David W Reynolds To: Brian Eick/APCO/NPS@NPS, Timbo Sims/BOWA/NPS@NPS, Charles na/ufi/?nn? 03-68 PM Rafkind/COLO/NPS@NPS, Patrick Lynch/DEWA/NPS@NPS, Paul uo/uo/zuuz UJ.OO KM Bitzel/HAMP/NPS@NPS, Connie Ranson/FONE/NPS@NPS, Gregg E D T Kneipp/FRSP/NPS@NPS, Rijk Morawe/GEWA/NPS@NPS, Doris

Fanelli/INDE/NPS@NPS, Ken Stephens/NERI/NPS@NPS, Dave Shockley/PETE/NPS@NPS, Ella Rayburn/STEA/NPS@NPS, Michael Reuber/UPDE/NPS@NPS, Brian LambertA/AFO/NPS@NPS, Carl Zimmerman/ASIS/NPS@NPS, Nancy Smith/ALPO/NPS@NPS, Kathy Penrod/ALPO/NPS@NPS, Deborah Darden/GETT/NPS@NPS, Steven Ambrose/HOFU/NPS@NPS, Kristen Allen/RICH/NPS@NPS, Gordon Olson/SHEN/NPS@NPS

cc: Subject: Oral Rabies Vaccination EA

Bob Mcintosh wanted park natural resource managers to be aware of this memo. Margaret Wild in the Biological Resources Division would be the person to talk with if you have questions.

Dave -— Forwarded by David W Reynolds/PHILADELPHIA/NPS on 08/06/2002 04:04 PM

Bob Mcintosh To: NER Leadership Council, NER Superintendents (by name), John 08/02/2002 0339 PM Karish/PHILADELPHIA/NPS@NPS, Mary Foley/Boston/NPS@NPS, E D T David WReynolds/PHILADELPHIA/NPS@NPS

cc: Subject: Oral Rabies Vaccination EA

fyi

mary/dave: please distribute to park resource managers, thaks

-— Forwarded by Bob Mclntosh/Boston/NPS on 08/02/02 03:41 PM -—

rm^rnrrrrrrT Margaret Wild To: Bob Mclntosh/Boston/NPS@NPS, John Yancy/Atlanta/NPS@NPS, Jim

JPt, 08/02/02 01:10 PM MDT Sherald/NCR/NPS@NPS 4 VC 5 / CC: S k i p L a d d / D E N V E R / N P S @ N P S , Gary Johnston/WASO/NPS@NPS * f * Subject: Oral Rabies Vaccination EA

This memo is to give you a "heads up" that David Reinhold from USDA Wildlife Services may be contacting you regarding environmental compliance for use of oral rabies vaccination (ORV) in NPS units in your region.

USDA Wildlife Services is beginning to address environmental compliance for proposed oral rabies vaccination programs in units of the NPS. Their highest priority at this point is for the western Texas parks. However, in talking with them, I reminded them that if ORV was proposed in NPS units in the eastern US for raccoon rabies control, that they'd need to be talking to others of you (in addition to Skip).

One difficulty is that we don't know exactly where intended ORV programs will be; however, I'm quite certain that New River Gorge NR may be one that will need to be considered. Additionally, I understand that USDA Wildlife Services is expanding their programmatic EA to an area that may include Great Smoky Mountains NP.

I've attached the original information material that went out last winter so that it is more easily accessible for you. Please let me know if you have any questions or need assistance.

Thanks, Margaret

******************************************** Margaret A. Wild, DVM, PhD Wildlife Veterinarian Biological Resource Management Division National Park Service 1201 Oak Ridge Dr., Suite 200 Fort Collins, CO 80525 Phone: (970) 225-3593 Fax: (970)225-3585 — Forwarded by Margaret Wild/FTCOLLINS/NPS on 08/02/02 12:54 PM -—

Craig Axtell To: Skip Ladd/DENVER/NPS@NPS, Bob Mclntosh/Boston/NPS@NPS, 02/21/02 1T12AM Gary Vequist/Omaha/NPS@NPS, John Yancy/Atlanta/NPS@NPS, Jim

Sherald/NCR/NPS@NPS cc: Gary Johnston/WASO/NPS@NPS, Margaret

Wild/FTCOLLINS/NPS@NPS, John Hanley/PARTNER/NPS@NPS, Joseph Winkelmaier/SANTAFE/NPS@NPS

Subject: Oral Rabies Vaccination Program

Good day,

I wanted to pass on to you a memo recently signed by the Director to your Regional Directors and Superintendents that is heading your way regarding the vaccination of wildlife with oral rabies vaccine. It is attached as a .pdf file. You may recall that I sent out an email to you in late July of last year, outlining the emerging issue. This note, and the Director's memo is a follow-up to that email.

