WILD HORSE HUB CENTRAL

THIS POST FEATURES ANIMALS ANGELS. FOREVER VIGILANT AND CONSTANTLY WORKING TO GIVE  YOU THE BEST RESULTS IN ALL THAT THEY DO. THANK YOU!

http://www.animalsangels.org/


Update from the hard working ever vigilant Animals Angels of the U.S. Thank you for your continued hard work in research, investigation and reporting. Please donate to your favorite horse rescue site; or your favorite .org sites so that we can continue this type of work. The Animals Angels .org site (http://www.animalsangels.org/) is constantly working hard for this country. You can subscribe to receive their email alerts from around the world.  They always answer my emails and question. Please, please think about supporting them in what ever way you can. Thank you.

WILD HORSE HUB CENTRAL

I received a letter from Senator Mark Pryor, Democrat, Arkansas. I posted this letter on the Facebook page for WHHC. I also posted my response and have the email from Senator Pryor and my response in my files. Since this is concerning more than just politics, I also sent a copy, with Senator J. Boozman's name added to the response letter. (Senator John Boozman, Republican, Arkansas).

I appreciated their responses, most of the time a form letter can be sent out. I try to send emails that have to be responded to without form, but with answers and commitments to do a better job - accordingly - as we all try to do.

I am not anti-government. I love this country. I just want us to try to do better with what we have been given. For wild horses and burros, this is essentially the part where we can have a more hands off method with holistic herd management and holistic land management rather than forcing the changes that a species can not bare and survive. We have to insist that our government stop managing these wild horses and burros to extinction.

I purposed a suggestion to remove all the wild horses from the holding facilities, no matter where they are, that have been collected (and preferably sold - if that would be possible - just another idea that just popped into my thoughts); and return them to the public lands. I suggested that there are states, such as my own, which does not have one single wild horse in it - yet "The Natural" state has acres and acres of forest and grazing for these wild horses and burros. It would be a game changer for every state. I also suggested that the care of these wild horses and burros be taken from BLM because of their blatant falsifying federal document, falsifying federal statements, and inadequate ability to do the job of caring for these wild horses and burros without spending money that is not necessary. I suggested that the money that BLM uses for these wild horses and burros be turned over the the advocates and rescue groups so they can hire personnel that can do the job of transporting these horses from these facilities to other states that are willing to have a wild horse population; and, support the advocates and rescue sites in the states that they are transported to. I truly hope this works. It's my best attempt yet to solve the holding facilities horrid conditions and the costs that are accruing to keep these wild horses. I suggested that the Veterinarians Against Horse Slaughter be contacted; and that veterinarians be hired or volunteer services as to the population control so as not to sterilize the mares permanently; and the castration of all stallions seems to be another management tool to destroy the existence of the wild horses and burros. I suggested R.T. Fitch and Anne Novak. I also gave information regarding the indigenous status of the wild horses, which was researched by several groups; one of which works for the BLM. (see posts on WILD HORSE HUB CENTRAL).
As this is seemingly a personal journal, I am hoping that I can keep track of myself. I can only try to do my best. In a moment, the horse that depended upon me to stop the slaughter, has died.

Catholics, Baptists come together over conscience rights bill :: Catholic News Agency (CNA)

This follows my previous blog which is uniting faith based people; people who believe that we are not God, but we serve God. We do not have a one world religion, we have one world, we have one human race, and if you are patient, we will all understand we have one God...We can not force people to believe, we can tell them and show them through our actions. Walk in the light while the light is still with you.
Catholics, Baptists come together over conscience rights bill :: Catholic News Agency (CNA)

What is faith?

This is my blog post for family. I use this blog to post about my faith, my family, and horses...and what may be interesting to me and you, as friends.
This link is one that you will love. As people we understand the meaning of each ethnic human being. The Jewish people have been given the responsibility of being a light unto the nations. That is a big and hard job when you are being bombed or attacked, threatened, and abused by the world, the UN, and other people who just weren't taught that there are some things that God does that we do not have to understand, that is where faith comes in. As a light unto the nations, let us hold on to each other and walk in the light of faith, what ever religion that you may be, there will be a day when we all die, and we will know the truth. It is said that a married couple does not both have to be christian, for what do you know that a man or a woman's faith may actually pull you from the fire, as you spouse is just that important to God in a relationship for men and women.
As Christians, we understand the new covenant. But, many forget, without the old covenant, there can be no new covenant. If a Jewish person does not understand salvation from Jesus Christ (Yaweh Jeshua as it was said to me by a Levite woman), then be patient. It is not our job to make them believe, but to be patient and let them see the works of God in the power of the Holy Trinity (God the Father, God the Son, and God the Holy Spirit) in our lives. God himself will teach them, change the stony heart to a heart that belongs to Him, for all people if we just believe that God's work continues as we do not have to know all the answers.
Today I read that the DOJ (Department of Justice) has changed the rules for children's groups that mention God. How absolutely criminal. In this world, we can not be intimidated. There will always be hard times, we weren't promised a perfect life. We were promised the promises from God because He loves us, but that doesn't keep us from suffering nor does it keep us from His love. His love will be with us eternally, no beginning and no end to God's love. So, today, accept the love of God, in your faith which will be taught to you by God; and let us love one another. Protect one another from harm. Be kind to one another. And rejoice, because God has given us this time to spend with one another in a joyful way; and when one of us is harmed or mourns, we are also harmed or mourn together. We can not have a one world religion. It is not God that has said that. Man can not dictate to God. God will be the one that governs some day, and we will understand the things that we ponder and pray about today...just which religion is right? It doesn't matter, keep your heart towards God and pray and God will teach you what you are suppose to do. Each of us has a purpose, that purpose is to worship God with all our hearts, minds and soul. It didn't mention what religion you are. Just love God above all things. Do no harm to another; and protect the widows and orphans and those who are weaker...that is our charge to one another. Be content. Be watchful. Be vigilant in our tasks toward one another keeping in mind that we too can be in a position, at any time, to rely on the charitable actions of another human being. No one is judged by God with wrath against their faith and actions, who takes care of others and keeps God first, and the love for his neighbor as his faithful action. Show me your faith and I will show you my works (or good deeds toward others) When have you ever seen anything bad happen when a person loves God (whatever faith you are) and also helps his neighbors who are in need and kind to the widow and orphans? When has God judged Islamic people who keep Him first and does what he knows is right towards others, and that is good will and deeds towards all people so that we all may be taught by God and please Him. What is amazing to me is that when we do what delights God and makes Him happy, we are also happy. If we laugh, and are happy, how much more so will God be? God speed in all you do in faithful hope that we will be pleasing to God and make Him happy.
Here is the link that I read for this blog:
Fight against secularism unites Jews, Catholics, Pope says :: Catholic News Agency (CNA)

Interior Dept. responds to Congressional letter on wild horses

As we continue the investigations of abuse, the blantant mistreatment and sometimes, the actual killing of wild horses and burros, the Department of Interior, Sec. Sally Jewell finally responds after pressure from the scientific researchers (who knew they would even respond!) sent shockwaves across BLM's bow to let them know that their program doesn't just fail - it is down right ignorant (my opinion - the scientists at NAS were much more professional in their attempts to stay STUPID).
One thing for sure: The meaning of crazy is doing the same thing over and over and expecting different results. Well, this isn't much different. The DOI has decided to extend the grazing rights for  ranchers from 10 to 20 years - without any approval from the people who actually own the public lands - lease or not - these lands are still called and under the government's ownership. One thing that has to be stopped: THE BLM has to STOP being the policing agency for the cattle ranchers who are whining constantly about the wild horses. Wait until the next pipeline comes down from Canada: that should really give them something to whine about and in the meantime, we can only hope that the CRAZY actions of the BLM will stop. You can follow my other blog: www.jagdb1957.wordpress.com ; the WILD HORSE HUB CENTRAL page on facebook, and of course, the incomplete but working site for WHHC website: http://jagdb1957.wix.com/wild-horse-whhc

Interior Dept. responds to Congressional letter on wild horses

WILD HORSE HUB CENTRAL

It's been a very long day. It started out too early and ends always, early in the morning. Right now, it's too early to mention. My coffee pot has been full all day. 

First, let me mention that having someone hack into my facebook account again is very frustrating, no it's down right time to get mad about it. I did. It worked.

Second, I met a new friend who is also a blogger, but didn't know about our site, as I just learned about his. So, I shared our site(s) and hopefully, someday, he and his friends will visit. Maybe they will find something they enjoy about wild horses and burros. Just looking at the pictures of these fantastically beautiful animals makes your heart pound. Maybe, this is the way to reach out to people; if they don't know, how will they help change the out come of what can happen?

I see that the Canadians are fast at it again with their wondrous pipeline to that "Texas Tea"  albeit there won't be any allowances for the natives, nay nay. As they plan the bag piper plans his greatest feat of stealing the town's children, they town's parents are packing the kids off to play with their Canadian cousins. Well, they should be, as much money as that oil costs they should have to at least babysit the kids. 

While these feats of wonder continue, our knowledge of what is happening will surely come to fruition  to quote the predecesor of the now SOI Jewel: "Wild horses don't have a place on public lands." I see it coming down the pipeline, and now it's time for all of us to stop up the pipe and see if we can't send this contaminated air back to Canada and the Queen of England so they can ruminate about what the subjects are doing in the new world. 

So far, as I know, there are several options. I must also tell you that I found a GAO Report that I downloaded which does not give me anything but a bad attitude. Since this "sequester" nothing is getting done that makes sense; and the only ones spending any money are the politicians who are traveling on their Royal Caribean and African Safari tours as we sleep and dream of the ducky scrooge counting his coins...clink clink clink. 

My pc locks up so many times it's like trying to start an old jalopy: aaarrrarrraarrr aarraarraarr  can you flood a pc? 

