UNITED STATES DEPARTMENT OF AGRICULTURE 

ANIMAL AND PLANT HEALTH INSPECTION SERVICE 

 WILDLIFE SERVICES 

ENVIRONMENTAL ASSESSMENT

ORAL VACCINATION 

TO CONTROL SPECIFIC RABIES VIRUS VARIANTS 

IN 

RACCOONS, GRAY FOXES, AND COYOTES 

IN THE UNITED STATES 

In cooperation with: 

United States Department of Agriculture 

Forest Service 

And 

In consultation with: 

United States Department of the Interior 

Bureau of Land Management 

December 2009 

Prepared By: 

United States Department of Agriculture 

Animal and Plant Health Inspection Service 

Wildlife Services 

4700 River Road, Unit 87 

Riverdale, MD 20737-1234 
i 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

TABLE OF CONTENTS 

CHAPTER 1: PURPOSE AND NEED FOR ACTION .............................................................................. 1 

1.1 BACKGROUND ....................................................................................................................................... 2 

1.1.1 Public Health Importance of Rabies ....................................................................................................... 2 

 1.1.2 Raccoon Rabies in the Eastern U.S .......................................................................................... 3 

1.1.3 Gray Fox and Coyote Rabies in Arizona, New Mexico, and Texas ....................................................... 4 

 1.1.4 Primary Need for Action .......................................................................................................... 5 

 1.1.5 Development of Oral Rabies Vaccine Programs ...................................................................... 5 

1.2 DESCRIPTION OF THE PROPSED ACTION ...................................................................................... 10

 1.2.1 Contingency Action................................................................................................................ 14 

1.3 AUTHORITIES ....................................................................................................................................... 16 

 1.3.1 Federal Authorities ................................................................................................................. 16 

 1.3.2 State and Local Authorities .................................................................................................... 18 

1.4 OTHER RELEVANT FEDERAL LAWS AND REGULATIONS ........................................................ 18 

1.5 RELATIONSHIP TO OTHER ENVIRONMENTAL DOCUMENTS ................................................... 21 

1.6 DECISION TO BE MADE ..................................................................................................................... 23 

1.7 GOALS .................................................................................................................................................... 23 

1.8 SCOPE OF THIS ENVIRONMENTAL ASSESSMENT ANALYSIS .................................................. 24 

 1.8.1 Actions Analyzed ................................................................................................................... 24 

 1.8.2 Period for which this EA is Valid .......................................................................................... 24 

 1.8.3 Site Specificity ....................................................................................................................... 24 

 1.8.4 Coordination ........................................................................................................................... 25 

1.9 SUMMARY OF PUBLIC INVOLVEMENT EFFORTS ....................................................................... 25 

CHAPTER 2: ISSUES AND AFFECTED ENVIRONMENT ................................................................. 26 

2.1 ISSUES .................................................................................................................................................... 26 

2.2 OTHER ISSUES CONSIDERED BUT NOT IN DETAIL WITH RATIONALE .................................. 26 

 2.2.1 Potential for Drugs Used in Animal Capture and Handling to Cause Adverse 

 Health Effects in Humans that Hunt and Eat the Species Involved................................................. 26 

 2.2.2 Potential for Drugs Used in Animal Capture and Handling to Cause Adverse 

 Health Effects in Scavengers or Other Nontarget Animals that May Consume 

 the Species Involved ....................................................................................................................... 27 

 2.2.3 Potential for Adverse Impacts on Wildlife from Aircraft Overflights 

 Conducted in the ORV Program ..................................................................................................... 27 

 2.2.4 Potential for ORV Bait Distribution to Affect Organic Farming ........................................... 29 

 2.2.5 Potential for ORV to Cause Abortions in Cattle .................................................................... 30 

 2.2.6 Potential Human Health Impacts in the Event of Human Consumption of 

 Vaccinated Wildlife ........................................................................................................................ 30 

 2.2.7 Potential Impacts on Water Resources, Including Aquaculture, Fish, Reptiles, 

 and Amphibians .............................................................................................................................. 31 

 2.2.8 Effects on Carnivore Populations in the Absence of Rabies .................................................. 32 

 2.2.9 The Affected Area Described in the EA Includes Some Lands that Have Not Been 

 Indentified as Having a Rabid Raccoon Problem ............................................................................ 33 

 2.2.10 Effects of Nontarget Species Consumption of ORV Baits on Program 

 Effectiveness ................................................................................................................................... 33 

 2.2.11 Effects of Global Warming, Habitat Loss, and Pollution on Wildlife 

 Populations ...................................................................................................................................... 33 

2.3 AFFECTED ENVIRONMENT ............................................................................................................... 34 

CHAPTER 3: ALTERNATIVES ............................................................................................................... 37 

3.1 ALTERNATIVES CONSIDERED, INCLUDING THE PROPOSED ACTION ................................... 37 

3.2 ALTERNATIVES CONSIDERED, BUT NOT IN DETAIL WITH RATIONALE .............................. 38 

 3.2.1 Depopulation of Target Species ............................................................................................. 38 

 3.2.2 Population Control through Birth Control .............................................................................. 39 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

 3.2.3 Employ Other Types of ORV instead of the V-RG Vaccine .................................................. 40 

3.3 STANDARD OPERATING PROCEDURES FOR RABIES ORV PROGRAMS ................................. 41 

 3.3.1 Monitoring ............................................................................................................................. 42 

CHAPTER 4: ENVIRONMENTAL CONSEQUENCES ........................................................................ 44 

4.1 ENVIRONMENTAL CONSEQUENCES FOR ISSUES ANALYZED IN DETAIL ............................ 44 

 4.1.1 Potential for Adverse Effects on Target Wildlife ................................................................... 44 

 4.1.1.1 Alternative 1: Current Action (the No Action Alternative)................................... 44 

 4.1.1.2 Alternative 2: Proposed Action (the Preferred Alternative) .................................. 50 

 4.1.1.3 Alternative 3: Live Capture-Vaccinate-Release Alternative ................................. 52 

 4.1.1.4 Alternative 4: No Animal Surveillance or Monitoring or 

 Lethal Removal Program Alternative ............................................................................... 53 

 4.1.1.5 Alternative 5: No Federal Program Alternative .................................................... 53 

 4.1.2 Potential for Adverse Effects on Nontarget Wildlife Species, including 

 Threatened or Endangered Species ................................................................................................. 54 

 4.1.2.1 Alternative 1: Current Action (the No Action Alternative)................................... 54 

 4.1.2.2 Alternative 2: Proposed Action (the Preferred Alternative) .................................. 74 

 4.1.2.3 Alternative 3: Live Capture-Vaccinate-Release Alternative ................................. 75 

 4.1.2.4 Alternative 4: No Animal Surveillance or Monitoring or 

 Lethal Removal Program Alternative ............................................................................... 76 

 4.1.2.5 Alternative 5: No Federal Program Alternative .................................................... 76 

 4.1.3 Potential for Adverse Effects on People, Pets, and Livestock that are 

 Exposed to or Consume the Vaccine Laden Baits ........................................................................... 77 

 4.1.3.1 Alternative 1: Current Action (the No Action Alternative)................................... 77 

 4.1.3.2 Alternative 2: Proposed Action (the preferred Alternative) .................................. 81 

 4.1.3.3 Alternative 3: Live Capture-Vaccinate-Release Alternative ................................. 82 

 4.1.3.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal 

 Removal Alternative ......................................................................................................... 82 

 4.1.3.5 Alternative 5: No Federal program Alternative .................................................... 83 

 4.1.4 Potential for the Recombined V-RG Virus to “Revert to Virulence” or 

 Recombine with Other Viruses that Could Cause Disease in Humans or 

 Animals .......................................................................................................................................... 84 

 4.1.4.1 Alternative 1: Current Action (the No Action Alternative)................................... 84 

 4.1.4.2 Alternative 2: Proposed Action (the Preferred Alternative) .................................. 86 

 4.1.4.3 Alternative 3: Live Capture-Vaccinate-Release Alternative ................................. 86 

 4.1.4.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal 

 Removal Alternative ......................................................................................................... 86 

 4.1.4.5 Alternative 5: No Federal Program Alternative .................................................... 86 

 4.1.5 Potential for Aerially Dropped Baits to Strike and Injure People or Domestic 

 Animals .......................................................................................................................................... 87 

 4.1.5.1 Alternative 1: Current Action (the No Action Alternative)................................... 87 

 4.1.5.2 Alternative 2: Proposed Action (the Preferred Alternative) .................................. 87 

 4.1.5.3 Alternative 3: Live Capture-Vaccinate-Release Alternative ................................. 88 

 4.1.5.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal 

 Removal Alternative ......................................................................................................... 88 

 4.1.5.5 Alternative 5: No Federal Program Alternative .................................................... 88 

 4.1.6 Cost of the Program in Comparison to the Perceived Benefits .............................................. 88 

 4.1.6.1 Alternative 1: Current Action (the No Action Alternative)................................... 88 

 4.1.6.2 Alternative 2: Proposed Action (the Preferred Alternative) .................................. 89 

 4.1.6.3 Alternative 3: Live Capture-Vaccinate-Release Alternative ................................. 92 

 4.1.6.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal 

 Removal Alternative ......................................................................................................... 93 

 4.1.6.5 Alternative 5: No Federal Program Alternative .................................................... 93 

 4.1.7 Humaneness of Methods Used to Collect Wild Animal Specimens Critical for 

 Timely Program Evaluation or to Reduce Local Populations of Target Species under 

 State Contingency Plans .................................................................................................................. 94 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

 4.1.7.1 Alternative 1: Current Action (the No Action Alternative)................................... 94 

 4.1.7.2 Alternative 2: Proposed Action (the Preferred Alternative) .................................. 94 

 4.1.7.3 Alternative 3: Live Capture-Vaccinate-Release Alternative ................................. 95 

 4.1.7.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal 

 Removal Alternative ......................................................................................................... 95 

 4.1.7.5 Alternative 5: No Federal Program Alternative .................................................... 95 

4.2 CUMULATIVE IMPACTS .................................................................................................................... 95 

4.3 SUMMARY OF IMPACTS OF ALTERNATIVES FOR EACH ISSUE ............................................... 96 

Tables 

Table 2-1 Some Descriptive Statistics of States Proposed for Federal Assistance by 

 APHIS-WS ORV Programs (data from USDC 2001, 2008) ................................................................................. 36 

Table 4-1 Number of Post ORV Raccoon Serum Samples Collected and Results ................................................................ 46 

Table 4-2 Number of Post ORV Gray Fox Serum Samples Collected and Results ............................................................... 47 

Table 4-3 Number of Post ORV Coyote Serum Samples and Results ................................................................................... 47 

Table 4-4 Number of Non-ORV Target Serum Samples Collected and Results ................................................................... 48 

Table 4-5 Non-ORV Target Species Taken by WS for the ORV Program 2006-2007 ......................................................... 49 

Table 4-6 Nontarget Species Taken by WS for the ORV Program 2006-2007 ..................................................................... 56 

Table 4-7 Federally Listed T&E Mammals in the Range of the ORV Projects ..................................................................... 59 

Table 4-8 Federally Listed T&E Birds in the Range of the ORV Projects ............................................................................ 65 

Table 4-9 Federally Listed T&E Reptiles in the Range of the ORV Projects ........................................................................ 67 

Table 4-10 Federally Listed T&E Amphibians in the Range of the ORV Projects ................................................................. 69 

Table 4-11 State Listed T&E and Sensitive (S1, S2) Mammals in the Range of the ORV Projects ....................................... 70 

Table 4-12 Impacts/Issues/Alternatives/Comparison ............................................................................................................... 96 

Figures 

Figure 1-1 Potential areas of the U.S. into which raccoon rabies could spread if not stopped by rabies 

 management programs (from Kemere et al. 2000) .................................................................................................. 4 

Figures 1-2 and 1-3 Expansion of the ORV program to include New Mexico and Arizona as a result of a recent 

 outbreak of gray fox variant rabies in coyotes. The outbreak occurred west, toward the New 

 Mexico border, of the original gray fox ORV zone in 2007. Contingency actions were used 

 to contain the spread. In 2008, a new gray fox ORV zone was created to incorporate and attempt 

 to contain the spread ................................................................................................................................................. 5 

Figure 1-4 Coated Sachet and Fishmeal Polymer baits utilized during the ORV program. (Photos 

 used with permission from MERIAL Limited, Athens, Georgia, USA) ................................................................. 7 

Figure 1-5 States were APHIS-WS would continue or expand assistance to and participation in ORV 

 programs ................................................................................................................................................................. 11 

Figures 1-6 and 1-7 Current and anticipated ORV barrier zones where APHIS-WS would continue or expand 

 participation in and assistance to ORV programs to stop the westward and northward 

 spread of raccoon rabies in the eastern U.S. and ORV zones where APHIS-WS is 

 proposing to continue or expand assistance to and participation in ORV programs in the 

 southwest to stop the spread of gray fox and coyote rabies. ORV baits would be distributed 

 in these and perhaps other zones under the proposed action to vaccinate wild raccoons 

 and form barriers to prevent further spread of the disease or where outbreaks of coyote 

 or gray fox rabies occur .......................................................................................................................................... 13 

Figure 1-8 Areas of enhanced surveillance conducted by APHIS-WS in and around current or anticipated 

 ORV zones in 2007 ................................................................................................................................................. 14 
iv 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Appendices 

Appendix A LIST OF PREPARERS, REVIEWERS AND PERSONS/AGENCIES CONSULTED ..................................... A-1 

Appendix B LITERATURE CITED ......................................................................................................................................... B-1 

Appendix C SPECIES LISTED AS THREATENED OR ENDANGERED UNDER THE ENDANGERED 

 SPECIES ACT ...................................................................................................................................................... C-1 

Appendix D SUMMARY OF SPECIES LISTED AS THREATENED, ENDANGERED, OR SPECIAL 

 STATUS UNDER STATE LAWS IN STATES PROPOSED FOR APHIS-WS CONTINUED 

 OR EXPANDED INVOLVEMENT IN ORAL RABIES VACCINATION PROGRAMS ............................... D-1 

Appendix E ECOREGION DESIGNATIONS WITHING STATES AFFECTED BY APHIS-WS CONTINUED 

 OR EXPANDED INVOLVEMENT IN ORAL RABIES VACCINATION PROGRAMS ............................... E-1 

Appendix F AMERICAN INDIAN TRIBES IN STATES THAT MIGHT BE AFFECTED BY APHIS-WS 

 CONTINUED OR EXPANDED INVOLVEMENT IN ORV PROGRAMS ...................................................... F-1 

Appendix G USDA-AGRICULTURAL MARKETING SERVICE – NATIONAL ORGANICS PROGRAM 

 RULE ON ORV BAIT DISTRIBUTION ON ORGANIC FARMS ................................................................... G-1 

Appendix H STATUES REGRADING RABIES MANAGEMENT ....................................................................................... H-1 

Appendix I NATIONAL FOREST SYSTEM (NFS) LANDS AND ACREAGE WITHIN CURRENT OR 

 POTENTIAL ORV ZONES AND MAPS OF FORESTS .................................................................................... I-1 

Appendix J BUREAU OF LAND MANAGEMENT (BLM) LANDS AND ACREAGE WITHIN CURRENT 

 OR POTENTIAL ORV ZONES AND MAPS...................................................................................................... J-1 

Acronyms 

AGFD Arizona Game and Fish Department 

AMDUCA Animal Medical Drug Use Clarification Act 

AMS Agricultural Marketing Service 

APHIS Animal and Plant Health Inspection Service 

AVEPA Aubrey Valley Experimental Population 

BIA Bureau of Indian Affairs 

BLM Bureau of Land Management 

BO Biological Opinion 

CA Contingency Action 

CAV2-RVG Canine Adenovirus Rabies Virus Glycoprotein 

CDC Centers for Disease Control and Prevention 

CFR Code of Federal Regulations 

CS Coated Sachet 

CZMA Coastal Zone Management Act 

DFP Dog Food Polymer 

DOD United States Department of Defense 

EA Environmental Assessment 

EIS Environmental Impact Statement 

EO Executive Order 

ESA Endangered Species Act 

FBI Federal Bureau of Investigation 

FMP Fishmeal Polymer 

FONSI Finding of No Significant Impact 

FR Federal Register 

FY Fiscal Year 

GAT Georgia-Alabama-Tennessee 

LCNCA Las Cienegas National Conservation Area 

MOU Memorandum of Understanding 

NASA National Aeronautics and Space Administration 

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act 

NMGFD New Mexico Game and Fish Department 

NMNHP New Mexico Natural Heritage Program 

NOP National Organic Program 

NPS National Park Service 
v 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

NRMP National Rabies Management Program 

ORV Oral Rabies Vaccination 

PEP Post Exposure Prophylaxis 

SLR Saint Lawerence Region 

SOP Standard Operating Procedures 

TDSHS Texas Department of State Health Services 

T&E Threatened and Endangered 

TVA Tennessee Valley Authority 

TVR Trap Vaccinate Release 

USACE United State Army Corps of Engineers 

USC United States Code 

USCG United States Coast Guard 

USDA United States Department of Agriculture 

USDI United States Department of the Interior 

USFS United States Forest Service 

USFWS United States Fish and Wildlife Service 

VDH Vermont Department of Health 

V-RG Vaccinia-Rabies Glycoprotein 

VSTA Virus Serum Toxin Act 

WS Wildlife Services 
1 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

CHAPTER 1: PURPOSE OF AND NEED FOR ACTION 

This Environmental Assessment (EA) documents the analysis of the potential environmental effects of a 

proposal to continue and expand the involvement of the U.S. Department of Agriculture (USDA), Animal 

and Plant Health Inspection Service, Wildlife Services (APHIS-WS) program in oral rabies vaccination 

(ORV) programs in 28 states and the District of Columbia including portions of the USDA Forest Service 

(USFS) National Forest System lands and Bureau of Land Management (BLM) lands, excluding 

Wilderness Areas (WA). The states where APHIS-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 programs’ primary goals are to stop the spread of specific rabies variants 

or “strains” of the rabies virus in raccoons (Procyon lotor) in eastern states, gray fox (Urocyon 

cinereoargenteus) in Arizona, New Mexico, and Texas, and coyotes (Canis latrans) in Texas. If not 

stopped, these strains could potentially spread over much broader areas of the United States and Canada 

and cause substantial increases in public and domestic animal health costs because of increased rabies 

exposures. 

This EA serves as the new, comprehensive EA for the ORV program and supersedes all previous ORV EAs 

and supplemental EAs along with their Findings of No Significant Impact (FONSI) and Decisions to 

conduct ORV Programs in various areas of the country. This update was made in order to streamline the 

environmental documentation for the ORV program, as well as to facilitate an easier understanding and 

ability to monitor the program for both the public and interested agencies. This EA contains all relevant 

analyses from the previous EA, supplemental EAs, and FONSIs/Decisions that have previously been 

subject to the public review process. Additionally, this new EA analyzes the effects of expanding the ORV 

program into the states of Arizona and New Mexico. 

The oral rabies vaccine used in these programs is the recombinant vaccinia-rabies glycoprotein 

(RABORAL V-RG®, Merial, Inc., Athens, GA) vaccine currently licensed for use in raccoons and coyotes 

in the U.S. and Canada (although it is only being used for raccoons in Canada, as canine rabies does not 

occur in coyotes in Canada) and approved for experimental use in gray fox in Texas. It has been used 

extensively and successfully in Europe to combat fox rabies. This vaccine is contained in baits which are 

distributed by aircraft or ground placement, and then are picked up and consumed by the target species. It 

has been found to be safe for use in a number of animal species with no known adverse effects. 

The proposed action would involve use of federal funds by APHIS-WS to purchase ORV baits and 

cooperate with programs in the aforementioned states in the distribution of such baits to create zones of 

vaccinated target species that then serve as barriers to further advancement of the particular rabies virus 

variants. ORV baits could also be used in other areas where the particular rabies virus variants are known 

to occur with the goal of eliminating those variants from such areas. The proposed action would also 

include APHIS-WS assistance in monitoring and surveillance of rabies and successful vaccination 

involving the capture and release or lethal collection of the targeted animal species in the aforementioned 

states to take biological samples for testing to determine the effectiveness of the ORV programs. APHISWS could also assist the states in implementing contingency actions which will be further defined in this 

document. Contingency actions may include a single action or an integration of two or more of the 

following: 1) enhanced surveillance, 2) treatment with increased bait density, 3) increased baiting 

frequency more than once/year, 4) trap-vaccinate-release (TVR) of targets and specific nontargets, and 5) 

localized target species population reduction. 

This EA analyzes a number of environmental issues or concerns with the oral rabies vaccine and with 

activities associated with ORV programs such as capturing and handling animals for monitoring and 

surveillance purposes, as well as the potential implementation of contingency actions to address rabies 

outbreaks such as more concentrated localized ORV use or localized suppression of target species 

populations. The EA also analyzes several alternatives to the proposed action, including no action (i.e., the 

current program), live-capture-vaccinate-release programs (i.e., trapping animals followed by 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

administration of injectable vaccines and then release), ORV bait distribution without animal specimen 

collections or localized lethal removal of target species under state contingency plans (i.e., no capturing or 

lethal removal of animals by APHIS-WS for monitoring or surveillance purposes or to address localized 

rabies outbreaks), and no federal program (i.e., no federal funding or participation by APHIS-WS). 

1.1 BACKGROUND

Rabies is an acute, fatal viral disease of mammals most often transmitted through the bite of a rabid animal. 

The disease can be effectively prevented in humans and many domestic animal species, but abundant and 

widely distributed reservoirs among wild mammals complicate rabies control. Within most of the U.S., 

these reservoirs occur in geographically discrete regions where the virus transmission is primarily between 

members of the same species (Krebs et al. 2000). These species include but are not limited to raccoons, 

coyotes, skunks (primarily the striped skunk (Mephitis mephitis)), gray foxes, and red foxes (Vulpes 

vulpes). Species specific variants of the virus may be transmitted to other animal species. However, these 

encounters rarely result in sustained virus transmission within that animal species. Once established, virus 

transmission within a specific animal species can persist at epidemic levels for decades, even perhaps for 

centuries (Krebs et al. 2000). 

The vast majority of rabies cases reported to the Centers for Disease Control and Prevention (CDC) for the 

United States, including Puerto Rico, each year occur in wildlife (>90% of all cases) as in most developed 

countries. For example in 2007, wildlife accounted for 93% of positive cases while domestic animals 

accounted for 7% (Blanton et al. 2008). A total of 7,259 cases were reported in 2007 broken down to 2,659 

raccoons (37%), 1,973 bats (27%), 1,478 skunks (20%), 489 foxes (7%), 274 domestic cats (4%), 93 dogs 

(1%), 57 cattle (1%), 177 other wildlife1

 (2%), 58 domestic animals2 (1%), and 1 human (Blanton et al. 

2008). This is very typical of other years, but the number fluctuates from year to year and can be 

influenced greatly by epizootics (epidemics in animals). Epizootic outbreaks can occur increasing the 

number of reported cases as well as the postexposure rabies treatments given to people. Two canine rabies 

epizootics emerged in Texas in 1988, one involving coyotes and dogs in South Texas and the other in gray 

foxes in West/Central Texas. The South Texas epizootic alone has resulted in two human deaths and 

caused over 3,000 people to receive postexposure rabies treatment (TDSHS 2009). 

1.1.1 Public Health Importance of Rabies.

Over the last 100 years, rabies in the United States has changed dramatically. About 90 percent or greater 

of all animal cases reported annually to CDC now occur in wildlife (Krebs et al. 2000, CDC 2009a). 

Before 1960 the majority of cases were reported in domestic animals. The principal rabies hosts today are 

wild carnivores and bats. The number of rabies-related human deaths in the U.S. has declined from more 

than 100 annually at the turn of the century to an average of one or two people/year in the 1990s. Modern 

day prophylaxis, which is the series of vaccine injections given to people who have been potentially or 

actually exposed, has proven nearly 100 percent successful in preventing mortality when administered 

promptly (CDC 2009a). In the U.S., human fatalities associated with rabies occur in people who fail to 

seek timely medical assistance, usually because they were unaware of their exposure to rabies. 

Human rabies deaths are rare, but the estimated public health costs associated with disease detection, 

prevention, and control are high, estimated to exceed $300 to $450 million annually. These costs include 

the vaccination of companion animals, maintenance of rabies laboratories, medical costs, such as those 

incurred for exposure case investigations, rabies post-exposure prophylaxis (PEP) and animal control 

programs (CDC 2009a). Accurate estimates of these expenditures are not available. Although the number 

of PEPs given in the U.S. each year is unknown, it is estimated to be about 40,000. When rabies becomes 

epizootic or enzootic (i.e., present in an area over time but with a low case frequency) in a region, the 

number of PEPs in that area increases. Although the cost varies, a course of rabies immune globulin and 

five doses of vaccine given over a four-week period typically exceeds $1,000 (CDC 2009) and has been 

 

1

 Includes 46 woodchucks, 39 bobcats, 33 coyotes, 32 mongoose (Puerto Rico included in report), 10 otter, 6 deer, 4 beaver, 3 

opossums, and 1 each bear, fisher, wolf, and wolf hybrid. 

2

 Includes 42 horses/mules, 13 sheep/goats, and 3 swine.
3 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

reported to be as high as $3,000 or more (Meltzer 1996). The cost per human life saved from rabies ranges 

from approximately $10,000 to $100 million, depending on the nature of the exposure and the probability 

of rabies in a region (CDC 2009a). In Massachusetts during 1991-95, the median cost for PEP was $2,376 

per person (CDC 2009b). Also, as epizootics spread in wildlife populations, the risk of “mass” human 

exposures requiring treatment of large numbers of people that contact individual rabid domestic animals 

infected by wild rabid animals increases – one case in Massachusetts involving contact with, or drinking 

milk from, a single rabid cow required PEPs for a total of 71 persons (CDC 2009b). The total cost of this 

single incident exceeded $160,000 based on the median cost for PEPs in that state cited above. Perhaps the 

most expensive single mass exposure case on record in the U.S. occurred in 1994 when a kitten from a pet 

store in Concord, NH tested positive for rabies after a brief illness. As a result of potential exposure to this 

kitten or to other potentially rabid animals in the store, at least 665 persons received postexposure rabies 

vaccinations at a total cost of more than $1.1 million (Noah et al. 1995). 

1.1.2 Raccoon Rabies in the Eastern U.S.

Based on surveillance data, raccoon rabies did not exist outside a focus in Florida before the 1940s and is, 

therefore, considered an exotic strain in the U.S. outside this area (C. Rupprecht, CDC, pers. comm. 2003 

as cited in USDA 2004a). After raccoon rabies was described in Florida, it spread slowly during the next 

three decades into Georgia, Alabama, and South Carolina. It was unintentionally introduced into the midAtlantic states, probably by translocation of infected animals (Krebs et al. 1999). The first cases appeared 

in West Virginia and Virginia in 1977 and 1978. Since then, raccoon rabies in the area expanded to form 

the most intensive rabies outbreak in the U.S. Raccoon rabies is now enzootic in all eastern coastal states as 

well as in Alabama, Ohio, Pennsylvania, Tennessee, Vermont, and West Virginia (Blanton et al. 2008). In 

the past 21 years, all of the mid-Atlantic and New England states have experienced at least one outbreak. 

The raccoon rabies epizootic front reached Maine in 1994, reflecting a movement rate of about 30 miles per 

year (48.3 km/yr). It was also first confirmed in northeastern Ohio in 1996 (Krebs et al. 1998). In 1999, 

the first three cases of raccoon rabies were confirmed in southern Ontario (Rosatte et al. 2001). 

Subsequently raccoon rabies was also confirmed in New Brunswick and Quebec in 2000 and 2006 

respectively. 

Raccoon rabies presents a human health threat through potential direct exposure to rabid raccoons, or 

indirectly through the exposure of a pet that had an encounter with a rabid raccoon. To date, one case 

resulting in the death of a human is attributable to the raccoon strain of the rabies virus. A 25-year-old, 

previously healthy northern Virginia man died in June 2003. A diagnosis of rabies had not been considered 

and was only made 3 months after death when brain tissue was examined. Patient history did not reveal 

contact with animals and no specific exposure experience could be determined (S. Jenkins, Virginia 

Department of Health, pers. comm. 2003, L. Orciari, CDC, pers. comm. 2003 all as cited in USDA 2004a). 

Adding to the threat of the raccoon strain of the rabies virus are the number of pets and livestock examined 

and vaccinated for rabies, the number of diagnostic tests requested, and the number of post exposure 

treatments are all greater when raccoon rabies is present in an area. Human and financial resources 

allocated to rabies-related human and animal health needs also increase, often at the expense of other 

important activities and services. 

The westward movement of the raccoon rabies front has slowed, probably in response to both natural 

geographic and man-made barriers. The Appalachian Mountains and perhaps river systems flowing 

eastward have helped confine the raccoon variant to the eastern U.S. However, a raccoon rabies positive 

case was confirmed outside of the previously established ORV zone in Ohio in 2004 (Krebs et al. 2005) 

prompting a closer look at the potential for westward spread of the virus. With no effective physical barrier 

across the middle of Ohio, rabies could move more rapidly through this zone then in any previously 

recorded epizootic (Russell et al. 2005). Live trapping results in Ohio (A. Montoney, APHIS-WS, pers. 

comm. cited in Kemere et al. 2001) as well as the status of raccoons in the Midwest (Sanderson and Hubert 

1982, Glueck et al. 1988, Hasbrouck et al. 1992, Mosillo et al. 1999) suggest that raccoon populations are 

sufficient for rabies to spread westward along a front at a rate similar to or greater (Rupprecht and Smith 

1994) than the rate at which this rabies strain has spread in the eastern U.S. When reinforced natural 

barriers are not an option for rabies control, as is the case in much of Ohio, the need for rapid remedial 

intervention by ORV and intensified, active surveillance is immediate (Russell et al. 2005). Figure 1-1 
4 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

shows the potential for spread of this rabies variant across the central portion of the U.S. if it is not stopped. 

Current area in which

raccoon rabies variant

occurs. 

Area of potential

westward spread.

Figure 1-1. Potential areas of the U.S. into which raccoon rabies could spread if not stopped by 

 rabies management programs (from Kemere et al. 2001). 

1.1.3 Gray Fox and Coyote Rabies in Arizona, New Mexico, and Texas. 

In 1988, a strain of rabies that had previously been confined to urban domestic dogs became established in 

coyotes along the U.S.-Mexico border in south Texas (Clark and Wilson 1995). This canine strain of rabies 

is readily transmitted from coyotes to domestic dogs and, subsequently, between domestic dogs (Clark et 

al. 1994). Rabies outbreaks involving domestic animals greatly increase the risk of human exposure which 

heightened the seriousness of this particular epizootic from a public health standpoint (Clark and Wilson 

1995). By 1994, this strain had advanced 158 miles (255 km) north of the U.S.-Mexico border. Two 

human deaths from this strain occurred during this time - one in 1991 and another in 1994 (Clark and 

Wilson 1995). 

Prior to 1988, a gray fox strain of rabies was enzootic (prevalent) in West Texas. From a starting point 

near Sonora, Texas in Sutton County in 1988, an epizootic of gray fox rabies cases expanded 80.8 miles 

(130 km) northward and 158.45 miles (255 km) eastward. This particular strain was readily transmitted to 

raccoons and to livestock, especially cows and goats (Clark and Wilson 1995). 

In addition to the two human deaths, the south Texas canine rabies epizootic alone has resulted in over 

3,000 people receiving post-exposure rabies treatment (TDSHS 2009). In 1994, the public health threat 

created by these two expanding epizootics prompted the Governor of Texas to declare rabies a public 

health emergency in the state (Clark and Wilson 1995). 

Most recently an outbreak of gray fox variant rabies in coyotes west of the original gray fox ORV zone in 

Texas toward the New Mexico border was confirmed in 2007 and as a result contingency actions were 

implemented to halt further spread of this variant (Figure 1-2 and 1-3). Additionally, an ongoing outbreak 

of gray fox variant rabies in western New Mexico and eastern Arizona continues to be a cause for concern. 

The State of Arizona recently released a management plan for invasive species. The rabies virus was 

included in this list of invasive species that should be controlled and managed (State of Arizona 2008). 
5 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

1.1.4 Primary Need for Action. 

If new rabies strains such as those transmitted by raccoons, gray foxes, and coyotes are not prevented from 

spreading to new areas of the U.S., the health threats and costs associated with rabies are expected to 

increase substantially as broader geographic areas of the U.S. are affected. In the area that stretches west 

from the leading edge of the current distribution of raccoon rabies (which stretches from Alabama northeast 

along the Appalachian Mountains through coastal Maine) to the Rocky Mountains, and north from the 

distribution of gray fox and coyote rabies in Texas, there are more than 111 million livestock animals, 

including cattle, horses, mules, swine, goats, and sheep, which are valued at $42 billion (65 FR 76606-

76607, December 7, 2000). If raccoon, gray fox, or coyote rabies were to spread into the above described 

area, many of these livestock would be at risk to these specific rabies variants. More importantly, human 

health care concerns would be expected to increase substantially as well if raccoon, coyote and gray fox 

strains of rabies infect a much broader geographic area which would add to the current high costs of living 

with these strains. 

1.1.5 Development of Oral Rabies Vaccine Programs.

Although the concept of ORV to control rabies in free-ranging wildlife populations originated in the U.S. 

(Baer 1988), it has a longer history of implementation in Europe and Canada. The emergence of raccoon 

rabies in the U.S. during the 1970s heightened interest in the application of ORV to raccoons. Due to 

biological and ecological differences among the types of animals that transmit rabies, development of 

specific vaccine and bait combinations was needed. One of the main difficulties was the development of a 

safe and effective vaccine for raccoons. In contrast to red foxes, which were the primary subjects of ORV 

programs in Europe and Canada, raccoons were not readily immunized by the oral route with the modified 

live rabies virus vaccines that worked well in foxes (Rupprecht et al. 1988). In addition, modified “live 

virus” vaccines pose a small risk of causing vaccine-induced rabies, and have resulted in some cases of 

vaccine-induced rabies in animals (but no cases in humans) during oral baiting programs in Europe and 

Canada (Wandeler 1991). However, vaccinia-rabies glycoprotein (V-RG) vaccine has proven to be orally 

effective in raccoons, coyotes and foxes. This vaccine was extensively evaluated in the laboratory for safety 

in more than 50 vertebrate species with no adverse effects regardless of route or dose. As a consequence of 

field safety testing in the early 1990s, V-RG was conditionally licensed in 1995 and fully licensed in 1997 

in the U.S. for vaccination of free-ranging raccoons. It remains the only effective vaccine licensed for use 

in the U.S. and Canada for raccoons. V-RG was also recently fully licensed by the USDA in 2002 for 

vaccination of coyotes in the U.S. and Canada. It has been approved for experimental use to vaccinate wild 

Figures 1-2and 1-3: Expansion of ORV program to include New Mexico and Arizona as a result of a recent outbreak of gray fox 

variant rabies in coyotes. The outbreak occurred west, toward the New Mexico border, of the original gray fox ORV zone in 2007.

Contingency actions were used to contain the spread. In 2008, a new gray fox ORV zone was created to incorporate and attempt 

to contain the spread. 
6 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

gray foxes in Texas. 

The vaccinia-rabies glycoprotein vaccine is commercially available from MERIAL, 115 Transtech Drive, 

Athens, GA 30601 under the registered name RABORAL V-RG®. It is currently the only licensed oral 

vaccine available for rabies control in some wild carnivores in the U.S. (CDC 2000). Throughout the 

remainder of this document, RABORAL V-RG® is referred to as “V-RG”. As a recombinant vaccine, the 

letter “V” is used to denote vaccinia, the self-replicating pox virus that serves as the vector (i.e., carrier) for 

the rabies virus gene that is responsible for the production of rabies glycoprotein. The letters “RG” stand 

for rabies glycoprotein which is the protective sheath around the bullet-shaped rabies virus core. The 

glycoprotein by itself is noninfective and cannot cause rabies, but it serves as an “antigen” which means it 

elicits an immune response to rabies when the vaccine is swallowed by raccoons, foxes, or coyotes. There 

is no possibility of vaccine-induced rabies with V-RG because the vaccine only contains the non-infective 

surface protein of the rabies virus; none of the viral nuclear material (i.e., RNA) which would be required 

for the rabies virus to replicate is present in the vaccine. Approximately 102.1 million doses3

 have been 

distributed in the U.S. since 1995 with only one case of vaccinia virus infection reported in humans 

(resulting in localized skin rashes) to date (Rupprecht et al. unpublished 2000, Rupprecht et al. 2001). This 

vaccine has been tested in more than 50 wild mammalian and avian species without adverse effects. In 

addition, a domestic animal’s annual rabies vaccination can be safely administered even if it recently 

ingested a dose of oral rabies vaccine. 

A number of studies have been conducted to determine the best bait formulations and strategies for delivery 

of ORV vaccines to raccoons (Hanlon et al. 1989a, Hable et al. 1992, Hadidian et al. 1989, Linhart et al. 

1991, Linhart et al. 1994), gray fox (Steelman et al. 1998, 2000), and coyotes (Linhart et al. 1997; Farry et 

al. 1998a, 1998b). When raccoons, foxes or coyotes eat oral rabies baits and puncture a sachet4

 containing 

the vaccine, the vaccine is swallowed and bathes the lymphatic tissue in the throat area and initiates the 

immunization process. A positive rabies antibody titer in an animal from a baited area is most likely due to 

consumption of a bait and adequate contact with vaccine. However, the lack of a detectable antibody 

response may not be an accurate reflection of immune status. It is possible that the animal was successfully 

immunized, but that the blood sample was taken earlier or later than when antibodies could be detected (C. 

Hanlon, CDC, pers. comm. 2003 as cited in USDA 2004a). Antibodies induced by a one-time oral 

vaccination appear to be of relatively short duration. Among a group of animals in a baited area, the best 

time to collect blood samples for detection of antibodies is 4-8 weeks after baiting. A successfully 

immunized animal may have antibodies shortly after vaccination, but then the level may decline to 

undetectable levels. If the animal is then exposed to rabies, it is still likely that the animal's "memory" 

immunity will become activated by the rabies exposure and more antibodies will be made very quickly. 

The successfully immunized animal will most likely survive exposure, even though it did not have 

measurable antibodies at the time of the exposure (C. Hanlon, CDC, pers. comm. 2003 as cited in USDA 

2004a). 

The baits are small blocks of fishmeal (for coyotes and raccoons) or dog food (for gray foxes) that are held 

together with a polymer binding agent and are considered to be “food grade” materials (Figure 1-2). The 

dog food baits are now prepared from poultry-based dog food as concerns were raised regarding the 

possibility of beef-based dog food containing bovine spongiform encephalopathy (BSE, also known as mad 

cow disease). To address these concerns, the change to poultry-based products was made on a voluntary 

basis by MERIAL, Inc. (J. Maki, MERIAL, Inc., pers. comm. 2003 as cited in USDA 2004a). The baits are 

rectangular or square in shape with hollow centers. The sachet containing the liquid vaccine is contained in 

the hollow center of the bait. “Coated” sachets (Figure 1-2) with a simple fishmeal attractant coating have 

also been field tested with effectiveness that appears to be comparable to fishmeal polymer baits containing 

the sachet (Linhart et al. unpublished 2001). Using the “coated” sachet may be equal in effectiveness at 

lower cost per vaccinated target wild animal. All baits are marked with a warning label that includes a 

 

3 Number of baits distributed over time refers only to APHIS-WS involvement. State and local health departments and other programs 

have also distributed baits without APHIS-WS involvement. 4 A thin plastic packet much like those in which condiments (e.g., catsup, mustard) are provided at fast food restaurants. 
7 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

phone number to call for additional information. 

Recently WS and cooperators have begun to shift from fishmeal polymer (FMP) baits to coated sachets 

(CS).CS’s are less expensive than FMP baits, less likely to cause damage from aerial distribution, are more 

palatable to smaller carnivores like skunks, and, most importantly, perform generally at least as well as 

FMP based on field titer responses from Cornell University. The shift to CS’s is currently viewed as an 

interim management step until improved baits can be developed, licensed, and produced (USDA 2008a). 

Additionally, captive studies being conducted by the APHIS-WS National Wildlife Research Center are 

critical to decisions regarding the best available bait for delivering oral rabies vaccine to raccoons. 

Fishmeal and dog food polymer baits (DFP) contain a tetracycline biomarker. These biomarkers bind to 

calcium, which can be found in the metabolically active portions of bones and teeth of animals. 

Tetracycline deposits can be viewed in the teeth or bones with fluorescent light under a microscope. When 

the tooth or bone sample of an animal is positive for tetracycline, it is likely that the animal has eaten at 

least one bait and possibly multiple baits (C. Hanlon, CDC, pers. comm. 2003 as cited in USDA 2004a). 

The presence of tetracycline, however, is not an indication of immunity since it is possible in some 

situations for an animal to eat the outer bait matrix without rupturing the vaccine sachet inside. Other 

potential sources of "background" tetracycline in a study area may include consumption of medicated feeds 

such as those sometimes used for production animals, intentional treatment by humans with tetracycline, 

and non-specific fluorescence from undescribed but similar chemical compounds that may be found 

naturally (C. Hanlon, CDC, pers. comm. 2003 as cited in USDA 2004a). 

However, field studies have indicated through antibody analysis that 40% of raccoons in a particular bait 

zone were antibody positive, yet only 10% of the population was positive for tetracycline biomarker (Slate 

pers. comm. 2003 from Johnston et al. 2005) thus indicating the need for more effective biomarkers. 

Rhodamine B, when ingested, stains the oral cavity and extremities of an animal that contacts it and it is 

absorbed systemically through diffusion (Clark 1953) in growing keratinous tissues (i.e. nails, hair and 

whiskers). Exposure to rhodamine B is easily identified in hair and whiskers as a fluorescent orange band 

under UV light. Research (Fisher et al. 1999) has indicated rhodamine B in hair and whiskers of feral cats 

under ambient light in 45% of cases, 56% of cases under hand held UV lamps, and in 100% of cases under 

UV microscopes. Research is currently being conducted to determine if the same may be true for raccoons. 

If proven effective, rhodamine B could reduce the need for samples to be sent to diagnostic labs as these 

samples could be assessed in the field or office thereby reducing costs. (Fry and Dunbar 2007). Recent 

research on the effectiveness of rhodamine B as a potential biomarker for raccoons, as a part of the 

National ORV program, is being completed and analyzed by scientists at WS, National Wildlife Research 

Center. The potential for rhodamine B to satisfy many of the ideal characteristics of a biomarker, 

Figure 1-4. Coated Sachet and Fishmeal Polymer baits utilized during the ORV program. 

(Photos used with permission from MERIAL Limited, Athens, Georgia, USA). 
8 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

affordability, persistence, and non-invasive sampling methods are met by this dye thus far (Fry and Dunbar 

2007). 

The growing need for bait-vaccine formulations that are both cost effective and have the ability to produce 

desirable antibody responses across a wide range of meso-carnivores has prompted field studies and 

research into the development of new bait delivery systems and new vaccines. Field studies are under way 

by APHIS-WS to determine the acceptability of a fishing lure-type enrobed sachet which, if proven 

effective, could provide a bait that is both cost effective and has the ability to carry a biomarker. 

Additionally, research is being conducted by Thomas Jefferson University to determine the efficacy and 

safety of a canine adenovirus rabies virus glycoprotein (CAV2-RVG). 

In field tests conducted in the U.S., the majority of ORV baits have been consumed within the first 7 to 14 

days after placement, with reports of up to 100 percent of the baits being consumed within a 7 day period 

(Farry et al. 1998b, Hable et al. 1992, Hadidian et al. 1989, Hanlon et al. 1989a, Linhart et al. 1994, 

Steelman et al. 2000, USDA 1995a). The likelihood of a bait being consumed is dependent upon several 

factors including animal population densities (target and non-target species), bait preference, and the 

availability of alternative food sources. Those baits that are not consumed may remain in the environment 

for several months after placement, dependent upon environmental conditions (precipitation, temperature, 

etc.) and the condition of the baits. The V-RG virus that is not consumed by the target species or other 

vertebrates will become inactivated over a relatively short time period. Persistence and stability of the VRG virus outside of an organism is highly dependent on ambient temperature and local environmental 

conditions, the higher the temperature the quicker the virus will become inactive (USDA 1992, USDA 

1995a). For example, at temperatures between 68 and 100 degrees Fahrenheit (20 and 37.8 Celsius) the 

liquid viral vaccine potency remains stable for approximately 14 to 7 days, respectively, in the unpunctured sachet or inside the bait. In situations where the bait and sachet are damaged, inactivation of the 

V-RG virus will occur more rapidly. 

Oral wildlife vaccination for raccoon rabies control has been under field evaluation in the U.S. since 1990. 

A limited field release of the recombinant vaccine occurred on Parramore Island, VA, prior to wider spread 

use in the U.S. for control of raccoon rabies (Hanlon et al. 1998). A major objective of this field trial was 

to evaluate the free-ranging raccoon population for adverse effects after the distribution of V-RG vaccineladen baits. With the development and field testing of the V-RG vaccine, a potential method of rabies 

control now exists for some rabies variants to complement methods of control which include public 

education, domestic animal vaccination, and human PEP. In 2004, APHIS-WS, in cooperation with the 

CDC, began conducting small mammal vaccinia monitoring at Parramore Island, VA. Because this is the 

site where vaccinia was first released into the wild in ORV baits and since these baits have not been 

released at this site since the early 1990s, viruses in hosts can be monitored. Microtine mammals, 

especially rodents, are typically the most likely hosts for orthopox viruses, which include vaccinia. Thus, 

these mammals are good sentinel species for indicators for the environmental presence of viruses, such as 

vaccinia. Samples were collected and tested at CDC laboratories to determine the presence of vaccinia 

virus in small mammals collected at this site. Results of this study found no evidence of V-RG circulation 

based upon the serological survey (C. Rupprecht, CDC, pers. comm. 2009). 

Since the first field release of the V-RG vaccine in 1990, the number of vaccine-laden baits that were 

distributed annually in the U.S. has risen exponentially. For instance, APHIS-WS’ involvement in the 

national rabies management program between 1995 and 2008 contributed to 102.1 million ORV baits 

disbursed in the U.S (USDA 2008b, ORV website). Numerous projects have been conducted or are in 

progress in the eastern U.S. and Texas (USDA 2009b, 2008b). Since ORV program inception, positive 

rabies cases have either decreased or the advance of the virus has been slowed or stopped in each state 

where an ORV program was initiated, or Contingency Actions have been successfully utilized to address 

emergencies: 

 In Maryland, 19 rabies cases were reported per year on the Annapolis Peninsula alone before the ORV 

program began in 1998. Between 1998 and 2007, with the intervention of 412,441 FMP baits, only 21 

raccoons have been reported from the Annapolis Peninsula, indicating success of the Anne Arundel 
9 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

County ORV Program (USDA 2009a). 

 In New York, an ORV program was implemented in 1998 to prevent the northward spread of the virus. 

Prior to the ORV program in New York, almost 150 positive rabies cases were recorded in 1998 and 

1999 in the St. Lawrence Region (SLR) ORV zone alone. In 2007, New York reported a decline to 35 

positive rabies cases in the SLR zone. Further, out of an additional 3089 animals tested for rabies from 

the three remaining NY ORV zones, only 95 were reported positive. The majority (75) of these came 

from the Long Island ORV zone which, as of 2007, is only in its fourth year of operation. (USDA 

2009a). 

 Vermont has been participating in the ORV program since 1996. However, in June 2006, the province 

of Quebec confirmed its first-ever case of raccoon rabies approximately 11 km (6.6mi) north of the 

Vermont border. Subsequently, a second positive case in Quebec was discovered in July 2007. In a 

continuing effort to stop the spread of raccoon rabies in northern Vermont, WS implemented several 

TVR campaigns throughout the standard and high bait density ORV zones. In 2008, WS will continue 

coordinated TVR efforts, but shift focus to the Lake Memphremagog basin in Orleans County to 

prevent rabies from entering Quebec from that area. WS will maintain communications and work 

closely with Quebec officials to coordinate field work and maximize efforts to contain (and explore 

strategies to eliminate) the raccoon variant of rabies from Vermont and Quebec (USDA 2009a). 

 In Ohio, 62 positive rabies cases were recorded prior to program implementation in 1997. From 2001-

2003, three cases were reported near the Pennsylvania border where raccoon rabies is still enzootic. In 

2001, APHIS-WS, in coordination with state agencies, began an ORV program in Pennsylvania 

(USDA 2009a) to address this issue. The ability to create rabies-free zones, within raccoon rabies 

enzootic areas, is a requisite to achieve elimination of this variant of the rabies virus. 

In mid-July 2004, a raccoon infected with raccoon variant of the rabies virus was confirmed just west 

of the ORV zone near Lake Erie in Lake County in northeastern Ohio. APHIS-WS and state, county 

and municipal cooperators responded immediately to this high priority rabies issue. A contingency 

action plan that included enhanced rabies surveillance, trap-vaccinate-release, and continuance of the 

ORV program was implemented upon detection of the index case. High raccoon population densities 

and additional rabies cases based on enhanced surveillance suggest that additional action may be 

required. Enhanced rabies surveillance is being maintained on the south and west sides of this 

outbreak to determine the next course of action, if required. The creation of an ORV zone, a 

cooperative ORV program, began in 1997 and has expanded to include the states of Pennsylvania, 

West Virginia, Virginia, Tennessee, Maryland, Georgia and Alabama. Throughout its length from 

Ohio to northeastern Alabama, the ORV zone is at least 30-miles in width to attempt to prevent the 

westward spread of raccoon rabies. 

As a component of the greater Appalachian Ridge ORV zone, Ohio continued biannual baiting of the 

Contingency Action (CA) ORV zone (east of Cleveland) in the spring and fall of 2007. Wildlife 

Services integrated TVR into the rabies control campaign within the CA zone to prevent the spread of 

raccoon rabies that was first detected there in 2004. As a result of this effort, 1,285 animals were hand 

vaccinated and released in northeastern Ohio. The number of rabid animals with raccoon variant in 

this CA zone decreased to 19 cases in 2007 with enhanced surveillance in place (from a high of 46 

cases in 2004) (USDA 2009a). 

 In Massachusetts, the rabies virus had not spread to the Cape where intensive baiting programs at the 

peninsular neck (since 1995), combined with the natural barrier of Cape Cod Canal, seemed to act as 

effective barriers (Robbins et al. 1998). In early March 2004, however, raccoon variant of the rabies 

virus was confirmed east of the Cape Cod Canal for the first time and by 2006 it was confirmed on the 

outer Cape (USDA 2009a). The canal served as the eastern anchor point for the ORV zone which was 

designed to prevent raccoon rabies from spreading east onto the Cape. This cooperative project was 

initiated in the mid-1990s by Tufts University and the State of Massachusetts Health Department. 

APHIS-WS became a partner in this effort in 2001. APHIS-WS, Tufts University, and the State of 

Massachusetts Health Department immediately implemented enhanced rabies surveillance, followed 
10 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

by trap-vaccinate-release and ORV as a contingency action plan to prevent further spread, with the 

long range goal of eliminating raccoon rabies from the area. It is not known if raccoon rabies spread to 

the Cape through the long range movement of an individual rabid raccoon or skunk infected with 

raccoon variant of the rabies virus or if the virus spread animal to animal approaching the canal, with 

rabies spreading to the Cape through a short range raccoon or skunk movement across the canal. 

Translocation, either intentional or unintentional (i.e., raccoon “hitch-hiking” in a garbage truck or 

tailored boat and escaping once on the Cape), represents another potential source of spread. 

The Cape Cod ORV zone now includes all townships on Cape Cod. In 2007, only 5 cases of raccoon 

variant rabies were confirmed on the Cape, down from 50 cases in 2006. (USDA 2009a). 

 In Maine, WS initiated rabies management efforts during 2003 in collaboration with New Brunswick, 

Canada to vaccinate raccoons and skunks. As rabies has progressed north and eastward, rabies 

vaccination efforts have been targeted along the Maine, USA and New Brunswick, Canada border 

creating a "barrier" to protect raccoon populations against rabies. Through vaccination efforts New 

Brunswick has maintained a terrestrial rabies-free status since 2002 and continued rabies surveillance 

and TVR rabies management efforts throughout 2007. Maine WS continues to support the 

international eradication of rabies through enhanced surveillance along the front line of documented 

cases and ORV bait distribution along the international border (USDA 2009a). 

 In November 2003, WS established the Georgia-Alabama-Tennessee (GAT) ORV zone where the 

Georgia and Alabama borders meet southern Tennessee. At the time, raccoon rabies was in 

northwestern Georgia and moving westward. The Alabama-Coosa River system to the south and the 

Appalachian Mountains to the north were serving as potential natural barriers to the westward spread 

of raccoon rabies. The GAT zone was established to help fill a gap between these potential barriers 

and to prevent the spread of raccoon rabies into the Tennessee Valley and subsequently the interior of 

the United States. In January 2004, raccoon rabies entered southeastern Tennessee from Georgia and 

reached the GAT ORV zone. In response to the first positive case of raccoon rabies inside the GAT 

zone, WS began baiting the city of Chattanooga and surrounding areas of Hamilton County in the 

spring, while baiting these areas again in the fall as part of the larger GAT ORV effort. During 2004, 

14 cases of raccoon rabies were documented in wildlife in Hamilton County. During 2005, only 1 

animal (a raccoon) was confirmed with raccoon rabies in Hamilton County and the virus was not 

detected in any surrounding counties. Although no cases of raccoon rabies were documented in 

Hamilton County in 2006, 1 case was confirmed in adjacent Bradley County in a gray fox (Urocyon 

cineroargenteus). In 2007, 1 raccoon case was confirmed in Hamilton County, but no additional cases 

were detected in Bradley or other surrounding counties (USDA 2009a). 

 Projects have also been conducted or are in progress in New Jersey (1992-1994, with additional 

projects reinitiated in the last few years), Florida (1995-present), Virginia (2000-present), West 

Virginia (2001-present), Pennsylvania (1995-present), NH (2002-present), AL (2003-present), GA 

(2003-present), and NC (2005-present). 

1.2 DESCRIPTION OF THE PROPOSED ACTION 

In accordance with the provisions of the Act of September 25, 1981, as amended (7 U.S.C. 147b), the 

Secretary of Agriculture declared rabies to be an emergency issue that threatens the agricultural production 

industry in the U.S. and authorized the transfer and use of funds from the Commodity Credit Corporation 

(CCC) of the USDA in FY 2001 for the continuation of ORV programs to address rabies problems in 

several eastern states and Texas (65 FR 76606-76607, December 7, 2000). Additional CCC funds continue 

to be provided to augment the funding obtained through the appropriations process and support the 

continuation and expansion of ORV programs to ensure that raccoon and gray fox rabies spread was 

contained. 

The APHIS-WS program, in cooperation with the USDA-Forest Service (USFS) and the USDI-Bureau of 

Land Management (BLM), is proposing to continue or expand federal cooperation through funding and 

direct involvement in these programs. APHIS-WS proposes to expand the ORV program to include a total 
11 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

of 28 states and the District of Columbia, including portions of National Forest System and BLM land, but 

excluding Wilderness Areas (see Appendices I and J for a list of National Forest and BLM lands and maps 

where APHIS-WS involvement would be continued or expanded). The states where APHIS-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. Figure 1-5 shows the states 

involved in the proposed action. Potential areas involved may cover several land types and land uses 

including: forests, meadows, wetlands, and rangelands, representing diverse wildlife habitats. Free water 

bodies, such as lakes, rivers, and oceans, would not be baited (see Section 2.2.7). 

Figure 1-5. States where APHIS-WS would continue or expand assistance to 

and participation in ORV programs. 

The primary goals of this program would involve the continuation and expansion of the national rabies 

management program, including the continuation and expansion to National Forest System and BLM lands, 

in attempt to: 1) stop the forward advance of specific rabies strains from areas where they now occur by 

immunizing portions of target species population along the leading edges of the rabies fronts; and 2) reduce 

the incidence of rabies cases involving wild and domestic animals and rabies exposures to humans in areas 

where the ORV programs are conducted. If the ORV program is successful in stopping the forward advance 

of specific strains of rabies, then the ultimate goal could include elimination of specific rabies variants. The 

inclusion of land areas managed by the federal government has become an increasingly important 

requirement for this program, given the extensive public lands within the ORV targeted zones. If baiting 

programs were conducted around these large land masses, reservoirs of the virus would likely still exists, 

creating holes in the program and potentially making the program less effective at stopping the forward 

advance or elimination of specific rabies virus strains. 

The program would involve the use of APHIS-WS federal funds to purchase and distribute ORV baits to 

create zones of vaccinated target species that would serve as barriers to cease the further advancement of 

specific rabies virus variants in raccoons, gray foxes, and coyotes. Vaccination zones would be determined 

in cooperation with the various state rabies task forces, state health or agriculture departments, and/or other 

agencies with jurisdiction over vaccine use and application in wildlife and domestic animals. ORV baits 

could also be used in other areas where raccoon, gray fox, and coyote rabies virus variants are known to 

occur with the goal of eliminating those variants from such areas. The proposed action would also include 

APHIS-WS assistance in monitoring and surveillance activities involving the capture and release or lethal 

collection of the targeted animal species in the above states to take biological samples for testing to 

determine the effectiveness of the ORV programs. APHIS-WS could also assist the states in implementing 
12 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

contingency plans that include localized population reduction of target species, trap-vaccinate-release 

(TVR) of target species, increased baiting frequency, or increased baiting density in areas where rabies 

outbreaks occur beyond ORV barriers. The role of the USFS and BLM would involve cooperation with 

APHIS-WS in permitting access to National Forest System and BLM lands for bait disbursal and rabies 

monitoring and surveillance activities. 

The emergency federal funds authorized above, along with other federal funds would be used to: 1) 

purchase ORV baits and participate in the distribution of ORV baits by air and ground placement; 2) 

provide other forms of assistance in monitoring rabies and determining the effectiveness of the ORV 

programs through collection and testing of samples from wild animal specimens, including; and 3) if 

necessary, participate in implementing contingency plans that may involve a reduction of target species 

populations through lethal means or trap-vaccinate-release programs to cover an emergency in a local area. 

The aforementioned actions may also occur on National Forest System and BLM lands, however 

coordination with specific National Forest and BLM State Offices would occur prior to project 

implementation. 

The ORV that would be used is the V-RG vaccine in any of several types of baits as described in Section 

1.1.5. The intent of the bait distribution is to orally vaccinate wild raccoons in portions of the above states 

with the exception of Texas. Similar programs would be directed at gray foxes in west-central Texas, 

Arizona, and New Mexico and coyotes in southern Texas. The primary goals of the program are to: 1) stop 

the forward advance of these strains of rabies from areas where they now occur by immunizing portions of 

target species populations along the leading edges of the rabies fronts and 2) reduce the incidence of rabies 

cases involving wild and domestic animals and rabies exposures to humans in the areas where the ORV 

programs are conducted. If the ORV program is successful in stopping the forward advance of these 

strains, then the ultimate goal could include elimination of these rabies variants. 

The areas over which the ORV baits would be distributed and from which animal specimens would be 

collected could be anywhere in the above listed 28 states and District of Columbia, including National 

Forest System and BLM lands, but excluding WAs. National Forest System and BLM lands proposed for 

inclusion in the ORV program are listed in Appendix I and J. Coordination with specific National Forests 

and BLM lands would occur prior to project implementation to ensure that the integrity of specially 

designated areas is maintained (i.e., Research Natural Areas, Wild and Scenic Rivers, etc.). The ORV 

zones would be delineated based on the most current distribution of rabies cases and the expected direction 

of disease spread. Vaccination zones would be determined in cooperation with state rabies task forces, 

state health departments, or other state agencies with jurisdiction over vaccine use and application in 

wildlife and domestic animals. Figures 1-6 and 1-7 show the current areas where APHIS-WS will continue 

treatment with ORV baits or expand. Figure 1-8 depicts the areas located within the current ORV zone 

where enhanced rabies surveillance was conducted in the eastern U.S. in 2007. Pending the verification of 

legal authorities to do so, ORV baits would be distributed by the states over a variety of classes of land 

ownership, including private, public, tribal, and other state and federal lands. Each bait will have a warning 

label advising persons not to handle or disturb the bait along with a toll-free telephone number to call for 

further information. 
13 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

 

Figures 1-6 and 1-7. Current and anticipated ORV barrier zones where APHIS-WS would continue or expand participation in 

and assistance to ORV programs to stop the westward and northward spread of raccoon rabies in the eastern U.S. and ORV 

zones where APHIS-WS is proposing to continue or expand assistance to and participation in ORV programs in the southwest 

to stop the spread of gray fox and coyote rabies. ORV baits would be distributed in these and perhaps other zones under the 

proposed action to vaccinate wild raccoons and form barriers to prevent further spread of the disease or where outbreaks of 

coyote or gray fox rabies occur. 

Wild animal collections for purposes of monitoring would be conducted using a variety of live capture or 

lethal methods. Information from raccoons would be predominantly collected from cage-trapped 

individuals that, if apparently healthy, would normally be released at or near their site of capture. The 

requisite sample from coyotes would be obtained primarily by aerial or ground-based shooting from sample 

areas within the ORV zones. Gray fox samples would be obtained by ground shooting and various capture 

methods including leghold traps, cage traps, and snares. Only legally approved methods would be used in 

all animal sample collection areas to provide critical data for the evaluation of project effectiveness. 

Project effectiveness would be based in large part on the percentage of ORV baits consumed in populations 

of target species, the presence of sufficient levels of serum neutralizing antibodies in a large enough 

percentage of the population to resist the spread of rabies, and the absence of the rabies strain targeted for 

control with ORV beyond the vaccination barrier established to prevent spread of the virus. In addition to 

the primary target species, several other species such as striped skunks and red foxes will be targeted 

during monitoring and surveillance, and for disease control in areas where a rabies outbreak has occurred. 

Several of these animals will be sampled to help determine efficacy of the treatment. 

Biological data such as sex, age, and weight would also be collected to determine if baits are consumed 

differently by various age or sex groups. For example, juvenile male raccoons are the most likely age/sex 

group to disperse from the home range in which they were born and are, therefore, the cohort which would 

be most important to vaccinate. Enhanced surveillance (using sick and strange-acting target and nontarget 

wildlife, nuisance wildlife captured during other WS damage management activities, and road-killed 

wildlife) would be conducted to track the occurrence of rabies within the ORV bait zones and to determine 

the epizootic front of the virus, so that ORV and other measures (i.e., trap-vaccinate-release) may be 

implemented ahead of these cases to maintain the integrity of the barrier. 
14 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Figure 1-8. Areas of enhanced surveillance conducted by APHIS-WS in and around current 

or anticipated ORV zones in 2007. 

1.2.1 Contingency Actions 

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 occur well beyond (e.g., raccoon rabies is 

detected greater than 80 km [50 miles] west of its known current distribution) ORV barriers (likely due to 

translocation of a rabid animal); Type 2) rabies case(s) that occur just beyond established ORV zones; Type 

3) rabies case(s) that occur where no ORV zone has been created; Type 4) persistence of rabies cases 

within ORV zones created as emergency treatments (e.g., northeast Ohio); Type 5) rabies hotspots found 

within the ORV zones that represent a high risk of spreading; and Type 6) aggressive epizootics (large 

numbers of infected animals in a relatively small area) approaching an established ORV zone that 

potentially could spread through the treatment area. 

Depending on the type(s) of rabies emergency(ies), contingency actions may employ one or more of the 

following practices: 

 Enhanced surveillance, which may include capture and release or euthanasia of target and specific 

nontarget animals for rabies testing. 

 Treatment with increased bait density (e.g., 75 baits/km2

 is considered the standard bait density for 

raccoons) to ensure sufficient baits for high density of target species or to bolster antibody 

response under “normal” 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. 
15 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

A licensed parenteral (injectable) vaccine, such as IMRAB® 3 (Merial, Inc.), rather than the oral 

rabies vaccine, would be used during the TVR contingency action. This action would involve the 

live capture of species being targeted (e.g., raccoons) followed by administration of rabies 

vaccines by injection and release back into the wild. Currently, no vaccine is specifically licensed 

for this type of use (CDC 2000). However, certain injectable vaccines may be used “off-label” 

under the direction of veterinarians to vaccinate wild animal species in certain situations (J. 

Mitzel, APHIS-Veterinary Services, pers. comm. 2001 as cited in USDA 2001a). Injectable 

vaccines, such as IMRAB® 3, are killed-virus rabies vaccines recommended for the vaccination of 

healthy 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 Pasteur Merieux 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 of an integrated rabies management program to eliminate or stop the 

spread of specific variants of the rabies virus in raccoons and skunks (Rosatte et al. 1990, 1992, 

2001). 

 Localized target species population reduction. 

The least intrusive contingency actions involve increasing levels of surveillance to determine if additional 

action is warranted. 

The rabies management program has several examples of contingency actions currently being conducted. 

In July 2007, rabies was documented in Quebec Canada, 3 km from the border with Clinton County, New 

York, while at the same time rabies was continuing to advance westward from Vermont (Type 2 and 4 

emergencies). In response to the threat of rabies continuing to spread south from Quebec and the 

continuing westward spread in Vermont, an emergency TVR effort was initiated in the northeast portion of 

Clinton County (USDA 2009). 

During 2004, Ohio identified its first case of raccoon variant of the rabies virus in Lake County, located 6.6 

miles (10.6 km) west of the existing ORV zone. Additional raccoon rabies cases were detected in the area 

from enhanced and public health surveillance (45 rabid raccoons and one skunk positive for raccoon rabies 

were confirmed within Geauga, Lake, and Cuyahoga Counties) in Ohio. This emergency (Types 2 and 4) 

triggered a contingency action response which encompassed a 954 mi2

 (2,471 km2) area in 2004. In 2007, 

the contingency action zone in Cuyahoga, Geauga, Lake, Portage, and Summit Counties was baited for the 

fourth year. Following the contingency action ORV baiting, Ohio WS assisted Lake County General 

Health District with supplemental hand baiting efforts in response to a cluster of rabies positives in the 

northwest corner of Lake County. 

Additionally, in a continuing effort to stop the spread of raccoon rabies in the CA ORV zone, WS 

conducted a Coordinated TVR effort in 2007. During this time, 1,013 unique raccoons and 3 striped skunks 

were immobilized, processed, and released; 1,007 of those raccoons and 3 striped skunks were hand 

vaccinated prior to release. Three feral cats were also trapped, vaccinated, and released. In addition, 445 

raccoons and 3 striped skunks were trapped, euthanized, and tested to enhance rabies surveillance. One of 

those raccoons from Cuyahoga County tested positive for rabies (USDA 2009a). 

In 2007, two cases of rabies that involved the Texas fox variant were confirmed west of the recently 

completed west-central Texas ORV zone. One case occurred at Rankin, 0.9mi (1.6 km) outside of the 

vaccination zone and the other near Grand falls, 26.0mi (42.0km) outside of the vaccination zone (Type 2 

emergency). In response, the Texas Department of State Health Services (TDSHS) and WS established an 

enhanced surveillance area. To eliminate the further spread, TDSHS and WS implemented population 

reduction efforts within a 100 mi2 (259 km2

) area surrounding Rankin. The Texas WS program provided a 

helicopter to distribute 8,687 FMP baits over the Rankin contingency area. However, 9 new cases of Texas 

fox variant were later confirmed in additional areas. To abate this problem, WS in cooperation with 

TDSHS distributed an additional 225,360 FMP and 112,476 dog food polymer (DFP) baits over 4,703 mi2

(12,179 km2

). In addition, WS, TDSHS, and city employees hand distributed 2,160 DFP baits throughout 

communities within the contingency areas. FMP baits were distributed to contain the rabies outbreak in 

coyotes across the western two-thirds of this second contingency area, while DFP baits were distributed in 

the eastern third of this area to target gray foxes and to increase the barrier width at key points along the 
16 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

eastern edge of the existing gray fox ORV zone. Upon completion of the second west-central Texas 

contingency action, WS and TDSHS increased the size of the enhanced surveillance area to include all 

counties surrounding the gray fox zone and contingency bait areas (USDA2009). 

In a continuing effort to stop the spread of raccoon rabies in northern Vermont, WS implemented several 

TVR campaigns throughout the standard and high bait density ORV zones in 2007. The first and second 

were coordinated TVR efforts were conducted in May and June-July 2007 in Franklin County, as well as in 

and around the city of St. Albans. A total of 766 unique raccoons and 46 skunks were captured during this 

initial effort. All skunks were euthanized to better understand the role they may have played in the 

outbreak; 40 were submitted and tested negative for rabies. Seventy-five raccoons were euthanized after 

exhibiting disorientation or showing clinical signs of rabies, or having puncture wounds, bite marks, or 

other lesions. Of these, 69 were submitted to the Vermont Department of Health (VDH) and 8 were 

positive for rabies. The remaining 689 raccoons were hand vaccinated and released. Additionally, 45 feral 

cats, 8 red foxes, and 2 fishers, were hand vaccinated and released. Most of the raccoons and skunks, and 

the 2 fishers were immobilized and processed as normal collecting blood and tooth samples to evaluate 

ORV efficacy from the previous year’s baiting. 

 In July 2007, raccoon rabies was documented in Quebec, just north of Grand Isle County. This prompted a 

shift in TVR priorities from Franklin to Grand Isle County and to vaccinating and releasing animals 

without processing. A total of 318 raccoons unique to this sampling period were captured. Of these, 108 

raccoons were euthanized with all but one submitted to VDH for testing. Four tested positive for rabies. 

The other 210 raccoons, all but 5 recaptures, were hand vaccinated and released. Nine of these 205 

raccoons were recaptured during the same sampling period. All 9 were euthanized upon recapture due to 

abnormal behavior, but all tested negative for rabies. Seventeen skunks were also trapped and euthanized; 

16 were submitted to the VDH and all were negative for rabies. Additionally, 9 feral/free-ranging cats, 2 

red foxes, 1 coyote, and 1 fisher were hand vaccinated and released. One more red fox was euthanized due 

to abnormal behavior, but it tested negative for rabies. Approximately 10% of the animals were 

immobilized and processed as normal collecting blood and tooth samples to evaluate ORV efficacy from 

the previous year's baiting (USDA 2009). 

In 2007, WS continued to enhance rabies surveillance in most of the states conducting ORV for raccoons, 

as well as emphasizing surveillance in adjacent states west of the raccoon ORV zone including Michigan, 

Kentucky, Mississippi and Louisiana. 

1.3 AUTHORITIES 

Wildlife disease and damage management are based on interagency relationships, which require close 

coordination and cooperation because of related or overlapping authorities or legal mandates. The APHISWS 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, NRMP cooperates closely with state agencies where APHIS-WS 

works with agencies such as the State Health and Wildlife Departments. 

1.3.1 Federal Authorities. 

APHIS – Wildlife Services. USDA is authorized and directed by law to protect American agriculture and 

other resources from damage associated with wildlife. The primary statutory authorities for the APHIS-WS 

program are the Act of March 2, 1931 (46 Stat. 1468; 7 United States Code (USC) 426-426c) as amended, 

and the Act of December 22, 1987 (101 Stat. 1329-331, 7 USC 426c). The Act of March 2, 1931, as 

amended in the Fiscal Year 2001 Agriculture Appropriations Bill, provides that: 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

“The Secretary of Agriculture may conduct a program of wildlife services with respect to injurious animal 

species and take any action the Secretary considers necessary in conducting the program. The Secretary 

shall administer the program in a manner consistent with all of the wildlife services authorities in effect on 

the day before the date of the enactment of the Agriculture, Rural Development, Food and Drug 

Administration, and Related Agencies Appropriation Act, 2001.” 

In 1988, Congress strengthened the legislative directive and authority of WS with the Rural Development, 

Agriculture, and Related Agencies Appropriations Act. This Act states, in part: 

“That hereafter, the Secretary of Agriculture is authorized, except for urban rodent control, to conduct 

activities and to enter into agreements with States, local jurisdictions, individuals, and public and private 

agencies, organizations, and institutions in the control of nuisance mammals and birds and those mammals 

and bird species that are reservoirs for zoonotic diseases, and to deposit any money collected under such 

agreements into the appropriation accounts that incur the costs to be available immediately and to remain 

available until expended for Animal Damage Control activities.” 

WS recognizes that wildlife is an important public resource greatly valued by the American people. By its 

very nature, however, wildlife is a highly dynamic and mobile resource that can damage agricultural 

resources, pose risks to human health and safety, and affect other natural resources. The WS program 

provides Federal leadership in helping to solve problems that occur when human activity and wildlife are in 

conflict with one another. 

The Act of September 25, 1981, as amended (7 U.S.C. Sec. 147b). This law authorizes the Secretary of 

Agriculture, in connection with emergencies which threaten any segment of the agricultural production 

industry of the U.S., to transfer from other appropriations or funds available to the agencies or corporations 

of USDA such sums as the Secretary may deem necessary, to be available only in such emergencies for the 

arrest and eradication of contagious or infectious diseases of animals. It is under this authority that funds 

from the federal Commodity Credit Corporation have been transferred to APHIS-WS to expend for the 

continuation and expansion of ORV programs in the states identified herein (65 FR 76606-76607, 

December 7, 2000). 

Virus-Serum-Toxin Act (21 U.S.C. 151 et seq.). The oral rabies vaccine (RABORAL V-RG®) is 

licensed for treatment of raccoons and coyotes by the USDA under the Virus-Serum-Toxin Act (VSTA). 

Animal vaccines shipped in or from the U.S. must be prepared under and cannot be imported without a 

USDA license. Federal regulations implementing the VSTA (9 CFR 103.3) require authorization by 

APHIS before an experimental biological product can be shipped for the purpose of treating limited 

numbers of animals as part of an evaluation process. The license for RABORAL V-RG® requires that it be 

restricted for use in state or federal rabies management programs. 

Public Health Service Act. CDC, located in Atlanta, Georgia, is an agency of the U.S. Department of 

Health & Human Services. CDC's mission is to promote health and quality of life by preventing and 

controlling disease, injury, and disability. CDC is authorized under 42 U.S.C. 241 to render assistance to 

other appropriate public authorities in the conduct of research, investigations, demonstrations, and studies 

relating to the causes, diagnosis, treatment, control, and prevention of physical and mental diseases and 

impairments of man. In addition, under 42 U.S.C. 243(a), the Secretary of Health & Human Services may 

assist states and their political subdivisions in the prevention and suppression of communicable diseases. 