To become further educated on the issue, to learn to goals of the other agencies, and to help develop the NPS response to those agencies, we have had a number of monthly calls with the Animal and Plant Health Inspection Service, Centers for Disease Control, and the State of Texas Public Health Department. With this information and advice from the NPS Public Health Program we developed a strategy to respond to the issue. Margaret Wild, our Wildlife Veterinarian, Gary Johnston, John Hanley of the NPS Public Health Program, and I briefed Mike Soukup on the issue and he concurred with our recommendation which is contained in the Director's memo. I have attached a 1-page briefing statement for you. However, there are a number of other documents that you may find useful, let us know if you want them and we can send them to you. They are:

• Expanded (5 page) Briefing Statement; contains significantly more detail on issue

• Discussion Paper prepared by Bruce Connery (ACAD) and Margaret Wild on Rabies and Rabies Control as related to the NPS

• Memo from NPS Public Health Service in response to questions posed by BRMD on aspects of rabies and public health

• Environmental Assessment and FONSI prepared by the Animal and Plant Health Inspection Service

Skip, we are aware that the State of Texas would like to distribute the vaccine in Texas parks this year, so your region is likely to be engaged first. Also, for your information, you may want to talk with Joe Winkelmaier, NPS Public Health Consultant located in Sante Fe (IMR-SSO) who prepared the Memo for the PHS noted above and is quite familiar with the issue.

Gary V., we are not sure, but some Midwest parks are likely to be involved next because of APHIS goals to create a barrier to the spread of raccoon rabies to the west. If we hear more, we will let you know.

Lastly, if you have questions on the issue or require some technical input, please let Margaret or I know.

Craig

oral rabies letter.

rabies 1 pager new.d

******************************************

Craig C. Axtell Chief, Division of Biological Resource Management Natural Resource Program Center National Park Service 1201 Oakridge Drive, Suite 200 Fort Collins, Colorado 80525 Phone: 970--225-3591 Fax: 970-225-3585

Wayne Millington To: Al Farrugio/STLI/NPS@NPS, Brian Eick/APCO/NPS@NPS, Brian 03/14/2002 08-13 AM Lambert/VAFO/NPS@NPS, Bruce Jacobson/BOHA/NPS@NPS, Carl U4/I4/4UU4 u». IJ A M Salmons-Perez/SAIR/NPS@NPS, Carl Zimmerman/ASIS/NPS@NPS,

S T Charles Rafkind/COLO/NPS@NPS, Charles Smith at NP-INDE@NPS_CCMAIL@NPS, EDIS Maintenance@NPS, Cindy Calvert/LOWE/NPS@NPS, Connie Ranson@NPS, Dave Hayes at NP-NAR@NPS_CCMAIL@NPS, Don Hamilton at NP-UPDE@NPS_CCMAIL@NPS, Dorothy Geyer/COLO/NPS@NPS, Emo Dewitt at NP-FRLA@NPS_CCMAIL@NPS, Ernest Taylor/FIIS/NPS@NPS, Fred Dell Angelo/VAFO/NPS@NPS, Gene Gabriel/ADAM/NPS@NPS, George Frame/GATE/NPS@NPS, Greg Waters@NPS, Gregg Kneipp/FRSP/NPS@NPS, Jack Veazy at NP-FOST@NPS_CCMAIL@NPS, James Akerson/SHEN/NPS@NPS, Janet Wise@NPS, Jason Thomas/GATE/NPS@NPS, John Bilski/STEA/NPS@NPS, John Perez/NERI/NPS@NPS, Judy Hazen Connery@NPS, Kim Murray/MABI/NPS@NPS, Larry Hilaire/DEWA/NPS@NPS, Marcy Beitel/BOST/NPS@NPS, Albert Atchison@NPS, Michael Bilecki/FIIS/NPS@NPS, Michael Byer/GATE/NPS@NPS, Michael Parr/SAMA/NPS@NPS, Nancy Finley/CACO/NPS@NPS, Paul Bitzel/HAMP/NPS@NPS, Randy Krichten/GETT/NPS@NPS, Richard Spotts/FIIS/NPS@NPS, Rijk Morawe/GEWA/NPS@NPS, Robert Masson/MORR/NPS@NPS, Scott Gurney/SAHI/NPS@NPS, Steve