I know I haven't mentioned this wonderful group on this blog. But, I do on my other blog ( http://jagdb1957.wordpress.com ). She is one of the hardest working people I know (met her on twitter and asked her to work harder...boy, that was a hoot! A professional journalist who became my friend, and actually worked harder! Amazing. Just amazing.) Her site is called Protect Mustangs at Protect Mustangs.com and she also has it connected to twitter and facebook. It's very professional. A gentle soul, though. Sometimes I wonder if she is cut out to deal with these cowboys who are always spitting and chewing tobacco and cursing their way to feed their cattle on public lands that we pay for so they can get rich. I just wonder if any one is since this country loves it's beef. I try to pick up the slack and sometimes, it works, sometimes I just am at a loss for what to do at all. Check out Protect Mustangs.com you won't be disappointed. 

Now, I have said that I would publish the GAO Report. Here it is:  
Report to Congressional Committees
June 2011
HORSE WELFARE
Action Needed to
Address Unintended
Consequences from
Cessation of Domestic
Slaughter
GAO-11-228
United States Government Accountability Office

GAO
United States Government Accountability Office
Accountability • Integrity • Reliability
Highlights of GAO-11-228, a report to congressional committees
June 2011
HORSE WELFARE
Action Needed to Address Unintended Consequences from Cessation of Domestic Slaughter
Why GAO Did This Study
Since fiscal year 2006, Congress has annually prohibited the use of federal funds to inspect horses destined for food, effectively prohibiting domestic slaughter. The U.S. Department of Agriculture (USDA) is responsible for overseeing the welfare of horses transported for slaughter.
Congress directed GAO to examine horse welfare since cessation of domestic slaughter in 2007. GAO examined (1) the effect on the U.S. horse market, if any, since cessation; (2) any impact of these market changes on horse welfare and on states, local governments, tribes, and animal welfare organizations; and (3) challenges, if any, to USDA’s oversight of the transport and welfare of U.S. horses exported for slaughter. GAO analyzed horse price and shipping data, and interviewed officials from USDA, state and local governments, tribes, the livestock industry, and animal welfare organizations, and reviewed documents they provided.
What GAO Recommends
GAO suggests that Congress may wish to reconsider restrictions on the use of federal funds to inspect horses for slaughter or, instead, consider a permanent ban on horse slaughter. GAO recommends that USDA issue a final rule to protect horses through more of the transportation chain to slaughter and consider ways to better leverage resources for compliance activities. USDA agreed with GAO’s recommendations and noted specific actions it will take to implement them.
What GAO Found
Since domestic horse slaughter ceased in 2007, the slaughter horse market has shifted to Canada and Mexico. From 2006 through 2010, U.S. horse exports for slaughter increased by 148 and 660 percent to Canada and Mexico, respectively. As a result, nearly the same number of U.S. horses was transported to Canada and Mexico for slaughter in 2010—nearly 138,000—as was slaughtered before domestic slaughter ceased. Available data show that horse prices declined since 2007, mainly for the lower-priced horses that are more likely to be bought for slaughter. GAO analysis of horse sale data estimates that closing domestic horse slaughtering facilities significantly and negatively affected lower-to-medium priced horses by 8 to 21 percent; higher-priced horses appear not to have lost value for that reason. Also, GAO estimates the economic downturn reduced prices for all horses by 4 to 5 percent.
Comprehensive, national data are lacking, but state, local government, and animal welfare organizations report a rise in investigations for horse neglect and more abandoned horses since 2007. For example, Colorado data showed that investigations for horse neglect and abuse increased more than 60 percent from 975 in 2005 to 1,588 in 2009. Also, California, Texas, and Florida reported more horses abandoned on private or state land since 2007. These changes have strained resources, according to state data and officials that GAO interviewed. State, local, tribal, and horse industry officials generally attributed these increases in neglect and abandonments to cessation of domestic slaughter and the economic downturn. Others, including representatives from some animal welfare organizations, questioned the relevance of cessation of slaughter to these problems.
USDA faces three broad challenges in overseeing the welfare of horses during transport to slaughter. First, among other management challenges, the current transport regulation only applies to horses transported directly to slaughtering facilities. A 2007 proposed rule would more broadly include horses moved first to stockyards, assembly points, and feedlots before being transported to Canada and Mexico, but delays in issuing a final rule have prevented USDA from protecting horses during much of their transit to slaughtering facilities. In addition, GAO found that many owner/shipper certificates, which document compliance with the regulation, are being returned to USDA without key information, if they are returned at all. Second, annual legislative prohibitions on USDA’s use of federal funds for inspecting horses impede USDA’s ability to improve compliance with, and enforcement of, the transport regulation. Third, GAO analysis shows that U.S. horses intended for slaughter are now traveling significantly greater distances to reach their final destination, where they are not covered by U.S. humane slaughter protections. With cessation of domestic slaughter, USDA lacks staff and resources at the borders and foreign slaughtering facilities that it once had in domestic facilities to help identify problems with shipping paperwork or the condition of horses before they are slaughtered.
View GAO-11-228 or key components.

For more information, contact Lisa Shames at (202) 512-3841 or shamesl@gao.gov.

Page i GAO-11-228 Horse Welfare
Letter 1
Background 5
U.S. Slaughter Horse Market Has Changed Since Domestic
Slaughter Ceased in 2007 10
Horse Welfare Has Reportedly Declined, Although the Extent Is
Unknown, Straining the Resources of State and Local
Governments, Tribes, and Animal Welfare Organizations 18
USDA’s Oversight of the Welfare of Horses Transported for
Slaughter Is Complicated by Three Challenges 27
Conclusions 42
Matters for Congressional Consideration 44
Recommendations for Executive Action 45
Agency Comments and Our Evaluation 46
Appendix I Objectives, Scope, and Methodology 47
Appendix II Results of the Econometric Analysis of
Horse Sale Prices 56
Appendix III Comments from the U.S. Department of Agriculture 59
Appendix IV GAO Contact and Staff Acknowledgments 61
Related GAO Products 62
Tables
Table 1: Estimates for Effect of Cessation of Slaughter and
Economic Downturn on Horse Sale Prices by Sale Price
Category, Spring 2004 through Spring 2010 18
Table 2: Semi-log Coefficients for Hedonic Quantile Regression of
Horse Prices 58

Contents
Page i GAO-11-228 Horse Welfare
Letter 1
Background 5
U.S. Slaughter Horse Market Has Changed Since Domestic
Slaughter Ceased in 2007 10
Horse Welfare Has Reportedly Declined, Although the Extent Is
Unknown, Straining the Resources of State and Local
Governments, Tribes, and Animal Welfare Organizations 18
USDA’s Oversight of the Welfare of Horses Transported for
Slaughter Is Complicated by Three Challenges 27
Conclusions 42
Matters for Congressional Consideration 44
Recommendations for Executive Action 45
Agency Comments and Our Evaluation 46
Appendix I Objectives, Scope, and Methodology 47
Appendix II Results of the Econometric Analysis of
Horse Sale Prices 56
Appendix III Comments from the U.S. Department of Agriculture 59
Appendix IV GAO Contact and Staff Acknowledgments 61
Related GAO Products 62
Tables
Table 1: Estimates for Effect of Cessation of Slaughter and
Economic Downturn on Horse Sale Prices by Sale Price
Category, Spring 2004 through Spring 2010 18
Table 2: Semi-log Coefficients for Hedonic Quantile Regression of
Horse Prices 58

Contents

Page iii GAO-11-228 Horse Welfare
Abbreviations
APHIS Animal and Plant Health Inspection Service
BLM Bureau of Land Management
CFIA Canadian Food Inspection Agency
FSIS Food Safety Inspection Service
OIG Office of Inspector General
SAGARPA Secretaría de Agricultura, Ganadería, Desarrollo Rural,
Pesca y Alimentación (Mexico)
TRAGIS Transportation Routing Analysis Geographic Information
System
USDA U.S. Department of Agriculture
This is a work of the U.S. government and is not subject to copyright protection in the
United States. The published product may be reproduced and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be

necessary if you wish to reproduce this material separately.

Page 1 GAO-11-228 Horse Welfare
United States Government Accountability Office
Washington, DC 20548
June 22, 2011
The Honorable Herb Kohl
Chairman
The Honorable Roy Blunt
Ranking Member
Subcommittee on Agriculture, Rural Development,
Food and Drug Administration, and Related Agencies
Committee on Appropriations
United States Senate
The Honorable Jack Kingston
Chairman
The Honorable Sam Farr
Ranking Member
Subcommittee on Agriculture, Rural Development,
Food and Drug Administration, and Related Agencies
Committee on Appropriations
House of Representatives
Many countries consider horsemeat an appropriate part of human diets—
and horsemeat was consumed in the United States as recently as the mid-
1940s. However, the slaughter of horses for any purpose, especially for
human consumption, is now a very controversial issue in the United
States, stemming largely from differences in how the country’s estimated 9
million horses are viewed. For example, some, including animal rights
advocates, horse enthusiasts, and some state governments, oppose horse
slaughter, citing the horse’s iconic role in helping to settle the American
West; its former importance as a work and transportation animal on farms
and in rural communities; and its continued value as a show, racing, and
recreation animal. Moreover, for many, horses are companion animals,
similar to dogs, cats, or other domestic pets. In contrast, others, including
the livestock and meatpacking industries and other state governments,
support horse slaughter, noting a strong export market for horsemeat; the
economic and employment benefits to local communities of horse
slaughtering facilities; and limited alternative options for dealing with
unwanted horses. Moreover, for many proponents of slaughter, horses are
livestock, similar to cattle, sheep, swine, and other farm animals raised to
produce commodities for human consumption. At present, horses are not
slaughtered in the United States due to an annual prohibition on the use of federal funds to inspect horses at slaughter. However, horses may be

