**The Evolution of the USDA’s Horse Protection Operating Plans: A Timeline of Negotiations and Challenges**
The history of the USDA’s Horse Protection Operating Plans reveals a complex and often contentious negotiation process between the government and various Horse Industry Organizations (HIOs). From the initial draft of the 2000 Operating Plan to the eventual implementation of the 2001-2003 plan, this timeline highlights key developments, disputes, and resolutions that have shaped the enforcement of the Horse Protection Act (HPA).
### **1999: The Foundation is Laid**
In November 1999, the USDA released its first draft of the 2000 Operating Plan. However, resistance from HIOs quickly surfaced. On November 14, the National Horse Show Commission (NHSC) identified 50 major contentions with the draft and opted to maintain the 1999 plan. Subsequent meetings between the USDA and HIO representatives failed to bridge significant gaps, particularly regarding changes in regulatory approaches. By December, the USDA issued a revised draft incorporating some feedback, but HIOs remained divided over its adoption.
### **2000: A Year of Stalemates and Adjustments**
The year 2000 began with discord. The NHSC and several other HIOs refused to sign the new plan, citing concerns over changes in enforcement methods, such as relying solely on palpation to detect soreness in horses. USDA Deputy Administrator Dr. Ron DeHaven expressed disappointment but affirmed that USDA personnel would enforce the HPA at non-compliant events.
Throughout the year, negotiations continued in fits and starts. Multiple meetings, letters, and revisions failed to yield consensus. In March, DeHaven introduced an alternative plan, “2000-B,” identical to the 1999 plan but with added endnotes. However, these endnotes sparked further objections from HIOs, who argued they altered the plan’s interpretation and implementation.
By mid-year, congressional representatives became involved, with several senators and congressmen urging the USDA to revert to the 1999 plan’s framework. Despite these interventions, disagreements persisted. The USDA extended deadlines for HIOs to sign either version of the plan and made concessions on contentious endnotes in response to industry feedback. By July, most HIOs had signed onto either the 2000 or 2000-B plans, though NHSC and Western International continued to resist.
### **Towards a Multi-Year Plan**
In October 2000, NHSC proposed a five-year operating plan modeled on the 1999 version with minor revisions. The USDA responded by scheduling a meeting for November 28 to discuss a multi-year plan for 2001 and beyond. At this meeting, DeHaven acknowledged divergent views among HIOs but expressed optimism about reaching an agreement for a unified operating plan.
By December, the USDA circulated a draft of the 2001-2003 Operating Plan. DeHaven described it as a significant improvement addressing industry concerns without compromising enforcement goals. Early feedback from NHSC representatives suggested cautious optimism about its provisions.
### **2001: Legal Challenges and Final Agreements**
In January 2001, progress was disrupted by a lawsuit from the American Horse Protection Association (AHPA). The AHPA argued that delegating enforcement authority to HIOs violated the HPA. A motion for a temporary restraining order to halt implementation of the new plan was denied, allowing negotiations to continue.
By February, several HIOs, including the Spotted Saddle Horse Breeders’ and Exhibitors’ Association (SSHBEA) and Missouri Fox Trotters, signed the 2001-2003 plan. Meanwhile, legal proceedings continued as both sides filed motions and rebuttals regarding the AHPA’s lawsuit.
Amidst this legal backdrop, congressional representatives from districts with horse shows advocated for clarity and fairness in enforcement plans. Their letters to USDA Secretary Ann Veneman underscored the importance of balancing regulatory oversight with industry needs.
In April 2001, a breakthrough occurred when NHSC chief negotiator Craig Evans signed the 2001-2003 Operating Plan alongside leaders from three other HIOs. A letter of clarification addressed lingering concerns, paving the way for broader acceptance of the plan.
### **Conclusion**
The evolution of the USDA’s Horse Protection Operating Plans underscores the challenges of balancing government oversight with industry cooperation. While each iteration of the plan brought incremental improvements, it also highlighted persistent tensions over enforcement methods and interpretations of regulatory authority. The eventual adoption of the 2001-2003 plan marked a significant step forward, setting a foundation for future multi-year agreements aimed at protecting horses while addressing industry concerns.
This timeline serves as a testament to the complexities of regulatory policy-making in industries where differing priorities must be reconciled for progress to occur.