National Forest Management Act of 1976 (16 U.S.C. section 2101 [note]). This law amended the Forest 

and Rangeland Renewable Resources Planning Act of 1974, which called for the management of renewable 

resources on national Forest lands. The national Forest Management Act requires the Secretary of 

agriculture to assess forest lands, develop a management program based on multiple-use, sustained-yield 

principles, and implement a resource management plan for each unit of the national Forest Systems. This 

Act is the primary statue governing the administration of national Forests. 

Cooperative Forestry Assistance Act of 1978 (16 U.S.C. section 2101 [note]). This laws authorizes the 

Secretary of agriculture to assist in controlling forest insects and diseases directly on National Forest 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

System lands and in cooperation on other federal and non-federal lands of all ownerships. 

U.S. Forest Service (USFS). Under the Act of March 2, 1931 (46 Stat. 1468; 7 U.S.C. 426-426b) as 

amended, and the act of December 22, 1987 (101 Stat. 1329-331, 7 U.S.C 426c), the USFS and the APHISWS, along with the states cooperate to manage wildlife damage on the USFS lands, the National Forest 

System. Under the framework of an MOU, signed June 4, 2004, between the USFS and APHIS-WS, 

APHIS-WS is designated as the lead agency concerning animal damage and disease management activities 

on USFS lands. This includes a responsibility to maintain technical expertise in the science of wildlife 

damage management, control tools and techniques, conducting management programs, and complying with 

NEPA for APHIS-WS activities. The MOU directs the USFS to coordinate with APHIS-WS in the 

development and review of work plans governing APHIS-WS’ activities on USFS lands and to cooperate in 

APHIS-WS’ NEPA processes. 

Bureau of Land Management. Under the Act of March 2, 1931 (46 Stat. 1468; 7 U.S.C. 426-426b) as 

amended, and the act of December 22, 1987 (101 Stat. 1329-331, 7 U.S.C 426c), BLM and APHIS-WS, 

along with the states, cooperate to manage wildlife damage on BLM lands. Similar to the USFS, BLM and 

APHIS-WS have entered into a MOU, signed March 21, 1995, which identifies the roles and 

responsibilities of each agency in wildlife damage management operations and coordination, and NEPA 

compliance. The MOU directs BLM to coordinate with APHIS-WS in the development and review of 

wildlife damage work plans governing APHIS-WS’ activities on BLM lands and to cooperate in APHISWS’ NEPA processes. 

1.3.2 State and Local Authorities. 

Each of the 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. APHIS-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, it is the various cooperating states that exercise their authorities under state 

law to propose or approve the distribution of ORV baits onto lands owned or managed by a variety of 

entities including private persons, federal land management agencies [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 of establishing and maintaining ORV barriers and, potentially, to the eventual 

elimination of targeted rabies strains in many areas, that all lands containing substantial amounts of habitat 

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. 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. 

1.4 OTHER RELEVANT FEDERAL LAWS AND REGULATIONS 

National Environmental Policy Act (NEPA) (42 U.S.C. 4321 et seq.). The purpose of NEPA is to 

declare a national policy that encourages productive and enjoyable harmony between man and the 

environment, promotes efforts that prevent or eliminate damage to the environment and biosphere, and 

stimulate the health and welfare for man, enriches the understanding of ecological systems and natural 

resources important to the Nation, and, lastly, establishes a Council on Environmental Quality. 

APHIS-WS prepares analyses of the environmental impacts of program activities to meet procedural 

requirements of this law. APHIS has previously prepared a number of environmental assessments (EAs) to 

address the environmental effects of experimental programs using V-RG ORV baits and covering the 

approval of licensing of the vaccine for use in raccoons (see Section 1.5). APHIS-WS also completed an 

EA and Finding of No Significant Impact (FONSI) (USDA 2001a), dated July 30, 2001; a supplemental 

FONSI (USDA 2002), dated August 5, 2002; a supplemental EA and FONSI (USDA 2003a), dated June 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

12, 2003; a supplemental EA and FONSI (USDA 2004a), dated September 9, 2004; and a FONSI (USDA 

2007c), dated April 10, 2007. These documents analyzed the environmental effects of APHIS-WS 

involvement in the funding of and participation in ORV programs to eliminate or stop the spread of raccoon 

rabies in a number of eastern states (Alabama, Connecticut, Delaware, Florida, Georgia, Indiana, Kentucky, 

Louisiana, Maine, Maryland, Massachusetts, Michigan, Mississippi, New Hampshire, New Jersey, New 

York, North Carolina, Ohio, Pennsylvania, Rhode Island, South Carolina, Tennessee, Vermont, Virginia, 

and West Virginia) and gray fox and coyote rabies in Texas. APHIS-WS determined these actions would 

not have a significant impact on the quality of the human environment (see Section 1.5). Furthermore, 

APHIS-WS, in cooperation with the USFS, prepared an EA and FONSI (USDA 2004b), dated February 12, 

2004; and a supplemental EA and FONSI (USDA 2006a), dated December 8, 2005. These documents 

analyzed the environmental effects of APHIS-WS involvement in the funding of and participation in ORV 

programs on several USFS lands (excluding Wilderness Areas) in the eastern U.S. to eliminate or stop the 

spread of raccoon rabies. APHIS-WS with USFS determined the action would not have a significant 

impact on the quality of the human environment (see Section 1.5). 

APHIS-WS determined that, because of increased federal involvement in ORV programs in recent years, 

because of the current proposal to continue or expand federal involvement in such programs in additional 

states, and because of the need for expanded monitoring and surveillance in the event contingency actions 

must be implemented, further NEPA documentation is appropriate. Therefore, this EA is intended to meet 

the NEPA requirement for the proposed action by clearly communicating the scope of federal involvement 

by APHIS-WS and by determining if there are any substantive new issues or alternatives that should be 

analyzed. 

Endangered Species Act (ESA) (16 U.S.C. 1531 et seq.). It is federal policy, under the ESA, that all 

federal agencies shall seek to conserve threatened and endangered (T&E) species and shall utilize their 

authorities in furtherance of the purposes of the Act (Sec.2(c)). For actions that “may affect” listed species, 

APHIS-WS conducts Section 7 consultations with the U.S. Fish & Wildlife Service (USFWS) to ensure 

that "any action authorized, funded or carried out by such an agency . . . is not likely to jeopardize the 

continued existence of any endangered or threatened species . . . Each agency shall use the best scientific 

and commercial data available" (Sec.7(a)(2)). APHIS-WS has analyzed the potential for effects on listed 

species in this EA and has concluded that the proposed action will have minimal potential to affect or no 

effect on any listed species (see Section 4.1.3.2). 

National Historic Preservation Act (NHPA) of 1966 as amended (16 U.S.C. 470). NHPA and its 

implementing regulations (36 CFR 800) require federal agencies to: 1) determine whether activities they 

propose constitute “undertakings” that can result in changes in the character or use of historic properties 

and, 2) if so, evaluate the effects of such undertakings on such historic resources and consult with the State 

Historic Preservation Office regarding the value and management of specific cultural, archaeological, and 

historic resources, and 3) consult with appropriate American Indian Tribes to determine whether they have 

concerns for traditional cultural properties in areas of these federal undertakings. 

ORV activities described under the proposed action (Section 1.2) do not cause major ground disturbance, 

do not cause any physical destruction or damage to property, do not cause any alterations of property, 

wildlife habitat, or landscapes, and do not involve the sale, lease, or transfer of ownership of any property. 

In general, such methods also do not have the potential to introduce visual, atmospheric, or audible 

elements to areas in which they are used that could result in effects on the character or use of historic 

properties. Therefore, the methods that would be used under the proposed action are not generally the 

types of activities that would have the potential to affect historic properties. If an individual activity with 

the potential to affect historic resources is planned under an alternative selected as a result of a decision on 

this EA, then site-specific consultation as required by Section 106 of the NHPA would be conducted as 

necessary. 

Executive Order on Environmental Justice. Executive Order (EO) 12898, Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations requires federal agencies to 

analyze disproportionately high and adverse environmental effects of proposed actions on minority and 
20 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

low-income populations. APHIS-WS has analyzed the effects of the proposed action and determined that 

implementation would not have adverse human health or environmental impacts on low-income or minority 

populations. 

Executive Order on Protection of Children from Environmental Health and Safety Risks. Executive 

Order 13045 was passed to help protect children who may suffer disproportionately from environmental 

health and safety risks for many reasons. ORV activities as proposed in this EA would only involve legally 

available and approved methods that have been subjected to safety evaluations and testing. The vaccinia 

virus used as a carrier of the rabies glycoprotein is the same type of virus that was used in smallpox 

eradication, although more attenuated or weakened (USDA 1991, p. 39). The analysis in Section 4.1.1 of 

this EA supports a conclusion of very low to no risk of adverse effects on children from the ORV baiting 

strategy. Implementation of the proposed action would not increase environmental health or safety risks to 

children, but would in fact reduce such risks by minimizing the potential for children to contract rabies. 

Children are particularly at risk from rabies because they are more prone to experiencing “undetected” or 

“unappreciated” exposures (Huntley et al. unpublished 1996) that do not lead to post-exposure vaccine 

treatments. Therefore, federal involvement in ORV programs is consistent with and helps to achieve the 

goals of EO 13045. 

Native American Graves and Repatriation Act of 1990. The Native American Graves Protection and 

Repatriation Act requires federal agencies to notify the Secretary of the Department that manages the 

federal lands upon the discovery of native American cultural items on federal or tribal lands. Federal 

projects would discontinue work until a reasonable effort has been made to protect the items and the proper 

authority has been notified. 

Federal Food, Drug, and Cosmetic Act (21 U.S.C. 360). This law places administration of 

pharmaceutical drugs, including those used in wildlife capture and handling, under the Food and Drug 

Administration. 

Controlled Substances Act of 1970 (21 U.S.C. 821 et seq.). This law requires an individual or agency to 

have a special registration number from the federal Drug Enforcement Administration (DEA) to possess 

controlled substances, including those that are used in wildlife capture and handling. 

Animal Medicinal Drug Use Clarification Act of 1994 (AMDUCA). The AMDUCA and its 

implementing regulations (21 CFR Part 530) establish several requirements for the use of animal drugs, 

including those used to capture and handle wildlife in rabies management programs. Those requirements 

are: (1) a valid “veterinarian-client-patient” relationship; (2) well defined record keeping; (3) a withdrawal 

period for animals that have been administered drugs; and (4) identification of animals. A veterinarian, 

either on staff or on an advisory basis, would be involved in the oversight of the use of animal capture and 

handling drugs under the proposed action. Veterinary authorities in each state have the discretion under 

this law to establish withdrawal times (i.e., a period of time after a drug is administered that must lapse 

before an animal may be used for food) for specific drugs. Animals that might be consumed by a human 

within the withdrawal period must be identified; the Western Wildlife Health Committee of the Western 

Association of Fish and Wildlife Agencies has recommended that suitable identification markers include 

durable ear tags, neck collars, or other external markers that provide unique identification (WWHC 

undated). APHIS-WS establishes procedures in each state for administering drugs used in wildlife capture 

and handling that must be approved by state veterinary authorities in order to comply with this law. 

Clean Air Act of 1970 as amended (42 U.S.C. 7401). The Clean Air Act is a comprehensive federal law 

that regulates air emissions from area, stationary, and mobile sources. 

Coastal Zone Management Act of 1972, as amended (CZMA) (16 USC 1451-1464, Chapter 33; P.L. 

92-583, October 27, 1972; 86 Stat. 1280). The CZMA established a voluntary national program within 

the Department of Commerce to encourage coastal states to develop and implement coastal zone 

management plans. Funds were authorized for cost-sharing grants to states to develop their programs. 

Subsequent to federal approval of their plans, grants would be awarded for implementation purposes. In 
21 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

order to be eligible for federal approval, each state's plan was required to define boundaries of the coastal 

zone, identify uses of the area to be regulated by the state, determine the mechanism (criteria, standards or 

regulations) for controlling such uses, and develop broad guidelines for priorities of uses within the coastal 

zone. In addition, this law established a system of criteria and standards for requiring that federal actions be 

conducted in a manner consistent with the federally approved plan. The standard for determining 

consistency varied depending on whether the federal action involved a permit, license, financial assistance, 

or a federally authorized activity. 

APHIS-WS submitted a National Consistency Determination concerning the potential effects of the 

national rabies management program on coastal zone resources to all potentially affected states with 

approved coastal management programs (AL, CT, DE, FL, GA, IN, LA, ME, MD, MA, MI, MS, NH, NJ, 

NY, NC, OH, PA, RI, SC, and VA). APHIS-WS received concurrence that the national rabies management 

program would have de minimus (15CFR930.33) cumulative or secondary effects on coastal resources. 

Thus, APHIS-WS has determined the national rabies management program to be consistent with the 

CZMA and associated coastal zone management programs within the potentially affected coastal zone 

states and the program is excluded from further state agency consistency review. 

Wilderness Act of 1964 – An Act (Public Law 88-577; 88th Congress, S.4; September 3, 1964). The 

Wilderness Act allows federally owned lands meeting specific criteria to be designated as “wilderness 

areas.” The act prohibits and restricts certain uses of these designated lands. The act provides special 

provisions to allow certain activities to take place within designated wilderness areas such as the use of 

aircraft to control fire, insects, and diseases (Sec. 4 (d)). APHIS-WS obtains USFS Forest Supervisor or 

BLM State Director approval to conduct control activities in Wilderness areas where necessary. 

1.5 RELATIONSHIP TO OTHER ENVIRONMENTAL DOCUMENTS 

Work Plan for Oral Vaccination by Ground or Aerial Baiting to Control Specific Rabies Virus 

Variant in Raccoons on National Forest System Lands in USFS Regions 8 and 9. This Work Plan has 

been prepared by APHIS-WS in coordination with the USFS to implement ORV program activities on 

National Forest System lands in USFS Regions 8 and 9. 

The USFS has reviewed the proposed action and alternatives described in this EA and has determined the 

proposed action to be consistent with Land and Resource Management Plans for the National Forests listed 

in Appendix I and excluding Wilderness Areas. 

A number of other NEPA documents have been prepared that analyzed the potential environmental effects 

of ORV programs and the methods used in rabies monitoring and surveillance. Pertinent information from 

those analyses has been incorporated by reference into this EA. 

Wildlife Services Programmatic EIS. APHIS-WS has issued a final Environmental Impact Statement 

(EIS) (USDA 1997j) and Record of Decision on the National APHIS-WS program. Relevant information 

from the EIS will be incorporated by reference in this document. 

EA, FONSI, and Decision – Oral Vaccination to Control Specific Rabies Virus Variants in Raccoons, 

Gray Foxes, and Coyotes in the United States. This EA and FONSI/Decision and Supplements (USDA 

2001a, 2002, 2003a, 2004a, 2007c) analyzed the environmental effects of APHIS-WS involvement in the 

funding of and participation in ORV programs to eliminate or stop the spread of raccoon rabies in a number 

of eastern states (Alabama, Connecticut, Delaware, Florida, Georgia, Indiana, Kentucky, Louisiana, Maine, 

Maryland, Massachusetts, Michigan, Mississippi, New Hampshire, New Jersey, New York, North Carolina, 

Ohio, Pennsylvania, Rhode Island, South Carolina, Tennessee, Vermont, Virginia, and West Virginia) and 

gray fox and coyote rabies in Texas. APHIS-WS determined the action would not have any significant 

adverse impact on the quality of the human environment. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

EA, FONSI, and Decision - Oral Vaccination to Control Specific Rabies Virus Variant in Raccoons 

on National Forest System Lands in the United States. This EA and FONSI and Supplement (USDA 

2004b, 2006a,) analyzed the potential environmental effects of a proposal to expand the involvement of the 

APHIS-WS program in ORV programs to portions of National Forest System lands, excluding Wilderness 

Areas, in a number of eastern states. The National Forest System lands where APHIS-WS involvement 

would be expanded may be located within the states of Alabama, Connecticut, Delaware, Florida, Georgia, 

Indiana, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Mississippi, New Hampshire, 

New Jersey, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, South Carolina, Tennessee, 

Vermont, Virginia, and West Virginia. Numerous National Forest System lands are located within current 

and potential ORV barrier zones. To effectively combat this strain of the rabies virus, it has become 

increasingly important to bait these large land masses. 

EA, FONSI, and Decision – Oral Rabies Vaccination Program. APHIS-WS was a cooperating agency 

in the preparation of this EA and FONSI/Decision (USDI 2004) which analyzed the environmental effects 

of NPS participation in ORV programs on fifteen NPS units in the states of Alabama, Florida, Georgia, 

North Carolina, and Tennessee in the effort of stopping the spread of a specific raccoon rabies variant or 

“strain” of the rabies virus and reducing or eliminating this strain of the virus from the eastern United 

States. The NPS determined the action would have a negligible impact on the quality of the human 

environment. 

EA, FONSI, and Decision – Oral Rabies Vaccination Program for Big Bend National Park, 

Guadalupe Mountains National Park, and Amistad National Recreation Area in Texas. APHIS-WS 

was a cooperating agency in the preparation of this EA and FONSI/Decision (USDI 2003) which analyzed 

the environmental effects of NPS participation in ORV programs to eliminate or stop the spread of gray fox 

rabies on three NPS units in Texas. The NPS determined the action would have a negligible impact on the 

quality of the human environment. 

EA, FONSI, and Decision – Proposed Issuance of a Conditional United States Veterinary Biological 

Product License to Rhone Merieux, Inc. for Rabies Vaccine, Live Vaccinia Vector. This EA and its 

FONSI/Decision, dated April 7, 1995, were prepared by APHIS and concluded that there would be no 

significant impact on the quality of the human environment from the decision to issue the conditional 

license mentioned above (USDA 1995a). The conditional license approved the use of V-RG in raccoon 

rabies control programs administered under the direction of state or federal government agencies. 

Mitigation measures required under the decision included public education and notification efforts prior to 

distributing the baits, and the placement of warning labels on each vaccine-laden bait. 

EA, FONSI, and Decision – Proposed Field Application of an Experimental Rabies Vaccine, Live 

Vaccinia Vector, in South Texas. This EA and its FONSI/ Decision, completed in 1995, analyzed the 

environmental effects of experimental distribution of ORV baits containing V-RG to eliminate and stop the 

spread of coyote rabies in South Texas (USDA 1995b). APHIS determined the action would not have any 

significant adverse impact on the quality of the human environment. 

EAs and Findings of No Significant Impact on Proposed Field Trials/Tests of Live Experimental 

Vaccinia-Vector Recombinant Rabies Vaccine for Raccoons. APHIS analyzed the potential 

environmental impacts of six separate field trials or tests of the recombinant V-RG vaccine in several 

northeastern states. In EAs and FONSIs/Decisions covering those actions, (USDA 1991, 1992, 1993, 

1994a, 1994b, 1994c), APHIS determined that none of the actions would have any significant adverse 

impact on the quality of the human environment. 

Risk Analyses for ORV Using the V-RG Recombinant Virus. Two formal risk analyses on the rabies 

vaccine -- live vaccinia vector (i.e., the recombinant V-RG vaccine) have been prepared previously by 

APHIS (USDA undated a, USDA undated b). Both analyses concluded the risk of adverse animal safety, 

human safety, or other environmental effects to be low. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

(Nine) EAs, Findings of No Significant Impact, and Decisions - Predator Damage Management in 

(Brownwood, Canyon, College Station, Fort Stockton, Fort Worth, Kerrville, Kingsville, San Angelo, 

and Uvalde) District(s) of the Texas Animal Damage Control Program. These EAs and their 

FONSIs/Decisions evaluated the environmental impacts of implementing various methods of predator 

damage management in nine districts in Texas, including methods proposed herein for collection of gray 

foxes and coyotes as part of rabies ORV program monitoring and surveillance activities. APHIS-WS 

determined that none of the district programs would have any significant impact on the quality of the 

human environment (USDA 1997a, 1997b, 1997c, 1997d, 1997e, 1997f, 1997g, 1997h, and 1997i). 

EA, Finding of No Significant Impact, and Decision – Predator Damage Management in New Mexico. 

This EA and its FONSI/Decision evaluated the environmental impacts of implementing predator damage 

management in New Mexico to protect all resources, including human health and safety from disease, and 

determined that the take of predators did not have a significant adverse impact on the quality of the human 

environment (USDA 2006b). 

EAs, Findings of No Significant Impact, and Decisions – Predator Damage Management on 

Nonfederal and Tribal Lands and Federal Public Lands in Arizona. These 2 EA and their 

FONSIs/Decisions evaluated the environmental impacts of implementing predator damage management, on 

all land classes combined, in Arizona to protect all resources, including human health and safety from 

disease, and determined that the take of predators did not have a significant adverse impact on the quality 

of the human environment (USDA 1996, 1999). 

1.6 DECISION TO BE MADE 

Based on the scope of this EA, the decisions to be made are: 

 Should APHIS-WS continue or expand its involvement in ORV programs in the eastern and 

southwestern United States, including National Forest System and BLM lands, to combat raccoon, 

gray fox, and coyote rabies? 

 If not, should APHIS-WS attempt to implement one of the alternatives as described in this EA? 

 Would implementing the proposed action or one of the other alternatives have significant adverse 

impacts on the quality of the human environment requiring preparation of an EIS? 

1.7 GOALS 

As stated in the description of the proposed action, the primary goals of the program are to: 

 Stop the forward advance of raccoon, gray fox, and coyote strains of rabies from areas where they now 

occur by immunizing portions of target species populations along the leading edges of the rabies 

fronts; and 

 reduce the incidence of rabies cases involving wild and domestic animals and rabies exposures to 

humans in the areas where the ORV programs are conducted. 

A Work Plan between the USFS and APHIS-WS has been prepared regarding implementation of ORV 

programs on National Forest System lands. Additionally, the states that would be involved in the proposed 

action have established, or are in the process of establishing, plans for the implementation of ORV or 

contingency action programs. The proposed action would be consistent with such plans and any statements 

of goals and objectives as they are developed by the involved state and federal agencies. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

1.8 SCOPE OF THIS ENVIRONMENTAL ASSESSMENT ANALYSIS

1.8.1 Actions Analyzed. 

This EA evaluates the environmental effects of the continued and expanded APHIS-WS funding of and 

participation in ORV programs to eliminate or stop the spread of raccoon, gray fox, and coyote strains of 

rabies in the eastern and southwestern United States, including National Forest System and BLM lands. 

Analyses specific to this EA include the incorporation of trap-vaccine-release (TVR) as a possible 

contingency action, as well as the clarification of the term “contingency actions” which were previously 

analyzed in a Supplemental EA with its FONSI/Decision (USDA 2007). Further, the additional effects of 

expanding the ORV program into Arizona and New Mexico are presented in this EA. Under the proposed 

action, ORV, monitoring, and surveillance activities, and contingency actions could be conducted on 

private, federal, state, tribal, county, and municipal lands in the eastern and southwestern United States 

(Figure 1-5). 

1.8.2 Period for which this EA is Valid. 

This EA would remain valid until APHIS-WS determines that new needs for action, new unforeseen 

significant issues, or new alternatives having different environmental effects must be analyzed. At that 

time, this analysis and document would be supplemented or revised pursuant to NEPA. Review of the EA 

will be conducted annually by APHIS-WS to ensure that the EA and the analyses contained herein are still 

appropriate for the scope of the program.

1.8.3 Site Specificity. 

This EA analyzes potential impacts of continued or expanded APHIS-WS participation in ORV programs 

in the states described in Section 1.2 (Figure 1-5), including National Forest System and BLM lands. 

Because the proposed action is to assist the affected states in accordance with plans, goals, and objectives 

developed by those states, the proposed action could involve APHIS-WS participation in ORV bait 

distribution, monitoring and surveillance, or local population reduction of target species anywhere in those 

states where the need has been identified by the appropriate state agencies. Therefore, all National Forest 

System and BLM lands within the aforementioned states could be affected. 

This EA identifies as possible the typical habitat and specific areas that are currently known to be in need 

of ORV program action. However, the location of every wildlife rabies outbreak that would trigger use of 

ORV cannot be predicted. Implementation of emergency response and contingency action plans that 

involve localized population suppression of target species could similarly be needed anywhere in the 

involved states where outbreaks of the targeted rabies strains occur. In addition, changes in funding levels 

over time could create changes in ORV program activities, such as increasing or decreasing the size of the 

ORV barrier zone and other areas to be baited and varying the types of monitoring and surveillance and 

research conducted in an adaptive management mode. Planning for the management of rabies epizootics 

must be viewed as being conceptually similar to federal or other agency actions whose missions are to stop 

or prevent adverse consequences from anticipated future events for which the actual sites and locations 

where they will occur are unknown but could be anywhere in a defined geographic area. Examples of such 

agencies and programs include fire and police departments, emergency clean-up organizations, and 

insurance companies. 

Although some of the sites where wildlife rabies outbreaks will occur can be predicted, specific locations or 

times where such outbreaks will occur in any given year cannot be accurately predicted. Thus, this EA 

addresses the substantive environmental issues that pertain to ORV use and monitoring/surveillance 

activities, and, if necessary, localized target species population reduction wherever these activities might 

occur in the states identified herein. The analyses in this EA are intended to apply to any action that may 

occur in any locale, except Wilderness Areas, and at any time within the analysis area. In this way, APHISWS believes it meets the intent of NEPA with regard to site-specific analysis and program planning and 

that this is the only practical way for WS to comply with NEPA and still be able to accomplish its mission. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

1.8.4 Coordination. 

WS is the lead agency and decision-maker for this EA. However, to assure that the concerns of other 

Federal land managers have been addressed, the USFS and BLM were asked to participate in the 

development and review of this EA. The agencies participated in the review of this EA as per 40 CFR 

1501.6 and ensure compliance with their respective Land and Resource Management Plans. 

APHIS-WS will coordinate with all applicable federal and state agencies, and tribal governments 

(Appendix F) who will be affected by APHIS-WS actions on their lands through compliance with the 

NEPA process or other agency specific coordination including, but not limited to, entrance into MOUs, 

establishment of work plans, or issuance of Special Use Permits. All affected agencies will be contacted 

early and prior to implementation of any APHIS-WS NRMP activity to ensure that the agencies are in 

accordance with APHIS-WS actions and gain their cooperation with any site specific issues the affected 

agency might have. However, APHIS-WS activities on NPS lands are not covered under the scope of this 

document. ORV implementation of NPS lands has been addressed through EAs maintained by the NPS. 

1.9 SUMMARY OF PUBLIC INVOLVEMENT EFFORTS 

Several EAs have been prepared previously to analyze the environmental effects of APHIS-WS’ continued 

and expanded participation with an ORV program in the eastern and southwestern United States (Figure 1-

5). Issues related to the proposed action were identified through involvement and planning/scoping 

meetings with numerous federal (i.e., Centers for Disease Control and Prevention), state (i.e., health, 

agriculture, and natural resource departments), and local government agencies, academic institutions, and 

Canadian provincial government agencies (i.e., Ontario Ministry of Natural Resources). 

For the previous EA and supplemental EAs, additional efforts to determine further issues that the public 

might have with this action were made through Federal Register Notices (66 FR 13696-13700, March 7, 

2001 and 66 FR 27489, 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 identify 

any substantive new issues or alternatives not already identified for analysis. A third Federal Register 

Notice (66 FR 45835-45836, August 30, 2001) was published announcing the availability of the EA and 

Decision/ FONSI. In 2002, a Notice of Availability for a subsequent Decision/FONSI was published 

through a Federal Register Notice (67 FR 44797-44798, July 5, 2002). In 2003, a Notice of Availability for 

a supplemental EA and Decision/FONSI was published through a Federal Register Notice (68 FR 38669-

38670, June 30, 2003). In 2004, a Notice of Availability for an EA and Decision/FONSI was published 

through a Federal Register Notice (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 of Availability for another supplemental EA and Decision/FONSI 

was published through a Federal Register Notice (69 FR 56992-56993, September 23, 2004) to document 

the expansion of the rabies management program to include 26 states and the District of Columbia. In 

response to the expanded program area, another Notice of Availability for a supplemental EA and 

Decision/FONSI was published through a Federal Register Notice (70 FR 72977-72978, December 8, 

2005) in 2005 to document additional National Forest System lands within the expanding program. In 

2007, a Notice of Availability for a subsequent Decision/FONSI was published through a Federal Register 

Notice (72 FR 20984-20986, April 27, 2007). These previous analyses and reviews indicated that the ORV 

program would have no significant effects. 

This draft EA will be made available to the public by a notice in the Federal Register, by directly mailing 

notices of availability to all people who have expressed an interest in this or similar APHIS-WS activities, 

and by posting this document and notice of its availability on the APHIS-WS website 

http://www.aphis.usda.gov/wildlife_damage/nepa.shtml. The draft EA will be available for public 

comment for a period of 30 days, with a closing date specified in the Federal Register notice. Anyone who 

proveds comments or expresses an interest in the proposal during the public comment period of this EA 

will receive a notice of the decision. 
26 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

CHAPTER 2: ISSUES AND AFFECTED ENVIRONMENT 

2.1 ISSUES 

In preparation of this EA, APHIS-WS compiled issues for the ORV EA from public input received in 

response to a Federal Register Notice (66 FR 13696-13700, March 7, 2001) and agency concerns discussed 

during scoping meetings held with state and local departments of health and the CDC. Many issues were 

discussed in previous EAs and FONSIs (USDA 2001a, 2002, 2003a, and 2004a), but the following issues 

were determined to be germane to the proposed action and were considered in detail: 

 Potential for adverse effects on target wildlife species populations. 

 Potential for adverse effects on nontarget wildlife species, including threatened or endangered species. 

 Potential for adverse effects on people, pets, and livestock that are exposed to or consume the vaccine 

laden baits. 

 Potential for the recombined V-RG virus to “revert to virulence” or recombine 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. 

 Cost of the program in comparison to perceived benefits. 

 Humaneness of methods used to collect wild animal specimens critical for timely program evaluation 

or to reduce local populations of target species under state contingency plans. 

2.2 OTHER ISSUES CONSIDERED BUT NOT IN DETAIL WITH RATIONALE

2.2.1 Potential for Drugs Used in Animal Capture and Handling to Cause Adverse Health Effects 

in Humans that Hunt and Eat the Species Involved

Among the species to be captured and handled under the proposed action, this issue is expected to be the 

most concern for raccoons which are hunted and sometimes consumed by people as food. Drugs used in 

capturing and handling raccoons for surveillance and monitoring purposes in rabies management programs 

include ketamine hydrochloride, xylazine (Rompun®, Bayer Health Care, Monheim, Germany), and a 

mixture of tiletamine and zolazepam (Telazol®, Wyeth Pharmaceuticals, Fort Dodge Animal Health, IA). 

Meeting the requirements of the AMDUCA (see Section 1.4) should prevent any significant adverse 

impacts on human health with regard to this issue. Standard operating procedures (SOPs) followed in each 

state include: 

 All drugs used in capturing and handling raccoons, coyotes, gray foxes, skunks, and other animals 

would be under the direction of state or federal veterinary authorities, either directly or through 

procedures agreed upon between those authorities and APHIS-WS. 

 As determined on a federal- or state-level basis by these veterinary authorities (as allowed by 

AMDUCA), ORV program participants may choose to avoid capture and handling activities that use 

immobilizing drugs within a specified number of days prior to the hunting or trapping season for the 

target species to avoid release of animals that may be consumed by hunters prior to the end of 

established withdrawal periods for the particular drugs used. However, capture and handling activities 

would likely extend into the hunting season during late summer/fall ORV baiting schedules. 

Therefore, target species would either be marked or euthanized if immobilizing drugs are used within 

30 days of hunting or trapping seasons. These measures would be taken to avoid release of animals that 

could be consumed by hunters prior to the end of established withdrawal periods for the particular 

drugs used. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

 Animals that have been immobilized and released are ear tagged or marked in some way to alert 

hunters and trappers that they should contact APHIS-WS personnel before consuming the animal. 

By following these procedures in accordance with AMDUCA, rabies management programs would avoid 

any significant impacts on human health with regard to this issue. 

2.2.2 Potential for Drugs Used in Animal Capture and Handling to Cause Adverse Health Effects 

in Scavengers or Other Nontarget Animals that May Consume the Species Involved 

Drugs used in the capturing and handling of raccoons, gray foxes, or coyotes for surveillance and 

monitoring purposes in the rabies management program include ketamine hydrochloride, xylazine, and a 

mixture of tiletamine and zolazepam. These drugs are generally injected intravenously or intramuscularly 

and, less-often, subcutaneously. Oral delivery of immobilizing drugs may be used to calm animals caught 

in traps. For example, oral delivery of ketamine can calm the animal enough to allow injection of 

additional drug via syringe (USDA 2001b). However, oral delivery is not recommended for anesthetizing 

the animal due to the much higher dosage required to compensate for the slower uptake rate and correct 

dosages cannot be guaranteed (USDA 2001b). 

APHIS-WS personnel would not release an animal until it has returned to full and normal function, thereby 

reducing its chances of succumbing to potential predators or other dangers. Most immobilizing drugs used, 

such as ketamine and xylazine, are metabolized and excreted within hours after the animal returns to full 

function (Dr. L. Bigler, New York State Animal Health Diagnostic Laboratory, pers. comm. 2004 as cited 

in USDA 2004a). In addition, reversal agents, such as yohimbine, may be used to rouse the animal more 

quickly. Therefore, if a previously immobilized animal dies in the field sometime later, even if a 

scavenging animal were to ingest an entire animal previously immobilized, they should suffer no adverse 

effects (Dr. G. Gathright, DVM, APHIS-WS, National Wildlife Research Center, pers. comm. 2004 as 

cited in USDA 2004a). Furthermore, the scavenger would be consuming the animal by oral route, thus 

requiring a much larger dosage of the drug. Immobilizing drugs would produce carcasses that are not 

considered toxic to scavengers (USDA 2001b). If an animal must be euthanized, APHIS-WS personnel 

would remove it from the field immediately, thereby eliminating the chance of scavengers finding the 

carcass. Due to these factors, immobilizing drugs will have no adverse effect on scavengers or predators 

that consume previously immobilized animals. 

2.2.3 Potential for Adverse Impacts on Wildlife from Aircraft Overflights Conducted in ORV 

Programs.

An issue that has arisen is the potential for low-level flights associated with ORV bait distribution to 

disturb wildlife, including T&E species, to the point that they are impacted. APHIS-WS uses aircraft in 

ORV bait distribution, and these aircraft typically fly at about 500 feet above ground level (AGL) and in 

straight transects for many miles to distribute baits equally across the landscape. A number of studies have 

looked at responses of various wildlife species to aircraft overflights. The National Park Service (1995) 

reviewed studies on the effects of aircraft overflights on wildlife. The report revealed that a number of 

studies have documented responses by certain wildlife species that suggest adverse impacts could occur. 

Few, if any studies, have proven that aircraft overflights cause significant adverse impacts on wildlife 

populations, although the report stated it is possible to draw the conclusion that impacts to populations are 

occurring. The Air National Guard (ANG) concluded that military training flights which occur frequently 

and generate much more noise were not expected to cause adverse effects on wildlife after extensive review 

of numerous studies of this issue (ANG 1997a, 1997b). In general, it appears that the more serious 

potential impacts occur when overflights are frequent such as hourly and over long periods of time which 

represents a chronic exposure. Chronic exposure situations generally involve areas near commercial 

airports and military flight training facilities. WS ORV bait distribution operations occur over the 

landscape and occur in any given area only for a short time period. 

Several examples of wildlife species that have been studied with regard to low-level flights are available in 

the literature. Colonial waterbirds were reported that low level overflights of 2-3 minutes in duration by a 

fixed-wing airplane and a helicopter produced no drastic disturbance of tree-nesting colonial waterbirds, 
28 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

and, in 90% of the observations, the individual birds either showed no reaction or merely looked up 

(Kushlan 1979). Conomy et al. (1998) quantified behavioral responses of wintering American black ducks 

(Anas rubripes), American wigeon (A. americana), gadwall (A. strepera), and American green-winged teal 

(A. crecca carolinensis) exposed to low-level flying military aircraft in North Carolina and found that only 

a small percentage (2%) of the birds reacted to the disturbance. They concluded that such disturbance was 

not adversely affecting the time-activity budgets of the species. Mexican spotted owls (Delaney et al. 

1999) did not flush when chain saws and helicopters were greater than 110 yards away; owls flushed to 

these disturbances at closer distances and were more prone to flush from chain saws. Owls returned to their 

predisturbance behavior 10-15 minutes following the event and researchers observed no differences in nest 

or nestling success (Delaney et al. 1999). USFS (2002) found that Mexican spotted owls showed only 

minor behavioral changes to F-16 fly-bys during training runs, but less behavioral changes than to natural 

occurrences. Andersen et al. (1989) conducted low-level helicopter overflights directly at 35 red-tailed 

hawk (Buteo jamaicensis) nests and concluded their observations supported the hypothesis that red-tailed 

hawks habituate to low level flights during the nesting period; results showed similar nesting success 

between hawks subjected to such overflights and those that were not. White and Thurow (1985) did not 

evaluate the effects of aircraft overflights, but found that ferruginous hawks (B. regalis) are sensitive to 

certain types of ground-based human disturbance to the point that reproductive success may be adversely 

affected. However, military jets that flew low over the study area during training exercises did not appear 

to bother the hawks, and nor did the hawks get alarmed when the researchers flew within 100 feet in a 

small fixed-wing aircraft (White and Thurow 1985). White and Sherrod (1973) suggested that disturbance 

of raptors by aerial surveys with helicopters may be less than that caused by approaching nests on foot. 

Ellis (1981) reported that five species of hawks, two falcons (Falco spp.), and golden eagles (Aquila 

chrysaetos) were incredibly tolerant of overflights by military fighter jets, and observed that, although birds 

frequently exhibited alarm, negative responses were brief and the overflights never limited productivity. 

Krausman et al. (1986) reported that only 3 of 70 observed responses of mule deer to small fixed-wing 

aircraft overflights at 150 to 500 feet above ground resulted in the deer changing habitats. They believed 

that the deer may have been accustomed to overflights because the study area was near an interstate 

highway that was frequently followed by aircraft. VerCauteren and Hygnstrom (2002) noted that when 

studying the efficacy of hunting to manage deer populations, that when deer were flown over during their 

censuses, they typically just stood up from their beds, but did not flush. In addition, WS aerial hunting 

personnel frequently observe deer and antelope standing apparently undisturbed beneath or just off to one 

side of aircraft. Krausman and Hervert (1983) reported that, in 32 observations of the response of bighorn 

sheep to low-level flights by small fixed-wing aircraft, 60% resulted in no disturbance, 21% in slight 

disturbance, and 19% in great disturbance. Another study (Krausman et al. 1999) found that 14% of 

bighorn sheep had elevated heart rates that lasted up to 2 minutes after an F-16 flew over at an elevation of 

400 feet, but it did alter the behavior of penned bighorns. Weisenberger et al. (1996) found that desert 

bighorn sheep and mule deer had elevated heart rates for 1 to 3 minutes and changed behavior to alerted for 

up to 6 minutes following exposure to jet aircraft. Fancy (1982) reported that only 2 of 59 bison (Bison 

bison) groups showed any visible reaction to small fixed-wing aircraft flying at 200-500 feet above ground. 

These studies indicate that ungulates are relatively tolerant of aircraft overflights, even those that involve 

noise at high decibels. 

WS has actively used fixed-wing aircraft and some helicopters at low levels for years in areas inhabited by 

wildlife in operational wildlife damage management. No known problems to date have occurred from 

APHIS-WS aircraft overflights on wildlife and these were analyzed in detail in several APHIS WS predator 

damage management EAs (e.g., WS 2005, 2006 (CO, NM EAs). Overflights for the purposes of ORV bait 

distribution activities would only occur once or twice per year and aircraft would only fly quickly over any 

one point on the ground. The aircraft do not circle over areas repeatedly, but fly in straight “transect” lines 

for the purposes of bait distribution. The potential impact would be of short-term (only momentary) 

duration, on a local scale, with negligible intensity and should not add appreciably to the frequency of 

overflights. The addition of one more overflight per year for ORV bait distribution should not constitute a 

substantive increase in any effects that might occur as a result of overflights. Furthermore, the types of 

aircraft used in bait distribution, the DeHavilland (DHC-6) Twin Otter and Beechcraft King Air B200, meet 

all Federal Aviation Regulation (FAR) requirements regarding noise limits (FAR Part 36). No evidence 

has been found to indicate harm to nontarget wildlife including bald eagles. In addition, the annual 
29 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

overflight is even less likely to adversely impact migratory birds if flights occur in the fall after the birds 

have dispersed. Thus, the short-term duration, infrequency, and negligible intensity of flights over any 

given area, in addition to the tolerance of wildlife of such activity, indicates ORV program overflights 

would have a negligible adverse environmental impact on wildlife. Based on the above information and 

analysis, it is reasonable to conclude that APHIS-WS the ORV bait distribution program low-level flights 

should not cause any adverse impacts to nontarget wildlife including T&E species. Therefore, this issue 

will not be considered further. 

2.2.4 Potential for ORV Bait Distribution to Affect Organic Farming.

This issue concerns the potential for ORV baits dropped on crops and livestock operations certified as 

"organic" under federal regulations to affect the status of the organic certification of such farms. Farmers 

and livestock producers were concerned they would not be able to sell, label, or represent their harvested 

crop or plant as organically produced if it had contact with the prohibited substance, which is the vaccine – 

V-RG (7 CFR Part 205.672). The ORV baits are comprised of a matrix of dog food or fishmeal and an 

ethylene copolymer which is a plastic material. The purpose of the polymer is to hold the fishmeal 

attractant together in a block that can withstand being dropped from an airplane and not dissolve or crumble 

readily when exposed to rain or melting snow. The process for producing the bait blocks eliminates all 

potentially reactive compounds (such as ethylene and vinyl acetate) that might have the potential for uptake 

by plants or absorption into the tissues of animals that consume the baits. Thus, the inorganic polymer in 

the ORV baits is totally nonreactive and cannot be absorbed by plants or animals (M. Smith, Bait-Tek, pers. 

comm. 2001 as cited in USDA 2001a). It is also among the types of materials approved by the Food and 

Drug Administration for use in producing, manufacturing, packing, processing, preparing, treating, 

packaging, transporting, or holding food (21 CFR Part 177). Therefore, the fishmeal polymer baits pose no 

risk of contaminating crops or animals raised for food and, consequently, will have no effect on the ability 

of certified organic farms to maintain their status. 

On April 15, 2003, the USDA-Agricultural Marketing Service (AMS) ruled that ORV bait blocks, 

consisting of a recombinant vaccine imbedded in fishmeal bound by a polymer binding agent, on an 

organic operation would not have an adverse impact on organic operations (see USDA-AMS letter in 

Appendix G). This ruling is posted on the USDA-AMS website at www.ams.usda.gov/nop. The USDAAMS considers the ORV program to be an emergency disease treatment for the control of rabies and, as 

such, is addressed under National Organic Program (NOP) Section 205.672, Emergency Pest or Disease 

Treatment. The USDA-AMS determined that “...in the unlikely event that a bait block breaks and exposes 

a plant(s) to the vaccine, the organic producer can remove the affected plant(s) with no adverse effect on 

the operation’s certification. This would comply with NOP Section 205.672(a). The organic status of 

animals feeding on the ORV bait block and not penetrating the vaccine would not be adversely affected. In 

the unlikely event that an animal consumes the vaccine within the ORV bait block that animal would lose 

organic status as provided in NOP Section 205.672(b).” The USDA-AMS believes there to be little chance 

that an organic animal would consume the vaccine within an ORV bait block; however, to reduce the 

chances of livestock consumption, producers can relocate any bait found within an area containing 

livestock to a point outside of that area. 

Additionally, field baiting studies suggest deer are not generally attracted to the ORV baits. Out of more 

than 4,300 baits exposed to target and nontarget animals in field bait acceptance studies in Georgia, Ohio, 

and Texas, none were observed to have been taken or consumed by deer, despite the prevalence of deer in 

the areas where the bait studies were conducted (Linhart et al. unpublished 2001). Sulfur compounds are a 

byproduct of the breakdown of animal proteins, including those found in fishmeal (D. Nolte, APHIS-WS, 

NWRC, pers. comm. 2001 as cited in USDA 2001a) and are generally repellent to herbivores (Nolte et al. 

1994). Therefore, the ORV baits used to address coyote and raccoon rabies problems are probably at least 

somewhat repellent to deer, which probably accounts in part for the lack of observed bait take by deer in 

the studies reported in Linhart et al. (unpublished 2001). For these reasons, it is unlikely that the ORV 

baits would be consumed by deer on venison farms that are certified as organic producers. 
30 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

2.2.5 Potential for ORV to Cause Abortions in Cattle. 

This issue was raised by a cattle producer in Ohio who reported an increase in abortions of pregnant cows 

following an ORV bait distribution project. V-RG vaccine was tested in a number of wild and domestic 

animal species, including cattle, and produced no adverse effects (see Section 4.1.3.1). Although pregnant 

cattle have not been specifically tested, V-RG has produced no adverse effects on gestation in pregnant 

female raccoons (C. Rupprecht, CDC, pers. comm. to K. Smith, Ohio Dept. of Health 2001 as cited in 

USDA 2001a). Recently, a woman who was 18 weeks pregnant in Ohio was exposed to the vaccine when 

she took a bait away from her dog and later delivered a healthy baby (see Section 4.1.1.2). ORV program 

administrators with the TDSHS have not received any other reports of this nature despite the distribution of 

millions of ORV baits in cattle and other livestock production areas since 1995 (E. Oertli, TX Dept. of 

Health, pers. comm. 2001 as cited in USDA 2001a). In the U.S., approximately 43.75 million doses of VRG have been distributed by APHIS-WS to date without any other reported concerns of this nature being 

raised. Therefore, the reported increase in cattle abortions was determined to be coincidental and not 

related to ORV. The Ohio producer was provided with further information and advice on determining 

which of a number of other known possible causes of abortions in cattle might be responsible (R. Hale, 

Ohio Dept. of Health, pers. comm. 2001 as cited in USDA 2001a). 

New vaccines may be considered for future use by the APHIS-WS ORV program and any environmental 

effects of the new vaccines on cattle not analyzed in this EA will be appropriately evaluated in further 

environmental documentation. 

2.2.6 Potential Human Health Impacts in the Event of Human Consumption of Vaccinated 

Wildlife.

The issue expressed here is the potential to develop a vaccinia infection from eating a vaccinated raccoon 

or some other animal that has eaten one or more ORV baits. Dr. Carolin Schumacher of MERIAL, Inc. 

was consulted to obtain information on this issue. Mahnel (1987) reported results of experiments to 

determine the stability of poxviruses (which include vaccinia used in the V-RG vaccine). “Naked” vaccinia 

(i.e., vaccinia found outside of host cells) will be inactivated within minutes by heat above 133 degrees 

Fahrenheit (56 degrees Celsius), by ultra-violet irradiation (sunlight), or by exposure to acid with a pH of 3 

or less5

 (e.g., similar to the acid environment found in the stomach of raccoons which is where the bulk of 

V-RG vaccine would end up). In contrast, poxviruses can be relatively stable for years in dry dust or in 

dried lesion crusts. 

The vaccinia from V-RG generally only binds to animal tissues in the mucous membrane of the oral cavity, 

pharynx and esophagus since V-RG does not have the tendency to spread throughout the animal. Those 

particular tissues are rarely consumed by humans, but if they were, they would most likely be cooked 

which would kill the virus. Also, concentrations of vaccinia in those tissues should be low because mucosa 

is not considered a tissue where the virus tends to accumulate (C. Schumacher, MERIAL, Inc., pers. comm. 

2001 as cited in USDA 2001a) as the virus infects the cells of the oral cavity, produces the glycoprotein, 

and then dies (J. Maki, MERIAL, Inc., pers. comm. 2009). 

Although cell-bound vaccinia is generally more resistant than free virus, humidity and cellular enzyme 

activity in the tissues as well as bacterial decomposition (e.g., in the gut of ruminants), normally results in 

inactivation of the virus. In the environment, inactivation of pox viruses is accelerated by temperature 

changes (C. Schumacher, MERIAL, Inc., pers. comm. 2001 as cited in USDA 2001a). 

The above information suggests that possible sources of contamination with vaccinia would be V-RG dried 

onto the fur of an animal, ingested virus in the stomach, or cell-bound virus in mucous membranes. 

However, with the combined activity of sunlight and ultraviolet light, humidity, stomach pH or bacteria, 

enzymes, temperature fluctuations, and cooking heat, the risk to human health should be low, especially 

when taking into consideration the attenuated or weakened condition of the vaccinia in the V-RG vaccine. 

 

5 pH is the measure of acidity or alkalinity of a solution with numbers below 7 representing a progressively more acidic solution. A 

pH of 3 is highly acidic.
31 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Therefore, the potential for adverse health effects from consuming animals that have eaten ORV baits 

should be negligible. 

New vaccines may be considered for future use by the APHIS-WS ORV program and any environmental 

effects of the new vaccines on humans who consume vaccinated wildlife not analyzed in this EA will be 

appropriately evaluated in further environmental documentation. 

2.2.7 Potential Impacts on Water Resources, including Aquaculture, Fish, Reptiles, and 

Amphibians. 

A concern has been expressed regarding the potential impacts of unconsumed V-RG vaccine and baits 

adversely impacting ground and surface water resources and aquaculture through direct and indirect 

exposure. Baits that are not consumed may remain in the environment for several months after placement, 

which is dependent upon environmental conditions (precipitation, temperature, etc.) and the physical 

condition of the baits. Potential impacts to water resources are greatly reduced by the limited number of 

baits that are dropped in a specific area, the biodegradability of the vaccine liquid and baits, the high 

consumption rate of ORV baits by animals, the safety and efficacy of the vaccine, and the Standard 

Operating Procedures (SOPs) that are used when dropping baits near a large water source. This conclusion 

is based upon: 

 The possibility of a large quantity of ORV baits being exposed to a specific water resource is 

extremely low due to the bait distribution densities used by the program. Under the proposed program, 

ORV baits would be distributed from aircraft at an average density of 75 baits per km2 for raccoons in 

the eastern U.S., 39 baits per km2

 for gray foxes in Texas, and 27 baits per km2 for coyotes in Texas. 

 The baits are non-toxic. The baits used for the ORV program are small blocks of either dog food or 

fishmeal that are held together with a polymer binding agent and are considered to be “food grade” 

materials. Therefore, the unconsumed bait material would biodegrade when exposed to the 

environment causing little to no effect on water resources. 

 The vaccinia virus and other orthopoxviruses will not replicate in water and do not replicate or 

reproduce themselves in non-warmblooded species (Rupprecht, CDC, pers. comm. 2002 as cited in 

USDA 2003a). Therefore, ORV is not expected to cause any adverse effects on fish, reptiles, 

amphibians, or any invertebrate species should any members of these species groups consume ORV 

baits or otherwise be exposed to the vaccine. 

 The ORV baits are readily taken up and consumed by animals, thereby limiting long term exposure to 

the environment. The likelihood of a bait being consumed is dependent upon several factors including 

animal population densities (target and non-target species), bait preference, and the availability of 

alternative food sources. In field tests conducted in the U.S., the majority of ORV baits have been 

consumed within the first 7 to 14 days after placement, with reports of up to 100 percent of the baits 

being consumed within a 7 day period (Farry et al. 1998b, Hable et al. 1992, Hadidian et al. 1989, 

Hanlon et al. 1989a, Linhart et al. 1994, Steelman et al. 2000; USDA 1995a). 

The V-RG virus biodegrades when exposed to the environment. The V-RG virus that is not consumed by 

the target species or other vertebrates will become inactivated over a relatively short period of time. 

Persistence and stability of the V-RG virus outside of an organism is highly dependent on ambient 

temperature and local environmental conditions; the higher the temperature, the quicker the virus becomes 

inactive (USDA 1992; USDA 1995a). For example at temperatures of 68 and 100 degrees Fahrenheit (20 

and 37.8 Celsius), the liquid vaccine potency remains stable for approximately 14 to 7 days, respectively, in 

the un-punctured sachet or inside the bait. In situations where the bait and sachet are damaged inactivation 

of the V-RG virus will occur more rapidly. A more detailed discussion of the development of ORV baits 

can be found in Chapter 1. 

Program SOPs limit the possibility of ORV baits being directly dropped into large water sources such as 

rivers, lakes, and reservoirs. When the aircraft approaches a large body of water the bait dropping 
32 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

equipment is shut off approximately 0.25 mile from the water source to reduce the possibility of ORV baits 

falling into the water. Nevertheless, due to changing environmental conditions and the limited possibility 

of human error when operating the bait dropping equipment, there is the possibility that baits may 

inadvertently be dropped into a body of water. Exposure of the V-RG vaccine into a water source from an 

intact bait and sachet is highly unlikely. The vaccine is enclosed in a sealed sachet thereby limiting the 

possibility of the vaccine liquid being directly released into a water source. Even if the vaccine was 

released into a water source through a damaged or punctured sachet, it is highly unlikely that the vaccine 

would cause any adverse effects since the vaccine liquid is biodegradable and nontoxic (USDA 1991; 

USDA undated a, undated b). 

The above information indicates that V-RG vaccine and baits pose no threat to groundwater or surface 

water through direct or indirect means. New vaccines may be considered for future use by the APHIS-WS 

ORV program and any environmental effects of the new vaccines on water resources not analyzed in this 

EA will be appropriately evaluated in further environmental documentation. 

2.2.8 Effects on Carnivore Populations in the Absence of Rabies. 

Concern has been expressed that specific carnivore populations, namely raccoons, may increase in the 

absence of the rabies virus as a mortality factor, leading to adverse effects on prey populations such as T&E 

species. The raccoon strain of the rabies virus has only relatively recently spread, and is contiguously 

distributed from Alabama to Maine, west to the eastern Ohio border with Pennsylvania (Krebs et al. 2000, 

Kemere et al. 2001). Translocation of rabid raccoons to the mid-Atlantic states has been implicated in 

establishing a new rabies foci in the mid-1970’s (Krebs et al. 1999), from which rabies has spread through 

the raccoon population at rates averaging about 30 miles/year (48.3 km/year) (Kemere et al. 2001). 

Rabies is only one of several diseases that may help regulate carnivore populations. In fact, the article by 

Guerra et al. (2003) does not support the idea that rabies exists specifically to control raccoon populations. 

Guerra et al. (2003) state that after an initial peak, populations approach lower ‘steady-state’ conditions. 

Based on surveillance data, raccoon rabies did not exist outside a focus in Florida before the 1940s. 

Therefore, elimination of raccoon rabies should merely create the scenario before raccoon rabies spread in 

the eastern U.S. (Rupprecht and Smith 1994). No evidence exists that the carrying capacity for raccoons 

could be increased by the implementation of ORV programs compared to population levels before the 

introduction of rabies (C. Rupprecht, CDC, pers. comm. 2003 as cited in USDA 2004a). 

Prior to the introduction of raccoon rabies into the mid-Atlantic region in the late 1970’s, canine distemper 

was considered a primary disease mortality factor in raccoons, gray foxes, and skunks (Roscoe 1993, 

Davidson et al. 1992). The epizootiology of canine distemper in raccoons in New Jersey and Florida has 

been characterized by outbreaks at the end of the mating season in March and with increased movements of 

young in September (Roscoe 1993, Hoff et al. 1974). Because of the cyclic nature of canine distemper 

outbreaks (4 year intervals), the wide distribution of canine distemper cases, and the low incidence of the 

disease between epizootic peaks in New Jersey, Roscoe (1993) proposed an enzootic status for canine 

distemper for raccoons that becomes epizootic when raccoon densities reach high levels. Evans (1982) 

found that 50 to 90 percent of raccoons and gray foxes may be incapable of producing protective levels of 

antibodies against the canine distemper virus, implicating it as a potentially important disease mortality 

factor. Davidson et al. (1992) diagnosed canine distemper in 78 percent of gray foxes studied in the 

southeastern U.S. and found canine distemper to be more significant as a mortality factor for gray foxes 

than all other infectious and noninfectious diseases combined. Roscoe (1993) reported that the effects of 

canine distemper on raccoon populations may diminish if raccoon rabies spreads and that concurrent canine 

distemper and rabies epizootics may become more common. The dynamics of sympatric rabies and canine 

distemper are not well understood; however, rabies may compensate for deaths that would have historically 

occurred due to canine distemper infection. Important attributes of canine distemper include that it is not a 

zoonotic disease like rabies and, historically, it has been implicated as a virus of importance to carnivore 

mortality. 
33 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

2.2.9 The Affected Area Described in the EA includes Lands that Have Not Been Identified as 

Having a Rabid Raccoon Problem. 

The affected area of the EA includes some lands that have or have the potential for a raccoon, coyote, and 

gray fox rabies outbreak to occur. ORV baits are distributed based upon vaccination zones. These 

vaccination zones are determined in cooperation with the involved state rabies task forces, state agencies, 

or other agencies with jurisdiction over vaccine use and application in wildlife and domestic animal 

species. Vaccination zones are delineated based on the most current distribution of rabies cases and the 

expected direction of disease spread. Therefore, some, all, or none of the lands, including National Forest 

System and BLM lands, identified in this EA may be involved in an ORV bait distribution program on an 

annual basis. Figures 1-6 and 1-7 in Chapter 1 show the current anticipated ORV zone based upon recent 

outbreaks of the virus. The states and National Forest System and BLM lands included in this EA were 

chosen since they have the greatest possibility of being involved in the overall efforts of stopping the 

northward and westward spread of the raccoon rabies virus in the eastern U.S., the northward expansion of 

coyote and gray fox rabies in Texas, and outbreaks of rabies in New Mexico and Arizona. 

2.2.10 Effects of Nontarget Species Consumption of ORV Baits on Program Effectiveness 

Consumption of ORV baits by nontarget species is not expected to impact program effectiveness. As 

described in Section 1.1.5, baits are developed to attract target species. The use of target-preferred baits 

increases the likelihood of the target species consuming the baits prior to the discovery of baits by 

nontarget species. Furthermore, bait distribution densities are developed to compensate for the uptake of 

baits by nontarget species. Baits are distributed at densities that allow raccoons, gray foxes, and coyotes 

the opportunity to find intact baits. It has been determined, based upon the success of previous ORV bait 

distribution activities, that baits should be disbursed at an average density of 27 baits per km2

 in the coyote 

rabies zone and 39 baits per km2

 in the gray fox rabies zone in Texas. Baiting density averages 75 baits per 

km2 in eastern states where raccoon rabies is targeted. In addition, surveillance activities have been and 

continue to be conducted to assess aerial or ground ORV baiting efficacy, summer versus fall baiting 

schedules, and seasonal raccoon movement in a number of states. Numerous density studies also continue 

to be conducted in the majority of participating states to determine raccoon densities in relation to habitat, 

elevation, and numbers of baits distributed. In areas where raccoon densities are low, bait distribution 

numbers may be reduced (USDA 2008a, 2008b). 

2.2.11 Effects of Global Warming, Habitat Loss, and Pollution on Wildlife Populations 

A concern has arisen that APHIS-WS fails to look at a variety of factors such as global warming, habitat 

loss, and pollution on wildlife populations under cumulative impacts to species where APHIS-WS lethally 

takes species. APHIS-WS acknowledges that many factors influence wildlife population levels including 

these and predation, inter- and intra-specific competition especially with invasive species, stochastic events 

such as hurricanes, tornadoes, earthquakes, floods, wild fires, and extreme climatic conditions such as 

extended drought and exceptionally hard winters. Wilcove et al. (1999) assessed the causes of extinction 

by looking at causes listed in T&E species USFWS recovery plans for vertebrates (n=1,880) and, not 

surprisingly, found that endangerment of species was caused, often by a combination of factors, but mostly 

included habitat degradation (85%), invasive species (49%), pollution (24%), overexploitation (17%), and 

disease (3%) as the leading causes of endangerment. Global warming is a relatively recent concern, but it 

is thought that it will cause a loss of 25% of the species on earth by 2050; the first victim of global 

warming is believed to be the Lemur-like ringtail possum (Hemibelideus lemuroides) of Australia due to 

excessive extended temperatures. It is assumed that global warming will increase some species’ range 

while shrinking others such as the polar bear (Thalarctos maritimus) which was listed as threatened under 

the ESA in 2008. In the listing it was stated that global warming was the causative agent for their listing, 

essentially due to a reduction in habitat from melting arctic ice floes. The then Secretary of Interior Dirk 

Kempthorne stated, “While the legal standards under the ESA compel me to list the polar bear as 

threatened, I want to make clear that this listing will not stop global climate change or prevent any sea ice 

from melting. Any real solution requires action by all major economies for it to be effective. That is why I 

am taking administrative and regulatory action to make certain the ESA isn't abused to make global 
34 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

warming policies." Thus, at this point, global warming changes are going to occur, part of the 

environmental status quo, unless a world-wide effort is conducted to reduce the causative agents. 

APHIS-WS is concerned that cumulative impacts to species from these factors are a concern, but feel that 

these are analyzed under the different alternatives. These factors can contribute greatly to species 

abundance and distribution, and have been a major factor in declines and increases in species abundance in 

the past and into the future. However, WS uses the best available information to determine the status of 

different species’ populations. Often, State wildlife agencies provide APHIS-WS with population 

estimates or trends to determine impacts. However, these factors would be consistent under all of the 

alternatives. The best information on these populations, which include the effects of these environmental 

pressures, is used in the analysis to determine impacts of lethal take on these species. Thus, we believe 

these outside forces are included in the analysis of impacts in Chapter 4 and that currently no data exists to 

quantify losses to such events. However, APHIS-WS will monitor such events and take appropriate actions 

to minimize further impacts if necessary in an Adaptive Management approach. 

2.3 AFFECTED ENVIRONMENT

This section presents some descriptive information on the environment of the areas that may be affected by 

the proposed action. Other descriptive aspects of the affected environment are included in Chapter 4 in the 

analysis of effects which is based on environmental and other types of issues identified in Section 2.1. 

The area of the proposed action encompasses 25 eastern states and the District of Columbia and National 

Forest System and BLM lands, but excluding Wilderness Areas, where raccoon rabies outbreaks currently 

or are expected to occur and Texas where gray fox and coyote rabies strains occur. Additionally, due to the 

recent spread of gray fox variant rabies west of the original ORV zone in Texas toward the New Mexico 

border with a possible host shift from gray foxes to coyotes and an ongoing outbreak of gray fox variant 

rabies in western New Mexico and eastern Arizona, program activities will be expanded to include New 

Mexico and Arizona. New Mexico and Arizona would participate in and assist with the ORV program to 

control gray fox variant rabies. APHIS-WS involvement would therefore be continued or expanded 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 of the aforementioned states. Currently, cooperative rabies surveillance activities are 

conducted in most of the aforementioned states and would likely be expanded to include all listed states. 

The potential areas involved in the ORV program are extensive and may cover several land ownership 

types and diverse land uses, including cultivated agricultural lands, forests, meadows, wetlands, rangelands, 

and pastures. Aerial distribution of ORV baits would avoid urban and suburban areas that support high 

human population densities, as well as lakes, rivers, and Wilderness Areas. Aerial distribution of baits 

would primarily target rural areas as well as known areas of habitat suitable for the target species. When 

aerial distribution by fixed-wing or helicopter aircraft is not practical, baits would be distributed by careful 

hand placement to help to minimize contact by humans, pets, and other domestic animals. 

Figure 1-5 in Chapter 1 shows the states and Appendices I and J show the National Forest System and 

BLM lands where APHIS-WS would continue or expand assistance to and participation in ORV programs 

under the proposed action. Figures 1-6 and 1-7 in Chapter 1 show the approximate ORV bait disbursal 

areas anticipated for 2009 and beyond. It must be kept in mind, however, that ORV baiting activities might 

be needed, and might therefore be conducted, in other areas within the involved states, or on other National 

Forest System and BLM lands, as part of the proposed action. In addition, the ORV bait disbursal areas 

would be the primary expected areas where assistance by APHIS-WS is expected to be requested to collect 

blood, tooth, and other biological samples from target animals for monitoring and surveillance. However, 

monitoring or surveillance activities by APHIS-WS could also occur anywhere in the respective states 

where state health or other appropriate agency officials determine there is a need to insure project 

effectiveness. Implementation of emergency response and contingency action plans that involve localized 

population suppression of target species could similarly be needed anywhere in the involved states where 
35 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

outbreaks of the targeted rabies strains occur. Furthermore, changes in funding levels over time could 

create changes in ORV program activities, such as increasing or decreasing the size of the ORV barrier 

zone and other areas to be baited and varying the types of monitoring and surveillance and research 

conducted. 

“Major Habitat Types” as described by Ricketts et al. (1999) that are found within the proposed project 

locations are: Temperate Broadleaf and Mixed Forests (AL, DE, GA, IN, KY, LA, ME, MD, MI, MS, NH, 

NJ, NY, NC, OH, PA, RI, SC, TN, VT, VA, WV), Temperate Coniferous Forests (AL, AZ, FL, GA, LA, 

MS, NM, NC, SC), Flooded Grassland (FL), Mississippi Riverine Forests (TN, KY), Temperate 

Grasslands/Savannah/Shrub (IN, LA, NM, TX), and Xeric Shrublands/Deserts (AZ, NM, TX). Appendix E 

shows the “ecoregions” (i.e., broad level ecosystems) that occur in the potentially affected states (Bailey 

1995). Ecoregions range from dry desert and grassland-shrub communities in Texas, to humid tropical 

areas and southern pine and hardwood forest areas in the Southeast, to broadleaf deciduous forest, mixeddeciduous forest and coniferous forest, and boreal forest types in the East and Northeast. 

Table 2-1 (USDC 2001, 2008) shows some descriptive statistics for the 28 states and District of Columbia 

proposed for federal assistance by APHIS-WS in ORV programs. These states contain about 66.7 percent 

of the U.S. resident population and possess average state population densities that range from about 16.1 

(New Mexico) to nearly 9,471 (District of Columbia) people per mi2

. Rural area (i.e., nondeveloped) 

averages 80.8 percent for the 28 states, ranging from approximately 56.2 percent in Arizona to almost 94.7 

percent in Maine. Population densities in rural areas are much lower than the statewide average figures 

shown. The percentage of federal land in each state ranges from 0.4 percent in Connecticut and Rhode 

Island to 48.1 percent in Arizona and averages 11.9 percent of the total area of affected states. 

A number of federally and state recognized American Indian Tribes are located in the states included in the 

proposed action and are shown in Appendix F. State agencies that conduct ORV programs involving the 

use of APHIS-WS funds or assistance would be responsible for obtaining agreements as appropriate from 

Tribes to conduct baiting. 

Chapter 4 contains further information on the affected environment with respect to target and nontarget 

species including T&E species. 
36 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Table 2-1. Some Descriptive Statistics of States Proposed for Federal Assistance by APHIS-WS ORV Programs

(data from USDC 2001, 2008) 

State Resident 

population 

(1000s) from 

2006 

Population 

per sq mile 

from 2006 

% popn. in 

nonmetropolitan areas 

from 2006 

Popn. of 

nonmetropolitan areas 

(1000s) from 

2000 

Total area 

(1000 acres) 

from 1997 

and 2004 

Developed 

area (1000 

acres) from 

1997 

Rural area 

(1000 

acres) from 

1997 

% rural 

area 

from 

1997 

Land in 

farms (mil. 

acres) from 

2006 

Z<500,000 

acres 

National 

Forest Land 

(1000 acres) 

from 1999 

Total area owned 

by federal govt. 

(1000 acres) 

from 2004 

% area owned

federalgovt. 

from 2004 

AL 4,599 90.6 29.1% 1,338 32,678 3,728 28,950 88.6% 9 665 514 1.6% 

CT 3,505 723.4 4.3% 149 3,135 957 2,178 69.5% Z 0 14 0.4% 

DE 853 436.9 18.4% 157 1,266 278 988 78.0% 1 0 26 2.0% 

DC 582 9,471.2 0% 0 39 -- -- -- Z 0 10 24.7% 

FL 18,090 335.5 6.3% 1,145 34,721 9,223 25,498 73.4% 10 1,147 2,859 8.2% 

GA 9,364 161.7 26.9% 2,520 37,295 6,647 30,648 82.2% 11 865 1,409 3.8% 

IN 6,314 176.0 26.8% 1,691 23,158 3,089 20,069 86.7% 15 196 463 2.0% 

KY 4,206 105.9 49.2% 2,069 25,512 3,185 22,327 87.5% 14 693 1,379 5.4% 

LA 4,288 98.4 25.6% 1,099 28,868 4,204 24,664 85.4% 8 604 1,475 5.1% 

ME 1,322 42.8 61.1% 808 19,848 1,054 18,794 94.7% 1 53 2,080 1.1% 

MD 5,616 574.6 6.9% 385 6,319 1,511 4,808 76.1% 2 0 179 2.8% 

MA 6,437 821.1 4.1% 261 5,035 1,641 3,394 67.4% 1 0 94 1.9% 

MI 10,096 177.7 17.5% 1,769 36,492 7,066 29,426 80.6% 10 2,857 3,638 10.0% 

MS 2,911 62.0 62.6% 1,821 30,223 3,794 26,429 87.4% 11 1,159 2,197 7.3% 

NH 1,315 146.6 37.7% 496 5,769 1,416 4,353 75.5% Z 827 776 13.4% 

NJ 8,725 1,176.2 0.0% 0 4,813 2,037 2,766 57.5% 1 0 148 3.1% 

NY 19,306 408.9 7.8% 1,503 30,681 3,979 26,702 87.0% 8 0 234 0.8% 

NC 8,857 181.8 29.5% 2,612 31,403 6,811 24,592 78.3% 9 1,244 3,710 11.8% 

OH 11,478 280.3 18.6% 2,139 26,222 4,152 22,070 84.2% 14 229 448 1.7% 

PA 12,441 277.6 15.2% 1,890 28,804 4,988 23,816 82.7% 8 513 720 2.5% 

RI 1,068 1021.7 5.8% 62 677 219 458 67.7% Z 0 3 0.4% 

SC 4,321 143.5 27.9% 1,205 19,374 3,356 16,018 82.7% 5 613 561 2.9% 

TN 6,039 146.5 30.3% 1,827 26,728 4,131 22,597 84.5% 11 634 866 3.2% 

VT 624 67.5 70.4% 439 5,937 754 5,183 87.3% 1 368 443 7.5% 

VA 7,643 193.0 20.3% 1,550 25,694 5,808 19,886 77.4% 9 1,659 2,534 9.9% 

WV 1,818 75.5 57.4% 1,043 15,411 2,159 13,252 86.0% 4 1,033 1,146 7.4% 

 

AZ 6,166 54.3 98.0% 604 72,688 31,830 40,858 56.2% 26 11,255 34,933 48.1% 

NM 1,955 16.1 40.1% 784 77,766 27,695 50,071 64.4% 45 9,327 32,484 41.8 

TX 23,508 89.8 13.4% 3,160 168,218 12,688 155,530 92.5% 130 755 3,130 1.9% 

Total 199,447 16,957.1 17.3% 34,526 824,774 158,400 666,325 80.8% 364 36,696 98,473 11.9% 

U.S. 299,398 84.6 18.5% 55,453 2,271,343 879,245 1,392,098 61.3% 943 191,910 653,299 28.8% 
37 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

CHAPTER 3: ALTERNATIVES 

3.1 ALTERNATIVES CONSIDERED, INCLUDING THE PROPOSED ACTION

Alternative 1. Current Action (the No Action Alternative). The “No Action” alternative is a procedural 

NEPA requirement (40 CFR 1502.14(d)), 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 practices (CEQ 1981). 

This alternative would involve the continued or 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 of the several states listed in Section 1.2, not including New Mexico and 

Arizona, 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 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 1 (Proposed Action) to include additional area 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 contingency actions as part of the ORV 

program; however, it did not address trap-vaccinate-release as one of them. This new proposed action 

better defines and identifies the types of contingency actions that may be used as part of the ORV program. 

(See page 14 for a description of the contingency actions.) 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 of the 

several states listed in Section 1.2, 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 of one or more of the five state contingency actions as 

described in Section 1.2.1 if rabies outbreaks occur beyond the designated ORV vaccination barriers to stop 

such outbreaks from spreading. 

Alternative 3. Live-Capture-Vaccinate-Release Alternative. This alternative would involve the live 

capture of species being targeted (e.g., raccoon, gray fox, coyotes) followed by administration of rabies 

vaccines by injection and release back into the wild. This strategy has been used in certain localized areas 

for reducing the incidence and spread of rabies in raccoons (Brown and Rupprecht 1990, Rosatte et al. 

1990, Rosatte et al. 1992, Rosatte et al. 1993) and skunks (Rosatte et al. 1990, Rosatte et al. 1992, Rosatte 

et al. 1993). This method has not been attempted for vaccination of foxes and coyotes because they are 

much more difficult to capture in cage traps (Baker and Timm 1998). In addition, the use of other traps 

such as leghold traps and snares, for foxes and coyotes has shown to be problematic in capturing and 

releasing a large enough population (Rosatte et al. 1993; C. MacInnes, Ontario Ministry of Natural 

Resources pers. comm. 2001 as cited in USDA 2001a; personal observation of APHIS-WS personnel). 

Currently, no vaccine is specifically licensed for this type of use (CDC 2000). However, certain injectable 

vaccines may be used “off-label” under the direction of veterinarians to vaccinate wild animal species in 

certain situations (J. Mitzel, APHIS-Veterinary Services, pers. comm. 2001 as cited in USDA 2001a). This 

method generally results in a higher percentage of a raccoon population being vaccinated than ORV, but 

takes much longer to accomplish in a given area. For example, in Ontario, 7 trappers working from July to 

October were required to trap and vaccinate 50-85 percent of the raccoons in an area less than 700 km.2 

(270.3 mi2), whereas the same area could have been treated with aerially dropped ORV baits in half a day 

(C. MacInnes, Ontario Ministry of Natural Resources, pers. comm. 2001, as cited in USDA 2001a). 

Alternative 4. No Animal Surveillance or Monitoring or Lethal Removal Programs Alternative. 

Under this alternative, APHIS-WS would provide resources for and assistance in ORV bait distribution 
38 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

only and would not engage in or provide funds for the collection of wild 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 without APHIS-WS 

assistance. 