purchased at auctions or other sales and exported for slaughter to Canada

Page 2 GAO-11-228 Horse Welfare
and Mexico. Horse slaughtering facilities in these countries generally
export the meat to consumer markets in Europe and Asia.
Aside from the question as to whether it is appropriate to slaughter horses for human consumption, both sides of this issue have raised concerns about
unintended consequences of the cessation of domestic slaughter. For
example, both sides note that horses intended for slaughter must now travel
much farther distances to foreign slaughtering facilities, potentially, during some part of that trip, in conveyances designed for smaller animals and
without adequate rest, food, and water. This controversy has also attracted
media attention, with reports of the inhumane treatment of horses during
transit or at foreign slaughtering facilities. For those who oppose horse
slaughter, the solution is to ban both domestic horse slaughter and trade in horsemeat or horses intended for slaughter for human consumption, effectively ending the export of horses intended for slaughter. Bills were
introduced in the 107th and 108th Congresses to create such a ban, but none
were enacted into law. In contrast, for those who support horse slaughter,
the solution is to reopen domestic slaughtering facilities. Although Congress
has not acted to create an explicit ban on horse slaughter, starting in fiscal
year 2006, it included language in annual appropriations bills that prohibits
the use of federal funds for inspection by the U.S. Department of Agriculture
(USDA) of horses in transit to slaughter and at slaughtering facilities.1 In
debating this provision in the House of Representatives, opponents argued
that it would not end horse slaughter, but instead would move this slaughter
across the borders, hurting horse welfare by increasing the distances horses would travel to slaughter. However, proponents of the provision countered
that there was no evidence of decreased horse welfare in states that had
banned slaughter.
As recently as 2007, three domestic horse slaughtering facilities—two in Texas and one in Illinois—continued to operate despite the prohibition on using federal funds for inspecting horses at slaughter. These facilities stayed
open by paying for these inspections under a voluntary fee-for-service
1Federal law requires that all U.S. horses slaughtered for human consumption and placed in

commerce be inspected.

Page 3 GAO-11-228 Horse Welfare
program implemented by USDA in February 2006.2 However, in 2007, all three
facilities closed when courts upheld state laws in Texas and Illinois
prohibiting sale or possession of horsemeat and horse slaughter, respectively.
New horse slaughtering facilities have, in effect, been prohibited from opening in other states since then because Congress has continued the annual
prohibition on the expenditure of federal funds to inspect horses at slaughter, and it added a prohibition on the use of federal funds, beginning in fiscal year 2008, for implementation of the fee-for-service program as well. Although the
domestic slaughter of horses for human food has stopped, USDA’s Slaughter Horse Transport Program (transport program) continues to operate. The
program, established in 2001, is intended to ensure that horses traveling to slaughter are fit to travel and handled humanely enroute. Among other things, the program collects and reviews shipping documents and inspects
conveyances used to transport these horses. However, because of the
prohibition on using federal funds for inspecting horses transported to
slaughter, the transport program may not inspect the condition of horses
designated for slaughter during their transport.
The Senate Committee on Appropriations directed that GAO examine the
status of horse welfare in the United States since horse slaughter
operations ceased in 2007.3 Our objectives to address this issue were to
examine (1) the effect on the U.S. horse market, if any, since domestic
slaughter for food ceased in 2007; (2) the impact, if any, of market changes
on horse welfare and on states, local governments, tribes, and animal
welfare organizations; and (3) challenges, if any, to USDA’s oversight of
the transport and welfare of U.S. horses exported for slaughter.
To address these objectives, we interviewed officials from USDA and other federal agencies, state and local governments, and tribes and
representatives from the livestock industry and animal welfare
organizations and reviewed the documents that they provided. We also
reviewed published literature addressing issues related to the horse industry
2This program enabled slaughtering facilities to pay for inspections of horses prior to
slaughter so that horses could continue to be processed for human consumption without the use of appropriated funds. It was established under the Agricultural Marketing Act, which authorizes a voluntary inspection service, on a fee-for-service basis, for agricultural
products. USDA has used this authority to provide inspections for animals it deems exotic,
including reindeer, elk, deer, antelope, and water buffalo. In 2006, USDA extended this
authority to horses. Meat inspected and passed under this authority is branded with a
USDA mark of inspection and can be sold interstate or exported.

3S. Rep. No. 111-39, at 44 (2009).

Page 3 GAO-11-228 Horse Welfare
program implemented by USDA in February 2006.2 However, in 2007, all three
facilities closed when courts upheld state laws in Texas and Illinois
prohibiting sale or possession of horsemeat and horse slaughter, respectively.
New horse slaughtering facilities have, in effect, been prohibited from opening in other states since then because Congress has continued the annual
prohibition on the expenditure of federal funds to inspect horses at slaughter, and it added a prohibition on the use of federal funds, beginning in fiscal year 2008, for implementation of the fee-for-service program as well. Although the
domestic slaughter of horses for human food has stopped, USDA’s Slaughter Horse Transport Program (transport program) continues to operate. The
program, established in 2001, is intended to ensure that horses traveling to slaughter are fit to travel and handled humanely enroute. Among other things, the program collects and reviews shipping documents and inspects
conveyances used to transport these horses. However, because of the
prohibition on using federal funds for inspecting horses transported to
slaughter, the transport program may not inspect the condition of horses
designated for slaughter during their transport.
The Senate Committee on Appropriations directed that GAO examine the
status of horse welfare in the United States since horse slaughter
operations ceased in 2007.3 Our objectives to address this issue were to
examine (1) the effect on the U.S. horse market, if any, since domestic
slaughter for food ceased in 2007; (2) the impact, if any, of market changes
on horse welfare and on states, local governments, tribes, and animal
welfare organizations; and (3) challenges, if any, to USDA’s oversight of
the transport and welfare of U.S. horses exported for slaughter.
To address these objectives, we interviewed officials from USDA and other federal agencies, state and local governments, and tribes and
representatives from the livestock industry and animal welfare
organizations and reviewed the documents that they provided. We also
reviewed published literature addressing issues related to the horse industry
2This program enabled slaughtering facilities to pay for inspections of horses prior to
slaughter so that horses could continue to be processed for human consumption without the use of appropriated funds. It was established under the Agricultural Marketing Act, which authorizes a voluntary inspection service, on a fee-for-service basis, for agricultural
products. USDA has used this authority to provide inspections for animals it deems exotic,
including reindeer, elk, deer, antelope, and water buffalo. In 2006, USDA extended this
authority to horses. Meat inspected and passed under this authority is branded with a
USDA mark of inspection and can be sold interstate or exported.

3S. Rep. No. 111-39, at 44 (2009).

Page 5 GAO-11-228 Horse Welfare
We conducted this performance audit from April 2010 through June 2011,
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
The Federal Agriculture Improvement and Reform Act of 1996 (1996 Farm Bill) authorized USDA to issue guidelines for the regulation of the
commercial transportation of horses and other equines for slaughter by
persons regularly engaged in that activity within the United States. The
statute gives USDA authority to regulate the commercial transportation of
equines to slaughtering facilities, which the statute indicates include
assembly points, feedlots, or stockyards. The authority to carry out this
statute was delegated to USDA’s Animal and Plant Health Inspection
Service (APHIS). Pursuant to this authority, APHIS issued a regulation,
“Commercial Transportation of Equines to Slaughter” (transport
regulation), in 2001. In 2001, APHIS also established the transport
program. This program seeks to ensure that horses being shipped for
slaughter are transported safely and humanely. In addition, USDA’s Food
Safety Inspection Service (FSIS) carries out the Humane Methods of
Slaughter Act and related regulations, which require the humane handling
of livestock, including horses, in connection with slaughter.5
APHIS’s transport regulation establishes a number of requirements that
owners/shippers (shippers) must meet for horses transported to slaughter. The regulation states that shippers must (1) provide horses with food,
water, and rest for at least 6 hours prior to loading; (2) provide horses
adequate floor space in whatever conveyance (e.g., a trailer) is being used;
(3) segregate all stallions and other aggressive equines; and (4) ensure that
trailers are free of sharp protrusions, are not double-decked, and have
adequate ventilation. If a trip is longer than 28 hours, horses must be
unloaded and provided at least 6 hours of food, water, and rest before
5For more information on the Humane Methods of Slaughter Act, see GAO, Humane
Methods of Slaughter Act: Weaknesses in USDA Enforcement, GAO-10-487T (Washington, D.C.: Mar. 4, 2010); Humane Methods of Slaughter Act: Actions Are Needed to Strengthen Enforcement, GAO-10-203 (Washington, D.C.: Feb. 19, 2010); and Humane Methods of
Slaughter Act: USDA Inspectors’ Views on Enforcement, GAO-10-244SP (Washington, D.C.: Feb. 19, 2010).

Background

Page 6 GAO-11-228 Horse Welfare
being reloaded. Horses cannot be shipped to slaughter unless they are
accompanied by an “Owner/Shipper Certificate—Fitness to Travel to a Slaughter Facility” (owner/shipper certificate) certifying that the horses
are fit for travel. The certificate must state that horses are over 6 months
of age, are not blind in both eyes, can bear weight on all four limbs, are
able to walk unassisted, and are not likely to foal (i.e., give birth) during
transport. Figure 1 provides an example of this certificate. Shippers found
to be in violation of the transport regulation can face penalties of $5,000

per horse, per violation.

