*sent to RHBAA Site by Kelly Smith 10/25/06

October 20, 2006

United States Department of Agriculture
APHIS, Animal Care
4700 River Road, Unit 84
Riverdale, MD 20737-1234

Dear Reviewer,

I want to report what I believe to be an egregious event that occurred in Priceville, Alabama Saturday night, September 2, 2006, the final night of the Racking Horse World Celebration Show.  I watched one member in particular that I presume is from the United States Department of Agriculture push, prod, scrape, and pull on a horse’s pasterns for what appeared to be 15 to 20 minutes and possibly more by the time all the checking activities were over.  Hardly any animal would put up with such abuse. I witnessed several youngsters crying because their horse was turned down because of a “scar rule”.  Just because a horse has a scar on his foot doesn’t mean it was from an excessive use of a chain, it could be like many athletes have, it could be from skinning their foot in various kinds of ways. If a scar is the result of something that has healed, then I do not understand the significance of that. 

It is my opinion that the industry is sadly lacking an advocate for their position and that your department is over extending their authority in this area.  This is a case where the pendulum has swung to far and you as the government have over stepped your bounds.  It is my opinion especially at such large events where the results have been aspired to all year long that there should in fact be a people’s advocate to observe the activities of the United States Department of Agriculture to allow the industry to be assured that they are in-fact acting within the law.  I find the procedure to be insulting and outrageous and lacking in real knowledge.  The DQP or Designated Qualified Person for the Industry is of little value in this area.

I do understand that some people were written up for foreign substances.  I don’t know of a horse show in America, be it cowboys or be it anybody else that doesn’t groom their horse and paint their hoofs.  The government ought to be able distinguish between that and other substances that would be illegal.  Even though there has been some abuse in the walking horse industry in the past, I believe for the most part that has been cleaned up and if a horse has really been soared I don’t think you have to press on his pasterns over and over, pull on him, and scratch him trying to make him flinch.  An examination and  re-examination over and over till it fails is an abuse of power which I think your representatives are guilty of.

 It’s my view that the government needs to have some way to keep them accountable and that a third party advocate (not a DQP) at the scene would be a sufficient way to assure the industry that they are receiving fair treatment.  I am a believer in cleaning up the industry and that includes abuses by the United States Department of Agriculture.  While I have been away from the industry for about 10 years, I’m astonished by the boldness and the extension of rules by interpretation that I witnessed.  Scars on horses that are healed and well taken care of ought to not automatically eliminate a horse from being able to appear in the show ring.  Interpretation of the scar rule is an example of where your representatives have extrapolated in my opinion from what was intended to a far reaching interpretation.  I do hope litigation won’t be necessary as it is so many times when the government goes beyond their reasonable bonds.

 I would very much like someone to respond to me why it is necessary to push, pull, tug, and prod on a horse for 20 to 30 minutes through an examination.  It’s a bizarre treatment in itself an abuse of the very animal they are trying to protect, and an activity that seemingly reflects forcing a desired end result.  Also I have enclosed a copy of Sheet – 23 from your document that I took off you Web Site regarding “Understanding the Scar Rule”.

Sincerely,

Robert D. Holloway
Holloway Farms

RDH/bf

 Cc:  Racking Horse Breeders’ Association of America
        National Walking Horse Association
        National Horse Show Commission, Inc.
        The Walking Horse Report
        The Racking Source
        The Racking Image
        The Show Horse Review
        Jeff Sessions, Senator, Alabama