Alternative 5. No Federal ORV Program. This alternative would imply no involvement by APHIS-WS 

in rabies prevention or control in the states identified in Section 1.2. 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. 

3.2 ALTERNATIVES CONSIDERED, BUT NOT IN DETAIL WITH RATIONALE 

3.2.1 Depopulation of Target Species.

This alternative would result in the lethal removal of raccoons (in the eastern states listed) and gray foxes 

and coyotes (in Arizona, New Mexico, and Texas) throughout the zones where outbreaks of the targeted 

strains of rabies are occurring or are expected to occur. The goal would be to achieve elimination of the 

rabies strains by severely suppressing populations of the target animal species over broad areas so that the 

specific strains of rabies could not be transmitted to susceptible members of the same species. This could 

theoretically stop the forward advance of the disease and potentially result in elimination of the particular 

rabies variants as infected animals die from rabies before they could transmit it to other members of the 

same species. 

Localized population reduction has been proposed as part of local programs to address raccoon rabies 

outbreaks as they are just beginning (Rosatte et al. 1997). This was deemed necessary because by the time 

a suspected rabies case is confirmed through animal testing, other raccoons in the area have invariably been 

infected and are incubating the disease, at which point vaccination would not be effective for those 

individuals (Rosatte et al. 1997). 

Population reduction is often suggested as a method to control rabies in wildlife populations since the 

disease is density dependent (Debbie 1991). Bounty incentives, regulated hunting and trapping, ingestible 

poisons, and fumigation of dens have all been employed to control populations with varying levels of 

success. MacInnes (1998) reviewed some of the past efforts to control rabies with population reduction of 

carrier species and concluded that, with a couple of exceptions, most such efforts have failed. In some of 

the situations, it could not be determined whether an observed decline or disappearance of rabies cases was 

attributable to population control or to the disease simply reaching some unexplainable geographical 

limitation or just dying out on its own (MacInnes 1998). Also, population control as a strategy can be 

questionable because the leading edges of rabies outbreaks do not necessarily coincide with the edge of the 

range of the principal “vectors” (e.g., raccoons, gray foxes, and coyotes), nor are they always related to the 

population density of such vectors (MacInnes 1998). 

Hanlon et al. (1999) reviewed historical efforts to control rabies through population reduction and 

evaluated the potential for success with this strategy. Information and conclusions they presented are 

summarized as follows: 

Skunk rabies was successfully controlled in Alberta, Canada by population reduction (Pybus 1988). 

Success was attributed to a high level of effort during several years, the well-defined behavior of skunks in 

prairie habitats, and access to an effective method (Pybus 1988). Compensatory changes in carnivore 

reproduction (i.e., the tendency for larger litters and larger percentages of adult females to have litters) and 

dispersal (i.e., immigration of animals from surrounding uncontrolled populations) can limit the 

effectiveness of controlling population numbers of other species in different conditions (Clark and Fritzell 

1992, Thompson and Fleming 1994). 

Population reduction with toxicants as a broad scale control alternative for rabies is impractical. The only 

approved toxicants currently registered are sodium cyanide in the M-44 device (registered for zoonotic 

disease control involving wild canids), and carbon monoxide-producing gas cartridges that can be used to 
39 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

kill skunks, coyotes, and red foxes in dens. Currently, these methods are primarily used in limited areas of 

the western U.S. for livestock protection. Presently, population reduction is most likely to be publicly 

accepted and effective in localized or site-specific scenarios in the U.S. (e.g., reducing the density of 

raccoon populations in parks where visitors could potentially come into contact with rabid animals). 

Population reduction using strychnine baits was successful in stopping the spread of rabies in foxes in 

Denmark (Gaede 1992). However, carcass recovery statistics indicated nontarget species [498 martens 

(Martes sp.), twelve European badgers (Meles meles), and four domestic dogs] were killed in slightly 

greater numbers than the targeted red foxes (n=482). The number of rabies cases declined sharply and the 

country has reportedly remained free of terrestrial rabies since 1982 (Gaede 1992). Broad scale population 

control with toxicants is most likely politically infeasible in the U.S. due to opposition by the public and 

state wildlife agencies. 

This alternative was not considered in detail because it would be impractical to obtain approval from the 

many hundreds of thousands 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 the high level of effort must be maintained almost indefinitely and would also undoubtedly be 

opposed by most members of the public (MacInnes 1998). Population suppression can be a challenge to 

maintain in many situations due to immigration (of other members of the same species from surrounding 

populations) and possibly compensatory reproduction (i.e., larger litters and greater percentages of females 

breeding following population reduction) (Clark and Fritzell 1992, Connolly and Longhurst 1975). These 

factors can mean local populations can recover to their previous levels within a year, thus requiring annual 

or more frequent suppression efforts to maintain such populations at low levels. Nevertheless, temporary 

localized population suppression activities could be conducted in an integrated program of ORV use as part 

of the proposed action, but such activities, if conducted at all, would be expected to occur as a part of 

contingency actions in response to a breach in a vaccination barrier. APHIS-WS has covered predator 

removal including to control disease, but mostly to resolve damage associated with them to resources such 

as livestock, in other EAs for Texas, New Mexico, and Arizona (Predator Damage Management EAs) and 

some eastern states for raccoons (APHIS-WS EAs can be found @ 

http://www.aphis.usda.gov/wildlife_damage/ nepa.shtml). 

3.2.2 Population Control through Birth Control

Under this alternative, APHIS-WS would provide funds or operational assistance to implement one or more 

methods to control populations of the target species by reducing reproduction. Such methods could involve 

live capture and surgical sterilization [reviewed by Kennelly and Converse (1997)], the use of chemical 

reproductive inhibitors placed out in baits or delivery devices (Balser 1964, Linhart et al. 1968), or the 

application of immunocontraception strategies (i.e., vaccines that can cause infertility in treated animals). 

The suppression of reproduction over time would eventually reduce the size of target species populations 

and lead to a reduction in the potential for the spread of rabies by reducing the chances of contact between 

infected and healthy animals. However, this approach would do nothing immediately in the short term to 

reduce the risk of rabies spread in the existing populations, since those animals would continue to be 

present and capable of contracting and passing on the disease. Therefore, this type of strategy would be 

viewed as a long-term remedy for stopping rabies spread. It would probably not be useful in meeting the 

immediate needs for stopping a localized outbreak of rabies that occurs beyond designated ORV baiting 

zones. 

Live capture and surgical sterilization of whole local populations of animals would be extremely expensive, 

time-consuming, and difficult to achieve. Considerable expense would be involved in employing 

experienced and qualified veterinarians to perform large numbers of surgical procedures on captured 

animals. From a rabies control standpoint, if all or nearly all of a local population could be live captured, it 

would be more effective and less costly to administer rabies vaccinations by injection, which is already 

considered as Alternative 3. 

Immunocontraception is a potentially useful concept for mammalian population suppression but is still in 
40 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

the early stages of research and development (Bradley 1995, Miller 1997). Genetically engineered 

vaccines that cause a target species to produce antibodies against its own sperm or eggs or that affect 

reproductive hormone functions have been produced (Miller 1997). Several logistical concerns still would 

need to be addressed before this method could be applied successfully in the field. These concerns include: 

1) durability of the contraceptive vaccines in baits after distribution in the field; and 2) the limitation of 

some current vaccine designs that require baiting an animal population twice about one month apart to 

successfully treat individual wild animals (Miller 1997). Furthermore, it is likely that a greater proportion 

of the population would have to be treated with contraceptive vaccines than with rabies vaccines in order to 

achieve effective rabies control. Thus, achieving effective control would be more costly and difficult under 

this alternative than under ORV programs (C. MacInnes, Ontario Ministry of Natural Resources, pers. 

comm. 2001 as cited in USDA 2001a). In addition, several environmental concerns regarding this strategy 

still need to be addressed, including safety of the proposed genetically engineered vaccines to humans, 

other wildlife species, and even nontarget members of the target species - e.g., juveniles that might 

consume baits (Miller 1997, Guynn 1997, Hanlon and Rupprecht 1997). 

No contraceptive agents are currently registered for use on raccoons, gray foxes, or coyotes and, thus, are 

not legal for use. For all of the above reasons, birth control strategies to control rabies will not be 

considered further. 

3.2.3 Employ Other Types of ORV instead of the V-RG Vaccine.

Under this alternative, APHIS-WS would provide funds to purchase and use “modified-live-virus” (i.e., 

“attenuated” or weakened strains that have been shown to have little chance of causing rabies in treated 

animals) or perhaps “killed-virus” (i.e., “inactivated” virus) oral vaccines instead of the V-RG vaccine in 

ORV baits. Modified-live-virus vaccines include those that have been used in the past in the U.S. to 

vaccinate domestic animals by injection. Oral baits that employed several strains of these types of virus 

vaccines have been investigated and used in Europe to stop the spread of rabies in red foxes (Flamand et al. 

1993, Artois et al. 1993, Artois et al. 1997). They have also been tested in red foxes in Canada (Lawson et 

al. 1989, Lawson et al. 1997), and in red foxes and raccoons in the U.S. (Rupprecht et al. 1989, Rupprecht 

et al. 1992c). 

The primary concern with attenuated or “live” virus vaccines (e.g., SAD and ERA) is that they can 

sometimes cause rabies (Flamand et al. 1993, Pastoret et al. 1992). Flamand et al. (1993) reported that one 

strain used widely in oral baits in Europe to vaccinate wild red foxes in the 1970s could cause rabies in 

rodents when injected and that the ability to cause rabies in nontarget animals by other modes (i.e., oral 

administration) could not be ruled out. Previously used attenuated strains are also “heat sensitive” which 

can limit their use in warmer seasons or climates (Pastoret et al. 1992). These types of safety concerns with 

attenuated rabies virus vaccines have been sufficient to prevent their approval for use in the U.S. 

(Rupprecht et al. 1992c). 

“Inactivated” virus or “killed-virus” rabies vaccines are safer than “live” vaccines in that they cannot cause 

rabies. This type of vaccine was found to be less effective in causing immunity when delivered into the 

intestinal tract in foxes (only 30 percent effective in test animals) and took two doses to cause immunity in 

the foxes that were successfully immunized (Lawson et al. 1989). Also, the amounts of virus particles that 

would have to be ingested in oral baits by wild carnivores to effectively vaccinate them would be 100 to 

1000 times the amount of the live-attenuated virus particles required (Rupprecht et al. 1992c). To 

manufacture vaccines with these amounts would likely be cost-prohibitive (Rupprecht et al. 1992c). 

Research is underway to identify a vaccine that is safe and effective not only in raccoons and foxes, but 

other carnivores as well such as skunks and dogs. Live modified canine adenovirus type 2 (CAV2), which 

is already used worldwide for the routine vaccination of dogs against both CAV1 and CAV2 and has an 

excellent safety record (Fisher et al. 2002, Appel et al. 1975), represents an almost ideal vaccine vector for 

immunization of carnivores against rabies (Li et al. 2006). In 2006, external research was conducted at 

Thomas Jefferson University in Philadelphia, Pennsylvania on the development of new, safe, and effective 

oral rabies vaccines. Because CAV2 is licensed for use as a live vaccine for dogs and has an excellent 

safety record, it was used as an expression vector for the rabies virus (RV) glycoprotein (G). This research 
41 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

indicated that the resulting CAV2 RVG vaccine is expected to have a potency comparable to that of the VRG vaccine (Li et al. 2006) and could, pending further research, provide a vaccine alternative suitable for 

use in feral dogs and other wildlife. 

Currently, RABORAL V-RG® is the only vaccine licensed for use in raccoons or approved for 

experimental use in wild gray foxes and coyotes in the U.S. (CDC 2000). For all of the above reasons, this 

alternative was not considered further. 

3.3 SOPs TO MINIMIZE POTENTIAL IMPACTS OF THE RABIES ORV PROGRAMS

An SOP is any aspect of an action that serves to prevent, reduce, or compensate for negative impacts that 

otherwise might result from that action. The current ORV program uses many such SOPs which would be 

incorporated in to programs initiated in Arizona and New Mexico or other States where the ORV program 

expands. Many WS SOPs are discussed in depth in USDA (1997, Chapt. 5). The key SOPs are 

incorporated into all alternatives as applicable, except the no federal program alternative (Alternative 2). 

Most SOPs are instituted to abate specific issues while some are more general and relate to the overall 

program. SOPs include those recommended or required by regulatory agencies such as EPA and these are 

listed where appropriate. Additionally, specific measures to protect resources such as T&E species that are 

managed by other agencies (USFWS and State Departments of Wildlife) are included in the lists below. 

 Public information, education, and media announcements would be made available to inform the 

public about ORV bait distribution activities in each county before they occur. APHIS-WS would 

coordinate with the appropriate state agency involved in the ORV program on preparing leaflets, 

posters, press releases, or other media to distribute to the public. Leaflets and posters would be posted 

in schools, hospitals, campgrounds, visitor centers, and state and county public agency offices. 

Notification of ORV bait drops would be sent to the state police, state emergency management 

associations, county hazardous materials coordinators, county cooperative extension agents, state and 

federal correctional facilities, wildlife rehabilitators, and medical and veterinary facilities within the 

ORV area informing them of the program and providing information about the ORV bait and vaccine 

and potential exposure issues. 

 Dog food baits for gray fox rabies control are now prepared from poultry-based dog food as concerns 

were raised regarding the possibility of beef-based dog food containing bovine spongiform 

encephalopathy (BSE, also known as mad cow disease). To address these concerns, the change to 

poultry-based products was made on a voluntary basis by MERIAL, Inc. (J. Maki, MERIAL, pers. 

comm. 2003 as cited in USDA 2004a). 

 Toll-free telephone numbers would be advertised in the media and on web sites for people to call for 

answers to questions. 

 In the unlikely event that an adverse vaccinia virus exposure in humans occurs (see recent example 

described in Section 4.1.1.2), the CDC can make vaccinia immune globulin available to a state on a 

case-by-case basis to provide a level of additional assurance that such a reaction would be successfully 

treated. 

 Bait distribution navigators would be trained to avoid dropping baits on people or structures. During 

aerial bait drop operations, the bait dispensing equipment is temporarily turned off over human 

dwellings, cities, towns, greenhouses, certain sensitive domestic animal pens, and when people are 

observed below. 

 APHIS-WS personnel would adhere to air safety standards. 

 ORV baits would not be distributed by aircraft within 0.25 miles of water bodies to reduce the 

potential of baits entering the water source. 
42 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

 APHIS-WS personnel would be trained in hand distribution of baits to avoid properties with greater 

risk of human or pet encounters with baits. 

 The appropriate government authorities/officials would be notified prior to distributing ORV baits 

along the U.S.-Mexico border. 

 The appropriate federal land management agency would be notified prior to distributing ORV baits on 

federal lands. 

 Labels would be placed on each ORV bait instructing persons not to disturb or handle them. Labels 

would contain a toll-free telephone number to call for further information and guidance in the event of 

accidental exposure to the vaccine (see Figure 1-2 in Chapter 1). 

 Methods used to capture raccoons would mainly involve the use of cage traps; however, other methods 

such as shooting, leg hold traps, and snares may be used in some programs. Animals caught in cage 

traps that are killed for monitoring and testing, purposes, local depopulation, or per cooperating 

landowner’s request would be euthanized in accordance with APHIS-WS policy in a manner as a 

humane as allowable under the circumstances. 

 Capture devices would be checked on a daily basis. 

 Field personnel involved in trapping and handling animals for monitoring and surveillance purposes 

would be immunized against rabies and tetanus. 

 All drugs designated for capturing and handling raccoons and other animals would be used under the 

direction of state or federal veterinary authorities, either directly or through procedures agreed upon 

between those authorities and APHIS-WS. 

 Monitoring and surveillance activities may extend into the hunting season during late summer/fall 

ORV baiting schedules. Therefore, target species would either be ear tagged, marked in some other 

way, or euthanized if capture and handling activities that utilize immobilizing drugs are used within 30 

days of hunting or trapping seasons. These measures would be taken to avoid release of animals that 

may be consumed by hunters prior to the end of established withdrawal periods for the particular drugs 

used. Most animals administered immobilizing drugs, however, would be released well before state 

controlled hunting/trapping seasons which would give the drug time to completely metabolize out of 

the animals’ systems before they might be taken and consumed by humans. 

 Aerial baiting would not be conducted on any designated Wilderness Areas of National Forest System 

or BLM lands. APHIS-WS flight transects would be drawn around Wilderness Areas during 

preparation for baiting campaigns. If this is not possible, aircraft pilots would increase their altitude to 

609.6 m (2000 ft) over Wilderness Areas. 

3.3.1 Monitoring 

APHIS-WS, in coordination with the appropriate agencies, would monitor any program that results from 

this EA. The impacts discussed in this EA would be monitored and used in two ways: 

1) APHIS-WS would determine if any additional information that arises subsequent to a NEPA decision 

from this EA would trigger the need for additional NEPA compliance. APHIS-WS would review 

program results and related NEPA documents annually, or as needed, to ensure that the need for 

action, issues identified, alternatives, regulatory framework, and environmental consequences are 

consistent with those identified in the final NEPA documents. 

2) APHIS-WS would monitor impacts on target and nontarget wildlife populations through its 

Management Information System (MIS) database. The MIS information would be used to assess the 
43 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

localized and cumulative impacts of the program on wildlife populations. APHIS-WS provides 

detailed information on animals removed to the involved state agencies to assist those agencies with 

managing species and resources under their jurisdiction. 
44 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

4.0 CHAPTER 4: ENVIRONMENTAL CONSEQUENCES 

This chapter analyzes potential environmental consequences using Alternative 1 (the current action) as the 

baseline for comparison with the other alternatives to determine if the real or potential impacts are greater, 

lesser or the same. Table 4-6 at the end of this chapter summarizes a comparison of the issues and impacts 

to each alternative. 

The following resource values within the state are not expected to be negatively impacted by any of the 

alternatives analyzed: soils, geology, minerals, floodplains, wetlands, visual resources, air quality, aquatic 

resources and range. These resources will not be analyzed further. 

Other than minor uses of fuels for motor vehicles and other materials, there are no irreversible or 

irretrievable commitments of resources. The contribution of the proposed action to the emission of gases 

that potentially contribute to global warming will be similar to the other alternatives and is expected to be 

minimal. Thus, these will not be analyzed further. 

The proposed action does not involve construction, major ground disturbance, or habitat modification. 

Therefore the following resource values are not expected to be affected by the proposed action: soils, 

geology, minerals, water quality/quantity, flood plains, wetlands, visual resources, air quality, prime and 

unique farmlands, aquatic resources, vegetation, timber, and range. These resources will not be analyzed 

further. 

4.1 ENVIRONMENTAL CONSEQUENSES FOR ISSUES ANALYZED IN DETAIL 

4.1.1 Potential for Adverse Effects on Target Wildlife 

4.1.1.1 Alternative 1: Current Action (the No Action Alternative) 

Effects of the ORV V-RG Vaccine on Raccoons, Gray Foxes, and Coyotes

The primary concern here is whether the V-RG virus might cause disease in target animals that consume 

the ORV baits. Large numbers of raccoons have been inoculated with or have consumed baits containing 

the vaccine without ill effects, with most being successfully immunized against rabies (USDA 1991, p. 25; 

Rupprecht et al.1986) without showing adverse effects. Tests showed that the V-RG virus did not invade 

the CNS or the cerebrospinal fluid of treated 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 of the virus in the blood) in tissues sampled from treated raccoons 

(Rupprecht et al. 1988). These studies, in addition to the absence of reports of adverse effects in freeranging wildlife in ORV program areas, have demonstrated the safety and effectiveness of the V-RG 

vaccine in raccoons. ORV baits containing the V-RG vaccine would thus have no adverse impact on 

raccoon populations. 

Artois et al. (1990) evaluated the safety of V-RG oral vaccine in coyotes and found no evidence of vaccinia 

virus infections or other complications. Rupprecht et al. (1992a) reported no adverse effects in gray foxes 

tested. Also, extensive experimental field testing of V-RG vaccine with subsequent collections and 

necropsies of gray foxes and coyotes for monitoring purposes in Texas have not produced any observed 

pathological signs of disease or other adverse effects on this species (E. Oertli, TX Dept. of Health, pers. 

comm. 2001 as cited in USDA 2001a). Extensive laboratory and field testing of V-RG vaccine in many 

nontarget species, including other closely related members of the canid (dog) family (Rupprecht et al. 

1992a), indicates virtually no risk of oral baits containing V-RG adversely affecting gray fox or coyote 

populations. 

To fulfill requirements for the USDA when using an experimental product, the TDSHS recently prepared 

the 2006 Texas Gray Fox after Action Report (TDSHS 2007). The report summarized ORV efficacy and 

safety following its use in the gray fox rabies control program. The TDSHS concluded that of the 

2,030,500 dog food based ORV baits distributed in west-central Texas in 2006, none of the 194 target 
45 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

species captured within the vaccination zones demonstrated lesions attributable to the vaccine. In addition, 

of the 146 gray foxes collected by the TDSHS, 74 (51%) contained levels of neutralizing rabies 

antibodies. Rabies surveillance data (n = 728 submissions) collected from counties outside the vaccination 

zone have not detected any animals infected with the gray fox strain of rabies. Therefore, as part of a 

rabies control program, this vaccine has prevented the further spread of the gray fox strain of rabies into 

uninfected parts of Texas. The report concluded that RABORAL V-RG® is a safe and efficacious vaccine 

for use in gray foxes and supports the continued use of ORV by the TDSHS to control rabies in gray foxes. 

The report will be submitted to the USDA towards full licensure of ORV for use in gray foxes. 

Research is underway to identify a vaccine that is safe and effective not only in raccoons and foxes, but 

also in other carnivores as well such as skunks and dogs. Live modified canine adenovirus type 2 (CAV2), 

which is already used worldwide for the routine vaccination of dogs against both CAV1 and CAV2 and has 

an excellent safety record (Fisher et al. 2002, Appel et al. 1975), represents an almost ideal vaccine vector 

for immunization of carnivores against rabies (Li et al. 2006). The use of different vaccines is anticipated 

to have similar effects on targets as RABORAL V-RG®. Research tests such as Rupprecht et al. (1992) 

will be conducted to determine potential side-effects of the new vaccine to confirm the effects on target 

species. Any environmental effects of the new vaccines on raccoons, gray foxes, or coyotes not analyzed 

in this EA will be appropriately evaluated in further environmental documentation. 

Effects of Monitoring and Surveillance on Raccoon Populations in Eastern States

The estimated cumulative size (over all involved states) of the proposed raccoon rabies ORV barrier zones 

to be treated with ORV baits purchased with USDA funds annually would be about 102,650 km2

 (or about 

39,623 mi2) (Kemere et al. 2001). Raccoon densities range from 0.9 to as high as 250 per km2 (about 2 to 

650 per mi2

) with most reported densities ranging from 4 to 30 per km2. (about 10 to 80 per mi2.) in rural 

areas (Riley et al. 1998). Assuming that this range of raccoon densities occurs in the treatment area, it is 

reasonable to assume that the raccoon population for the entire area would be between 400,000 and 3.1 

million. 

Raccoon populations can generally be expected to withstand harvest rates of about 49 percent or more 

annually (Sanderson 1987, USDA 1997j). APHIS-WS and cooperating state or local agencies expect to 

continue to live-trap or lethally remove less than one percent of the lowest estimated number of raccoons in 

all states combined for monitoring and surveillance purposes or implementation of localized contingency 

plans involving lethal population reduction. The 2006 Monitoring Report (USDA 2008b) for the APHISWS EA – Oral Vaccination to Control Specific Rabies Virus Variants in Raccoons, Gray Foxes, and 

Coyotes in the U.S. (2004a) indicates the lowest estimated size of the raccoon population totaled from 

those states participating in the ORV program is 2,225,031 raccoons. The APHIS-WS program killed 676 

raccoons for enhanced rabies surveillance as a part of cooperative ORV efforts or 0.03 percent of the total 

lowest estimated population in 2006. The report summarizes that the ORV program continues to have no 

adverse impacts to raccoon densities and that, in the absence of the ORV program, it is highly likely that far 

more raccoons would die from rabies than are killed for surveillance and monitoring purposes to critically 

evaluate the integrity of ORV campaigns. In comparison, during 2005-2006, sportsmen in Pennsylvania 

and Ohio harvested 106,082 and 46,886 raccoons respectively (or 11.4% and 5.5% of the total raccoon 

populations in those states) (ODNR 2009, PGC 2009a, USDA 2008b). 

The majority of raccoons captured for monitoring or surveillance purposes would be released at their site of 

live capture once they have fully recovered from anesthesia. Individual raccoons may be lethally removed 

and tested for rabies if they were demonstrating strange behavior symptomatic of the rabies virus or were 

injured. An exception may be when the animals were captured and drugged for handling purposes close to 

or during hunting/trapping seasons, at which times they may be euthanized to avoid concerns about hunters 

or trappers consuming raccoons that contain drug residues (see Section 2.2.1). Contingency actions would 

be considered that could result in lethal raccoon population suppression in small areas to attempt to contain 

an outbreak that could occur beyond an existing ORV zone. Given that hunter and trapper harvest and 

other sources of mortality would occur, there are no anticipated significant cumulative impacts to raccoon 

populations even if contingency actions would be infrequently conducted in small areas of the states 

involved in ORV programs. 
46 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

The RABORAL V-RG® vaccine exhibits significant effectiveness in producing rabies VNA in target 

species. In all states conducting ORV bait distribution, APHIS-WS conducts post-ORV monitoring to 

evaluate program efficacy by collecting blood and tooth samples for determining rabies VNA levels and 

bait uptake (when appropriate) in raccoons, coyotes, and gray foxes. Serum samples are collected from 

unique (previously uncaptured and unsampled) raccoons captured. Table 4-1 displays the serology results 

for post-ORV raccoon monitoring and surveillance activities from 2002-2006. Positive rabies VNA results 

of ≥0.05IU indicate that the animal sampled displayed sufficient antibody results and were effectively 

vaccinated. 

Table 4-1. Number of Post-ORV Raccoon Serum Samples Collected and Results. 

Post ORV Serum Samples Positive Rabies Antibody Response (≥0.05IU)

Year 2002 2003 2004 2005 2006 2002 2003 2004 2005 2006 

AL n/a 126 255 398 387 n/a 41(32.5%) 44(17.3%) 91(22.9%) 105(27.1%) 

FL n/a 201 83 548 271 n/a 16(8.0%) 4(4.8%) 96(17.5%) 32(11.8%) 

GA n/a 116 130 134 123 n/a 35(30.2%) 33(25.4%) 28(22.6%) 24(23.5%) 

ME n/a 117 128 85 94 n/a 28(23.9%) 67(52.3%) 55(69.6%) 44(48.9%) 

MD 145 133 139 210 176 51(35.2%) 38(28.3%) 33(23.7%) 41(19.5%) 56(31.8%) 

MA 94 40 478 24 29 n/a 15(37.5%) 80(16.7%) 5(14.7%) 11(37.9%) 

NH 5 n/a 7 7 11 0(0%) n/a 2(28.6%) 2(28.6%) 5(45.5%) 

NJ n/a n/a 25 n/a n/a n/a n/a 8(32.0%) n/a n/a 

NY 256 313 295 101 198 66(25.8%) 92(29.4%) 83(28.1%) 28(27.7%) 43(21.7%) 

NC n/a n/a n/a 133 121 n/a n/a n/a 9(6.8%) 16(13.2%) 

OH 118 143 191 838 453 11(9.3%) 43(30.1%) 14(7.3%) 88(10.5%0 163(36.0%) 

PA 306 338 739 677 69 42(13.7%) 91(27.0%) 113(15.4%) 25(3.7%) 11(15.9%) 

TN 74 217 437 488 267 8(10.8%) 34(22.2%) 129(29.5%) 111(22.7%) 94(35.2%) 

VT 311 309 327 239 189 45(14.5%) 69(22.3%) 63(19.3%) 38(15.9%) 39(20.6%) 

VA 71 110 129 194 238 17(23.9%) 38(34.5%) 48(37.2%) 63(32.5%) 135(56.7%) 

WV 70 189 316 327 262 23(32.9%) 61(32.3%) 83(26.3%) 69(21.1%) 100(38.2%) 

Effects of Monitoring/Surveillance on Gray Fox Populations in Texas

The APHIS-WS program in Texas has analyzed the impacts of program activities on gray fox populations 

including activities that involve assistance with rabies monitoring and surveillance in several previous EAs. 

Those EAs covered such activities in the area of the state affected by the ORV program as well as the entire 

state, and include analysis of the effects of all lethal removal of gray foxes by APHIS-WS. The analyses 

in, and subsequent monitoring reviews of, the EAs showed that APHIS-WS total gray fox take combined 

with other known take (e.g., annual trapper and hunter harvest), has been far below any level that would 

begin to adversely impact overall populations of gray fox (USDA 1996, 1997a, 1997b, 1997c, 1997d, 

1997e, 1997f, 1997g, 1997h,1997i). Thus, the cumulative impact on gray fox populations in Texas would 

be insignificant. 

These EA monitoring reports state that gray fox populations can generally be expected to withstand annual 

harvest rates of about 25 percent or more (USDA 2007b). The 2006 Monitoring Report (USDA 2008b) for 

the APHIS-WS EA – Oral Vaccination to Control Specific Rabies Virus Variants in Raccoons, Gray Foxes, 

and Coyotes in the U.S. (2004a) indicates the number of gray foxes removed in Texas by the APHIS-WS 

ORV program alone equated to 0.02% of the estimated population. In 2006, lethal removal (private harvest 

rates combined with APHIS-WS damage management activities) totaled 1.2% for gray foxes in Texas, far 

below the sustainable harvest level (USDA 2007b). Thus, the cumulative lethal removal of gray fox in 

Texas was far below a sustainable harvest of 25% (20 times as many gray fox could be taken and still be 

below a level of significance) (USDA 2008b). Therefore, the impacts associated with the ORV program 

alone (monitoring and surveillance, localized population reduction, annual trapper and hunter harvest, other 

mortality) and cumulatively to gray fox populations have been and would continue to be negligible under 

the proposed action. 

The RABORAL V-RG® vaccine exhibits significant effectiveness in producing rabies VNA in target 

species. In all states conducting ORV bait distribution, APHIS-WS conducts post-ORV monitoring to 

evaluate program efficacy by collecting blood and tooth samples for determining rabies VNA levels and 
47 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

bait uptake (when appropriate) in raccoons, coyotes, and gray foxes. Serum samples are collected from 

gray foxes captured. Table 4-2 displays the serology results for post-ORV gray fox monitoring and 

surveillance activities from 2002-2006. Positive rabies VNA results of ≥0.05IU indicate that the animal 

sampled displayed sufficient antibody results and were effectively vaccinated. 

Table 4-2. Number of Post ORV Gray Fox Serum Samples Collected and Results. 

Post ORV Serum Samples Positive Rabies Antibody Response (≥0.05IU)

Year 2002 2003 2004 2005 2006 2002 2003 2004 2005 2006 

Gray Fox 88 129 136 141 146 46(52.3%) 88(68.2%) 88(64.7%) 80(56.7%) 74(50.7%) 

Effects of Monitoring/Surveillance on Coyote Populations in Texas

Impacts on coyote populations from APHIS-WS depredation management and rabies monitoring activities 

in Texas were also analyzed in prior EAs (USDA 1996, 1997a, 1997b, 1997c, 1997d, 1997e, 1997f, 1997g, 

1997h, 1997i). Those EAs covered such activities in the area of the state affected by the coyote rabies 

ORV program and include analysis of the effects of all lethal removal of coyotes in those areas by APHISWS. Those analyses show that APHIS-WS’ take in combination with other known harvest has been less 

than 15% of the estimated population in Texas [5.4% harvested by sportsman, 6% by WS] in any one year 

which is far below the 70% harvest level that can be sustained by coyotes (USDA 1997g, 1997i). Thus, the 

cumulative impact on coyote populations in Texas would be insignificant. 

The 2006 Monitoring Report (USDA 2008a) for the APHIS-WS EA – Oral Vaccination to Control Specific 

Rabies Virus Variants in Raccoons, Gray Foxes, and Coyotes in the U.S. (2004a) indicates the number of 

coyotes removed in Texas by the APHIS-WS ORV program alone equates to 0.05 % of the estimated 

population. In 2006, lethal removal (private harvest rates combined with APHIS-WS damage management 

activities) totaled 9.8 percent for coyotes, far below the sustainable harvest level (USDA 2007b). 

Combining APHIS-WS lethal removal during the ORV program with the aforementioned take, cumulative 

lethal removal equates to 12.7 percent for the coyote population (USDA 2008a). Therefore, cumulative 

impacts (monitoring and surveillance, localized population reduction, annual trapper and hunter harvest, 

other mortality) to coyote populations have been and are expected to continue to be negligible. 

The RABORAL V-RG® vaccine exhibits significant effectiveness in producing rabies VNA in target 

species. In all states conducting ORV bait distribution, APHIS-WS conducts post-ORV monitoring to 

evaluate program efficacy by collecting blood and tooth samples for determining rabies VNA levels and 

bait uptake (when appropriate) in raccoons, coyotes, and gray foxes. Serum samples are collected from 

coyotes captured. Table 4-3 displays the serology results for post-ORV coyote monitoring and surveillance 

activities from 2002-2006. Positive rabies VNA results of ≥0.05IU indicate the number of animals sampled 

that displayed sufficient antibody results to effectively vaccinate them. 

Table 4-3. Number of Post ORV Coyote Serum Samples Collected and Results. 

Post ORV Serum Samples Positive Rabies Antibody Response (≥0.05IU)

Year 2002 2003 2004 2005 2006 2002 2003 2004 2005 2006 

Coyote 124 30 100 115 145 68(54.8%) 25(83.3%) 50(50.0%) 29(25.2%) 95(33.8%) 

Effects on other species not targets for purposes of ORV, but which may be considered targets for 

monitoring and surveillance, contingency actions, or limited wildlife damage management

Although the ORV program specifically targets raccoons, gray foxes, and coyotes, several other species 

may be treated as targets for rabies monitoring and surveillance, contingency actions, rabies testing in cases 

of human exposure, or for limited wildlife damage management purposes. These species will be referred to 

as non-ORV targets for purposes of this EA. The methods proposed for use in raccoon rabies monitoring 

and surveillance areas or in implementing localized population reduction under state contingency actions 

would have no significant adverse effects on non-ORV target species. Species which are considered 

targets for monitoring and surveillance, but might not be targets for specific ORV programs will include all 

known rabies reservoir species including raccoons, grey foxes, red foxes, coyotes, striped skunks, hooded 

skunks, spotted skunks, hog-nosed skunks, bobcats, ringtails, feral dogs, and feral cats. Occasionally 

samples are collected for serology from some mammal species which are incidentally captured during ORV 
48 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

monitoring and surveillance activities, but not specifically targeted by the ORV program. They are 

opportunistically sampled to determine the potential effectiveness of RABORAL V-RG® as many of these 

species have a propensity for contracting, harboring, and spreading the rabies virus (Table 4-4). Non-ORV 

target animals captured in cage traps would normally be released unharmed unless lethal removal was 

requested by the cooperating landowner or if the animal appeared injured or sick. Therefore, monitoring 

and surveillance should have no effect on other target species populations. Species which have the 

potential to be targets on highly limited basis for wildlife damage management (WDM) include 

woodchucks, opossums, striped skunks, raccoons, gray squirrels, red squirrels, Norway rats, black rats, and 

armadillos. APHIS-WS has considered the effects of WDM on these species in several previous EAs 

which may be found at: http://www.aphis.usda.gov/wildlife_damage/nepa.shtml. 

Table 4-4. Number of Non-ORV Target Serum Samples Collected and Results. 

Post ORV Serum Samples Positive Rabies Antibody Response (≥0.05IU) 

Year 2002 2003 2004 2005 2006 2002 2003 2004 2005 2006 

Coyote 23 52 42 26 19 8(34.8%) 31(59.6%) 9(21.4%) 6(23.1%) 4(21.1%) 

Raccoon 8 17 10 9 4(50.0%) 7(41.2%) 2(20.0%) 1(11.2%) 

Skunk 11 75 35 17 60 6(54.5%) 16(21.3%) 3(2.9%) 1(5.9%) 10(16.7%) 

Red fox 1 1 0(0.0%) 0(0.0%) 

Grey fox 1 2 1(100.0%) 2(100.0%) 

Bobcat 2 8 1(50.0%) 1(12.5%) 

Mountain lion 1 0(0.0%) 

Ringtail 1 0(0.0%) 

Non-ORV target wildlife species have been incidentally captured during ORV monitoring and surveillance 

efforts. A total of 3,847 non-ORV target animals were captured between 2006 and 2007 (Table4-5). Most 

non-ORV target species were captured in cage traps and released unharmed (3,297 or 86%). Some nonORV target animals were euthanized (550 or14%) for rabies diagnostic testing, if they were injured, if they 

were demonstrating strange behavior symptomatic of the rabies virus, or for wildlife damage management 

in conjunction with rabies surveillance (these were animals targeted for reasons other than ORV 

surveillance and monitoring). The non-ORV targets that were euthanized were not considered to be from 

low density populations and removal was not expected to have any cumulative adverse effects on the 

populations in the area. The most common non-ORV target species taken (Table 4-5) was the Virginia 

opossum, accounting for 67% of the nonlethal take and 19% of the lethal take. Virginia opossums are 

abundant throughout much of the area where ORV baiting occurs and this take represents only a minor 

percent of their population. To compare to other mortality, sportsman harvest in Pennsylvania alone 

annually averaged over 44,000 opossums in the 2005-06 to 2007-08 seasons (PGC 2009a) illustrating the 

minimal take by WS. The second most frequently taken nontarget species were striped skunks accounting 

for 13% of the nonlethal and 58% of the lethal take. This species is abundant throughout the analysis area 

and would be expected to be commonly taken. For comparison, sportsmen in Pennsylvania took an 

average of 10,000 from 2005-06 to 20007-08 hunting seasons (PGC 2009a), again illustrating the minimal 

take by WS. The next most common nontarget species taken were woodchucks, accounting for 5% of the 

nonlethal take and 14% of the lethal take by WS (Table 4-5). Sportsman harvest woodchucks is usually 

higher; for example, in Pennsylvania alone, take was annually estimated at about 900,000 from 2005-2007 

(PGC 2009b). As illustrated, WS has little effect on the woodchuck population. Finally, feral cats 

accounted for 14% of the nonlethal take and 5% of the lethal take. Some were feral cats running at large 

and returned to owners. Feral cats which exhibited unusual behavior associated with the rabies virus were 

humanely euthanized for rabies testing. These 4 species accounted for 99% of the nonlethal take and 96% 

of the lethal take with another 9 species taken accounting for the remaining 6% of the take. 
49 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Table 4-5. Non-ORV Target Species Taken by WS for the ORV Program 2006-2007. 

Year 2006 2006 

Species Freed Killed Intent Freed Killed Intent 

Striped skunk 301 - 134 - 

- 1 Human exposure - 1 Human exposure 

- 19 Surveillance - 21 Surveillance 

- 70 Nuisance - 201 Nuisance 

- 7 Found dead/died under care - - 

Hooded skunk - 2 Human exposure - - 

Spotted skunk - 1 Surveillance - - 

Red fox - - 23 - 

- - 1 Human exposure 

- - 2 Surveillance 

Feral cat 153 - 297 - 

- 8 Human exposure - 4 Human exposure 

- 5 Surveillance - 4 Surveillance 

- 5 Nuisance - 2 Nuisance 

Feral dog 8 - 5 - 

- 1 Human exposure - - 

Ringtail 1 Human exposure - 

Woodchuck 81 - 74 - 

- 2 Surveillance - 3 Surveillance 

- 36 Nuisance - 34 Nuisance 

Virginia opossum 1,035 - 1,186 - 

- 1 Surveillance - 2 Surveillance 

- 32 Nuisance - 67 Nuisance 

Bobcat - 8 Surveillance - 4 Surveillance 

- - - 1 Nuisance 

Ringtail - 1 Human exposure - - 

- - - 1 Surveillance 

Snowshoe hare - - - 1 Nuisance 

Snake spp. - - - 1 Nuisance 

Total 1,578 200 1,719 350

Research is underway to identify a vaccine that is safe and effective for other carnivores such as skunks and 

dogs as well as for raccoons and foxes. Live modified canine adenovirus type 2 (CAV2), which is already 

used worldwide for the routine vaccination of dogs against both CAV1 and CAV2 and has an excellent 

safety record (Fisher et al. 2002, Appel et al. 1975), represents an almost ideal vaccine vector for 

immunization of carnivores against rabies (Li et al. 2006). It should be noted that the ORV program could 

expand target species if new vaccines are manufactured that enable bait use for additional species such as 

skunks. Skunks are a primary reservoir of the rabies virus variants in several states. And it would be 

advantageous to vaccinate this species and others to promote the effectiveness of the rabies management 

program. The use of different vaccines is anticipated to have similar effects on other targets as RABORAL 

V-RG®. Research tests such as Rupprecht et al. (1992) will be conducted to determine potential sideeffects of the new vaccine to confirm the effects to other target species. Any environmental effects of the 

new vaccines on other target species not analyzed in this EA will be appropriately evaluated in further 

environmental documentation.
50 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

4.1.1.2 Alternative 2: Proposed Action (the Preferred Alternative) 

Effects of the ORV V-RG Vaccine on Raccoons, Gray Foxes, and Coyotes

As with Alternative 1, no adverse effects would be expected with Alternative 2. Contingency Action 2 

(treatment with increased bait density to ensure sufficient baits for high density of target species or to 

bolster antibody response under “normal” target species densities) and Contingency Action 3 (increase 

baiting frequency more than once/year) utilize ORV. Current/historical ORV programs and research 

conducted on the V-RG vaccine have demonstrated its safety and effectiveness in target populations. The 

V-RG vaccine is currently licensed by the USDA for raccoons and coyotes and is approved for 

experimental use in gray foxes. New vaccines may be considered for future use by the APHIS-WS ORV 

program and any environmental effects of the new vaccines on raccoons, gray foxes, or coyotes not 

analyzed in this EA will be appropriately evaluated in further environmental documentation. 

Effects of Monitoring and Surveillance or Contingency Actions on Raccoon Populations in Eastern 

States

As with the effects of monitoring and surveillance described above, the five Contingency Actions are also 

expected to have negligible adverse risks or impacts to raccoon populations. Contingency Action 2 

(treatment with increased bait density to ensure sufficient baits for high density of target species or to 

bolster antibody response under “normal” target species densities) and Contingency Action 3 (increased 

baiting frequency more than once/year) use ORV and the ORV programs conducted thus far and research 

conducted on the V-RG vaccine have demonstrated its safety and effectiveness in target populations. The 

V-RG vaccine is currently licensed by the USDA for raccoons and coyotes and is approved for 

experimental use in gray foxes. 

Contingency Action 1 (enhanced surveillance, which may include capture and release or euthanasia of 

target and specific nontarget species for rabies testing) and Contingency Action 5 (localized target species 

population reduction) involve the possible removal of raccoons. As discussed above, APHIS-WS and 

cooperating state and local agencies expect to lethally remove less than 1% of the lowest estimated number 

of raccoons in all states combined. To date, lethal removal has accounted for less than 0.006% - 0.12% of 

the lowest estimated raccoon population annually (USDA 2008b, 2007a, 2005, 2004c, 2004d, 2003b). The 

APHIS-WS rabies management program’s lethal removal of far less than 1% of raccoons did not reduce 

statewide or regional densities of raccoons. As a result of the review of possible impacts to raccoons, the 

potential for cumulative impacts continues to be negligible. Therefore, the rabies management program 

continues to have no adverse impacts to raccoon densities. In the absence of the ORV program, it is highly 

likely that substantially greater numbers of raccoons would succumb to the invariably fatal rabies virus than 

are removed during contingency actions or other rabies management activities. These activities are integral 

to preserving the integrity of the ORV program, preventing rabies spread among raccoons to areas not 

infected with this fatal virus, and for monitoring effectiveness. 

Contingency Action 4 (TVR) involves the use of a parenteral (injectable) vaccine, such as IMRAB®3, 

which can be used “off label” under the direction of veterinarians to vaccinate healthy wildlife. After being 

vaccinated against the rabies virus, healthy target species would be released at the site of capture. 

Therefore, injectable vaccine use would have no adverse effects on raccoons. Beneficial impacts include 

bolstering target species population immunity and preventing further rabies spread. Sick or injured target 

animals would likely be euthanized for rabies testing. Impacts of euthanasia and lethal removal on target 

species were discussed in the above paragraph. 

Effects of Monitoring/Surveillance or Contingency Actions on Gray Fox Populations in Arizona, New 

Mexico, and Texas

 

The APHIS-WS programs in Arizona, New Mexico, and Texas have analyzed the impacts of program 

activities on gray fox populations including activities that involve assistance with rabies monitoring and 

surveillance in several previous EAs. Those EAs covered such activities in the area of the state affected by 
51 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

the ORV program as well as the entire state, and include analysis of the effects of all lethal removal of gray 

foxes by APHIS-WS. The analyses in, and subsequent monitoring reviews of, the EAs showed that 

APHIS-WS total gray fox take combined with other known take (e.g., annual trapper and hunter harvest), 

has been far below any level that would begin to adversely impact overall populations of gray fox (USDA 

1996, 1997a, 1997b, 1997c, 1997d, 1997e, 1997f, 1997g, 1997h,1997i, 1999, 2006b). In fact, gray fox 

populations can generally be expected to withstand annual harvest rates of about 25% or more (USDA 

2007b). In 2007, cumulative take of gray fox (private harvest rates combined with APHIS-WS 

management actions including the ORV program) in Texas totaled 1.2% with the number of gray fox 

specifically taken by the APHIS-WS ORV program equating to 0.02% of the population (USDA 2009c). 

Thus, the cumulative impact on gray fox populations in Arizona, New Mexico, and Texas would be 

insignificant. 

Contingency Action 1 -5 are also expected to have negligible adverse risk to the gray fox population. 

Contingency Action 2 (treatment with increased bait density to ensure sufficient baits for high density of 

target species or to bolster antibody response under “normal” target species densities) and Contingency 

Action 3 (increased baiting frequency more than once/year) utilize ORV. Current/historical ORV programs 

and research conducted on the V-RG vaccine have demonstrated its safety and effectiveness in target 

populations. The V-RG vaccine is currently licensed by the USDA for raccoons and coyotes and is 

approved for experimental use in gray foxes. 

Contingency Action 1 (enhanced surveillance, which may include capture and release or euthanasia of 

target and specific nontarget species for rabies testing) and Contingency Action 5 (localized target species 

population reduction) involve the possible removal of gray foxes. As discussed above, gray fox populations 

can generally be expected to withstand harvest rates of about 25% or more annually (USDA 2007b). The 

ORV program in Arizona, New Mexico, and Texas targets coyote and gray fox variants of the rabies virus. 

The number of gray foxes removed annually by the APHIS-WS ORV program equates to an average of 

0.03% of their estimated population (USDA 2009c, 2008b, 2007a, 2005, 2004c, 2004d, 2003b). The 

APHIS-WS rabies management program’s lethal removal of less than 1% of gray foxes did not reduce the 

statewide densities of gray foxes and, if contingency actions are utilized, lethal removal is not expected to 

result in an appreciable increase in to number of gray fox taken by the rabies program. As a result of the 

review of the impacts to the gray fox population by the rabies program, APHIS-WS has determined that the 

potential for adverse cumulative impacts continues to be negligible. Therefore, the rabies management 

program continues to have no adverse impacts to gray fox densities. 

Contingency Action 4 (TVR) involves the use of a parenteral (injectable) vaccine, such as IMRAB®3, 

which can be used “off label” under the direction of veterinarians to vaccinate healthy wildlife. After being 

vaccinated against the rabies virus, healthy target species would be released at the site of capture. 

Therefore, injectable vaccine use would have no adverse effects on raccoons. Beneficial impacts include 

bolstering target species population immunity and preventing further rabies spread. Sick or injured target 

animals would likely be euthanized for rabies testing. Impacts of euthanasia and lethal removal on target 

species were discussed in this section under Contingency Action 1. 

Effects of Monitoring/Surveillance or Contingency Actions on Coyote Populations in Arizona, New 

Mexico, and Texas

Impacts on coyote populations from APHIS-WS depredation management and rabies monitoring activities 

in Arizona, New Mexico, and south Texas were also analyzed in prior EAs (USDA 1996, 1997a, 1997b, 

1997c, 1997d, 1997e, 1997f, 1997g, 1997h, 1997i, 1999, 2006). Those EAs covered such activities in the 

area of the state affected by the coyote rabies ORV program and include analysis of the effects of all lethal 

removal of coyotes in those areas by APHIS-WS. Those analyses show that APHIS-WS’ take in 

combination with other known harvest has been less than 15% of the estimated population in Texas [5.4% 

harvested by sportsman, 6% by WS] and less than 35% in Arizona [30% harvested by sportsman, 1% or 

less by WS] in any one year which is far below the 70% harvest level that can be sustained by coyotes 

(USDA 1997g, 1997i). Thus, the cumulative impact on coyote populations in south Texas, Arizona, and 

New Mexico would be insignificant. 
52 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Contingency Action 1 -5 are also expected to have negligible adverse risk to the coyote population. 

Contingency Action 2 (treatment with increased bait density to ensure sufficient baits for high density of 

target species or to bolster antibody response under “normal” target species densities) and Contingency 

Action 3 (increased baiting frequency more than once/year) utilize ORV. Current/historical ORV programs 

and research conducted on the V-RG vaccine have demonstrated its safety and effectiveness in target 

populations. The V-RG vaccine is currently licensed by the USDA for raccoons and coyotes and is 

approved for experimental use in gray foxes. 

Contingency Action 1 (enhanced surveillance, which may include capture and release or euthanasia of 

target and specific nontarget species for rabies testing) and Contingency Action 5 (localized target species 

population reduction) involve the possible removal of coyotes. As discussed above, coyote populations can 

generally be expected to withstand harvest rates idefinitely of up to 60% or more annually (USDA 2007b). 

The ORV program in Arizona, New Mexico, and Texas targets coyote and gray fox variants of the rabies 

virus. The number of coyotes removed annually in Texas by the APHIS-WS ORV program equates to an 

average of 0.13% of their estimated population (USDA 2008b, 2007a, 2005, 2004c, 2004d, 2003b). The 

APHIS-WS rabies management program’s lethal removal of less than 1% of coyotes did not reduce the 

statewide densities of coyotes. Based on this data, the potential for adverse cumulative impacts continues 

to be negligible. Therefore, the rabies management program continues to have no adverse impacts to coyote 

densities. 

A population model (Pitt et al. 2001) assessed the impact of removing a set proportion of a coyote 

population during one year and then allowing the population to recover. In the model, all populations 

recovered within 1 year when <60% of the population was removed. Recovery occurred within 5 years 

when 60-90% of the population was removed. Pitt et al. (2001) also evaluated the impact of removing a set 

proportion of the population every year for 50 years. When the removal rate was <60% of the population, 

the population size was the same as for an unexploited population. These findings are consistent with an 

earlier model developed by Connolly and Longhurst (1975), and revisited by Connolly (1995) which 

indicated that coyote populations could withstand an annual removal of up to 70% of their numbers and 

still maintain a viable population. 

Contingency Action 4 (TVR) involves the use of a parenteral (injectable) vaccine, such as IMRAB®3, 

which can be used “off label” under the direction of veterinarians to vaccinate healthy wildlife. After being 

vaccinated against the rabies virus, healthy target species would be released at the site of capture. 

Therefore, injectable vaccine use would have no adverse effects on raccoons. Beneficial impacts include 

bolstering target species population immunity and preventing further rabies spread. Sick or injured target 

animals would likely be euthanized for rabies testing. Impacts of euthanasia and lethal removal on target 

species were discussed in this section under Contingency Action 1. 

Effects on other species not targets for purposes of ORV, but which may be considered targets for 

monitoring and surveillance, contingency actions, or limited wildlife damage management

As with Alternative 1, a similar negligible impact would be expected with Alternative 2. 

4.1.1.3 Alternative 3: Live-Capture-Vaccinate-Release Alternative 

Effects of the ORV V-RG Vaccine on Raccoons, Gray Foxes, and Coyotes

Under this alternative, APHIS-WS would not provide funds for ORV purchase and distribution but would 

assist in monitoring and surveillance programs involving the capture or lethal collection and testing of wild 

raccoons, gray foxes, and coyotes following live-capture-vaccinate and release activities. Under a livecapture-vaccinate-release alternative, it is expected that little or no ORV use by the states would occur. 

Thus, there would be little or no potential for the V-RG oral vaccine to affect these species. 
53 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Effects of Monitoring and Surveillance or Contingency Actions on Raccoon , Gray Fox, Coyote, and 

non-ORV Target Species

Under a live-capture-vaccinate-release alternative (Contingency Action 4), it is expected that extent of 

lethal removal of raccoons in eastern states and gray foxes and coyotes in Arizona, New Mexico, and Texas 

for monitoring/surveillance activities or localized population reduction under contingency plans to address 

rabies outbreaks would be similar to the proposed action. Contingency Actions 2 and 3 would not be 

utilized under this alternative. Thus, the impact on populations of raccoons, gray foxes, coyotes, and other 

target species would be similar to the proposed action and would be very low. 

4.1.1.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal Removal Programs 

Alternative 

Under this alternative, the states would have to fund collection of target species for monitoring and 

surveillance without APHIS-WS funds or personnel assistance. This would likely mean that less 

monitoring would be conducted. If insufficient monitoring and surveillance occurs along the leading edge 

of the advancing rabies strains, rabies managers would not be able to plan the most efficient and effective 

use of ORV baiting strategies to control the specific strains spread by wild carnivores. One possibility is 

that, without adequate surveillance, managers would have to resort to distributing ORV baits across more 

areas than necessary. The ability to stop or prevent the forward advance of specific rabies strains would 

likely be reduced, perhaps to the point that cooperative efforts fail. 

Effects of the ORV V-RG Vaccine on Raccoons, Gray Foxes, and Coyotes

This alternative would result in the same risk as the proposed action because although there would be no 

surveillance monitoring, or lethal removal, APHIS-WS would still conduct ORV programs. That risk is 

that adverse effects are highly unlikely. Positive effects on these species from protecting them against 

rabies would be similar to the proposed action. However, more animals are likely to die of rabies if the 

lack of federal assistance in monitoring and surveillance results in a reduction in the effectiveness of ORV 

programs. 

Effects of Monitoring and Surveillance or Contingency Actions on Raccoon , Gray Fox, Coyote, and 

non-ORV Target Species

Under this alternative, APHIS-WS would not provide assistance in collecting animal specimens for 

monitoring purposes. The involved states could still conduct such collections; however, it is likely that 

fewer animals would be collected without APHIS-WS funds and assistance for that activity. Effects on 

raccoon, gray fox, coyote, and other target species populations would be exceedingly minor as supported 

by the analysis in Section 4.1.1.2. 

4.1.1.5 Alternative 5: No Federal Program Alternative 

It is most likely that fewer raccoons, gray foxes and coyotes in the proposed ORV zones would be 

vaccinated against rabies without APHIS-WS funds to contribute to ORV bait purchases and distribution. 

Therefore, more animals would likely die from rabies with potentially greater short-term population 

impacts. Such impacts would be expected to recur as raccoon, gray fox or coyote populations have strong 

capabilities to recover (Connolly and Longhurst 1975, Fritzell 1987, and Sanderson 1987), which would 

establish new populations susceptible to rabies mortality. If the state ORV programs failed for lack of 

APHIS-WS assistance, rabies epizootics may be expected to occur that would likely result in short-term 

die-offs of target species over broader geographic areas. 

Effects of the ORV V-RG Vaccine on Raccoons, Gray Foxes, and Coyotes

Under the no federal program alternative, states would still be able to employ the V-RG oral vaccine to 

combat raccoon rabies, and Arizona, New Mexico, and Texas would still be able to use V-RG to combat 

gray fox and coyote rabies. As concluded in the analysis in Section 4.1.1.1 and 4.1.1.2, baits using the V-
54 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

RG vaccine would have no adverse impact on raccoon, gray fox, or coyote populations. 

Effects of Monitoring and Surveillance or Contingency Actions on Raccoon Populations in Eastern 

States

Under the no federal program alternative, states would still likely implement some level of monitoring, 

control, and, potentially, implementation of contingency actions in response to breaches in vaccination 

barriers that result in localized population suppression to attempt to maintain the integrity of vaccination 

barriers. The numbers of raccoons killed under such programs would probably be less than if APHIS-WS 

funds and personnel were available. Therefore, as supported by the analysis in Section 4.1.1.1 and 4.1.1.2, 

effects on raccoon populations would be insignificant. 

Effects of Monitoring/Surveillance or Contingency Actions on Gray Fox Populations in Arizona, New 

Mexico, and Texas

Under the no federal program alternative, the States of Arizona, New Mexico, and Texas would likely still 

conduct monitoring, surveillance and local depopulation activities without APHIS-WS assistance; however, 

such activities would probably occur on a lesser scale. Therefore, as supported by the analysis in Section 

4.1.1.1 and 4.1.1.2, effects on gray fox populations would be insignificant. 

Effects of Monitoring/Surveillance or Contingency Actions on Coyote Populations in Arizona, New 

Mexico, and Texas

Under the no federal program alternative, the States of Arizona, New Mexico, and Texas could still 

conduct monitoring, surveillance and local depopulation activities even without APHIS-WS assistance, but 

such activities would probably occur on a lesser scale. Therefore, as supported by the analysis in Section 

4.1.1.1 and 4.1.1.2, effects on coyote populations would be insignificant. 

Effects on other species not targets for purposes of ORV, but which may be considered targets for 

monitoring and surveillance, contingency actions, or limited wildlife damage management

Under the no federal program alternative, the states could still conduct monitoring, surveillance, and local 

depopulation activities even without APHIS-WS assistance, but such activities would probably occur on a 

lesser scale. Therefore, as supported by the analysis in Section 4.1.1.1 and 4.1.1.2, effects on non-ORV 

target populations would be insignificant. 

4.1.2 Potential for Adverse Effects on Nontarget Wildlife Species, including Threatened or 

Endangered Species 

4.1.2.1 Alternative 1: Current Action (the No Action Alternative) 

Effects of the RABORAL V-RG® Vaccine on Nontarget Wildlife including Threatened or 

Endangered Species

A primary concern of the vaccinia virus-rabies glycoprotein combination (i.e., RABORAL V-RG® 

vaccine) is that it might cause the disease in nontarget animals that consume or contact the vaccine in baits. 

Rupprecht et al. (1992a) and Pastoret et al. (1995) summarized the results of V-RG safety trials in nontarget 

species. More than 50 species from Europe and North America have been tested which included relevant 

taxonomic groups believed to be potentially at risk for contact with the V-RG vaccine such as: 

 Natural ecological competitors of raccoons and foxes such as the opossum (Didelphis virginianus), 

several mustelids [striped skunk (Mephitis mephitis), European badger (Meles meles), mink (Mustela 

vison), North American river otter (Lontra canadensis), domestic ferret (Mustela putorius)], other 

members of the Canid family [coyote, red fox, gray fox, arctic fox (Alopex lagopus), raccoon dog 

(Nyctereutes procyonoides)], bobcat (Lynx (Felis) rufus), and American black bear (Ursus 

americanus). 
55 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

 Domestic cats (Felix domesticus) and dogs (Canis familiaris). 

 Nineteen rodent species (Order Rodentia) that might be expected to gnaw on or consume baits. 

Families within this order represented in the studies included: Muridae (old World rats and mice), 

Erethizontidae [North American porcupine (Erethizon dorsatum)], Sciuridae (Squirrels), Cricetidae 

(New World rats and mice), and Dipodidae (jumping mice – Subfamily Zapodinae). 

 One bat species [Daubenton’s bat (Myotis daubentoni)]. 

 Eight bird species, including three species of hawks [red-tailed hawk (Buteo jamaicensis), Eurasian 

kestrel (Falco tinnunculus), common buzzard (Buteo buteo)], and one species of owl [great horned 

owl (Bubo virginianus)], crow [carrion crow (Corvus corone) - similar to American crow (C. 

brachyrhynchos)], gull [ring-billed gull (Larus delawarensis)], magpie [European magpie (Pica 

pica) – similar to the once conspecific the black-billed magpie (P. hudsonia)] and jay [Eurasian jay 

(Garrulus glandarius)]. 

 Domestic livestock [cattle (Bos taurus) and sheep (Ovis ovis)]. 

 Two wild ungulate species [wild boar (Sus scrofa) and white-tailed deer (Odocoileus virginianus)]. 

 Two primate species [squirrel monkey (Saimiri sciureus) and common chimpanzee (Pan 

troglodytes)]. 

Rupprecht et al. (1992a) reported that the V-RG vaccine did not cause any mortality or morbidity (i.e., 

signs or symptoms of disease), or lesions typical of pox virus infections in over 350 individual animals 

representing some 20 taxonomic families of animals. They concluded that the extensive laboratory safety 

experiments showed V-RG to be safe in all species tested. In field trials with V-RG ORV baits to treat wild 

raccoons in which target and nontarget species were captured and tested, no vaccine-related lesions or other 

adverse effects were found to occur (Rupprecht et al. 1992a). The ORV program may, instead, actually 

reduce the likelihood of wildlife being exposed to the rabies virus. The Texas Department of Health (2007) 

concluded in their “2006 Texas Gray Fox after Action Report” that none of the 48 ORV nontarget species 

(19 coyotes, 12 striped skunks, 9 raccoons, 8 bobcats) captured within the vaccination zones exhibited 

lesions attributable to the vaccine. Other ORV nontargets observed during monitoring and surveillance 

activities within the vaccination zone had no indication of adverse reactions to the ORV baits. 

Overdosage of RABORAL V-RG® vaccine by any route or from multiple doses has not been found to 

occur in target and nontarget species. A number of nontarget species have been dosed with 2 to 10 times 

the amount of vaccine in an ORV bait without adverse effects (USDA 1991; Rupprecht et al. 1992a). 

Therefore, even if domestic animals or wildlife received multiple doses of vaccine by consuming multiple 

baits, no adverse effects would be expected to occur. 

The RABORAL V-RG® vaccine will not likely adversely affect any non-warm blooded animal species. 

The vaccinia virus and other orthopox viruses do not replicate or reproduce themselves in non-warm 

blooded species (C. Rupprecht, CDC, pers. comm. 2002 as cited in USDA 2003a). Therefore, ORV is not 

expected to cause any adverse effects on fish, reptiles, amphibians, or any invertebrate species should any 

members of these groups of species consume or otherwise be exposed to the vaccine. 

The consumption or contact with RABORAL V-RG® vaccine distributed in baits would have no adverse 

effects on any state or federally listed threatened or endangered species or their critical habitats (see 

Appendices C and D for species lists). Some listed species could be attracted to and consume the ORV 

baits, but those species will not be affected, other than possibly becoming immunized against rabies. 

The use of different vaccines is anticipated to have similar effects on nontargets as RABORAL V-RG®. 

Research tests such as Rupprecht et al. (1992) will be conducted to determine potential side-effects of new 
56 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

the new vaccine to confirm the effects to nontarget species. New vaccines may be considered for future use 

by the APHIS-WS ORV program and any environmental effects of the new vaccines on nontargets not 

analyzed in this EA will be appropriately evaluated in further environmental documentation. 

Annual reporting since preparation of the first ORV-related EA in 2001 and data analyzed for program 

activities through 2006 (USDA 2003b, 2004c, 2004d, 2005, 2007a, 2008b) indicate that nontarget 

populations have not been adversely affected by APHIS-WS actions. During this time, no reports were 

received regarding nontarget wildlife experiencing adverse reactions to baits. Therefore, we conclude that 

the RABORAL V-RG® vaccine will have no effect on nontarget species, including T&E species, because 

the baits have been extensively tested in many groups of animals with no adverse effects. Thus, the 

potential for ORV baits to adversely impact wildlife will not be considered further. 

Effects of Capture/Removal Methods (Used in Monitoring and Surveillance or to Reduce Local 

Populations of Target Species under State Contingency Plans) on Nontarget Species, including 

Threatened or Endangered Species

The methods proposed for use in raccoon rabies monitoring and surveillance areas or in implementing 

localized population reduction under state contingency actions would have no significant adverse effects on 

nontarget species. Nontarget animals captured in cage traps would normally be released unharmed unless 

the animal appeared injured or sick. Therefore, monitoring and surveillance should have no effect on 

nontarget species populations. 

Annual reporting since preparation of the first ORV-related EA in 2001 and data analyzed for program 

activities through 2006 (USDA 2008b, 2007a, 2005, 2004c, 2004d, 2003b) indicate that nontarget 

populations have not been adversely affected by APHIS-WS actions. No reports have been received 

regarding nontarget wildlife experiencing adverse reactions to baits. Nontarget wildlife species have been 

incidentally captured during ORV monitoring and surveillance efforts. A total of 3,182 nontargets were 

captured between 2006 and 2007. Most species were captured in cage traps and released unharmed (3,156 

nontargets were released out of the total capture of 3,182). Some nontarget animals were euthanized if they 

were injured or died in the trap (26 nontargets were euthanized or died in the trap out of the total capture of 

3,182 between 2006 and 2007). The nontargets that were euthanized or died were not considered to be 

from low density populations and removal was not expected to have any cumulative adverse effects on 

populations in the area. 

Table 4-6. Nontarget Species Taken by WS for the ORV program 2006-2007.

Year 2006 2007 Average 

Species Freed Killed Freed Killed Freed Killed 

Virginia Opossum (Didelphis virginiana) 1,035 5 1,186 1 1,111 3.0 

Feral Cat (Felis catus) 153 - 297 - 225 - 

Woodchuck (Marmota monax) 81 - 74 1 78 0.5 

Eastern Cottontail (Sylvilagus floridanus) 49 - 36 1 43 0.5 

Norway Rat (Rattus norvegicus) 28 - 7 1 18 0.5 

Snowshoe Hare (Lepus americanus) 2 - 30 - 16 - 

Eastern Gray Squirrel (Sciurus carolinensis) 30 1 - - 15 0.5 

Fox Squirrel (Sciurus niger) 1 2 21 1 11 1.5 

Turtle spp. 20 - - - 10 - 

Fisher (Martes pennanti) 4 - 13 - 8.5 - 

Red Squirrel (Tamiasciurus hudsonicus) 4 - - 12 2.0 6.0 

Porcupine(Erethizon dorsatum) 6 - 8 - 7.0 - 

Feral Dog (Canis familiaris) 8 - 5 - 6.5 - 

Muskrat (Ondatra zibethicus) 4 - 9 - 6.5 - 

Nine-banded Armadillo (Dasypus novemcinctus) 7 - 2 - 4.5 - 

Mink (Mustela vison) - - 7 - 3.5 - 

Eastern Chipmunk (Tamias striatus) 1 - 2 - 1.5 - 

Field Mouse spp. (Peromyscus spp) - - 3 - 1.5 - 

Cotton Rat (Sigmodon hispidus) 1 - 2 - 1.5 - 

Ruffed Grouse (Bonasa umbellus) - - 2 1 1.0 0.5 

Black Bear (Ursus amicanus) - - 2 - 1.0 - 

Red-winged Blackbird (Agelaius phoeniceus) - - 2 - 1.0 - 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Purple Finch (Carpodacus purpureus) 2 - - - 1.0 - 

House Sparrow (Passer domesticus) 1 - 1 - 1.0 - 

American Robin (Turdus migratorius) - - 2 - 1.0 - 

Beaver (Castor canadensis) 1 - - - 0.5 - 

Northern Flying Squirrel (Glaucomys sabrinus) - - 1 - 0.5 - 

Eastern Woodrat (Neotoma floridana) 1 - - - 0.5 - 

American Bittern (Botaurus lentiginosus) - - 1 - 0.5 - 

Common Grackle (Quiscalus quiscula) 1 - - - 0.5 - 

Mallard (Anas platyrhynchos) 1 - - - 0.5 - 

Wood Duck (Aix sponsa) - - 1 - 0.5 - 

Unidentified Bird 1 - - - 0.5 - 

Total 1,441 8 1,715 18 1,578 13 

From 2001 to 2005, several additional species were taken as nontargets. Most were similar to the nontarget 

or target species taken in 2006 and 2007. Other than the target and nontarget species taken and listed 

above, additional mammals trapped between 2001 and 2005 included a mountain lion, bobcat, marten, 

domestic ferret, long-tailed and least weasels, spotted skunk, and ringtail, rodents including beaver and 

black rat, and marsh rabbit. Additional birds included feral chickens, pheasants, wild turkeys, bobwhites, 

Turkey Vultures, Sharp-shinned Hawks, Red-tailed Hawks, Northern Flickers, American Crows, Blue Jays, 

Gray Catbirds, and Wood Thrush. Finally an alligator, several species of turtles, and bullfrogs have been 

taken. Most of these species were taken in cage traps and released. However, this gives the variety of 

species that can be taken, though most are taken in cage traps and released. Many of these species are 

likely taken more haphazardly (entering the trap not for the bait, but because it is there) rather than as a 

result of being attracted to the bait. 

No T&E species have been adversely affected by APHIS-WS actions during the course of the ORV 

program between 2001 and 2007. Although data regarding T&E species continues to be collected, due to 

the time needed for laboratory analysis of biological specimens collected from target species there is 

generally a one to two year period before the ORV program is able to report on all data in monitoring and 

national reports. Therefore, T&E data from 2001 through 2007 is presented in this EA. Subsequent EAs 

and monitoring reports will include T&E data from 2008 and 2009. Between 2001 and 2007, a total of five 

T&E species were incidentally captured and all five were released unharmed. In 2001, one stateendangered river otter (Lutra canadensis) was incidentally captured in a cage trap during Ohio ORV 

surveillance activities, but was released unharmed in accordance with the direction of the Ohio Division of 

Wildlife. River otter have since been delisted due to rapidly increasing numbers of the species throughout 

OHION (USDA 2007c). APHIS-WS concluded in the monitoring report (USDA 2004d) that the 

cumulative impact on nontarget species is negligible and that APHIS-WS has not adversely affected the 

viability of any wildlife species populations. One American alligator (Alligator mississippiensis) was 

incidentally captured in Florida during the 2003 ORV program and a second was captured during the 2004 

ORV program; however, both were released unharmed. The American alligator was delisted in 1987 and 

reclassified as “threatened due to similarity of appearance (T-S/A)” [50 CFR 17.42(a)] to the endangered 

crocodile and is state-listed as a species of concern in Florida. The federal designation regulates 

commercial sale and trade of alligator skins and other products. Because the animals were released 

unharmed, APHIS-WS did not violate the spirit of the “similarity of appearance” designation of the 

Endangered Species Act. In the 2006 ORV program, two Eastern box turtles (Terrapene carolina) in 

Massachusetts and one gopher tortoise (Gopherus polyphemus) in Florida were captured incidentally; 

however, all three animals were released unharmed. The Eastern box turtle is state-listed in Massachusetts 

as a Species of Concern and the gopher tortoise is state-listed in Florida as a Species of Special Concern. 

Again, APHIS-WS stated in the monitoring reports (USDA 2004c, 2005, 2008b) that the determination of 

no adverse effect is still valid for the proposed action. The report concluded that the cumulative impact on 

nontarget species is negligible and that APHIS-WS had not adversely affected the viability of any wildlife 

species populations. 

Some of the methods proposed for use in collecting target species in ORV areas have the potential for 

accidentally catching or killing nontarget animals (i.e., leghold traps or snares). Methods such as groundbased and aerial shooting would have no effect on nontarget species because they are essentially 100 

percent selective for target species. APHIS-WS has analyzed the effects on nontarget species by such 

methods in nine previous EAs which found no significant adverse effects on populations (USDA 1997a, 
58 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

1997b, 1997c, 1997d, 1997e, 1997f, 1997g, 1997h, and 1997i). 

APHIS-WS reviewed lists of federal and state T& E species (Appendices C and D) and USDA-Forest 

Service Regional Forester Sensitive Animals (Regions 8 and 9) to determine if any species might be 

affected. ORV programs or the methods used in capture/removal of target species in monitoring activities 

or contingency plan implementation would have no effect on any listed fish, invertebrate, or plant species. 

Federally Listed T&E Species (USFWS 2009): 

The ORV program has the potential to capture/take T&E species. The distribution and consumption of 

baits is expected to have no adverse effect on any species. The distribution and consumption by mammals 

is more likely to have a positive effect on mammals because a successful program will reduce the risk 

mammals contracting and dying from rabies. Although no T&E species was specifically tested for safety 

of vaccinia baits, safety studies on other species including all vertebrate classes indicate that no species will 

be affected by the baits (Rupprecht et al. 1992a). The only exception is the sensitivity to vaccines shown 

by black-footed ferrets. This particular issue will be addressed under that species’ description. However, 

surveillance and monitoring does have the potential for take. Raccoons, coyotes, and gray fox are the 

primary targeted species in surveillance and monitoring with other species such as skunks and woodchucks 

being secondarily targeted to determine the prevalence of rabies in these species and the effectiveness of 

the ORV Program and for TVR contingency actions. Cage traps, leghold traps, snares, and firearms are 

used to capture/take these species and have the potential to take T&E species. Species on the federal T&E 

list that could be taken under the proposed action with cage traps, leghold traps and snares are mammals, 

birds, reptiles, and amphibians, mostly similar in size and weight to the target species . These are discussed 

below. The use of firearms is highly target-specific and will have no effect on T&E species. 

Recently, APHIS-WS initiated formal consultation with the USFWS for those species where a “may 

affect” situation exists within the national program. Any new findings that result from this most recent 

consultation will supersede previous findings. Additionally, for those findings which are more stringent, all 

reasonable and prudent alternatives and measures required by the USFWS will be incorporated into the 

proposed program.

T&E Mammals 

A total of 35 mammals are listed under the Endangered Species Act as T&E species (Table 4-7), excluding 

marine mammals, 6 whales and 1 manatee, because these will not be affected by the current ORV program. 

The Caribbean monk seal (Monachus tropicalis) is still listed as endangered on the USFWS website, but 

has been declared extinct and was not included in this list. Additionally, 3 species have been listed as 

candidates for the T&E list, but have not officially been listed. Finally, one species is listed in some states, 

the black bear, because of a similarity of appearance to the Louisiana black bear, a separate subspecies, but 

it is not threatened or endangered. 