Page 8 GAO-11-228 Horse Welfare
As of fall 2007, the last three horse slaughtering facilities in the United
States were closed following unsuccessful challenges to state laws
banning the practice. According to USDA data, those facilities, two in
Texas and one in Illinois, slaughtered almost 105,000 horses in 2006—the
last full year of operations—and exported more than 17,000 metric tons of
horsemeat, which was valued at about $65 million at that time. Regarding the Texas facilities, in January 2007, the U.S. Court of Appeals for the Fifth
Circuit ruled that a 1949 Texas law banning the sale or possession of
horsemeat applied to them. They ceased operations in May 2007.
Regarding the Illinois facility, the state enacted a law in May 2007 making
it illegal to slaughter horses for human consumption. In September 2007, the U.S. Court of Appeals for the Seventh Circuit upheld this slaughter
ban, and the Illinois facility ceased operations that month.
Since fiscal year 2006, Congress also has taken annual actions in
appropriations legislation that have effectively prevented the operation of horse slaughtering facilities in the United States by prohibiting USDA’s use
of federal funds to (1) inspect horses being transported for slaughter and (2) inspect horses intended for human consumption at slaughtering
facilities. The 1996 Farm Bill authorized the issuance of guidelines for the
regulation of the commercial transportation of equines for slaughter as
well as the conduct of any inspections considered necessary to determine
compliance. The Federal Meat Inspection Act requires inspection of
certain animals, including cattle, sheep, swine, goats, and horses, before
they are slaughtered and processed into products for human food to
ensure that meat and meat products from those animals are unadulterated,
wholesome, and properly labeled. However, Congress prohibited USDA
from using appropriated funds to pay for these inspections, effective 120
days after enactment of the fiscal year 2006 appropriations legislation on
November 10, 2005.
Following the prohibitions, the three domestic slaughtering facilities open
at that time petitioned USDA to create a voluntary fee-for-service
inspection program for horses prior to slaughter, and USDA created such a
program in early 2006, allowing required inspections, and, thus, domestic
slaughtering, to continue. The congressional prohibition on use of
appropriated funds continued in fiscal year 2007, but, as previously 

Page 9 GAO-11-228 Horse Welfare
discussed, the plants had already been shut down by state law that year.6
In fiscal year 2008, Congress renewed the prohibition on the use of
appropriated funds for inspections on horses being transported to
slaughter and at slaughtering facilities, and it added a new prohibition on
the use of appropriated funds for implementation or enforcement of the
fee-for-service program. These prohibitions were continued in fiscal years
2009 through 2011. These prohibitions notwithstanding, U.S. horses
intended for slaughter are still allowed to be transported within the United
States under the oversight of USDA’s transport program and exported to
slaughtering facilities in Canada and Mexico.
In September 2010, USDA’s Office of Inspector General (OIG) reported, in part, on the operations of the transport program.7 The OIG found that
APHIS needs to improve its controls for ensuring that horses being
shipped to foreign facilities for slaughter are treated humanely. For
example, APHIS does not deny authorization to shippers with a record of
inhumanely transporting horses intended for slaughter from shipping
other loads of horses, even if unpaid fines are pending for previous
violations. The OIG also found deficiencies in how APHIS tags horses that
have been inspected and approved for shipment to foreign slaughtering
facilities. For example, the agency requires shippers to mark such horses
with backtags, which are intended to allow APHIS to trace horses back to
their owner and also to verify that horses have passed inspection by an accredited veterinarian. However, APHIS lacked an appropriate control to
track individual horses by backtag number on approved shipping
documents so that it could perform reconciliations, investigate violations,
and initiate enforcement actions, as appropriate. In addition, the OIG
noted that APHIS needs to obtain the resources necessary to adequately
oversee the transport program and issue in final a proposed rule that
would broaden the scope of the agency’s regulation of horses being
shipped to foreign slaughtering facilities. In its official response to the OIG
report, APHIS concurred with the OIG’s findings and recommendations
6Two plants in Texas were effectively closed when a court there upheld a state statute
prohibiting the sale or possession of horsemeat. Empacadora de Carnes de Fresnillo, S.A.
de C.V. v. Curry, 476 F. 3d 326 (5th Cir. 2007). A plant in Illinois closed after a court there upheld a state statute prohibiting horse slaughter. Cavel Int’l v. Madigan, 500 F. 3d 551 (7th Cir. 2007).
7U.S. Department of Agriculture, Office of Inspector General, Animal and Plant Health
Inspection Service Administration of the Horse Protection Program and the Slaughter

Horse Protection Program, Audit Report 33601-2-CK (Washington, D.C.: Sept. 30, 2010).

Page 10 GAO-11-228 Horse Welfare
related to the transport program, and APHIS proposed specific actions and
time frames for implementing the recommendations.8 For example, APHIS
agreed to work with USDA’s Office of General Counsel and complete by
May 31, 2011, an evaluation of “the best options to revise regulations
necessary that will establish an agencywide policy that those who have
violated the humane handling regulations and failed to pay the associated penalties shall not receive endorsement of any subsequently requested
shipping documents.”
The U.S. slaughter horse market has changed since domestic slaughter for
food ceased in 2007, particularly in terms of increased exports to Canada
and Mexico and lower domestic sales and prices, especially for lower-
value horses, according to our analysis of available trade data and horse
auction sales data.
The number of horses slaughtered in the United States decreased from
1990 (345,900 horses) through 2002 (42,312 horses), according to available
data from USDA’s National Agricultural Statistics Service. At the same
time, the reported number of slaughtering facilities dropped from at least
16 U.S. facilities that operated in the 1980s to 7 facilities in 1994 to as few
as 2 in 2002. Beginning in 2003, however, the number of horses slaughtered
began rising through 2006, the last full year of domestic slaughtering
operations, when nearly 105,000 horses were slaughtered in the United
States. According to USDA officials, this increase can be explained, in part, by the reopening of a horse slaughtering facility in DeKalb, Illinois, in 2004 that increased domestic slaughtering capacity. This facility had been closed for 2 years following a fire set by anti-slaughter arsonists. Because
all domestic slaughtering facilities closed by September 2007, however, the
number of horses being slaughtered in the United States dropped to zero by the end of that year. Figure 2 shows the changes in the number of
horses slaughtered in the United States from 1990 through 2007.
8APHIS’s official response may be found at the end of the OIG report.
U.S. Slaughter Horse Market Has Changed
Since Domestic Slaughter Ceased in
2007
Horse Exports to Canada
and Mexico Have
Increased with the
Cessation of Domestic

Slaughter

Page 11 GAO-11-228 Horse Welfare
Figure 2: Number of Horses Slaughtered in the United States, 1990 through 2007
Before 2007, horses were slaughtered in domestic slaughtering facilities
only when the horsemeat was destined for consumption by humans or zoo
animals. Currently, pet food and other products, including glue, may still
be obtained from the corpses of horses that are hauled to rendering plants for disposal. The production of these products is not covered by the
requirements of the Federal Meat Inspection Act and is therefore not
affected by the current ban on the use of appropriated funds for the ante-
mortem inspection of horses destined for human consumption. According
to a transport program official, USDA is not aware of any domestic facility
slaughtering horses for any purpose, including for zoos, as of the end of
2010. USDA identified at least three establishments—in Colorado,
Nebraska, and New Jersey—that import horsemeat for repackaging and
distribution to purchasers in the United States who feed the meat to
animals at zoos and circuses.
With the cessation of domestic slaughter, U.S. exports of horses intended for slaughter increased to Canada and Mexico, the current locations of all
North American horse slaughtering facilities. As of the end of 2010,
Canada had four such facilities, and Mexico three, that were the principal destinations of U.S. horses exported for slaughter. According to USDA
officials, this increase in exports began, in part, because shippers were

*GRAFT NOT LEGIBLE OR UNABLE TO POST ON THIS BLOG*
0
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

Number of horses slaughtered
Source: GAO analysis of USDA’s National Agricultural Statistics Service data.
Year
Last full year of domestic slaughtering operations
345,900
276,700
243,500
169,900
107,000 109,200 105,000
87,200
72,120
62,813
47,134
56,332
42,312 50,062
66,183
94,037
104,899

29,767

Page 12 GAO-11-228 Horse Welfare
anticipating the closure of the three horse slaughtering facilities in the
United States at that time. From 2006 through 2010, Canadian and Mexican
imports increased by 148 percent and 660 percent, respectively, with the
total number of horses imported from the United States for slaughter
increasing from about 33,000 in 2006 to about 138,000 in 2010. In addition,
the total number of horses exported for all purposes, including breeding
and showing, also increased from 2006 through 2010, as shown in figure 3. According to USDA officials, some horses exported for purposes other
than slaughter were likely “feeder” horses that were ultimately sent to
slaughtering facilities at a later time. For example, feeder horses may be
sent to a Canadian or Mexican feedlot for fattening before subsequently
being sent to a slaughtering facility in that country. The extent to which
horses are exported as feeder horses is unknown, according to USDA
officials.
Figure 3: U.S. Exports of Horses Intended for Slaughter and Other Purposes, 2004
through 2010
Note: U.S. exports of horses intended for slaughter are unofficial estimates because official U.S.
export trade data do not specify the quantity or value of horses exported for slaughter. Thus, while
official U.S. trade data can be used to determine total U.S. live horse exports (the sum of horses
exported for slaughter or other purposes, such as breeding and showing), an estimate of horses
intended for slaughter can only be determined using Canadian and Mexican official trade statistics.