Walasewicz/SAGA/NPS@NPS, Sue Andrews/ROWI/NPS@NPS, Tim Blumenschine/PETE/NPS@NPS, Timbo Sims/BOWA/NPS@NPS, WORI Superintendent, Christopher Davis/MIMA/NPS@NPS, Kristen Allen/RICH/NPS@NPS, Bert Frost/GETT/NPS@NPS, Patrick Lynch/DEWA/NPS@NPS, Gary Somers/SHEN/NPS@NPS, Tom C Nash/COLO/NPS@NPS

cc: Bruce Connery@NPS Subject: Re: Oral Rabies Vaccination Program

Attached are t w o documents and a note concerning a proposed action to manage rabies in wild animal populations. As you read, you will see that the project will be managed by the Wildlife Services group of APHIS. I know that rabies is more an issue for some of your park units, but it would be great if each of you could take ten minutes to read the attached information. The attachments should be helpful for basic information on rabies and for the NPS point-of-view on the subject. If you have any questions concerning this project, feel free to give me a call at 814-863-8352.

Thanks,

Wayne

Forwarded by Wayne Millington/PHILADELPHIA/NPS on 03/14/2002 07:56 AM —-

a * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *

* * * *

Bob Mcintosh

Craig Axtell To: Skip Ladd/DENVER/NPS@NPS, Bob Mclntosh/Boston/NPS@NPS, Gary Vequist/Omaha/NPS@NPS, John Yancy/Atlanta/NPS@NPS,

United States Department of the Interior

MUFLYUIUTO:

NATIONAL PARK SERVICE 1849 C Street, N.W.

WWhlnpon,D.C 20240

FEB 2 0 2002 N 16<2340)

Memorandum

To: Regional Directors and Superintendents in Northeast, National Capital, Southeast, Midwest, and Intcrmountain Regions

From: . Director ^ /> / W j ^

Subject: Proposed oral vaccination of certain wildlife species in units of the National Park System with an oral rabies vaccine

Parks in your region may have been, or may soon be, approached by USDA Animal and Plant Health Inspection Service-Wildlife Services (APHIS-WS) or state public health departments to participate in an effort to control the spread of rabies in raccoons, coyotes or gray foxes through the use of an orally administered vaccine. I ask each park or group of parks so approached to constructively engage in discussions with APHIS-WS and states regarding the extent of proposed actions and aspects of park resource management needs that may influence NPS participation. Prior to undertaking any actions within the parks environmental planning documents, including NEPA and Section 7 consultation with the US Fish and Wildlife Service, will need to be prepared. APHIS-WS has offered to assist with lie preparation of these documents.

This environmental compliance will tier off of a programmatic environmental assessment prepared by APHIS-WS. AFONS1 was issued on that EA on July 30,2001. The preferred method for rabies control is to distribute via air or on the ground a genetically engineered recombinant vaccine packaged in bait specially formulated for the target species. This oral vaccine is effective in raccoon, coyote, and fox and has been tested for safety in more than 50 vertebrate species.

Use of an oral rabies vaccine is consistent with NPS policy to control exotic organisms. Rabies is clearly an exotic disease in raccoons in the eastern United States, except Florida, and coyote in Texas. Scientific information is inconclusive on the native vs. exotic status cf raccoon rabies in Florida and gray fox rabies in Texas; however, experts believe that these outbreaks would not have occurred without post-Columbian human intervention.

Further, rabies is considered a serious public health problem by the Centers for Disease Control and Prevention (CDC). The NPS Public Health Program concurs with the CDC

assessment that rabies is a significant public health risk and suggests that every reasonable effort should be made to control the disease.

