The number of affected facilities under the proposed regulation for horses alone could be in the thousands. Add in the food production animals and poultry, and you have a real problem to deal with. This proposal could have dire unintended consequences if passed as written. The State of California will have problems developing even General Permits to include the expanded definition of facilities due to the need to comply with CEQA regulations. Horses are not essentially food production animals.
Horses are agricultural and recreational by the government's own definition.
Regulation of horses should be voluntary, incentive-based and supported by educational efforts if funding for BMPs continues to be unavailable. CNMPs related to this regulation are supposed to be voluntary, incentive-based programs with government funding available to help people implement BMPs to achieve them. Probably, slim to none. If horses are NOT the problem, as the EPA itself suggests, and if there continues to be no substantial financial assistance for horse keeping BMPs, the EPA should exempt agricultural and recreational horses from CNMPs, PNPs and other proposed requirements. States and local jurisdictions will not have the ability to put these types of programs together and administer them effectively if agricultural and recreational horse keeping is thrown into the equation with other food production animals and poultry.