*GRAFT UNABLE TO POST ON THIS BLOG*
Quantity (head)
Calendar year
Sources: GAO analysis of Department of Commerce Foreign Trade data and USDA Foreign Agricultural Service documents.
For other purposes
For slaughter
0
50,000
100,000
150,000
200,000
250,000
300,000
350,000
2004 2005 2006 2007 2008 2009 2010
23,782 25,145 32,789
May—Two Texas slaughter facilities closed
September—Illinois slaughter facility
closed
99,172
78,061
99,049 109,487
137,984
56,414 51,635 61,223
154,126 148,827

168,011

Page 13 GAO-11-228 Horse Welfare
The total number of U.S. horses sent to slaughter in 2006, the last full year
of domestic slaughter, was comprised of horses slaughtered domestically
(i.e., 104,899, as shown in fig. 2) and those sent for slaughter in Canada or Mexico (i.e., 32,789, as shown in fig. 3)—for a total of 137,688 horses.
Taken together, the 137,984 U.S. horses that were sent to slaughter in
Canada or Mexico in 2010 is approximately equal to the total number of
horses slaughtered in 2006.
Additional certification may affect Canadian and Mexican exports of
horsemeat to Europe and, in turn, may affect the future export of horses
intended for slaughter from the United States to these countries. In 2010,
the European Union began prohibiting the importation of horsemeat from
horses treated with certain drugs and requiring countries to document
withdrawal periods for horses treated with other drugs before meat from
such horses could be imported to the European Union. Those regulations
precipitated similar regulations in Canada and Mexico. For example,
Canadian requirements went into effect on July 31, 2010, banning specific medications, such as phenylbutazone—the most common anti-
inflammatory medication given to horses—and requiring a 180-day withdrawal period for other medications, such as fentanyl, an analgesic.
Also, since November 30, 2009, Mexico has required an affidavit by
transporters that horses have been free from certain medications for 180
days prior to shipment. Furthermore, effective July 31, 2013, the European
Union will require lifetime medication records for all horses slaughtered in
non-European Union countries before accepting imports of horsemeat
from those countries. According to APHIS and horse industry sources,
these requirements could result in shippers certifying that their horses are
free of medication residues without having first-hand knowledge or
documentation of the horses’ status for the previous 180 days.
With regard to sales, many of the State Veterinarians said that fewer horse
sales have occurred and fewer auctions have operated within their states
since 2007, in part, because of lower horse prices and sale commissions
since the cessation of domestic slaughter. As a result, they said, horse
owners have fewer options for getting rid of horses they no longer want.
There also has been reduction in the number of commercial shippers
doing business since the cessation of slaughter. In reviewing USDA
documentation, we found that more than 110 shippers operated from 2005
through 2006—the 2 years prior to the cessation of domestic slaughter in
2007—and fewer than 50 shippers operated from 2008 through 2009. Some in the horse industry, as well as the State Veterinarians, generally
attributed this decrease to the closing of horse auctions around the
Horse Sales and Prices
Have Declined Since 2007,
Especially for Lower-
Valued Horses

Page 14 GAO-11-228 Horse Welfare
country, reflecting a smaller market and the lower profit margins resulting
from the increased costs of transporting horses intended for slaughter to
Canada and Mexico.
Horse industry representatives also stated that the closing of domestic
slaughtering facilities has dramatically affected the prices of horses.
National data on horse prices do not exist, but data from individual auctions are available. For example, the Billings, Montana, horse auction, one of the
nation’s largest, which also sells horses purchased for slaughter, reported a
large increase in the percentage of lower-priced horses sold—the type of
horse that typically ends up at slaughter—and a general decrease in sale
prices. In May 2005, approximately 25 percent of “loose” horses—less
expensive horses that are run through the auction ring without a rider or saddle—sold for less than $200 at that auction, whereas in May 2010, about
50 percent of loose horses sold for less than that amount.
The economic downturn in the United States that started in December
2007 also likely affected horse prices, according to the academic experts
and industry representatives we consulted. Since many U.S. horses are
used for recreational purposes, they are generally thought to be luxury
goods, and their ownership is sensitive to upturns and downturns in the
general economy. Furthermore, some horse sellers could no longer afford to keep their horses, and potential buyers also were not able to offer as
much to buy horses or were not in the market to purchase horses at all,
according to some industry observers. In particular, a considerable
number of horse owners are from lower-to-moderate income households
and are less able to withstand the effects of a recession, according to
academic experts. For example, one study estimated that up to 45 percent
of horse owners have an annual household income of between $25,000 and
$75,000.9 According to several State Veterinarians, those owners are more
likely to have problems affording the care of their horses during an
economic downturn.
To estimate the impact of the cessation of domestic slaughter on horse
prices, we collected price data on more than 12,000 sale transactions from spring 2004 through spring 2010 from three large horse auctions located in
the western, southern, and eastern United States. Our analysis of these
9Ahern, J., Anderson, D., Bailey, D., Baker, L., Colette, W., Neibergs, J., North, M., Potter, G.,
& Stull, C. (2006), “The Unintended Consequences of a Ban on the Humane Slaughter

(Processing) of Horses in the United States,” Animal Welfare Council, Inc.

Page 15 GAO-11-228 Horse Welfare
data controlled for the economic downturn and other factors that are
auction- and horse-specific, such as a horse’s breed/type, age, and gender, which may also affect prices.10 Horse sale prices ranged from a minimum
of $4 to a maximum of $48,500, with most of these sales clustered at the lower end of the price range. Figure 4 shows the distribution of these sales
prices, including the median and average price per head.
Figure 4: Distribution of Horse Prices from the Horse Auctions Used in the
Analysis, Spring 2004 through Spring 2010
Our analysis also shows a statistically significant reduction in average sale price across all price categories after the cessation of slaughter in 2007, as shown in figure 5.11 For example, the average sale price for horses in the
lowest price category (20th percentile), dropped by about $110 per head
(from $433 to $323), and the average price for the highest price category
(80th percentile) dropped by about $140 per head (from $2,380 to $2,241).
10The other variables that we considered included season of year of the auction, auction
location, and percentage of “no sales” (horses that did not receive a bid acceptable to the seller) for each auction.
11For the purpose of this discussion, we use the term “category” to refer generally to the quantiles of price from our analysis.
Percent of horses
Source: GAO analysis of horse auction sales data.

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Price (in dollars)
20
10
5
3
2
1 1 1 1
17
37
Median
Median
$1,400
per head
Average
Average
$2,140
per head
0
<2 percent
5,500
6,500
7,500
8,500
9,500
10,500
11,500
12,500
4,500
3,500
2,500
1,500
500
48,500
0
5
10
15
20
25
30
35

40

Page 16 GAO-11-228 Horse Welfare
Figure 5: Average Horse Prices Before and After Cessation of Horse Slaughter for
Each Price Category, Spring 2004 through Spring 2010
Using these data and regression methods to isolate the impact on prices
for specific variables, our analysis indicates that the cessation of domestic
horse slaughter led to an 8- to 21-percent decline—depending on sale
price—in the per head price of horses sold at those auctions.12 As
illustrated in figure 6, we estimate that price reductions were greatest, in
percentage terms, for lowest-priced horses, gradually declined as prices
increased, and became insignificant for horses in the higher price
categories. For example, the average per head price decreased by nearly
21 percent for horses in the lowest price category (20th percentile) and
about 8 percent at the median, whereas the price change per head was not
statistically significant for higher price categories.
12Specifically, we used an econometric model and hedonic quantile regression methods. For a more detailed explanation, see appendix I.

*GRAFT UNABLE TO POST ON THIS BLOG*
Source: GAO analysis of horse auction data.
0
250
500
750
1,000
1,250
1,500
1,750
2,000
2,250
2,500
20th 40th 50th 60th 80th
Before cessation (2004-2006)
After cessation (2007-2010)
Price per head (dollars)
Lower price category (percentile)Higher price category (percentile)
784
1,178
1,537
2,241
323
891
1,340
2,380
433

1,684

Page 17 GAO-11-228 Horse Welfare
Figure 6: Estimates of the Effect on Horse Prices from Closing Domestic
Slaughtering Facilities and the Economic Downturn for Each Price Category, Spring
2004 through Spring 2010
In contrast to the effects of closing slaughtering facilities—where the
percentage decrease in prices for lower-priced horses was greater than
that for higher-priced horses—our estimates show that the economic
downturn (represented by the change in the average unemployment rate
for the region where the auction was held) was associated with a
consistent decline of about 5 percent in price across all price categories
for those auctions. Table 1 provides our estimates of the price change per
head (in dollars and percentage decline) associated with the cessation of
slaughter and the economic downturn, along with the average sale price for each price category.

*GRAFT UNABLE TO POST ON THIS BLOG*
Source: GAO analysis of horse auction data.
-25
-20
-15
-10
-5
0
5
10
15
20
25
20th 40th 50th 60th 80th
Effect (percent change)
Lower price category (percentile)Higher price category (percentile)
Effect on price from closing
horse slaughter facilities
Effect on price from economic downturn
NS
Not significant
-20.93%
-10.42%
-7.83%

NS NS

Page 18 GAO-11-228 Horse Welfare
Table 1: Estimates for Effect of Cessation of Slaughter and Economic Downturn on Horse Sale Prices by Sale Price Category,
Spring 2004 through Spring 2010
Effect by sale price category (percentile)
Variable Type of change 20th 40th50th (median) 60th 80th
Price change -$125.61 -$104.24-$109.58 a a Cessation of slaughter on
horse prices (per head) Percentage change -20.93 -10.42 -7.83 a a
Price change -$30.90-$52.26-$67.22 -$82.09-$142.91 Economic downturn on
horse prices (per head) Percentage change -5.15-5.23 -4.80 -4.69 -4.76
Upper bound for category
(price per head)
$600$1,000$1,400 $1,750$3,000
Source: GAO analysis of data from selected horse auctions and the Department of Labor’s Bureau of Labor Statistics.
aThe effect on price was not statistically significant for that category. These estimates suggest that the closing of domestic horse slaughtering
facilities had a significant and negative impact on horse prices at the low-
to-mid levels of price at these auctions, while relatively higher-priced
horses appear not to have lost their value due to the cessation of slaughter.
Appendix II provides further details on the results of our analysis.
Horse welfare in the United States has generally declined since 2007, as
evidenced by a reported increase in horse abandonments and an increase
in investigations for horse abuse and neglect. The extent of the decline is
unknown due to a lack of comprehensive, national data, but state officials
attributed the decline in horse welfare to many factors, but primarily to
the cessation of domestic slaughter and the U.S. economic downturn.
Abandoned, abused, and neglected horses present challenges for state and local governments, tribes, and animal welfare organizations. In response,
some states and tribes have taken several actions to address these
challenges and the demand on their resources.
Horse Welfare Has
Reportedly Declined,
Although the Extent
Is Unknown, Straining
the Resources of State
and Local
Governments, Tribes,
and Animal Welfare