The BiologicaJ Resource Management Division and the NPS Public Health Program are engaged in discussions with APHIS-WS, CDC, and the state of Texas regarding potential NPS participation in oral rabies vaccination programs. If you have questions or need more irdbrmaiion please contact Dr. Margaret Wild, NPS Wildlife Veterinarian, in the Biological Resource Management Division at 970-225-3593,

Briefing Statement February 2002

BUREAU: National Park Service, Associate Director, Natural Resource Stewardship and Science

TITLE: Proposed vaccination of wildlife in units of the National Park System with an oral rabies vaccine (ORV)

BACKGROUND: Rabies:

o Rabies is a viral disease of warm-blooded animals including humans, and is fatal in humans if left untreated. Rabies is categorized into variants that occur primarily in given host (reservoir) species but that affect other exposed species as well. In the United States, specific rabies virus variants have been identified in raccoons, coyote, fox, skunk, and bats.

o There is no documentation of rabies occurring in the lower 48 states of the United States prior to European presence; the first documentation was in dogs brought from Europe in the 1700s.

o Raccoon rabies variant was first identified in Florida in the late 1940s and has an unknown origin. Translocations of infected raccoons from Florida to the mid-Atlantic region during the late 1970s resulted in additional outbreaks. Raccoon rabies now occurs from Maine to Florida and west to Alabama and West Virginia.

o In southern Texas, the rabies outbreak in coyotes is due to a domestic dog variant that invaded from Mexico. The origin of the gray fox variant in western Texas is unknown; however, the variant is similar to the dog-coyote variant.

o Rabies is clearly an exotic disease in raccoons in the eastern United States, except Florida, and coyote in Texas. Scientific information is inconclusive on the native vs. exotic status of raccoon rabies in Florida and gray fox rabies in Texas. However, experts at the Centers for Disease Control and Prevention (CDC) suggest that these two rabies virus variants would not have occurred without post-Columbian intervention by humans (e.g., animal and disease translocations, habitat fragmentation and modification, landscape alternations).

o The impact of this exotic virus on native wildlife is difficult to determine. In 1999, 6466 wildlife deaths from rabies were reported to the CDC; however, many rabid animals are never observed or go untested.

o In the United States, 32 rabies-related human deaths were reported between 1990-2000. Only two of these were attributed to terrestrial rabies acquired within the United States. However, an estimated 40,000 people per year receive post­exposure prophylaxis after exposure to a potentially rabid animal (most commonly raccoons).

o In a letter to the USDA Animal and Plant Health Inspection Service (APHIS) Wildlife Services (dated 29 May 2001), CDC states that "rabies is a serious public health problem" and that "rabies can be managed safely and effectively with the strategic use of oral rabies vaccination".

1

o The National Park Service (NPS) Public Health Program concurs with the CDC assessment that rabies is a significant public health threat and that every reasonable effort should be made to control the disease.

Oral Rabies Vaccination: o Oral rabies vaccination (ORV) has been used in Europe, Canada, and the United

States to control rabies in fox, coyote, and raccoons. In the United States, the genetically engineered recombinant vaccinia-rabies glycoprotein (Raboral V-RG) is licensed for use in raccoons and approved for experimental use in gray fox and coyotes in Texas. The vaccine is not effective in skunks or bats.

o Raboral V-RG rabies vaccine has been tested and shown to be safe in >50 vertebrate species.

o The vaccine is packaged with bait and distributed by air or ground application. o Since 1990, several state and county health departments have initiated ORV

efforts to manage raccoon rabies. In 1994, Governor Ann Richards declared a public health emergency in Texas that resulted in ORV efforts for coyote and gray fox rabies outbreaks.

o In November 2000, Secretary of Agriculture Dan Glickman declared an emergency regarding the spread of rabies in the United States. Since that declaration, USDA APHIS Wildlife Services has expanded its role with affected states in ORV efforts. In FY2002, Congress appropriated about $16 million to APHIS to support states ORV efforts.

o The immediate goal of the rabies control efforts is to stop westward expansion of the raccoon rabies outbreak and stop further expansion of the coyote and gray fox rabies outbreaks in Texas. To do this, USDA APHIS Wildlife Services proposes to use ORV in a barrier from New Hampshire to Alabama to limit the raccoon outbreak and in concentric rings around the outbreaks in Texas. Subsequently, ORV control or eradication efforts would proceed within the area of the ORV barrier.

Oral Rabies Vaccination and the NPS: o Units of the NPS have been, or will likely be, requested by USDA APHIS

Wildlife Services and states to participate in the expanded ORV efforts for raccoons in the eastern United States and coyotes and gray fox in Texas. If NPS units do not participate in ORV efforts, the areas may serve as reservoirs of rabies and a source of re-infection for animals on adjacent lands. The NPS Public Health Program advises that a lack of cooperation among all land managers in an area targeted for an ORV effort may be a significant factor in the ultimate failure to control or eradicate the disease.

o In July 2001, a finding of no significant impact was issued on a programmatic environmental assessment (EA) for ORV prepared by USDA APHIS Wildlife Services. The EA did not cover a number of significant questions and issues that would need to be addressed before ORV could be applied in NPS units. Therefore, additional NEPA compliance will be required for parks (or clusters of parks with similar issues). Topics for additional coverage in park EAs include: origin of virus variants, park purpose, site-specific ORV objectives and protocols, monitoring programs, effects on visitor use, concerns for special sites and species of special interest, mitigating measures, implications of "no action" alternative,

2

and omission of lethal take as a considered alternative. Additional consultation under Section 7 of the Endangered Species Act will be required as well.

