The Tennessee Walking Horse National Celebration sent a letter seeking a 60-day extension to the comment period on the USDA’s proposed rule published at 88 FR 56924.  The letter, sent from Patrick F. Philbin, counsel for The Celebration, points out two major reasons the extension should be granted.

The first highlights the enormous impact the rule would have and how many horses would be affected by the elimination of pads and action devices.  This rule would effectively eliminate the entire performance division of horses.

In addition, the letter points out that the USDA published the proposed rule seeking comment just days before the 85th Annual Celebration.  The Celebration, and its SHOW HIO, has limited resources to devote to comment on the rule and those resources will be dedicated to The Celebration and the ensuing required reporting by USDA until mid-September.  This timeline would exhaust half the comment period and only leave 30 days for The Celebration to comment.

The data collected by the SHOW HIO will be critical in the response and it will take time for that data over the last six years to be accumulated and analyzed to help support the comment from The Celebration.  In addition, data from this year’s Celebration will also be critical as the rule eliminates all HIOs and changes the inspection process.

The USDA has not yet replied to The Celebration’s request seeking additional time.  The original comment period will end on October 21, 2023 if no extension is granted.