If the winter is severe and prolonged, greater than 45 days of supplemental feeding may be required to see them through the winter. Special considerations and exemptions are needed for at least these two cyclical naturally occurring conditions, and perhaps others. Not enough input has been obtained from horse councils, breeders, ranchers, etc., to develop a reasonable regulation for horses in this regard. Distinguishing horses as agricultural and recreational animals and thereby defining them out of this regulation would resolve this. 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 horses as agricultural and recreational, and not including them with food production animals and poultry. The State of California currently has NO CAFOs, and consequently no procedures for dealing with them. 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.