NPS POLICY: o The exotic species status of the raccoon rabies variant outside of Florida and the

dog-coyote variant in southern Texas has been well documented. Scientific data are inconclusive regarding the origin, and therefore native vs. exotic status, of raccoon rabies in Florida and gray fox rabies in Texas. However, based on best available information, experts at the CDC report that without post-Columbian intervention by humans these variants would not have arisen to cause the observed outbreaks. Therefore, it is the determination of the NPS Biological Resource Management Division that for discussions regarding ORV, rabies variants in raccoons throughout the eastern United States, and coyote and gray fox in Texas be considered exotic viruses. Thus, NPS Management Policies to control this exotic virus in native wildlife species apply.

o Management Policy sec. 4.4.4.2 states that exotic species will be managed if control is prudent and feasible and if the exotic species poses a public health hazard. The NPS Public Health Program advises that rabies poses a significant public health concern anytime it is encountered and that every reasonable effort should be made to control the disease. Previous experience by European, Canadian, and American public health experts suggest that ORV efforts are feasible in NPS units.

o Management Policy sec. 4.4.4.1 allows for the introduction of an exotic species (Raboral V-RG vaccine, which is a genetically engineered vaccinia virus) in rare situations to control another already established exotic species (rabies).

o The proposed action will trigger preparation of additional NEPA compliance as well as Section 7 consultation.

ANALYSIS: o The proposed action may:

• Eliminate rabies in gray fox and coyote in Texas and control or eliminate rabies in raccoons in the eastern United States.

• Lead to multiple years of ORV application to achieve desired goals in some areas.

• Improve relationships with adjacent land owners and public health and wildlife officials supportive of ORV. The NPS Public Health Program advises that rabies cannot be eliminated if NPS units harbor unvaccinated reservoir species.

• Require the parks to continue visitor education programs regarding the potential presence of rabies in the park and measures to control it.

• Require closure or limited use of parks for short periods during treatment periods.

• Although data are limited and in some cases contradictory, result in changes to population size of target and non-target species. Regardless if changes occurred, population sizes in the absence of an exotic species would be considered more natural. However, if population increases in ORV target

3

species lead to more nuisance animals or resultant impact, either directly or indirectly, on other species including federally listed species, then other management activities may be required

• In extremely rare instances, human exposure to the V-RG vaccine may cause a localized skin lesion (one case has been documented in an immune-compromised woman). NPS Public Health Program advises that this is a minimal threat; however, they would remain cautious in cases of possible human contact with vaccine. An extremely remote chance also exists that the vaccinia virus of the V-RG vaccine will recombine with a native pox virus to create a new virus. CDC has reviewed this potential and determined it to be extremely unlikely (<1 in 100 million).

o USDA APHIS Wildlife Services has informally offered resources to perform additional NEPA/Section 7 compliance. This would not negate the need for park staff to be involved in assistance and in park-specific details of the EA and Section 7 process.

o ORV efforts are more likely to succeed if rigorous evaluation of the proposed application plan is performed prior to implementation and if non-lethal surveillance activities are used to assess efficacy of the treatment program. Collaboration with CDC experts and potentially other researchers would be required to plan and evaluate ORV efforts in NPS units.

o NPS units that have been, or in the near term may be, approached by USDA APHIS Wildlife Services and states to initiate ORV efforts include: Palo Alto Battlefield NHS, Padre Island NS, Big Bend NP, Amistad NRA (all of these Texas parks have already been contacted for inclusion in ORV), Guadalupe Mountains NP, Russell Cave NM, Little River Canyon N Pres., Cuyahoga Valley NRA, James A. Garfield NHS, and Theodore Roosevelt Inaugural NHS.

o Use of ORV is only precedent setting for the management of longstanding public health concerns in which technological developments have allowed for safe and effective vaccines that can be widely distributed to control diseases in wildlife. For example, this decision may influence future decisions regarding vaccination against plague in rodents such as prairie dogs.

