, localized population reduction, annual trapper and hunter harvest, other mortality) to both coyote and gray fox populations are negligible. The ORV program continues to have no adverse impacts to the coyote and gray fox densities. In the absence ofthe ORV program, it is highly likely that substantially greater numbers ofraccoons, coyotes, and gray faxes would succumb to the invariably fatal rabies virus than are removed during some contingency actions aT

### 13**surveill~nce ~d**  

### monitoring activities. These**activitie~** 

### are integral to preserving the integrity**of~e** 

### ORV program,**preve~tmg** 

### rabIes spread among raccoons to areas not mfected with this fatal virus, and 

### for monitoring program effectiveness. 

### 9. Laws sbould be 

### passed requiring tbe dropping ofrabies baits in wildlife areas. The EA analyzes the effects ofAPHIS·WS' ORV program and does not propose legislation to enforce distribution ofORV baits. Each ofthe states involved in this proposed action has a state agency or agencies with authority 

### under state law to approve, conduct or coordinate rabies control programs. APHlS-WS involvement in rabies control in each state has previously occurred and, under the proposed action, would only occur in complete cooperation with the appropriate state agency(ies) and in accordance with state authorities as identified by those 

### agencies. With regard to ORV programs, i!,is the various cooperating states that exercise their authorities under state law to propose or approve the

### distribution ofORV" 

### baits onto lands owned or managed by avariety ofentities including private persons, federal land managementagencies [e

.g., USDA Forest Service, National Park Service (NPS), and others), state, county, and city governments, and American Indian Tribes. It is critical to the success ofestablishing 

### and mairitaining ORV 

### barriers and, potentially, to the eventual elimination oftargeted 

### rabies strains in many areas, that altlands containing substantial amounts ofhabitat for the targeted carnivore species are included. APHIS-WS would not 

### be making the decision to distribute baits on the various land ownerships

. Those decisions would 

### be made by the states
. Additionally, the Wilderness Act of 1964 established restrictions on the kinds ofactivities that can be undertaken on Wilderness Areas. The proposed action assumes that ORV baits would be distributed under 

### state authorities, consistent with pertinent property rights laws and regulations and would include acquiring permission from public land managers and American Indian Tribes when appropriate. 

### 10. Developers that build in forested areas should be required to belp pay for the bait. The EA analyzes the use offederal funds for the continuation and expansion ofORV program. Analyses of additional sources offunding are not within the scope oftheEA. 

### 11. Public citizens sbould not bave to pay for post-exposure shots. When a perSon is suspected orknowiito have been exposed to the rabies virus (i.e. a dog bite, but the dog is 

### "unavailable for quarantine; abat is found in the bedroom ofaslee" ping person;or a " person receives abite or scratch from a wild anim" al which is unavailable for rabies testing) they must undergo a series ofrabies post-exposure prophylaxis shots. The comment is outside the scope ofthis EA because APHIS-WS is not proposing to pay for 

### post-exposure treatments. 

### 12; Several comments recognized the effectiveness ofORV and TVR and would like to see the

. programs expanded to include skunks. WS recognizes the need for new oral rabies vaccine, baits, and biomarkers effective in vaccinating and marking meso-carnivores including coyotes, red and gray foxes, raccoons, skunks, mongoose, and free-ranging dogs. Cuirently RABORAL V-RG® is the only oral rabies vaccine**licens~d** for use in raccoons and coyotes and licensed 

### for experimental use in gray foxes. It does not, however, produce significant detectable virus neutralizing antibodies in skunks. Research is currently underway on the development ofsafe and effective vaccine bait combinations fOf use in skunks, as well as, all rabies vector meso·carnivores. Jojola et a!. (2007) recently published a study regarding 

### oral fabies vaccination bait uptake by captive striped skunks. Early field 

### trials with 

### new vaccines show potential efficacy in skunks. Knowles et a1. (2009) recently published the results ofa study to detennine the safety ofanother vaccine, ONRAB® (Artemis Technologies Inc., Guelph, Ontario)

. Safety trials involving target species, including 

### striped skunks, and specific non·target species were conducted. The results ofthe study indicate that despite use of a relatively high dose ofvaccine, no untoward clinical signs were observed. Further, the study concluded that the 

### low rates ofrecovery ofvaccine 

### virus from tissues, feces, and the oral cavity suggest that the likelihood of ONRAB® 

### causing anegative impact on wHdlife species is unlikely. Additionally. other vaccines, such as acanine adenovirus (CAV

### 2) recombinant rabies vaccine (Li 

### et al. 2006) are being explored in captive studies.

### 13. Thebaits should be made available to the public to reduce the government's costs. Individuals owning large tracts ofland should be encouraged and guided through baiting tbeir land. Wildlife rehabbers should have access to the bait. The denial ofvaccine sale to the public may have an effect on feline transmitted viruses.
RABORAL V-RG® is !icensed for use