Although reports of rabies among carnivores other than primary reservoir host species are rare, other 

carnivorous mammals, including T&E species or closely related species, can be a source of rabies exposure 

to humans and domestic animals. A total of 2,851 cases of rabies among other carnivorous mammals of at 

least 17 different species were reported from 1960 through 2000. This total represents 1.5% of the 185,014 

wildlife cases reported during the same time period. A total of 45 otters, 40 badgers, 31 wolves, 29 

ringtails, 23 domestic ferrets, 12 coatis, 11 mink, 11 weasels, 8 fisher, 4 puma, 4 bears, and 1 ocelot tested 

positive for the rabies virus (Krebs et al., 2003). Rabies among some other carnivorous mammals has been 

regarded as a threat to the survival of certain rare or endangered species (MacDonald, 1993). An epizootic 

or rabies in Alaska was credited with decimating an entire pack of wolves in one instance (Chapman, 

1978), and on several occasions a substantial number of wolves wearing radio-collars as part of long-term 

ecological studies have died of rabies (Ritter 1991; Theberge et al., 1994; Kat et al., 1995). Therefore, 

control of rabies in raccoons, foxes, and coyotes may have a potential indirect beneficial effect of 

preventing unnecessary die-offs of T&E and other sensitive species from rabies. 
59 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

As discussed, the distribution of ORV baits will not have an adverse effect on these species. It is expected 

that the vaccination of animals, the primary target species, and potentially the T&E species, could have a 

beneficial effect on T&E mammals, especially the carnivores and ungulates which are more apt to be in 

contact with infected animals, but not be killed by them. Mammals succumb to the rabies virus, if exposed, 

unless vaccinated. The chance of a T&E mammal species being exposed in ORV treatment areas is much 

less. However, APHIS-WS does have the chance to incidentally capture T&E species during monitoring 

and surveillance. The primary methods used in the ORV monitor and surveillance program that could 

impact T&E species are cage traps, leghold traps, and snares with cage traps being used by the most. 

Table 4-7. Federally listed T&E mammals in the range of the ORV projects. 

Mammalian Species Scientific Name Status States (# - Location) ORV 

Delmarva Peninsula Fox Squirrel Sciurus niger cinereus E 4 – DE, MD, PA, VA - 

Mount Graham Red Squirrel Tamiasciurus hudsonicus grahamensis E 1 - AZ - 

Carolina Northern Flying Squirrel Glaucomys sabrinus coloratus E 2 – NC, TN - 

Gunnison's Prairie Dog (N-central NM) Cynomys gunnison C 1 – NM - 

New Mexican Meadow Jumping Mouse Zapus hudsonius luteus C 2 – AZ, NM 0 

Hualapai Mexican Vole Microtus mexicanus hualpaiensis E 1 - AZ 0 

Florida Salt Marsh Vole Microtus pennsylvanicus dukecampbelli E 1 - FL 0 

Key Largo Woodrat Neotoma floridana smalli E 1 - FL 0 

Key Largo Cotton Mouse Peromyscus gossypinus allapaticola E 1 - FL 0 

Choctawhatchee Beach Mouse Peromyscus polionotus allophrys E 1 - FL 0 

Alabama Beach Mouse Peromyscus polionotus ammobates E 1 - AL 0 

Southeastern Beach Mouse Peromyscus polionotus niveiventris T 1 - FL 0 

St. Andrew Beach Mouse Peromyscus polionotus peninsularis E 1 - FL 0 

Anastasia Island Beach Mouse Peromyscus polionotus phasma E 1 - FL 0 

Perdido Key Beach Mouse Peromyscus polionotus trissyllepsis E 2 – AL, FL 0 

Marsh Rice Rat Oryzomys palustris natator E 1 - FL 0 

New England Cottontail Sylvilagus transitionalis C 7 – NE US - 

Lower Keys Marsh Rabbit Sylvilagus palustris hefneri E 1 - FL 0 

Mexican Long-nosed Bat Leptonycteris nivalis E 2 – NM, TX 0 

Lesser :Long-nosed Bat Leptonycteris curasoae yerbabuenae E 2 - AZ, NM 0 

Virginia Big-eared Bat Corynorhinus townsendii virginianus E 4 – KY, NC, VA, WV 0 

Gray Bat Myotis grisescens E 8 – Central SE US 0 

Indiana Bat Myotis sodalis E 17 – E US 0 

Ocelot Leopardus pardalis E 2 – AZ, TX - 

Margay Leopardus wiedii E 1 - TX - 

Canada Lynx Lynx canadensis T 5 - ME, MI, NH, NY, - 

Gulf Coast Jaguarundi Herpailurus yagouaroundi cacomitli E 1 - TX - 

Sinaloan Jaguarundi Herpailurus yagouaroundi tolteca E 1 - AZ - 

Florida Panther Puma concolor coryi E 7 – SE US - 

Eastern Puma* Puma concolor couguar E/SAT 20 - E US - 

Jaguar Panthera onca E 4 – AZ, LA, NM, TX - 

Gray Wolf Canis lupus E 28 - All - 

Mexican Wolf Canis lupus baylei E/X AZ, NM/ AZ, NM - 

Red Wolf* Canis rufus E/X 1 – TX/ NC - 

Black-Footed Ferret Mustela nigripes E/X 3 –ZZ NM, TX/AZ, - 

American Black Bear Ursus americanus SAT 3 – LA, MS, TX - 

Louisiana Black Bear Ursus americanus luteolus T 3 – LA, MS, TX - 

Grizzly Bear* Ursus arctos horribilis T 2 – AZ, NM 0 

Key Deer Odocoileus virginianus clavium E 1 - FL 0 

Sonoran Pronghorn Antilocapra americana sonoriensis E 1 - AZ 0 

* Extirpated or not known to be present in State 

STATUS ORV Sampling Impacts

E - Endangered (-) - Negative 
60 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

T - Threatened 0 - none 

C - Candidate (+) - Positive 

X - Exp. nonessential pop. 

SAT =- Similarity of Appearance with T&E Spp. 

The ORV Program will have no effect on several mammalian T&E species. Several species are outside of 

the projected area of surveillance including the Florida salt marsh vole (northwest Florida along Gulf Coast 

on Cedar Key and nearby mainland coastal marshes), six subspecies of beach mice (from northeast (2 

pops.) and northwest coast Florida (4 pops.) and Alabama (this pop is in Florida too)), the Key Largo 

woodrat, Key Largo cotton mouse, silver rice rat, Lower Keys marsh rabbit, and Key deer (all 5 species in 

the Florida Keys, currently south of any possible surveillance work). The ORV program will have no 

effect on these species. The grizzly bear has been extirpated for more than 50 years from the analysis area 

with all known grizzly bears currently residing in states north of the analysis area. Although this species is 

currently listed in Arizona and New Mexico, the ORV Program will have no effect on it as the current 

distribution of grizzly bears is not known to extend into those states. The red wolf was believed to be 

extinct in the wild by 1980 with the last remaining known wolves in Texas captured for a captive breeding 

program. It is still listed in Texas. Two non-essential experimental red wolf populations (NEP) were 

designated in North Carolina and Tennessee (Parker and Philips 1991). One NEP was established in 1991 

in the Great Smokey Mountains National Park of eastern Tennessee and western North Carolina, but was 

discontinued in 1998 primarily due to poor pup survival caused by domestic dog diseases (Henry 1998). 

The other NEP began in 1987 on the Albemarle Peninsula of northeastern North Carolina near the Outer 

Banks region; this population is currently the only population of red wolves known to exist in the wild. 

Annual counts for the red wolf NEP in North Carolina has been between 100 and 130 (USFWS 2007). 

The NEPs are not located within current or anticipated ORV zones. Therefore, the ORV bait distribution 

would have no effect on this species. The 5 species of bats listed in the analysis area will not be captured 

by ORV methods, and therefore, the ORV Program will have no effect on them. Finally, it is believed that 

Sonoran pronghorn will be outside the range of the ORV Program because most efforts will be focused in 

areas away from this species around Flagstaff and southeast Arizona. Even so, this species would not be 

impacted by the small cage traps that would be used to capture skunks and other species (snares would not 

be used in occupied habitat of the pronghorn). 

On the other hand, 6 species of rodents (tree squirrels, ground squirrels, and vole), 1 rabbit, and 12 predator 

species have the potential of being taken during monitoring activities. WS maintains standard operating 

procedures to minimize risks, but as documented by Table 4-6, nontargets animals can be taken. WS may 

avoid take by refraining from using some methods in a T&E species’ occupied habitat. These species will 

be discussed with measures to minimize the potential for take. 

Tree Squirrels. Three species of tree squirrels are federally listed as endangered, the Delmarva fox 

squirrel, Mount Graham red squirrel, and Carolina northern flying squirrel. These squirrels could 

potentially be taken in cage traps, mostly being attracted to the different baits used or from curiosity. 

Leghold traps would only be used with pan-tension devices requiring an animal similar in size to the target 

species to activate the trap. Thus, it is not likely squirrels will be taken with this method. Snares could be 

used to take the primary target species, but these will not likely take and hold a squirrel. If APHIS-WS 

needed to conduct surveillance in an area where one of these species was present, APHIS-WS Specialists 

would implement measures to minimize the potential for take. Cage traps would be baited with 

unattractive baits. APHIS-WS would monitor the traps frequently and close them when the target species 

were not likely to be present (e.g., most target species are nocturnal whereas the fox and red squirrels are 

diurnal, thus, traps could be closed during daylight hours to avoid capture). If APHIS-WS uses leghold 

traps in any of these squirrels’ ranges, pan-tension devices will be used on leghold traps to preclude 

capture. If a squirrel was inadvertently captured in a cage trap, it would be immediately released unharmed 

to avoid lethal take and reported to the appropriate wildlife agency. The USFWS issued a BO (USDA 

1997, Appendix F) stating that the above mentioned tree squirrel species are not likely to be adversely 

affected by the APHIS-WS program. APHIS-WS has conducted Section 7 consultations in the range of the 

squirrels and abides by the Reasonable and Prudent Alternatives and Measures, and Terms and Conditions 

of all Biological Opinions. 

Gunnison’s Prairie Dog. The Gunnison’s prairie dog is currently a candidate for the federal T&E species 
61 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

list. The population of concern is in north-central New Mexico and south-central Colorado. Currently, no 

ORV project is being conducted in the area. However, APHIS-WS potentially could at some time expand 

to these areas in the future. Cage traps and leghold traps would possibly be used in and around prairie dog 

towns and have the potential for take; snares would probably not be used, but even so, would not likely 

capture and hold a prairie dog. APHIS-WS would avoid take by setting cage traps only at night since this 

species is diurnal and the primary target species are nocturnal or checking the traps frequently during 

daylight hours to minimize the chance of a prairie dog dying of exposure. Leghold traps would only be 

used with pan-tension devices for larger animals such as coyotes that preclude capture of prairie dogs. The 

ORV program has minimal potential for take and will not have more than a minimal chance, if that, to 

impact this population. 

Small Field Rodents. Two small field rodents, the New Mexico meadow jumping mouse (candidate) and 

Hualapai Mexican Vole (endangered), are federally listed. These two species are currently outside the 

range of ORV projects, but have the potential for being in a designated ORV area in the future, depending 

on rabies epizootics locations in the future. These species only have a slight chance of being taken and 

only in cage traps. Most cage traps would preclude capture because the small rodents could exit the traps 

through gaps in the door. However, APHIS-WS would check traps frequently in these species’ occupied 

habitat so that any individuals captured could be release unharmed. The primary concern is exposure to 

elements such as sun as they could perish. APHIS-WS will not likely take either species, but a very slight 

potential exists. 

New England Cottontail. This species, another candidate for the federal T&E species list, potentially 

could be listed in the New England states from New York to Maine in the Appalachian Mountains. The 

cottontail could be taken in a cage trap, the most likely method to be used in its range. If cage traps are used 

in its range, they will be located such to minimize exposure and checked frequently enough to release them 

alive. Leghold traps will be equipped with pan-tension devices to preclude capture. Snares are unlikely to 

be used in their range, but can be set high enough off the ground to preclude capture. Therefore, WS will 

have minimal potential to take this species and will have no impact on its population. 

Ocelot and Margay. These species are federally designated as endangered in Texas and the ocelot in 

Arizona. The margay is a Neotropical felid that ranges from northern Mexico to northern Argentina. It has 

not been recorded in Texas since one was taken in the 1850s. It is extremely unlikely this species would 

wander into portions of Texas where the ORV program is occurring. The ocelot is a medium-sized spotted 

cat that ranges from southern Texas and Arizona to northern Argentina (USFWS 1990). Although small 

populations of ocelots exist in southern Texas, populations are not known to occur in Arizona. 

Unconfirmed sightings of individual ocelots, however, have been reported infrequently in Arizona. Since 

1900, only two ocelots have been killed in Arizona in 1927 and 1931/32. Ocelots were photographed in the 

Huachuca Mountains in 1964 and 1966 (Brown and Lopez Gonzales 2001). Brown and Lopez Gonzales 

(2001) stated that ocelots should not be considered a resident animal in the American southwest. 

Krebs et al. (2003) documented one case of rabies in ocelots in the U.S. between 1960 and 1969, but none 

from 1970 to 2000. Thus, this suggests that ocelots and margays could be impacted by rabies, and benefit 

from its reduction. Therefore, APHIS-WS has determined that the proposed action would have no effect on 

this species. A potential benefit of rabies programs on ocelot and margay conservation would be a reduced 

risk of contracting and dying of rabies if the spread of rabies is successfully halted or if the variants located 

in Texas or Arizona were eliminated. 

USFWS issued a Biological Opinion (USFWS 1997) which was supplemented (USFWS 1999) and 

provided incidental take for ocelots, but believed that incidental take would be unlikely from wildlife 

damage management activities of the Texas APHIS-WS program following the Reasonable and Prudent 

Alternatives and Terms and Conditions of the BO. USFWS believed that ocelots were extirpated in 

Arizona and the margays in Texas. APHIS-WS agrees with this assertion and, therefore, believes that the 

APHIS-WS Program will not impact them in these areas However, USFWS (1999) recognized that the 

margay and ocelot could potentially wander into Texas or Arizona, respectively, but believed that no 

breeding population exists in Mexico near enough to think that it would occur frequently. USFWS issued a 

“may affect, but not likely to jeopardize” BO with reasonable and prudent alternatives and measures to 
62 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

avoid take and APHIS-WS abides by these. These measures have been successful since APHIS-WS has 

not taken an ocelot in south Texas even though a population of ocelots does occur there. 

Canada Lynx. This species was recently declared federally threatened in the states of Maine, Michigan, 

New Hampshire, New York, and Vermont (68 FR 40076-40101, July 3, 2003) in the ORV analysis area. 

The primary habitat for this species is boreal forest with an abundance of snowshoe hare (Lepus 

americanus). The only breeding population in these states occurs in northern Maine where these conditions 

exist. A potential population could also occur in New Hampshire because of its direct connectivity with 

Maine and the Canadian boreal forest. Since 1900, lynx in Vermont, New York, and Michigan have 

always existed solely as dispersers. Lynx were also historically found in Colorado where it was listed as 

well. The Colorado Division of Wildlife initiated a reintroduction program into that state prior to their 

listing in 1999 which continued thru 2006 with 218 released. These lynx, trapped in Canada and Alaska 

where they are not endangered, became listed as threatened following the transplant. Some of these lynx 

have dispersed into New Mexico where they had never been officially documented until now (especially 

common following their release). However, the lynx was not listed in New Mexico because it historically 

did not occur there (no verified records). Thus, they were not offered protection under ESA. In 2007, the 

Western Environmental Law Center, on behalf of several special interest groups, petitioned the USFWS to 

change the listing status of the Canada lynx to incorporate the southern Rocky Mountains in north central 

New Mexico. The USFWS has since announced in a Federal Register Notice (73 FR 76990-76994, 

December 18, 2008) a 90-day finding on a petition to revise the listing of the Canada lynx as threatened 

under ESA to include New Mexico. 

APHIS-WS wildlife biologists consulted USFWS on the Canada lynx in March 2001 for the northeastern 

U.S. The USFWS determined that Canada lynx are unlikely to be affected by WS wildlife damage 

management actions in the northeast. This letter states that a “not likely to adversely affect” determination 

is appropriate for APHIS-WS operation programs which was the conclusion of APHIS-WS for northeastern 

states. APHIS-WS abides by standard operating procedures to avoid take in the northeast and has not taken 

a lynx. 

The lynx in New Mexico are most likely to be encountered in the north-central part of the state. In 2002, 

New Mexico WS consulted USFWS under Section 7 of the ESA and stated that their personnel would 

abide by WS Western Region Interim Guidance Policies to avoid capture of Canada lynx until a National 

consult was completed. However, the National Consultation excluded lynx. Therefore, Colorado WS 

consulted USFWS under the ESA and was provided a BO with incidental take. Lynx, at that point, were 

not listed in New Mexico and was not included in the consultation. Even so, WS in New Mexico abides by 

the Reasonable and Prudent Measures and Alternatives of the Colorado BO to avoid take. To date, New 

Mexico WS has not taken a lynx. 

Based on a review of past capture records, APHIS-WS has determined there to be no risk to lynx from 

ORV programs, from rabies monitoring or surveillance (including the capture and testing of target animals) 

or other current APHIS-WS rabies-related activities in these states (USDA 2000). This is mostly because 

APHIS-WS has not conducted monitoring activities within occupied lynx habitat. If APHIS-WS conducts 

surveillance and monitoring in lynx occupied area, WS will only use cage traps and will check them 

frequently. Bobcats have been captured in cage traps and the potential exist for a lynx to be taken. 

Therefore, APHIS-WS determined that the proposed action has the potential to take a lynx if APHIS-WS 

conducts ORV monitoring and surveillance in their habitat, but currently will have no effect on this species. 

Florida Panther and Eastern Puma. These subspecies of mountain lion or cougar have been federally 

designated as endangered in southeast and eastern U.S., respectively. In the 1990s, the Florida panther had 

been reduced to occupying less than 5% of its original range and gene flow had stopped. Thus, cougar 

numbers were continuing to decline and were dangerously low causing the remaining population to 

continue its decline. Cougars from Texas, the closest living subspecies, were transplanted into the range to 

bolster the population without genetic swamping. This project was successful as the declining population 

increased. In 2008, the population was estimated to be around 100 cougars in southern Florida. The 

Eastern cougar was considered extinct by USFWS with no verifiable evidence such as DNA to suggest 

otherwise. Some sightings have been reported in Minnesota and Michigan recently. These individuals are 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

believed to have originated from around New Brunswick or Manitoba, Canada (per 

http://endangered.fws.gov/). In addition, a number of sightings have been reported in the Southeast 

Region, but the best evidence for a small permanent population has come from the Great Smoky Mountain 

National Park Region. Sightings have also been reported in three other North Carolina areas including the 

Nantahala National Forest, the northern portion of the Uwharrie National Forest, and the State's 

southeastern counties. However, these potential populations have not been verified. 

The potential take of these T&E species was analyzed in the 2004 supplemental EA (USDA 2004a). 

Animals the size of panthers with the exception of their kittens are not expected to be taken by the 

relatively small-sized cage traps used to capture raccoons for monitoring and surveillance purposes. Even 

so, the distribution or potential distribution of these subspecies would preclude capture by the APHIS-WS 

Program as they are not in areas where monitoring and surveillance are expected to be conducted. If 

APHIS-WS initiated a project in occupied habitat, APHIS-WS would conduct a more formal consultation 

on potential effects. Cage traps would be monitored frequently and nontargets including the cougar 

subspecies could be released. Leghold traps and snares would not likely be used in occupied habitat. 

However, APHIS-WS believes that the ORV Program will have no effect on this species considering areas 

under monitoring and surveillance. 

Jaguarundi. Two subspecies of jagaurundis are listed by USFWS as endangered, one in Texas (Gulf 

Coast subspecies) and one in Arizona (Sinaloan subspecies). A population potentially occurs in south 

Texas. The USFWS provided APHIS-WS an opinion that ORV programs in south Texas are not likely to 

adversely affect this species (Letter dated January 18, 1995, copy contained in 1995b). APHIS-WS has 

agreed to certain program restrictions (the same as and similar to those used for ocelot) on the use of certain 

methods used to collect coyotes for monitoring purposes in areas where this species might occur in order to 

avoid incidental take or jeopardy to these species, and the USFWS has issued a BO and incidental take 

statement concurring that incidental take is unlikely to occur (USFWS 1997). The USFWS also recognized 

that a potential beneficial indirect impact of ORV programs on this species would be the reduced risk of 

contracting and dying of rabies if the spread of coyote rabies is successfully halted or if the variant is 

eradicated. As far as the Sinaloan subspecies, the Arizona Game and Fish Department does not recognize 

their presence within the state as there has been no documented record of their occurrence in Arizona or the 

Mexican bordering states of Sonora, or Chihuahua (AGFD 2004b). Therefore, expansion of APHIS-WS’ 

ORV program into Arizona will have no effect on the jaguarondi in that state. 

Jaguar. This species is federally designated as endangered in Arizona, New Mexico, Texas, andLousiana. 

The jaguar’s historic range included the much of the southern U.S. from California, to Louisiana, south 

through Texas to central South America. However, the species’ current distribution only includes central 

Mexico to central South America as far south as northern Argentina. There are no known breeding 

populations in the U.S., although individuals may cross into Texas, New Mexico, and Arizona. Except for 

occasional wanderers from Mexico, the jaguar is considered extirpated from the U.S. (USFWS 1990, 

2007). McCain and Childs (2008) documented jaguars in Arizona frequently, continuously, and yearround, and videotaped several scent-marking behaviors, indicating the residency of adult jaguars within 

Arizona. After two sightings of jaguars in 1996, a camera monitoring program in southeastern Arizona was 

implemented. From March 2001 to July 2007, 9–44 trail cameras were maintained and opportunistic track 

surveys were conducted. Two adult males and a possible third unidentified jaguar were observed and 

recorded with 69 photographs and 28 sets of tracks. One jaguar, originally photographed in 1996, was 

resighted 64 times between 2004 and 2007 (McCain and Childs 2008). The USFWS (2007) recently 

concluded in a statement, however, that regular or intermittent use of the borderlands area by wide-ranging 

males, and no evidence of the presence of females or cubs, indicates that the U.S. does not support a 

separate breeding population. Therefore, actions taken within the U.S. are likely to benefit a small number 

of individual jaguars peripheral to the species’ range, with little potential to effect recovery of the species 

as a whole. Thus, the USFWS does not support development of a formal recovery plan at this time. 

APHIS-WS does not anticipate take of a jaguar because they are rare in the analysis area with only adult 

males being documented, are generally not attracted by the baits used, and are too large for most methods 

that would be used in ORV surveillance and monitoring program. It is conceivable that a jaguar cub could 

be taken, but highly unlikely. Additionally, the USFWS (1999a and b) issued a BO on the effects of the 
64 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

APHIS-WS program on the jaguar in 1999 and determined that activities by APHIS-WS were not likely to 

jeopardize the continued existence of this species. The BO contained an incidental take statement with 

reasonable and prudent measures and terms and conditions that APHIS-WS follows to minimize the risk of 

incidental take (USFWS 1999a and b). APHIS-WS personnel abide by the requirements of the BO which 

minimize further the unlikely potential for take. 

Gray and Mexican Wolf. Gray wolves, including the Mexican subspecies, are federally designated as 

endangered in all of the lower 48 states with the exception of Minnesota where they are classified as 

threatened and Northern Rocky Mountain Distinct Population Segment which was recently delisted. The 

USFWS recently issued final rules to delist both the Western Great Lakes and Northern Rocky Mountains 

Distinct Population Segments in 74 FR 15069-15123, April 2, 2009 and 74 FR 15123-15188, April 2, 2009 

respectively. The rule became effective May 4, 2009. However, in response to a legal challenge, the 

decision to delist the Western Great Lakes Distinct Population Segment was withdrawn on July 1, 2009 to 

allow for additional opportunity for public comment. No population of gray wolves is currently found in 

the ORV area with the exception of a small portion of Indiana. 

The Mexican gray wolf subspecies was extirpated from the southwestern U.S. by 1970. In 1998, the 

USFWS reintroduced the endangered Mexican gray wolf as a NEP into the Blue Range Wolf Recovery 

Area, a designated area within the subspecies’ probable historic range. The Blue Range Wolf Recovery 

Area consists of the entire Apache and Gila National Forests in east-central Arizona and west-central New 

Mexico (63 FR 1752-1772, January 12, 1998). In 1998, the USFWS issued a BO, for naturally-occurring 

wolves, and Conference Opinion, on the NEP established in Arizona and New Mexico, regarding the 

effects of the APHIS-WS program on the Mexican wolf. In the BO, the USFWS determined activities by 

APHIS-WS were not likely to jeopardize the continued existence of this species or adversely modify its 

critical habitat (USDA 1997, Appendix F; USFWS 1998). However, the use of rabies management 

methods such as leghold traps, snares, and aerial shooting have the potential to affect the gray wolf. Thus, 

Reasonable and Prudent Measures and Terms and Conditions are followed by APHIS-WS to minimize 

effects. Reasonable and Prudent Measures relating to rabies program activities include: 1) taking all 

possible precautions to reduce incidental take, 2) monitoring incidental take to ensure compliance with 

anticipated take levels (1 wolf per state per year where wolves are located), and 3) immediately releasing 

any nontarget wolves inadvertently captured alive. The current USFWS 10(j) rule published in the Federal 

Register requires APHIS-WS to discontinue use of M-44s and choking-time snares in “occupied Mexican 

gray wolf range.” Other predator management activities may be restricted or modified pursuant to a 

cooperative management agreement or conference between the USFWS and APHIS-WS ( 63 FR 1752-

1772, January 12, 1998). The USFWS is expected to complete a Mexican Wolf Conservation Assessment 

to broadly address the long term conservation needs for the Mexican wolf as public comment ended in 

March 2009. 

The ORV program would likely only use small cage traps in the range of wolves in the U.S. to preclude 

capture. However, all use of traps, including padded-jaw leghold traps, would comply with the Reasonable 

and Prudent Measures and Terms and Conditions of the B.O.s and 10j rules implemented to protect wolves. 

Any traps used would be checked frequently enough to allow release. WS does not anticipate taking any 

wolves, but the potential exists. It should be noted that Krebs et al. (2003) documented 31 cases of rabies 

in gray wolves in the U.S. between 1960 and 2000 and that the Mexican gray wolf NEP is in an area that 

has an ongoing outbreak of gray fox variant rabies. Thus, this subspecies would likely benefit from any 

reduction in rabies in Arizona and New Mexico because they have an increased potential to succumb to 

rabies. 

Black-footed Ferret (Mustela nigripes). This species is federally classified as endangered in Arizona, 

New Mexico, and Texas. However, wild populations have likely been extirpated. An experimental 

nonessential population was released in Aubrey Valley including parts of Coconino, Mohave, and Yavapai 

Counties in northwestern Arizona and has been successfully established. The USFWS issued a BO (USDA 

1997, Appendix F) that determined that cage traps and leghold traps could potentially take this species. 

WSW will not use these methods in occupied habitat. However, WS uses pan-tension devices on leghold 

traps to preclude capture and cage traps can be checked frequently enough to allow release (the proper 

authorities would be notified) in the vicinity of potential habitat for this species should it become necessary 
65 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

for a rabies project. Thus, while there is a slight risk of take, APHIS-WS does not anticipate such an 

occurrence. The BO (USDA 1997, Appendix F) did note that the take of predators in or near occupied 

habitat would likely provide beneficial effects for the ferret from a reduction in predation and disease 

transfer. It must also be noted that, although not specifically tested for safety in this species, studies on 

other mustelids including the domestic ferret (Mustela putorius) (Rupprecht et al. 1992a) indicate these 

species would not be adversely affected if they were to consume baits. However, black-footed ferrets have 

not always shown the same response to vaccines as their domestic relatives. For instance, a modified-live 

virus vaccine for canine distemper, previously shown to be safe in domestic ferrets, caused fatal distemper 

in four of six captured black-footed ferrets. In contrast, inactivated vaccines for canine distemper, although 

not as long-lasting, have shown no adverse reactions and should continue to be used for vaccinating captive 

black-footed ferrets (Williams et al. 1996). Williams et al. (1996) suggested that the use of recombinant 

vaccines also be studied for efficacy in black-footed ferrets. Because it is unclear what effect recombinant 

oral rabies vaccines could have on black-footed ferrets at this time, baiting would not be conducted in and 

around reintroduced ferret colonies in Arizona. 

Louisiana Black Bear. The Louisiana black bear and American black bear are federally listed species, 

threatened and similarity of appearance, in Louisiana, Mississippi, and Texas. This species could be taken 

with leghold traps and snares. However, these will not be used in occupied habitat. APHIS-WS was issued 

a BO for the Louisiana black bear (USDA 1997, Appendix F) and APHIS-WS abides by the Reasonable 

and Prudent Alternatives and Measures and Terms and Conditions. Thus far, these have been effective in 

minimizing take of this species APHIS-WS will continue to abide by the BO which covers the use of cage 

traps, leghold traps, and snares. APHIS-WS has taken a nontarget black bear, a cub, in a cage trap which 

was released, but not in the listed states. APHIS-WS does not anticipate taking a Louisiana black bear and 

will take measures to avoid take. 

T&E Birds 

A total of 27 birds are listed under the Endangered Species Act as federal T&E and candidate species 

(Table 4-8) in the range of the APHIS-WS proposed ORV programs. Additionally, 3 species have been 

listed as candidates for the T&E list, but have not officially been listed. 

As discussed, the distribution of ORV baits will not have an adverse effect on birds, even though some 

could potentially be eaten by a few bird species. Rabies is a mammalian disease, and birds do not acquire 

the disease or become vaccinated against the disease if they consume ORV baits. However, APHIS-WS 

could incidentally capture T&E species during monitoring and surveillance. The primary methods used in 

the ORV monitor and surveillance program that could impact T&E species are cage traps, leghold traps, 

and snares. Of these, cage traps are most often used. 

Table 4-8. Federally listed T&E birds in the range of the ORV projects. 

Bird Species Scientific Name Status States (# - Location) ORV 

Attwater's Greater Prairie-Chicken Tympanuchus cupido attwateri E 1 - TX - 

Lesser Prairie-Chicken Tympanuchus pallidicinctus C 2 – NM, TX - 

Masked Bobwhite Colinus virginianus ridgwayi E 1 - AZ - 

Brown Pelican Pelecanus occidentalis E 3 – LA, MS, TX 0 

Wood Stork Mycteria americana E 4 – AL, FL, GA, SC 0 

California Condor Gymnogyps californianus E/X 1 – 0/AZ - 

Everglade Snail Kite Rostrhamus sociabilis plumbeus E 1 - FL 0 

Bald Eagle, Southern DPS Haliaeetus leucocephalus T 1 - AZ - 

Audubon's Crested Caracara Polyborus plancus audubonii T 1 – FL 0 

Northern Aplomado Falcon Falco femoralis septentrionalis E 3 – AZ, NM, TX 0 

Yuma Clapper Rail Rallus longirostris yumanensis E 1 – AZ 0 

Mississippi Sandhill Crane Grus canadensis pulla E 1 – MS 0 

Whooping Crane Grus americana E/X 1 – TX/ - 

Piping Plover Charadrius melodus E/T 5/21– NE & Cen US 0 

Eskimo Curlew* Numenius borealis E 28 - All 0 

Red Knot Calidris canutus rufa C 14 – East US 0 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Bird Species Scientific Name Status States (# - Location) ORV 

Least Tern, Interior Population Sterna antillarum E 7 – Central US 0 

Roseate Tern Sterna dougallii dougallii E 8 – ME to NC 0 

Yellow-Billed Cuckoo, Western U.S. DPS Coccyzus americanus C 3 – AZ, NM, TX 0 

Mexican Spotted Owl Strix occidentalis lucida T 3 – AZ, NM, TX 0 

Red-Cockaded Woodpecker Picoides borealis E 9 – SE US 0 

Ivory-Billed Woodpecker Campephilus principalis E Not listed ORV area 0 

Southwestern Willow Flycatcher Empidonax traillii extimus E 3 – AZ, NM, TX 0 

Black-Capped Vireo Vireo atricapilla E 1 - TX 0 

Florida Scrub-Jay Aphelocoma coerulescens T 1 - FL - 

Bachman's Warbler* Vermivora bachmanii E 1 - SC 0 

Golden-Cheeked Warbler Dendroica chrysoparia E 1 - TX 0 

Kirtland's Warbler Dendroica kirtlandii E 1 - MI 0 

Florida Grasshopper Sparrow Ammodramus savannarum floridanus E 1 - FL 0 

Cape Sable Seaside Sparrow Ammodramus maritimus mirabilis E 1 - FL 0 

* Possibly extinct. 

STATUS ORV Sampling Impacts

E - Endangered (-) - Negative 

T - Threatened 0 - none 

C - Candidate (+) - Positive 

X - Exp. nonessential pop. 

The ORV Program will have no effect on most avian T&E species. Several species are outside of the 

projected area of surveillance including the Brown Pelican (coastal), Everglade Snail Kite (southern Fla.), 

Yuma Clapper Rail (southwest Ariz.), Mississippi Sandhill Crane, Audubon’s Crested Caracara (south 

central peninsular Fla.), Roseate Tern (coastal), Florida Grasshopper Sparrow (central peninsular Fla.), and 

Cape Sable Seaside Sparrow (southwest Fla.). The Eskimo Curlew and Bachman’s Warbler are listed in all 

and 1 state, respectively, but are likely extinct with no recent documented records of their existence; 

however, the ORV program would have no effect on these species, even so, because of habitat selection. 

Another species that is likely extirpated from (if not extinct) and no longer listed in the analysis area is the 

Ivory-billed Woodpecker; the ORV program again would have no effect on this species because of habitat 

selection. Habitat selection of mostly mudflats and wetlands by several species of birds would preclude 

many avian T&E species from being affected by the ORV program and include the Wood Stork, Red Knot, 

interior Least Tern, and Piping Plover. Diet (insectivorous/frugivorous) and habitat usage (usually stays off 

ground in trees or shrubs) precludes capture of 6 species including the small insectivorous Southwestern 

Willow Flycatcher, Black-capped Vireo, Golden-cheeked Warbler, and Kirtland’s Warbler, and the 

Western Yellow-billed Cuckoo; the Northern Aplomado Falcon takes birds and insects on wing eliminating 

them from being captured with monitoring and surveillance methods used in the ORV Program. Finally, 

the Mexican Spotted Owl lives in dense woodlands where it hunts for small mammals. The baits used in 

cage traps will not be attractive to them. The ORV Program will have no effect on these species. 

On the other hand, 8 species of birds have the potential of being taken during monitoring activities. WS 

maintains standard operating procedures to minimize risks, but as documented by Table 4-6, nontarget 

animals can be taken. WS may not use some methods in a T&E species’ occupied habitat to avoid take. 

These species will be discussed with measures to minimize the potential for take. 

Attwater’s Greater and Lesser Prairie-Chickens and Masked Bobwhite. Two species of grounddwelling, gallinaceous birds are federally listed as endangered and a third a federal candidate. These 3 

species could be potentially taken during ORV surveillance and monitoring activities. The Attwater’s 

Greater Prairie-Chicken is outside the range of current ORV activities and will not likely be taken unless 

ORV activities move. However, pan-tension devices on leghold traps in use will preclude capture of this 

and the other 2 species. Snares can be set where the prairie-chickens will not be affected and will have no 

effect on the bobwhite. Cage trap use in the range of the bobwhite (far south-central Arizona) could take 

them, but are not likely to take the prairie-chickens because of their size. The bait used will not be 

attractive to these species and are, therefore, less likely to be taken. However, if cage traps are used in the 

range of these species, they can be closed during the day to preclude capture. APHIS-WS does not 
67 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

anticipate taking any of these species, but does have minimum potential to take them. If taken, they will be 

released alive and the appropriate authority notified. 

California Condor, Bald Eagle, Whooping Crane, and Mexican Spotted Owl. The Spotted Owl and 

Bald Eagle’s southern population, are listed as threatened in the southwest, and the Whooping Crane as 

endangered in Texas. The California Condor and Whooping Crane have NEP populations in Arizona and 

much of the east. Large birds such as raptors (condor, eagle, and owl) and wading birds (crane) have the 

potential of being taken in traps and snares, but not likely in the smaller cage traps used to take the 

predators being monitored in these species’ ranges. USFWS considered these species in the 1992 BO 

(USDA 1997) and APHIS-WS follows the Reasonable and Prudent Alternatives and Measures for these 

species to avoid take. Thus, APHIS-WS believes that the ORV Program will have minimal potential to 

take any of these species. 

Florida Scrub-Jay. The Florida Scrub-Jay is currently a resident just outside the range of the ORV 

Program in Florida and is listed as a threatened species. APHIS-WS may conduct monitoring and 

surveillance in that area in the future. This species could be taken in a leghold trap without a pan-tension 

device and cage trap during monitoring and surveillance. To avoid take, APHIS-WS will use pan-tension 

devices on leghold traps in occupied habitat. For cage traps, APHIS-WS will either close traps during the 

day or monitor them frequently to avoid take. APHIS-WS believes that take is possible, but that if take 

occurs, they will be released unharmed. 

T&E Reptiles 

APHIS-WS has taken some reptiles as nontarget species during ORV operations including turtles and 

alligators. A total of 22 reptiles are listed under the Endangered Species Act as federal T&E and candidate 

species (Table 4-9) in the range of the APHIS-WS proposed ORV programs. Additionally, the American 

alligator is listed due to Similarity of Appearance with the American crocodile. Of the listed species, 

APHIS-WS believes that the species most likely to be taken are alligators and turtles with cage traps. As 

discussed, the distribution of ORV baits will not have an adverse effect on reptiles, even though some could 

potentially be eaten by a few reptile species. Rabies is a mammalian disease. Reptiles cannot be infected 

with rabies or would not be vaccinated against the disease, even if they consumed ORV baits. However, 

APHIS-WS could incidentally capture T&E species during monitoring and surveillance. The primary 

methods used in the ORV monitor and surveillance program that could impact T&E reptiles are cage traps 

and to a lesser extent snares and leghold traps. 

Table 4-9. Federally listed T&E reptiles in the range of the ORV projects. 

Reptile Species Scientific Name Status States (# - Location) ORV 

American Crocodile Crocodylus acutus T 1 - FL 0 

American Alligator Alligator mississippiensis SAT 1 - FL - 

Flattened Musk Turtle Sternotherus depressus T 1 - AL - 

Sonoyta Mud Turtle Kinosternon sonoriense longifemorale C 1 - AZ - 

Bog Turtle Clemmys muhlenbergii T 7 – NE US - 

Ringed Map Turtle Graptemys oculifera T 2 – LA, MS - 

Yellow-Blotched Map Turtle Graptemys flavimaculata T 1 – MS - 

Alabama Red-Bellied Turtle Pseudemys alabamensis E 1 – AL - 

Plymouth Red-Bellied Turtle Pseudemys rubriventris bangsi E 1 – MA - 

Gopher Tortoise Gopherus polyphemus T 2 – AL, LA - 

Dunes Sagebrush Lizard Sceloporus arenicolus C 2 – NM, TX 0 

Bluetail Mole Skink Eumeces egregius lividus T 1 - FL 0 

Sand Skink Neoseps reynoldsi T 1 - FL 0 

Copperbelly Water Snake Nerodia erythrogaster neglecta T 3 – IN, MI, OH - 

Lake Erie Watersnake Nerodia sipedon insularum T 1 - OH - 

Atlantic Salt Marsh Snake Nerodia clarkii taeniata T 1 - FL 0 

Concho Water Snake Nerodia paucimaculata T 1 - TX - 

Northern Mexican Gartersnake Thamnophis eques megalops C 2 – AZ, NM 0 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Reptile Species Scientific Name Status States (# - Location) ORV 

Eastern Indigo Snake Drymarchon corais couperi T 5 – AL, FL, GA, MS 

SC 

- 

Black Pine Snake Pituophis melanoleucus lodingi C 3 – AL, LA, MS - 

Louisiana Pine Snake Pituophis ruthveni C 2 – LA, TX 0 

Eastern Massasauga Sistrurus catenatus catenatus C 5 – IN, MI, NY, OH, 

PA 

- 

New Mexican Ridge-Nosed Rattlesnake Crotalus willardi obscurus T 2 – AZ, NM - 

STATUS ORV Sampling Impacts

E - Endangered (-) - Negative 

T - Threatened 0 - none 

C - Candidate 

SAT – Similarity of Appearance 

The ORV Program will have no effect on 7 reptilian T&E species. Four species are too small (lizards and 

skinks) or skinny (garter snakes) to be trapped. The American Crocodile (Florida Keys), Atlantic salt 

marsh snake (East coast of Florida), and Louisiana pine snake (east-central Texas-Louisian border) are 

mostly outside of the areas that are being monitored and, thus, the ORV Program will have no effect on 

them. 

American Alligator. This species was once a listed T&E species, but has made a remarkable recovery 

throughout its range with hunting seasons in some states. It is currently listed throughout its range because 

of similarity of appearance to other crocodilians. Two alligators were captured in cage traps in Florida 

during rabies monitoring and surveillance, one in 2003 and one in 2004. Both were released unharmed per 

the appropriate Florida wildlife agency. APHIS-WS uses cage traps almost exclusively in its range, but 

could potentially use snares and leghold traps. Thus, alligators could be captured in cage traps but are 

much less likely to be captured in snares and leghold traps. In most all cases, any alligator caught should 

be able to be released. Thus, the ORV Program would have minimal potential to impact this species. Even 

if APHIS-WS did accidentally lethally take an alligators, their population would not be impacted. Any 

alligator taken would be reported to the appropriate wildlife agencies. Thus, APHIS-WS will not have an 

adverse impact on this species. 

Turtles. Eight species of turtles, including the gopher tortoise, are federally listed T&E, and candidate 

species. Though most are not in the range of surveillance activities, they could be and have the potential to 

be caught in cage traps, especially those that walk frequently over land, such as the gopher tortoise. The 

more water dwelling species, the other 7, are less likely to be trapped because they are strongly aquatic and 

do not venture far from the security of their wetland habitats. However, turtles have been taken in cage 

traps by the APHIS-WS ORV Program as nontargets (mostly box turtles). Because of their size and height, 

leghold traps and snares are highly unlikely to capture them. Thus far, APHIS-WS has released all turtles 

taken. If, per chance, a listed T&E turtle were captured, the appropriate regulatory agency would be 

notified and the turtle would be released or turned over to the agency per their direction (they may want to 

take measurements and radio-track some turtle species). It is highly unlikely that a turtle would be taken 

lethally. However, when APHIS-WS is working within the range of a T&E turtle species, cage traps will 

be monitored frequently to ensure that the turtles are released quickly, nullifying the risk of lethal take. 

APHIS-WS believes that it will have no adverse impact on turtle populations. 

Snakes. A few snakes, primarily the larger adults, could be trapped and held in cage traps because they are 

too large to exit the wire mesh. Smaller snakes could get out because the wire mesh would not hold them. 

Large adults that enter a cage trap and set it off prior to having their entire body being inside, could also 

escape by following their tail back under the cage trap-door (not uncommon). However, some could 

potentially be caught. However, no snakes were taken by the APHIS-WS ORV Program from 2000 to 

2007, suggesting the unlikelihood of such an occurrence. APHIS-WS believes that it is highly unlikely that 

a T&E species of snake will be taken, but if one is, the appropriate agency will be notified and the snake 

released, APHIS-WS believes that it will have no adverse effect on any T&E species of snake. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

T&E Amphibians 

APHIS-WS has taken a few larger amphibians, mainly bullfrogs. It is possible that APHIS –WS could take 

toads and larger frogs as nontarget species during ORV operations in cage traps. A total of 17 amphibians 

are federally listed as T&E or candidate species (Table 4-10). APHIS-WS believes that it will have no 

effect on any of these species. The only species that possibly could be taken would be the Houston toad. 

However, APHIS-WS does not conduct monitoring and surveillance in its range and does not anticipate 

doing so. 

As discussed, the distribution of ORV baits will not have an adverse effect on amphibians, even though 

some could potentially be eaten by a few species. Rabies is a mammalian disease. Amphibians cannot be 

infected with rabies or would not be vaccinated against the disease, even if they consumed ORV baits. 

Table 4-10. Federally listed T&E amphibians in the range of the ORV projects. 

Amphibian Species Scientific Name Status States (# - Location) ORV 

Black Warrior Waterdog Necturus alabamensis C 1 - AL 0 

Frosted Flatwoods Salamander Ambystoma cingulatum E 4 – AL, FL, GA, SC 0 

Sonora Tiger Salamander Ambystoma tigrinum stebbinsi E 1 - AZ 0 

Cheat Mountain Salamander Plethodon nettingi E 1 - WV 0 

Shenandoah Salamander Plethodon shenandoah E 1 - VA 0 

San Marcos Salamander Eurycea nana T 1 - TX 0 

Barton Springs Salamander Eurycea sosorum E 1 - TX 0 

Austin Blind Salamander Eurycea waterlooensis C 1 - TX 0 

Georgetown Salamander Eurycea naufragia C 1 - TX 0 

Jollyville Plateau Salamander Eurycea tonkawae C 1 - TX 0 

Salado Salamander Eurycea chisholmensis C 1 - TX 0 

Texas Blind Salamander Typhlomolge rathbuni E 1 - TX 0 

Houston Toad Bufo houstonensis E 1 - TX 0 

Arizona Treefrog, Huachuca/Canelo Pop. Hyla wrightorum C 1 - AZ 0 

Chiricahua Leopard Frog Rana chiricahuensis T 2 – AZ, NM 0 

Relict Leopard Frog Rana onca C 1 - AZ 0 

Mississippi Gopher Frog Rana capito sevosa E 3 – AL, LA, MS 0 

STATUS ORV Sampling Impacts

E - Endangered (-) - Negative 

T - Threatened 0 - none 

C - Candidate 

State Listed Species (USFWS 2009b, NMDGF 2008a, AGFD 2007b6

 ): 

APHIS-WS is also concerned with the take of state listed T&E and sensitive (includes only species in the 

S1 (imperiled) or S2 (vulnerable) categories) species (species listed obtained from state agency websites), 

but does not believe that the APHIS-WS ORV Program will have more than a minor impact on any listed 

species. From 2000 to 2007, APHIS-WS has trapped thousands of animals for monitoring and 

surveillance, but has lethally taken only a handful of nontarget species (Table 4-6) where more than one 

was taken in a year. Those nontargets taken lethally have been representatives from 3 groups of mammals: 

the carnivores, rodents, and lagomorphs. Other vertebrates could be taken lethally by APHIS-WS, but it is 

anticipated that this will be no more than a few, at most, in any given year. This take will not have an 

impact on any species, including state listed T&E species. APHIS-WS will consult with states and provide 

them information on any listed species taken during ORV monitoring and surveillance, but believes that 

any take will be minimal enough not to have more than a minor impact on any population. As discussed 

above for federal T&E species impacts, APHIS-WS believes that the consumption of ORV baits will have 

no effect on state listed species, but the overall effect of the program will be beneficial if the prevalence of 

 

6 The state of Arizona does not have a separate state listing for threatened or endangered species and instead uses the USFWS federal 

listing of protected species in Arizona. Arizona designates these protected species as Wildlife of Special Concern (WSC). 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

rabies is reduced. 

APHIS-WS has the potential to take some State listed T&E and sensitive species. APHIS-WS believes, 

though, that state listed species from the following groups will not be impacted, except potentially very 

minimally, and, therefore, will not be discussed further including some mammals (bats, insectivores 

(moles/shrews), and ungulates (deer)), birds, reptiles, amphibians, invertebrates, and plants. APHIS-WS 

believes that if APHIS-WS does have any potential to impact species it would be from the following groups 

of mammals: the rodents, lagomorphs, and carnivores. Table 4-11 lists all species in these groups that are 

state listed T&E or sensitive (those listed as S1 and S2 only and not including S3 - rare) species. The 

following list does not include those species that are federally listed as these were discussed above. 

Table 4-11. State listed T&E and sensitive (S1, S2) mammals in the range of the ORV projects. 

Mammalian Species Scientific Name Status States (# - Location) ORV 

Goat Peak Pika Ochotona princeps nigrescens P NM 0 

Appalachain Cottontail Sylvilagus obscurus P AL, GA - 

Swamp Rabbit Sylvilagus aquaticus E IN, SC - 

Snowshoe Hare Lepus americanus E OH, NM, VA - 

White-tailed Jackrabbit Lepus townsendii campanius P NM 0 

White-sided Jackrabbit Lepus callotis T NM - 

Plains Pocket Gopher Geomys bursarius P IN 0 

Southeastern Pocket Gopher Geomys pinetis T GA 0 

Southern Pocket Gopher Thomomys umbrinus T NM 0 

American Porcupine Erethizon dorsatum P MD - 

Houserock Valley Chisel-toothed Kangaroo Dipodomys microps leucotis P AZ - 

Texas Kangaroo Rat Dipodomys elator T TX - 

Woodland Jumping Mouse Napaeozapus insignis P OH 0 

Southern Rock Vole Microtus chrotorrhinus carolinensis E/P MD, VA/NC, TN, VT, - 

Navajo Mexican Vole Microtus mexicanus navaho P AZ - 

Arizona Montane Vole Microtus montanus arizonensis E NM - 

Prairie Vole Microtus ochrogaster E/P MI/AL, NM - 

Red-backed Vole Myodes gapperi P OH, SC - 

Round-tailed Muskrat Neofiber alleni T GA - 

Western/Eastern Harvest Mouse Reithrodontomys megalotis/humulis P IN/WV 0 

Northern/Southern Bog Lemming Synaptomys borealis/cooperi T/P ME/CT, MA, RI, WV - 

Northern Pygmy Mouse Baiomys taylori P NM 0 

Eastern/Southern Appalachian Woodrat Neotoma floridana floridana/haematoeia P NC/TN - 

Allegheny Woodrat* Neotoma magister T/E/P NE US 1/5/3 States - 

Golden Mouse Ochrotomys nuttali P WV 0 

Palo Duro Mouse Permyscus truei comanche T TX 0 

Buxton Woods/Pungo White-footed Mouse Peromyscus leucopus buxtoni/easti P NC 0 

Coleman’s Oldfield Mouse Peromyscus polionotus colemani P NC 0 

Coue’s Rice Rat Oryzomys couesi T TX - 

Camp Verde Cotton Rat Sigmidon arizonae arizonae P AZ - 

Yellow-nosed Cotton Rat Sigmidon ochrognathus P NM - 

Arizona Gray Squirrel Sciurus arizonensis arizonensis P NM - 

Big Cypress/Sherman’s Fox Squirrel Sciurus niger avicennia/shermani T/P FL 0 

Abert’s Squirrel Sciurus aberti chuscensis/kaibabensis P NM/AZ 

West Virginia Northern Flying Squirrel Glaucomys sabrinus fuscus P WV - 

Franklin’s Ground Squirrel Spermophilus franklinii E IN - 

Black-tailed Prairie Dog Cynomys ludovicianus P AZ/NM - 

Eastern Chipmunk Tamias striatus P FL 

Organ Mtns/Oscura Mtns Colorado Chipmunk Tamias quadrivittatus australis/ oscuraensis T NM - 

Peñasco Least Chipmunk Neotamias minimus atristriatus E NM - 

Bobcat Lynx rufus T/E/P MA/NJ, OH/IN - 

Swift Fox Vulpes velox velox P NM - 

American Black Bear Ursus americanus (FL – subspp. floridanus) T/E/P FL/OH, TX/AL - 

Eastern Spotted Skunk* Spilogale putorius E/P AL, MD, WV - 

Ermine Mustela erminea P OH - 
71 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Mammalian Species Scientific Name Status States (# - Location) ORV 

Least Weasel Mustela nivalis P IN, MD, TN - 

American Marten Martes americana T/E NH, NM/VT - 

Everglades Mink Neovison vison evergladensis T FL 0 

American Badger Taxidea taxus P IN, OH - 

North American River Otter Lontra canadensis P AZ, IN - 

White-nosed Coati Nasua narica E/P TX, NM - 

STATUS ORV Sampling Impacts

E - Endangered (-) - Negative 

T - Threatened 0 - none 

P- Protected (Sensitive S1 & S2 spp.) (+) – Positive 

* States = PA/IN, MD, NJ, NY, OH/CT, IN, NC

A few of the state listed T&E and sensitive species (Table 4-11) will be unaffected by the APHIS-WS 

Program. This includes species outside the expected range of monitoring (pika ,white-tailed jackrabbit, the 

Sherman and Big Cypress fox squirrels, and Everglades mink), dominantly fossorial (underground) species 

(plains, southeastern, and southern pocket gophers) and species too small to be held by cage traps or other 

monitoring methods (woodland and meadow jumping mice, western and eastern harvest mice, northern 

pygmy mouse, and golden, Palo Duro. white-footed, and Coleman’s oldfield mice). These will not be 

discussed further. As discussed, ORV is not expected to cause any adverse effects on any of the sensitive 

species listed (Ruprecht et al.1992a). It is expected that the vaccination of wild animals, including the 

primary target species and, potentially, the T&E species, could have a beneficial effect on T&E mammals, 

especially the carnivores and ungulates which are more likely to be in contact with infected animals. 

Mammals succumb to the rabies virus, if exposed, unless vaccinated. The chance of a T&E mammal 

species being exposed in ORV treatment areas is much less. However, APHIS-WS does have the potential 

to incidentally capture T&E species during monitoring and surveillance. The primary methods used in 

ORV monitoring and surveillance programs that could impact T&E species are cage traps, leghold traps, 

and snares with cage traps used to capture target species. 

Rabbits. Four state listed species of rabbits are found in the ORV area that could potentially be in a 

surveillance area. These species could be taken in cage traps, leghold traps, or snares. If cage traps are 

used in their ranges, they will be located such to minimize exposure and checked frequently enough to 

release them alive. Leghold traps will be equipped with pan-tension devices to preclude capture. Snares 

will be elevated off the ground high enough to minimize potential exposure especially for cottontails or not 

set in areas where they would likely be taken. Therefore, WS will have minimal potential to take these 

species and will have virtually no impacts on their populations. 

American Porcupine and Round-tailed Muskrat. The porcupine is common in the United States, but a 

species of concern in Maryland. The round-tailed muskrat, a small relative of the common muskrat, has a 

limited range in Georgia and much of Florida. It is listed as threatened in Georgia. The method of capture 

most likely to be used in these two species’ ranges is the cage trap which has the potential to capture either 

species. Cage traps will be checked frequently enough and placed in areas to minimize exposure to reduce 

the potential for lethal take. If one or the other was inadvertently captured in a cage trap, it would be 

released unharmed to avoid lethal take and reported to the appropriate state agency. Therefore, the 

proposed action should have negligible potential to impact these populations in Maryland and Georgia. 

Small Field Rodents. Several field rodents are large enough to be captured in cage traps and include 

kangaroo rats, voles, muskrats, lemmings, woodrats, rice rats, and cotton rats with 17 species and 

subspecies that could potentially be taken, but only in small wire-mesh or enclosed cage traps used for 

monitoring smaller predators (e.g., spotted skunks). These species only have a slight chance of being taken 

even in cage traps because the small rodents could exit the traps through gaps in the door. The primary 

concern with these species is exposure to the elements such as excessive sun/heat as this could result in a 

lethal take. However, APHIS-WS would check traps frequently in these species’ occupied habitat so that 

any individuals captured could be release unharmed. APHIS-WS will not likely take these species, but a 

very slight potential exists. 

Tree/Ground Squirrels. Nine species of tree and ground squirrels, including chipmunks, are state listed 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

as T&E or sensitive species (Table 8). These species could potentially be taken in cage traps, mostly being 

attracted to the different baits used or from curiosity. Leghold traps would only be used with pan-tension 

devices requiring a heavier animal to activate the trap. Thus, it is not likely squirrels will be taken with this 

method. Snares could be used to take the primary target species, but these will not likely take and hold a 

squirrel. If APHIS-WS needed to conduct surveillance in an area where one of these species was present 

(many are currently outside surveillance areas), APHIS-WS Specialists would implement measures to 

minimize the potential for take. Cage traps would be baited with unattractive baits, though squirrels are 

often attracted to a wide variety of baits. APHIS-WS would monitor the traps frequently and may close 

them when the target species were not likely to be present (e.g., most target species are nocturnal whereas 

the fox and red squirrels are diurnal, thus, traps could be closed during daylight hours to avoid capture). If 

APHIS-WS uses leghold traps in any of these squirrels’ ranges, pan-tension devices will be used on leghold 

traps to preclude capture. If a squirrel was inadvertently captured in a cage trap, it would be immediately 

released unharmed to avoid lethal take and reported to the appropriate wildlife agency, if listed as T&E. 

Black-tailed Prairie Dog. The black-tailed prairie dog is listed as a sensitive species. Cage traps and 

leghold traps would possibly be used in or around prairie dog towns and have the potential for take; snares 

would probably not be used because prairie dogs are not found in habitat conducive for setting snares, but 

even so, would not likely capture and hold a prairie dog. APHIS-WS would avoid lethal take by checking 

the traps frequently during daylight hours to minimize the chance of a prairie dog dying of exposure. 

Leghold traps would only be used with pan-tension devices for larger animals such as coyotes that preclude 

capture of prairie dogs. The ORV program has minimal potential for take and will not have more than a 

minimal chance, if that, to impact this population. 

Bobcat. The bobcat is state-listed in five northeastern states (Table 4-11). While bobcats are not likely to 

be attracted to lures used for raccoons and other predators, they potentially could be. Additionally, they 

may investigate new things in their environment. From 2001 to 2007, APHIS-WS captured an average of 

about 4 bobcats annually as targets and nontargets throughout the ORV area (excluded Arizona and New 

Mexico). Those captured as nontargets were released unharmed. Thus, they could be captured in cage 

traps, leghold traps, and snares. Northeastern states generally use cage traps to capture raccoons for 

surveillance, but could use other methods should a species, such as the coyote, which is extremely difficult 

to lure to a cage trap was targeted. In areas where bobcats are listed, APHIS-WS will ensure that cage traps 

and leghold traps are checked frequently to ensure prompt release of bobcats and that traps are placed in 

areas, as possible, to ensure that bobcats do not die from exposure. It should be noted that some bobcats 

may be targeted during surveillance, primarily in states where they are not listed. However, even so, the 

APHIS-WS ORV Program will have no adverse effects on their population. 

Swift Fox. This species, a small fox, is listed as a species of conservation concern in New Mexico. It 

could be taken as a nontarget with cage traps, leghold traps, and snares during ORV surveillance activities. 

To minimize take, cage traps will be checked frequently and placed in areas not exposed to harsh elements 

as possible. Pan-tension devices will be used on traps to exclude capture of smaller predators. Neck snares 

will be used at a minimum in the swift fox range. This species was analyzed in the New Mexico Predator 

Damage Management EA (2006) and it was concluded that the take of up to 100 cumulatively (sportsman 

harvest and WS take) would have no noticeable effect on the population, estimated at almost 14,000 for 

New Mexico. Thus, even if WS took a few (some may be targeted in rabies areas), it is doubtful that the 

population would be impacted to any extent. Therefore, APHIS-WS believes that the ORV Program will 

not have a noticeable effect on the swift fox population. Of all species, this species would likely 

experience a very noticeable positive effect from the reduced spread of rabies. 

Black Bear/Florida Black Bear. Black bears, including the Florida subspecies, are listed in 4 states as 

T&E or sensitive species. Precautions will be taken in these states similar to those taken for the Louisiana 

black bear described in the previous section. The APHIS-WS ORV Program will not adversely impact this 

species, including the Florida subspecies because take will be minimal. It should be noted that the black 

bear population in the eastern United States is expanding and growing, with several states now having more 

frequent damage problems associated with the increase. 

Eastern Spotted Skunk. This species is state-listed as a sensitive species in Alabama, Maryland, and 
73 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

West Virginia. This species is taken as a target or nontarget infrequently (2 from 2001-2007) due to its 

rarity in most areas where APHIS-WS has been conducting ORV surveillance. However, it is attracted to 

baits often used in cage traps, the most prevalent method used to take species in the raccoon rabies strain 

surveillance area. APHIS-WS personnel will check cage traps frequently and keep them in areas where 

animals captured are not exposed to the elements. Leghold traps will be fitted with pan-tension devices 

where appropriate (e.g., in area where smaller mammals are not being targeted, including the spotted 

skunk). Neck snares would not likely capture this species, unless they were of smaller gauge wire for 

smaller animals. However, this method is rarely used. This species, along with the other skunks, frequently 

contract rabies and, therefore, are monitored and taken as targets. However, APHIS-WS will not have 

more than a minor effect on their populations, including those states where they are listed as sensitive. 

Ermine and Least Weasel. These two small weasels are listed in Ohio, and Indiana, Maryland and 

Tennessee as sensitive species, respectively. These species could be taken in cage traps, but will be 

precluded from capture in leghold traps with pan-tension devices and larger neck snares. Cage traps in 

their range will be checked frequently and placed in areas that limit exposure to minimize the potential for 

lethal take. In fact, from 2001 to 2007, APHIS-WS took 2 least weasels (no ermine) in cage traps, but both 

were released. Therefore, APHIS-WS had no impact from lethal take on these species for the 7 year 

period. APHIS-WS expects not to have more than a minimal effect, if any, on their populations. 

American Marten. This species is state-listed as threatened in New Mexico. It is conceivable that this 

species could consume ORV baits intended for gray foxes. Although not specifically tested for safety in 

this species, safety studies on other closely related Mustelid species (e.g., skunk, mink, badger, ferret, and 

otter) (Rupprecht et al. 1992) indicate martens would not be adversely affected if they were to consume 

ORV baits. If a marten was inadvertently captured in a trap set for the target species, it would be released 

unharmed to avoid lethal take and reported to the appropriate state agency to complement their population 

monitoring data for this state-listed species. An indirect benefit of rabies management programs would be 

a reduced risk of the species suffering further declines due to a rabies epizootic. Therefore, the proposed 

action should have no significant impact on this species. 

American Badger. This large mustelid is listed as a sensitive species in Indiana and Ohio, the eastern 

most part of their range. Within the ORV area their range includes only Indiana, Ohio, Arizona, New 

Mexico, and Texas. This species could be taken with any method used by the APHIS-WS ORV program. 

However, none were taken by APHIS-WS from 2001 to 2007 including Texas where they are most 

common. As with other predators, APHIS-WS will check traps and snares often to release badgers alive 

and keep them in areas, as possible, where they are not exposed to the elements. Badgers are often freed 

from cage and leghold traps. Neck snares generally do not take badgers as their posture is low to the 

ground. APHIS-WS believes that few, if any, will be taken in Indiana or Ohio where they are listed. 

River Otter. The river otter is listed in Arizona and Indiana as a sensitive species. The Arizona Game and 

Fish Department reintroduced a Louisiana subspecies (Lontra canadensis lataxina) into central Arizona 

(Verde River drainage) during 1981-1983. Though a debated subspecies, the Southwestern river otter (L.c. 

sonrae), is considered extirpated from Arizona and New Mexico. Some believe, with undocumented 

sightings, that they still could potentially persist in the lower Colorado River (AGFD 2002). It was 

believed to have inhabited the Colorado and Gila rivers and their major tributaries, but current distribution 

is uncertain. The Southwestern river otter was originally state-listed as endangered in New Mexico; 

however, in 1975 it was removed from listing as the subspecies was considered extirpated throughout its 

historic range. It is now classified as a protected furbearer with a closed season in New Mexico with the 

State reintroducing Northern river otters from Oregon (NMDGF 2008). The New Mexico Department of 

Game and Fish (NMDGF) and cooperating special interest groups are currently in the process of 

reintroducing otters into the Upper Rio Grande (NMDGF 2008, 2006), which is located within the current 

outbreak of gray fox variant rabies. Krebs et al. (2003) documented 45 cases of rabies in otters in the U.S. 

between 1960 and 2000. Thus, an indirect benefit of rabies management programs would be a reduced risk 

of the species suffering further declines because of a rabies epizootic. Therefore, the proposed action 

should have no significant adverse impact on this species. 

White-nosed Coati. This species is state-listed as an endangered species in Texas and is state-listed as 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

sensitive in New Mexico. It could be taken as a nontarget with cage traps, leghold traps, and snares during 

ORV surveillance activities. To minimize take, cage traps will be checked frequently and placed in areas 

not exposed to harsh elements as possible. Pan-tension devices will be used on traps to exclude capture of 

larger predators. Neck snares will be used at a minimum in their range. According to ADHS (2007) eight 

coatis were found positive for rabies in Arizona between 1968 and 1977 and Krebs et al. (2003) 

documented 12 cases of rabies in coatis between 1960 and 2000. In March, 2008 a coati tested positive for 

rabies in Pinal County, Arizona (KVOA NEWS 2008). Thus, an indirect benefit of rabies management 

programs would be a reduced risk of the species suffering further decline because of a rabies epizootic. 

Therefore, the proposed action should have no significant impact on this species. 

USFS and BLM Sensitive Species (USDA 2008c): 

USFS and BLM list several species as sensitive and monitor the presence of these species on their lands. 

Most of the species have been discussed above (e.g. river otter, bobcat, marten, black bear, badger, wolf, 

spotted skunk, and mink). However, several additional species such as yellow-bellied marmots (Marmota 

flaviventris), Mexican fox squirrel (Sciurus nayaritensis chiricahuae), and others are also listed. APHISWS has reviewed the lists of USFS (USDA 2008c, 2007d, 2001c) and BLM (USDI 2007, 2005, 1999) 

sensitive species and has determined that the ORV Program will have no effect on these species. Although 

few of the sensitive species were specifically tested for the safety of vaccinia baits, safety studies on other 

species including all vertebrate classes indicate that no species will be adversely affected by the baits 

(Rupprecht et al. 1992a). As discussed, the distribution of ORV baits will not have an adverse effect on 

these species. It is expected that the vaccination of animals, the primary target species, and potentially the 

T&E species, could have a beneficial effect on T&E mammals, especially the carnivores and ungulates 

which are more likely to be in contact with infected animals, but not be killed by them. Mammals succumb 

to the rabies virus, if exposed, unless vaccinated. The chance of a T&E mammal species being exposed in 

ORV treatment areas is much less. However, APHIS-WS does have the chance to incidentally capture 

sensitive species during monitoring and surveillance. The primary methods used in the ORV monitoring 

and surveillance programs that could impact USFS and BLM sensitive species are cage traps, leghold traps, 

and snares with cage traps. However, most of the nontarget species taken will be released at the capture 

site. Thus APHIS-WS does not anticipate having more than a minimal effect on any species.

4.1.2.2 Alternative 2: Proposed Action (the Preferred Alternative) 

Effects of the RABORAL V-RG® Vaccine on Nontarget Wildlife including Threatened or 

Endangered Species

As with monitoring and surveillance activities, Contingency Actions 1-5 are also expected to have a 

negligible adverse risk or effect on nontarget wildlife. Contingency Action 2 (treatment with increased bait 

density to ensure sufficient baits for high density of target species or to bolster antibody response under 

“normal” target species densities) and Contingency Action 3 (increase baiting frequency more than 

once/year) utilize ORV. As discussed in Section 4.1.3.1, more than 50 wildlife species from Europe and 

North America have been tested, including relevant taxonomic groups believed to be potentially at risk for 

contact with the RABORAL V-RG® vaccine. Rupprecht et al. (1992a) reported that the V-RG vaccine is 

safe in all species (more than 350 individual animals) tested to date. In addition, there is no evidence of 

potential harm to target or nontarget species from overdosage of V-RG vaccine by any route or from 

multiple doses (Rupprecht et al. 1992a). Few nontarget species are likely attracted to the ORV baits, and 

the few carnivore species that might consume baits would be expected to experience no effect other than 

possibly becoming immunized against rabies. The ORV program may instead reduce the likelihood of 

rabies virus exposure by wildlife, including protected species. 

New vaccines may be considered for future use by the APHIS-WS ORV program and any environmental 

effects of the new vaccines on nontargets not analyzed in this EA will be appropriately evaluated in further 

environmental documentation. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Effects of Capture/Removal Methods (Used in Monitoring and Surveillance or to Reduce Local 

Populations of Target Species under State Contingency Plans) on Nontarget Species, including 

Threatened or Endangered Species

Contingency Action 1 involves enhanced surveillance, which may include capture and release or euthanasia 

of specific nontarget animals for rabies testing. Nontarget wildlife species have been incidentally captured 

during ORV monitoring and surveillance efforts. As discussed above, over 6 years of data for the ORV 

program indicate that 88% of nontargets (9,051 nontargets were released out of the total capture of 10,304) 

were released at the site of capture. The remaining (12%) nontargets were euthanized for rabies diagnostic 

testing, if they were sick, injured, or were demonstrating strange behavior symptomatic of the rabies virus. 

The nontargets that were euthanized were not considered to be from low density populations and removal 

was not expected to have any cumulative adverse effects on populations in the area. Any T&E species 

incidentally trapped during surveillance activities were released unharmed. Therefore, nontarget 

populations would not be adversely affected by trapping methods used during enhanced surveillance. 

Contingency Action 5 (localized target species population reduction). Some of the methods proposed for 

use in collecting target species within ORV zones or other contingency action locations have the potential 

for accidentally catching or killing nontarget animals (i.e., cage traps, leghold traps, or snares). However, 

measures such as size or location of traps and types of baits used help to minimize the potential for 

capturing nontargets. Methods such as ground-based and aerial shooting have no effect on nontarget 

species as they are essentially 100 percent selective for target species. APHIS-WS has analyzed the effects 

on nontarget species by such methods in numerous EAs, including this EA, which found no significant 

adverse effects on populations (USDA 2004a, USDA 1997b-j). 

Contingency Action 4 (TVR of targets and specific nontargets, such as skunks and feral cats that are known 

to harbor and transmit rabies) involves the use of a parenteral (injectable) vaccine, such as IMRAB® 3, 

which can be used “off label” under the direction of veterinarians to vaccinate healthy wildlife. 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 if incidentally 

captured during TVR activities. Healthy nontarget animals that are vaccinated should exhibit no effect 

other than becoming immunized against rabies. The majority of nontargets would be released at the site of 

capture, 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 of the rabies virus. 

Some of the methods proposed for use in collecting target species within ORV zones or other contingency 

action locations have the potential for accidentally catching or killing free-roaming, domestic animals (i.e., 

cage traps, leghold traps, or snares). However, measures such as size or location of traps and types of baits 

used help to minimize the potential for capturing nontargets, including domestic animals. Methods such as 

ground-based and aerial shooting have no effect on nontarget species as they are essentially 100 percent 

selective for target species. APHIS-WS has analyzed the effects on nontarget species by such methods in 

numerous EAs, including this EA, which found no significant adverse effects on populations (USDA 

2004a, USDA 1997b-j). Pets and other domestic animals captured incidentally in traps would either be 

released at the site of capture or brought to the local animal control shelter. 

4.1.2.3 Alternative 3: Live-Capture-Vaccinate-Release Alternative 

Effects of the RABORAL V-RG® Vaccine on Nontarget Wildlife including Threatened or 

Endangered Species

Under a live-capture-vaccinate-release alternative, it is expected that little or no ORV use by the states 

would occur. Thus, there would be no potential for the V-RG oral vaccine to affect nontarget species. 

Live-capture-vaccinate-release programs would be virtually 100 percent selective for target species and 

would therefore have little or no potential to affect nontarget wildlife. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Effects of Capture/Removal Methods (Used in Monitoring and Surveillance or to Reduce Local 

Populations of Target Species under State Contingency Plans) on Nontarget Species, including 

Threatened or Endangered Species

Under this alternative, APHIS-WS would continue to assist in monitoring activities and, potentially, in 

localized contingency plans that involve the use of lethal methods such as those discussed under the 

proposed action. The potential for effects on nontarget species would be similar to the current and 

proposed actions. The analysis in Sections 4.1.2.1 and 4.1.2.2 shows that effect on nontarget and T&E 

species would be negligible. 

4.1.2.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal Removal Programs 

Alternative 

Effects of the RABORAL V-RG® Vaccine on Nontarget Wildlife including Threatened or 

Endangered Species

Effects of the V-RG vaccine on nontarget wildlife would be the same as under the current and proposed 

actions. The analysis in Sections 4.1.2.1 and 4.1.2.2 showed that adverse effects are unlikely. However, 

more animals are likely to die of rabies if the lack of federal assistance in monitoring and surveillance 

results in a reduction in the effectiveness of ORV programs. 

Effects of Capture/Removal Methods (Used in Monitoring and Surveillance or to Reduce Local 

Populations of Target Species under State Contingency Plans) on Nontarget Species, including 

Threatened or Endangered Species

Under this alternative, APHIS-WS would not continue to assist in monitoring activities or local 

depopulation activities that involve the use of lethal methods such as those discussed under the proposed 

action. Therefore, the potential for adverse effects on nontarget species would be even lower than under 

the proposed action. States would still likely implement monitoring and localized population reduction 

actions even without APHIS-WS, but such activities would likely be on a lesser scale without APHIS-WS 

funds. However, the analysis in Sections 4.1.2.1 and 4.1.2.2 indicates that the effects on nontarget and 

T&E species would not be significant under the proposed action and would likely also not be significant 

even without APHIS-WS assistance. 

4.1.2.5 Alternative 5: No Federal Program Alternative 

Effects of the RABORAL V-RG® Vaccine on Nontarget Wildlife including Threatened or 

Endangered Species

Under the no federal program alternative, there would be no potential for APHIS-WS assistance to result in 

adverse impacts on nontarget wildlife because of ORV programs. However, states would still be free to 

conduct ORV programs using the V-RG vaccine. Such programs would probably be conducted on a 

reduced scale without APHIS-WS funds. However, based on the analysis in Section 4.1.2.1 and 4.1.2.2, 

there is almost no potential for adverse effects on nontarget wildlife because of ORV bait consumption 

under any scenario involving the distribution of baits containing the V-RG vaccine. 

