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Many Arabian Horse Association members are aware of the U.S. Department of Agriculture's (USDA) Animal and Plant Health Inspection Service (APHIS) recently proposed changes to the regulations governing enforcement of the Horse Protection Act (HPA).

A 60-day Public Hearing and Public Comment period began. This comment period has been extended and ends October 26, 2016 at which time the USDA will review comments, make any revisions/changes, and finalize the Rule. Because the HPA is already a law, there is no Congressional vote.

AHA is adamantly opposed to any cruel or abusive actions that endanger the welfare of any horses. We support the effort to eliminate soring and other abusive practices. 

However, AHA feels that the proposed rule is over-reaching, arbitrary, capricious and potentially detrimental to the Arabian breed. The rule would forbid the use of pads, bands and action devices in Tennessee Walking Horses, Racking Horses, Spotted Saddlehorses "AND RELATED BREEDS".  

Please read the letter and position statement below from AHA Executive Vice President, Glenn T. Petty:

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September 26, 2016

Docket ID: APHIS-2011-0009

Regulatory Analysis and Development

PPD, APHIS, Station 3A-03.8

4700 River Road, Unit 118

Rockville, MD 20737-1238

Re:       Docket ID: APHIS-2011-0009.  Horse Protection Act: Licensing of Designated Qualified Persons and Other Amendments

To whom it may concern:

The Arabian Horse Association asks USDA to modify this proposed rule because, as written, the rule is overly broad, vague, and ambiguous and would impede our efforts to protect our horse's welfare. We ask that section 11.2 be changed to read: "The use of the following devices, equipment, or practices is specifically prohibited with respect to any Tennessee Walking Horse, Racking Horse, or Spotted Saddlehorses, that performs with a gait that raises concerns about soring at any horse show, horse exhibition, horse sale, or horse auction, and excepting breeds governed by the U.S Equestrian Federation, the National Governing Body for Equestrian Sports pursuant to the Ted Stevens Olympic and Amateur Sports Act,  36 U.S.C. Sec. 220501 et seq., and the United States Olympic Committee."  9CFR Section 11.2.

The Arabian Horse Association (AHA) is a major equine association serving 85,600 Arabian, Half-Arabian and Anglo-Arabian horse owners and 214 clubs across North America.  AHA registers and maintains a database of more than one million Arabian, Half-Arabian and Anglo-Arabian horses and administers approximately $1 million in annual prize money.  AHA produces championship events, recognizes over 400 Arabian horse shows and distance rides and provides activities, education, and programs that promote breeding and ownership.

Almost 50 years ago in the late '60s, the Walking and Racking Horse industry was out of control with soring their horses and other means to achieve "the big lick."  This led to the implementation of the much needed U.S. Horse Protection Act of 1970 (USHPA).

What is sad is that after all these years, soring of Walking Horses, Racking Horses, and Spotted Saddle Horses has not been eliminated. About two years ago, the Prevent All Soring Tactics (PAST) Act was proposed in Congress to stop the abuse, specifically naming Walking Horses, Racking Horses and Spotted Saddle Horses. That Act was opposed and effectively stalled in Congress. This has led to the U.S. Department of Agriculture (USDA) proposing new rules - a rewritten United States Horse Protection Act (USHPA), which in its present form mirrors the PAST Act but appears to not restrict the Act's application to just those three breeds. As written this means that breeds such as Arabians, Morgans and Saddlebreds, which wear pads that allow horses to be sound and comfortable, could be included in the vague, overly broad, and ambiguous language of this proposed rule. 

The American Horse Council (AHC) has stated "The proposed rule would make several changes to current USHPA regulations with the goal of improving enforcement of the law and ending soring. However, the proposed rule has prompted some questions about its potential impact on the wider industry, particularly on other gaited breeds. The AHC convened a USHPA working group and has been engaging industry stake holders to answer some of these questions and draft formal comments regarding the proposed rule. The AHC has been actively communicating with industry groups including the American Association of Equine Practitioners (AAEP), the U.S Equestrian Federation (USEF), the American Saddlebred Horse Association (ASHA), the American Morgan Horse Association (AMHA) as well as the Arabian Horse Association (AHA)."

As the Executive Vice President of AHA, I represent AHA on this USHPA working group. Unlike Walking Horses, trotting breeds such as Arabians must be sound in order to compete. Our industry has been diligent in self-enforcement. Our judges, for instance, will very quickly eliminate an unsound horse from either their card or the ring.  Also, to my knowledge, not one single charge has ever been made by USDA against trotting breeds as a violation of the USHPA.

Julie Broadway, AHC's President, has stated, "It is equally important that any new regulations are narrowly focused on the problem of soring and do not adversely impact or unnecessarily burden other segments of the horse show industry that are not soring horses and have no history of soring horses."

Key points:

• Trotting breeds have to be sound in order to compete
• Trotting breeds have never been cited to be in violation of USHPA
• USDA's budget to enforce the USHPA is limited and needs to focus on the breeds which have been proven to have problems
• Very thick exaggerated stacked pads used by Walking horses are the problem; not pads and bands used by the trotting breeds that serve as therapeutic, supportive, and in many cases, protective in nature to avoid soreness issues

Arabian show rules are very focused on not allowing abuse to our horses. Following are two sections from our show rules specific to both welfare of the horse and shoeing: (rules have been omitted from this eblast, but were included in the letter. These rules can be found here: https://www.usef.org/documents/ruleBook/2016/05-AR.pdf sections AR105 and AR106). 

The Arabian Horse Association asks the USDA to modify this proposed rule because, as written, the rule is overly broad, vague, and ambiguous and would impede our efforts to protect our horse's welfare. We ask that section 11.2 be changed to read: "The use of the following devices, equipment, or practices is specifically prohibited with respect to any Tennessee Walking Horse, Racking Horse, or Spotted Saddlehorses, that performs with a gait that raises concerns about soring at any horse show, horse exhibition, horse sale, or horse auction, and excepting breeds governed by the U.S Equestrian Federation, the National Governing Body for Equestrian Sports pursuant to the Ted Stevens Olympic and Amateur Sports Act,  36 U.S.C. Sec. 220501 et seq., and the United States Olympic Committee."  9CFR Section 11.2.

The Arabian Horse Association (AHA) is adamantly opposed to any abusive and cruel actions that endanger the welfare of any horses. We support the effort to eliminate soring and other abusive practices. However, AHA feels that the current wording is over-reaching, arbitrary, capricious and potentially detrimental to the Arabian horse breed. The health, welfare, happiness and soundness of the Arabian breed is our number one priority.

Our breed has never been sanctioned by the USDA for violation of the US Horse Protection Act and therefore does not need to be burdened by the Walking and Racking Horse industries lack of self-regulation.  This rule needs to focus on and name the three breeds - Walking Horses, Racking Horses, and Spotted Saddle Horses - that have been violators over the years.

In addition as stated above, Arabians have self-regulated by implementing our shoeing rules.   Our shoeing rules have been reviewed and modified as needed by our Equine Stress, Research, and Education Committee and our convention.   Pads and bands are beneficial to our horses and necessary to good care of our horses.  

The Arabian Horse Association has always placed the welfare of our horses as paramount and is known for self-regulation!

Glenn T. Petty

Executive Vice President

Arabian Horse Association

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To find out more how you as an AHA member can make your voice heard, where to read the original bill, the latest deadlines and more on this current bill, visit here.

-- via AHA