Data on the composition of and pathogens in horse manure demonstrates that horses are no worse than other animals with 1000 pound body weight, and in many instances are actually preferable. This should be of grave concern to the EPA because of the unintended consequences of potentially making every agricultural and recreational animal, companion animal or pet in a yard a point-source of pollution, subject to permitting and reporting. Horses are not essentially food production animals. Regulation of horses should be voluntary, incentive-based and supported by educational efforts if funding for BMPs continues to be unavailable. Most horse keeping facilities will easily fall below the CAFO regulatory limit proposed of 500 if body weight rather than AUs are applied to regulation and the three-tier structure is adopted.
Most horse keeping facilities are small.
The proposed regulation, if applied to horses as drafted, will lead to unintended consequences that can be avoided by a more prudent approach exempting or defining horse as agricultural and recreational, and not including it with food production animals and poultry. According to the American Horse Council in 1996, keeping horses in an area brings a four-fold economic return to the local community. If unnecessary regulation is promulgated, the EPA will drive horses and their positive collateral impact from our communities. Employ the historic USDA description of horses as agricultural and recreational animals and either exempt or define agricultural and recreational animals out of this proposed regulation of primarily food production animals and poultry. Clarify the proposal so agricultural and recreational animals, companion animals and pets will not be CAFOs.