Effects of Capture/Removal Methods (Used in Monitoring and Surveillance or to Reduce Local 

Populations of Target Species under State Contingency Plans) on Nontarget Species, including 

Threatened or Endangered Species

Under the no action alternative, the potential for APHIS-WS assistance to result in adverse impacts on 

nontarget wildlife would be zero. However, states could still conduct ORV programs and monitoring that 

include the capture and/or killing of wild animals for monitoring purposes or localized depopulation under 

contingency plans. The potential effect on nontarget wildlife and T&E species from methods used in 

monitoring and surveillance programs would be less than the proposed action, but, similar to the proposed 

action, would be insignificant. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

4.1.3 Potential for adverse effects on people, pets, and livestock that are exposed to or consume the 

vaccine laden baits 

Direct tests of the safety of V-RG in humans have not been conducted, for understandable reasons. Prior 

EAs by APHIS have analyzed in detail the potential for adverse effects on humans from V-RG exposure as 

a result of ORV experimental programs (USDA 1991, 1992). New vaccines may be considered for future 

use by the APHIS-WS ORV program and any environmental effects of the new vaccines on people, pets, 

and livestock not analyzed in this EA will be appropriately evaluated in further environmental 

documentation. 

4.1.3.1 Alternative 1: Current Action (the No Action Alternative) 

Potential to Cause Rabies in Humans

The nature of the recombinant virus used as the V-RG vaccine is such that it cannot cause rabies. This is 

because the V-RG vaccine only carries the gene for producing the outer coating of the rabies virus (i.e., 

rabies virus glycoprotein) and not those portions of the virus that could result in replication of the rabies 

virus which would have to happen for the disease to occur. Implementation of ORV programs would 

reduce the risk of humans contracting rabies by reducing the chance of encountering rabid animals that 

have been infected by rabid raccoons, gray foxes, or coyotes. 

Potential for Vaccinia Virus to Cause Disease in Humans

The vaccinia virus portion of the 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 of an 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 of virus that was used in smallpox eradication, 

although more attenuated 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 of smallpox vaccinations was 

discontinued after smallpox was eradicated. Thus, a large percentage of the population (particularly 

younger individuals) has not been vaccinated against vaccinia. Vaccinia virus rarely poses much risk of 

serious health effects – even when it was directly applied (via “scarification” or by scratching the skin) to 

many hundreds of millions of people during smallpox eradication campaigns, the number that developed 

vaccinia virus-related illness was only a few per million. In most of those cases the extent of the illness 

was a mild fever and some lesions or pustules at the site of the injection, followed by full recovery and 

subsequent immunity to the vaccinia virus (USDA 1991, p. 39; Elvinger 2001). In most people, localized 

lesions occurred around the site on the arm where the smallpox vaccine was applied, but this a normal and 

expected response and, in general, no cause for concern. 

More severe complications involving the central nervous system can occur with vaccinia virus and the 

nature of these complications is generally thought to be allergic in nature (USDA 1991, p. 39). Central 

nervous system complications occurred at an average rate of three per million among persons vaccinated 

with vaccinia virus (e.g., to prevent smallpox) with about 10 to 30 percent of those cases resulting in death 

(USDA 1991, p. 39). Thus, the chance of a person dying from direct application of a high dose of vaccinia 

virus via scarification would be about 1 in a million cases or less. With ORV baits distributed in the wild, 

people would run far less risk of being exposed to vaccinia virus or the V-RG vaccine in a way similar to 

deliberate smallpox vaccinations, but would primarily only run the risk of skin contact by handling broken 

baits or coming into contact with the oral regions of pets that had just consumed a bait. For that type of 

exposure, the chance of adverse effects from human infection with vaccinia virus would be far less than 1 

in a million. 

Another highly important characteristic of the V-RG vaccine is that it is 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 of V-RG vaccine causing 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

vaccinia-related illness in humans. However, persons with immune system deficiencies (e.g., AIDS) run a 

relatively greater risk of experiencing adverse effects if directly exposed to the vaccinia virus than would 

persons with normal immune systems (USDA 1991, p. 40; USDA 1995a; USDA undated a, undated b). 

Experiments in mice suggest that immune-deficient people would be at minimal risk of adverse effects 

when exposed to V-RG vaccine (Hanlon et al. 1997; USDI 1991, p. 41 and Appendix E therein). To aid in 

further minimizing the potential for adverse effects on humans because of contact with V-RG vaccine, each 

ORV bait contains a warning label and telephone number advising persons who make contact with baits or 

the vaccine liquid to call the number for further guidance. 

An indirect source of information on this issue is the safety record of laboratories that have worked with the 

V-RG vaccine (USDA 1991, p. 27). Ordinarily, lab personnel working with infectious materials or animals 

are protected by immunization and by procedures and equipment that minimize risk. V-RG vaccine has 

been completely safe for humans in laboratory situations (USDA 1991, p. 27). Potential nonlaboratory 

exposure of humans in the various European field trials of V-RG vaccine has been considerable, with no 

program in place that monitors antibody levels of residents before and after the field trials. However, there 

have not been any reports of increased incidence of sickness in the field trial areas that could be attributable 

to the V-RG vaccine (USDA 1991, p. 27; G. Moore, TX Dept. of Health, pers. comm. 2001 as cited in 

USDA 2001a). 

Studies of the effects of V-RG vaccine on nonhuman primates can provide an indication of the potential to 

affect humans (USDA 1991, p. 27). Studies in which squirrel monkeys (Saimiri sciureus) and chimpanzees 

(Pan troglodytes) were inoculated with the V-RG vaccine demonstrated that indirect human exposure to the 

vaccine that might occur via a bite or from contact with body fluids of a recently vaccinated animal is 

unlikely to produce adverse effects in healthy individuals (Rupprecht et al. 1992b; USDA 1991, p. 27). 

McGuill et al. (1998) conducted a retrospective four-year survey of directors of six 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 km2

 (42,181 mi2) of treated area and a total of nearly six million baits 

distributed. Human contacts with the baits totaled 316, of which 53 resulted in contact with the actual 

vaccine liquid. The directors of all programs reported that human contact was minimal and that there were 

no reported adverse reactions in people exposed to the baits. Human contact with the baits was more likely 

in areas where bait had white labels vs. lettering in black ink, and the authors speculated the reason to be 

because the white labeled baits were more visible and, thus, more likely to be noticed. The authors 

concluded that, based on their survey, major concerns about public health risks from V-RG vaccine were 

unfounded. 

Out of approximately 76.6 million baits disbursed since APHIS-WS program inception in 1995, only 1128 

people reported contacting or potentially contacting a bait (i.e., picking up bait, finding a bait in yard, or 

removing bait or sachet from pet’s mouth, feces, or vomit - any type of contact with a bait is also defined 

throughout the document as an “exposure”). This equates to one human 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 involved touching a broken bait, 

sachet, or liquid vaccine. Furthermore, of the 0.0013 perent of contact cases reported since APHIS-WS 

ORV program inception in 1995, only two known adverse reactions have occurred (USDA 2004a, 2008a; 

CDC 2009c). 

The first adverse reaction occurred in Ohio in September, 2000, when a woman was bitten by her dog while 

trying to take away an ORV bait. The vaccine liquid was exposed to the bite area, resulting in localized 

inflammation and pox virus lesions at the site of the bite, as well as a whole body rash. She further 

experienced sloughing of the outer layers of skin from some portions of her body, similar to what occurs in 

the skin condition eczema (C. Rupprecht, CDC, pers. comm. 2001 as cited in USDA 2001a). The woman, 

who was in her first trimester of pregnancy, is reported to have recovered from complications and gave 

birth to a 10-lb. baby boy with no apparent adverse health effects (R. Krogwold, OH Dept. of Health, pers. 

comm. 2001 as cited in USDA 2001a). Most recent reports attribute her response to the vaccinia virus as 

likely due to the reduced state of immunity typical during pregnancy and an underlying skin disorder 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

(epidermolytic hyperkeratosis) that the woman already had (C. Rupprecht, CDC, pers. comm. 2001 as cited 

in USDA 2001a). The woman also tested positive for rabies antibodies three weeks after the exposure, 

indicating she may also have developed rabies immunity (Rupprecht et al. unpublished 2000, Rupprecht et 

al. 2001). A lawsuit was filed in 2001 and a judgment was determined in favor of the defendant, the Ohio 

Department of Health, in May 2003. This type of incident appears to be unusual, but, nevertheless, points 

to the need for continued public information and education activities and field surveillance for accidental 

human exposure to the V-RG virus. 

The second adverse reaction occurred in Pennsylvania in August, 2009. A dog belonging to a 35 year old 

woman picked up a bait in his mouth and punctured the bait with his teeth. After the dog dropped the bait, 

the woman picked it up, and V-RG vaccine dripped from the bait onto her right hand and wrist. Before the 

incident the woman was picking blackberries and had several abrasions on the exposure sites from the 

blackberry thorns. Approximately 30 minutes passed before the woman was able to wash her hands. The 

woman had a history of inflammatory bowel disease, for which she was taking multiple 

immunosuppressive medications (CDC 2009c). 

By day 4 after the exposure, the woman reported several red papules on her right hand and was advised to 

stop taking her immunosuppressant medication. On day 5, a real-time polymerase chain reaction (PCR) 

assay of scrapings from her papules tested positive for nonvariola Orthopoxvirus DNA. Subsequent testing 

preformed at CDC confirmed the presence of vaccinia virus DNA and rabies virus G protein DNA in 

papule material and serologic evidence of rabies virus neutralizing antibodies. Neither Orthopoxvirus IgG 

nor IgM antibodies were detected. By day 6 the papules had increased in number and size and the woman 

was hospitalized. Because of the woman’s immune suppression and concerns about progressive vaccinia, 

she was administered a single dose of human vaccinia immune globulin intravenous (VIGIV) (Cangene 

Corporation, Winnipeg, Canada). The woman began to experience myalgia and headache, had pronounced 

redness in her right hand, and right axillary adenopathy by day 11. On day 12, in an attempt to reduce viral 

replication and prevent progressive vaccinia, a second dose of VIGIV was administered along with the 

investigational antiviral agent, ST-246 (SIGA Technologies, Corvalis, Oregon). On day 13 the woman 

began receiving phased reintroduction of her immunosuppressive medications. She was discharged on day 

19 and by day 28 all scabs from her legions had separated and her underlying inflammatory bowel disease 

condition was stable. The woman remained Orthopoxvirus IgM negative throughout her illness (CDC 

2009c). 

This case marks the first infected person taking immunosuppressive medication. The woman was of 

particular concern for three reasons. First, she was immunosuppressed from medications to treat her 

inflammatory bowel disorder. Second, she had fresh abrasions and prolonged contact with V-RG vaccine 

(approximately 30 minutes) before washing her hands. Third, she did not exhibit features of a normal 

immune response for a person previously naïve for Orthopoxvirus infection. Careful monitoring and 

prompt diagnostic evaluation allowed for timely medical interventions, and the vaccinia virus infection 

resolved. Although her treatment with 2 doses of VIGIV and ST-246 might have contributed to her 

recovery, the role of these agents is difficult to assess (CDC 2009c). 

Recent bait exposure information during an ORV project in western Pennsylvania (August-September, 

2003) revealed that out of 1,710,399 baits distributed over approximately 25,189 km2

, 190 humans or pets 

were exposed to a bait. This equates to one exposure per 9,002 baits disbursed or 0.011 percent of 

distributed baits being found by pets or people. In at least 69 of the 190 potential contact cases, the 

household pet (dog or cat) found the bait; however, the bait and sachet or sachet alone was normally still 

intact (at least 91 percent of cases). Of the six cases where the sachet was ruptured, no reports were 

submitted regarding the development of an adverse reaction (i.e., lesions) (USDA 2004c). This ORV 

project involved hand baiting in several urban areas such as Allegheny County, and aerial baiting of the 

rural areas. Therefore, pets and other domestic animals were more likely to find the baits and are the 

primary source for potential and human exposure to ORV baits. Most ORV baiting locations occur over 

rural or undeveloped lands where human exposure cases can be expected to be much lower. 

Although there is no approved anti-viral compound available yet for treatment of suspected vaccinia virus 

complications, the CDC can make vaccinia immune globulin available to the state on a case-by-case basis, 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

with a requirement that certain specimens (such as acute and convalescent sera and swabs/scabs of the 

affected site) be collected for diagnosis (C. Rupprecht, CDC, pers. comm. 2001 as cited in USDA 2001a). 

This option provides some level of additional assurance that severe adverse effects on humans from 

vaccinia virus reactions would be successfully treated to avoid significant public health problems. 

A recent study indicates vaccinia virus that originated from a strain used in smallpox vaccinations in Brazil 

may have become established in domestic cows in that country (Damaso et al. 2000). This indicates there 

is some potential for the use of vaccinia virus to result in a new emerging infectious disease. There is 

currently no evidence that this type of phenomenon has occurred in the U.S. (C. Rupprecht, CDC, pers. 

comm. 2001 as cited in USDA 2001a). Also, the vaccinia virus strain used for smallpox vaccination in 

Brazil was different than the strain that is currently used in the V-RG vaccine, and the vaccinia virus 

portion of V-RG is more attenuated (i.e., weaker) than the strains used in smallpox vaccines (USDA 1991, 

p. 18-19). Thus, it is less likely that V-RG vaccine would result in the establishment and persistence of 

vaccinia virus in wild or domestic animals. However, no surveillance or testing of animals for this virus 

has been done in the U.S. to test this hypothesis (C. Rupprecht, CDC, pers. comm. 2001 as cited in USDA 

2001a). 

The above information shows there is some potential for unusual circumstances to result in short-term 

adverse health effects from exposure to the vaccinia virus in the V-RG vaccine. However, the overall risk 

of such effects appears to be low based on the extremely low rate of reported occurrences in ORV 

programs. 

Potential to Cause Cancer (Oncogenicity)

This issue has been addressed in a previous EA and in formal risk analyses (USDA 1991, p. 40; USDA 

undated a, undated b). Vaccinia virus is not known to be a tumor-inducing virus. There have been no 

documented reports of oncogenicity associated with natural vaccinia virus infections in any animal species. 

The recombinant DNA methods used for preparation of the V-RG vaccine do not introduce any known 

oncogenes (i.e., cancer-causing genes) into the vaccinia virus strain that could cause it to become tumorinducing. 

Based on this information, risks to humans from contact with the V-RG vaccine are believed to be minimal. 

The risk and potential severity of adverse effects from rabies exposures in humans would probably be 

greater without ORV programs than would be the risk of serious adverse effects from vaccinia virus 

infections with ORV programs. 

Potential for Adverse Effects on Pet Dogs or Other Domestic Animals that Might Consume the Baits

Rupprecht et al. (1992a) and Pastoret et al. (1995) summarized the results of V-RG safety trials in nontarget 

species (USDA 2004a). The studies included oral vaccination of domestic dogs, cats, cattle, and sheep and 

found no adverse effects on those species. More than 76.6 million ORV baits using the RABORAL VRG® vaccine have been distributed in the U.S. during the APHIS-WS program thus far with no reported 

adverse effects on domestic animals (USDA 2008b). Between 1995 and 2006, 843 instances have been 

reported where a pet or other domestic animal had contact with a bait (i.e. carrying bait in mouth, chewing 

bait, vomiting sachet, etc. are considered “contact” or “exposures” for the purposes of this document). This 

equates to 0.001% contact cases or 1 domestic animal per 90,807 baits disbursed (USDA 2008b).There is 

no evidence of potential harm to target or nontarget species, including domestic dogs, cats, cattle, and 

sheep, from overdosage of RABORAL V-RG® vaccine by any route; a number of species have been dosed 

with 2 to 10 times the amount of vaccine in an individual ORV bait without adverse effects (USDA 1991, 

p. 47; Rupprecht et al. 1992a). Therefore, even if domestic animals received multiple doses of vaccine by 

consuming multiple baits, no adverse effects would be expected to occur. 

As discussed in Section 4.1.1.2, a recent study indicates vaccinia virus that originated from a strain used in 

smallpox vaccinations in Brazil may have become established in domestic cows in that country (Damaso et 

al. 2000). This indicates there is some potential for use of vaccinia virus in vaccinations to result in a new 

emerging infectious disease in domestic animals; however, there is currently no evidence that this type of 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

phenomenon has occurred in the U.S. (C. Rupprecht, CDC, pers. comm. 2001 as cited in USDA 2001a). 

Also, the vaccinia virus strain used for smallpox vaccination in Brazil was different than the strain that is 

currently used in the V-RG vaccine, and the vaccinia virus portion of V-RG is more attenuated (i.e., 

weaker) than strains used in smallpox vaccines (USDA 1991, p. 18-19). Thus, it is less likely that V-RG 

would result in the establishment and persistence of vaccinia virus in wild animal populations. 

Instances have been reported where a pet dog has consumed several baits and then vomited the plastic 

sachets (R. Hale, Ohio Dept. of Health, pers. comm. 2001 as cited in USDA 2001a). Reports of these types 

of instances have been few, and the dogs have reportedly not experienced any substantive or long term 

adverse effects. USDA (2008b) documented that of the 76.6 million baits distributed during the APHISWS program between 1995 and 2006 only 843 instances have been reported where a pet or other domestic 

animal had contact with a bait. This equates to 1 domestic exposure per 90,807 baits disbursed or 0.001 % 

contact cases. No cases of adverse reaction in pets or other domestic animals have ever been reported 

during the APHIS-WS program. In addition, USDA (2008b) documented that 172 incidents were reported 

where pets came into contact with a bait in 2006; however, no reports of pets or other domestic animals 

experiencing any type of adverse reaction were submitted. Domestic animals that bite into and ingest a bait 

are most likely to be immunized against rabies or receive a boost from a previous vaccination. USDA 

(2008b) also documented the number of baits distributed in those states conducting ORV programs and the 

number of people who reported contact or potential contact with a bait by their pet or other domestic 

animal (i.e., carrying bait in mouth, chewing bait, vomiting sachet). In 2006, 172 incidents were reported 

where pets came into contact with a bait. The number of documented exposures equates to 0.001% of the 

12.1 million baits distributed in 2006 or one domestic animal exposure per 70,391 baits distributed (USDA 

2008b). In the monitoring report (USDA 2008b), APHIS-WS concluded that adverse cumulative impacts 

to pets and other domestic animals continue to be negligible. 

Research is underway to identify a vaccine that is safe and effective not only in raccoons and foxes, but in 

other carnivores as well such as skunks and dogs. Live modified canine adenovirus type 2 (CAV2), which 

is already used worldwide for the routine vaccination of dogs against both CAV1 and CAV2 and has an 

excellent safety record (Fisher et al. 2002, Appel et al. 1975), represents an almost ideal vaccine vector for 

immunization of carnivores against rabies (Li et al. 2006). The use of different vaccines is anticipated to 

have similar effects on pet dogs and other domestic animals as RABORAL V-RG®. Research tests such as 

Rupprecht at al. (1992) will be conducted to determine potential side-effects of new the new vaccine to 

confirm the effects to pet dogs and other domestic animals. Additionally, CAV2 is licensed for use as a live 

vaccine for dogs and has an excellent efficacy and safety record (Li et al. 2006). New vaccines may be 

considered for future use by the APHIS-WS ORV program and any environmental effects of the new 

vaccines on pet dogs or other domestic animals not analyzed in this EA will be appropriately evaluated in 

further environmental documentation. 

4.1.3.2 Alternative 2: Proposed Action (the Preferred Alternative) 

Potential for Adverse Effects on People that Become Exposed to the Vaccine or the Baits

Implementation of Contingency Action 2 (treatment with increased bait density to ensure sufficient baits 

for high density of target species or to bolster antibody response under “normal” target species densities) 

and Contingency Action 3 (increase baiting frequency more than once/year) as described in Section 1.2.1 

are not expected to increase the potential for adverse effects on humans. The potential for humans to 

become exposed to a bait is remote (1 human contact per 74,278 baits distributed under current baiting 

practices) (USDA 2008a). 

Potential for Adverse Effects on Pet Dogs or Other Domestic Animals that Might Consume the Baits

The EA concluded that the ORV program had a negligible risk of adversely affecting pet dogs or other 

domestic animals that might consume ORV treated baits. A similar impact is expected with regard to 

Contingency Action 2 (treatment with increased bait density to ensure sufficient baits for high density of 

target species or to bolster antibody response under “normal” target species densities) and Contingency 

Action 3 (increase baiting frequency more than once/year). Rupprecht et al. (1992) and Pastoret et al. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

(1995) summarized the results of RABORAL V-RG® safety trials in nontarget species (USDA 2004a). 

The studies included oral vaccination of domestic dogs, cats, cattle, and sheep and found no adverse effects 

on those species. In addition, more than 66.3 million ORV baits using the V-RG vaccine have been 

distributed in the U.S. with no reported adverse effects on pets or other domestic animals. The potential for 

domestic animals to become exposed to a bait is remote, even with an increase in baiting density or 

frequency during localized contingency actions. A beneficial effect involved includes the possibility of 

vaccinating strays and other previously unvaccinated pets, thereby immunizing them against the rabies 

virus. 

Oral rabies vaccines and baits are not used during Contingency Action 1 (enhanced surveillance, which 

may include capture and release or euthanasia of target and specific nontarget animals for rabies testing) or 

Contingency Action 5 (localized target species population reduction), therefore, there would be no effect on 

domestic animals with regard to vaccines or baits. 

New vaccines may be considered for future use by the APHIS-WS ORV program and any environmental 

effects of the new vaccines on pet dogs or other domestic animals not analyzed in this EA will be 

appropriately evaluated in further environmental documentation. 

4.1.3.3 Alternative 3: Live-Capture-Vaccinate-Release Alternative 

Under this alternative, APHIS-WS would not provide funds to purchase or distribute ORV baits but would 

provide such funds for live-capture-vaccinate-release programs. For purposes of comparison, it is assumed 

that, with adequate APHIS-WS funding to conduct these types of programs, states would choose not to 

implement ORV programs. 

Potential for Adverse Effects on People that Become Exposed to the Vaccine or the Baits

Live-capture-vaccinate-release programs might be as effective as ORV programs in stopping the spread of 

the three variants of rabies if conducted throughout all areas where ORV programs would have been 

conducted under the proposed action. The method itself would not present risk of causing rabies in 

members of the public. The risk of increases in human rabies cases because of the failure to stop epizootics 

of raccoon, gray fox, and coyote rabies would be about the same as with ORV programs under the 

proposed action. Because it is assumed that ORV using the vaccinia virus vector in V-RG would not be 

used by states or by APHIS-WS, there should be no risk of vaccinia virus infections in humans caused by 

contact with the vaccine from ORV baits. No increased risk of cancer would result from this alternative. 

Potential for Adverse Effects on Pet Dogs or Other Domestic Animals that Might Consume the Baits

Live-capture-vaccinate-release programs would pose no risk of inadvertent vaccine exposure to pets or 

other domestic animals. 

4.1.3.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal Removal Programs 

Alternative 

Under this alternative, the states would have to fund collection of target species for monitoring and 

surveillance without APHIS-WS funds or personnel assistance. This would likely mean that less 

monitoring would be conducted. If insufficient monitoring and surveillance occurs along the leading edge 

of the advancing rabies strains, rabies managers would not be able to plan the most efficient and effective 

use of ORV baiting strategies to control the specific strains spread by wild carnivores. One possibility is 

that, without adequate surveillance, managers would have to resort to distributing ORV baits across more 

areas than necessary. The ability to stop or prevent the forward advance of specific rabies strains would 

likely be reduced, perhaps to the point that cooperative efforts fail. 

 Potential for Adverse Effects on People that Become Exposed to the Vaccine or the Baits

This alternative would present the same risk as the proposed action. Since the V-RG vaccine cannot cause 
83 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

rabies, there would be no potential for the ORV baits to cause rabies in humans under this or any other 

alternative or scenario involving the distribution of V-RG oral vaccine baits. However, there would be a 

greater risk of human rabies cases if the lack of federal assistance in monitoring and surveillance results in 

a reduction in the effectiveness of ORV programs. As shown by the analysis in Section 4.1.1.2, the risk of 

V-RG vaccine in ORV baits causing any health problems in humans is exceedingly low. This alternative 

would result in no probable risk of causing cancer in humans or animals, similar to the proposed action and 

other alternatives. 

Potential for Adverse Effects on Pet Dogs or Other Domestic Animals that Might Consume the Baits

Under this alternative, the potential for adverse effects on domestic animals from ORV baits would be the 

same as the proposed action. Based on the analysis in Section 4.1.4, there is almost no potential for 

significant adverse effects on domestic animals because of ORV bait consumption under any scenario 

involving the distribution of ORV baits containing the V-RG vaccine. Stopping or preventing the spread of 

rabies would result in beneficial effects on domestic animals by reducing their likelihood of contracting 

rabies. However, more domestic animals are likely to die of rabies if the lack of federal assistance in 

monitoring and surveillance results in a reduction in the effectiveness of ORV programs. 

4.1.3.5 Alternative 5: No Federal Program Alternative 

Under this alternative, no APHIS-WS funds would be available for purchasing ORV baits. The states 

would still likely fund ORV programs to some degree without APHIS-WS’ assistance. They may seek 

other sources of federal funds to complement state or other sources of funding. Thus, people would still 

have the potential to come into contact with baits or the vaccine; however, the potential would be less. 

Actual risks of adverse effects from exposure to vaccinia virus would still be exceedingly low and 

insignificant. 

It is conceivable that federal coordination of ORV programs would actually result in fewer numbers of 

ORV baits used over the years or that ORV bait use in many areas would be for shorter time periods. This 

is because effective federal coordination may have a better chance of stopping or even eliminating one or 

more of the several rabies strains from large areas than if the individual states are left to themselves to 

conduct ORV programs. 

Based on the following information, risks to humans from contact with the V-RG vaccine are believed to 

be minimal with or without APHIS-WS funding or assistance. The risk and potential severity of adverse 

effects from rabies exposures in humans would probably be greater without ORV programs than would be 

the risk of serious adverse effects from vaccinia virus infections with ORV programs. 

Potential to Cause Rabies in Humans

The no federal program alternative would most likely result in greater risk of human exposure to rabies 

than the proposed action because state-run ORV programs without APHIS-WS funds would have less 

chance of being successful in stopping or preventing the spread of the three rabies variants. Therefore, an 

absence of APHIS-WS cooperative funding could be expected to result in increased risk of human rabies 

cases because of expanding epizootics. The V-RG vaccine would not cause rabies under any expected 

scenario involving the distribution of ORV baits. 

Potential for Vaccinia Virus to Cause Disease in Humans

Under the no federal program alternative, V-RG oral vaccine containing the vaccinia virus vector would 

still be available for state-approved use in ORV programs. Such programs would probably be on a lesser 

scale without APHIS-WS funds. The potential for vaccinia-related disease cases would be lower than 

under the proposed action. The likelihood that any cases would occur is extremely remote under any 

expected scenario involving the distribution of ORV baits. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Potential to Cause Cancer (Oncogenicity)

Under the no federal program alternative, V-RG oral vaccine containing the vaccinia virus vector would 

still be available for state-approved ORV programs but would probably be used on less total land area 

without APHIS-WS funds. Because vaccinia virus used in the V-RG vaccine is not a cancer-causing agent, 

expected scenarios involving the use of ORV baits by the states would not result in increased cancer risks. 

Potential for Adverse Effects on Pet Dogs or Other Domestic Animals that Might Consume the Baits

Under the no federal program alternative, the potential for APHIS-WS assistance to result in adverse 

impacts on domestic pets or other domestic animals would be zero. However, states could still conduct 

ORV programs, but such programs would probably be accomplished on a reduced scale without APHISWS funds. Based on the analysis in Section 4.1.3.1 and 4.1.3.2, there is almost no potential for adverse 

effects on domestic animals because of ORV bait consumption under any scenario involving the 

distribution of baits containing the V-RG vaccine. On the other hand, failure to stop or prevent the spread 

of rabies would result in adverse effects on domestic animals by increasing their likelihood of exposure to 

rabid wild animals. 

4.1.4 Potential for the recombined V-RG virus to “revert to virulence” or recombine with other 

viruses and result in a virus that could cause disease in humans or animals. 

4.1.4.1 Alternative 1: Current Action (the No Action Alternative) 

Potential for the Recombined V-RG Virus to “Revert to Virulence” and Result in a Virus that could 

Cause Disease in Humans or Animals

The concern here is whether the V-RG recombinant virus is genetically stable so that it would not become 

virulent (i.e., capable of causing disease) after it replicates (or reproduces) in animals that eat ORV baits 

containing the RABORAL V-RG® vaccine and, perhaps, be transmitted on to other animals. This issue 

was addressed in previous EAs and in formal risk assessments by APHIS (USDA 1991, p. 41-42; USDA 

undated a, undated b). The Wistar Institute conducted experiments with mice in which the V-RG was 

“subpassaged7

” four times into groups of mice (results cited in USDA 1991, p. 41). The V-RG virus could 

not be found after passage through the second or third groups of mice. The experiments demonstrated that 

the ability of the V-RG virus to cause disease does not increase by repeated animal passage, thus “reversion 

to virulence” is unlikely. Further alleviating the concern about this issue is the evidence that V-RG virus 

does not transmit readily to other animals from animals that have consumed ORV baits (Rupprecht and 

Kieny 1988). Impacts of the program on this issue are expected to remain insignificant or nonexistent 

(USDA 2008b). 

Further, the use of potential new vaccines such as CAV2 RVG is expected to have similar results. New 

vaccines may be considered for future use by the APHIS-WS ORV program and any environmental effects 

of the new vaccines or on their potential to “revert to virulence” not analyzed in this EA will be 

appropriately evaluated in further environmental documentation. 

Potential for the RABORAL V-RG® Vaccine to Recombine with Other Viruses in the Wild to Form 

New Viruses that could Cause Disease in Humans or Animals

The concern here is whether the RABORAL V-RG® vaccine in the ORV baits might encounter other 

 

7 This means the V-RG was inoculated into one group of mice from which material containing the virus was obtained later and 

injected into a second group of mice, and then material obtained from the second group was injected into a third group, etc., until four 

such passages had been conducted.
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

viruses in animals, exchange genetic material with them during replication, and result in new viruses that 

could cause serious diseases in humans or animals. This potential recombination has been recognized as 

being more probable with wild pox viruses that are genetically similar to the vaccinia virus used as the 

vector in the RABORAL V-RG® vaccine. 

Wild pox viruses present in the U.S. include skunk, rodent, and raccoon pox viruses (C. Rupprecht, CDC, 

pers. comm. 2001 as cited in USDA 2001a). One type of wild pox virus that would logically be considered 

for the possibility of recombination with vaccinia virus is raccoon pox which could occur in raccoons 

targeted by ORV programs in the eastern U.S. For this type of unanticipated spontaneous recombination to 

occur, the V-RG and RP would have to simultaneously infect the same cells in the same animal at the same 

time. RP has not been found to be prevalent in the environment, with only two concurrent isolations (or 

detections) of it having occurred in the U.S. (Herman 1964, cited in USDA 1991, p. 42). Laboratory 

experiments on mice infected with RP and inoculated with V-RG showed no adverse effects on the mice 

(USDA, 1991, p. 42). 

The Wistar Institute identified three circumstances that would have to occur simultaneously for there to be 

a chance of a hazardous recombination between V-RG and RP virus: (1) they would have to occur at the 

same time in the same animal; (2) “genome contact” (i.e., contact between the actual genetic material in the 

two viruses as they replicate in an infected cell); and (3) the regeneration of the gene that was previously 

removed from the vaccinia virus (known as the thymidine kinase “TK” gene) (USDA 1991, p. 42). Wistar 

determined the probability of all three circumstances occurring at the same time was 1 chance in 100 

million or less (USDA 1991, p. 42). Also, if this did somehow occur resulting in a recombined virus with 

the functional “TK” gene reestablished, the properties and virulence of the new virus would probably be 

similar to the original recipient virus which is vaccinia (USDA undated b, p. 28). Vaccinia only causes 

mild short-term symptoms in most cases (i.e., similar to the localized rash and pustules that occurred on the 

arms of many persons who received smallpox vaccinations) (USDA 1991, p. 39; Elvinger 2001). Thus, 

recombination with wild viruses is unlikely, but, if it did occur, it is also unlikely to result in significant 

adverse effects on animals or people. 

The combination of two types of pox viruses in rabbits or hares (leporipoxviruses) has been known to occur 

(Omlin 1997), but the combination of a leporipoxvirus with another unrelated pox virus has not been 

known to occur (USDA 1991, p. 42). Rare examples of recombination between different poxviruses in 

animal hosts have been documented, although the probability of two viruses infecting the same cell at the 

same time (which is required for recombination to occur) under natural conditions remains very low (Omlin 

1997). Recombination of V-RG with viruses other than orthopoxviruses is not likely (Omlin 1997). In 

formal risk analyses, APHIS concluded that the probability of recombination with other orthopoxviruses 

would be limited due to the low prevalence of orthopoxviruses in wildlife species in the U.S. (USDA 

undated a, undated b). 

Hahn (1992) concluded that vaccines developed by the newer recombinant techniques such as the ones 

used to make V-RG vaccine, are no more hazardous than vaccines created by more conventional methods 

(e.g., “attenuation” and “fractionation”). He further indicated that, with recombinant technology, the 

potential for ending up with a dangerous virulent strain is probably less than with the older “hit-or-miss” 

methods, because the specific genetic material responsible for making a virus virulent can be removed or 

altered which makes the virus safer. 

This analysis, which incorporates previous analyses by reference, supports a conclusion that adverse 

environmental effects from spontaneous recombination of V-RG with other wild viruses are exceedingly 

unlikely. This is further supported by the fact there have been no observed adverse effects in wildlife and 

humans both in Europe and North America following a number of years of experimental and field use of 

the V-RG vaccine. 

Further, the use of potential new vaccines such as CAV2 RVG is expected to have similar results. New 

vaccines may be considered for future use by the APHIS-WS ORV program and any environmental effects 

of the new vaccines or on their potential to “revert to virulence” not analyzed in this EA will be 

appropriately evaluated in further environmental documentation. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

4.1.4.2 Alternative 2: Proposed Action (the Preferred Alternative) 

Potential for the recombined V-RG virus to revert to virulence and result in a virus that could cause 

disease in humans or animals

A similar impact, as with Alternative 1, is expected with regard to Contingency Action 2 (treatment with 

increased bait density to ensure sufficient baits for high density of target species or to bolster antibody 

response under “normal” target species densities) and Contingency Action 3 (increase baiting frequency 

more than once/year). The V-RG vaccine is not used in Contingency Action 1 (enhanced surveillance, 

which may include capture and release or euthanasia of target and specific nontarget animals for rabies 

testing), Contingency Action 4 (TVR of targets and specific nontargets, such as skunks and feral cats that 

are known to harbor and transmit rabies), and Contingency Action 5 (localized target species population 

reduction). Therefore, APHIS-WS has determined no effect regarding this potential issue. 

Potential for the V-RG virus to recombine with other viruses in the wild to form new viruses that 

could cause disease in humans or animals 

A similar impact, as with Alternative 1, is expected with regard to Contingency Action 2 (treatment with 

increased bait density to ensure sufficient baits for high density of target species or to bolster antibody 

response under “normal” target species densities) and Contingency Action 3 (increase baiting frequency 

more than once/year). The V-RG vaccine is not used in Contingency Action 1 (enhanced surveillance, 

which may include capture and release or euthanasia of target and specific nontarget animals for rabies 

testing), Contingency Action 4 (TVR of targets and specific nontargets, such as skunks and feral cats that 

are known to harbor and transmit rabies), and Contingency Action 5 (localized target species population 

reduction). Therefore, APHIS-WS has determined that adverse effects regarding this potential issue would 

be minimal. 

4.1.4.3 Alternative 3: Live-Capture-Vaccinate-Release Alternative 

Under this alternative, it is assumed that the states would not use ORV baits with the V-RG vaccine. Thus, 

there would be no potential for the V-RG virus to revert to a more virulent strain to recombine with other 

viruses in the wild. 

4.1.4.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal Removal Programs 

Alternative

This potential would be the same as under the proposed action. The risk of adverse effects from the V-RG 

virus possibly reverting to a more virulent strain or recombining with other viruses in the wild and resulting 

in significant adverse effects on humans or animal health would be highly remote. 

4.1.4.5 Alternative 5: No Federal Program Alternative 

Potential for the recombined V-RG virus to revert to virulence and result in a virus that could cause 

disease in humans or animals

Under the no federal program alternative, ORV baits with the V-RG vaccine would probably still be used 

by the states even without APHIS-WS funds, although such use would likely be on a reduced scale. As 

shown by the analysis in Sections 4.1.4.1 and 4.1.4.2, the potential for serious environmental effects with 

regard to this issue is very low. 

Potential for the V-RG virus to recombine with other viruses in the wild to form new viruses that 

could cause disease in humans or animals 

Under the no federal program alternative, ORV baits with the V-RG vaccine would probably still be used 

by the states even without APHIS-WS funds, although such use would likely be on a reduced scale. As 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

shown by the analysis in Section 4.1.4.1 and 4.1.4.2, the potential for serious environmental effects with 

regard to this issue is very low. 

4.1.5 Potential for aerially dropped baits to strike and injure people or domestic animals 

4.1.5.1 Alternative 1: Current Action (the No Action Alternative) 

ORV baits would be distributed from aircraft at an average density of 27 baits per km2 (70 baits per mi2

) in 

the coyote rabies zone and 39 baits per km2

 (100 baits per mi2) in the gray fox rabies zone in Texas under 

the proposed action. Bait density would average 75 baits per km2

 (194 baits per mi2) in eastern states 

where raccoon rabies is targeted. These densities are sparse enough to predict that the chance of a person 

being struck and harmed by a falling bait is extremely remote. For example, if 100 persons were standing 

outdoors in a square mile of area in which ORV baits were being dropped, and each person occupies about 

2 square feet of space at the time that baits were dropped, the chance of being struck would be 1 in 139,000 

(200 ft2

 total space occupied by persons divided by 27.8 million ft2 per mi2). The negligible risk of being 

struck is further supported by the fact that out of more than 76.6 million baits distributed in the U.S. by 

APHIS-WS between 1995 and 2006, only 10 incidents have been reported in which a person claimed to 

have been struck by a falling bait (0.00001 percent chance of being struck by a bait or 1 strike per 7.6 

million baits dropped) (USDA 2008b). None of the reports since APHIS-WS’ ORV program inception 

have resulted in any injury or harm to the individuals involved. Eight of these incidents occurred in 

Pennsylvania, Texas, Ohio, and Ontario and did not result in any significant injury or harm to the 

individuals involved (G. Moore, TX Dept. of Health, pers. comm. 2001; R. Hale, OH Dept. of Health, pers. 

comm. 2001; C. MacInnes, Ontario Ministry of Natural Resources, pers. comm. 2001 all as cited in USDA 

2001a). 

Of the 12.1 million baits that were distributed by APHIS-WS in 2006, no incidents were reported in which 

a person claimed to have been struck by a falling bait . No reports of injury were received during the 2006 

APHIS-WS ORV program (USDA 2008b). In 2006, no cases were documented involving falling baits 

striking or injuring domestic animals. Additionally, in 2006, no reports were received regarding baits 

striking property (USDA 2008b). The potential for falling baits to strike or injure people or domestic 

animals continues to be insignificant. Impacts of the program on this issue are expected to remain 

negligible. The potential for baits to strike people or animals is further mitigated by the fact that bait 

disbursal crews avoid dropping baits into cities, towns, and other areas with human dwellings, or if humans 

are observed below. Hand placement or dropping of baits from slower moving helicopters to allow for 

more precise control over the areas on which the baits are dropped would primarily be used in urban parks 

or suburban situations, which would further reduce the risk of being struck. 

4.1.5.2 Alternative 2: Proposed Action (the Preferred Alternative) 

A similar impact, as with Alternative 1, is expected with regard to Contingency Action 2 (treatment with 

increased bait density to ensure sufficient baits for high density of target species or to bolster antibody 

response under “normal’ target species densities) and Contingency Action 3 (increased baiting frequency 

more than once/year). Bait distribution densities are spares enough to predict that the chance of a person 

being struck and harmed by a falling bait is extremely remote. In fact, the chance of being struck by a bait 

is 1 per 7.6 million baits dropped (USDA 2008b). In addition, trained air crews avoid dropping baits into 

cities, towns, and other areas with human dwellings, or if humans are observed below. In areas of higher 

human density, ground placement of baits is normally used. Thus, the potential of falling baits striking 

people, domestic animals, or property continues to be insignificant, even with an increase in baiting density 

or frequency used during localized contingency actions. 

ORV baits are not used during Contingency Action 1 (enhanced surveillance, which may include capture 

and release or euthanasia of target and specific nontarget animals for rabies testing), Contingency Action 4 

(TVR of targets and specific nontargets, such as skunks, and feral cats that are known to harbor and 

transmit rabies), and Contingency Action 5 (localized population reduction). Therefore, APHIS-WS has 

determined that adverse effects regarding this potential issue would be minimal. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

4.1.5.3 Alternative 3: Live-Capture-Vaccinate-Release Alternative 

Under this alternative it is assumed there would be few or no ORV baits dropped from aircraft. Thus, there 

would be no potential for such baits to strike people or animals. 

4.1.5.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal Removal Programs 

Alternative

This potential would be the same as under the proposed action. The risk of striking and injuring people or 

domestic animals with baits is highly remote. 

4.1.5.5 Alternative 5: No Federal Program Alternative 

Under the no federal program alternative, the potential for APHIS-WS assistance to result in this risk would 

be zero. States could still implement ORV programs, but such programs would probably be accomplished 

on a lesser scale without APHIS-WS funds. As discussed in Sections 4.1.5.1 and 4.1.5.2, the risk of 

persons or animals being struck by ORV baits is extremely remote. 

4.1.6 Cost of the program in comparison to perceived benefits 

4.1.6.1 Alternative 1: Current Action (the No Action Alternative) 

Raccoon Rabies ORV Programs

The median number of annual human death rates from rabies in the U.S. is low – less than 3 per year 

(Childs 2002, Krebs et al. 2003b). Still, this disease poses a major economic and public health concern due 

to diverse costs incurred from human or domestic animal contacts with suspected rabid animals such as 

veterinary, medical, legal, and insurance costs (Meltzer and Rupprecht 1998 a,b). 

Human postexposure prophylaxis (PEP) and pet vaccinations are probably the two greatest factors 

determining the societal costs of rabies (Meltzer 1996). In an archival and interview study to determine 

direct and indirect costs associated with human exposures to suspected rabid wildlife in two southern 

California counties, Shwiff et al. (2007) estimated a mean direct cost of a suspected human rabies exposure 

was $2,564 and the mean indirect cost was $1,124. Thusly, it was concluded that indirect costs of suspected 

human rabies exposures can add one third to the direct costs commonly associated with these cases and that 

suspected rabies exposures exert sizable economic burdens on local municipalities and county governments 

in rabies endemic areas. 

Sterner and Sun (2004) recently developed a comprehensive model of the costs associated with rabies. 

They analyzed minimum-maximum estimates of the individual costs (i.e. per unit cost) for 11 factors in an 

attempt to reduce the uncertainty of economic costs and to identify key sources of potential savings as a 

result of rabies management activities. The 11 factors included: 1) pet vaccination, 2) livestock vaccination, 

3) pet replacement, 4) livestock replacement, 5) pre-exposure prophylaxis, 6) post-exposure prophylaxis, 7) 

adverse reactions, 8) public health, 9) animal control, 10) quarantine, and 11) human death. Sterner and Sun 

(2004) stated that although pet vaccination and post-exposure prophylaxis have traditionally been cited as 

the major cost impacts of the disease, they found that the maximum and largest ranges per unit cost were 

associated with livestock replacement, post-exposure prophylaxis, animal replacement, and human death. 

Further, the maximum values for livestock replacement and human death were estimated to be as high as 

$30,000 and 500,000 respectively. These factors help reduce the uncertainty surrounding the economic 

impacts of wildlife rabies and allow for improved policy decisions involving the development and 

distribution of ORV for wildlife. 

Meltzer (1996) described a model for estimating the costs and benefits of using oral vaccines to stop or 

prevent raccoon rabies and identified factors important for consideration. Preventing raccoon rabies from 

moving into an area is generally much less expensive than the cost of elimination. The cost of eliminating 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

raccoon rabies from New York using ORV was estimated at $72.9 million over a 10-year period. 

Statewide cost of raccoon rabies was estimated at $0.23 per capita pre-epizootic to $0.89 per capita once 

the area became infected. Comparing 1990 to 1994, New York found the rabies epizootic increased that 

state's annual costs over $10 million per year (Huntley et al. unpublished 1996). 

Benefit-cost ratios of using V-RG vaccine in oral baits to control raccoon rabies in two counties in New 

Jersey were estimated by Uhaa et al. (1992). In that study, the estimated value of benefits was 2.21 times 

the cost for the most expensive vaccination program. The least expensive program resulted in benefits that 

exceeded costs by a factor of 6.8. The authors concluded that the program would be cost effective (Uhaa et 

al. 1992). 

Kemere et al. (2001) conducted a detailed analysis of the expected costs compared to the expected value of 

benefits for establishing a barrier to prevent further westward spread of raccoon rabies that would extend 

from Lake Erie to the Gulf of Mexico. The barrier would combine natural barriers provided by 

geographical features such as the Appalachian Mountains with ORV zones. All program costs and benefits 

(in terms of avoided costs) were discounted to present values to provide valid comparisons. The types of 

costs avoided by preventing the westward spread of raccoon rabies included post-exposure vaccination 

treatments for humans, need for increased livestock vaccinations, and costs of increased surveillance and 

monitoring of rabies in wildlife and domestic animals (including laboratory diagnostic costs, costs of 

preparing samples for testing, and animal bite investigations). The analysis did not factor in an economic 

benefit for lives saved. It also did not factor in the potential benefit of decreased costs associated with 

nuisance and damage by raccoons or of raccoon impacts on ground nesting birds that might occur if the 

epizootics were not treated and raccoon populations declined as a result. It is probable that such a potential 

benefit would be short term (1-3 years) until local raccoon populations recovered, or were affected by other 

disease cycles. However, these types of outcomes are largely unpredictable. 

Costs of establishing and maintaining the raccoon rabies barrier are estimated to total between $58 million 

and $148 million, while the estimates of net benefits ranged between $48 million and $496 million. The 

analysis indicated that a large scale ORV program should be economically feasible and that net economic 

benefits would most likely be substantial (Kemere et al. 2001). 

WS and cooperators continue to shift from fishmeal polymer (FMP) baits to coated sachets (CS). At 

$1.00/bait CS’s are $0.25 less expensive than FMP baits, less likely to cause damage from aerial 

distribution, more palatable to smaller carnivores like skunks, and perform generally at least as well as 

FMP baits based on field titer responses from Cornell University. The shift to CS’s is currently viewed as 

only an interim management step until improved or new baits can be developed, licensed and produced 

(USDA 2009a). 

Surveillance activities were conducted in all states participating in ORV to assess aerial and/or ground 

ORV baiting efficacy, summer versus fall baiting schedules, and seasonal raccoon movement in a number 

of states. Numerous density studies were also conducted in the majority of participating states to determine 

raccoon densities in relation to habitat, elevation, and numbers of baits distributed. In areas where raccoon 

densities are low, baiting may be reduced to increase cost effectiveness of the ORV program (USDA 

2009a). 

Gray Fox and Coyote Rabies ORV Programs in Texas

Although no detailed economic analysis of the costs and benefits of the gray fox and coyote rabies 

programs has been conducted, the assumption about the potential spread of rabies across much of the U.S. 

without effective ORV programs is most likely also valid for the gray fox and coyote rabies variants. Thus, 

it is probable that the Texas ORV programs would be found to be cost effective under similar analysis. 
90 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

4.1.6.2 Alternative 2: Proposed Action (the Preferred Alternative) 

Raccoon Rabies ORV Programs

Contingency actions, such as TVR and population reduction, may be more labor intensive and time 

consuming, but these actions are conducted relatively infrequently and on a localized scale to prevent the 

spread of rabies during emergency situations. When used as a part of an integrated rabies management 

program with ORV, the benefits (I.E., bolstering population immunity, stopping disease spread to new 

areas) likely outweigh the costs involved. 

 In Maryland, 19 rabies cases were reported per year on the Annapolis Peninsula alone before the ORV 

program began in 1998. Between 1998 and 2007, with the intervention of 412,441 FMP baits, only 21 

raccoons have been reported from the Annapolis Peninsula, indicating success of the Anne Arundel 

County ORV Program (USDA 2009a). 

 In New York, an ORV program was implemented in 1998 to prevent the northward spread of the virus. 

Prior to the ORV program in New York, almost 150 positive rabies cases were recorded in 1998 and 

1999 in the St. Lawrence Region (SLR) ORV zone alone. In 2007, New York reported a decline to 35 

positive rabies cases in the SLR zone. Further, out of an additional 3089 animals tested for rabies from 

the three remaining NY ORV zones on 95 were reported positive. The majority (75) of these came 

from the Long Island ORV zone which, as of 2007, is only in its fourth year of operation. (USDA 

2009). 

 Vermont has been participating in the ORV program since 1996. However, in June 2006, the province 

of Quebec confirmed its first-ever case of raccoon rabies approximately 11 km (6.6mi) north of the 

Vermont border. Subsequently, a second positive case in Quebec was discovered in July 2007. In a 

continuing effort to stop the spread of raccoon rabies in northern Vermont, WS implemented several 

TVR campaigns throughout the standard and high bait density ORV zones. In 2008, WS will continue 

coordinated TVR efforts, but shift focus to the Lake Memphremagog basin in Orleans County to 

prevent rabies from entering Quebec from that area. WS will maintain communications and work 

closely with Quebec officials to coordinate field work and maximize efforts to contain (and explore 

strategies to eliminate) the raccoon variant of rabies from Vermont and Quebec (USDA 2009a). 

 In Ohio, 62 positive rabies cases were recorded prior to program implementation in 1997. From 2001-

2003, three cases were reported near the Pennsylvania border where raccoon rabies is still enzootic. In 

2001, APHIS-WS, in coordination with state agencies, began an ORV program in Pennsylvania 

(USDA 2009a) to address this issue. The ability to create rabies-free zones, within raccoon rabies 

enzootic areas, is a requisite to achieve elimination of this variant of the rabies virus. 

In mid-July 2004, a raccoon infected with raccoon variant of the rabies virus was confirmed just west 

of the ORV zone near Lake Erie in Lake County in northeastern Ohio. This cooperative ORV project 

began in 1997 and has expanded to include the states of Pennsylvania, West Virginia, Virginia, 

Tennessee, Maryland, Georgia and Alabama. Throughout its length from Ohio to northeastern 

Alabama, the ORV zone is at least 30-miles in width to attempt to prevent the westward spread of 

raccoon rabies. APHIS-WS and state, county and municipal cooperators responded immediately to 

this high priority rabies issue. A contingency action plan that included enhanced rabies surveillance, 

trap-vaccinate-release, and ORV was implemented upon detection of the index case. High raccoon 

population densities and additional rabies cases based on enhanced surveillance suggest that additional 

action may be required. Enhanced rabies surveillance is being maintained on the south and west sides 

of this outbreak to determine the next course of action, if required. 

As a component of the greater Appalachian Ridge ORV zone, Ohio continued biannual baiting of the 

Contingency Action (CA) ORV zone (east of Cleveland) in the spring and fall of 2007. Wildlife 

Services integrated TVR into the rabies control campaign within the CA zone to prevent the spread of 

raccoon rabies that was first detected there in 2004. As a result of this effort, 1,285 animals were hand 

vaccinated and released in northeastern Ohio. The number of rabid animals with raccoon variant in 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

this CA zone decreased to 19 cases in 2007 with enhanced surveillance in place (from a high of 46 

cases in 2004) (USDA 2009a). 

 In Massachusetts, the rabies virus had not spread to the Cape where intensive baiting programs at the 

peninsular neck (since 1995), combined with the natural barrier of Cape Cod Canal, seemed to act as 

effective barriers (Robbins et al. 1998). In early March 2004, however, raccoon variant of the rabies 

virus was confirmed east of the Cape Cod Canal for the first time and by 2006 it was confirmed on the 

outer Cape (USDA 2009a). The canal served as the eastern anchor point for the ORV zone which was 

designed to prevent raccoon rabies from spreading east onto the Cape. This cooperative project was 

initiated in the mid-1990s by Tufts University and the State of Massachusetts Health Department. 

APHIS-WS became a partner in this effort in 2001. APHIS-WS, Tufts University, and the State of 

Massachusetts Health Department immediately implemented enhanced rabies surveillance, followed 

by trap-vaccinate-release and ORV as a contingency action plan to prevent further spread, with the 

long range goal of eliminating raccoon rabies from the area. It is not known if raccoon rabies spread to 

the Cape through the long range movement of an individual rabid raccoon or skunk infected with 

raccoon variant of the rabies virus or if the virus spread animal to animal approaching the canal, with 

rabies spreading to the Cape through a short range raccoon or skunk movement across the canal. 

Translocation, either intentional or unintentional (i.e., raccoon “hitch-hiking” in a garbage truck or 

tailored boat and escaping once on the Cape), represents another potential source of spread. 

The Cape Cod ORV zone now includes all townships on Cape Cod. In 2007, only 5 cases of raccoon 

variant rabies were confirmed on the Cape, down from 50 cases in 2006. (USDA 2009a). 

 In Maine, WS initiated rabies management efforts during 2003 in collaboration with New Brunswick, 

Canada to vaccinate raccoons and skunks. As rabies has progressed north and eastward, rabies 

vaccination efforts have been targeted along the Maine, USA and New Brunswick, Canada border 

creating a "barrier" to protect raccoon populations against rabies. Through vaccination efforts New 

Brunswick has maintained a terrestrial rabies-free status since 2002 and continued rabies surveillance 

and TVR rabies management efforts throughout 2007. Maine WS continues to support the 

international eradication of rabies through enhanced surveillance along the front line of documented 

cases and ORV bait distribution along the international border (USDA 2009a). 

 In November 2003, WS established the Georgia-Alabama-Tennessee (GAT) ORV zone where the 

Georgia and Alabama borders meet southern Tennessee. At the time, raccoon rabies was in 

northwestern Georgia and moving westward. The Alabama-Coosa River system to the south and the 

Appalachian Mountains to the north were serving as potential natural barriers to the westward spread 

of raccoon rabies. The GAT zone was established to help fill a gap between these potential barriers 

and to prevent the spread of raccoon rabies into the Tennessee Valley and subsequently the interior of 

the United States. In January 2004, raccoon rabies entered southeastern Tennessee from Georgia and 

reached the GAT ORV zone. In response to the first positive case of raccoon rabies inside the GAT 

zone, WS began baiting the city of Chattanooga and surrounding areas of Hamilton County in the 

spring, while baiting these areas again in the fall as part of the larger GAT ORV effort. During 2004, 

14 cases of raccoon rabies were documented in wildlife in Hamilton County. During 2005, only 1 

animal (a raccoon) was confirmed with raccoon rabies in Hamilton County and the virus was not 

detected in any surrounding counties. Although no cases of raccoon rabies were documented in 

Hamilton County in 2006, 1 case was confirmed in adjacent Bradley County in a gray fox (Urocyon 

cineroargenteus). In 2007, 1 raccoon case was confirmed in Hamilton County, but no additional cases 

were detected in Bradley or other surrounding counties (USDA 2009a). 

 Projects have also been conducted or are in progress in New Jersey (1992-1994, with additional 

projects reinitiated in the last few years), Florida (1995-present), Virginia (2000-present), West 

Virginia (2001-present), Pennsylvania (1995-present), NH (2002-present), AL (2003-present), GA 

(2003-present), and NC (2005-present). 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Gray Fox and Coyote Rabies ORV Programs in Arizona, New Mexico, and Texas

Although no detailed economic analysis of the costs and benefits of the gray fox and coyote rabies 

programs has been conducted, the assumption about the potential spread of rabies across much of the U.S. 

without effective ORV programs is most likely also valid for the gray fox and coyote rabies variants. Thus, 

it is probable that the Arizona, New Mexico, and Texas ORV programs would be found to be cost effective 

under similar analysis. 

Contingency actions, such as TVR and population reduction, may be more labor intensive and time 

consuming, but these actions are conducted relatively infrequently and on a localized scale to prevent the 

spread of rabies during emergency situations. When used as a part of an integrated rabies management 

program with ORV, the benefits (I.E., bolstering population immunity, stopping disease spread to new 

areas) likely outweigh the costs involved. 

 Since 1995, 12.31 million ORV baits have been distributed over south Texas by the coyote ORVP. 

This has proved to be highly effective in the elimination of the canine variant of rabies in that area, 

leading to a declaration of canine rabies-free status in the United States in 2007. A barrier strategy has 

been developed to sustain a zone of immunized wildlife along the Texas-Mexico border with only two 

incursions into the zone at Laredo since 2001, thus preventing the re-emergence of the variant (USDA 

2009a). 

 Early in 2007, the Texas cooperative ORVP program observed an outbreak of the Texas Fox variant of 

rabies in far west-central Texas (west of the then current gray fox ORV zone). The high number of 

coyotes affected with this rabies variant and the possibility of coyote-to-coyote transmission further 

complicated this outbreak. Contingency actions were immediately implemented via local population 

reduction of rabies vector species, additional ORV bait distribution, and enhanced rabies surveillance 

throughout the entire outbreak area. 

 In spite of this recent outbreak, the cooperative ORVP in west-central Texas has been successful in 

reducing (by more than half) the size of the gray fox epizootic from 186,554 km2

 (72,029 mi2) in 1996 

to approximately 88,098 km2

 (34,015 mi2) by 2007. With continued support for the cooperative 

ORVP effort, ongoing success with the gray fox epizootic is expected in west-central Texas where 

19.28 million ORV baits have been distributed since 1996 (USDA 2009a). 

4.1.6.3 Alternative 3: Live-Capture-Vaccinate-Release Alternative 

Raccoon Rabies ORV Programs

A live-capture-vaccinate-release program to control rabies in skunks and raccoons was implemented in 

Toronto in 1992 and cost an estimated $450 to $1,150/km2

 ($1,165 to $2,979/mi2) in Canadian dollars 

(Rosatte et al. 1992). A more recent cost estimate of $500 Canadian/km2

 for a trap-vaccinate-release 

program in Ontario was presented by Rosatte et al. (2001). This analysis assumes the latest cost estimate in 

Rosatte et al. (2001) is the most applicable for comparing this alternative with ORV programs. At the 

current exchange rate of 0.78 U.S. dollars per Canadian dollar (OANDA 2009), the cost would be about 

$390/km2

 ($1006/mi2) in U.S. dollars. In contrast, Kemere et al. (2001) estimated the cost of establishing 

an ORV barrier of 102,650 km2

 (39,623 mi2) from Lake Erie to the Gulf Coast as totaling about $121/km2 

($313/mi2) (costs included $1.30/bait, 75 baits/km2, $8.62/km2 for aerial distribution cost, and $15/km2 for 

program evaluation). This is comparable to the reported cost of ORV in Ontario of $200 Canadian/km2 

($152 U.S./km2) (Rosatte et al. 2001). Therefore, it appears a live-capture-vaccinate-release alternative to 

manage raccoon rabies could cost about 2.5 times as much as the proposed action. Although a greater 

known proportion of targeted raccoon populations may be vaccinated by this approach (Rosatte et al. 

2001), it is probably not necessary to achieve such greater vaccination rates because ORV programs have 

been successful in stopping or eliminating raccoon rabies outbreaks (see Section 1.1.5). Based on the 

analysis in Section 4.1.8, it appears benefits may not exceed costs under this alternative. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Gray Fox and Coyote Rabies ORV Programs in Arizona, New Mexico, and Texas

Live-capture-vaccinate-release programs have not been attempted for these species. It is believed this 

alternative would be highly difficult to achieve with these species, particularly with coyotes. Although 

coyotes can be captured with certain devices such as leghold traps and snares, they are generally too wary 

to capture in cage traps (Baker and Timm 1998) and it is difficult to live capture and release a large enough 

proportion of fox or coyote populations with other traps such as leghold traps and snares (Rosatte et al. 

1993; C. MacInnes, Ontario Ministry of Natural Resources pers. comm. 2001 as cited in USDA 2001a; 

personal observation of APHIS-WS personnel). The aerial ORV programs in Texas cost about $64 /km2

($166/mi2

), including the cost of aircraft, crew, ORV baits, ground crews, surveillance, and laboratory 

testing (derived from information from E. Oertli, TX Dept. of Health, pers. comm. 20018 as cited in USDA 

2001a). Based on the estimated costs of live-capture-vaccinate-release actions shown in Section 4.3.8.1, it 

is expected that this type of program would be much more expensive and time consuming to implement 

than ORV programs and would result in costs that exceed benefits. 

4.1.6.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal Removal Programs 

Alternative

Raccoon Rabies ORV Programs

Costs of the federal portion of state-run ORV programs would be less since no APHIS-WS funds would be 

spent on animal collections to be used in monitoring. Benefits would probably be similar to the proposed 

action. Total costs, including the expenditure of federal and state funds, might be similar if states increased 

activities for monitoring because of the lack of APHIS-WS funds for this type of activity. Benefits would 

still probably exceed costs unless reduced monitoring/surveillance results in a reduction in the effectiveness 

of ORV programs. 

Gray Fox and Coyote Rabies ORV Programs in Arizona, New Mexico, and Texas

Costs of the federal portion of state-run ORV programs would be less since no APHIS-WS funds would be 

spent on animal collections to be used in monitoring. Benefits would probably be similar to the proposed 

action. Total costs, including the expenditure of federal and state funds, might be similar if states increased 

activities for monitoring because of the lack of APHIS-WS funds for this type of activity. Benefits would 

still probably exceed costs unless reduced monitoring/surveillance results in a reduction in the effectiveness 

of ORV programs. 

4.1.6.5 Alternative 5: No Federal Program 

Under the no federal program alternative, the states or others would be left to conduct ORV programs in the 

absence of APHIS-WS participation. Without APHIS-WS funds and assistance, such programs would 

probably be conducted on a reduced scale and may be less successful in stopping the forward advance of 

the three rabies variants across much of the U.S. Overall program costs would decline, but benefits, in 

terms of avoided costs (described in Section 4.1.6.1), would also decline with the most likely result being 

greatly increased state and private costs to monitor and vaccinate for rabies across large areas of the U.S. It 

is believed that, based on the analysis in Section 4.1.6.1 and 4.1.6.2, the increased state and private costs 

resulting from failure to stop the spread of the rabies variants would exceed by a substantial margin the 

savings in program costs that would occur by implementing the no action alternative. Thus, the benefitcost ratio of this alternative would be expected to be much less (i.e., less desirable) than that of the 

 

8

 Reported cost of $152.83 per sq mile for the 2001 TX ORV program bait drop from E. Oertli (pers. comm. 2001), which included 

cost of baits, aircraft use, pilot and 3 crew members, fuel, surveillance, laboratory titer costs, and laboratory biomarker analysis, but 

not salary/benefits of other involved personnel. Additional personnel totaled 64 over two 13-day bait drop periods (one each for gray 

fox and coyote ORV areas), for a total of 1,664 person-days. At an assumed daily cost of $150 per person-day for salaries/benefits, 

and total treated area of 7,700 sq km (20,000 sq mi), the cost per unit area for additional personnel is estimated to be $4.90/sq km 

($12.80/sq mi). Total estimated cost per unit area was therefore about $64/sq mi ($166/sq mi). 
94 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

proposed action.

4.1.7 Humaneness of methods used to collect wild animal specimens critical for timely program 

evaluation or to reduce local populations of target species under state contingency plans. 

4.1.7.1 Alternative 1: Current Action (the No Action Alternative) 

Some people would view methods employed to capture and/or kill raccoons, gray fox, coyotes, and other 

wild animals for monitoring and surveillance or local depopulation purposes as inhumane. Humaneness, as 

it relates to the killing or capturing of wildlife is an important but complex concept that can be interpreted 

in a variety of ways. Humaneness is a person's perception of harm or pain inflicted on an animal, and 

people may perceive the humaneness of an action differently. 

However, humaneness as it relates to the natural world through natural mortality versus man-induced 

mortality must be brought into perspective. DeVos and Smith (1995) explain the characteristics of natural 

mortality in wildlife populations. There seems to be an increasing public perception that, left alone by 

humans, animal populations will experience few premature deaths and live to an old age without harm, pain 

or suffering. It should be recognized that wildlife populations reproduce at far greater rates than would be 

necessary to replace deaths if all lived to old age. To counterbalance this high reproduction, it is natural for 

most individuals of most species to die young, often before reaching breeding age. Natural mortality in 

wildlife populations includes predation, malnutrition, disease, inclement weather, and accidents. These 

“natural” deaths are often greater in frequency than human-caused deaths through regulated hunting, 

trapping, and wildlife damage management operations. From the standpoint of the animal, these natural 

mortality factors also may cause more suffering by wildlife, as perceived by humans, than human-induced 

mortality. Under given habitat conditions, most wildlife populations fluctuate around a rather specific 

density, sometimes called the carrying capacity. Populations that overshoot this density via reproduction 

become very sensitive to various sources of mortality, and death rates increase. Conversely, as populations 

drop, mortality rates decline (DeVos and Smith 1995). Thus, human-induced mortality, which often 

involves much less suffering of individual animals, invariably lessens mortality from other sources. For 

example, it would seem that an animal taken in a leg-hold trap or by a snare, would certainly suffer less 

than if it died from rabies. A similar impact is expected with regard to the contingency actions defined 

previously that involve capture methods, handling, euthanasia, and localized population reduction. 

Research suggests that with some methods, such as restraint in leghold traps, changes in the blood 

chemistry of trapped animals indicate “stress.” Blood measurements indicated similar changes in foxes that 

had been chased by dogs for about five minutes as those restrained in traps (USDA 1997j). However, such 

research has not yet progressed to the development of objective, quantitative measurements of pain or 

stress for use in evaluating humaneness. The challenge in coping with this issue is how to achieve the least 

amount of animal suffering with the constraints imposed by current technology. To insure the most 

professional handling of these issues and concerns, APHIS-WS has policies giving direction toward the 

achievement of the most humane program possible while still accomplishing the program’s mission. 

APHIS-WS has made modifications to management devices through research and development which have 

increased selectivity toward the species being targeted. Research is continuing with the goal of bringing 

new findings and products into practical use. Until such time as new findings and products are found to be 

practical, some animal suffering will occur during lethal collection of animal specimens if monitoring and 

program effectiveness objectives are to be met. 

A similar impact is expected with regard to the contingency actions defined previously that involve capture 

methods, handling, euthanasia, and localized population reduction. 

4.1.7.2 Alternative 2: Proposed Action (the Preferred Alternative) 

As with Alternative 1, a similar impact is expected with regard to the contingency actions defined 

previously that involve capture methods, handling, euthanasia, and localized population reduction. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

4.1.7.3 Alternative 3: Live-Capture-Vaccinate-Release Alternative 

Some persons would view live-capture-vaccinate-release programs as less humane than ORV programs, 

because large numbers of animals would experience the stress of being caught and handled to administer 

the vaccine. Others would view them as relatively humane compared to other types of rabies control 

efforts that involve lethal means to suppress target populations over broad geographic areas. Because it is 

believed this alternative could be as successful in stopping or preventing the spread of rabies as the 

proposed action, the amount of animal suffering due to contracting and dying from rabies would probably 

be similar to the proposed action. 

4.1.7.4 Alternative 4: No Animal Surveillance or Monitoring or Lethal Removal Programs 

Alternative

Under this alternative, no APHIS-WS funds would be used to collect animal specimens or to conduct 

localized population reduction of target species using live-capture or lethal methods. States could still 

conduct these activities, but such efforts would probably be accomplished at a lesser scale without APHISWS assistance. This alternative would be viewed by some persons as more humane than the proposed 

action. Animal suffering due to rabies would probably be similar to the proposed action (i.e., greatly 

reduced). However, more animals are likely to suffer and die of rabies if reduced monitoring/surveillance 

results in a reduction in the effectiveness of ORV programs (see Section 4.1.7.5) for more detailed 

discussion). 

4.1.7.5 Alternative 5: No Federal Program 

Under the no federal program alternative, APHIS-WS would not assist in collecting wild animal specimens 

for ORV monitoring programs or for local population suppression efforts under contingency plans to 

address local rabies outbreaks beyond ORV barriers. States would still most likely conduct such programs 

on their own, although to a lesser degree without APHIS-WS funds and personnel. The primary method 

that would be used by APHIS-WS to capture raccoons (cage traps) would also most likely be the primary 

method used by state programs, although possibly to a lesser degree. It is probable that the methods that 

would be used by APHIS-WS to capture or kill gray fox and coyotes in Texas for rabies monitoring would 

also be used to a lesser degree without APHIS-WS funds and personnel. Thus, some persons would view 

this as being a more humane alternative because of the lower intensity of the methods used. 

Failure of a successful ORV program would likely result in an increased, but varying, proportion of the 

raccoon, gray fox, coyote, and other wild mammal species populations succumbing to rabies when exposed 

to the various specific strains. The symptoms of rabies include insomnia, anxiety, confusion, slight or 

partial paralysis, excitation, hallucinations, agitation, hypersalivation, difficulty swallowing, and 

hydrophobia (fear of water) (CDC 2001a). Some persons might argue that dying from rabies, which can 

take several days once symptoms appear, results in more animal suffering than being captured or killed by 

monitoring and surveillance activities. In any event, it is almost certain that much larger numbers of 

animals would succumb to rabies without effective ORV programs than would experience stress and 

suffering from being captured or killed by monitoring activities. The numbers dying of rabies could 

increase dramatically as epizootics of specific strains spread across larger areas of the U.S. With this in 

mind, it would appear that, on balance, the implementation of successful ORV programs that include 

animal collections for monitoring results in less animal suffering than taking no action. 

4.2 CUMULATIVE IMPACTS

No significant cumulative environmental impacts are expected from any alternative, with the possible 

exception of Alternative 2 - No Action, which might lead to increased human exposures and domestic and 

wild animal rabies cases across much of the U.S. Although some persons will likely remain opposed to the 

use of recombinant vaccines or the use of the vaccinia pox virus as a component of ORV, and some will 

remain opposed to the lethal removal of raccoons, gray fox, or coyotes for monitoring purposes or for 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

implementation of contingency rabies management plans, the analysis in this EA indicates that ORV use 

and such lethal removals will not result in significant risk of cumulative adverse impacts on the quality of 

the human environment. 

4.3 SUMMARY OF IMPACTS OF ALTERNATIVES FOR EACH ISSUE 

Table 4-12 presents a comparison of the alternatives and environmental consequences (impacts) on each of 

the issues identified for detailed analysis: 

Table 4-12. Issues/Impacts/Alternatives/Comparison

Alt. 1: Current 

Action: 

(provide 

APHIS-WS 

funds for ORV 

and 

monitoring/ 

surveillance, 

potential 

localized target 

species 

population 

reduction)

Alt. 2: Proposed 

Action: (ORV 

program as 

described in Alt. 

1 with 

contingency 

actions that 

include Alt. 3) 

Alt. 3: Live 

Capture/Vaccinate 

and Release

Alt. 4: Provide 

Funds for ORV 

without Lethal 

Animal Collections 

or Removals

Alt. 5: No Federal 

Program 

Potential for 

adverse effects on 

target wildlife 

species 

populations.

 Effects of the 

ORV V-RG 

vaccine on 

raccoons, 

gray foxes, 

and coyotes 

No probable 

risk of adverse 

effects 

No probable risk 

of adverse impacts 

from V-RG 

vaccine or 

injectable 

vaccines used in 

TVR activities. 

No risk from V-RG 

vaccine. 

No probable risk of 

adverse impact (same 

as Alt 1). 

No probable risk; 

states would likely 

still conduct ORV 

programs, but 

probably on a lesser 

scale without 

federal assistance 

 Effects of 

monitoring 

and 

surveillance 

and localized 

population 

reduction 

actions on 

raccoon 

populations 

in eastern 

states. 

Very low 

impact. 

Very low impact 

(similar to Alt. 1 

and3). 

Very low impact 

(similar to Alt. 1). 

Slightly lower impact 

than Alt. 1; states 

would still conduct 

monitoring and 

surveillance and 

contingency actions, 

but these are likely to 

be on a lesser scale 

without federal 

assistance. 

Slightly lower 

impact than Alt. 1 

or 2; states would 

still conduct 

monitoring and 

surveillance and 

contingency 

actions, but these 

are likely to be on a 

lesser scale without 

federal assistance. 

 Effects of 

monitoring 

and 

surveillance 

and localized 

population 

reduction 

actions on 

gray fox 

populations 

in Texas. 

Low impact. Low impact 

(Similar to Alt.1). 

Low impact (similar 

to Alt. 1). 

Lower impact than 

Alt. 1; the state 

would still conduct 

monitoring and 

surveillance and 

contingency actions, 

but these are likely to 

be on a lesser scale 

without federal 

assistance. 

Slightly lower 

impact than Alt. 1or 

2; the state would 

still conduct 

monitoring and 

surveillance and 

contingency 

actions, but these 

are likely to be on a 

lesser scale without 

federal assistance. 

 Effects of 

monitoring 

Low impact. Low impact 

(Similar to Alt 1 

Low impact (similar Lower impact than 

Alt. 1; the state 

Slightly lower 

impact than Alt. 1 
97 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Table 4-12. Issues/Impacts/Alternatives/Comparison

and 

surveillance 

and localized 

population 

reduction 

actions on 

coyote 

populations 

in Texas. 

and 3). to Alt. 1). would still conduct 

monitoring and 

surveillance and 

contingency actions, 

but these are likely to 

be on a lesser scale 

without federal 

assistance. 

or 2; the state would 

still conduct 

monitoring and 

surveillance and 

contingency 

actions, but these 

are likely to be on a 

lesser scale without 

federal assistance. 

 Effects on 

non-ORV 

target 

species. 

Low impact. Low impact 

(similar to Alt 1 

and 3. 

Low impact (similar 

to Alt. 1) 

Lower impact than 

Alt. 1; the state 

would still conduct 

monitoring and 

surveillance and 

contingency actions, 

but these are likely to 

be on a lesser scale 

without federal 

assistance.

Slightly lower 

impact than Alt. 1 

or 2; the state would 

still conduct 

monitoring and 

surveillance and 

contingency 

actions, but these 

are likely to be on a 

lesser scale without 

federal assistance 

Potential for 

adverse effects on 

nontarget wildlife 

species, including 

threatened or 

endangered 

species.