Organizations

Page 19 GAO-11-228 Horse Welfare
In interviewing the 17 State Veterinarians, we asked whether the states
had data for cases of horse abandonments, abuse, and neglect. Most
veterinarians from these states, including some with the largest horse
populations—California, Florida, and Texas—said they do not routinely
collect such data because, in part, their resources are limited and
jurisdiction of animal welfare is usually a local (e.g., county) responsibility. Nearly all the State Veterinarians, however, reported
anecdotes indicating that cases of abandonments and abuse or neglect
have increased in recent years. For example, several State Veterinarians,
including those from California, Florida, and Texas, reported an increase
in horses abandoned on private or state park land since 2007, although
specific data quantifying those abandonments were not available.
In addition, states that do collect some data reported increases in
abandonments or investigations of abuse and neglect since the cessation of domestic slaughter. For example, data from Colorado showed a 50-
percent increase in investigations for abuse and neglect from 1,067 in 2005 to 1,588 in 2009. Similarly, data from Indiana indicated that horse abuse
and neglect investigations more than doubled from 20 in 2006 to 55 in
2009. In addition, organizations representing localities, especially counties
and sheriffs, have reported an increasing problem. For example, the
Montana Association of Counties reported that the number of horses being
abandoned by their owners has rapidly increased since horse slaughter for
human consumption was halted in the United States, but the association
did not have specific data. In addition, the National Association of
Counties reported that the increasing abandonment problem is not
exclusive to Montana or the West but is happening nationwide.
We also asked the 17 State Veterinarians whether horse welfare, in
general, had improved, declined, or remained about the same in their
states over the last 5 years. Without exception, these officials reported that
horse welfare had generally declined, as evidenced by a reported increase
in cases of horse abandonment and neglect. They most frequently cited
two factors that contributed to the decline in horse welfare—the cessation of domestic slaughter in 2007 and the economic downturn—although they
generally were careful not to pin the decline on any single factor. Other
factors that they generally cited include poor weather conditions (e.g.,
drought in western states); the cost of horse disposal methods (e.g.,
veterinarian-assisted euthanasia); the increasing costs of feeding and
caring for horses; and the lack of auction markets to sell horses.
Cases of Horse
Abandonments, Abuse,
and Neglect Have
Reportedly Increased
Since 2007
State Veterinarians
Attributed Decline in
Horse Welfare Primarily to
Cessation of Slaughter and
Economic Downturn, but
Representatives of Animal
Welfare Organizations
Question Cessation’s

Impact

Page 20 GAO-11-228 Horse Welfare
Among the factors affecting horse owners, the State Veterinarians said a
horse owner’s decision to abandon a horse generally related to (1)
cessation of domestic slaughter, (2) poor economic conditions, and (3)
low horse prices or lack of sale opportunities. They also said the factors
most often related to a horse owner’s neglect of a horse were (1) poor
economic conditions, (2) the cost of horse care and maintenance, and (3)
lower horse prices. Several State Veterinarians pointed out that, in their
professional experience, very few owners directly physically abuse their
horses, which would be a crime. More common, however, were owners
who neglected the feeding and proper care—such as providing farrier
services (i.e., hoof care) and vaccinations—of their horses. Thus, based on the information these officials provided, the primary drivers for the
increase in abandonment and neglect cases are the cessation of domestic
slaughter, causing lower horse prices and difficulty in selling horses, and
the economic downturn, affecting horse owners’ ability to properly care
for their animals. As discussed, our analysis also showed that the
cessation of slaughter and the economic downturn generally reduced
horse prices at our selected auctions; in particular, the cessation affected
prices for the low-to-mid range priced horses that are more frequently abandoned and neglected. Furthermore, regarding neglect, some State
Veterinarians, noting that people are more inclined to take care of that
which has value, said that the drop in horse prices affected some owners’
interest in caring for their animals, especially if their financial situation
had declined.
With regard to the entities most affected by the increase in abandoned and
neglected horses, the State Veterinarians generally said that counties,
including sheriffs, bear the responsibility for investigating potential cases
affecting horse welfare. Many State Veterinarians, particularly from western states, indicated that their offices did not have the resources to
support the counties beyond providing expert veterinary advice regarding
conditions of abandoned and neglected horses, such as opining on a

horse’s nutritional status (known as “body scoring”).

Page 21 GAO-11-228 Horse Welfare
State and local governments, tribes, and animal welfare organizations,
especially horse rescues, are facing growing pressures to care for
abandoned and neglected horses at a time of economic recession and tight
budgets. According to the State Veterinarians, counties and animal welfare
organizations bear the costs of collecting and caring for abandoned
horses, while county governments generally bear the costs of investigating
reports of neglect. These officials said horse rescue operations in their
states are at, or near, maximum capacity, with some taking on more
horses than they can properly care for since the cessation of domestic
slaughter. One State Veterinarian added that his office is reluctant to
pressure horse rescues in his state to take on additional animals because
of this problem, even though alternatives are lacking. Some State
Veterinarians also described situations in which counties and sheriff
departments were reluctant to investigate reports of abandoned or
neglected horses because these jurisdictions lacked resources to deal with
the consequences of finding such animals. In some cases, these officials
said local jurisdictions may lack the resources even to initiate such
investigations, let alone to take possession of and care for these animals.
And in cases where an investigation results in horse seizures, local
jurisdictions may have to appeal for the public’s help in caring for the
animals. For example, the Montana State Veterinarian and his staff
described a recent situation in their state involving the seizure of hundreds
of neglected horses, many of which had low body scores and would not
have survived the winter without intervention. These horses were seized
from a ranch owner near Billings, Montana, in January 2011 who was no
longer able to afford their care. Because of the strain placed on state and county resources to care for so many animals, these jurisdictions had to
seek private donations of hay to feed these horses. Figure 7 shows some of
the horses seized in this case.
State and Local
Governments, Tribes, and
Animal Welfare
Organizations Are Affected
by Neglected and
Abandoned Horses, as Is

the Federal Government

Page 22 GAO-11-228 Horse Welfare
Figure 7: A Band of Horses, Some of Hundreds That Have Been Neglected on
Montana Ranchland and Seized by the County after the Collapse of Their Owner’s
Ranching Company
Tribes also reported increases in abandonments on their land,
exacerbating the overpopulation of horse herds on tribal lands. According to 2009 data from the Northwest Tribal Horse Coalition (now the National
Tribal Horse Coalition), the number of horses on its tribal lands exceeded
30,000 horses. When we met with representatives of tribes in the western
United States, they showed us significant degradation of their lands as a
result of the over-grazing by large populations of wild horses, as shown in
figure 8. They explained that the increase in abandoned horses on their
lands has compounded the challenge of restoring native and religiously-
significant species of plants to their land—an effort often paid for, in part,
by the federal government. Moreover, domesticated horses abandoned on
public lands generally have poor survival prospects, according to officials from the Department of the Interior’s Bureau of Land Management (BLM).
These horses are unfamiliar with which wild plants are edible and are
likely to be shunned or hurt by wild horses. These abandoned horses may
also introduce diseases to wild herds.

Source: Larry Mayer/Billings Gazette. Photo used with permission.
*photo not published here*

Page 23 GAO-11-228 Horse Welfare
Figure 8: Wild Horse Herd on Degraded Land Owned by the Yakama Nation in Washington State The effects of the increasing number of abandoned or neglected horses
have been felt by local animal welfare organizations as well—in particular,
the horse rescues and local societies for the prevention of cruelty to
animals that work with local officials to place such horses, according to
the State Veterinarians. The total number of rescues and their capacities is
unknown because there is no national registry or association for horse
rescues. However, both the National Association of Counties and the
Unwanted Horse Coalition estimated that the nationwide capacity of
rescue facilities is about 6,000 horses. They also reported that the vast
majority of these facilities are already full. Some State Veterinarians told
us that some rescue organizations have taken on more horses than they can properly care for, especially in an economic environment in which
donations have declined; as a result, horses at some of these organizations’
facilities have been seized. For example, it has been reported that horse
rescues in California, Florida, New York, and West Virginia have recently

Source: GAO.

Page 24 GAO-11-228 Horse Welfare
had their animals seized by local authorities because they were not
properly caring for them, and others in New Hampshire and Pennsylvania closed due to financial difficulties.
In addition, the increase in unwanted domesticated horses available for
sale or being abandoned on public lands is affecting the federal
government’s ability to manage wild horse and burro populations. Most of these wild animals are found on lands managed by BLM and USDA’s
Forest Service in the western United States.13 From 1971 through 2007,
BLM removed over 267,000 wild horses and burros from these lands, and during the same period, approximately 235,700 of these animals were
adopted by the public under a BLM program that promotes these
adoptions. As we reported in 2008, BLM has, however, experienced a
steady decline in adoptions in recent years, which agency officials
attributed, in part, to the large number of domesticated horses flooding the
market.14 More recently, BLM officials said that annual adoptions had
fallen from about 8,000 in 2005 to about 3,000 in 2010. In an October 2010
Web message, the BLM Director estimated that the number of horses and
burros on lands the agency manages exceeds by about 12,000 the number
that would allow these lands to remain sustainable for other uses and
species.15 According to BLM officials, in addition to natural reproduction in
wild horse and burro herds, the increasing number of domesticated horses
being abandoned on public lands has contributed to this overpopulation
problem.
Other officials, including those from animal welfare organizations,
questioned the relevance of the cessation of domestic slaughter to the rise
in abandoned and neglected horses, which they attributed more to the
economic downturn. For example, in March 2010, Animal Welfare Institute
representatives said that since a 1998 California ban on dealing in horses
intended for slaughter, their organization has offered a $1,000 reward for
13BLM estimates, as of October 2010, that it is managing about 38,400 free-roaming wild
horses and burros on these lands, and it also is holding about 37,000 additional horses and
burros removed from these lands in short- and long-term holding facilities. BLM estimates
its feeding and care of animals in holding facilities cost the federal government more than
$36 million annually, more than half the wild horse and burro program’s budget in fiscal
year 2010.
14GAO, Bureau of Land Management: Effective Long-Term Options Needed to Manage
Unadoptable Wild Horses, GAO-09-77 (Washington, D.C.: Oct. 9, 2008).
15This Web message is available at http://www.blm.gov/wo/st/en/prog/

wild_horse_and_burro/national/about/director.print.html.