### i~ state and federal rabies control programs. It is not available for use by prIvate vetermary**praclI~ners** or the public. Although RABORAL V-RG® will not harm dogs or cats, the vaccine does not replace conventIOnal rabies vaccines. Only rabies vaccines administered 

### by veterinarians are considered**p~oof**ofvaccination for domestic pets. 

### 14. Bats are an integralpartofourecosystem and doing a "kill all" method eradicates more thanjustdiseased animals. 14

WS' ORVprograms specifically target raccoons, coyotes, and gray foxes. Control ofrabies in bats is not part ofthe WS ORV program and, therefore, is addressed in the EA. 

### 15. The vaccine should bedropped in large amounts in the spring and fall so thatlarge numbers ofeach species will take the bait.
WS implements ORV programs and detennines effectiveness based on a variety off actors including local food supplies and species biology. Typically baits are distributed at a rate of75 baits perkm'for raccoons in the eastern U.S. and 39 and 27 baits per

### km'for gray foxes and coyotes, respectively, in the southwestern states. Most ORV baiting campaigns do occur in late winter/early spring or late summer/early fall in orderto take advantage on the above stated factors. 

### 16. This is not a good way to disperse this alleged medicine. The c6mmenter did not elaborate as to which dispersal methods they were unpleased with nor did they suggest alternate dispersal methods. WS relies primarily on fixed-wing and helicopter distribution, as well'as, grourid baiting for urban and residential areas. In 2007 alone, WS baited 225,645 km'in 18 states combined. WS maintains that aerial distribution is the most efficient and cost effective method ofOR V baiting, as described in the EA. 

### 17. Oral Contraception for wildlife should be considered. TheEA did considerthe alternative ofpopulation control through birth control, butthe alternative was not analyzed in detail. Under this alternative, APlllS· WS would provide funds or operational assistance to implement one or more methods to control populations ofthe target species byreducing reproduction. Such methods could involve live capture and surgical sterilization, the use ofchemical reproductive inhibitors placed out in baits or delivery devices, orthe application ofimmunocontraception strategies (i.e., vaccines that can cause infertility in treated animals). This alternative was not considered in detail because ofthe extreme expense and difficulty involved, the greater effectiveness ofvaccination alternatives, and because no contraceptive agents are currently registered for use in the target species. Further analysis ofthis alternative may be found in section 3.2.2 ofthe EA

.



### .18. What measures are in place to deal with the virus strains that might enterthrough carriers byway ofMexico? Are there additional resources set aside from either the U.S. orMexico to combat such a threat? Is there a contingency plan associated with the introduction of additional strains that could arise from Mexico? APlllS·WS currently conducts ORV programs in Texas which include monitoring and surveillance in border areas, and ORV programs 'Curreritly in effect have and continue to address rabies emergence along the U.S. Mexico border. APHIS·WS also conducts enhanced surveillance along the AZ and NM international borders. Additionally, any rabies emergency, which couldinclude confirmed rabies cases beyond an ORV zone or where no ORV zone



## .,

### 15 currently exists,**co~ld** 

### be**a~dressed** 

### by the contingencY 'actions detailed in section 1.2.1 ofthe EA. The preferred aUernatlVe (aUernahve 2)will also allow APHIS-WS to implement contingency action in Arizona and New Mexico. SInce 2005, APHIS-WS

### ~as led an effort with other agencies in the United States, Mexico, and Canada to develop the North American RabIes Management Plan (NARMP) and in 2008 the NARMP was signed by U.S., Mexican, and Canadian official. The ':IARMP**establis~es** 

### a pr?tocol for rabies management in North America by assessing and definIng the needs, prlorlhes, and strategIes reqUIred to control and eventually eliminate terrestrial rabies. The establishment ofa NARMP represents a key step in facilitating a planning processes by which mutual border rabies control and prevention goals and objectives can be identified and better met among Canada, Mexico and the U

.S

. 19. The draft mentions that baits will not be dropped on Wilderness Areas. 