 Effects of the 

RABORAL 

V-RG® 

vaccine on 

nontarget 

wildlife 

including 

threatened or 

endangered 

species. 

No effect on 

T&E species; 

No probable 

risk of adverse 

effects on other 

nontarget 

species. 

No effect on T&E 

species; No 

probable risk of 

adverse effects on 

other nontarget 

species. 

No effect on T&E 

species; no risk of 

adverse effect on 

other species from 

ORV vaccine. 

No effect on T&E 

species; No probable 

risk of adverse 

effects on other 

nontarget species 

(Same as Alt. 1); but 

greater risk of 

adverse effects on 

these species from 

rabies if reduced 

monitoring and 

surveillance reduces 

effectiveness of ORV 

programs. 

No probable risk of 

adverse effects from 

ORV vaccine; but 

greater risk of 

adverse effects on 

these species from 

rabies. 

 Effects of 

capture/remo

val methods 

(used in 

monitoring, 

surveillance, 

and localized 

population 

reduction) on 

nontarget 

species, 

including 

threatened or 

endangered 

species. 

No effect on 

T&E species; 

Very low risk 

of adverse 

effects on other 

nontarget 

species. 

No effect on T&E 

species; Very low 

risk of adverse 

effects on other 

nontarget species. 

Less impact than 

Alt. 1. 

Less impact than Alt. 

1; states would still 

conduct monitoring 

and surveillance and 

contingency actions, 

but these are likely to 

be on a lesser scale 

without federal 

assistance. 

Probably slightly 

less impact than 

Alt. 1 or 2. 

Potential for 

adverse effects on 

people, pets, and 

livestock that are 

exposed to or 

consume the 

vaccine laden 

baits. 

 Potential to 

cause rabies 

No probable 

risk. 

No probable risk. No probable risk. No probable risk 

from ORV use; 

No probable risk 

from ORV use by 
98 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Table 4-12. Issues/Impacts/Alternatives/Comparison

in humans. higher risk of human 

rabies cases if 

reduced monitoring 

and surveillance 

reduces effectiveness 

of ORV programs. 

states. Higher risk 

of human rabies 

cases if states are 

unable to stop the 

spread of rabies 

without federal 

assistance. 

 Potential for 

vaccinia 

virus to 

cause disease 

in humans 

Possible but 

risk is low; risk 

of significant 

adverse effects 

on individuals 

that experience 

vaccinia 

infections also 

is low. 

Possible but risk is 

low; risk of 

significant adverse 

effects on 

individuals that 

experience 

vaccinia infections 

also is low. 

No risk. Possible but risk is 

low; risk of 

significant adverse 

effects on individuals 

that experience 

vaccinia infections 

also is low (same as 

Alt. 1). 

Slightly lower risk 

than Alt. 1or 2; 

states would likely 

still conduct ORV 

programs, but 

probably on a lesser 

scale without 

federal assistance 

 Potential to 

cause cancer 

(oncogenicit

y). 

No probable 

risk. 

No probable risk. No probable risk. No probable risk. No probable risk. 

 Potential for 

adverse 

effects on pet 

dogs or other 

domestic 

animals that 

might 

consume the 

baits. 

Low risk; 

Possible benefit 

from improving 

immunity to 

rabies. 

Low risk; Possible 

benefit from 

improving 

immunity to 

rabies. 

No risk of adverse 

effects from 

consuming ORV 

baits. 

Low risk (similar risk 

as Alt. 1); increased 

risk of rabies for 

unvaccinated animals 

if reduced monitoring 

and surveillance 

reduces effectiveness 

of ORV programs. 

Low risk; states 

would likely still 

conduct ORV 

programs. Increased 

risk of rabies for 

unvaccinated 

animals without 

federal assistance. 

Potential for the 

recombined V-RG 

virus to “revert to 

virulence” or 

recombine with 

other viruses and 

result in a virus 

that could cause 

disease in humans 

or animals.

 Potential for 

the 

recombined 

V-RG virus 

to “revert to 

virulence” 

and result in 

a virus that 

could cause 

disease in 

humans or 

animals. 

Very low risk. Very low risk. No risk. Low risk (similar risk 

as Alt. 1). 

Less risk than Alt. 1 

or 2; states would 

likely still conduct 

ORV programs. 

 Potential for 

the V-RG 

virus to 

recombine 

with other 

viruses in the 

wild to form 

new viruses 

that could 

cause disease 

Very low risk. Very low risk. No risk. Low risk (similar risk 

as Alt. 1). 

Less risk than Alt. 1 

or 2; states would 

likely still conduct 

ORV programs. 
99 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Table 4-12. Issues/Impacts/Alternatives/Comparison

in humans or 

animals. 

Potential for 

aerially dropped 

baits to strike and 

injure people or 

domestic animals. 

Low risk. Low risk. No risk. Low risk (similar risk 

as Alt. 1). 

Less risk than Alt. 

1or 2; states would 

likely still conduct 

ORV programs. 

Cost of the 

program in 

comparison to 

perceived benefits. 

Expected 

benefits exceed 

costs of 

program. 

Expected benefits 

exceed costs of 

program. 

Expected benefits 

unlikely to exceed 

costs of program. 

Expected benefits 

exceed costs of 

program (similar to 

Alt. 1); benefits may 

not exceed costs if 

reduced monitoring 

and surveillance 

reduces effectiveness 

of ORV programs. 

Cost of adverse 

effects from rabies 

spread would be 

much greater than 

cost savings from 

not having federal 

assistance. 

Humaneness of 

methods used to 

collect wild 

animal specimens 

critical for timely 

program 

evaluation or to 

reduce local 

populations of 

target species 

under state 

contingency plans 

Capture and 

handling of 

raccoons would 

be viewed by 

some persons as 

inhumane. 

Methods 

viewed as 

inhumane by 

some persons 

would be used 

to take gray fox 

and coyotes in 

Arizona, New 

Mexico, and 

Texas, but 

many animals 

saved from 

suffering and 

death due to 

rabies. 

Capture and 

handling of 

raccoons would be 

viewed by some 

persons as 

inhumane. 

Methods viewed 

as inhumane by 

some persons 

would be used to 

take gray fox and 

coyotes in 

Arizona, New 

Mexico, and 

Texas, but many 

animals saved 

from suffering and 

death due to 

rabies. 

Capture and 

handling of target 

species would be 

viewed by some 

persons as 

inhumane. Fewer 

gray fox and 

coyotes would be 

taken in Arizona, 

New Mexico, and 

Texas using lethal 

methods, however, 

so this alternative 

would be viewed as 

more humane than 

Alt. 1. 

This Alt. would be 

viewed as more 

humane than Alt. 1; 

states likely to still 

conduct monitoring 

and surveillance and 

contingency plan 

implementation, but 

at a smaller scale 

without federal 

assistance; more 

animals likely to die 

of rabies if reduced 

monitoring and 

surveillance reduces 

effectiveness of ORV 

programs. 

Probably less 

impact on this issue 

than Alt. 1 or 2; 

states likely to still 

conduct ORV 

programs with 

monitoring and 

surveillance and 

contingency plan 

implementation, but 

at a smaller scale 

without federal 

assistance; more 

animals likely to die 

of rabies if lack of 

federal assistance 

reduces 

effectiveness of 

ORV programs. 
A-1 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

APPENDIX A

LIST OF PREPARERS, REVIEWERS AND PERSONS/AGENCIES CONSULTED 

LIST OF PREPARERS/REVIEWERS: 

Beth Kabert, Wildlife Biologist - Environmental Coordinator, USDA, APHIS-WS, Pittstown, NJ – 

preparer/editor 

Tom Hall, Wildlife Biologist - Environmental Coordinator, USDA, APHIS-WS, Fort Collins, CO – 

preparer/editor 

Shannon Hebert, Environmental Coordinator, USDA, APHIS-WS, Portland, OR – preparer/editor 

Dennis Slate, Wildlife Biologist - National Rabies Program Coordinator, USDA, APHIS-WS, 

Concord, NH – preparer/editor 

Richard Chipman, Wildlife Biologist – Assistant National Rabies Program Coordinator, USDA, 

APHIS-WS, Castleton, NY – preparer/editor 

Robert L. Hale, Rabies Program Planner – Rabies Program, USDA, APHIS-WS, Columbus, OH – 

prepared maps 

Kathleen Nelson, Wildlife Biologist – Rabies Program, USDA, APHIS-WS, Concord, NH – prepared 

maps 

LIST OF PERSONS/AGENCIES CONSULTED: 

In addition to the reviewers listed above, the following federal and state agencies and persons were 

consulted on various aspects of the information and analysis in this EA: 

Wendy Anderson, Wildlife Biologist, State Director NJ, USDA, APHIS-WS, Pittstown, NJ 

Scott Barras, Wildlife Biologist, State Director VA, USDA, APHIS- WS, Moseley, VA 

David Bergman, Wildlife Biologist, State Director AZ, USDA, APHIS – WS, Phoenix, AZ 

Frank Boyd, Wildlife Biologist, State Director AL, USDA, APHIS-WS, Auburn, AL 

Dr. Laura L. Bigler, Zoonotic Disease Section, College of Veterinary Medicine, Cornell University, 

Ithaca, NY 

Peter Butchko, Wildlife Biologist, State Director MI, USDA, APHIS-WS, Okemos, MI 

Monte Chandler, Wildlife Biologist – State Director – MA/RI/CT - USDA, APHIS-WS, Amherst, MA 

Bernice Constantin, Wildlife Biologist - State Director – FL, USDA, APHIS-WS, Gainesville, FL 

Christopher Croson, Wildlife Biologist – State Director – WV, USDA, APHIS – WS, Elkins, WV 

Eugene DeGayner, National Wildlife Program Leader, USFS, Washington, D.C. 

Brett Dunlap, Wildlife Biologist – State Director – TN/KY, USDA, APHIS-WS, Madison, TN 

Dr. Eleanor Eagly, Senior Staff Veterinarian, USDA, APHIS - Veterinary Services, Center for 

Veterinary Biologics, Ames, IA 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Rebecca Ewing, TES Regional Biologist, USDA, Forest Service, Region 9, Milwaukee, WI 

John Forbes, Wildlife Biologist – State Director – ME, USDA, APHIS-WS, Augusta, ME 

Dr. Donna Gatewood, Chief Staff Veterinarian, Mammalian Virology and Antibody Products, USDA, 

APHIS - Veterinary Services, Center for Veterinary Biologics, Ames, IA 

Ernesto Garcia, Wildlife Program Leader, USFS Region 8, Atlanta, GA 

Harris Glass, Wildlife Biologist – State Director – PA, USDA, APHIS-WS, Harrisburg, PA 

Kris Godwin, Wildlife Biologist – State Director – MS, USDA, APHIS-WS, Mississippi State 

University, MS 

Dr. Cathleen Hanlon, CDC, Atlanta, GA 

Jon Heisterberg, Wildlife Biologist – State Director – NC, USDA, APHIS-WS, Raleigh, NC 

Chris Horyza, Planning and Environmental Coordinator, AZ State Office, BLM 

Ken Karkula, NEPA Specialist, USFS, Washington, D.C. 

Dennis Krusac, Acting Director, Biological and Physical Resources, USDA, Forest Service, Region 8, 

Atlanta, GA 

Dr. Roger Krogwold, Assistant State Public Health Veterinarian, Ohio Department of Health, 

Columbus, OH 

Dwight LeBlanc, Wildlife Biologist – State Director – LA, USDA, APHIS-WS, Port Allen, LA 

Bruce Leland, Wildlife Biologist – Asst. State Director – USDA, APHIS-WS, San Antonio, TX 

Michael Liddel, Policy Analyst, USDA, APHIS-PPD, Riverdale, MD 

Samuel B. Linhart, Research Coordinator (retired), Southeastern Cooperative Wildlife Disease Study, 

University of Georgia, Athens, GA 

Judy Loven, Wildlife Biologist – State Director – IN, USDA, APHIS-WS, West Lafayette, IN 

Martin Lowney, Wildlife Biologist – State Director – NY, USDA, APHIS-WS, Castleton, NY 

Dr. Charles D. MacInnes, Coordinator (Retired) - Rabies Research, Ontario Ministry of Natural 

Resources, Wildlife and Natural Heritage Science Section, Peterborough, Ontario 

Ron Maes, TES Program Leader, USDA, Forest Service, Region 3, Albuquerque, NM 

Dr. Joanne Maki, Merial, Inc., Athens, GA 

Elroy Masters, Wildlife Program Lead, AZ State Office, BLM 

Alan May, Wildlife Biologist – State Director – NM, USDA, APHIS – WS, Albuquerque, NM 

Dr. John Mitzel, USDA, APHIS - Veterinary Services, Center for Veterinary Biologics, Ames, IA 

Andrew Montoney, Wildlife Biologist - State Director - OH, USDA, APHIS-WS, Columbus, OH 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants 

Guy Moore, Wildlife Biologist, Deputy Director, Oral Rabies Vaccination Program, Texas Department 

of Health, Zoonosis Control Division, Austin, TX 

Noel Myers, Wildlife Biologist – State Director – SC, USDA, APHIS-WS, Columbia, SC 

Dr. Dale L. Nolte, Research Wildlife Biologist, USDA, APHIS-WS National Wildlife Research 

Center, Olympia Field Station, Olympia, WA 

Dr. Ernest Oertli, Director, Oral Rabies Vaccination Program, Texas Department of Health, Zoonosis 

Control Division, Austin, TX 

David Purser, USFS Region 8, Atlanta, GA 

Dr. Charles Rupprecht, Chief, Rabies Section, CDC, Atlanta, GA 

Dr. Carolin Schumacher, Merial, Inc., Athens, GA 

John Sherman, Wildlife Program Lead, NM State Office, BLM 

Dr. Kathleen A. Smith, State Public Health Veterinarian, Ohio Department of Health, Columbus, OH 

Dr. Malcolm Smith, Senior Vice President, Bait-Tek, The Woodlands, TX 

Steve Smith, Wildlife Biologist – State Director – SC, USDA, APHIS-WS, Athens, GA 

Mark Spencer, Planning and Environmental Coordinator, NM State Office, BLM 

Kevin Sullivan, Wildlife Biologist – State Director – MD, DE, DC – USDA, APHIS-WS, Annapolis, 

MD 

Gail Tunberg, Wildlife Program Leader, USFS SW Region 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

APPENDIX B 

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System lands in the United States. USDA, APHIS, Wildlife Services, 4700 River Road, Unit 87, 

Riverdale, MD 20737-1234. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2006b. Environmental assessment (EA) and decision/finding of no significant impact 

(FONSI) – Predator Damage Management in New Mexico. USDA, APHIS, Wildlife Services, New 

Mexico State Office, 8441 Washington NE, Albuquerque, NM 87113-1001. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2005. Monitoring Report-Calendar Year 2004-for Environmental Assessments Concerning 

the Management of Rabies in the United States. USDA, APHIS, Wildlife Services, 6213-E Angus 

Drive, Raleigh, NC 27617. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2004a. Supplemental environmental assessment (EA) and decision/finding of no significant 

impact (FONSI) – Oral vaccination to control specific rabies virus variants in raccoons, gray foxes, 

and coyotes in the United States. USDA, APHIS, Wildlife Services, 4700 River Road, Unit 87, 

Riverdale, MD 20737-1234. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2004b. Environmental assessment (EA) and decision/finding of no significant impact 

(FONSI) – Oral vaccination to control specific rabies virus variants in raccoons on National Forest 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

System lands in the United States. USDA, APHIS, Wildlife Services, 4700 River Road, Unit 87, 

Riverdale, MD 20737-1234. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2004c. Monitoring Report-Calendar Year 2003-for Environmental Assessment – Oral 

vaccination to control specific rabies virus variants in raccoons, gray foxes, and coyotes in the United 

States. USDA, APHIS, Wildlife Services, 6213-E Angus Drive, Raleigh, NC 27617. 22p. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2004d. Monitoring Report-Calendar Year 2002-for Environmental Assessments Concerning 

the Management of Rabies in the United States. USDA, APHIS, Wildlife Services, 6213-E Angus 

Drive, Raleigh, NC 27617. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2003a. Supplemental environmental assessment (EA) and decision/finding of no significant 

impact (FONSI) – Oral vaccination to control specific rabies virus variants in raccoons, gray foxes, 

and coyotes in the United States. USDA, APHIS, Wildlife Services, 4700 River Road, Unit 87, 

Riverdale, MD 20737-1234. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2003b. Monitoring Report-Calendar Year 2001-for Environmental Assessments Concerning 

the Management of Rabies in the United States. USDA, APHIS, Wildlife Services, 6213-E Angus 

Drive, Raleigh, NC 27617. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2002. Decision/finding of no significant impact (FONSI) for environmental assessment oral 

vaccination to control specific rabies virus variants in raccoons, gray foxes, and coyotes in the United 

States. USDA, APHIS, Wildlife Services, 4700 River Road, Unit 87, Riverdale, MD 20737-1234. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2001a. Environmental Assessment (EA) and decision/finding of no significant impact 

(FONSI) - Oral vaccination to control specific rabies virus variants in raccoons, gray foxes, and 

coyotes in the United States. USDA, APHIS, Wildlife Services, 4700 River Road, Unit 87, Riverdale, 

MD 20737-1234. 

USDA-APHIS-WS. 2001b. Wildlife Services Field Operations Manual for the Use of Immobilization and 

Euthanasia Drugs. 120pp 

USDA (U.S. Department of Agriculture), Forest Service (FS). 2001c. Regional Foresters Sensitive Species 

Lists, Region 8). December 12, 2001. USDA, FS, 1720 Peachtree Rd, Atlanta, GA 30309. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Wildlife 

Services. 2000. Biological Assessment of Potential Impacts on Lynx by the USDA, APHIS, Wildlife 

Services Program - Eastern Region. USDA, APHIS, Wildlife Services, Eastern Regional Office, 920 

Main Campus Drive, Suite 200, Raleigh, NC 27606. October, 2000. 12p. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1999. Environmental assessment (EA) -- Predator damage management on 

Federal Lands in Arizona. USDA, APHIS, Wildlife Services-Arizona State Office, 8836, North 23rd

Avenue, Suite 2, Phoenix, AZ 85021. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997a. Environmental assessment (EA) -- Predator damage management 

in the Brownwood animal damage control district - Texas. USDA, APHIS, Wildlife Services-Texas 

State Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997b. Environmental assessment (EA) -- Predator damage management 

in the Canyon animal damage control district - Texas. USDA, APHIS, Wildlife Services-Texas State 

Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997c. Environmental assessment (EA) -- Predator damage management 

in the College Station animal damage control district - Texas. USDA, APHIS, Wildlife ServicesTexas State Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997d. Environmental assessment (EA) -- Predator damage management 

in the Fort Stockton animal damage control district - Texas. USDA, APHIS, Wildlife Services-Texas 

State Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997e. Environmental assessment (EA) -- Predator damage management 

in the Fort Worth animal damage control district - Texas. USDA, APHIS, Wildlife Services-Texas 

State Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997f. Environmental assessment (EA) -- Predator damage management in 

the Kerrville animal damage control district - Texas. USDA, APHIS, Wildlife Services-Texas State 

Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997g. Environmental assessment (EA) -- Predator damage management 

in the Kingsville animal damage control district - Texas. USDA, APHIS, Wildlife Services-Texas 

State Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997h. Environmental assessment (EA) -- Predator damage management in 

the San Angelo animal damage control district - Texas. USDA, APHIS, Wildlife Services-Texas State 

Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997i. Environmental assessment (EA) -- Predator damage management in 

the Uvalde animal damage control district - Texas. USDA, APHIS, Wildlife Services-Texas State 

Office, P.O. Box 100410, San Antonio, TX 78201-1710. 21 pp. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1997j. Final Environmental Impact Statement - revised October 1997. 

USDA, APHIS, Wildlife Services Operational Support Staff, 4700 River Road, Unit 87, Riverdale, 

MD 20737-1234. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1996. Environmental assessment (EA) -- Predator damage management on 

nonfederal and Tribal Lands in Arizona. USDA, APHIS, Wildlife Services-Arizona State Office, 

8836, North 23rd Avenue, Suite 2, Phoenix, AZ 85021. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), 

Biotechnology, Biologics, and Environmental Protection (BBEP). 1995a. EA and Finding of No 

Significant Impact – Proposed Issuance of a Conditional United States Veterinary Biological Product 

License to Rhone Merieux, Inc., for Rabies Vaccine, Live Vaccinia Vector. USDA, APHIS, BBEP, 

4700 River Road, Riverdale, MD 20737-1234. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), Animal 

Damage Control Program. 1995b. Environmental Assessment and Finding of No Significant Impact – 

Proposed Field Application of an Experimental Rabies Vaccine, Live Vaccinia Vector, In South Texas. 

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

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), 

Biotechnology, Biologics, and Environmental Protection (BBEP). 1994a. Environmental Assessment 

and Finding of No Significant Impact – Proposed Field Test of an Experimental Rabies Vaccine, 

Vaccinia Vector, Cape Cod Canal, Massachusetts. USDA, APHIS, BBEP, 4700 River Road, 

Riverdale, MD 20737-1234. March 1994 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), 

Biotechnology, Biologics, and Environmental Protection (BBEP). 1994b. Environmental Assessment 

and Finding of No Significant Impact – Proposed Field Test of an Experimental Rabies Vaccine, 

Vaccinia Vector, Cape Cod Canal, Massachusetts. USDA, APHIS, BBEP, 4700 River Road, 

Riverdale, MD 20737-1234. October 1994 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), 

Biotechnology, Biologics, and Environmental Protection (BBEP). 1994c. Environmental Assessment 

and Finding of No Significant Impact – Proposed Field Test of an Experimental Rabies Vaccine, 

Vaccinia Vector, Northern Cape May Peninsula, New Jersey. USDA, APHIS, BBEP, 4700 River 

Road, Riverdale, MD 20737-1234. October 1994 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), 

Biotechnology, Biologics, and Environmental Protection (BBEP). 1993. Environmental Assessment 

and Finding of No Significant Impact – Proposed Field Test of an Experimental Rabies Vaccine, 

Vaccinia Vector, Northern Cape May Peninsula, New Jersey. USDA, APHIS, BBEP, 4700 River 

Road, Riverdale, MD 20737-1234. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), 

Biotechnology, Biologics, and Environmental Protection (BBEP). 1992. Environmental Assessment 

and Finding of No Significant Impact – Proposed Field Trial in New Jersey of a Live Experimental 

Vaccinia-Vector Recombinant Rabies Vaccine for Raccoons. USDA, APHIS, BBEP, 4700 River 

Road, Riverdale, MD 20737-1234. 

USDA (U.S. Department of Agriculture), Animal and Plant Health Inspection Service (APHIS), 

Biotechnology, Biologics, and Environmental Protection (BBEP). 1991. Environmental Assessment 

and Finding of No Significant Impact – Proposed Field Trial in Pennsylvania of a Live Experimental 

Vaccinia-Vector Recombinant Rabies Vaccine for Raccoons. USDA, APHIS, BBEP, 4700 River 

Road, Riverdale, MD 20737-1234. 

USDC (U.S. Department of Commerce), U.S. Census Bureau. 2001. Statistical abstract of the United 

States. Retrieved from: www.census.gov/prod/2002pubs/01statab/stat-ab01.html. 

USDC (U.S. Department of Commerce), U.S. Census Bureau. 2008. Statistical abstract of the United 

States. Retrieved on February 4, 2008 from: www.census.gov/prod/www/statistical-abstract.html. 

USDI (U.S. Department of the Interior), Bureau of Land Management (BLM). 2007. Species of 

Management Concern for New Mexico BLM. August 2007. USDi, BLM, 1474 Rodeo Rd., Santa Fe, 

NM 87502 

USDI (U.S. Department of the Interior), Bureau of Land Management (BLM). 2005. Arizona BLM 

Sensitive Species List. October, 2005. USDI, BLM, 1 North Central Ave., Phoenix, AZ 85004. 

USDI (U.S. Department of the Interior), National Park Service (NPS). 2004. Environmental Assessment 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

and Finding of No Significant Impact - Oral Rabies Vaccination Program (on Southeast Region NPS 

units). USDI/NPS, Southeastern Region, 100 Alabama St. SW, 1924 Building, Atlanta, GA 30303. 

USDI (U.S. Department of the Interior), National Park Service (NPS). 2003. Environmental Assessment 

and Finding of No Significant Impact - Oral Rabies Vaccination Program, Big Bend National Park, 

Guadalupe Mountains National Park, Amistad National Recreation Area, Texas. USDI/NPS, 

Intermountain Region, 12795 Alameda Parkway, Denver, CO 80225. 

USDI (U.S. Department of the Interior), Bureau of Land Management (BLM). 1999. New Mexico BLM 

Sensitive Species List. February 1999. USDI, BLM, 1474 Rodeo Rd., Santa Fe, NM 87502. 

USDI (U.S. Department of the Interior), National Park Service (NPS). 1995. Report of effects of aircraft 

overflights on the National Park System. USDI-NPS D-1062, July, 1995. 

USFWS (U.S. Fish and Wildlife Service). 2008. News Release: Gunnison’s Prairie Dog Populations in 

Portions of Colorado and New Mexico Warranted for Listing Under the Endangered Species Act. 

USFWS, Mountain-Prairie Region, 134 Union Boulevard, Lakewood, Colorado 80228. 

USFWS (U.S. Fish and Wildlife Service). 2007. Letter regarding 4(f)(1) Determination regarding recovery 

planning for the jaguar (Panthera onca). USFWS, P.O. Box 1306, Albuquerque, New Mexico 87103. 

5pp. 

USFWS (U.S. Fish and Wildlife Service), Endangered Species Program. 2009. Species information. 

Retrieved on February 26, 2009 from www.fws.gov/endangered/wildlife.html. 

USFWS (U.S. Fish and Wildlife Service). 2009b. USFWS Management Offices – State, Territorial, and 

Tribal. Retrieved on March 9, 2009 from http://www.fws.gov/offices/statelinks.html. 

USFWS (U.S. Fish and Wildlife Service). 2007. Red Wolf 5-Year Status Review: Summary and 

Evaluation. Manteo, NC. 58pp. 

USFWS (U.S. Fish and Wildlife Service). 1999. Biological Opinion — Effects of the Nationwide Wildlife 

Services Program on the Jaguar. USFWS, 2321 W. Royal Palm Road, Suite 103. Phoenix, AZ 85021-

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the Nationwide Wildlife Services Program on the Mexican Gray Wolf. USFWS, P.O. Box 1306, 

Albuquerque, NM 87103. 17pp. + Appendices A & B. 

USFWS (U.S. Fish and Wildlife Service). 1997. Biological Opinion — Effects of the Nationwide Wildlife 

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87103. 23pp. 

USFWS (U.S. Fish and Wildlife Service). 1990. Listed Cats of Texas and Arizona Recovery Plan (with 

Emphasis on the Ocelot). Albuquerque, NM. 131pp. 

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Wandeler, A.I. 1991. Oral immunization of wildlife. p. 485-505 in The natural history of rabies, 2nd ed., 

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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Watson, J.W. 1993. Responses of nesting bald eagles to helicopter surveys. Wildl. Soc. Bull. 21:171-178. 

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Vaccination of black-footed ferret (Mustela nigripes) x Siberian polecat (M. eversmanni) hybrids and 

domestic ferrets (M. putorius furo) against canine distemper. J. Wildl. Dis. 32(3):417-423 
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. 

APPENDIX C 

SPECIES LISTED AS THREATENED OR ENDANGERED 

UNDER THE ENDANGERED SPECIES ACT 

Information obtained from http://ecos.fws.gov/tess_public/StateListing.do?state=all on March 2009. 

Alabama -- 117 listings 

Animals – 99 

Status Listing 

E Acornshell, southern (Epioblasma othcaloogensis) 

T Bankclimber, purple (mussel) (Elliptoideus sloatianus)

E Bat, gray (Myotis grisescens) 

E Bat, Indiana (Myotis sodalis) 

E Bean, Cumberland (pearlymussel) Entire Range; Except where listed as Experimental Populations (Villosa trabalis) 

XN Bean, Cumberland (pearlymussel) AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and 

Lauderdale Counties, AL (Villosa trabalis)

E Beetle, American burying (Nicrophorus americanus) 

E Blossum, tubercled (pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma torulsa 

torulosa) 

XN Blossum, tubercled (pearlymussel) AL; Free-Flowing Reaches of the Tennessee River below the Wilson dam, Colbert and 

Lauderdale Counties (Epioblasma torulsa torulosa) 

E Blossum, turgid (pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma turgidula) 

XN Blossom, turgid (pearlymussel) AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and 

Lauderdale Counties, AL (Epioblasma turgidula) 

E Blossum, yellow (pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma florentina 

florentina) 

XN Blossom, yellow (pearlymussel) AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and 

Lauderdale Counties, AL (Epioblasma florentina florentina) 

E Campeloma, slender (Campeloma decampi) 

E Catspaw (=purple cat's paw pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma 

obliquata obliquata) 

XN Catspaw (=purple cat's paw pearlymussel) AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, 

Colbert and Lauderdale Counties, AL (Epioblasma obliquata obliquata) 

E Cavefish, Alabama (Speoplatyrhinus poulsoni) 

T Chub, spotfin Entire (Cyprinella monacha) 

E Clubshell Enitre Range; Except where listed as Experimental Popualtions (Pleurobema clava) 

XN Clubshell AL; Free-Flowing Reaches of the Tennessee River below the Wilson Dam, Colbert and Lauderdale Counties, AL 

(Pleurobema clava) 

E Clubshell, black (Pleurobema curtum) 

E Clubshell, ovate (Pleurobema perovatum) 

E Clubshell, southern (Pleurobema decisum) 

E Combshell, Cumberlandian Entire Range; Except where listed as Experimental Populations (Epioblasma brevidens) 

XN Combshell, Cumberlandian AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and 

Lauderdale Counties, AL (Epioblasma brevidens) 

E Combshell, southern (Epioblasma penita) 

E Combshell, upland (Epioblasma metastriata) 

E Curlew, Eskimo (Numenius borealis) 

E Darter, amber (Percina antesella) 

E Darter, boulder (Etheostoma wapiti) 

T Darter, goldline (Percina aurolineata) 

T Darter, slackwater (Etheostoma boschungi) 

T Darter, snail (Percina tanasi) 

E Darter, vermilion (Etheostoma chermocki) 

E Darter, watercress (Etheostoma nuchale) 

T Elimia, lacy (snail) (Elimia crenatella) 

E Fanshell (Cyprogenia stegaria) 

E Frog, Mississippi gopher Whereever found west of Mobile and Tombigbee Rivers in AL, MS, and LA (Rana captio 

sevosa) 

T Heelsplitter, Alabama (=inflated) (Potamilus inflatus) 

E Kidneyshell, triangular (Ptychobranchus greeni) 

E Lampmussel, Alabama Entire Range; Except where listed as Experimental Populations (Lampsilis virescens) 

XN Lampmussel, Alabama AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and Lauderdale 

Counties, AL (Lampsilis virescens) 

E Lilliput, pale (pearlymussel) (Toxolasma cylindrellus) 

E Lioplax, cylindrical (snail) (Lioplax cyclostomaformis) 

E Mapleleaf, winged Entire, except where listed as experimental populations (Quadrula fragosa) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

XN Mapleleaf, winged (mussel) AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and 

Lauderdale Counties, AL (Quadrula fragosa) 

T Moccasinshell, Alabama (Medionidus acutissimus) 

E Monkeyface, Cumberland (pearlymussel) Entire Range; Except where listed as Experimental Populations (Quadrula 

intermedia) 

XN Monkeyface, Cumberland (pearlymussel) AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert 

and Lauderdale Counties, AL (Quadrula intermedia) 

E Mouse, Alabama beach (Peromyscus polionotus ammobates) 

E Mouse, Perdido Key beach (Peromyscus polionotus trissyllepsis) 

T Mucket, orangenacre (Lampsilis perovalis) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 

E Mussel, oyster Entire Range; Except where listed as Experimental Populations (Epioblasma capsaeformis) 

XN Mussel, oyster AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and Lauderdale Counties, 

AL (Epioblasma capsaeformis) 

E Mussel, scaleshell (LEptodea leptodon) 

E Panther, Florida (Puma (=Felis) concolor coryi) 

E Pearlymussel, cracking Entire Range; Except where listed as Experimental Populations (Hemistena lata) 

XN Pearlymussel, cracking AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and Lauderdale 

Counties, AL (Hemistena lata) 

XN Pearlymussel, dromedary AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and Lauderdale 

Counties, AL (Dromus dromas) 

E Pearlymussel, littewing (Pegias fibula) 

E Pebblesnail, flat (Lepyrium showalteri) 

E Pelican, brown except U.S. Atlantic coast, FL, Al (Pelecanus occidentalis) 

E Pigtoe, dark (Pleurobema furvum) 

E Pigtoe, finerayed Entire Range; Except where listed as Experimental Populations (Fusconaia cuneolus) 

XN Pigtoe, finerayed AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and Lauderdale 

Counties, AL (Fusconaia cuneolus) 

E Pigtoe, flat (Pleurobema marshalli) 

E Pigtoe, heavy (Pleurobema taitianum) 

E Pigtail, oval (Pleurobema pyriforme) 

E Pigtoe, rough (Pleurobema plenum) 

E Pigtoe, shiny Entire Range; Except where listed as Experimental Populations (Fusconaia cor) 

XN Pigtoe, shiny AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and Lauderdale Counties, 

AL (Fusconaia cor) 

E Pigtoe, southern (Pleurobema georgianum) 

E Pimpleback, orangefoot (pearlymussel) (Plethobasus cooperianus) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

T Pocketbook, finelined (Lampsilis altilis) 

E Pocketbook, shinyrayed (Lampsilis subangulata) 

E Riffleshell, tan (Epioblasma florentina walkeri (=E. walkeri)) 

E Ring pink (mussel) (Obovaria retusa) 

E Riversnail, Anthony's Entire Range; Except where listed as Experimental Populations (Athearnia anthonyi) 

XN Riversnail, Anthony's AL; Free-Flowing Reach of the Tennessee River below the Wilson Dam, Colbert and Lauderdale 

Counties, AL (Athearnia anthonyi) 

T Rocksnail, painted (Leptoxis taeniata) 

E Rocksnail, plicate (Leptoxis plicata) 

T Rocksnail, round (Leptoxis ampla) 

T Salamander, frosted flatwoods (Ambystoma cingulatum) 

T Salamander, Red Hills (Phaeognathus hubrichti) 

T Sculpin, pygmy (Cottus paulus (=pygmaeus)) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

T Shiner, blue (Cyprinella caerulea) 

E Shiner, Cahaba (Notropis cahabae) 

E Shiner, palezone (Notropis albizonatus) 

E Shrimp, Alabama cave (Palaemonias alabamae) 

T Slabshell, Chipola (Elliptio chipolaensis) 

E Snail, armored (Pyrgulopsis (=Marstonia) pachyta) 

E Snail, tulotoma (Tulotoma magnifica) 

T Snake, eastern indigo (Drymarchon corais couperi) 

E Stirrupshell (Quadrula stapes) 

E Stork, wood (AL, FL, GA, SC) (Mycteria americana) 

E Sturgeon, Alabama (Scaphirhynchus suttkusi) 

T Sturgeon, gulf (Acipenser oxyrinchus desotoi) 

T Tortoise, gopher (W of of Mobile/Tombigbee Rs.) (Gopherus polyphemus) 

E Turtle, Alabama red-belly (Pseudemys alabamensis) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

T Turtle, flattened musk (species range clarified) (Sternotherus depressus) 

E Wartyback, white (pearlymussel) (Plethobasus cicatricosus) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico (Canis lupus) 

E Woodpecker, red-cockaded (Picoides borealis) 

Plants -- 18

Status Listing 

T Amphianthus, little (Amphianthus pusillus) 

T Potato-bean, Price's (Apios priceana) 

T Fern, American hart's-tongue (Asplenium scolopendrium var. americanum) 

E Leather flower, Morefield's (Clematis morefieldii) 

E Leather flower, Alabama (Clematis socialis) 

E Prairie-clover, leafy (Dalea foliosa) 

T Bladderpod, lyrate (Lesquerella lyrata) 

T Button, Mohr's Barbara (Marshallia mohrii) 

E Harperella (Ptilimnium nodosum) 

T Water-plantain, Kral's (Sagittaria secundifolia) 

E Pitcher-plant, green (Sarracenia oreophila) 

E Pitcher-plant, Alabama canebrake (Sarracenia rubra alabamensis) 

E Chaffseed, American (Schwalbea americana) 

E Pinkroot, gentian (Spigelia gentianoides) 

T Fern, Alabama streak-sorus (Thelypteris pilosa var. alabamensis) 

E Trillium, relict (Trillium reliquum) 

E Grass, Tennessee yellow-eyed (Xyris tennesseensis) 

E Pondberry (Lindera melissifolia) 

Arizona -- 55 Listings

Animals - 38 

Status Listing 

E Ambersnail, Kanab (Oxyloma haydeni kanabensis) 

E bat, lesser long-nosed (Leptonycteris curasoae yerbabuenae) 

T Bear, grizzly lower 48 States, except where listed as an experimental population or delisted (Ursus arctos horribilis) 

E Bobwhite, masked (quail) (Colinus virginianus ridgwayi) 

T Catfish, Yaqui (Ictalurua procei) 

E Chub, bonytail entire (Gila elegans) 

E Chub, Gila (Gila intermedia) 

E Chub, humpback entire (Gila cypha) 

T Chub, Sonora (Gila ditaenia) 

E Chub, Virgin River (Gila seminude (=robusta)) 

E Chub, Yaqui (Gila purpurea) 

E Condor, California U.S.A only (Gymnogyps californianus) 

E Curlew, Eskimo (Numeniu borealis) 

T Eagle, bald Sonoran Desert DPS: Arizona: (1) Yavapai, northern Mexico. Gila, Graham, Pinal, amd Maricopa, Counties; 

and (2) Southern Mohave County (that portion south and east of the center of Interstate Highway 40 and east of Arizona 

Highway 95), eastern laPaz County (that portion east of the centerline of U.S. and Arizona Highways 95), and north of the 

centerline of Interstate Highway 8) (Haliaeetus leucocephalus) 

E Falcon, northern aplomado (Falco femoralis septntrionalis) 

E Ferret, black-footed entire population, except where EXPN (Mustela nigripes) 

XN Ferret, black-footed U.S.A. (specific portions of AZ, CO, MT, SD, UT, WY) (Mustela nigripes) 

E Flycatcher, southwestern willow (Empidonax traillii extimus) 

T Frog, Chiricahua leopard (Rana chiricahuensis) 

E Jaguar (Panthera onca) 

E Jaguarundi, Sinalaon (Herpailurus (+Felis) yagouroundi tolteca) 

T Minnow, loach (Tairoga cobitis) 

E Ocelt (Leopardus (=Felis) paradlis) 

T Owl, Mexican spotted (Strix occidentalis lucida) 

E Pronghorn, Sonoran (Antilocara americana sonoriensis) 

E Pupfish, desert (Cyprinodon macularius) 

E Rail, Yuma clapper U.S.A. only (Rallus longirostris yumanensis) 

T Rattlesnake, New Mexican ridge-nosed (Crotalus willardi obscurus) 

E Salamander, Sonora tiger (Ambystoma tigrinum stebbinsi) 

T Shiner, beautiful (Cyprinella Formosa) 

T Spikedace (Meda fulgida) 

T Spinedace, Little Colorado (Lepidomeda vittata) 

E Squirrel, Mount Graham red (Tamiasciurus hudsonicus grahamenisi) 

E Sucker, razorback entire (Xyrauchen texanus) 

E Topminnow, Gila (incl. Yaqui) U.S.A only (Poeciliopsis occidentalis) 

T Trout, Apache (Oncorhynchus apache) 

T Trout, Gila (Oncorhynchus gilae) 
C-4 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Vole, Hualapai Mexican (Microtus mexicanus hualpaiensis) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico (Canus lupus) 

XN Wolf, gray Mexican gray wolf, EXPN population U.S.A. (portions of AZ, NM, TX) (Canus lupus) 

Plants -- 17

Status Listing 

E Blue-star, Kearney’s (Amsonia kearneyana) 

E Cactus, Arizona hedgehog (Echinocereus triglochidiatus var. arizonicus) 

E Cactus, Brady pincushion (Pediocactus bradyi) 

T Cactus, Cochise pincushion (Coryphantha robbinsorum) 

E Cactus, Nichol’s Turk’s head (Echinocactus horizonthalionus var. nicholii) 

E Cactus, Peebles Navajo (Pediocactus peeblesianus peeblesianus) 

E Cactus, Pima pineapple (Coryphantha scheeri var. rabustispina) 

T Cactus, Siler pincushion (Pediocactus (=Echinocactus, =Utahia) sileri) 

E Cliff-rose, Arizona (Purshia (=Cowania) subintegra) 

T Cycladeni, Jones (Cycladeni jonesii (=humilis)) 

T Groundsel, San Francisco Peaks (Sencio franciscanus) 

E Ladies’-tresses, Canelo Hills (Spiranthus delitescens) 

E Milk-vetch, Sentry (Astragalus cremnophylax var. cremnophylax) 

T Milkweed, Welsh’s (Asclepias welshii) 

T Sedge, Navajo (Carex specuicola) 

E Water-umbel, Huachuca (Lilaeopsis schaffneriana var. recurva) 

Connecticut -- 21 listings

Animals – 18

Status Listing 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numenius borealis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

E Tern, roseate (northeast U.S. nesting pop.) (Sterna dougallii dougallii) 

T Tiger beetle, northeastern beach (Cicindela dorsalis dorsalis) 

T Tiger beetle, Puritan (Cicindela puritana) 

T Turtle, bog (=Muhlenberg) (northern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, finback (Balaenoptera physalus) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canus lupus) 

Plants -- 3

Status Listing 

E Chaffseed, American (Schwalbea Americana) 

E Gerardia, sandplain (Agalinis acuta) 

T Pogonia, small whorled (Isotria medeoloides) 

Delaware -- 23 listings

Animals – 17

Status Listing 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numenius borealis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Squirrel, Delmarva Peninsula fox (except Sussex Co., DE) (Sciurus niger cinereus) 

XN Squirrel, Delmarva Peninsula fox [XN] (Sciurus niger cinereus) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

T Turtle, bog (=Muhlenberg) (northern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 
C-5 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Plants -- 6

Status Listing 

T Amaranth, seabeach (Amaranthus pumilus) 

E Chaffseed, American (Schwalbea Americana) 

T Pink, swamp (Helonias bullata) 

T Joint-vetch, sensitive (Aeschnomene virginica) 

T Pogonia, small whorled (Isotria medeoloides) 

E Dropwort, Canby's (Oxypolis canbyi) 

District of Columbia -- 7 listings

Animals – 6

Status Listing 

E Amphipod, Hay's Spring (Stygobromus hayi) 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numensius borealis) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico (Canis lupus) 

Plants – 1

T Pogonia, small whorled (Isotria medeoloides) 

Florida -- 116 listings

Animals – 61

Status Listing 

T(S/A) Alligator, American (Alligator mississippiensis) 

T Bankclimber, purple (mussel) (Elliptoideus sloatianus) 

E Bat, gray (Myotis grisescens) 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfly, Schaus swallowtail (Heraclides aristodemus ponceanus) 

T Caracara, Audubon's crested (FL pop.) (Polyborus plancus audubonii) 

XN Crane, whooping U.S.A. (CO, ID, FL, NM, UT, and the western half of Wyoming) (Grus americana) 

T Crocodile, American FL pop. (Crocodylus acutus) 

E Curlew, Eskimo (Numenius borealis) 

E Darter, Okaloosa (Etheostoma okaloosae) 

E Deer, key (Odocoileus virginianus clavium) 

T Jay, Florida scrub (Aphelocoma coerulescens) 

E Kite, Everglade snail (FL pop.) (Rostrhamus sociabilis plumbeus) 

E Manatee, West Indian (Trichechus manatus) 

E Moccasinshell, Gulf (Medionidus penicillatus) 

E Moccasinshell, Ochlockonee (Medionidus simpsonianus) 

E Mouse, Anastasia Island beach (Peromyscus polionotus phasma) 

E Mouse, Choctawhatchee beach (Peromyscus polionotus allophrys) 

E Mouse, Key Largo cotton (Peromyscus gossypinus allapaticola) 

E Mouse, Perdido Key beach (Peromyscus polionotus trissyllepsis) 

T Mouse, southeastern beach (Peromyscus polionotus niveiventris) 

E Mouse, St. Andrew beach (Peromyscus polionotus peninsularis) 

E Panther, Florida (Puma (=Felis) concolor coryi) 

E Pelican, brown except U.S. Atlantic coast, FL, Al (Pelecanus occidentalis) 

E Pigtoe, oval (Pleurobema pyriforme) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Pocketbook, shinyrayed (Lampsilis subangulata) 

T(S/A) Puma (=mountain lion) (FL) (Puma (=Felis) concolor (all subsp. except coryi)) 

E Rabbit, Lower Keys marsh (Sylvilagus palustris hefneri) 

E Rice rat (lower FL Keys) (Oryzomys palustris natator) 

T Salamander, frosted flatwoods (Ambystoma cingulatum) 

E Sawfish, smalltooth (Pristis pectinata) 

E Sea turtle, green (FL, Mexico nesting pops.) (Chelonia mydas) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Seal, Caribbean monk (Monachus tropicalis) 

T Shrimp, Squirrel Chimney Cave (Palaemonetes cummingi) 

T Skink, bluetail mole (Eumeces egregius lividus) 

T Skink, sand (Neoseps reynoldsi) 

T Slabshell, Chipola (Elliptio chipolaensis) 

T Snail, Stock Island tree (Orthalicus reses (not incl. nesodryas)) 

T Snake, Atlantic salt marsh (Nerodia clarkii taeniata) 

T Snake, eastern indigo (Drymarchon corais couperi) 
C-6 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Sparrow, Cape Sable seaside (Ammodramus maritimus mirabilis) 

E Sparrow, Florida grasshopper (Ammodramus savannarum floridanus) 

E Stork, wood (AL, FL, GA, SC) (Mycteria americana) 

T Sturgeon, gulf (Acipenser oxyrinchus desotoi) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

T Tern, roseate (Western Hemisphere except NE U.S.) (Sterna dougallii dougallii) 

E Three-ridge, fat (mussel) (Amblema neislerii) 

E Vole, Florida salt marsh (Microtus pennsylvanicus dukecampbelli) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico (Canis lupus) 

E Wolf, red (except where XN) (Canis rufus) 

E Woodpecker, red-cockaded (Picoides borealis) 

E Woodrat, Key Largo (Neotoma floridana smalli) 

Plants -- 55

Status Listing 

E Aster, Florida golden (Chrysopsis floridana) 

E Beargrass, Britton's (Nolina brittoniana) 

E Beauty, Harper's (Harperocallis flava) 

E Bellflower, Brooksville (Campanula robinsiae) 

T Birds-in-a-nest, white (Macbridea alba) 

E Blazingstar, scrub (Liatris ohlingerae) 

T Bonamia, Florida (Bonamia grandiflora) 

T Buckwheat, scrub (Eriogonum longifolium var. gnaphalifolium) 

T Butterwort, Godfrey's (Pinguicula ionantha) 

E Cactus, Key tree (Pilosocereus robinii) 

E Campion, fringed (Silene polypetala) 

E Chaffseed, American (Schwalbea americana) 

E Cladonia, Florida perforate (Cladonia perforata) 

E Fringe-tree, pygmy (Chionanthus pygmaeus) 

T Gooseberry, Miccosukee (Ribes echinellum) 

E Gourd, Okeechobee (Cucurbita okeechobeensis ssp. okeechobeensis) 

E Harebells, Avon Park (Crotalaria avonensis) 

E Hypericum, highlands scrub (Hypericum cumulicola) 

E Jacquemontia, beach (Jacquemontia reclinata) 

E Lead-plant, Crenulate (Amorpha crenulata) 

E Lupine, scrub (Lupinus aridorum) 

E Meadowrue, Cooley's (Thalictrum cooleyi) 

E Milkpea, Small's (Galactia smallii) 

E Mint, Garrett's (Dicerandra christmanii) 

E Mint, longspurred (Dicerandra cornutissima) 

E Mint, scrub (Dicerandra frutescens) 

E Mint, Lakela's (Dicerandra immaculata) 

E Mustard, Carter's (Warea carteri) 

E Pawpaw, beautiful (Deeringothamnus pulchellus) 

E Pawpaw, four-petal (Asimina tetramera) 

E Pawpaw, Rugel's (Deeringothamnus rugelii) 

T Pigeon wings (Clitoria fragrans) 

E Pinkroot, gentian (Spigelia gentianoides) 

E Plum, scrub (Prunus geniculata) 

E Polygala, Lewton's (Polygala lewtonii) 

E Polygala, tiny (Polygala smallii) 

E Pondberry (Lindera melissifolia) 

E Prickly-apple, fragrant (Cereus eriophorus var. fragrans) 

E Rhododendron, Chapman (Rhododendron chapmanii) 

E Rosemary, Apalachicola (Conradina glabra) 

E Rosemary, Etonia (Conradina etonia) 

E Rosemary, short-leaved (Conradina brevifolia) 

E Sandlace (Polygonella myriophylla) 

T Seagrass, Johnson's (Halophila johnsonii) 

T Skullcap, Florida (Scutellaria floridana) 

E Spurge, deltoid (Chamaesyce deltoidea ssp. deltoidea) 

T Spurge, Garber's (Chamaesyce garberi) 

T Spurge, telephus (Euphorbia telephioides) 

E Snakeroot (Eryngium cuneifolium) 

E Torreya, Florida (Torreya taxifolia) 

E Warea, wide-leaf (Warea amplexifolia) 

E Water-willow, Cooley's (Justicia cooleyi) 

T Whitlow-wort, papery (Paronychia chartacea) 
C-7 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Wireweed (Polygonella basiramia) 

E Ziziphus, Florida (Ziziphus celata) 

Georgia -- 74 listings

Animals – 52

Status Listing 

E Acornshell, southern (Epioblasma othcaloogensis) 

T(S/A) Alligator, American (Alligator mississippiensis) 

T Bankclimber, purple (mussel) (Elliptoideus sloatianus) 

E Bat, gray (Myotis grisescens) 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

T Chub, spotfin Entire (Erimonax monachus) 

E Clubshell, ovate (Pleurobema perovatum) 

E Clubshell, southern (Pleurobema decisum) 

E Combshell, upland (Epioblasma metastriata) 

E Curlew, Eskimo (Numenius borealis) 

E Darter, amber (Percina antesella) 

T Darter, Cherokee (Etheostoma scotti) 

E Darter, Etowah (Etheostoma etowahae) 

T Darter, goldline (Percina aurolineata) 

T Darter, snail (Percina tanasi) 

E Kidneyshell, triangular (Ptychobranchus greeni) 

E Lioplax, cylindrical (snail) (Loiplax cyclostomaformis)

E Logperch, Conasauga (Percina jenkinsi) 

E Manatee, West Indian (Trichechus manatus) 

T Moccasinshell, Alabama (Medionidus acutissimus) 

E Moccasinshell, Coosa (Medionidus parvulus) 

E Moccasinshell, Gulf (Medionidus penicillatus) 

E Moccasinshell, Ochlockonee (Medionidus simpsonianus) 

E Mussel, oyster Entire Range; Except where listed as EXPN populations (Epioblasma capsaeformis) 

E Panther, Florida (Puma (=Felis) concolor coryi) 

E Pelican, brown except U.S. Atlantic coast, FL, AL (Pelecanus occidentalis) 

E Pigtoe, oval (Pleurobema pyriforme) 

E Pigtoe, southern (Pleurobema georgianum) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

T Pocketbook, finelined (Lampsilis altilis) 

E Pocketbook, shinyrayed (Lampsilis subangulata) 

E Riversnail, Anthony's Entire Range; Except where listed as EXPN (Athearnia anthonyi) 

T Salamander, flatwoods (Ambystoma cingulatum) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

T Shiner, blue (Cyprinella caerulea) 

T Snake, eastern indigo (Drymarchon corais couperi) 

E Stork, wood (AL, FL, GA, SC) (Mycteria americana) 

T Sturgeon, gulf (Acipenser oxyrinchus desotoi) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

T Tern, roseate (Western Hemisphere except NE U.S.) (Sterna dougallii dougallii) 

E Three-ridge fat (mussel) (Amblema neislerii) 

T(S/A) Turtle, bog (=Muhlenberg) (southern) (Clemmys muhlenbergii) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Woodpecker, red-cockaded (Picoides borealis) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico (Canis lupus) 

Plants -- 22

Status Listing 

T Amphianthus, little (Amphianthus pusillus) 

E Rattleweed, hairy (Baptisia arachnifera) 

E Coneflower, smooth (Echinacea laevigata) 

T Pink, swamp (Helonias bullata) 

E Quillwort, black spored (Isoetes melanospora) 

E Quillwort, mat-forming (Isoetes tegetiformans) 

T Pogonia, small whorled (Isotria medeoloides) 

E Pondberry (Lindera melissifolia) 
C-8 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

T Button, Mohr's Barbara (Marshallia mohrii) 

E Dropwort, Canby's (Oxypolis canbyi) 

E Harperella (Ptilimnium nodosum) 

E Sumac, Michaux's (Rhus michauxii) 

T Water-plantain, Kral's (Sagittaria secundifolia) 

E Pitcher-plant, green (Sarracenia oreophila) 

E Chaffseed, American (Schwalbea americana) 

T Skullcap, large-flowered (Scutellaria montana) 

E Campion, fringed (Silene polypetala) 

T Spiraea, Virginia (Spiraea virginiana) 

E Torreya, Florida (Torreya taxifolia) 

E Trillium, persistent (Trillium persistens) 

E Trillium, relict (Trillium reliquum) 

E Grass, Tennessee yellow-eyed (Xyris tennesseensis) 

Indiana -- 31 listings

Animals – 27

Status Listing 

E Bat, gray (Myotis grisescens) 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfly, Karner blue (Lycaeides melissa samuelis) 

E Butterfly, Mitchell's satyr (Neonympha mitchellii mitchellii) 

E Catspaw (=purple cat's paw pearlymussel) Entire Range; Except where listed as EXPN (Epioblasma obliquata obliquata) 

E Catspaw, white (pearlymussel) (Epioblasma obliquata perobliqua) 

E Clubshell Entire Range; Except where listed as Experimental Populations (Pleurobema clava) 

E Curlew, Eskimo (Numenius borealis) 

E Dragonfly, Hine’s emerald (Somatochlora hineana) 

E Fanshell (Cyprogenia stegaria) 

E Mapleleaf, winged Entire; except where listed as EXPN (Quadrula fragosa) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 

E Mussel, scaleshell (leptodea leptodon) 

E Pearlymussel, cracking Entire Range; Except where listed as Experimental Populations (Hemistena lata) 

E Pigtoe, rough (Pleurobema plenum) 

E Pimpleback, orangefoot (pearlymussel) (Plethobasus cooperianus) 

E Plover, piping (Great Lakes watershed) (Charadrius melodus) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Pocketbook, fat (Potamilus capax) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Riffleshell, northern (Epioblasma torulosa rangiana) 

E Ring pink (mussel) (Obovaria retusa) 

T Snake, copperbelly water (MI, OH, IN N of 400 N. Lat.) (Nerodia erythrogaster neglecta) 

E Tern, least (interior pop.) (Sterna antillarum) 

E Wartyback, white (pearlymussel) (Plethobasus cicatricosus) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 4

Status Listing 

T Milkweed, Mead's (Asclepias meadii) 

T Thistle, Pitcher's (Cirsium pitcheri) 

E Clover, running buffalo (Trifolium stoloniferum) 

T Orchid, eastern prairie fringed (Platanthera leucophaea) 

Kentucky -- 41listings 

Animals -- 33

Status Listing 

E Bat, gray (Myotis grisescens) 

E Bat, Indiana (Myotis sodalis) 

E Bat, Virginia big-eared (Corynorhinus (=Plecotus) townsendii virginianus) 

E Bean, Cumberland (pearlymussel) Entire Range; Except where listed as Experimental Populations (Villosa trabalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Catspaw (=purple cat's paw pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma 

obliquata obliquata) 

E Clubshell Entire Range; Except where listed as Experimental Populations (Pleurobema clava) 

E Combshell, Cumberlandian Entire Range; Except where listed as Experimental Populations (Epioblasma brevidens) 

E Curlew, Eskimo (Numenius borealis) 

T Dace, blackside (Phoxinus cumberlandensis) 

E Darter, relict (Etheostoma chienense) 

E Elktoe, Cumberland (Alasmidonta atropurpurea) 

E Fanshell (Cyprogenia stegaria) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 
C-9 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Mussel, oyster Entire Range; Except where listed as Experimental Populations (Epioblasma capsaeformis) 

E Mussel, scaleshell (Leptodea leptodon) 

E Pearlymussel, cracking Entire Range; Except where listed as Experimental Populations (Hemistena lata) 

E Pearlymussel, dromedary Entire Range; Except where listed as Experimental Populations (Dromus dromas) 

E Pearlymussel, littlewing (Pegias fabula) 

E Pigtoe, rough (Pleurobema plenum) 

E Pimpleback, orangefoot (pearlymussel) (Plethobasus cooperianus) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Pocketbook, fat (Potamilus capax) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Riffleshell, northern (Epioblasma torulosa rangiana) 

E Riffleshell, tan (Epioblasma florentina walkeri (=E. walkeri)) 

E Ring pink (mussel) (Obovaria retusa) 

E Shiner, palezone (Notropis albizonatus) 

E Shrimp, Kentucky cave (Palaemonias ganteri) 

E Sturgeon, pallid (Scaphirhynchus albus) 

E Tern, least (interior pop.) (Sterna antillarum) 

E Wartyback, white (pearlymussel) (Plethobasus cicatricosus) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 8

Status Listing 

T Potato-bean, Price's (Apios priceana) 

E Rock-cress, Braun's (Arabis perstellata) 

E Sandwort, Cumberland (Arenaria cumberlandensis) 

T Rosemary, Cumberland (Conradina verticillata) 

T Goldenrod, white-haired (Solidago albopilosa) 

E Goldenrod, Short's (Solidago shortii) 

T Spiraea, Virginia (Spiraea virginiana) 

E Clover, running buffalo (Trifolium stoloniferum) 

Louisiana -- 32 listings

Animals –28

Status Listing 

T(S/A) Alligator, American (Alligator mississippiensis) 

T(S/A) Bear, American black (County range of LA b.bear) (Ursus americanus) 

T Bear, Louisiana black (Ursus americanus luteolus) 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numenius borealis) 

E Frog, Mississippi gopher Wherever found west of Mobile and Tombogbee Rivers in AL, MS, and LA (Rana captio sevosa) 

T Heelsplitter, Alabama (=inflated) (Potamilus inflatus) 

E Jaguar (Panthera onca) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 

E Panther, Florida (Puma (=Felis) concolor coryi) 

T Pearlshell, Louisiana (Margaritifera hembeli) 

E Pelican, brown (except U.S. Atlantic coast, FL, AL) (Pelecanus occidentalis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

T Sturgeon, gulf (Acipenser oxyrinchus desotoi) 

E Sturgeon, pallid (Scaphirhynchus albus) 

E Tern, least (interior pop.) (Sterna antillarum) 

T Tortoise, gopher (W of of Mobile/Tombigbee Rs.) (Gopherus polyphemus) 

T Turtle, ringed map ( Graptemys oculifera) 

E Vireo, black-capped (Vireo atricapilla) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

E Woodpecker, red-cockaded (Picoides borealis) 

Plants --4

Status Listing 

T Geocarpon minimum (No common name) 

E Quillwort, Louisiana (Isoetes louisianensis) 

E Chaffseed, American (Schwalbea americana) 

E Pondberry (Lindera melissifolia) 

Maine -- 16 listings

Animals – 13
C-10 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Status Listing 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numenius borealis) 

T Lynx, Canada (Lynx canadensis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Salmon, Atlantic Gulf of Maine Atlantic Salmon DPS (Salmo salar) 

E Sea turtle, leatherback (Dermochelys coriacea) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

E Tern, roseate (northeast U.S. nesting pop.) (Sterna dougallii dougallii) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

T Wolf, gray Eastern Distinct Population Segment (Canis lupus) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 3

Status Listing 

T Pogonia, small whorled (Isotria medeoloides) 

E Lousewort, Furbish (Pedicularis furbishiae) 

T Orchid, eastern prairie fringed (Platanthera leucophaea) 

Maryland -- 31 listings

Animals –21 

Status Listing 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numenius borealis) 

E Darter, Maryland (Etheostoma sellare) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Squirrel, Delmarva Peninsula fox (except Sussex Co., DE) (Sciurus niger cinereus) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

T Tiger beetle, northeastern beach (Cicindela dorsalis dorsalis) 

T Tiger beetle, Puritan (Cicindela puritana) 

T Turtle, bog (=Muhlenberg) (northern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants – 10

Status Listing 

T Joint-vetch, sensitive (Aeschynomene virginica) 

E Gerardia, sandplain (Agalinis acuta) 

T Amaranth, seabeach (Amaranthus pumilus) 

T Pink, swamp (Helonias bullata) 

E Dropwort, Canby's (Oxypolis canbyi) 

E Harperella (Ptilimnium nodosum) 

E Bulrush, Northeastern (Scirpus ancistrochaetus) 

E Chaffsee, American (Schwalbea Americana) 

E Coneflower, smooth (Echinacea laevigata) 

T Pogonia, small whorled (Isotria medeoloides) 

Massachusetts -- 27 listings

Animals – 22

Status Listing 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfy, Karner blue (Lycaeides melissa samuelis) 

E Curlew, Eskimo (Numenius borealis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Plymouth Red-Bellied Turtle (Pseudemys rubriventris bangsi) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 
C-11 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

T Sea turtle, loggerhead (Caretta caretta) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

E Tern, roseate (northeast U.S. nesting pop.) (Sterna dougallii dougallii) 

T Tiger beetle, northeastern beach (Cicindela dorsalis dorsalis) 

T Tiger beetle, Puritan (Cicindela puritana) 

T Turtle, bog (=Muhlenberg) (northern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, blue (Balaenoptera musculus) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Whale, Sei (Balaenoptera borealis) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 5

Status Listing 

T Amaranth, seabeach (Amaranthus pumilus) 

E Bulrush, Northeastern (Scirpus ancistrochaetus) 

E Chaffseed, American (Schwalbea Americana) 

E Gerardia, sandplain (Agalinis acuta) 

T Pogonia, small whorled (Isotria medeoloides) 

Michigan -- 25 listings

Animals – 16

Status Listing 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Beetle, Hungerford's crawling water (Brychius hungerfordi) 

E Butterfly, Karner blue (Lycaeides melissa samuelis) 

E Butterfly, Mitchell's satyr (Neonympha mitchellii mitchellii) 

E Catspaw, white (pearlymussel) (Epioblasma obliquata perobliqua) 

E Clubshell Entire Range; Except where listed as Experimental Populations (Pleurobema clava) 

E Curlew, Eskimo (Numenius borealis) 

E Plover, piping (Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Riffleshell, northern (Epioblasma torulosa rangiana) 

T Snake, copperbelly water (MI, OH, IN N of 400 N. Lat.) (Nerodia erythrogaster neglecta) 

E Warbler (=wood), Kirtland's (Dendroica kirtlandii) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

E Wolf, gray Western Great Lakes DPS (Canis lupus) 

Plants -- 9

Status Listing 

E Chaffseed, American (Schwalbea Americana) 

T Daisy, lakeside (Hymenoxys herbacea) 

T Fern, American hart's-tongue (Asplenium scolopendrium var. americanum) 

T Goldenrod, Houghton's (Solidago houghtonii) 

T Iris, dwarf lake (Iris lacustris) 

E Monkey-flower, Michigan (Mimulus glabratus var. michiganensis) 

T Orchid, eastern prairie fringed (Platanthera leucophaea) 

T Pogonia, small whorled (Isotria medeoloides) 

T Thistle, Pitcher's (Cirsium pitcheri) 

Mississippi -- 42 listings

Animals -- 38

Status Listing 

T(S/A) Alligator, American (Alligator mississippiensis) 

E Bat, Indiana (Myotis sodalis) 

T(S/A) Bear, American black (County range of LA b.bear) (Ursus americanus) 

T Bear, Louisiana black (Ursus americanus luteolus) 

E Clubshell, black (Pleurobema curtum) 

E Clubshell, ovate (Pleurobema perovatum) 

E Clubshell, southern (Pleurobema decisum) 

E Combshell, Cumberlandian Entire Range; Except where listed as EXPN (Epioblasma brevidens) 

E Combshell, southern (Epioblasma penita) 

E Crane, Mississippi sandhill (Grus canadensis pulla) 

T Darter, bayou (Etheostoma rubrum) 

T Eagle, bald (lower 48 States) (Haliaeetus leucocephalus) 

E Frog, Mississippi gopher Wherever found west of Mobile and Tombigbee Rivers in AL, MS, and LA. (Rana capito sevosa) 

T Hellsplitter, Alabama (=inflated) (Potamilus inflatus) 

T Moccasinshell, Alabama (Medionidus acutissimus) 

T Mucket, orangenacre (Lampsilis perovalis) 
C-12 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Panther, Florida (Puma (=Felis) concolor coryi) 

E Pelican, brown (except U.S. Atlantic coast, FL, AL) (Pelecanus occidentalis) 

E Pigtoe, flat (Pleurobema marshalli) 

E Pigtoe, heavy (Pleurobema taitianum) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Pocketbook, fat (Potamilus capax) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Stirrupshell (Quadrula stapes) 

E Sturgeon, Alabama (Scaphirhynchus suttkusi) 

T Sturgeon, gulf (Acipenser oxyrinchus desotoi) 

E Sturgeon, pallid (Scaphirhynchus albus) 

E Tern, least (interior pop.) (Sterna antillarum) 

T Turtle, ringed map (Graptemys oculifera) 

T Turtle, yellow-blotched map (Graptemys flavimaculata) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

E Woodpecker, red-cockaded (Picoides borealis) 

Plants -- 4

Status Listing 

E Chaffseed, American (Schwalbea americana) 

E Pondberry (Lindera melissifolia) 

T Potato-bean, Price's (Apios priceana) 

E Quillwort, Louisiana (Isoetes louisianensis) 

New Hampshire -- 14 listings

Animals –11

Status Listing 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfly, Karner blue (Lycaeides melissa samuelis) 

E Curlew, Eskimo (Numenius borealis) 

T Lynx, Canada (Lynx canadensis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Tiger beetle, Puritan (Cicindela puritana) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, finback (Balaenoptera physalus) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 3

Status Listing 

E Bulrush, Northeastern (Scirpus ancistrochaetus) 

E Milk-vetch, Jesup's (Astragalus robbinsii var. jesupi) 

T Pogonia, small whorled (Isotria medeoloides) 

New Jersey -- 26 listings

Animals -- 19

Status Listing 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfly, Mitchell’s satyr (Neonympha mitchellii mitchellii) 

E Curlew, Eskimo (Numenius borealis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

E Tern, roseate (northeast U.S. nesting pop.) (Sterna dougallii dougallii) 

T Tiger beetle, northeastern beach (Cicindela dorsalis dorsalis) 

T Turtle, bog (=Muhlenberg) (northern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 
C-13 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 7

Status Listing 

T Amaranth, seabeach (Amaranthus pumilus) 

T Beaked-rush, Knieskern's (Rhynchospora knieskernii) 

E Chaffseed, American (Schwalbea americana)

T Joint-vetch, sensitive (Aeschynomene virginica) 

T Orchid, eastern prairie fringed (Platanthera leucophaea) 

T Pink, swamp (Helonias bullata) 

T Pogonia, small whorled (Isotria medeoloides) 

New Mexico -- 45 listings

Animals -- 32

Status Listing 

E Amphipod, Noel’s (Gammarus desperatus) 

E Bat, lesser long-nosed (Leptonycteris curasoae yerbabuenae) 

E Bat, Mexican long-nosed (Leptonycteris nivalis) 

T Bear, grizzly lower 48 States, except where listed as EXPN or delisted (Ursus arctos horribils) 

T Chub, Chihuahua (Gila nigrescens) 

E Chub, Gila (Gila intermedia) 

E Curlew, Eskimo (Numenius borealis) 

E Falcon, northern aplomado (Falco femoralis septentrionalis) 

E Flycatcher, southwestern willow (Empidonax traillii extimus) 

T Frog, Chiricahua leopard (Rana chiricahuensis) 

E Gambusi, Peco (Gambusia nobilis) 

E Isopod, Socorro (Thermosphaeroma thermophilus) 

E Jaguar (Panthera onca) 

T Minnow, loach (Tiaroga cobitis) 

E Minnow, Rio Grande silvery (Hybognathus amarus) 

T Owl, Mexican spotted (Strix occidentalis lucida) 

E Pikeminnow (=squawfish), Colorado except Salt and Verde R. drainages, AZ (ptychocheilus lucius) 

T Rattlesnake, New Mexico ridge-nosed (Crotalus willardi obscurus) 

T Shiner, Arkansas River Arkansas R. Basin (Notropis girardi) 

T Shiner, beautiful (Cyprinella Formosa) 

T Shiner, Pecos bluntnose (Notropis simus pecosensis) 

E Snail, Pecos assiminea (Assininea pecos) 

T Spikedace (Meda fulgida) 

E Springsnail, Alamosa (Rtyonia alamosae) 

E Springtail, Koster’s (Juturnia kosteri) 

E Springtail, Roswell (Pyrgulopsis roswellensis) 

E Springtail, Socorro (Pyrgulopsis neomexicana) 

E Sucker, razorback entire (Xyraauchen texanus) 

E Tern, least interior pop. (Sterna antillarum) 

E Topminnow, Gila (incl. Yqui) U.S.A only (Poeciliopsis occidentalis) 

T Trout, Gila (Oncorhynchus gilae) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 13

Status Listing 

E Cactus, Knowlton (Pediocactus knowltonii) 

E Cactus, Kuenzler hedgehog (Echinocereus fendleri var. kuenzleri) 

T Cactus, Lee pincushion (Coryphantha sneedii var. leei) 

T Cactus Mesa Verde (Sclerocactus mesae-verdae) 

E Cactus Sneed pincushion (coryphantha sneedii var. sneedii) 

T Fleabane, Zuni (Erigeron rhizomatus) 

E Ipomopsis, Holy Ghost (Ipomopsis sanct-spiritus) 

E Milk-vetch, Mancos (Astragalus humillimus) 

E Pennyroyal, Todsen’s (Hedeoma todsenii) 

E Poppy, Sacramento prickly (=puzzle, =paradox) (Helianthus paradoxus) 

T Thistle, Sacramento Mountains (Cirsium vinaceum) 

T Wild-buckweat, gypsum (Eriogonum gypsophilum) 

New York -- 33listings

Animals – 23 

Status Listing 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfly, Karner blue (Lycaeides melissa samuelis) 

E Curlew, Eskimo (Numenius borealis) 
C-14 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

T Lynx, Canada (Lynx canadensis) 

E Plover, piping (Great Lakes watershed) (Charadrius melodus) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

T Snail, Chittenango ovate amber (Succinea chittenangoensis) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

E Tern, roseate (northeast U.S. nesting pop.) (Sterna dougallii dougallii) 

T Tiger beetle, northeastern beach (Cicindela dorsalis dorsalis) 

T Turtle, bog (=Muhlenberg) (northern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 10

Status Listing 

T Amaranth, seabeach (Amaranthus pumilus) 

E Bulrush, Northeastern (Scirpus ancistrochaetus) 

E Caffseed, American (Schwalbea Americana) 

T Fern, American hart's-tongue (Asplenium scolopendrium var. americanum) 

E Gerardia, sandplain (Agalinis acuta) 

T Monkshood, northern wild (Aconitum noveboracense) 

T Orchid, eastern prairie fringed (Plarantha leucophaea) 

T Pink, swamp (Helonias bullata) 

T Pogonia, small whorled (Isotrai medeoloides) 

T Roseroot, Leedy's (Sedum integrifolium ssp. leedyi) 

North Carolina -- 67 listings

Animals -- 40

Status Listing 

T(S/A) Alligator, American (Alligator mississippiensis) 

E Bat, Indiana (Myotis sodalis) 

E Bat, Virginia big-eared (Corynorhinus (=Plecotus) townsendii virginianus) 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfly, Saint Francis' satyr (Neonympha mitchellii francisci) 

E Cahow (Pterodroma cahow) 

T Chub, spotfin Entire (Cyprinella monacha) 

E Elktoe, Appalachian (Alasmidonta raveneliana) 

E Heelsplitter, Carolina (Lasmigona decorata) 

E Mussel, oyster Entire Range; Except where listed as Experimental Populations (Epioblasma capsaeformis) 

E Pearlymussel, littlewing (Pegias fabula) 

E Pelican, brown except U.S. Atlantic coast, FL, AL (Pelecanus occidentalis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Riffleshell, tan (Epioblasma florentina walkeri (=E. walkeri)) 

E Sawfish, smalltooth (Pristis pectinata) 

T Sea turtle, green (except where endangered) ( Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Shiner, Cape Fear (Notropis mekistocholas) 

T Silverside, Waccamaw (Menidia extensa) 

T Snail, noonday (Mesodon clarki nantahala) 

E Spider, spruce-fir moss (Microhexura montivaga) 

E Spinymussel, Tar River (Elliptio steinstansana) 

E Squirrel, Carolina northern flying (Glaucomys sabrinus coloratus) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

E Tern, roseate (northeast U.S. nesting pop.) (Sterna dougallii dougallii) 

T(S/A) Turtle, bog (=Muhlenberg) (southern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 
C-15 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Whale, sperm (Physeter catodon (=macrocephalus)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

E Wolf, red (except where XN) (Canis rufus) 

XN Wolf, red [XN] (Canis rufus) 

E Woodpecker, red-cockaded (Picoides borealis) 

Plants -- 27

Status Listing 

T Joint-vetch, sensitive (Aeschynomene virginica) 

T Amaranth, seabeach (Amaranthus pumilus) 

E Bittercress, small-anthered (Cardamine micranthera) 

E Sedge, golden (Carex lutea) 

E Coneflower, smooth (Echinacea laevigata) 

E Avens, spreading (Geum radiatum) 

E Lichen, rock gnome (Gymnoderma lineare) 