Page 25 GAO-11-228 Horse Welfare
notification of abandoned horses but has never received a tip. In addition, the Humane Society of the United States and the United Animal Nations
reported that there has been no documented rise in abuse and neglect
cases in California since the 1998 ban. United Animal Nations also
reported there was no documented rise in abuse and neglect cases in
Illinois following the 2-year closure of the horse slaughtering facility in
that state in 2002. Furthermore, Humane Society of the United States
officials said that owners who abandon horses are going to abandon them
regardless of having the option for domestic slaughter, adding that there were instances of horse abandonment near domestic horse slaughtering
facilities before they closed. These officials acknowledged that there are
no good data on horse abandonments but noted an increase in
abandonments of all kinds of domesticated animals as the economy
worsened.
Some states took actions related to horse welfare and slaughter even
before the cessation of domestic slaughter in 2007. For example, in 1998,
California made it illegal to export horses for the purpose of having them
slaughtered for human consumption outside the state. Specifically,
California law makes it unlawful for any person to possess; to import into
or export from the state; or to sell, buy, give away, hold, or accept any
horse with the intent of killing or having another kill that horse, if that
person knows or should have known that any part of that horse will be
used for human consumption. Several state officials told us that this ban is
difficult to enforce because it may be difficult to show when an owner
knew or should have known that a buyer intended that animal for
slaughter. For example, if an owner transports a horse to an auction in
another state (e.g., Montana or Texas), it may be difficult to prove that the
owner specifically intended to sell the horse for slaughter or should have
known that the buyer of the horse intended to sell the horse for slaughter.
In addition, since 2007, states and tribes have taken a variety of legislative
or other actions related to horse welfare or slaughter. For example, in
2009 Montana passed a law that allows horse owners to surrender horses
that they cannot afford to maintain to the state at a licensed livestock
market without being charged with animal cruelty. Also, Colorado
authorized the inclusion of a checkbox on state income tax return forms
allowing taxpayers to make a contribution to the Colorado Unwanted
Horse Alliance. In authorizing the program, the Colorado legislature found
that the number of unwanted horses is increasing; most horse rescue
facilities are operating at capacity and have limited ability to care for
additional horses; and incidences of horse abuse and neglect are rising. 

Page 26 GAO-11-228 Horse Welfare
addition, Kentucky passed a law in the spring of 2010 creating the
Kentucky Equine Health and Welfare Council and charged it with
developing regional centers of care for unwanted, abused, neglected, or
confiscated equines; creating a system of voluntary certification of equine rescue and retirement operations; and suggesting statutory changes
affecting equine health, welfare, abuse, and neglect issues. Also, in 2009,
the National Congress of American Indians and the Northwest Tribal
Horse Coalition passed resolutions supporting domestic slaughter to
manage overpopulated horse herds. A number of the 17 states that we
examined have also enacted laws related to horse welfare and slaughter
since the cessation of domestic slaughter. For example:
• Arkansas, Oklahoma, Utah, and Wyoming passed resolutions urging
Congress to facilitate the resumption of horse slaughtering in the
United States and oppose federal legislation that would ban domestic
slaughter. North Dakota and South Dakota passed similar resolutions
urging Congress to reinstate and fund federal inspection programs for
horse slaughter and processing.
• Montana passed a law that would make it easier to establish a horse
slaughtering facility by making it harder for those opposing such a
plant to get an injunction against it while challenging various permits
that the plant would need to operate. In his 2009 testimony in support
of the bill, the chair of Montana’s Farm Bureau cited rising numbers of
unwanted horses and associated costs.
• Wyoming amended its existing law to provide that strays, livestock, and
feral livestock, including horses, may be sent to slaughter as an
alternative to auction or destruction. The legislative changes also
provided that the state could enter into agreements with meat
processing plants whereby meat from livestock disposed of by
slaughter could be sold to state institutions or nonprofits at cost or to
for-profit entities at market rate.
Several states are seeking to reopen domestic horse slaughter facilities,
under a provision of the Food, Conservation, and Energy Act of 2008,
which authorized USDA to establish a new voluntary cooperative program
under which small state-inspected establishments would be eligible to ship meat and poultry products in interstate commerce. USDA recently
finalized a rule to implement the program, but USDA officials said that the
rule does not include horsemeat, because recent appropriations legislation
has prohibited the use of federal funds for inspecting horses prior to

slaughter. And although, under the proposed program, the inspections

Page 27 GAO-11-228 Horse Welfare
would be done by state officials, federal law requires USDA to reimburse
the state for at least 60 percent of the associated costs. However, as noted
by USDA officials, the prohibition in appropriations legislation against
using federal funds for inspecting horse at slaughter would preclude these
reimbursements. USDA officials said the same issue would preclude tribal slaughtering facilities from shipping horsemeat in interstate or
international commerce as well.
USDA faces three challenges in its oversight of the welfare of horses
during their transport for slaughter. First, APHIS faces several specific
management challenges in implementing the transport program. Second,
legislative prohibitions on using federal funds for inspecting horses prior
to slaughter impede USDA’s ability to ensure horse welfare. Third, the
cessation of domestic slaughter has diminished APHIS’s effectiveness in
overseeing the transport and welfare of horses intended for slaughter.
Several management challenges are affecting APHIS’s implementation of
the transport program. These challenges include (1) delays in issuing a
final rule to give the agency greater oversight over horses transported for
slaughter to protect their welfare; (2) limited staff and funding that
complicates the agency’s ability to ensure the completion, return, and
evaluation of owner/shipper certificates; and (3) a lack of current, formal
agreements with Canadian, Mexican, and state officials whose cooperation
is needed for program implementation.
APHIS’s transport regulation sets minimum care standards to protect
horse welfare, but it applies only when the horses are being moved
directly to slaughtering facilities, at which point shippers designate the
horses as “for slaughter” on an owner/shipper certificate and move the
horses directly to slaughtering facilities. Consequently, the regulation does
not apply to horses that are moved first to an assembly point, feedlot, or
stockyard before going to slaughter. For example, a horse’s journey to
slaughter may have covered several states, from point-of-purchase at an
auction to an assembly point, such as a farm; from the assembly point to a
feedlot or stockyard; and from the feedlot or stockyard to a point near a
slaughtering facility or a border crossing where the slaughter designation
was first made.
USDA’s Oversight of
the Welfare of Horses
Transported for
Slaughter Is
Complicated by Three
Challenges
Management Challenges
Affect APHIS’s
Implementation of the
Slaughter Horse Transport
Program
APHIS Has Not Issued a Final
Rule to Better Protect Horses

Transported for Slaughter

Page 28 GAO-11-228 Horse Welfare
In reviewing a generalizable sample of nearly 400 owner/shipper
certificates from before and after cessation of domestic slaughter in 2007,
we found that shippers usually designated horses as “for slaughter” on the
final leg of their journey to a slaughtering facility, as allowed under the
current regulation. For example, prior to cessation in 2007, shippers
sometimes designated horses near the U.S. facility in which they would be slaughtered. Specifically, we found cases in which horses shipped to the
slaughtering facility in DeKalb, Illinois, were designated for slaughter at a
point just a few miles from the plant. Similarly, since cessation in 2007,
shippers sometimes made this designation near border crossings with
Canada or Mexico. For example, since cessation, we found shipments of
horses being designated for slaughter in Shelby, Montana, about 36 miles
from the border crossing into Canada and in El Paso, Texas, about 10
miles from where they cross the border into Mexico. According to APHIS
officials, in virtually all of these cases, without a “for slaughter”
designation, it is likely that before reaching these designation points, the
horses already had traveled for long distances within the United States
without the protection of the APHIS transport regulation to ensure their
humane treatment. For example, some of the horses may have been
transported in double-deck trailers intended for smaller livestock animals; as discussed, the APHIS transport regulation prohibits the use of this type of trailer after the designation for slaughter is made.
To address this issue, APHIS proposed, in November 2007, to amend the
existing transport regulation to extend APHIS’s oversight of horses
transported for slaughter to more of the transportation chain that these
horses pass through. The proposed rule defines equine for slaughter as an
equine transported to intermediate assembly points, feedlots, and
stockyards, as well as directly to slaughtering facilities.16 The current
regulation does not define equine for slaughter and only applies to those
equines being transported directly to slaughtering facilities. APHIS has
experienced repeated delays in issuing a final rule that would extend
APHIS’s oversight of horses being transported for slaughter. According to
USDA officials, the delay is the result of a number of factors, including,
competing priorities and the need to address substantive, public
comments on the proposed rule that resulted in reclassifying it as
16This proposed regulatory change is consistent with the definition of equine for slaughter

in the Federal Agriculture Improvement and Reform Act of 1996.