INTERESTED PARTIES: The proposed broadcast application of ORV in NPS units may generate interest from a number of sectors, including:

o Congress approved an additional $8 million (total $16 million) in the USDA APEIIS budget for FY2002 for the rabies control program.

o USDA APHIS Wildlife Services is coordinating the ORV effort among states. o CDC has addressed this issue for years and also has a significant interest in how

the NPS responds. o State health departments, particularly Texas, and wildlife agencies will be

interested because of their related efforts. o Animal rights groups will have concern if lethal take is used for rabies control,

surveillance programs, or if required, in subsequent management programs to control animal populations. Wilderness groups may have concern over the use of aircraft for ORV application within areas managed as wilderness. Other citizen

4

groups may have a concern over the use of a genetically-engineered vaccine in NPS units.

o The general public may become interested in the issue due to concerns over public health or ORV application within parks.

o The news media may develop an interest in the issue within NPS units or surrounding areas.

o Alternatively, because ORV efforts have been in place in numerous local areas in the eastern United States and in Texas for over six years, media and public response may be limited. USDA APHIS Wildlife Services received only one comment in response to publication of their Environmental Assessment in the Federal Register. That comment was from an animal protection group that supported ORV but opposed the lethal take of animals for rabies control and surveillance activities.

RECOMMENDATIONS: o Parks and regions become engaged in discussions and collaborate with USDA

APHIS Wildlife Services and/or states in development of proposals and alternatives (e.g., NEPA, Section 7) upon which decisions on ORV application will be made by Superintendents and Regional Directors

o NPS Biological Resource Management Division staff believes that with some further review and possibly mitigation, application of ORV can likely occur in park units without substantial impacts on park resources. However, use of lethal methods to control populations or for surveillance is not necessary and will not be permitted.

o If ORV efforts are implemented in NPS units, that rigorous review of the plan be made by qualified experts (e.g., CDC) prior to implementation and that scientific evaluation of the programs is performed in NPS units or on similar lands (where results can be extrapolated to NPS sites).

o NPS Biological Resource Management Division continues to serve as a liaison with national coordinators of the ORV program (USDA APHIS Wildlife Services, CDC, and states) and provide technical assistance to parks on decision-making processes and review of ORV programs.

o Review adequacy and applicability of NPS policies as they apply to pathogenic agents (prions, viruses, bacteria) and control programs.

CONTACTS: Craig C. Axtell, Chief, Division of Biological Resource Management, at craig axtell@nps.gov or telephone (970) 225-3591, or Dr. Margaret Wild, Wildlife Veterinarian, Biological Resource Management Division, margaret wild@nps.gov or telephone (970) 225-3593.

5

United States Department of the Interior NATIONAL PARK SERVICE

INTERMOUNTAIN REGION Southwest Support Office

P. O. Box 728 Santa Fe, New Mexico 87504-0728

VIA ELECTRONIC MAIL: NO HARD COPY TO FOLLOW

Memorandum

Date: September 20, 2002

To: Linda Drees, Acting Chief, Biological Resource Management Division

From: Public Health Consultant, IMR-SSO, Santa Fe I si Joseph Winkelmaier

Subject: Response to 12/21/01 Memorandum Concerning Oral Rabies Vaccine

Captain Hanley, Director, NPS Public Health Program (PHP), requested that I respond to your memorandum dated December 21, 2001, concerning the public health impact of rabies as it relates to a proposed ORV program that may impact NPS lands. The questions put forth in the memorandum are presented below followed by the PHP response.

It is my understanding that Captain Hanley will be available for the briefing with Mike Soukup on January 29, 2002. If you require further information or clarification of any of the opinions presented below, please do not hesitate to contact me a 505-988-6040.

1. With respect to National Park Service Management Policy sections 4.4.2, 4.4.4.2, and 4.4.5.1, does rabies found in raccoons in the eastern United States and coyotes and gray fox in Texas present a public health hazard or, is control in units of the NPS necessary to protect human health?

Rabies represents a significant public health concern anytime it is encountered in domestic or wild animals. Although only 1 or 2 people die annually from rabies in the United States, it is estimated that up to 100,000 persons die annually from rabies worldwide, and exposures to potentially rabid animals resulted in an estimated 40,000 individuals in the United States receiving postexposure prophylaxis (PEP) a year. As stated in the May 29, 2001 letter from

Director Jeffrey Koplan from Centers for Disease Control and Prevention (CDC), rabies continues to be considered a serious public health threat in the United States.

