AHC Comments on USDA Proposed Rules for the Importation of Noncompetitive Entertainment Horses from CEM Affected Countries

October 1, 2007
Dr. Ellen M. Buck
Veterinary Medical Officer, Import/Export Animals
USDA/APHIS/VS/NCIE
Docket No. APHIS–2006–0164,
Regulatory Analysis and Development,
PPD, APHIS, Station 3A–03.8,
4700 River Road Unit 118
Riverdale, MD 20737–1238
Re: Docket No. APHIS–2006–0164

Dear Dr. Buck:
The American Horse Council (AHC) appreciates the opportunity to comment on the proposed rules to allow noncompetitive entertainment horses from countries affected with contagious equine metritis to be temporarily imported into the United States under certain conditions. The AHC is the national association representing all segments of the horse industry in Washington, D.C. The AHC includes over 160 organizations and 1,200 individuals representing every facet of the horse world – from owners, breeders, trainers, veterinarians,
farriers, breed registries and horsemen’s associations to horse shows, racetracks, rodeos,commercial suppliers and state horse councils.

With a total of 9.2 million horses, the U.S. horse industry is a $102 billion industry that supports 1.4 million full-time jobs. There are 4.6 million Americans involved in the industry as horse owners, service providers, employees and volunteers; and tens of millions more
participate as spectators.

The U.S. horse industry is an international one and increasingly more foreign horses are being brought into the U.S. for a variety of purposes. The AHC recognizes the importance of the many safeguards that are currently in place, including the import regulations, which exist to protect the U.S. horse population from the introduction of foreign animal diseases. However, the AHC also recognizes the need for a new category within the import regulations to further accommodate the entertainment sector of the horse industry. Many problems have arisen in the past with the importation of non-competitive entertainment horses and their continual application for permits. The AHC supports the amendment of the current import regulations to allow noncompetitive entertainment horses from countries affected with contagious equine metritis to be temporarily imported into the United States under certain conditions, which provides a solution to these problems.

Though the AHC is in full support of the proposed rules, there is one concern. The proposed rules provide for no limit on the period of time that the imported horses can remain in the U.S. The AHC is concerned that USDA may not be able to commit to upholding the requirements specified for these horses over extended periods of time.

The AHC wants to make sure that USDA will be able to carry out the actions required to protect the U.S. horse industry from the introduction of disease, which is a priority of our industry. The introduction of an exotic equine disease to our 9.2 million horses would not
only have a devastating effect on the equine industry but on the rest of the country as well. This being said, the AHC appreciates the USDA’s effort to respond to the problems with theimportation and allocation of permits for non-competitive entertainment horses, and to better accommodate this sector of the industry while protecting the safeguards that are in place. Thank you for the opportunity to comment on this proposal and for your careful consideration of these comments. If further information is desired, please do not hesitate to contact us.
Sincerely,
James J. Hickey, Jr.
AHC President