The following letter is in response to the United States Department of Agriculture's request for comments on the proposed horse protection rule regarding the Licensing of Designated Qualified Persons and Other Amendments that appeared in the Federal Register on July 26, 2016 ("proposed rule")(81 FR 49112). Founded in 1968, the United Professional Horsemen's Association ("UPHA") represents thousands of horse trainers and other professionals, including 21 regional chapters that comprise all 50 states and Canada. The UPHA is dedicated to bettering the conditions of those engaged in the pursuit of various equine related activities, to supporting research aimed at improving the horse as a species, and to promoting the development of a higher degree of efficiency for its members in their efforts to improve the general condition of the show horse industry.

On behalf of its membership, UPHA appreciates the opportunity to provide comments and additional information to assist APHIS in its development of the proposed rule to ensure it protects horse welfare, reflects the needs of the show horse industry and is consistent with the intent and language of the Horse Protection Act ("HPA"). While the UPHA is supportive of APHIS' intention to protect the integrity of the inspection system and strengthen existing requirements to prevent the cruel and inhumane practice of soring, UPHA cannot support the proposed rule as drafted. UPHA is concerned that the proposed rule exceeds the Agency's statutory authority under the HPA and contains a number of provisions with vague language that may result in confusion, uncertainty and unintended detrimental impacts to trotting breeds that have no history of soring. To prevent these outcomes, UPHA believes that the following modifications and clarifications must be made to ensure the proposed rule remains within the confines of the statutory authority granted by Congress, is easily understood by UPHA's members, and is consistently applied by APHIS: Please click on the following link to read the entire UPHA response: RE- Docket No. APHIS-2011-0009 Horse Protection