The low rabies-related human mortality rate in the United States is primarily due to the public health infrastructure in place to address this significant threat. The coyote variant in south Texas, which is indistinguishable from that of infected dogs in the border area, has resulted in two documented human deaths. Although no human case of rabies has been documented to date from the raccoon rabies epizootic, there has been a tremendous economic and psychological cost in administering PEP treatments.

The oral rabies vaccine program currently underway is a significant part of the rabies elimination and control plan in the state of Texas and in the eastern United States, and plays an important role in combating rabies inside and outside of NPS lands. Although human rabies is currently under control due to extensive, ongoing efforts of the public health community, it is considered a significant public health threat and every reasonable effort should be made to control the disease.

2. What are the public health implications, both within National Park System units and outside, if the National Park Service does not participate (i.e., allow for use of ORV) in APHIS-WS/state ORV programs?

Rabies prevention in the United States has traditionally focused on the vaccination of domestic animals and postexposure treatment (PET). By 1960, rabies in animals was diagnosed more frequently in wildlife than domesticated animals, with the principal hosts being wild carnivores and bats. The Centers for Disease Control and Prevention (CDC) first conceived of the oral vaccination concept during the 1960's, and the concept has progressed and was first used extensively in Europe.

Outbreaks of rabies in raccoons in the mid-Atlantic and northeastern states, gray fox in west central Texas, and coyotes in south Texas has served to focus prevention measures on oral rabies vaccine (ORV) as a tool for controlling rabies in wildlife. Control or elimination of rabies using ORV is contingent on obtaining a minimum vaccination rate in the reservoir species to eliminate or contain the rabies epizootic. A lack of cooperation among all land managers in the area targeted for an ORV program may lead to reinfection of the reservoir population and may be a significant factor in the ultimate failure of the program. Efforts at vaccination of red foxes in Western Europe has led to the elimination of rabies from large areas of land, but reinfections have occurred from neighboring regions that did not participate in the program.

A lack of participation by the NPS in an ORV program is unlikely to have an immediate adverse health affect within individual NPS units. The high level of awareness, control of domestic animals, and habitat modification tends to minimize risk within the NPS units. However, failure to cooperate with a regional ORV program will have significant negative long-term public health implications and financial costs if it contributes to failure of the program on adjacent lands. The public health impact of rabies outside of NPS lands is clearly demonstrated by the estimated

40,000 PET's administered each year. As long as rabies is endemic in the wildlife population, the risk of exposure exists and NPS units will need to increase educational efforts targeted to the staff and visitors.

The spatial and temporal coverage of the ORV program is critical to achieve the goals of the program. Rabies cannot be eliminated without the danger of reinfection if areas of land controlled by the NPS are allowed to harbor unvaccinated reservoir species.

3. Is there a public health risk to park visitors or employees from the application of and/or presence of ORV baits in units of the National Park System?

The vaccine used in the bait drops is not a live rabies vaccine and therefore cannot cause rabies. There is a very slight risk that an immunocompromised individual may develop vaccinia-mediated disease with exposure to the vaccine through contamination of a flesh wound or actual inoculation. The primary avenue of exposure for humans is associated with dogs recovering the bait. The bait is designed to be attractive to the target population while being repugnant to humans. ORV programs are accompanied by an intensive educational effort in an attempt to inform and educate the population living in the area. Each bait also has a warning and a telephone number that an individual may contact for additional information.

Aerial ORV programs similar to that currently proposed on and adjacent to NPS lands have been in use since the mid 1970's. During that time, only one exposure has resulted in an adverse health impact on a human. A recent study reviewed data from 6 programs with a total of 6 million bait drops from 1992 through 1996. Of the 316 documented bait contacts, 53 had probable contact with the vaccine, and there were no documented adverse health impacts. Due the increased education and awareness possible in NPS units and the reduced number of domesticated animals that may encounter the baits, the potential danger to park visitors is most likely significantly lower than in the general population.

All available information indicates that there is minimal public health threat associated with use of the oral vaccine in baits. However, public health officials have been advised that they should remain cautious in cases of possible human contact with the vaccine, particularly in immunocompromised individuals.

cc: CAPT John Hanley, Director, Public Health Program, WASO Dr. Margaret Wild, Biological Resource Management Division