E Bluet, Roan Mountain (Hedyotis purpurea var. montana) 

E Sunflower, Schweinitz's (Helianthus schweinitzii) 

T Pink, swamp (Helonias bullata) 

T Heartleaf, dwarf-flowered (Hexastylis naniflora) 

T Heather, mountain golden (Hudsonia montana) 

T Pogonia, small whorled (Isotria medeoloides) 

T Blazingstar, Heller's (Liatris helleri) 

E Pondberry (Lindera melissifolia) 

E Loosestrife, rough-leaved (Lysimachia asperulaefolia) 

E Dropwort, Canby's (Oxypolis canbyi) 

E Harperella (Ptilimnium nodosum) 

E Sumac, Michaux's (Rhus michauxii) 

E Arrowhead, bunched (Sagittaria fasciculata) 

E Pitcher-plant, green (Sarracenia oreophila) 

E Pitcher-plant, mountain sweet (Sarracenia rubra ssp. jonesii) 

E Chaffseed, American (Schwalbea americana) 

E Irisette, white (Sisyrinchium dichotomum) 

T Goldenrod, Blue Ridge (Solidago spithamaea) 

T Spiraea, Virginia (Spiraea virginiana) 

E Meadowrue, Cooley's (Thalictrum cooleyi) 

Ohio -- 30 listings

Animals – 25

Status Listing 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfly, Karner blue (Lycaeides melissa samuelis) 

E Catspaw (=purple cat's paw pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma 

obliquata obliquata) 

E Catspaw, white (pearlymussel) (Epioblasma obliquata perobliqua) 

E Clubshell Entire Range; Except where listed as Experimental Populations (Pleurobema clava) 

E Curlew, Eskimo (Numenius borealis) 

E Dragonfly, Hine's emerald (Somatochlora hineana) 

E Fanshell (Cyprogenia stegaria) 

E Madtom, Scioto (Noturus trautmani) 

E Mapleleaf, winged Entire; except where listed as EXPN (Quadrula fragosa) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 

E Mussel, scaleshell (Leptodea leptodon) 

E Pearlymussel, cracking Enire Ranges; except where listed as EXPN (Hemistena lata) 

E Pimpleback, orangefoot (pearlymussel) (Plethobasus cooperianus) 

E Plover, piping (Great Lakes watershed) (Charadrius melodus) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Pocketbook, fat (Potamilus capax) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Riffleshell, northern (Epioblasma torulosa rangiana) 

E Ring pink (mussel) (Obovaria retusa) 

T Snake, copperbelly water (MI, OH, IN N of 400 N. Lat.) (Nerodia erythrogaster neglecta) 

T Snake, Lake Erie water (subspecies range clarified) (Nerodia sipedon insularum) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

E Wolf, gray Western Great Lakes DPS (Canis lupus) 

Plants -- 5

Status Listing 

T Monkshood, northern wild (Aconitum noveboracense) 

T Daisy, lakeside (Hymenoxys herbacea) 

T Orchid, eastern prairie fringed (Platanthera leucophaea) 
C-16 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

T Spiraea, Virginia (Spiraea virginiana) 

E Clover, running buffalo (Trifolium stoloniferum) 

Pennsylvania -- 24 listings 

Animals – 18

Status Listing 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Butterfly, Karner blue (Lycaeides melissa samuelis) 

E Clubshell Entire Range; Except where listed as Experimental Populations (Pleurobema clava) 

E Curlew, Eskimo (Numenius borealis) 

E Fanshell (Cyprogenia stegaria) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 

E Pigtoe, rough (Pleurobema plenum) 

E Pimpleback, orangefoot (pearlymussel) (Plethobasus cooperianus) 

E Plover, piping (Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Riffleshell, northern (Epioblasma torulosa rangiana) 

E Ring pink (mussel) (Obovaria retusa) 

E Squirrel, Delmarva Peninsula fox Entire, except Sussex Co., DE (Sciurus niger cinereus) 

T Tiger beetle, northeastern beach (Cicindela dorsalis dorsalis) 

T Turtle, bog (=Muhlenberg) (northern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 6

Status Listing 

E Coneflower, smooth (Echinacae laevigata) 

T Joint-vetch, sensitive (Aeschynomene virginica) 

T Orchid, eastern prairie fringed (Platanthera leucophaea) 

T Pogonia, small whorled (Isotria medeoloides) 

E Bulrush, Northeastern (Scirpus ancistrochaetus) 

T Spiraea, Virginia (Spiraea virginiana) 

Rhode Island -- 18 listings

Animals – 15

Status Listing 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numenius borealis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

E Tern, roseate (northeast U.S. nesting pop.) (Sterna dougallii dougallii) 

T Tiger beetle, northeastern beach (Cicindela dorsalis dorsalis) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 3

Status Listing 

T Amaranth, seabeach (Amaranthus pumilus) 

E Gerardia, sandplain (Agalinis acuta) 

T Pogonia, small whorled (Isotria medeoloides) 

South Carolina -- 45 listings

Animals -- 26

Status Listing 

T(S/A) Alligator, American (Alligator mississippiensis) 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numenius borealis) 

E Heelsplitter, Carolina (Lasmigona decorata) 

E Panther, Florida (Puma (=Felis) concolr coryi) 

E Pelican, brown except U.S. Atlantic coast, FL, AL (Pelecanus occidentalis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 
C-17 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

T Salamander, flatwoods frosted (Ambystoma cingulatum) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

T Snake, eastern indigo (Drymarchon corais couperi) 

E Stork, wood (AL, FL, GA, SC) (Mycteria americana) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

T Tern, roseate (Western Hemisphere except NE U.S.) (Sterna dougallii dougallii) 

T(S/A) Turtle, bog (=Muhlenberg) (southern) (Clemmys muhlenbergii) 

E Warbler (=wood), Bachman’s (Vermivora bachmanii) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

E Wolf, red (except where XN) (Canis rufus) 

E Woodpecker, red-cockaded (Picoides borealis) 

Plants -- 19

Status Listing 

T Amaranth, seabeach (Amaranthus pumilus) 

T Amphianthus, little (Amphianthus pusillus) 

E Coneflower, smooth (Echinacea laevigata) 

E Sunflower, Schweinitz's (Helianthus schweinitzii) 

T Pink, swamp (Helonias bullata) 

T Heartleaf, dwarf-flowered (Hexastylis naniflora) 

E Quillwort, black spored (Isoetes melanospora) 

T Pogonia, small whorled (Isotria medeoloides) 

E Pondberry (Lindera melissifolia) 

E Loosestrife, rough-leaved (Lysimachia asperulaefolia) 

E Dropwort, Canby's (Oxypolis canbyi) 

E Harperella (Ptilimnium nodosum) 

E Sumac, Michaux's (Rhus michauxii) 

T Gooseberry, Miccosukee (Ribes echinellum) 

E Arrowhead, bunched (Sagittaria fasciculata) 

E Pitcher-plant, mountain sweet (Sarracenia rubra ssp. jonesii) 

E Chaffseed, American (Schwalbea americana) 

E Trillium, persistent (Trillium persistens) 

E Trillium, relict (Trillium reliquum) 

Tennessee -- 95 listings

Animals – 75 

Status Listing 

E Acornshell, southern (Epioblasma othcaloogensis) 

E Bat, gray (Myotis grisescens) 

E Bat, Indiana (Myotis sodalis) 

E Bean, Cumberland (pearlymussel) Entire Range; Except where listed as Experimental Populations (Villosa trabalis) 

XN Bean, Cumberland (pearlymussel) U.S.A (TN – specified portions of the French Broad and Holston Rivers) 

E Bean, purple (Villosa perpurpurea) 

E Beetle, American burying (Nicrophorus americanus) 

E Blossom, green (pearlymussel) (Epioblasma torulosa gubernaculum) 

E Blossom, turgid (pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma turgidula) 

E Blossom, yellow (pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma florentina 

florentina) 

E Catspaw (=purple cat's paw pearlymussel) Entire Range; Except where listed as Experimental Populations (Epioblasma 

obliquata obliquata) 

T Chub, slender (Erimystax cahni) 

T Chub, spotfin Entire (Cyprinella monacha) 

E Clubshell Enitre Range; Except where listed as EXPN (Pleurobema clava) 

E Clubshell, ovate (Pleurobema perovatum) 

E Clubshell, southern (Pleurobema decisum) 

E Combshell, Cumberlandian Entire Range; Except where listed as Experimental Populations (Epioblasma brevidens) 

XN Combshell, Cumberlandian U.S.A. (TN – specified portions of the French Broad and Holston Rivers) 

E Combshell, upland (Epioblasma metastriata) 

E Crayfish, Nashville (Orconectes shoupi) 

E Curlew, Eskimo (Numenius borealis) 

T Dace, blackside (Phoxinus cumberlandensis) 

E Darter, amber (Percina antesella) 

E Darter, bluemask (=jewel) (Etheostoma /) 
C-18 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Darter, boulder (Etheostoma wapiti) 

E Darter, duskytail Entire (Etheostoma percnurum) 

T Darter, goldline (Percina aurolineata) 

T Darter, slackwater (Etheostoma boschungi) 

T Darter, snail (Percina tanasi) 

E Elktoe, Appalachian (Alasmidonta raveneliana) 

E Elktoe, Cumberland (Alasmidonta atropurpurea) 

E Fanshell (Cyprogenia stegaria) 

E Kidneyshell, triangular (Ptychobranchus greeni) 

E Lampmussel, Alabama Entire Range; Except where listed as Experimental Populations (Lampsilis virescens) 

E Lilliput, pale (pearlymussel) (Toxolasma cylindrellus) 

E Logperch, Conasauga Percina jenkinsi) 

E Madtom, pygmy (Noturus stanauli) 

E Madtom, smoky Entire (Noturus baileyi) 

T Madtom, yellowfin (except where XN) (Noturus flavipinnis) 

XN Madtom, yellowfin U.S.A. (TN – specified portions of the French Broad and Holston Rivers); Tellico River, TN (Noturus 

flavipinnis) 

E Marstonia, royal (snail) (Pyrgulopsis ogmorhaphe) 

E Moccasinshell, Coosa (Medionidus parvulus) 

E Monkeyface, Appalachian (pearlymussel) (Quadrula sparsa) 

E Monkeyface, Cumberland (pearlymussel) Entire Range; Except where listed as Experimental Populations (Quadrula 

intermedia) 

XN Monkeyface, Cumberland (pearlymussel) U.S.A. (TN – specified portions of the Fench Broad and Holston Rivers) 

(Quadrula intermedia) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 

E Mussel, oyster Entire Range; Except where listed as Experimental Populations (Epioblasma capsaeformis) 

E Panther, Florida (Puma (=Felis) concolr coryi) 

E Pearlymussel, birdwing Entire Range; Except where listed as Experimental Populations (Conradilla caelata) 

E Pearlymussel, cracking Entire Range; Except where listed as Experimental Populations (Hemistena lata) 

E Pearlymussel, dromedary Entire Range; Except where listed as Experimental Populations (Dromus dromas) 

E Pearlymussel, littlewing (Pegias fabula) 

E Pigtoe, Cumberland (Pleurobema gibberum) 

E Pigtoe, finerayed Entire Range; Except where listed as Experimental Populations (Fusconaia cuneolus) 

XN Pigtoe, finerayed U.S.A. (TN – specified portions of the Fench Broad and Holston Rivers) (Fusconaia cuneolus) 

E Pigtoe, rough (Pleurobema plenum) 

E Pigtoe, shiny Entire Range; Except where listed as Experimental Populations (Fusconaia cor) 

XN Pigtoe, shiny U.S.A. (TN – specified portions of the Fench Broad and Holston Rivers) (Fusconaia cor) 

E Pigtoe, southern ( Pleurobema georgianum) 

E Pimpleback, orangefoot (pearlymussel) (Plethobasus cooperianus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Rabbitsfoot, rough (Quadrula cylindrica strigillata) 

E Riffleshell, tan (Epioblasma florentina walkeri (=E. walkeri)) 

E Ring pink (mussel) (Obovaria retusa) 

E Riversnail, Anthony's Entire Range; Except where listed as Experimental Populations ( Athearnia anthonyi) 

XN Riversnail, Anthony's AL U.S.A. (TN – specified portions of the Fench Broad and Holston Rivers) ( Athearnia anthonyi) 

T Shiner, blue (Cyprinella caerulea) 

T Snail, painted snake coiled forest (Anguispira picta) 

E Spider, spruce-fir moss (Microhexura montivaga) 

E Squirrel, Carolina northern flying (Glaucomys sabrinus coloratus) 

E Sturgeon, pallid (Scaphirhynchus albus) 

E Tern, least (interior pop.) (Sterna antillarum) 

E Wartyback, white (pearlymussel) (Plethobasus cicatricosus) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

XN Wolf, red [XN] (Canis rufus) 

Plants -- 20

Status Listing 

T Potato-bean, Price's (Apios priceana) 

E Rock-cress, Braun's (Arabis perstellata) 

E Sandwort, Cumberland (Arenaria cumberlandensis) 

T Fern, American hart's-tongue (Asplenium scolopendrium var. americanum) 

E Ground-plum, Guthrie's (=Pyne's) (Astragalus bibullatus) 

T Rosemary, Cumberland (Conradina verticillata) 

E Prairie-clover, leafy (Dalea foliosa) 

E Coneflower, Tennessee purple (Echinacea tennesseensis) 

E Avens, spreading (Geum radiatum) 

E Lichen, rock gnome (Gymnoderma lineare) 

E Bluet, Roan Mountain (Hedyotis purpurea var. montana) 

T Pogonia, small whorled (Isotria medeoloides) 

E Bladderpod, Spring Creek (Lesquerella perforata) 

E Aster, Ruth's golden (Pityopsis ruthii) 
C-19 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Pitcher-plant, green (Sarracenia oreophila) 

T Skullcap, large-flowered (Scutellaria montana) 

T Goldenrod, Blue Ridge (Solidago spithamaea) 

T Spiraea, Virginia (Spiraea virginiana) 

E Grass, Tennessee yellow-eyed (Xyris tennesseensis) 

E Chaffseed, American (Schwalbea americana) 

Texas -- 96 listings

Animals – 68

Status Listing 

T(S/A) Alligator, American (Alligator mississippiensis) 

E Amphipod, Peck's cave (Stygobromus (=Stygonectes) pecki) 

E Bat, Mexican long-nosed (Leptonycteris nivalis) 

T(S/A) Bear, American black (County range of LA b.bear) (Ursus americanus) 

T Bear, Louisiana black (Ursus americanus luteolus) 

E Beetle, American burying (Nicrophorus americanus) 

E Beetle, Coffin Cave mold (Batrisodes texanus) 

E Beetle, Comal Springs dryopid (Stygoparnus comalensis) 

E Beetle, Comal Springs riffle (Heterelmis comalensis) 

E Beetle, Helotes mold (Batrisodes venyivi) 

E Beetle, Kretschmarr Cave mold (Texamaurops reddelli) 

E Beetle, Tooth Cave ground (Rhadine persephone) 

E Crane, whooping (except where XN) (Grus americana) 

E Curlew, Eskimo (Numenius borealis) 

E Darter, fountain (Etheostoma fonticola) 

E Falcon, northern aplomado (Falco femoralis septentrionalis) 

E Flycatcher, southwestern willow (Empidonax traillii extimus) 

E Gambusia, Big Bend (Gambusia gaigei) 

E Gambusia, Clear Creek (Gambusia heterochir) 

E Gambusia, Pecos (Gambusia nobilis) 

E Gambusia, San Marcos (Gambusia georgei) 

E Ground beetle, [unnamed] (Rhadine exilis) 

E Ground beetle, [unnamed] (Rhadine infernalis) 

E Harvestman, Bee Creek Cave (Texella reddelli) 

E Harvestman, Bone Cave (Texella reyesi) 

E Harvestman, Cokendolpher Cave ( Texella cokendolpheri) 

E Jaguar (Panthera onca) 

E Jaguarundi, Gulf Coast (Herpailurus (=Felis) yagouaroundi cacomitli) 

E Manatee, West Indian (Trichechus manatus) 

E Margay Mexico southward (Leoparus (=Felis) weidii) 

E Meshweaver, Braken Bat Cave (Cicurina venii) 

E Meshweaver, Government Canyon Bat Cave (Cicurina vespera) 

E Meshweaver, Madla's Cave (Cicurina madla) 

E Meshweaver, Robber Baron Cave (Cicurina baronia) 

T Minnow, Devils River (Dionda diaboli) 

E Minnow, Rio Grande silvery (Hybognathus amarus) 

E Ocelot (Leopardus (=Felis) pardalis) 

T Owl, Mexican spotted (Strix occidentalis lucida) 

E Pelican, brown (except U.S. Atlantic coast, FL, AL) (Pelecanus occidentalis) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Prairie-chicken, Attwater's greater (Tympanuchus cupido attwateri) 

E Pseudoscorpion, Tooth Cave (Tartarocreagris texana) 

E Pupfish, Comanche Springs (Cyprinodon elegans) 

E Pupfish, Leon Springs (Cyprinodon bovinus) 

E Salamander, Barton Springs (Eurycea sosorum) 

T Salamander, San Marcos (Eurycea nana) 

E Salamander, Texas blind (Typhlomolge rathbuni) 

E Sawfish, smalltooth (Pristis pectinata) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

T Shiner, Arkansas River (Arkansas R. Basin) (Notropis girardi) 

E Snail, Pecos assiminea (Assiminea pecos) 

T Snake, Concho water (Nerodia paucimaculata) 

E Spider, Government Canyon Bat Cave (Neoleptoneta microps) 

E Spider, Tooth Cave (Neoleptoneta myopica) 

E Tern, least (interior pop.) (Sterna antillarum) 

E Toad, Houston (Bufo houstonensis) 

E Vireo, black-capped (Vireo atricapilla) 
C-20 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Warbler (=wood), golden-cheeked (Dendroica chrysoparia) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

XN Wolf, gray Mexican gray wolf, EXPN population (Canis lupus) 

E Wolf, red (except where XN) (Canis rufus) 

E Woodpecker, red-cockaded (Picoides borealis) 

Plants -- 28

Status Listing 

E Sand-verbena, large-fruited (Abronia macrocarpa) 

E Ambrosia, south Texas (Ambrosia cheiranthifolia) 

E Cactus, Tobusch fishhook ( ncistrocactus tobuschii) 

E Cactus, star (Astrophytum asterias) 

E Ayenia, Texas (Ayenia limitaris) 

E Poppy-mallow, Texas (Callirhoe scabriuscula) 

E Cactus, Nellie cory (Coryphantha minima) 

T Cory cactus, bunched (Coryphantha ramillosa) 

E Cactus, Sneed pincushion (Coryphantha sneedii var. sneedii) 

E Cat's-eye, Terlingua Creek (Cryptantha crassipes) 

T Cactus, Chisos Mountain hedgehog (Echinocereus chisoensis var. chisoensis) 

E Cactus, black lace (Echinocereus reichenbachii var. albertii) 

E Pitaya, Davis' green (Echinocereus viridiflorus var. davisii) 

T Cactus, Lloyd's Mariposa (Echinomastus mariposensis) 

E Frankenia, Johnston's (Frankenia johnstonii) 

T Sunflower, Pecos (=puzzle, =paradox) (Helianthus paradoxus) 

E Rush-pea, slender (Hoffmannseggia tenella) 

E Dawn-flower, Texas prairie (Hymenoxys texana) 

E Bladderpod, white (Lesquerella pallida) 

E Bladderpod, Zapata (Lesquerella thamnophila) 

E Manioc, Walker's (Manihot walkerae) 

E Phlox, Texas trailing (Phlox nivalis ssp. texensis) 

E Pondweed, Little Aguja (=Creek) (Potamogeton clystocarpus) 

T Oak, Hinckley (Quercus hinckleyi) 

E Ladies'-tresses, Navasota (Spiranthes parksii) 

E Snowbells, Texas (Styrax texanus) 

E Dogweed, ashy (Thymophylla tephroleuca) 

E Wild-rice, Texas (Zizania texana) 

Vermont -- 11 listings

Animals – 8

Status Listing 

E Bat, Indiana (Myotis sodalis) 

E Beetle, American burying (Nicrophorus americanus) 

E Curlew, Eskimo (Numenius borealis) 

T Lynx, Canada (Lynx canadensis) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

T Tiger beetle, Puritan (Cicindela puritana) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants --3

Status Listing 

E Milk-vetch, Jesup's (Astragalus robbinsii var. jesupi) 

E Bulrush, Northeastern (Scirpus ancistrochaetus) 

T Pogonia, small whorled (Isotrai medeoloides) 

Virginia -- 67 listings

Animals -- 52

Status Listing 

E Bat, gray (Myotis grisescens) 

E Bat, Indiana (Myotis sodalis) 

E Bat, Virginia big-eared (Corynorhinus (=Plecotus) townsendii virginianus) 

E Bean, Cumberland (pearlymussel) Entire Range; Except where listed as Experimental Populations (Villosa trabalis) 

E Bean, purple (Villosa perpurpurea) 

E Beetle, American burying (Nicrophorus americanus) 

E Blossom, green (pearlymussel) (Epioblasma torulosa gubernaculum) 

T Chub, slender (Erimystax cahni) 

T Chub, spotfin Entire (Cyprinella monacha) 

E Combshell, Cumberlandian Entire Range; Except where listed as Experimental Populations (Epioblasma brevidens) 
C-21 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Curlew, Eskimo (Numenius borealis) 

E Darter, duskytail Entire (Etheostoma percnurum) 

E Fanshell (Cyprogenia stegaria) 

E Isopod, Lee County cave (Lirceus usdagalun) 

T Isopod, Madison Cave (Antrolana lira) 

E Logperch, Roanoke (Percina rex) 

XN Madtom, yellowfin Holston River, VA, TN (Noturus flavipinnis) 

T Madtom, yellowfin (except where XN) (Noturus flavipinnis) 

E Monkeyface, Appalachian (pearlymussel) (Quadrula sparsa) 

E Monkeyface, Cumberland (pearlymussel) Entire Range; Except where listed as Experimental Populations (Quadrula 

intermedia) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 

E Mussel, oyster Entire Range; Except where listed as Experimental Populations (Epioblasma capsaeformis) 

E Pearlymussel, birdwing Entire Range; Except where listed as Experimental Populations (Conradilla caelata) 

E Pearlymussel, cracking Entire Range; Except where listed as Experimental Populations (Hemistena lata) 

E Pearlymussel, dromedary Entire Range; Except where listed as Experimental Populations (Dromus dromas) 

E Pearlymussel, littlewing (Pegias fabula) 

E Pigtoe, finerayed Entire Range; Except where listed as Experimental Populations (Fusconaia cuneolus) 

E Pigtoe, rough (Pleurobema plenum) 

E Pigtoe, shiny Entire Range; Except where listed as Experimental Populations (Fusconaia cor) 

T Plover, piping (except Great Lakes watershed) (Charadrius melodus) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Rabbitsfoot, rough (Quadrula cylindrica strigillata) 

E Riffleshell, tan (Epioblasma florentina walkeri (=E. walkeri)) 

E Salamander, Shenandoah (Plethodon shenandoah) 

T Sea turtle, green (except where endangered) (Chelonia mydas) 

E Sea turtle, hawksbill (Eretmochelys imbricata) 

E Sea turtle, Kemp's ridley (Lepidochelys kempii) 

E Sea turtle, leatherback (Dermochelys coriacea) 

T Sea turtle, loggerhead (Caretta caretta) 

E Snail, Virginia fringed mountain (Polygyriscus virginianus) 

E Spinymussel, James (Pleurobema collina) 

E Squirrel, Delmarva Peninsula fox (except Sussex Co., DE) (Sciurus niger cinereus) 

E Sturgeon, shortnose (Acipenser brevirostrum) 

E Tern, roseate (northeast U.S. nesting pop.) (Sterna dougallii dougallii) 

T Tiger beetle, northeastern beach (Cicindela dorsalis dorsalis) 

T(S/A) Turtle, bog (=Muhlenberg) (southern) (Clemmys muhlenbergii) 

E Wedgemussel, dwarf (Alasmidonta heterodon) 

E Whale, finback (Balaenoptera physalus) 

E Whale, humpback (Megaptera novaeangliae) 

E Whale, right (Balaena glacialis (incl. australis)) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

E Woodpecker, red-cockaded (Picoides borealis) 

Plants -- 15

Status Listing 

T Joint-vetch, sensitive (Aeschynomene virginica) 

T Amaranth, seabeach (Amaranthus pumilus) 

E Rock-cress, shale barren (Arabis serotina) 

T Birch, Virginia round-leaf (Betula uber) 

E Bittercress, small-anthered (Cardamine micranthera) 

E Coneflower, smooth (Echinacea laevigata) 

T Sneezeweed, Virginia (Helenium virginicum) 

T Pink, swamp (Helonias bullata) 

E Mallow, Peter's Mountain (Iliamna corei) 

T Pogonia, small whorled (Isotria medeoloides) 

T Orchid, eastern prairie fringed (Platanthera leucophaea) 

E Sumac, Michaux's (Rhus michauxii) 

E Bulrush, Northeastern (Scirpus ancistrochaetus) 

T Spiraea, Virginia (Spiraea virginiana) 

E Chaffseed, American (Schwalbea Americana) 

West Virginia -- 22 listings

Animals – 16

Status Listing 

E Bat, gray (Myotis grisescens) 

E Bat, Indiana (Myotis sodalis) 

E Bat, Virginia big-eared (Corynorhinus (=Plecotus) townsendii virginianus) 

E Beetle, American burying (Nicrophorus americanus) 

E Clubshell Entire Range; Except where listed as Experimental Populations (Pleurobema clava) 

E Curlew, Eskimo (Numenius borealis) 
C-22 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

E Fanshell (Cyprogenia stegaria) 

E Isopod, Lee County cave (Lirceus usdagalun) 

E Mucket, pink (pearlymussel) (Lampsilis abrupta) 

E Puma (=cougar), eastern (Puma (=Felis) concolor couguar) 

E Riffleshell, northern (Epioblasma torulosa rangiana) 

E Ring pink (mussel) (Obovaria retusa) 

T Salamander, Cheat Mountain (Plethodon nettingi) 

T Snail, flat-spired three-toothed (Triodopsis platysayoides) 

E Spinymussel, James (Pleurobema collina) 

E Wolf, gray Lower 48 States, except where delisted and where EXPN. Mexico. (Canis lupus) 

Plants -- 6

Status Listing 

E Rock-cress, shale barren (Arabis serotina) 

T Pogonia, small whorled (Isotria medeoloides) 

E Harperella (Ptilimnium nodosum) 

E Bulrush, Northeastern (Scirpus ancistrochaetus) 

T Spiraea, Virginia (Spiraea virginiana) 

E Clover, running buffalo (Trifolium stoloniferum) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

APPENDIX D 

SUMMARY OF SPECIES LISTED AS THREATENED, ENDANGERED, OR SPECIAL STATUS 

UNDER STATE LAWS IN STATES PROPOSED FOR APHIS-WS CONTINUED OR EXPANDED 

INVOLVEMENT IN ORAL RABIES VACCINATION PROGRAMS

Number of State Listed Species by Category 

(Species for which concerns about ORV programs might be raised are identified and shown in bold) 

Information obtained from http://www.fws.gov/office/statelinks.html on March 2009. 

State Mammals Birds Reptiles Amphibians Fish Invertebrates Plants 

Alabama 9NG 

long-tailed weasel 

19NG 14NG 8NG 30NG 32E, 10T 11E, 

7T 

Arizona 28WSC 

Mexican gray 

wolf, 

Intermountain 

gray wolf, Blacktailed prairie dog, 

Ocelot, 

Southwestern 

river otter, Blackfooted ferret, 

Jaguar, Mt. 

Graham red 

squirrel, Grizzly 

bear

55WSC 14WSC 11WSC 27WSC 0WSC 143SR, 

43HS, 

3HR 

Connecticut 2E, 9SC 

gray wolf, eastern 

puma 

21E, 

9T, 

20SC 

4E, 3T, 

4SC 

1E, 3T, 3SC 3E, 2T, 

2SC 

17E, 24T, 

128SC 

119E, 

38T, 

186SC 

Delaware 1E 

Delmarva fox 

squirrel 

24E 6E 2E 1E 15E 

Florida 20E, 4T, 6SSC 

Florida black 

bear, Everglades 

mink, Florida 

panther, 

Sherman’s fox 

squirrel, Lower 

Keys marsh 

rabbit, Big 

Cypress fox 

squirrel 

8E, 9T, 

18SSC 

6E, 11T, 

7SSC 

5 SSC 3E, 2T, 

10 SSC 

4E, 4SSC 335E, 

67T 

Georgia 7E, 1T, 1R 

eastern puma, 

Florida panther, 

round-tailed 

muskrat 

5E, 4T, 

11R 

5E, 6T, 

3R, 2U 

5T, 4R 32E, 

18T, 

17R, 

2U 

28E, 19T, 4R 56E, 

462T, 

32R, 

4U 

Indiana 7E, 15SC 

American badger, 

bobcat, northern 

river otter, least 

weasel 

27E, 

20SC 

15E, 

4SC 

5E, 6SC 10E, 

15SC 

15E, 11SC 210E, 

90T, 

107R 
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Kentucky 5E, 3T, 3SC 

American black 

bear, eastern 

spotted skunk, 

least weasel 

13E, 

12T, 

12SC 

2E, 8T, 

7SC 

2E, 1T, 8SC 28E, 

11T, 

09SC 

27E, 5T, 2SC 156E, 

117T, 

58SC 

Louisiana 6E, 1 T 

Louisiana black 

bear, Florida 

panther, red wolf 

9E, 2T 3E, 4T, 0 1E, 1T, 2E, 1T 0 

Maine 1E 

New England 

cottontail 

10E, 

11T 

3E, 1T 0 1E, 1T 7E,10T 88E, 

98T, 

105SC 

Maryland 12E, 6I 

North American 

porcupine, 

bobcat, least 

weasel, Delmarva 

fox squirrel, New 

England 

cottontail 

16E, 

4T, 7I 

7E, 3T, 

1I 

6E, 3T, 1I 7E, 6T, 

3I 

39E, 6T, 9I 272E, 

74T 

Massachusetts 7E, 4SC 12E, 

6T, 

10SC 

8E, 5T, 

2SC 

2T, 2SC 4E, 2T, 

4SC 

28E, 26T, 

53SC 

154E, 

54T, 

42SC 

Michigan 4E, 2T, 4SC 

eastern puma, 

Canada lynx, 

gray wolf 

8E, 

13T, 

21SC 

2E, 2T, 

6SC 

1E, 1T, 2SC 8E, 7T, 

11SC 

19E, 15T, 

110SC 

31E, 

210T, 

110SC 

Mississippi 6E 

American black 

bear, Louisiana 

black bear, 

Florida panther 

11E 14E 5E 15E 24E 4E 

New 

Hampshire 

4E, 1T 

Canada lynx, 

American 

marten, New 

England 

cottontail, Gray 

wolf 

8E, 7T 3E, 2T 1E 1T 9E, 2T 282E, 

98T, 

New Jersey 9E 

bobcat 

17E, 

16T 

8E, 3T 3E, 3T 1E 9E, 8T 339E 

New Mexico 7E, T9, 44S, R2 

Jaguar, Ocelot, 

American 

marten, Whitesided jack rabbit, 

Mexican gray 

wolf, Black-tailed 

prairie dog, 

White-nosed 

coati, Red fox, 

Swift fox, Yellowbellied marmot, 

12E, 

21T, 9S 

7E, 8T, 

6S 

4E, 2T, 2S 13E, 

11T, 8S 

12E, 15T, 4S 46E 
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Mink, Pecos 

River muskrat, 

White-tailed 

jackrabbit, 

Ringtail, Hognosed skunk, 

Hooded skunk, 

Western spotted 

skunk, Red 

squirrel

New York 10E, 1T, 3SC 

Canada lynx, 

New England 

cottontail, gray 

wolf, eastern 

puma 

10E, 

10T, 

19SC 

7E, 5T, 

6SC 

2E, 7SC 8E, 

11T, 

5SC 

16E, 8T, 18SC 359E, 

152T, 

83SC 

North 

Carolina 

6E, 2T, 13SC 

eastern puma, 

Carolina 

northern flying 

squirrel 

9E, 4T, 

23SC 

5E, 4T, 

11SC 

1E, 4T, 12SC 11E, 

16T, 

28SC 

26E, 21T, 

24SC 

78E, 

39T, 

19SC 

Ohio 5E, 8SC 

bobcat, snowshoe 

hare, American 

black bear, 

ermine, American 

badger 

16E, 

11T, 

13SC, 

31SI 

5E, 1T, 

2SC 

5E, 1T, 1 SC 23E, 

13T, 

11SC 

71E, 28T, 

52SC, 11SI 

253E, 

162T 

Pennsylvania 3E, 3T 

Delmarva fox 

squirrel 

15E, 

3T 

3E, 1T 4E, 1T 32E, 

15T 

2SC 276E, 

78T 

Rhode Island 1T, 4C 

Bobcat, New 

England 

cottontail 

8E, 5T, 

33C 

1E, 5C 1E, 2C 1T 2E, 9T, 44C 50E, 

56T, 

132C 

South 

Carolina 

3E, 1T, 24SC 

American black 

bear, eastern fox 

squirrel, New 

England 

cottontail, eastern 

spotted skunk, 

swamp rabbit 

6E, 2T, 

11SC 

1E, 4T, 

12SC 

3E, 3T, 13SC 1E, 1T, 

8SC 

1E, 16SC 14E, 

6T, 

400SC 

Tennessee 3E, 14SM 

Carolina 

northern flying 

squirrel 

4E, 4T, 

21SM 

3T, 4SM 1T, 10SM 20E, 

17T, 

40SM 

51E, 4T, 1SM 196E, 

133T, 

186S 

Texas 12E, 20T 

ocelot, 

jaguarondi, 

jaguar, gray wolf, 

red wolf, 

Louisiana black 

bear, black bear, 

white-nosed coati, 

black-footed 

ferret, margay 

13E, 

21T 

3E, 21T 3E, 10T 8E, 

22T 

1E 23E, 

5T 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Vermont 4E, 1T, 

Canada lynx, 

eastern cougar, 

American 

marten, New 

England 

cottontail 

8E, 1T 3E, 3T 1E 4E, 2T 8E, 6T 62E, 

91T 

Virginia 19E, 1T, 3SC 

Delmarva fox 

squirrel, eastern 

puma, gray wolf, 

snowshoe hare, 

Virginia northern 

flying squirrel, 

marsh rabbit, 

northern river 

otter 

6E, 8T, 

31SC 

6E, 4T, 

1SC 

2E, 2T, 9SC 7E, 

14T, 

17SC 

43E, 15T, 

18SC 

56E, 

28T, 

11SC 

West Virginia 6S1, 11S2, 5S3 

West Virginia 

northern flying 

squirrel, eastern 

spotted skunk, 

Appalachian 

cottontail 

28S1, 

15S2, 

15S3 

3S1, 

9S2, 6S3 

6S1, 7S2, 5S3 26S1, 

26S2, 

20S3 

173S1, 80S2, 

26S3 

267S1, 

136S2, 

27S3 

C=Candidate Species for Listing as Threatened or Endangered; NG=Nongame Species Regulation; 

ISP=Invertebrate Species Regulation; SSC or SC=Species of Concern or Special Concern; SI=“Special 

Interest” Species; PEx=Possibly Extirpated; E=State Endangered; T=State Threatened; SM=Species in 

Need of Management; I=In need of Conservation; R=Rare; U=Unusual; S1, S2, or S3=WV designations for 

levels of concern. 

State T&E Protections under State Law 

Alabama no state threatened or endangered status; certain listed “nongame” species given special 

protection against “take”; “take” not specifically defined 

Arizona “Endangered wildlife” means any crustacean, mollusk, fish, amphibian, reptile, bird, or 

mammal that is listed by the Department as a species of Wildlife of Special Concern in 

Arizona, or by the U.S. Fish and Wildlife Service as endangered or threatened, or which is a 

candidate for such status. 

Arizona Revised Statutes 17-314. Civil liability for illegally taking or wounding wildlife; 

recovery of damages:

A. The commission or any officer charged with enforcement of the laws relating to game and 

fish, if so directed by the commission, may bring a civil action in the name of the state 

against any person unlawfully taking, wounding or killing, or unlawfully in possession of, 

any of the following wildlife, or part thereof, and seek to recover the following minimum 

sums as damage: 

...6. For each trophy or endangered species animal - $8,000.00 

(from Arizona State Legislature 2007) 

Connecticut it is unlawful for (1) any person to willfully take any endangered or threatened species on or 

from public property, waters of the state, or property of another without the written 

permission of the owner on whose property the species occurs; (2) any person, including the 
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owner of the land on which an endangered or threatened species occurs, to willfully take an 

endangered or threatened species for the purpose of selling, offering for sale, transporting for 

commercial gain or exporting such specimen; (3) any state agency to destroy or adversely 

modify essential habitat designated pursuant to section 26-306, so as to reduce the viability 

of the habitat to support endangered or threatened species or so as to kill, injure, or 

appreciably reduce the likelihood of survival of the species. 

Delaware the Division may designate species of fish and wildlife that are seriously threatened with 

extinction as endangered species 

Florida unlawful to “capture” endangered or to “take” threatened species without permit. 

Georgia species are listed as endangered, threatened, rare or unusual and are given this status under 

the Georgia Endangered wildlife Act of 1973. 

Indiana vertebrates, mollusks, and crustaceans classified as endangered in Indiana are protected from 

taking pursuant to the Nongame and Endangered Species Act of 1973 and Fish and Wildlife 

Administrative Rules 

Kentucky state laws define “take” for state-listed endangered species similar to ESA; state threatened, 

species of concern, and historical biota have no special additional protection 

Louisiana the state should assist in the protection of species of wildlife which are determined to be 

"threatened" or "endangered" elsewhere pursuant to the Federal Endangered Species Act, as 

concurred by the Louisiana Wildlife and Fisheries Commission, by prohibiting the taking, 

possession, transportation, exportation from the state, processing, sale or offer for sale or 

shipment within this state of such endangered species, or by carefully regulating such 

activities with regard to such species 

Maine unlawful to “hunt, take or trap” any endangered or threatened species without a permit issued 

for specific action by the commissioner or the state of Maine 

Maryland state law defines “take” similar to ESA; endangered and threatened categories have 

protections against “take” 

Massachusetts “take” defined similar to ESA; threatened, endangered, and “special concern” categories 

have equal protections against “take” 

Michigan a person shall not take, possess, transport, import, export, process, sell, offer for sale, buy, 

or offer to buy, and a common or contract carrier shall not transport or receive for shipment, 

any species of fish, plants, or wildlife on the following lists: 

(a) The list of fish, plants, and wildlife indigenous to the state determined to be endangered 

or threatened within the state pursuant to section 36503 or subsection (3). 

(b) The United States list of endangered or threatened native fish and wildlife. 

(c) The United States list of endangered or threatened plants. 

(d) The United States list of endangered or threatened foreign fish and wildlife 

Mississippi All birds of prey (eagles, hawks, osprey, owls, kites and vultures) and other nongame birds 

are protected and may not be hunted, molested, bought or sold. English sparrows, starlings, 

blackbirds and crows may be taken according to regulations. The following endangered 

species are also protected: black bear, Florida panther, gray bat, Indiana bat, all sea turtles, 

gopher tortoise, sawback turtles (black-knobbed, ringed, yellow-blotched), black pine snake, 

eastern indigo snake, rainbow snake, and the southern hognose snake 

New Hampshire With respect to any endangered or threatened species, it is unlawful to: (a) Export any such 

species from this state; (b) Take any such species within this state; (c) Possess, process, sell 

or offer for sale, deliver, carry, transport or ship, by any means whatsoever, any such 

species; (d) Violate any rule adopted under this chapter pertaining to the conservation of 
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such species of wildlife listed pursuant to RSA 212-A:6, IV 

New Jersey unlawful to “take” any endangered species of fish or wildlife; “take” defined similar to ESA; 

no exemptions or permits to allow for incidental take 

New Mexico New Mexico Statutes. Title 19, Chapter 33. Endangered and Threatened Wildlife. 

The state legislature declares that: species and subspecies of wildlife indigenous to the state 

found to be endangered should be managed and, to the extent possible, enhanced in number 

within the carrying capacity of the habitat; the state should assist in the management of 

wildlife deemed to be endangered elsewhere by prohibiting the taking, possession, 

transportation, exportation, processing, sale or offering for sale or shipment within this state 

wildlife listed on the U.S. lists of endangered fish and wildlife, unless such actions will assist 

in preserving or propagating the species or subspecies... 

Endangered and threatened animals are protected under sections 17-2-37 through 17-2-46, 

Wildlife Conservation Act...It is unlawful to take, possess, transport, export, process, sell or 

ship species or subspecies of wildlife on the New Mexico Endangered Species list or the 

U.S. lists of endangered native and foreign fish and wildlife to the extent that such lists have 

been adopted by Commission regulation. Transport through the state is allowed under valid 

federal and state permits (17-2-41). 

(from NMDGF 2007) 

New York endangered and threatened categories have protections against “take”; “special concern” 

category has no special additional protection 

North Carolina unlawful to take or possess any endangered, threatened, or special concern species at any 

time without the appropriate permit 

Ohio unlawful to “take” any endangered species of fish or wildlife; “take” not specifically defined; 

no exemptions or permits to allow for incidental take; no special protections for “threatened” 

or “special interest” species; APHIS-WS advised to just release any state listed species if 

captured or to report accidental mortality 

Pennsylvania endangered and threatened categories have protections against “take” 

Rhode Island no person shall buy, sell, offer for sale, store, transport, import, export, or otherwise traffic in 

any animal or plant or any part of any animal or plant whether living, dead, processed, 

manufactured, preserved, or raw if the animal or plant has been declared to be an endangered 

species by either the United States secretaries of the interior or commerce or the director of 

the Rhode Island department of environmental management; exception is for purposes of 

scientific research or educational display either of which must be done by or under the 

formal supervision of a legitimate college or university and then only upon the issuance of a 

special permit for each individual excepted species 

South Carolina unlawful to take, possess, transport, export, process, sell or ship wildlife in need of 

management except as otherwise provided 

Tennessee unlawful to take, possess, transport, export or ship any endangered or threatened species 

without permit; regulations allow provisions for “take” to alleviate damage and to protect 

human health and safety 

Texas unlawful to “take” any endangered or threatened species without the issuance of a permit; 

“take” not specifically defined; state law includes all federally listed species as state listed 

Vermont unlawful to “take” any endangered or threatened species without the issuance of a permit; 

“take” not specifically defined; state law includes all federally listed species as state listed 

Virginia unlawful to “take” any endangered or threatened species of fish or wildlife; “take” defined 

same as federal ESA; no exemptions or permits to allow for incidental take 
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West Virginia only lists federal T&E species as having protections; “Species of Concern” are listed, but 

have no legal status other than those that are already federally listed 
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APPENDIX E 

APPENIDX E ECOREGION DESIGNATIONS WITHIN STATES AFFECTED BY APHIS-WS 

CONTINUED OR EXPANDED INVOLVEMENT INRABIES ORAL VACCINATION 

PROGRAMS 

Ecoregions are ecosystems of regional extent as defined by Bailey (1995). An “X” means the state contains the 

ecosystem/ecoregion described in the key below. The reader is referred to Bailey (1995) for more detailed 

descriptions of each ecoregion and the climate, soils, vegetation, and animal life that occur there. 

 212 M212 221 222 M221 231 232 234 255 313 M313 315 321 322 331 M331 411 

Maine X X X 

New 

Hampshire 

 X X 

Vermont X X 

Massachusetts X X 

Connecticut X X 

Rhode Island X 

New York X X X X 

Pennsylvania X X X 

Ohio X X 

Michigan X X 

Indiana X 

New Jersey X 

Maryland X X X X 

Delaware X 

West Virginia X X 

Virginia X X X 

Kentucky X X X X 

Tennessee X X X X X 

North 

Carolina 

 X X X 

South 

Carolina 

 X X X 

Georgia X X X 

Alabama X X 

Florida X X 

Mississippi X X X 

Louisiana X X X 

Texas X X X X X 

New Mexico X X X X X X 

Arizona X X X X 

Key to Ecoregion Designations (adapted from descriptions by Bailey 1995): 

Numbers in the 200 series are within the “Humid Temperate Domain”: 

212 Laurentian Mixed Forest Province - lower elevation areas (sea level to 2,400 ft.); flat to rolling hills in 

relief; moderately long and severe winters; average annual precipitation is moderate, ranging from 24 to 

45 in.; native vegetation types are transitional between spruce-fir coniferous boreal forest and broadleaf 

deciduous forest zones and are characterized by mixed stands of coniferous (mainly pine) species and a 

few deciduous species (mainly yellow birch, sugar maple, and American beech). 

M212 Adirondack-New England Mixed Forest-Coniferous Forest-Alpine Meadow Province - mountainous 

region with elevations between 500 and 4,000 ft.; warm summers and sometimes cold winters; annual 

precipitation averages 35 in. and average annual snowfall is more than 100 in.; native vegetation types 

transitional between boreal spruce-fir coniferous forest to the north and deciduous forest to the south; 

valleys contain hardwood forest (sugar maple, yellow birch, beech, hemlock); lower mountain slopes are 

characterized by mixed forest of spruce, fir, maple, beech, and birch; higher elevations are dominated by 

fir and spruce. 

221 Eastern Broadleaf Forest (Oceanic) Province - diverse topography; elevations from 1,000 to 3,000 ft.; 

cold winters and warm summers; year-round precipitation averaging 35 to 60 in.; native vegetation 

characterized by temperate deciduous forest dominated by tall broadleaf trees that provide a dense, 

continuous canopy in summer and shed their leaves in winter; dominant deciduous species include 
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American beech, yellow-poplar, basswoods, sugar maple, buckeye, red oak, white oak, hemlock; 

includes areas of pine-oak forest (“Pine Barrens”). 

222 Eastern Broadleaf Forest (Continental) Province - flat to rolling to moderate in relief; elevations from 

80 to 1,650 ft.; hot summers; precipitation varies from 20 to 50 in. mostly occurring during the growing 

season; native vegetation dominated by broadleaf deciduous forest with oak and hickory tree species 

more abundant than in other provinces; gradually turns to prairie towards the Midwest, forming a 

mosaic pattern with prairie. 

M221 Central Appalachian Broadleaf Forest-Coniferous Forest-Meadow Province - low mountains at 

elevations ranging from 300 to 6,700 ft.; distinct summers and winters; average annual precipitation 

varies from 35 in. in the valleys to up to 80 in. on the highest peaks; native vegetation characterized by 

mixed oak-pine forest, dominated by the white and black oak groups at lower levels; northeastern 

hardwood forest at mid elevation levels; and spruce-fir forest and meadows on the highest peaks. 

231 Southeastern Mixed Forest Province - comprised of the Piedmont and irregular Gulf Coastal Plains 

with elevations from 100 to 1,000 ft. and flat to gentle sloping relief; mild winters and hot, humid 

summers; rain falls throughout the year, with an average of 40 to 60 in. annually; native vegetation 

comprised of broadleaf deciduous (oak, hickory, sweetgum, red maple, winged elm) and needleleaf 

evergreen trees (mostly loblolly pine, shortleaf pine, other southern yellow pine species). 

232 Outer Coastal Plain Mixed Forest Province - flat and irregular Atlantic and Gulf Coastal Plains areas; 

flat to gentle sloping to gentle rolling in relief; temperatures relatively steady across seasons; rain falls 

throughout the year, with an average of 40 to 60 in. annually; native vegetation comprised of temperate 

rainforest characterized by evergreen oaks and members of the laurel and magnolia families, with 

coastal marshes and interior swamps dominated by gum and cypress tree species; most upland areas 

covered by subclimax pine forest. 

234 Lower Mississippi Riverine Forest Province - flat to gently sloping broad floodplain and low terraces 

made up of alluvium and loess; from near sea level in the south, altitude increases gradually to about 

660 ft. in the north; land of oxbow lakes and swamps are significant in the extreme southern portion of 

the province; warm winters and hot summers; rain falls throughout the year, with an average of 55 in. 

annually; temperature and precipitation decrease heading north; native vegetation comprised of bottomland deciduous forest, with ash, elm, cottonwood, sugarberry, sweetgum, water tupelo, oak, bald 

cypress, and vines significant along water courses. 

255 Prairie Parkland (Subtropical) Province - gently rolling to flat plains, many of them part of the Gulf 

Coastal Plain; elevations range from sea level to 1,300 ft.; streams and rivers are sluggish; numerous 

wetland areas along the coast; warm winters and hot summers; rain falls throughout the year, between 

35 and 55 in.; hurricanes are frequent in autumn; vegetation consists of prairies and savannas with 

medium-to-tall grasses and few hardy tree species. 

Numbers in the 300 series are within the “Dry Domain”: 

313 Colorado Plateau Semidesert Province - tablelands with moderate to considerable relief; elevations of 

the plateau tops range from 5,000 to 7,000 ft., with local relief ranging from 500 to more than 3,000 ft. 

in some of the deeper canyons; volcanic mountains rise 1,000 to 3,000 ft. above the plateau surface; 

stream valleys are narrow and widely spaced; climate is characterized by cold winters and hot summer 

days with cool nights; average annual precipitation is about 20 in.; vegetational zones are conspicuous, 

but lack uniformity; the lowest zone includes arid grasslands with xeric shrubs, cactus, and yucca; the 

woodland zone is extensive and dominated by open stands of pinyon pine and juniper; the montane zone 

extends over the high plateaus and includes ponderosa pine; the subalpine zone includes Engelman 

spruce and fir. 

M313 Arizona-New Mexico Mountains Semidesert-Open Woodland-Coniferous Forest-Alpine Meadow 

Province - mostly steep foothills and mountains; elevations range from 4,500 to 10,000 ft., with some 

mountain peaks reaching 12,600 ft.; average annual precipitation ranges from 10 to 35 in.; foothill zone 

is characterized by mixed grasses, chaparral brush, oak-juniper woodland, and pinyon-juniper 

woodland; open forests of ponderosa pine are found at 7,000 ft., Douglas-fir and aspen at 8,000 ft., 

Engelmann spruce and corkbark fir at 9,000 ft., and an alpine belt covers small areas above 11,000 ft. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

315 Southwest Plateau and Plains Dry Steppe and Shrub Province - generally flat to rolling plains and 

plateaus with elevations ranging from sea level to 6,500 ft.; semiarid climate; long, hot summers and 

short, mild winters; 10 to 30 in. annual precipitation; native vegetation characterized by arid grasslands 

in which shrubs and low trees grow singly or in bunches; dominant grass species include blue grama, 

buffalo grass, with mesquite, oak, and juniper typically the dominant shrub and tree species. 

321 Chihuahuan Desert Province - mostly desert with undulating plains with elevations near 4,000 ft.; long, 

hot summers and short winters; annual precipitation averages 8 in.; native vegetation mostly dominated 

by thorny shrubs, in many places associated with short grass such as grama; shrubs and trees include 

mesquite, creosote bush, yucca, and occasional scattered juniper and pinyon. 

322 American Semidesert and Desert Province - extensive, gently undulating plains from which isolated 

low, rocky mountains and buttes rise abruptly; elevations range from 280 ft. below sea level to 4,000. in 

valleys and basins with some mountain ranges reaching as high as 11,000 ft.; summers are long and hot 

and winters are moderate with occasional frosts; average annual precipitation is 2 to 10 in. vegetation is 

very sparse, with bare ground between individual plants; cacti and thorny shrubs are conspicuous, but 

many thornless shrubs and herbs are also present; such plants include the creosote bush, cholla, 

mesquite, paloverde, ocotillo, saguaro, bitterbrush, and saltbush. 

331 Great Plains-Palouse Dry Steppe Province - rolling plains and tablelands of moderate relief (1,200 to 

6,000 ft.); region lies in the rain shadow east of the Rocky Mountains and climate is semiarid; winters 

are cold and dry and summers are warm to hot; precipitation ranges from 10 to 25 in.; steppe, sometimes 

called shortgrass prairie, is a formation of short grasses, such as buffalo grass, grama, and wheatgrass, 

usually bunched and sparsely distributed with scattered trees and shrubs, such as sagebrush. 

M331 Southern Rocky Mountain Steppe-Open Woodland-Coniferous Forest-Alpine Meadow Province - 

Rocky Mountains are rugged glaciated mountains as high as 14,000 ft.; climate is a temperate semiarid 

steppe regime; climate is influenced by the prevailing west winds and the north-south orientation of the 

mountain ranges; bases of mountains receive only 10 to 20 in. of rainfall per year and higher elevations 

receive up to 40 in.; pronounced vegetational zonation, controlled by altitude, latitude, prevailing winds, 

and slope exposure; the uppermost alpine zone is characterized by alpine tundra and the absence of 

trees; subalpine zone below is dominated by Engelmann spruce and subalpine fir; the montane zone 

includes ponderosa pine and Douglas-fir; the foothill zone is characterized by dry rocky slopes with 

mountain-mahogany and scrub oak. 

Numbers in the 400 series are within the “Humid Tropical Domain”: 

411 Everglades Province - extensive low elevation (sea level to about 25 ft.) consisting primarily of large 

areas of swamps and marshes; hot summers and warm winters; average of 50 to 65 in. annual rainfall; 

native vegetation consists of tropical moist hardwood forest dominated by cypress trees and mangroves 

along the eastern and southern coasts; much open marsh characterized by grasses, reeds, sedges, and 

other aquatic herbaceous plants; some areas with dense stands of sawgrass and three-awn grasses. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

APPENDIX F 

AMERICAN INDIAN TRIBES LOCATED IN STATES THAT MAY BE AFFECTED BY 

APHIS-WS CONTINUED OR EXPANDED INVOLVEMENT IN ORV PROGRAMS

FEDERALLY RECOGNIZED TRIBES 

(74 FR 40218-40223, August 11, 2009)

Ak-Chin Indian Community (AZ) 

Alabama-Coushatta Tribe (TX) 

Aroostook Band of Micmacs (ME) 

Bay Mills Indian Community (MI) 

Catawba Indian Tribe (SC) 

Cayuga Nation of Nations (NY) 

Chitimacha Indian Tribe (LA) 

Cocopah Tribe (AZ) 

Colorado River Indian Tribes (AZ) 

Coushatta Indian Tribe (LA) 

Eastern Band of Cherokee Indians (NC) 

Fort McDowell Yavapai Nation (AZ) 

Fort Mojave Indian Tribe (AZ) 

Gila River Indian Community (AZ) 

Grand Traverse Band of Ottawa and 

Chippewa Indians (MI) 

Hannahville Indian Community (MI) 

Havasupai Tribe (AZ) 

Hopi Tribe (AZ) 

Houlton Band of Maliseet Indians (ME) 

Hualapai Indian Tribe (AZ) 

Jena Band of Choctaw Indians (LA) 

Jicarilla Apache Nation (NM) 

Kaibab Band of Paiute Indians (AZ) 

Keweenaw Bay Indian Community (MI) 

Kickapoo Traditional Tribe (TX) 

Lac Vieux Desert Band of Lake Superior 

Chippewa (MI) 

Little River Band of Ottawa Indians (MI) 

Little Traverse Bay Bands of Odawa 

Indians (MI) 

Mashantucket Pequot Tribal Nation (CT) 

Match-e-be-nash-she-wish Band of 

Pottawatomi Indians (MI) 

Mashpee Wampanoag Tribe (MA) 

Mescalero Apache Tribe (NM) 

Miccosukee Indian Tribe (FL) 

Mississippi Band of Choctaw Indians 

(MS) 

Mohegan Indian Tribe (CT) 

Narragansett Indian Tribe (RI) 

Navajo Nation (AZ) 

Navajo Nation (NM) 

Nottawaseppi Huron Band of the 

Potawatomi (MI) 

Ohkay Owingeh (NM) 

Oneida Indian Nation (NY) 

Onondaga Indian Nation (NY) 

Pascua Yaqui Tribe (AZ) 

Passamaquoddy Tribe (ME) 

Penobscot Indian Nation (ME) 

Poarch Band of Creek Indians (AL) 

Pokagon Band of Potawatomi Indians 

(MI) 

Pueblo of Acoma (NM) 

Pueblo of Cochiti (NM) 

Pueblo of Isleta (NM) 

Pueblo of Jemez (NM) 

Pueblo of Laguna (NM) 

Pueblo of Nambe (NM) 

Pueblo of Picuris (NM) 

Pueblo of Pojoaque (NM) 

Pueblo of San Felipe (NM) 

Pueblo of San Ildefonso (NM) 

Pueblo of Sandia (NM) 

Pueblo of Santa Ana (NM) 

Pueblo of Santa Clara (NM) 

Pueblo of Santo Domingo (NM) 

Pueblo of Taos (NM) 

Pueblo of Tesuque (NM) 

Pueblo of Zia (NM) 

Quechan Tribe of the Fort Yuma Indian 

Reservation (AZ) 

Saginaw Chippewa Indian Tribe (MI) 

Salt River Pima-Maricopa Indian 

Community (AZ) 

San Carlos Apache Tribe (AZ) 

San Juan Southern Paiute Tribe (AZ) 

Sault Ste. Marie Tribe of Chippewa 

Indians (MI) 

Seminole Tribe (FL) 

 

Seneca Nation of Indians (NY) 

St. Regis Mohawk Tribe (NY) 

Tohono O’odham Nation (AZ) 

Tonawanda Band of Seneca (NY) 

Tonto Apache Tribe (AZ) 

Tunica – Biloxi Tribe (LA) 

Tuscarora Nation (NY) 

Ute Mountain Tribe of the Ute Mountain 

Reservation (NM) 

Wampanoag Tribe of Gay Head 

(Aquinnah) (MA) 

White Mountain Apache Tribe (AZ) 

Yavapai-Apache Nation (AZ) 

Yavapai-Prescott Indian Tribe (AZ) 

Ysleta del Sur Pueblo (TX) 

Zuni Tribe of the Zuni Reservation (NM) 
STATE RECOGNIZED TRIBES 

(NCSL 2009) 

Abenaki People (VT) 

Adai Caddo Tribe (LA) 

Bayou LaFourche Band of the Biloxi 

Chitimacha Confederation of Muskegee 

(“BCCM”) (LA) 

Beaver Creek Indians (SC) 

Pee Dee Indian Nation of Upper South 

Carolina (SC) 

Burt Lake Band of Ottawa and Chippewa 

Indians (MI) 

Chaloklowa Indian People (state 

recognized group) (SC) 

Chappaquiddick Wampanoag (MA) 

Chaubunagungamang Band / Nipmuc 

Tribal Council (MA) 

Cherokee of Georgia Tribal Council 

(GA) 

Cherokees of SE Alabama 

Cherokee Tribe of Northeast Alabama 

Cher-O-Creek Intra Tribal National (AL) 

Chickahominy Tribe (VA) 

Choctaw Apache of Ebarb (LA) 

Clifton Choctaw (LA) 

Coharie Intra-Tribal Council (NC) 

Eastern Chickahominy (VA) 

Echota Cherokee of Alabama 

Edisto Indian Organization (state Indian 

organization ) (SC) 

Four Winds Tribe Louisiana Cherokee 

Confederacy (LA) 

Georgia Tribe of Eastern Cherokee (GA) 

Golden Hill Paugussett Tribe (CT) 

Grand Caillou/Dulac Band of the BCCM 

(LA) 

Grand River Band of Ottawa Indians 

(MI) 

Gun Lake Village Band of Grand Lake 

Ottawa Indians (MI) 

Haliwa-Saponi Tribe, Inc. (NC) 

Hassanamisco Nipmuc (MA) 

Herring Pond Wampanoag Tribe (MA) 

Isle de Jean Charles Band of the BCCM 

(LA) 

Kokenescv Natchez Tribe (GA) 

Langley Band of Chickamogee Cherokee 

Indians (AL) 

Lower Muscogee Creek Tribe (GA) 

Lumbee Tribal Council (NC) 

Machis Lower Creek Indian (AL) 

Mattiponi Indian Nation (VA) 

Meherrin Indian Tribe (NC) 

Monacan Indian Tribe (VA) 

Mowa Band of Choctaws (AL) 

Nansemond Indian Tribal Association 

(VA) 

Nanticoke Indian (DE) 

Nanticoke Lenni-Lenape (NJ) 

Occanecchi Band of the Saponi Nation 

(NC) 

Oklevuaha Band of Yamassee Seminole 

(FL) 

Pamunkey Nation (VA) 

Paucatuck Eastern Pequot (CT) 

Piqua Shawnee Tribe (AL) 

Pocasset Wampanoag Tribe (MA) 

Point au Chien Indian Tribe (LA) 

Poospatuck Indain Nation (NY) 

Powhatan Renape Nation (NJ) 

Ramapough Mountain Indians (NJ) 

Santee Indian Organization (SC) 

Sappony (NC) 

Schaghticoke Indian Tribe (CT) 

Seaconke Wampanoag Tribe (MA) 

Shinnecock Tribe (NY) 

Star Clan of Muskogee Creeks of Pike 

County (AL) 

Swan Creek Black River Confederated 

Ojibwa Tribe (MI) 

United Cherokee ani-Yun-Wiya Nation 

(AL) 

United Houma Nation (LA) 

United Rappahannock Tribe (VA) 

United Remnant Band Shawnee Nation 

(OH) 

Unkechaug Indian Nation of Poospatuck 

Indians (NY) 

Upper Mataponi Tribe (VA) 

Waccamaw Indian People (SC) 

Waccamaw-Siouan Development (NC) 

Wyandot of Anderdon Nation (MI) 
G-1 

APPENDIX G 

USDA-AGRICULTURAL MARKETING SERVICE-NATIONAL ORGANICS PROGRAM RULE ON ORV 

BAIT DISTRIBUTION ON ORGANIC FARMS 
G-2 
H-1 

APPENDIX H 

STATUTES REGARDING RABIES MANAGEMENT 

States to be included in the expanding program: 

Arizona

Arizona Revised Statutes 

11-1014. Biting animals; reporting; handling and destruction.

A. An unvaccinated dog or cat that bites any person shall be confined and quarantined in a county pound or, on 

request of and at the expense of the owner, at a veterinary hospital for a period of not less than ten days. The 

quarantine period shall start on the day of the bite incident. If the day of the bite is not known, the quarantine period 

shall start on the first day of impoundment. A dog properly vaccinated pursuant to this article that bites any person 

may be confined and quarantined at the home of the owner or wherever the dog is harbored and maintained with the 

consent of and in a manner prescribed by the county enforcement agent. 

B. Any domestic animal, other than a dog, a cat or a caged or pet rodent or rabbit, that bites any person shall be 

confined and quarantined in a county pound or, on the request and at the expense of the owner, at a veterinary hospital 

for a period of not less than fourteen days. Livestock shall be confined and quarantined for the fourteen-day period in 

a manner regulated by the Arizona department of agriculture. Caged or pet rodents or rabbits shall not be quarantined 

or laboratory tested. 

C. With the exception of a wild rodent or rabbit, any wild animal that bites any person or directly exposes any person 

to its saliva may be killed and submitted to the county enforcement agent or the agent's deputies for transport to an 

appropriate diagnostic laboratory. A wild rodent or rabbit may be submitted for laboratory testing if the animal has 

bitten a person and either the animal's health or behavior indicates that the animal may have rabies or the bite occurred 

in an area that contains a rabies epizootic, as determined by the department of health services. 

D. Whenever an animal bites any person, the incident shall be reported to the county enforcement agent immediately 

by any person having direct knowledge. 

E. The county enforcement agent may destroy any animal confined and quarantined pursuant to this section before 

the termination of the minimum confinement period for laboratory examination for rabies if: 

1. The animal shows clear clinical signs of rabies. 

2. The animal's owner consents to its destruction. 

F. Any animal subject to licensing under this article found without a tag identifying its owner shall be deemed 

unowned. 

G. The county enforcement agent shall destroy a vicious animal by order of a justice of the peace or a city magistrate. 

A justice of the peace or city magistrate may issue an order to destroy a vicious animal after notice to the owner, if 

any, and the person who was bitten, and a hearing. The justice of the peace or city magistrate may impose additional 

procedures and processes to protect all parties in the interest of justice and any decision by the justice of the peace or 

magistrate may be appealed to the superior court. 

H. The owner of a vicious animal shall be responsible for any fees incurred by the enforcement agent for the 

impounding, sheltering and disposing of the vicious animal. 

11-1005. Powers and duties of Board of Supervisors. 

A. Each county Board of Supervisors may: 

1. Designate or employ a county enforcement agent. If such designation or employment is not made, the county 

sheriff shall be the county enforcement agent, but nothing in this article shall be deemed to prevent the county 

board of supervisors from designating or employing a county enforcement agent at any time it is deemed necessary 

or advisable. 

3. Contract with any city or town to enforce the provisions of any ordinance enacted by such city or town for the 

control of dogs. 

4. For the unincorporated areas of the county, by ordinance, regulate, restrain and prohibit the running at large of 

dogs, except dogs used for control of livestock or while being used or trained for hunting. 

D. The county board of supervisors shall be responsible for declaring a rabies quarantine area within its jurisdiction 

on a recommendation of the county board of health or the local health department. If a rabies quarantine area is 

declared, the county board of supervisors shall meet with the county board of health and the county enforcement agent 

and institute an emergency program for the control of rabies within that area provided that any regulations restricting 

or involving the movement of livestock within that area shall be developed by the state veterinarian. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

11-1011. Rabies control fund. 

A. The board of supervisors shall transmit the monies collected under the provisions of this article to the county 

treasurer for deposit in a special fund to be known as the rabies control fund to be used for the enforcement of the 

provisions of this article and the regulations promulgated thereunder. The county treasurer shall maintain the fund. 

11-1002. Powers and duties of the state veterinarian and the Arizona Department of Agriculture. 

A. The state veterinarian shall designate the type or types of anti-rabies vaccines that may be used for vaccination of 

animals, the period of time between vaccination and revaccination and the dosage and method of administration of the 

vaccine. 

B. The Arizona Department of Agriculture shall regulate the handling and disposition of animals classed as livestock 

that have been bitten by a rabid or suspected rabid animal or are showing symptoms suggestive of rabies. 

11-1003. Powers and duties of Department of Health Services. 

A. The Department of Health Services shall regulate the handling and disposition of animals other than livestock that 

have been bitten by a rabid or suspected rabid animal or are showing symptoms suggestive of rabies. 

B. The Department of Health Services may require the county enforcement agent to submit a record of all dog 

licenses issued and in addition any information deemed necessary to aid in the control of rabies. 

11-1010. Anti-rabies vaccination; vaccination and license stations. 

A. ...No dog shall be licensed unless it is vaccinated in accordance with the provisions of this article and the 

regulations promulgated pursuant to this article. 

B. A dog vaccinated in any other state prior to entry into Arizona may be licensed in Arizona provided that, at the 

time of licensing, the owner of the dog presents a vaccination certificate, signed by a veterinarian licensed to practice 

in that state or a veterinarian employed by a governmental agency in that state, stating the owner's name and address, 

and giving the dog's description, date of vaccination and type, manufacturer and serial number of the vaccine used. 

The vaccination must be in conformity with the provisions of this article and the regulations promulgated pursuant to 

this article. 

C. The county enforcement agent shall make provisions for vaccination clinics as deemed necessary. The vaccination 

shall be performed by a veterinarian. 

11-1008. License fees for dogs; issuance of dog tags; classification. 

A. The Board of Supervisors of each county may set a license fee which shall be paid for each dog three months of 

age or over that is kept, harbored or maintained within the boundaries of the state for at least thirty consecutive days 

of each calendar year. License fees shall become payable at the discretion of the board of supervisors of each county. 

The licensing period shall not exceed the period of time for revaccination as designated by the state veterinarian. 

B. If the board of supervisors adopts a license fee, the board shall provide durable dog tags. Each dog licensed under 

the terms of this article shall receive, at the time of licensing, such a tag on which shall be inscribed the name of the 

county, the number of the license, and the year in which it expires. The tag shall be attached to a collar or harness 

which shall be worn by the dog at all times, except as otherwise provided in this article. 

C. The board of supervisors may set license fees that are lower for dogs permanently incapable of procreation. 

D. All fees and penalties shall be deposited in the rabies control fund pursuant to section 11-1011. 

11-1012. Dogs not permitted at large; wearing licenses. 

A. Neither a female dog during her breeding or mating season nor a vicious dog shall be permitted at large. 

B. In a rabies quarantine area, no dogs shall be permitted at large. Each dog shall be confined within an enclosure on 

the owner's property, secured so that the dog is confined entirely to the owner's property, or on a leash not to exceed 

six feet in length and directly under the owner's control when not on the owner's property. 

C. Any dog over the age of three months running at large shall wear a collar or harness to which is attached a valid 

license tag. Dogs that are used for control of livestock, being used or trained for hunting or dogs, being exhibited or 

trained at a kennel club event or engaged in races approved by the Arizona racing commission, and while the dogs are 

being transported to and from such events, need not wear a collar or harness with a valid license attached provided 

that they are properly vaccinated, licensed and controlled. 

D. No person in charge of any dog shall permit such dog in a public park or upon any public school property unless 

the dog is physically restrained by a leash, enclosed in a car, cage or similar enclosure or being exhibited or trained at 

a recognized kennel club event, public school or park sponsored event. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

9-499.04. Animal control officers; appointment; authority; powers and duties. 

A. Any city and town may by ordinance provide for the appointment of animal control officers who may commence 

an action or proceeding before a court for any violation of a state statute or local ordinance relating to rabies and 

animal control which occurs within the jurisdiction of the city or town. 

B. An animal control officer appointed pursuant to subsection A shall: 

1. Be unarmed during the course of duties except that a small caliber firearm may be available to be used in 

controlling vicious animals or in dispatching of a wounded animal. 

New Mexico

New Mexico Administrative Code 

New Mexico Department of Game and Fish 

17-1-14. General powers and duties of state game commission; game protection fund. 

B. The state game commission shall have authority to: 

(15) Adopt rules to control, eradicate or prevent the spread of a contagious disease, pest or parasite, including 

chronic wasting disease, to or among game animals. The rules shall include provisions for: 

(a) Notification to the department of game and fish of the diagnosis or suspected presence of a contagious 

disease; 

(b) Examination by the state veterinarian or his designee of suspected infected game animals; 

(c) Quarantine, treatment or destruction of an infected game animal; 

(d) Disinfection and isolation of a licensed private park where an infected game animal has been; and 

(e) Indemnification and destruction of a protected game animal; 

C. The director of the department of game and fish shall exercise all the powers and duties conferred upon the state 

game and fish warden by all previous statutes now in force not in conflict with Chapter 17 NMSA 1978. 

New Mexico Livestock Board 

77-2-7 Additional powers of the board.

In addition to the powers transferred from the cattle and sheep sanitary boards, the board may: 

A. Exercise general regulatory supervision over the livestock industry of this state in order to protect the industry 

from theft and diseases and in order to protect the public from diseased or unwholesome meat or meat products; 

D. Employ livestock inspectors and brand inspectors and other personnel necessary to carry out the purposes of The 

Livestock Code. All livestock inspectors appointed by the board shall have the same powers as any other peace officer 

in the enforcement of that code; 

E. Appoint a state veterinarian and subordinate veterinarians as are necessary to carry out the duties of the board; 

H. Establish quarantine, provide its boundaries and give notice of the quarantine and do all other things necessary to 

effect the object of the quarantine and to protect the livestock industry of this state from disease and prevent the 

spread of disease; 

I. Adopt and promulgate rules for meat inspection, including the slaughter and disposition of the carcasses of 

livestock affected with diseases when the action appears necessary to prevent the spread of any contagion or infection 

among livestock; 

J. Adopt and promulgate rules governing the importation, manufacture, sale, distribution or use within the state of 

serums, vaccine and other biologicals intended for diagnostic or therapeutic uses with livestock and regulate the 

importation, manufacture or use of virulent blood or living virus of any diseases affecting livestock; 

L. Consider the views of the livestock industry in the administration of The Livestock Code; 

M. Adopt and promulgate rules to otherwise carry out the purposes of The Livestock Code; 

77-3-13. Dangerous epidemics; emergency rules; imports prohibited; penalty. 

A. When the board or any of its authorized representatives finds that a disease, the nature of which is known to be 

fatal or highly injurious to livestock, pigeons or fowl of any kind, has become epidemic or exists in a locality in a 

country, state or territory beyond the limits of this state, the board shall immediately adopt and promulgate emergency 

rules to prohibit the importation into this state of any animals, including livestock, subject to the disease that may be 

so reported. 

B. The board shall specify such restrictions and safeguards as it deems proper and shall specify for the protection of 

livestock in this state and may also prohibit the importation into this state of any hoofs, hides, skins or meat of any 

animals or any hay, straw fodder, cottonseed or other products or material calculated to carry the infection of such 

disease. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

C. Emergency rules may be adopted and promulgated without the notice and hearing required of other rules and shall 

take effect immediately. If the board contemplates that an emergency rule will be in effect for longer than ninety days, 

it shall give notice and hold a hearing to adopt the emergency rule as a rule. 

New Mexico Department of Health 

24-1-3. Powers and authority of department. 

The department has authority to: 

A. Receive such grants, subsidies, donations, allotments or bequests as may be offered to the state by the federal 

government or any department thereof or by any public or private foundation or individuals; 

B. Supervise the health and hygiene of the people of the state; 

C. Investigate, control and abate the causes of disease, especially epidemics, sources of mortality and other conditions 

of public health; 

D. Establish, maintain and enforce isolation and quarantine; 

E. Close any public place and forbid gatherings of people when necessary for the protection of the public health; 

H. Provide educational programs and disseminate information on public health; 

I. Maintain and enforce rules for the licensure of health facilities; 

J. Bring action in court for the enforcement of health laws and rules and orders issued by the department; 

K. Enter into agreements with other states to carry out the powers and duties of the department; 

L. Cooperate and enter into contracts or agreements with the federal government or any other person to carry out the 

powers and duties of the department; 

M. Maintain and enforce rules for the control of communicable diseases deemed to be dangerous to public health; 

N. Maintain and enforce rules for immunization against diseases deemed to be dangerous to the public health; 

States included under the continuing program: 

Alabama

Alabama Department of Agriculture and Industries (Alabama Administrative Code: Sec. 2-15-152). The 

Alabama Department of Agriculture and Industries is authorized to cooperate with federal agencies in control of 

contagious and infectious diseases. 

