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**Comments Due Today**

The comment period on the proposed rule issued by USDA-APHIS ends this Wednesday, October 26, 2016.  The proposed rule, APHIS-2011-0009-0001, would prohibit the use of any action device, pad, hoof band or substance on any Tennessee Walking Horse, Racking Horse, Spotted Saddle Horse, or related breed.  

In addition, the proposed rule eliminates the self-regulatory Horse Industry Organization (HIO) system and places complete enforcement responsibility of the HPA on APHIS and horse show management. APHIS proposes to institute a Horse Protection Inspector (HPI) system that utilizes only veterinarians and vet techs as inspectors driving the cost up substantially on any horse show with Tennessee Walking Horses or related breeds.

The proposed rule and its corresponding costs and demands on horse show budgets will require horse show management in most cases to cancel their shows. The demands on horse show management affect both pleasure and performance horse shows. In addition, USDA issued a clarification and is considering prohibiting all shoes except for keg or conventional shoes in the show ring.  Without defining conventional shoes, many fear a 16-ounce weight limit on show horses, eliminating all divisions except for Country Pleasure.

The USDA has cited no additional scientific evidence to support their equipment bans yet emphasizes that the equipment could be utilized to facilitate soring. All scientific evidence and studies confirm that the current equipment allowed under the HPA and Regulations do not cause soring.

The proposed rule will have devastating impacts on businesses, communities and those individuals and companies that rely on the show horse industry. It is imperative that you voice your opposition to this proposed rule as well as getting all of the vendors you do business with to voice their opposition as their businesses will suffer.

The USDA has cited the proposed rule would have very little economic impact. Nothing could be further from the truth as communities stand to lose millions of dollars in economic activity and individuals stand to lose jobs, income and their businesses, leaving many unemployed.

When the rule was first issued in July, the Walking Horse Report published an article outlining how you could help oppose the rule. Imperative in that article was for each person affected by the rule to comment.

We urge you to comment by clicking here. You can also read the comments already submitted here as well.

Below are some suggestions to help you with your comment from the previous article in Walking Horse Report.

When submitting your comment, you don’t have to have an elaborate speech but need to focus on the impact the rule has with you. For example, if you are a…

Trainer – How many employees you have, how the rule will impact your business, the effect it will have on your household income and the loss you will suffer as a result.  You should also recruit a representative from every vendor you buy from to be at the hearing and submit a comment talking about the impact of the loss of your business on their business.

Owner – How many horses you own, their current value and what the value will be if the rule goes into effect, constituting the illegal taking of that value by the USDA with zero regard for veterinary science that proves no relationship between pads, action devices and hoof bands and soring.  You can also speak to the real estate you own that is specifically tied to your involvement in the horse industry.  This should not just be padded horse owners – flat shod horses will be affected by the prohibition of bands, the difficulty in having horse shows to show your horses and the loss of shows with both divisions making your horses less marketable and thus less valuable.

Breeder – How many broodmares you own, how many stallions you own, if you own a breeding operation, how many employees you have and how your operation would be impacted by the rule.  A good measure of this impact would be the already large decrease in breeding as a result of the USDA’s overregulation of the current horse show and inspection system.

Horse Show Management – Speak to the value your horse show brings to the community where it is held and the charities that you benefit and with the rule how difficult it will be to have a horse show, have horses participate and how the new rules are making it too difficult and too cost prohibitive to have a horse show and thus the loss to the community and charities as a result.  We have many shows that donate thousands and thousands of dollars to worthy causes.

Farrier – How many employees you have, how the rule will affect your business, the effect it will have on your household income and the loss you will suffer as a result

Veterinarians – How many employees you have, the impact of the Tennessee Walking Show Horse on your practice, the loss of revenue to your practice, etc.  You should also be able to speak professionally to the prohibition of the equipment and how it is unrelated to soring. You can also speak to the difficulty of recruiting veterinarians and vet techs to serve as DQPs.

Elected officials – You can speak to the value of the Tennessee Walking Horse to shows in your community, the tax revenue received as a result of the Tennessee Walking Horse and the use of the Tennessee Walking Horse to help civic clubs in your community and the valuable work they do. Most of the local shows across the state offer both divisions and will be impacted by the rule dramatically, reducing the economic impact to the community.

Business Owner – You can speak to the impact of the Tennessee Walking Horse, the owners, the trainers and all the spectators to your business and how you would be affected if the industry went away

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