### Is there a process to deal with rabies carriers on Wilderness Areas? Currently, APHIS-WS does not conduct ORv'programs on Wilderness Areas. The Wilderness Act of 1964 

### established restrictions on the kinds ofactivities that can be undertaken in such areas. Ifthe need arises, APHIS-WS will work closely with the federal agencies responsible for the management ofsuch lands to ensure that the integrity ofORY zones are maintained. APHIS-WS will only conduct ORY activities in Wilderness Areas after conducting the necessary environmental analysis and after obtaining permission from the USFS Forest Supervisor, BLM State Direct or

,or other official as appropriate. 20. The Arizona Game and Fish Department provided the following recommendations: "The Department 

### is recommending additional measures be 

### taken in tbe region ofIhe Mexican Gray WolfReintroduction Project in the Blue Range ofEastern Arizona. The Department respectfully requests that leghold trapping in the area ofthe reintroduction be 

### coordinated with the field team leader so tbat captured wolves can be sampled, tagged, and collared. Mexican WolfReintroduction Project personnel have received training and it is recommended that all WS personnel or contractors using leghold traps in tbe project area also receive this training

. The Department follows guidelines iterated in 2 SOP documenls: Trap Preparation and use (MW SOP 14. Trap Preparation and use) and Handling, Immobilizing, and Processing Live Mexican Wolves (MW SOP 21. Handling and Immobilization)

. 

### It is recommended that these documents be'referenced for guidance, especially trap preparation and use. In addition, traps should be set so that a wolfwili not become entangled in wire or another hazard, rail Into wa' teror offa cliff, or gel two reel trapped in two different traps. Traps should be set at distances that will prevent two trapped animals from flgbting with each other. Traps should not be set closer than 30 feet to any carcass so that eagles, vultures, condors, and other raptors will not be 

### caught. Personnel sbould consider the weather and temperature cbanges in order to prevent hypothermia and heat stroke when scheduling trapping. Traps should be securely staked with wolfsized drags and chains so that a trapped animal will not be able to escape with a trap still attached to its foot. Trap monitors should be used. Trapped wolves should not be photographed

." The U.S. Fish and Wildlife Service (USFWS) is responsible for the administration ofthe Endangered Species Act (ESA) and, thusly, is the lead agency responsible for the management ofMexican Wolves. The USFWS issued a 

### 1996 Final Environmental Impact Statement (EIS) and a 

### 1998 Final Rule, Establishment ofa Nonessential Populationofthe Mexican Gray Wolfin Arizona and New Mexico. The Final Rule provides regulations for how the reintroduced population will be 

### managed by the responsible agencies and spells out public rights with respect to human safety and protection ofproperty from Mexican Wolves on private, tribal, and public lands. APHIS-WS complies with both the ESA and the necessary practices and restrictions set forth by the Final EIS and Final Rule

. Additionally, APHIS-WS has signed a Memorandum ofUnderstanding (MOU) establishing working relationships

### 16

wlth partner agencies 

### in the reintroduction ofMexican 

### wolves in the Blue Range. This relationship includes the assignment ofa 

### full time employee and additional personnel dedicated to working cooperatively with the primary agencies involved through the Interagency Field Team, the Adaptive ManagementOversight Committee, and the Agency ofDirectors. These primary agencies include the Arimna Game and Fish Department,New Mexico DepartmentofGame and Fish, White Mountain Apache Tribe, USDA-Forest Service, U.S

. Fish and Wildlife Service, and APHIS-WS. Activities within the reintroduction area are coordinated on a daily basis with the primary agencies and additional government agencies as appropriate. Further, APHIS-WS assisted in the development of. 

### the SOPs mentioned in the above comment and receives formal wolfimmobilization training and informal wolf handling training from the USFWS on an annual basis. APHIS-WS will continue to work cooperatively and 

### communicate with the Arizona Game and Fish Department to address their recommendations as appropriate.

### APPENDIXB LITERATURE CITED 17

Artois M., K.M. Charlton, N.D. Tolson ,G.A. Casey, M.K. Knowles, and J.B. Campbell. 1990. Vaccinia 

### recombinant virus expressing the 

### rabies virus glycoprotein: safety and efficacy trials in Canadian wildlife. Can J Vet Res. 54(4):504-7. CDC (Centers for Disease Control and Prevention). 2009c. Human vaccinia infection aftercontact with a raccoon

.rabies vaccine bait

- Pennsylvania, 2009. CDC

- Morbidity and Mortality Weekly Report. Info' nnation obataine dfrom website: http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5843a2.htm ' CDC (Centers for Disease Control and Prevention). 2000. Compendium ofanimal rabies prevention and control, 2000

- National Association ofState Public Health Veterinarians, Inc. CDC

- Morbidity and Mortality Weekly Report Vol. 49, No. RR-8. p.21-30. (Infonnation obtained from web site: hnp:/ /www,cdc.gov/ncidod/dvrd/rabies!) Gannon, W.L., R.S. Sikes, and the Animal Care and Use Committee ofthe American Society ofMammalogists. 2007. Guidelines ofthe American Society ofMammalogists for the use ofwild mammals in research. J. of Marnmalogy

. 88(3):809-823. 

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### 20

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. USDA, APHIS, BBEP, 4700 River Road, Riverdale, MD 20737- 1234.



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