Alabama Board of Health (Alabama Administrative Code: §22-2-2(2)). The Alabama Board of Health is 

authorized to investigate causes, modes or propagation and means of prevention of diseases. 

Connecticut

Connecticut Department of Agriculture (General Statutes of Connecticut: Title 22, Chapters 433, 435, and 

436a regarding Agriculture and Domestic Animals). The Connecticut Department of Agriculture’s mission is to 

foster a healthy economic, environmental and social climate for agriculture by developing, promoting and regulating 

agricultural businesses; protecting agricultural and aquacultural resources; enforcing laws pertaining to domestic 

animals; and promoting an understanding among the state's citizens of the diversity of Connecticut agriculture, its 

cultural heritage and its contribution to the state's economy.

Connecticut Department of Environmental Protection (General Statutes of Connecticut: Title 26, Chapter 490 - 

Fisheries and Game). The Connecticut Department of Environmental Protection’s mission is to conserve, improve 

and protect the natural resources and environment of the State of Connecticut in such a manner as to encourage the 

social and economic development of Connecticut while preserving the natural environment and the life forms it 

supports in a delicate, interrelated and complex balance, to the end that the state may fulfill its responsibility as trustee 

of the environment for present and future generations.

Delaware

Delaware Department of Natural Resources and Environmental Control (Delaware Code: Title 3, Ch. 82). The 

Delaware Department of Natural Resources and Environmental Control is authorized to protect and manage the state's 

vital natural resources, protect public health and safety, provide quality outdoor recreation and to serve and educate 

the citizens of the First State about the wise use, conservation and enhancement of Delaware's environment. 

Delaware Department of Agriculture (Delaware Code: Title 3, Ch. 82). The Delaware Department of 

Agriculture’s mission is to sustain and promote the viability of food, fiber, and agricultural industries in Delaware 

through quality services that protect and enhance the environment, health, and welfare of the general public.
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Delaware Division of Public Health (Delaware Code: Title 3, Ch. 82). The Delaware Division of Public Health is 

authorized to protect and enhance the health of the people of Delaware by: Working together with others; Addressing 

issues that affect the health of Delawareans; Keeping track of the state's health; Promoting positive lifestyles; 

Responding to critical health issues and disasters; and Promoting the availability of health services. This 

responsibility includes managing rabies. Delaware’s Rabies program began in 1988 to assist residents in coping with 

the increasing number of rabid raccoons and other rabid animals in New Castle County. As the raccoon rabies 

epidemic spread into Kent and Sussex Counties, the program adjusted to meet the needs of citizens throughout the 

state. 

Florida

Florida Department of Agriculture and Consumer Services – Division of Animal Industry (Florida 

Administrative Code: Chapter 5). The Florida Department of Agriculture and Consumer Services is authorized to 

safeguard the public and support Florida’s agricultural economy. The Division of Animal Industry is responsible for 

preventing, controlling and eradicating certain infectious or communicable diseases of livestock and other domestic 

animals. 

Florida Department of Health (Florida Administrative Code: Chapter 64). The Florida Department of Health is 

authorized to promote and protect the health and safety of all people in Florida through the delivery of quality public 

health services and promotion of health care standards. 

Georgia

Georgia Department of Natural Resources (Official Code of Georgia Annotated: Title 12 - Conservation and 

Natural Resources and Title 27 - Game and Fish). The Georgia Department of Natural Resources is authorized to 

sustain, enhance, protect, and conserve Georgia’s natural, historic, and cultural resources for present and future 

generations, while recognizing the importance of promoting the development of commerce and industry that utilize 

sound environmental practices. 

Georgia Department of Agriculture (Official Code of Georgia Annotated: 4-9-1 through 4-9-9). The Georgia 

Department of Agriculture is authorized to ensure an abundance of safe food and fiber for Georgia, America and the 

world. 

Georgia Department of Human Resources, Division of Public Health (Official Code of Georgia Annotated: 

Title 31, Chapter 19, Section 2). The Georgia Department of Human Resources issued a Declaration to Protect the 

Public Health in October 1, 2003 to control the spread of the raccoon strain of the rabies virus in four counties within 

the Northwest Georgia Health District. 

Indiana

Indiana Department of Natural Resources – Division of Fish and Wildlife (Indiana Administrative Code: Title 

14, Article 22, Chapter 2, Section 3). The Indiana Division of Fish and Wildlife “shall . . .provide for the protection, 

reproduction, care, management, survival and regulation of wild animal populations regardless of whether the wild 

animals are present on public or private property. . . and organize and pursue a program of research and management 

of wild animals that will serve the best interests of the resources and the people of Indiana.” 

Indiana Board of Animal Health (Indiana Administrative Code: Title 345). The Indiana Board of Animal Health 

mission involves “...the protection of public health by preventing and controlling the spread of animal diseases, such 

as rabies, which pose a threat to people.” Pertinent sections of the law include the establishment of a rabies control 

program (345 IAC 1-5-3a) and the translocation of animals across state lines (345 IAC 1-3-2c). 

Indiana State Department of Health (Indiana Administrative Code: Title 410). The Indiana State Department of 

Health “serves to promote, protect and provide for the public health of the people in Indiana.” A pertinent section of 

the law includes control measures for the reporting of animal bites, including the administering of post-exposure 

rabies prophylaxis to a bite victim. Any person bitten or scratched by a wild carnivorous mammal or bat not available 

for rabies testing should be regarded as having been potentially exposed to rabies (410 IAC 1-2.3-52). 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Reporting and Investigation of Animal Bites [410 IAC 1-2.1-6(c)] Reporting, investigation, quarantine, wild animals 

and submitting animal heads. 

(1) Reporting: Every case of a human bitten by a domestic or wild animal shall be reported promptly to the local 

health officer having jurisdiction. If a physician is in attendance, it shall be reported by such physician. If no physician 

is in attendance and the person bitten is a child, it shall be the duty of the parent or the guardian to make such a report 

immediately. If the person bitten is an adult, such person shall make the report or, if or, if incapacitated, it shall be 

reported by whomever is caring for the person bitten. It shall be the duty of the local health officer to report directly to 

the State Board of Health on the prescribed form the information concerning the bite.

(2) Investigation: Each reported bite shall be investigated immediately by the local health officer or his designee. 

(3) Quarantine and/or laboratory examination: Any domestic animal which has bitten a person or is suspected or being 

rabid shall be confined and held in observation for the period specified in IAC 15-2.1-6-11 (not less than 10 days) or 

filled at once for laboratory examination. The head of any animal that dies during the period of observation or is killed 

subsequent to having bitten a person or another animal and is suspected of being rabid shall be removed, packed in an 

iced container and forwarded immediately to the laboratory of the State Board of Health for examination. Any wild 

animal that has bitten a human or domestic animal or is suspected of being rabid shall not be placed under 

observation, but shall be killed at once and the head submitted to the laboratory of the State Department of Health. 

(Rodents and lagomorphs are seldom rabid in the United States; these animals should be submitted for laboratory 

examination only under exceptional circumstances such as an unprovoked attack.) 

(4) Responsibility for submitting animal heads: The animal's owner shall be responsible for submitting the animal's 

head to the State Department of Health for rabies examination; in the case of an unowned animal or an animal whose 

owner cannot be found, the local health, department shall assume this responsibility.

Kentucky

Kentucky Cabinet for Health and Family Services (Kentucky Revised Statutes: 258). The Kentucky Department 

for Public Health, within the Cabinet for Health and Family Services, coordinates a diverse group of programs that 

impact the health of all Kentuckians, including public health emergency preparedness, maternal and child health, 

chronic disease, nutrition and wellness, environmental health, epidemiology, the state public health laboratory, and 

working with the state’s network of local health departments. The Rabies Program in the Division of Epidemiology 

and Health Planning works to control rabies and prevent human infection, consult on the needs of pre-exposure and 

post-exposure treatment and train local health department environmental personnel on animal quarantine procedures. 

Rabies control is provided by law in Kentucky Revised Statutes 258.005-258.990 and under the state Communicable 

Disease Regulation 902 Kentucky Administrative Regulations 2:070. 

Kentucky Department of Agriculture - Office of the State Veterinarian (Kentucky Revised Statutes: 257-259. 

302 Kentucky Administrative Regulations: Chapter 20). The Kentucky Department of Agriculture - Office of the 

State Veterinarian’s mission is the control and eradication of infectious and communicable animal diseases. 

Louisiana

Louisiana Department of Health and Hospitals (Louisiana Revised Statutes: Title 51 State Sanitary Code, Part 

III, Chapter 1 - The Control of Rabies). The mission of the Louisiana Department of Health and Hospitals is to 

protect and promote health and to ensure access to medical, preventive, and rehabilitative services for all citizens of 

the State of Louisiana. 

Maine

Maine Department of Human Services - Maine State Health and Environmental Testing 

Laboratory/Epidemiology Program (22 Maine Revised Statutes Annotated: Subtitle 2, Part 2, Chapter 157-A, 

Section 565). The Maine State Health and Environmental Testing Laboratory/Epidemiology Program are authorized 

to offer the direct fluorescent antibody for the rapid and accurate diagnosis of rabies in a suspect animal using brain 

tissue. The diagnosis of the presence or absence of rabies can be used as a guide for medical recommendations for 

humans or domestic animals who are at risk of exposure. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Maine Department of Inland Fisheries and Wildlife (22 Maine Revised Statutes Annotated: Subtitle 2, Part 3, 

Chapter 251, Section 1313). The Maine Department of Inland Fisheries and Wildlife is authorized to provide for or 

pay all necessary costs for transportation and euthanasia of an undomesticated animal suspected of having rabies. 

Maine State Department of Agriculture (7 Maine Revised Statutes Annotated: part 1, Chapter 1, Section 1-B). 

The Maine State Department of Agriculture has the authority to implement the rules and regulations for rabies 

throughout Maine. State veterinarians dispense the rabies vaccination to livestock, enforce quarantines, and regulate 

animal transportation in and out of Maine’s borders. 

Maryland

Maryland Department of Health and Mental Hygiene (Maryland Code: Title 18, Subtitle 3, §18-313). The 

Maryland Department of Health and Mental Hygiene shall provide a statewide system to: 1) control rabies; 2) to grant 

authority to the public health veterinarian and the local health officer in matters pertaining to the disposition of 

animals that bite or otherwise expose rabies to an individual; 3) to assist local political subdivisions regarding the 

laboratory testing of rabid animals; 4) to treat each individual who is exposed or suspected of having been exposed to 

rabies; 5) to distribute the biological products that are needed to prevent and treat rabies. 

Maryland Department of Natural Resources (Maryland Code: Title 10, Subtitle 2, §10-202). The Maryland 

Department of Natural Resources is responsible for conservation and management of wildlife and wildlife resources 

of the state. 

Massachusetts

Massachusetts Department of Public Health (Massachusetts Code: 105). The Massachusetts Department of 

Public Health is dedicated to protecting, preserving, and improving the health of all the Commonwealth’s residents. 

Massachusetts Department of Fish and Game, Division of Fisheries and Wildlife (Massachusetts Code: 321). 

The Massachusetts Division of Fisheries and Wildlife works to protect the public & wildlife by: 1)monitoring 

outbreaks of wildlife disease; 2) sharing information with humane and animal health authorities; 3) prohibiting 

possession of wildlife as pets; 4) regulating wildlife populations through harvest of animals by licensed hunters and 

trappers; 5) prohibiting the importation or relocation of wildlife; and 6) increasing public awareness of wildlife 

through education. 

Massachusetts Department of Agricultural Resources (Massachusetts Code: 330). The Massachusetts 

Department of Agricultural Resources deals with the prevention and the spread of rabies in humans and domestic 

animals. 

Michigan

Michigan Department of Community Health. The Michigan Department of Community Health “strives for a 

healthier Michigan. To that end, the department will: 1) Promote access to the broadest possible range of quality 

services and supports; 2) Take steps to prevent disease, promote wellness and improve quality of life; and 3) Strive for 

the delivery of those services and supports in a fiscally prudent manner.” 

Michigan Department of Natural Resources. The Michigan Department of Natural Resources is “responsible for 

the stewardship of Michigan's natural resources and for the provision of outdoor recreational opportunities...” One of 

many goals involves managing disease and invasive species occurrence. Michigan’s natural resources are under 

constant threat from diseases and the introduction of exotic species not indigenous to the area. These threats pose a 

significant threat to precious natural resources as well as vital segments of the State’s economy such as hunting and 

fishing, agriculture and tourism. A system of monitoring and response must be implemented to deal with such threats 

as they develop in order to minimize their impact. 

Michigan Department of Agriculture. The Michigan Department of Agriculture’s mission is “to serve, promote, 

and protect the food, agriculture and economic interests of the people of the state of Michigan.” 

Mississippi
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Mississippi State Department of Health (Mississippi Statutes: 41-53 and 41-3. Mississippi Regulations Section 

XVII: Specific Disease Control Measures, Section 12 - Rabies). The mission of the Mississippi State Department 

of Health is to promote and protect the health of all Mississippians. 

Mississippi Department of Agriculture and Commerce - Board of Animal Health (Rules of the Mississippi 

Board of Animal Health Subpart 2: Administrative Rules, Chapter 18 - Animal Rabies Control. Mississippi 

Regulations Section XVII: Specific Disease Control Measures, Section 12 - Rabies). The Board of Animal Health 

was given plenary power to deal with all contagious and infectious diseases of animals as in the opinion of the board 

may be prevented, controlled, or eradicated, and with full power to make, promulgate, and enforce such rules and 

regulations as may be necessary to control, eradicate and prevent those diseases.

New Hampshire

New Hampshire Department of Health and Human Services (New Hampshire Revised Statutes Annotated: 

Title X, Chapter 125, Section 125:9:II). The New Hampshire Department of Health and Human Services is 

authorized to make investigations and inquiries concerning the causes of epidemics and other diseases, the sources of 

morbidity and mortality, and the effects of localities, employments, conditions, circumstances, and the environment on 

the public health. Investigations also include an extended rabies surveillance effort which shall be conducted with 

assistance from the New Hampshire Department of Agriculture, Markets, and Food; and New Hampshire Fish and 

Game Department. 

New Hampshire Department of Agriculture, Markets, and Food (New Hampshire Revised Statutes Annotated: 

Title XL, Chapter 436-A, Section 436-A:1). The state veterinarian within the New Hampshire Department of 

Agriculture, Markets, and Food may authorize the application of vaccines and treatments for zoonotic diseases to 

wildlife within the state through baiting or other methods. 

New Hampshire Fish and Game Department (New Hampshire Revised Statutes Annotated: Title XVIII, 

Chapter 206, Section 206:10:I). The New Hampshire Fish and Game Department is charged with protecting, 

propagating and preserving the fish, game and wildlife resources of New Hampshire and protecting and conserving 

nongame birds of New Hampshire. 

New Jersey

New Jersey Department of Environmental Protection - Division of Fish and Wildlife. The mission of the New 

Jersey Department of Environmental Protection, Division of Fish and Wildlife is to protect and manage New Jersey’s 

fish and wildlife to maximize their long-term biological, recreational, and economic values for New Jersey’s residents. 

New Jersey Department of Agriculture. The mission of the New Jersey Department of Agriculture is to develop, 

promote, conserve, and support the agriculture and agribusiness industry of the state and those natural and renewable 

resources that are associated with agriculture and other open lands for the benefit of all its citizens. 

New Jersey Department of Health and Senior Services. The New Jersey Department of Health and Senior Services 

provides guidance on public health related issues and potential health problems associated with wildlife. 

New York

New York State Agriculture and Markets (New York Legislative Authorization Code: Chapter 69, Article 5, 

Section 73b). The New York State Department of Agriculture and Markets is authorized to establish a New York 

State Veterinary Diagnostic Laboratory (Cornell University works under this law during ORV program participation) 

which is authorized to respond to disease outbreaks in animals; establish diagnostic testing capabilities to establish 

heard health status and evaluation of disease programs; support disease surveillance and monitoring programs of 

domestic, zoo, and wild animals; support veterinarians by analyzing and interpreting samples obtained from clinical 

cases; and evaluate, adjust, and improve New York’s ability to recognize diseases that impact animal populations. 

(New York Legislative Authorization Code: Chapter 69, Article 5, Section 72). The New York State Department 

of Agriculture and Markets is authorized to investigate, suppress, or eradicate infectious or communicable disease 

affecting domestic animals or carried by domestic animals and affecting humans. Measures shall be taken to prevent 

such disease from being brought into the state or suppress or prevent the disease from spreading within the state. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

New York Department of Environmental Conservation (New York Legislative Authorization Code: Chapter 

43-B, Article 11, Title 3, Section 11-0325 and 11-0525). The New York Department of Environmental Conservation 

is authorized to undertake fish or wildlife control measures to eliminate, reduce, or confine a disease which endangers 

the health and welfare of fish or wildlife populations. The New York Department of Environmental Conservation is 

directed to undertake through the use of professional trappers or by other means wildlife control measures when rabies 

is certified to exist in an area of the state in attempt to eliminate, reduce, or confine the disease. 

New York State Department of Health (New York Legislative Authorization Code: Chapter 45, Article 2, 

Section 201). The New York State Department of Health is directed to supervise the reporting and control of disease 

and promote education in the prevention and control of disease. 

North Carolina

North Carolina Wildlife Resources Commission (North Carolina General Statutes: 113-131). The North 

Carolina Wildlife Resource Commission is charged with the stewardship of wildlife resources. 

North Carolina Department of Agriculture and Consumer Services (North Carolina General Statutes: 113-3). 

The North Carolina Department of Agriculture focuses of providing animal disease programs designed to control and 

eliminate animal diseases and ensure general animal health. 

North Carolina Department of Environment and Natural Resources (North Carolina General Statutes: 113-3). 

The North Carolina Department of Environment and Natural Resources is the lead stewardship agency for the 

preservation and protection of North Carolina’s outstanding natural resources. 

North Carolina Department of Health and Human Services (North Carolina General Statutes: 130A-1.1). The 

North Carolina Department of Health and Human Services is authorized to provide efficient services that enhance the 

quality of life of North Carolina individuals and families so that they have opportunities for healthier and safer lives 

resulting ultimately in the achievement of economic and personal independence. 

Ohio 

Ohio Department of Health (Ohio Administrative Code: Chapter 3701 - Zoonotic Diseases and Animal Bites).

The Ohio Department of Health Rabies Program conducts rabies prevention activities to protect Ohio residents from 

the spread of wildlife rabies to people, pets, and other animals. Bat, raccoon, skunk, other wild animal and domestic 

animal rabies cases are reviewed to determine any necessary control initiatives. 

Ohio Department of Natural Resources – Division of Wildlife (Ohio Administrative Code: Chapter 1501:31).

The Ohio Department of Natural Resources is “dedicated to conserving and improving the fish and wildlife resources 

and their habitats, and promoting their use and appreciation by the public so that these resources continue to enhance 

the quality of life for all Ohioans.” 

Ohio Department of Agriculture (Ohio Administrative Code: Chapter 901). The Ohio Department of 

Agriculture’s mission is “to provide regulatory protection to producers, agribusinesses and the consuming public; to 

promote Ohio agricultural products in domestic and international markets; and to educate the citizens of Ohio about 

our agricultural industry.” 

Pennsylvania

Pennsylvania Game Commission (Law 322 (a) Title 34). The Pennsylvania Game Commission is charged to 

protect, propagate, manage, and preserve the game or wildlife of this Commonwealth and to enforce, by proper 

actions and proceedings, the law of this Commonwealth relating thereto. 

 

Pennsylvania Department of Agriculture (Pennsylvania Agriculture Code: Chapter 23, Section 2327 (d)). The 

Pennsylvania Department of Agriculture is authorized to solicit assistance from and provide assistance to federal and 

other state agencies, local governments and private entities in monitoring wild animals in this Commonwealth to 

determine the presence of dangerous transmissible diseases. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Pennsylvania Department of Health (Pennsylvania Administrative Code: Chapter 532, Section 2102 (a)). The 

Pennsylvania Department of Health is authorized to protect the health of the people of this Commonwealth and to 

determine and employ the most efficient and practical means for the prevention and suppression of disease. 

Rhode Island

Rhode Island Department of Environmental Management - Division of Agriculture - Animal Health Unit 

(Rhode Island General Laws: Chapter 4-13). The Animal Health Unit enforces state laws and regulations, controls 

the spread of diseases that impact the livestock industry and also diseases, such as rabies, that can spread from animals 

to people. The rabies program has become critical now that this disease is established in the state's raccoon 

population. Only an intensive rabies-control program will prevent this disease from spreading to domestic animals 

and then to people. The Department of Environmental Management’s veterinarian plays a key role in this program. 

Rhode Island Department of Health (Rhode Island General Laws: Chapter 4-13). The Rhode Island Department 

of Health’s mission is to prevent disease and to protect and promote the health and safety of the people of Rhode 

Island. 

Rhode Island Department of Environmental Management - Division of Fish and Wildlife (Rhode Island 

General Laws: Chapters 42-35 regarding importation/possession of native wildlife). The Division of Fish and 

Wildlife protects, restores, and manages the fish and wildlife resources of the state. 

Rabies Control Board of Rhode Island (Rhode Island General Laws: Chapter 4-13). The Rabies Control Board 

adopted rules and regulations pursuant to the authority provided under Rhode Island General Laws 4-13- 1.3 et seq. 

and 42-35 for the purpose of preventing the spread of the contagious disease rabies. 

South Carolina

South Carolina Department of Agriculture (South Carolina Code of Laws: Title 47 - Animals, Livestock and 

Poultry, Chapter 5 - Rabies). The South Carolina Department of Agriculture’s mission is to promote and nurture the 

growth and development of South Carolina's agriculture industry and its related businesses while assuring the safety 

and security of the buying public.

South Carolina Department of Health and Environmental Control (South Carolina Code of Laws: Title 47 - 

Animals, Livestock and Poultry, Chapter 5 - Rabies). The South Carolina Department of Health and 

Environmental Control’s mission is to promote and protect the health of the public and the environment.

Department of Natural Resources (South Carolina Code of Laws: Title 50 - Fish, Game and Watercraft, 

Chapter 11 - Protection of Game, Section 50-11-105 - Wildlife disease control; regulation of wildlife shipments; 

euthanasia). The Wildlife Section within the Department’s Division of Wildlife and Freshwater Fisheries protects, 

manages and enhances the state’s habitats and associated wildlife for the public benefit of present and future 

generations. 

Tennessee

Tennessee Wildlife Resources Agency (Tennessee Code Annotated: Title 70, Chapters 1-8). The Tennessee 

Wildlife Resources Agency is authorized to protect, propagate, increase, preserve, and conserve the wildlife of this 

state, and enforce by proper action and proceedings, the existing laws. 

Tennessee Department of Health (Tennessee Code Annotated: Title 68, Chapter 8). The Tennessee Department 

of Health works to promote, protect, and improve the heath and well-being of the people of Tennessee. It provides 

public health services not available from other sources, such as rabies testing. It also conducts environmental surveys 

in schools and child care facilities and monitors rabies control. 

Tennessee Department of Agriculture (Tennessee Code Annotated: Title 44, Chapters 1-20). The Tennessee 

Department of Agriculture’s mission is to serve the citizens of Tennessee by promoting wise uses of Tennessee’s 

agricultural and forest resources, developing economic opportunities, and ensuring safe and dependable food and 

fiber. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Texas

Texas Department of State Health Services (Texas Administrative Code: Title 25, Part 1, Chapter 169). The 

Texas Department of State Health Services is authorized to conduct programs to address wildlife caused disease 

problems, including the suppression of rabies in wildlife. 

Texas Parks and Wildlife Department (Texas Administrative Code: Title 31, Part 2, Chapters 51-69). The 

Texas Parks and Wildlife Department is authorized to manage and regulate the take of native wildlife and fisheries in 

the state of Texas, including state listed threatened and endangered species.

Vermont

Vermont Department of Health (Vermont Statutes Annotated: Title 18, Chapter 1). The Vermont Department of 

Health is authorized to promote health and safety, and prevent disease. 

Vermont Agency of Agriculture, Food, and Markets (Vermont Statutes Annotated: Title 6, Chapter 102, 

§1152). The Vermont Agency of Agriculture, Food, and Markets may contract and cooperate with the USDA and 

other federal agencies or other states for the control and eradication of contagious diseases of animals. (Vermont 

Statutes Annotated: Title 6; Chapter 102; §1151, “contagious disease” includes rabies). 

Vermont Department of Fish and Wildlife (Vermont Statutes Annotated: Title 10, Chapter 103). The Vermont 

Department of Fish and Wildlife is charged with conservation of fish, wildlife, and plants and their habitats for the 

people of Vermont. 

Virginia

Virginia Department of Health (Code of Virginia: Section 32.1.42). The Virginia Department of Health is 

authorized to control human disease and diseases in wildlife that threaten public health. 

Virginia Department of Game and Inland Fisheries (Code of Virginia: Title 29.1). The Virginia Department of 

Game and Inland Fisheries is authorized to manage Virginia’s wildlife and inland fish to maintain optimum 

populations of all species to serve the needs of the Commonwealth; to provide opportunity for all to enjoy wildlife, 

inland fish, boating, and related outdoor recreation; to promote safety for persons and property in connection with 

boating, hunting, and fishing. 

West Virginia

West Virginia Department of Agriculture (West Virginia Code of State Regulations: Section §19-9-2A). The 

West Virginia Department of Agriculture is charged with prevention, suppression, control, and eradication of any 

communicable disease of animals or poultry. 

West Virginia Department of Health and Human Resources (West Virginia Code of State Regulations: Chapter 

16, Section §16-2-11 (a)(1)(iii)). Chapter 16 of the West Virginia Department of Health and Human Resources 

authorizes the creation of a state public health system, including local boards of health, whose duties include 

“prevention and control of rabies.” 

West Virginia Division of Natural Resources (West Virginia Code of State Regulations: Section §20-2-1). The 

West Virginia Division of Natural Resources is charged with protecting the wildlife resources for the use and 

enjoyment of all the citizens in West Virginia. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

APPENDIX I 

NATIONAL FOREST SYSTEM (NFS) LANDS AND ACREAGE9

WITHIN CURRENT OR POTENTIAL ORV ZONES 

AND 

MAPS OF FORESTS 

FOREST SERVICE REGION 3 – SOUTHWESTERN REGION 

 AZ 

Apache National Forest (1,813,601 NFS acres) 

Coconino National Forest (1,856,038 NFS acres) 

Coronado National Forest (1,786,620 NFS acres) 

Kaibab National Forest (1,560,165 NFS acres) 

Prescott National Forest (1,239,775 NFS acres) 

Sitgreaves national Forest (818,749 NFS acres) 

Tonto National Forest (2,872,769 NFS acres) 

 NM 

Black Kettle National Grassland (31,286 NFS acres) 

Carson National Forest 91,391,674 NFS acres) 

Cibola National Forest (1,631,419 NFS acres) 

Gila National Forest (2,709,005 NFS acres) 

Jemez National Recreation Area (44,670 NFS acres) 

Kiowa National Grassland (136,417 acres) 

Lincoln National Forest (1,103,828 NFS acres) 

McClellan Creek National Grassland 91,449 NFS acres) 

Rita Blanca National Grassland (92,989 NFS acres) 

Santa Fe National Forest (1,566,147 NFS acres) 

FOREST SERVICE REGION 8 – SOUTHERN REGION 

 AL 

Talladega National Forest (389,831 NFS acres) 

Tuskegee National Forest (11,252 NFS acres) 

Conecuh National Forest (83,858 NFS acres) 

William B. Bankhead National Forest (181,033 NFS acres) 

 FL

Ocala National Forest (383,584 NFS acres) 

Apalachicola National Forest (565,585 NFS acres) 

Osceola National Forest (162,157 NFS acres) 

 GA 

Chattahoochee National Forest (748,372 NFS acres) 

Ed Jenkins National Recreation Area (23,166 NFS acres) 

Oconee National Forest (115,225 NFS acres) 

Coosa Bald National Scenic Area (7,100 NFS acres) 

 KY 

Daniel Boone National Forest (557,789 NFS acres) 

 

9 Although entire National Forest System acreage is listed, only portions of each National Forest may be baited, depending on the

needs of the program over time. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Land Between the Lakes National Recreation Area (170,310 NFS acres) 

Jefferson National Forest (720,552 NFS acres) 

 LA 

Kisatchie National Forest (603,393 NFS acres) 

 MS 

Bienville National Forest (178,542 NFS acres) 

Delta National Forest (60,215 NFS acres) 

DeSoto National Forest (517,939 NFS acres) 

Holly Springs National Forest (155,661 NFS acres) 

Homochitto National Forest (191,585 NFS acres) 

Tombigee National Forest (66,874 NFS acres) 

 NC 

Pisgah National Forest (506,785 NFS acres) 

Nantahala National Forest (530,202 NFS acres) 

Croatan National Forest (159,885 NFS acres) 

Uwharrie National Forest (50,174 NFS acres) 

 SC 

Francis Marion-Sumter National Forests (364,598 NFS acres) 

 TN 

Cherokee National Forest (636,125 NFS acres) 

Land Between the Lakes National Recreation Area (170,310 NFS acres) 

 TX 

Angelina National Forest (153,179 NFS acres) 

Davy Crockett National Forest (160,000 NFS acres) 

Sabine national Forest (160,656 NFS acres) 

Sam Houston National Forest (163,037 NFS acres) 

Caddo/LBJ National Grasslands (38,035 NFS acres) 

 VA 

George Washington National Forest (1,065,232 NFS acres) 

Jefferson National Forest (720,552 NFS acres) 

Mount Rogers National Recreation Area (118,509 NFS acres) 

Mount Pleasant National Scenic Area (7,580 NFS acres) 

FOREST SERVICE REGION 9 – EASTERN REGION 

 IN 

Hoosier National Forest (199,291 NFS acres) 

 ME 

White Mountain National Forest (746,581 NFS acres) 

White Mountain National Forest Purchase Unit (34,251 NFS acres) 

 MI 

Hiawatha National Forest (894,652 NFS acres) 

Huron National Forest (437,269 NFS acres) 

Manistee National Forest (538,979 NFS acres) 

Ottawa National Forest (984,290 NFS acres) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Grand Isle National Recreation Area (12,961 NFS acres) 

 NH 

White Mountain National Forest (746,581 NFS acres) 

White Mountain National Forest Purchase Unit (34,251 NFS acres) 

 NY 

Finger Lakes National Forest (16, 211 NFS acres) 

 OH 

Wayne National Forest (232,610 NFS acres) 

Wayne National Forest Purchase Unit (1,027 NFS acres) 

 PA 

Allegheny National Forest (513,139 NFS acres) 

Allegheny National Recreation Area (23,063 NFS acres) 

 VT 

Green Mountain National Forest (384,196 NFS acres) 

Moosalamoo National Recreation Area (15,858 NFS acres) 

White Rocks National Recreation Area (36,400 NFS acres)

 WV 

George Washington National Forest (1,065,232 NFS acres) 

Jefferson National Forest (720,552 NFS acres) 

Monongahela National Forest (897,892 NFS acres) 

Monongahela National Forest Purchase Unit (5,986 NFS acres) 

Spruce Knob-Seneca Rock National Recreation Area (57,237 NFS acres) 

WILDERNESS AREAS WOULD BE EXCLUDED FROM ORV PROGRAM 

WILDERNESS AREAS IN FOREST SERVICE REGION 3 – SOUTHWESTERN REGION 

o AZ 

Apache-Sitgreaves National Forest 

 Bear Wallow (11,080 NFS acres) 

 Blue Range National Primitive Area (173,726 NFS acres) 

 Escudilla (5,200 NFS acres) 

 Mount Baldy (7,079 NFS acres) 

Coconino National Forest 

 Fossil Springs (22,149 NFS acres) 

 Kachina Peaks (18,616 NFS acres) 

 Munds Mountain (24,411 NFS acres) 

 Red Rock-Secret Mountain (47,194 NFS acres)

 Strawberry Crater (10,743 NFS acres) 

 Sycamore Canyon (55,937 

 West Clear Creek (15,238 NFS acres) 

 Wet Beaver (6,155 NFS acres) 

Coronado National Forest 

 Chiricahua (87,700 NFS acres) 

 Galiuro (76,317 NFS acres) 

 Miller Peak (20,228 NFS acres) 

 Mt. Wrightson (25,260 NFS acres) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

 Pajarita (7,553 NFS acres) 

 Pusch Ridge (56,933 NFS acres)

 Rincon Mountain (38,590 NFS acres) 

 Santa Teresa (26,780 NFS acres) 

Kaibab National Forest 

 Kanab Creek (70,460 NFS acres) 

 Kendrick Mountain (6,510 NFS acres) 

 Saddle Mountain (40,539 NFS acres) 

Prescott National Forest 

 Apache Creek (5,666 NFS acres) 

 Castle Creek (25,215 NFS acres) 

 Cedar Bench (14,950 NFS acres) 

 Granite Mountain (9,762 NFS acres) 

 Juniper Mesa (7,406 NFS acres) 

 Pine Mountain (20,061 NFS acres) 

 Woodchute (5,833 NFS acres) 

TontoNational Forest 

 Four Peaks (61,074 NFS acres) 

 Hellsgate (37,440 NFS acres) 

 Mazatzal (252,390 NFS acres) 

 Salome (18,531 NFS acres) 

 Salt River Canyon (32,101 NFS acres) 

 Sierra Ancha (20,850 NFS acres) 

 Superstition (159,757 NFS acres) 

o NM 

Carson National Forest 

 Chama River Canyon (2,900 NFS acres) 

 Dome (18,000 NFS acres) 

 Latir Peak 920,000 NFS acres) 

 Wheeler Peak (18,897 NFS acres) 

Cibola National Forest 

 Apache Kid (44,626) 

 Manzano Mountain (36,875 NFS acres) 

 Sandia Mountain (37877 NFS acres) 

 Withington 919,000 NFS acres) 

Gila National Forest 

 Aldo Leopold (202,016 NFS acres) 

 Blue Range (29,304 NFS acres) 

 Gila (558,014NFS acres) 

Lincoln National Forest 

 Capitol Mountain (34,658 NFS acres) 

 White Mountain (48,266) 

Santa Fe National Forest 

 Cruces Basin (47,400) 

 Pecos (223,333 NFS acres) 

 San Pedro Parks (41,132 NFS acres) 

WILDERNESS AREAS IN FOREST SERVICE REGION 8 – SOUTHERN REGION 

o AL 

Talladega National Forest 

 Cheaha (7,245 NFS acres) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

 Dugger Mountain (9,200 NFS acres) 

William B. Bankhead National Forest 

 Sipsey (24,922 NFS acres) 

o FL 

Apalachicola National Forest 

 Bradwell Bay (24,602 NFS acres) 

 Mud Swamp/New River (8,090 NFS acres) 

Ocala National Forest 

 Alexander Springs (7,941 NFS acres) 

 Billies Bay (3,092 NFS acres) 

 Juniper Prairie (14,277 NFS acres) 

 Little Lake George (2,833 NFS acres) 

Osceola National Forest 

 Big Gum Swamp (13,660 NFS acres) 

o GA 

Chattahoochee National Forest 

 Big Frog (89 NFS acres) 

 Blood Mountain (7,800 NFS acres) 

 Brasstown (12,896 NFS acres) 

 Cohutta (35,268 NFS acres) 

 Ellicott Rock (2,021 NFS acres) 

 Mark Trail (16,400 NFS acres) 

 Raven Cliffs (9,115 NFS acres) 

 Rich Mountain (9,476 NFS acres) 

 Southern Nantahala (11,770 NFS acres) 

 Tray Mountain (9,702 NFS acres) 

o KY 

Daniel Boon National Forest 

 Beaver Creak (4,753 NFS acres) 

 Clifty (12,026 NFS acres) 

o LA 

Kisatchie National Forest 

 Kisatchie Hills (8,679 NFS acres) 

o MS 

DeSoto National Forest 

 Black Creek (5,052 NFS acres) 

 Leaf (994 NFS acres) 

o NC 

Croatan National Forest 

 Catfish Lake South (8,530 NFS acres) 

 Pocosin (11,709 NFS acres) 

 Pond Pine (1,685 NFS acres) 

 Sheep Ridge (9,297 NFS acres) 

Nantahala National Forest 

 Ellicott Rock (3,394 NFS acres) 

 Joyce Kilmer-Slickrock (13,562 NFS acres) 

 Southern Nantahala (11,703 NFS acres) 

Pisgah National Forest 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

 Linville Gorge (11,786 NFS acres) 

 Middle Prong (7,460 NFS acres) 

 Shining Rock (18,483 NFS acres) 

Uwharrie National Forest 

 Birkhead Mountains (5,025 NFS acres) 

o SC 

Francis-Marion National Forest 

 Hell Hole Bay (2,125 NFS acres) 

 Little Wambaw Swamp (5,047 NFS acres) 

 Wambaw Creek (1,825 NFS acres) 

 Wambaw Swamp (4,815 NFS acres) 

Sumter National Forest 

 Ellicott Rock (2,859 NFS acres) 

o TN 

Cherokee National Forest 

 Bald River Gorge (3,721 NFS acres) 

 Big Frog (7,993 NFS acres) 

 Big Laurel Branch (6,332 NFS acres) 

 Citico Creek (16,226 NFS acres) 

 Cohutta (1,709 NFS acres) 

 Gee Creek (2,493 NFS acres) 

 Joyce Kilmer-Slickrock (3,832 NFS acres) 

 Little Frog Mountain (4,666 NFS acres) 

 Pond Mountain (6,890 NFS acres) 

 Sampson Mountain (7,991 NFS acres) 

 Unaka Mountain (4,496 NFS acres) 

o TX 

Angelina National Forest 

 Turkey Hill (5,473 NFS acres)

 Upland Island (13,331 NFS acres)

Davy Crockett National Forest 

 Big Slough (3,455 NFS acres)

Sabine National Forest 

 Indian Mounds (12,369 NFS acres)

Sam Houston National Forest 

 Little Lake Creek (3,855 NFS acres)

o VA 

George Washington National Forest 

 Barbours Creek (4 NFS acres) 

 Priest (5,963 NFS acres) 

 Ramseys Draft (6,518 NFS acres) 

 Rich Hole (6,450 NFS acres) 

 Rough Mountain (9,300 NFS acres) 

 Saint Mary’s (9,835 NFS acres) 

 Shawvers Run (101 NFS acres) 

 Three Ridges (4,608 NFS acres) 

Jefferson National Forest 

 Barbours Creek (5,378 NFS acres) 

 Beartown (5,609 NFS acres) 

 James River Face (8,886 NFS acres) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

 Kimberling Creek (5,542 NFS acres) 

 Lewis Fork (5,618 NFS acres) 

 Little Dry Run (2,858 NFS acres) 

 Little Wilson Creek (3,613 NFS acres) 

 Mountain Lake (8,314 NFS acres) 

 Peters Mountain (3,328 NFS acres) 

 Shawvers Run (3,366 NFS acres) 

 Thunder Ridge (2,344 NFS acres) 

WILDERNESS AREAS IN FOREST SERVICE REGION 9 – EASTERN REGION 

o IN 

Hoosier National Forest 

 Charles C. Deam (12,945 NFS acres) 

o ME 

White Mountain National Forest 

 Caribou-Speckled Mountain (12,000 NFS acres) 

o MI 

Hiawatha National Forest 

 Big Island Lake (5,856 NFS acres) 

 Delirium (11,870 NFS acres) 

 Horseshoe Bay (3,790 NFS acres) 

 Mackinac (12,230 NFS acres) 

 Rock River Canyon (4,640 NFS acres) 

 Round Island (378 NFS acres) 

Ottawa National Forest 

 McCormick (16,850 NFS acres) 

 Sturgeon River Gorge (14,500 NFS acres) 

 Sylvania (18,327 NFS acres) 

Manistee National Forest 

 Nordhouse Dunes (3,450 NFS acres) 

o NH 

White Mountain National Forest 

 Great Gulf (5,552 NFS acres) 

 Pemigewasset (45,000 NFS acres) 

 Presidential Range-Dry River (27,380 NFS acres) 

 Sandwich Range (25,000 NFS acres) 

o PA 

Allegheny National Forest 

 Allegheny Islands (368 NFS acres) 

 Hickory Creek (8,663 NFS acres)

o VT 

Green Mountain National Forest 

 Big Branch (6,720 NFS acres) 

 Breadloaf (21,480 NFS acres) 

 Bristol Cliffs (3,738 NFS acres) 

 George D. Aiken (5,060 NFS acres) 

 Lye Brook (15,503 NFS acres) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

 Peru Peak (6,920 NFS acres) 

o WV 

Monongahela National Forest 

 Cranberry (35,864 NFS acres) 

 Dolly Sods (10,215 NFS acres) 

 Laurel Fork North (6,055 NFS acres) 

 Laurel Fork South (5,997 NFS acres) 

 Otter Creek (20,000 NFS acres) 

Jefferson National Forest 

 Mountain Lake (2,721 NFS acres) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

NATIONAL FOREST MAPS 

GENERAL 

The USFS manages the 193 million acres of the National Forest System in a sustainable manner in 

collaboration with the American public; interested organizations; private landowners; State, local and tribal 

governments; federal agencies; and others. 

Through the Organic Administration Act of June 4, 1897, (chapter 2, 30 Stat. 34-36) Congress authorized 

the creation of what is now the National Forest System “to improve and protect” federal forests. To carry 

out this mission, the USFS has authority “to regulate [the Forests’] occupancy and use and to preserve the 

forests therein from destruction” (16 U.S.C. 551). The Multiple-Use Sustained-Yield Act of 1960 confirms 

USFS authority to manage the national forests and grasslands “for outdoor recreation, range, timber, 

watershed, and wildlife and fish purposes,” (16 U.S.C. § 528). 

Please see the USFS website, http://www.fs.fed.us/, for detailed descriptions of each National Forest listed 

in this appendix. 

FOREST SERVICE SYSTEM LANDS WITHIN POTENTIAL ORAL RABIES VACCINATION 

(ORV) ZONES 

 

 USFS Region 9 within ORV zone USFS Region 8 within ORV zone

USFS Region 3 within potential ORV zone 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

APPENDIX J 

BUREAU OF LAND MANAGEMENT (BLM) LANDS AND ACREAGE10

WITHIN CURRENT OR POTENTIAL ORV ZONES 

AND 

MAPS 

AZ BLM NATIONAL LANDSCAPE CONSERVATION SYSTEM WILDERNESS AREAS 

Aravaipa Canyon Wilderness (19,700 BLM acres) 

Arrastra Mountain Wilderness (129,800 BLM acres) 

Aubrey Peak Wilderness (15,400 BLM acres) 

Baboquivari Peak Wilderness (2,040 BLM acres) 

Beaver Dam Mountains Wilderness (15,000 BLM acres 

Big Horn Mountains Wilderness (21,000 BLM acres 

Cottonwood Point Wilderness (6,860 BLM acres) 

Coyote Mountains Wilderness (5,100 BLM acres) 

Dos Cabezas Mountains Wilderness (11,700 BLM acres) 

Eagletail Mountains Wilderness (97,880 BLM acres) 

East Cactus Plain Wilderness (14,630 BLM acres) 

Fishhooks Wilderness (10,500 BLM acres) 

Gibraltar Mountain Wilderness (18,790 BLM acres) 

Grand Wash Cliffs Wilderness (37,030 BLM acres) 

Harcuvar Mountains Wilderness (25,050 BLM acres) 

Harquahala Mountains Wilderness (22,880 BLM acres) 

Hassayampa River Canyon Wilderness (12,300 BLM acres) 

Hells Canyon Wilderness (9,311 BLM acres) 

Hummingbird Springs Wilderness (31,200 BLM acres) 

Mount Logan Wilderness (14,650 BLM acres) 

Mount Nutt Wilderness (28,080 BLM acres) 

Mount Tipton Wilderness (31,320 BLM acres) 

Mount Trumbull Wilderness (7,880 BLM acres) 

Mount Wilson Wilderness (23,900 BLM acres) 

Muggins Mountain Wilderness (7,711 BLM acres) 

Needle's Eye Wilderness (8,760 BLM acres) 

New Water Mountains Wilderness (24,600 BLM acres) 

North Maricopa Mountains Wilderness (63,200 BLM acres) 

North Santa Teresa Wilderness (5,800 BLM acres) 

Paiute Wilderness (87,900 BLM acres) 

Paria Canyon-Vermilion Cliffs Wilderness (109,400) BLM acres) 

Peloncillo Mountains Wilderness (19,440 BLM acres) 

Rawhide Mountains Wilderness (38,470 BLM acres) 

Redfield Canyon Wilderness 96,600 BLM acres) 

Sierra Estrella Wilderness (14,400 BLM acres) 

Signal Mountain Wilderness (13,350 BLM acres) 

South Maricopa Mountains Wilderness (60,100 BLM acres) 

Swansea Wilderness (16,400 BLM acres) 

Table Top Wilderness (34,400 BLM acres) 

Tres Alamos Wilderness (8,300 BLM acres) 

Trigo Mountain Wilderness (30,300 BLM acres) 

Upper Burro Creek Wilderness (27,440 BLM acres) 

 

10 Although entire BLM acreage is listed, only portions of each BLM areat may be baited, depending on the needs of the program 

over time. 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

Wabayuma Peak Wilderness (38,944 BLM acres) 

Warm Springs Wilderness (112,400 BLM acres) 

White Canyon Wilderness (5,790 BLM acres) 

Woolsey Peak Wilderness (64,000 BLM acres) 

AZ BLM NATIONAL LANDSCAPE CONSERVATION SYSTEM NATIONAL MONUMENTS 

Aqua Fria National Monument (70,900 BLM acres) 

Grand Canyon-Parashant National Monument (808,727 BLM acres) 

Ironwood Forest National Monument (128,398 BLM acres) 

Sonoran Desert National Monument (486,600 BLM acres) 

Vermillion Cliffs National Monument (279,568 BLM acres) 

AZ BLM NATIONAL LANDSCAPE CONSERVATION SYSTEM NATIONAL CONSERVATION 

AREAS 

Gila Box Riparian National Conservation Area (21,767 BLM acres) 

Las Cienegas National Conservation Area (41,972 BLM acres) 

San Pedro Riparian National Conservation Area (55,495 BLM acres) 

NM BLM NATIONAL LANDSCAPE CONSERVATION SYSTEM WILDERNESS AREAS 

Bisti/De-Na-Zin Wilderness (38,381 BLM acres) 

Cebolla Wilderness (61,500 BLM acres) 

Ojito Wilderness (11,183 BLM acres) 

Sabinoso Wilderness (16,030 BLM acres) 

Salt Creek Wilderness (9,621 BLM acres) 

West Malpais Wilderness (39,400 BLM acres) 

NM BLM NATIONAL LANDSCAPE CONSERVATION SYSTEM NATIONAL MONUMENTS 

Kasha-Katuwe Tent Rocks National Monument (4,645 BLM acres) 

NM BLM NATIONAL LANDSCAPE CONSERVATION SYSTEM CONSERVATION AREAS 

El Malpais National Conservation Areas (227,100 BLM acres) 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

GENERAL 

The BLM is responsible for carrying out a variety of programs for the management and conservation of 

resources on 256 million surface acres, as well as 700 million acres of subsurface mineral estate. These 

public lands make up 13 percent of the total land surface of the U.S. and more than 40 percent of all land 

managed by the Federal government. In AZ and NM the BLM manages 12.2 million and 13.4 million 

surface acres respectively. 

The BLM was established in 1946 through the consolidation of General Land Office and the U.S. Grazing 

Service by the US Reorganization Plan No. 3 or 1946 §403. The functions of the BLM are addressed in the 

Federal Land Policy and Management Act of 1976 (FLPM) (40 U.S.C. 1701 et seq.) In FLPMA, Congress 

recognized the value of the remaining public lands by declaring that these lands would remain in the public 

ownership. Further, the FLPM outlines function of the BLM Directorate, provides for the administration of 

public lands through the BLM, provides for the management of the public lands on a multiple-use basis, 

and requires land use planning including public involvement and a continuing inventory of resources. 

For more information regarding the BLM or for detailed information regarding the lands describe in this 

Appendix please visit the BLM website at http://www.blm.gov. 

BUREAU OF LAND MANAGEMENT MAPS WITHIN POTENTIAL ORAL RABIES 

VACCINATION (ORV) ZONES 

 

 Arizona BLM lands New Mexico BLM lands 
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APPENDIX K 

REGIONAL FORESTER SENSITIVE SPECIES 

 REGIONS 3, 8, and 9 

TABLE 1: REGIONAL FORESTER SENSTIVE SPECIES – REGION 3 

National Forest Designations: A-S = Apache-Sitgreaves National Forest (AZ), BK = Black Kettle National Grassland (NM), CAR = Carson 

National Forest (NM), CIB = Cibola National Forest (NM), COC = Coconino National Forest (AZ), COR = Coronado National Forest (AZ), GIL 

= Gila National Forest (NM), KAI = Kaibab National Forest (AZ), KRB = Kiowa/Rita Blanca National Grassland (NM), LIN = Lincoln National 

Forest (NM), PRE = Prescott National Forest (AZ), SFE = Santa Fe National Forest (NM), TON = Tonto National Forest (AZ) 

National Forest Group Scientific Name Common Name G-Rank Candidate 

LIN Amphibians Aneides hardii Sacramento Mountains salamander G3 

SFE Amphibians Plethodon neomexicanus Jemez Mountains salamander G2 

CAR Amphibians Bufo boreas boreas Boreal toad G4 

A-S, COC, PRE, TON, 

GIL 

Amphibians Bufo microscaphus Arizona toad G3/G4 

COR, TON Amphibians Eleutherodactylus augusti 

cactorum 

Western barking frog G4T3 

A-S, COC, COR, GIL, 

PRE, TON 

Amphibians Rana yavapaiensis Lowland leopard frog G4 

COR Amphibians Rana tarahumarae Tarahumara frog G3 

A-S, CAR, COC, KAI, 

SFE, TON 

Amphibians Rana pipiens Northern leopard frog G5 

LIN, CIB Amphibians Rana blairi Plains leopard frog G5 

COR Amphibians Rana subaquavocalis Ramsey Canyon leopard frog G1 

COR Amphibians Gastrophryne olivacea Great Plains narrow-mouthed toad G5 

COC, TON Bird Aechmophorus clarkii Clark’s grebe G5 

ALL Bird Haliaeetus leucocephalus Bald eagle G5 

COR, GIL Bird Phalacrocorax brasilianus Neotropic cormorant G5 

CIB (BK, KRB) Bird Plegadis chihi White-face ibis G5 

A-S, CIB (KRB), LIN, 

TON 

Bird Buteo albonotatus Zone-tailed hawk G4 

A-S, CAR, CIB, COC, 

COR, GIL, KAI, LIN, 

PRE, SFE, TON 

Bird Accipiter gentilis Northern goshawk G5 

COR, GIL, TON Bird Asturina nitida maximus Northern gray hawk G4T4Q 

A-S, COC, COR, GIL, 

PRE, TON 

Bird Buteogallus anthracinus Common black-hawk G4G5 

CIB (KRB, BK), LIN Bird Buteo swainsoni Swainson’s hawk G5 

CIB (KRB), COC Bird Buteo regalis Ferruginous hawk G4 

A-S, CAR, CIB (except 

BK), COC, COR, GIL, 

KAI, LIN, PRE, SFE, 

TON 

Bird Falco peregrinus anatum American peregrine falcon G4T3 

CAR, SFE Bird Lagopus leucurus White-tailed ptarmigan G5 

CIB (KRB, BK) Bird Tympanuchus pallidicinctus Lesser prairie-chicken G3 C 

COR Bird Meleagris gallopavo mexicana Gould’s wild turkey G5T3 

CIB (KRB) Bird Charadrius montanus Mountain plover G2 

CIB, GIL Bird Columbina passerina Common ground dove G5 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

National Forest Group Scientific Name Common Name G-Rank Candidate 

A-S, CAR, CIB (except 

BK), COC, COR, GIL, 

PRE, SFE, TON 

Bird Coccyzus americanus occidentalis Western yellow billed cuckoo G5T3 C 

COR Bird Glaucidium brasilianum cactorum Cactus ferruginous pygmy owl G3 

COR Bird Otus trichopsis Whiskered screech owl G5 

A-S, CAR, CIB (KRB, 

BK), COC, GIL, KAI, 

LIN, SFE 

Bird Athene cunicularia hypugaea Burrowing owl (Western) G4T4 

CAR, SFE Bird Aegolius funereus Boreal owl G5 

COR Bird Caprimulgus ridgwayi Buff-collared nighjar G5 

COR Bird Cynanthus latirostris Broad billed hummingbird G4 

CIB, GIL, COR Bird Hylocharis leucotis White eared hummingbird G5 

COR Bird Amazilia violiceps Violet-crowned hummingbird G5 

COR Bird Calothorax lucifer Lucifer Hummingbird G4G5 

GIL Bird Calypte costae Costa’s Hummingbird G5 

COR Bird Euptilotis neoxenus Eared Quetzal G3 

GIL Bird Melanerpes uropygialis Gila woodpecker G5 

COR Bird Camptostoma imberbe Northern beardless-tyrannulet G5 

COR Bird Empidonax fulvifrons pygmaeus Northern buff breasted flycatcher G5T5 

COR Bird Tyrannus crassirostris Thick-billed kingbird G5 

CIB ( BK, KRB) Bird Lanius ludovicianus Loggerhead shrike G4 

CIB (BK only), GIL, 

LIN 

Bird Vireo bellii arizonae Arizona bell’s vireo G5T4 

CAR, SFE, CIB, GIL, 

LIN 

Bird Vireo vicinior Gray vireo G4 

A-S Bird Dumetella carolinensis Gray catbird G5 

COR Bird Pachyramphus aglaiae Rose-throated becard G4G5 

A-S, COC, COR, PRE, 

TON, GIL, CIB 

Bird Pipilo aberti Abert’s towhee G3G4 

COR Bird Ammodramus savannarum 

ammolegus 

Arizona grasshopper sparrow G5TU 

A-S, CIB (KRB, BK), 

COR, LIN 

Bird Ammodramus bairdii Baird’s sparrow G4 

COR, LIN Bird Passerina versicolor Varied bunting G5 

COR Mammal Sorex arizonae Arizona Shrew G3N2N3 

CAR, SFE Mammal Sorex cinereus cinereus Cinereus (masked) shrew GN5 

A-S, CIB, COC, GIL, 

KAI 

Mammal Sorex merriami leucogenys Merriam’s shrew G5 

A-S, CAR, CIB, COC, 

GIL, KAI, LIN, SFE 

Mammal Sorex nanus Dwarf shrew G4 

CIB, LIN Mammal Sorex neomexicanus New Mexico shrew G2N2N3 

A-S, CAR, SFE Mammal Sorex palustris navigator Water shrew G5 

SFE Mammal Sorex preblei Preble’s shrew G4 

COR Mammal Notiosorex cockrumi Cockrum’s desert shrew GNR 

COR Mammal Choeronycteris mexicana Mexican long-tongued bat G4N2 

COR, TON Mammal Macrotus californicus California leaf-nosed bat G4N3N4 

COR Mammal Lasiurus xanthinus Western yellow bat G5N2 

A-S, COC, COR, GIL, 

KAI, PRE, TON 

Mammal Lasiurus blossevillii Western red bat G5N4 

A-S, CAR, CIB, COC, 

GIL, KAI, LIN, SFE, 

Mammal Euderma maculatum Spotted bat G4N3N4 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

National Forest Group Scientific Name Common Name G-Rank Candidate 

TON 

A-S, CIB, COC, COR, 

GIL, KAI, TON 

Mammal Idionycteris phyllotis Allen’s lappet-browned bat G3G4N3 

A-S, CAR, CIB, COC, 

COR, GIL, KAI, LIN, 

PRE, SFE, TON 

Mammal Corynorhinus townsendii 

pallescens 

Pale Townsend’s big-eared bat GTN4 

COR, PRE, TON Mammal Nyctinomops femorosaccus Pocketed free-tailed bat G4 

A-S, COC, COR, TON Mammal Eumops perotis californicus Greater western mastiff bat G5T4N3 

CAR, SFE Mammal Ochotona princeps Pika GN5 

SFE Mammal Ochotona princeps nigrescens Goat peak pika G5TN1 

CAR, SFE Mammal Lepus americanus Snowshoe hare G5 

COR Mammal Lepus callotis White-sided jack rabbit G3 

CAR Mammal Lepus townsendii campanius White-tailed jack rabbit GN5 

CIB, LIN Mammal Neotamias canipes Gray-footed chipmunk GN3 

A-S Mammal Tamias minimus arizonensis White mountains chipmunk G5T2NR 

LIN Mammal Neotamias minimus atristriatus Penasco least chipmunk G5T1NX 

KAI Mammal Neotamias minimus consobrinus Kaibab least chipmunk G5TNR 

CAR, SFE Mammal Marmota flaviventris Yellow-bellied marmot GN5 

A-S, CIB, GIL, LIN Mammal Spermophilus tridecemlineatus 

monticola 

White mountains ground squirrel G5TN3 

CIB (KRB, BK only) Mammal Cynomys ludovicianus ludovicianus Black-tailed prairie dog G3 

CAR, CIB, SFE, GIL Mammal Cynomys gunnisoni Gunnison’s prairie dog GN5 

KAI Mammal Sciurus aberti kaibabensis Kaibab squirrel G5T3Q 

GIL Mammal Sciurus arizonensis arizonensis Arizona gray squirrel GN4 

COR Mammal Sciurus nayaritensis chiracahuae Chiricahua fox squirrel G3 

LIN Mammal Tamiasciurus hudsonicus 

lychnuchus 

Ruidoso red squirrel G5 

CIB, GIL, SFE Mammal Thomomys bottae aureus Botta’s pocket gopher G5 

COR Mammal Thomomys bottae grahamensis Graham mountains squirrel G5T3Q 

LIN Mammal Thomomys bottae guadalupensis Guadalupe pocket gopher G5TN2 

CIB Mammal Thomomys bottae morulus Botta’s pocket gopher G5 

CIB Mammal Thomomys bottae paguatae Cebolleta southern pocket gopher G5TN2 

CIB Mammal Thomomys bottae planorum Botta’s pocket gopher G5 

KAI Mammal Thomomys talpoides kaibabensis Kaibab northern pocket gopher UNK 

CIB Mammal Thomomys talpoides taylori Mt. Taylor northern pocket gopher UNK 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

National Forest Group Scientific Name Common Name G-Rank Candidate 

COR Mammal Thomomys umbrinus intermedius Huachuca pocket gopher G5TN3 

COR Mammal Thomomys umbrinus quercinus Southern (Pajarito) pocket gopher G5TN3 

LIN Mammal Cratogeomys castanops Yellow-faced pocket gopher GN5 

LIN Mammal Peromyscus pectoralis laceianus White-ankled mouse GN5 

COC Mammal Perognathus amplus cineris Wupatki Arizona pocket mouse G5T2Q 

A-S Mammal Perognathus flavus goodpasteri Springerville silky pocket mouse G5TN3 

KAI Mammal Dipodomys microps leucotis Houserock valley chisel toothed 

kangaroo rat 

G5T2Q 

CIB, SFE Mammal Dipodomys spectabilis clarenci NM Banner tailed kangaroo rat G5TN4 

COR Mammal Reithrodontomys fulvescens Fulvous harvest mouse GN5 

COC, COR, PRE Mammal Reithrodontomys montanus Plains harvest mouse G5 

COR Mammal Peromyscus merriami Mesquite (Merriam’s) mouse G5N2 

COR Mammal Baiomys taylori ater Northern pygmy mouse G4G5N4 

COR, GIL Mammal Sigmodon ochrognathus Yellow-nosed cotton rat G4G5N3

N4 

A-S, CAR, CIB, GIL, 

SFE 

Mammal Clethrionomys gapperi Southern red-backed vole GN5 

CAR, SFE Mammal Phenacomys intermedius 

intermedius 

Western heather vole GN5 

A-S, GIL Mammal Microtus montanus arizonensis Arizona montane vole G3 

A-S, COC, KAI Mammal Microtus mogollonensis navaho Navajo mogollon vole G4TN2Q 

A-S, CAR, CIB, COC, 

COR, GIL, LIN, KAI, 

SFE 

Mammal Microtus longicaudus Long-tailed vole GN5 

COR Mammal Microtus longicaudus leucophaeus White-bellied long-tailed vole G3TN3 

A-S, CAR, LIN, SFE Mammal Zapus hudsonius luteus Meadow (New Mexico) jumping 

mouse 

G3TN2 

TON, COR, GIL Mammal Nasua narica White-nosed coati G5N4 

CAR, SFE Mammal Martes americana origenes American marten GN5 

CAR, SFE Mammal Mustela erminea muricus Ermine GN5 

CAR, SFE Mammal Mustela vison energumenos Mink GN5 

COR, GIL Mammal Mephitis macroura milleri Hooded skunk G5N4 

CIB (KRB only) Mammal Odocoileus virginianus texana Sandhill white-tailed deer G5 

CAR, SFE, CIB, GIL, 

KAI, TON 

Mammal Ovis canadensis canadensis Rocky mountain bighorn sheep G4 

COR, TON Mammal Ovis canadensis mexicana Desert bighorn sheep G3 

COC, TON, COR, GIL Reptile Heloderma suspectum suspectum Reticulate gila monster G4T4 

COR, PRE, TON Reptile Gopherus agassizii (Sonoran 

Population) 

Sonoran desert tortoise G4T4 

COR Reptile Sceloporus slevini Slevin’s bunchgrass lizard G4 

COR Reptile Eumeces callicephalus Mountain skink G5 

COR Reptile Aspidoscelis burti stictogrammus Giant spotted whiptail G4T3 

COR Reptile Senticolis triaspis Green ratsnake G5 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

National Forest Group Scientific Name Common Name G-Rank Candidate 

COR Reptile Oxybelis aeneus Brown vinesnake G5 

COR Reptile Gyalopion quadrangulare Thornscrub hooknosed snake G4 

TON Reptile Phyllorhynchus browni lucidus Maricopa leqaf-nosed snake G5T2 

COR Reptile Tantilla yaquia Yaqui black-headed snake G4 

A-S, COC, COR,TON, 

PRE, GIL 

Reptile Thamnophis eques megalops Mexican garter snake G3T3 

CIB (KRB), LIN Reptile Thamnophis proximus diabolicus Arid land ribbon snake G5 

A-S, COC, GIL, PRE, 

TON 

Reptile Thamnophis rufipunctatus Narrow-headed garter snake G3G4 

LIN Reptile Crotalus lepidus lepidus Mottled rock rattlesnake G5T4T5 

COR Reptile Crotalus pricei Twin spotted rattlesnake G5 

COR Reptile Crotalus willardi willardi Arizona ridge-nosed rattlesnake G5T3 

TABLE 2: REGIONAL FORESTER SENSITIVE SPECIES – REGION 8 

National Forest Desigations: 1 = Alabama National Forests, 2 = Daniel Boone National Forest (KY), 3 = Chattahoochee National Forest (GA), 4 = 

Cherokee National Forest (TN), 5 = Florida National Forests, 6 = Kisatchie National Forest (LA), 7 = Mississippi National Forests, 8 = George 

Washington/Jefferson National Forests (VA, KY), 11 = North Carolina National Forests, 12 = Sumter National Forest (SC), 13 TX National Forests, 

17 = Land Between the Lakes National Forest (KY, TN)

National Forest Group Scientific Name Common Name G-Rank Candidate 

5 Amphibian Amphiuma pholeter One-toed amphiuma G3 

5 Amphibian Desmognathus apalachicolae Apalachicola dusky salamander G3 

4 Amphibian Desmognathus caroliniensis Carolina Mountain Dusky 

Salamander 

G2 

4,11 Amphibian Desmognathus santeetlah Santeetlah dusky salamander G3Q 

16 Amphibian Eleutherodactylus eneidae Coqui, mottled G1 

16 Amphibian Eleutherodactylus gryllus a coqui G2 

16 Amphibian 'Eleutherodactylus hedricki a coqui G2 

16 Amphibian 'Eleutherodactylus hedricki Coqui, web-footed G1 

16 Amphibian 'Eleutherodactylus locustus Coqui, Martilitto G3 

16 Amphibian Eleutherodactylus richmondi Coqui, Caoba G3 

16 Amphibian 'Eleutherodactylus unicolor Coqui, Burrow G1 

4,11 Amphibian Eurycea junaluska Junaluska salamander G3Q 

10 Amphibian Eurycea tynerensis Oklahoma salamander G3 C 

1 Amphibian Necturus alabamensis Black Warrior waterdog G2 

11 Amphibian Necturus lewisi Neuse River waterdog G3 

5 Amphibian Notophthalmus perstriatus Striped newt G2G3 

4,11 Amphibian Plethodon aureolus Tellico salamander G2G3Q 

9 Amphibian Plethodon caddoensis Caddo Mountain salamander G2 

9 Amphibian Plethodon fourchensis Fourche Mountain salamander G2 

8 Amphibian Plethodon hubrichti Peaks of Otter salamander G2 

9 Amphibian Plethodon kiamichi Kiamichi slimy salamander G2Q 

6 Amphibian Plethodon kisatchie Louisiana slimy salamander G3Q 

9 Amphibian Plethodon ouachitae Rich Mountain salamander G2, G3 
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Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

National Forest Group Scientific Name Common Name G-Rank Candidate 

8 Amphibian Plethodon punctatus Cow Knob salamander G3 

9 Amphibian Plethodon sequoyah Sequoyah slimy salamander G2Q 

3,4,11 Amphibian Plethodon teyahalee Southern Appalachian salamander G2G3Q 

7,12 Amphibian Plethodon websteri Webster's salamander G3 

4,8,11 Amphibian Plethodon welleri Weller's salamander G3 

1,11,12 Amphibian Rana capito capito Carolina gopher frog G3G4T3 

1,2,3,5,6,7,9,10,11,12,1

3 

Bird Aimophila aestivalis Bachman's sparrow G3 

16 Bird 'Dendroica angelae Warbler, Elfin woods G1 C 

1,3,4,8,9,11 Bird Falco peregrinus Peregrine Falcon G4 

5 Bird Grus canadensis pratensis Florida sandhill crane G5T2T3 

3,4,8,11,12,13 Bird Lanius ludovicianus migrans Migrant loggerhead shrike G4T3Q 

2,8,11 Bird Thryomanes bewickii altus Appalachian Bewick's wren G5T2Q 

1,2,3,4,5,7,11,12,13,17 Mammal Corynorhinus rafinesquii Rafinesque's big-eared bat G3G4 

4,8,11 Mammal Microtus chrotorrhinus carolinensis Southern rock vole G4T3 

1,2,9,12,17 Mammal Myotis austroriparius Southeastern myotis G3G4 

2,3,4,8,9,10,11,12 Mammal Myotis leibii Eastern small-footed bat G3 

5 Mammal Neofiber alleni Round-tailed muskrat G3 

5 Mammal Podomys floridanus Florida mouse G3 

5 Mammal Sciurus niger shermani Sherman's fox squirrel G5T2 

2 Mammal Sorex dispar blitchi Long-tailed shrew G4T3 

3,4,8,11 Mammal Sorex palustris puntculatus Southern water shrew G5T3 

16 Mammal 'Stenoderma rufum Bat, Desmarest's fig-eating GU 

1,5 Mammal Ursus americanus floridanus Florida black bear G5T2 

3,4 Reptile Clemmys muhlenbergi Bog turtle G3 

1,5 Reptile Gopherus polyphemus Gopher tortoise G3 

1 Reptile Graptemys ernsti Escambia map turtle G2 

5 Reptile Lampropeltis getula goini Apalachicola kingsnake G5T2 

11 Reptile Nerodia sipedon williamengelsi Carolina salt marsh snake G5T3 

1,11 Reptile Ophisaurus mimicus Mimic glass lizard G3 

7 Reptile Pithuophis melanoleucus lodingi Black pine snake G4T3 C 

1,5 Reptile Pituophis melanoleucus mugitus Florida pine snake G5T3 

6, 13 Reptile Pituophis melanoleucus ruthveni Louisiana pinesnake G4T3 C 

5 Reptile Pseudemys concinna suwanniensis Suwannee cooter G5T3 

5 Reptile Sceloporus woodi Florida scrub lizard G3 

5 Reptile Stilosoma extenuatum Short-tailed snake G3 

TABLE 3: REGIONAL FORESTER SENSITIVE SPECIES – REGION 9 

1 = Allegheny National Forest (PA), 2 = Finger Lakes National Forest (NY), 3 = Hiawatha National Forest (MI), 4 = Hoosier National Forest (IN), 5 = 

Huron-Manistee National Forests (MI),6 = Monongahela National Forest (WV), 7 = Ottawa National Forest (MI), 8 = Wayne national Forest (OH), 9 

= White Mountain National Forest (NH, ME) 

National Forest Group Scientific Name Common Name G-Rank Candidate 

4, 6, 8 Amphibians Aneides aeneus Green salamander G3G4 

4, 5, 7, 8 Amphibians Hemidactylium scutatum Four-toed salamander G5 

6, 8 Amphibians Cryptobranchus alleganiensis Hellbender G3G4 

8 Amphibians Acris crepitans blanchardi Northern cricket frog G5 

8 Amphibians Psuedotriton montanus Mud salamander G5 
K-7 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

National Forest Group Scientific Name Common Name G-Rank Candidate 

1, 2, 3, 5, 6, 7 Bird Accipiter gentilis Northern goshawk G5 

2,4, 5, 6, 8 Bird Ammodramus henslowii Henslow’s sparrow G4 

2 Bird Bartaramia longicauda Upland sandpiper G5 

2, 5 Bird Circus cyaneus Northern harrier G5 

1 Bird Empidonax flaviventris Yellow-bellied flycatcher G5 

1, 3, 4, 5, 6, 7, 8 Bird Haliaeetus leucocephalus Bald eagle G5 

1, 5, 9 Bird Pandion haliaetus Osprey G5 

3 Bird Ammodramus leconteli Le Conte’s sparrow G4 

3, 5 Bird Asio Flammeus Short-eared owl G5 

3, 5, 7 Bird Buteo lineatus Red-shouldered hawk G5 

3, 5, 7 Bird Chilidonias niger Black tern G4 

3, 5 Bird Coturnicops noveboracensis Yellow rail G4 

3, 5, 7 Bird Cynus buccinator Trumpeter swan G4 

3, 5 Bird Dendroica discolor Prairie warbler G5 

3, 6, 7, 9 Bird Flaco peregrines anatum American peregrine falcon G4T3 

3, 5, 7, 9 Bird Gavia immer Common loon G5 

3, 4, 5, 6 Bird Lanius ludovicianus migrans Migrant loggerhead shrike G4T3Q 

3, 5 Bird Nycticorax nycticorax Black-crowned night heron G5 

3, 5, 7 Bird Oporornis agillis Connecticut warbler G4 

3, 5, 7 Bird Picoides arcticus Black-backed woodpecker G5 

3 Bird Sterna caspia Caspian tern G5 

3 Bird Sterna hirundo Common tern G5 

3, 5 Bird Tympanuchus phasianellus Sharp-tailed grouse G4 

4 Bird Bonasa umbellus Ruffed grouse G5 

4, 5, 8 Bird Dendroica cerulea Cerulean warbler G4 

4, 5 Bird Dolichonyx oryzivorus Bobolink G5 

4 Bird Scolopax minor American woodcock G5 

4 Bird Tyto alba Barn owl G5 

5 Bird Ammodramus savannarum Grasshopper sparrow G5 

5 Bird Asio otus Long-eared owl G5 

5 Bird Botaurus lentigiinosus American bittern G4 

5 Bird Caprimulgus vociferus Whip-poor-will G5 

5, 6 Bird Contopus cooperi Olive-sided flycatcher G5 

5, 7 Bird Falcipennis canadensis Spruce grouse G5 

5 Bird Flaco columbarius Merlin G5 

5 Bird Ixobrychus exilis Least bittern G5 

5, 6 Bird Melanerpes erythrocephalus Red-headed woodpecker G5 

5 Bird Rallus elegans King rail G4G5 

5 Bird Seiurus motacilla Louisiana waterthrush G5 

5, 6 Bird Vermivora chysoptera Golden-winged warbler G4 

6 Bird Pooecetes gramineus Vesper sparrow G5 

9 Bird Catharus bicknelli Bicknell’s thrush G4 

9 Bird Podilymbus podiceps Pied-billed grebe G5 

2, 6, 9 Mammal Myotis leibii Eastern small-footed bat G3 

1 Mammal Glaucomys sabrinus Northern flying squirrel G5T2 

3, 7 Mammal Canis lupus Gray (timber) wolf G4 

4 Mammal Lutra canadensis River otter G5 

4, 8 Mammal Lynx rufus Bobcat G5 

4, 6 Mammal Neotoma magister Allegheny woodrat G3G4 

4 Mammal Nycticeius humeralis Evening bat G5 

4 Mammal Taxidea taxu American Badger G5 

5 Mammal Martes americana American marten G5 

5, 7 Mammal Pipistrrrellus subflavus Eastern pipistrelle G5 

6 Mammal Microtus chrotorrhinus 

carolinensis 

Southern rock vole G4T3 

6 Mammal Sorex palustris punctulatus Southern water shrew G5T3 

6 Mammal Spilogale putorius Eastern spotted skunk 

8 Mammal Ursus americanus Black bear G5 

9 Mammal Synaptomys borealis sphagnicola Northern bog lemming G4T3Q 

2 Reptile Lasmigonia subviridis Bog turtle G3 

1, 5, 6, 7, 9 Reptile Clemmys insculpta (Glyptemys) Wood turtle G4 

1, 4, 6, 8 Reptile Crotalus horridus Timber rattlesnake G4 

3, 5 Reptile Emydoooooidea blandingii Blanding’s turtle G4 

4 Reptile Clonophis kirtlandii Kirtland’s snake G2 
K-8 

Environmental Assessment of Oral Vaccination to Control Specific Rabies Virus Variants

National Forest Group Scientific Name Common Name G-Rank Candidate 

5 Reptile Hemidactylium scutatum Spotted turtle G5 

5 Reptile Sistrurus catenatus catenatus Eastern massasauga G3G4T3T4 

5 Reptile Terrapene carolin carolin Easertn box turtle G5T5