Page 29 GAO-11-228 Horse Welfare
significant under Executive Order 12866.17 As of June 2011, USDA officials
said they anticipate issuing the final rule by the end of calendar year 2011. APHIS officials noted that this change to the transport regulation could
help address another issue as well. Specifically, the regulation currently
does not apply to shippers transporting horses to Canada as feeder
horses.18 As discussed, some U.S. horses exported for purposes other than
slaughter (i.e., not designated for slaughter on an owner/shipper
certificate) may be feeder horses that are ultimately sent to slaughtering
facilities at a later time. According to APHIS officials, the number of feeder
horses has likely grown with the increase in total horse exports to Canada
since 2007. Because feeder horses are not designated for slaughter before crossing the border, they are not covered by the transport regulation at
any point in their journey. If the transport regulation is amended, however,
as APHIS has proposed, the designation “equine for slaughter” would
apply to these animals during the leg of their trip from the U.S. auction
where they were purchased to the border crossing, including any
intermediate stops within the United States at assembly points, feedlots,
and stockyards. Such a designation would place those animals under the
protection afforded by APHIS’s oversight. APHIS officials also noted that
the provision of the 1996 Farm Bill authorizing the transport regulation is the only federal statute that regulates the transportation of horses, and
they commented on the irony that horses designated for slaughter are
provided greater protection, under current federal law and the transport
regulation, than other horses in commercial transit.
Over the past 6 fiscal years, the transport program’s annual funding has
varied, generally declining from a high of over $306,000 in fiscal year 2005
to about $204,000 in fiscal year 2010. This funding primarily provides for
the salaries and expenses of two staff, one of whom is the national
compliance officer, who inspects conveyances and owner/shipper
17Executive Order 12866 defines significant regulatory actions as those that are likely to
result in a rule that may, among other things, raise novel legal or policy issues arising out of
legal mandates, the President’s priorities, or the principles set forth in the order. Such rules
require additional review by the Office of Information and Regulatory Affairs within the Office of Management and Budget.
18Shippers may send horses across the border as “feeder” horses to a feedlot to add weight
to these animals, enhancing their slaughter value. Moreover, as a practical matter, because
of the European Union’s new restrictions on drug residues in horsemeat, it may be
necessary to hold U.S. horses at a Canadian feedlot for several months before slaughtering
to ensure they are purged of drug residues.
Limited Staff and Funding
Complicates Program

Implementation

Page 30 GAO-11-228 Horse Welfare
certificates for compliance with the transport regulation, with the
remainder going to travel costs.19 The two program officials stated that the program’s limited funding, particularly for travel, has significantly
curtailed their ability to provide coverage at border crossings and to work
with shippers and inspectors in foreign slaughtering facilities to ensure
compliance with the transport regulation. For example, with one
compliance officer, the program cannot adequately cover the numerous
border crossings on the Canadian and Mexican borders through which
shipments of horses intended for slaughter move. In April 2011, transport
program officials said they recently had begun training inspectors in
APHIS’s Western region and Texas area office to assist the program at
southern border crossings by, in part, collecting owner/shipper certificates
and returning them to APHIS headquarters. However, these officials said
they did not have a written plan or other document that describes this
initiative, including the number of staff to be involved, their anticipated
duties to support the transport program, and the time frames for
implementing the initiative. Hence, while this appears to be a positive step,
we were unable to evaluate the potential usefulness of this initiative.
Figure 9 provides information on the transport program’s funding for fiscal
years 2005 through 2010.
19The Compliance Officer’s duties include inspecting paperwork and conveyances at U.S.
border crossings and other inspection points and visiting auctions to work with

owner/shippers to gain compliance with the regulation.

Page 31 GAO-11-228 Horse Welfare
Figure 9: Slaughter Horse Transport Program’s Budget Obligations, Fiscal Years
2005 through 2010
According to program officials, the reduction in funds in 2009 was the result
of a cut in travel funds that were allocated to other APHIS programs. The
program officials added that the seesaw nature of the program’s funding, as well as the fact the program has just two staff, has affected their ability to ensure compliance with, and enforce, the transport regulation and
contributed to year-to-year variations in the number of violations found. In
addition, because of limited staff and funding, APHIS stopped entering
information from owner/shipper certificates into an automated database in 2005. Agency officials said that the database was used in the early years of
the transport program to document demographic information, such as the
identity of shippers and origin of horses they shipped. However, after
several years, this information was well established, and there was no need
to continue to collect data for this purpose. They also said that the database did not provide beneficial information for protecting horse welfare that justified the cost of maintaining the database. Nonetheless, automating the
certificate data would make it easier for the agency to analyze them to, for
example, identify potential problem areas for management attention and
possible enforcement action, such as patterns of violations or other
problems associated with particular shippers, border crossings, or slaughtering facilities. It would also allow the agency to easily identify
buying trends and common shipping routes. Furthermore, automating data
Obligations (in dollars)

*GRAFT UNABLE TO PUBLISH ON THIS BLOG*
Source: USDA’s Slaughter Horse Transport Program.
Fiscal year
306,475.01
0
50,000
100,000
150,000
200,000
250,000
300,000
350,000
2005 2006 2007 2008 2009 2010
269,901.69
216,456.02
256,505.31
204,189.33

118,876.82


Page 32 GAO-11-228 Horse Welfare
from the certificates on the number of horses in each shipment could
potentially provide USDA a more accurate count of the number of U.S.
horses exported for slaughter. At present, to estimate the number of horses
exported for this purpose, USDA’s Foreign Agricultural Service pieces
together Canadian and Mexican data on horses imported for slaughter and
makes certain extrapolations to arrive at an approximate number since no
official U.S. trade data exist on horses exported for slaughter.
Federal internal control standards call for agencies to obtain, maintain,
and use relevant, reliable, and timely information for program oversight
and decision making, as well as for measuring progress toward meeting
agency performance goals.20 Furthermore, the Office of Management and
Budget’s implementing guidance directs agency managers to take timely
and effective action to correct internal control deficiencies.21 APHIS’s lack
of a reliable means of collecting, tracking, and analyzing owner/shipper
certificates constitutes an internal control weakness and leaves the agency without key information and an important management tool for
enforcement of the transport regulation.
With the cessation of domestic slaughter and the transport program’s
limited staff and funding, APHIS relies on the cooperation of officials from Canada and Mexico working at border crossings and in their countries’
slaughtering facilities to help the agency implement the transport regulation.
APHIS has sought similar cooperation from officials working for the Texas
Department of Agriculture regarding horses exported through Texas border crossings. The effectiveness of these cooperative arrangements has been
uneven, in part because APHIS lacks current, formal written agreements
with its foreign and state counterparts to better define the parameters of this cooperation and ensure continuity over time as the personnel involved
change. We have previously reported that by using informal coordination
mechanisms, agencies may rely on relationships with individual officials to
ensure effective collaboration and that these informal relationships could
end once personnel move to their next assignments.22
20GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1
(Washington, D.C.: November 1999).
21Office of Management and Budget, Executive Office of the President, OMB Circular No.
A-123, Management’s Responsibility for Internal Control (Dec. 21, 2004).
22GAO, National Security: Key Challenges and Solutions to Strengthen Interagency
Collaboration, GAO-10-822T (Washington, D.C.: June 9, 2010).
Uneven Cooperation with
Canadian, Mexican, and State

Officials Impedes Oversight

Page 33 GAO-11-228 Horse Welfare
Regarding Canada, representatives of APHIS and the Canadian Food
Inspection Agency (CFIA) signed a letter of intent in October 2002 outlining their shared responsibilities for enforcement of the transport
regulation. Each country pledged to help the other enforce its regulations.
For example, to assist APHIS, CFIA agreed to ensure, either at points of
entry or slaughtering facilities, the following regarding shipments of U.S.
horses to Canada for slaughter:
• health certificates for the horses are endorsed by USDA-accredited
veterinarians within the 30 days prior to export;
• horses are clinically healthy, fit for travel, and transported humanely to
the points of entry;
• owner/shipper certificates are properly completed, including the date, time, and location the horses were loaded;
• horses are listed correctly on the owner/shipper certificate, so that for
example, the backtags on the horses match the backtags listed on the
certificate;
• an ante-mortem inspection of each horse is performed;
• date and time the shipment arrived at the facility is noted on the
certificate; and
• copies of all relevant documents (e.g., owner/shipper certificates) are
returned to APHIS each month.
APHIS officials said they rely on owner/shipper certificates, properly
completed by shippers and CFIA officials, as appropriate, and returned by CFIA to APHIS for compliance and enforcement purposes. For example,
APHIS needs information on the timing of the loading and off-loading of a
shipment of horses to assess whether a shipper complied with regulatory
requirements related to the amount of time a shipment is in transit. Figure
10 highlights sections of the owner/shipper certificate that are to be

completed by shippers or Canadian or Mexican officials.

Page 35 GAO-11-228 Horse Welfare
In reviewing a generalizable sample of certificates returned by CFIA from 2005 through 2009, however, we found instances in which certificates
were not properly completed by either the shipper or CFIA officials. Based
on the results of our review, we estimate that about 52 percent of
certificates were missing key information that should have been filled in
by either the shipper (e.g., loading date and time, or certification that the
horses were fit for transport) or CFIA (e.g., arrival date and time, or
slaughtering facility identification). In addition, we estimate that about 29
percent of certificates returned to APHIS were missing some or all of the
information to be provided by CFIA officials at the slaughtering facility.23
Moreover, in our review of these certificates we noted that the extent to
which they were returned incomplete from CFIA to APHIS increased over
time. For example, from 2005 through 2006, the 2 years prior to the
cessation of domestic slaughter in the United States, we estimate that
about 48 percent of certificates were missing key information that should
have been completed by either the shippers or CFIA officials. However,
from 2008 through 2009, the 2 years after the cessation, we estimate that
about 60 percent of certificates were missing key information.24 This
increase suggests that the growth in U.S. horse exports for slaughter since
the cessation has been accompanied by an increase in problems with
owner/shipper certificates needed by APHIS for enforcement purposes.
However, APHIS and CFIA have not revisited this agreement since 2002 to
reflect changes since the cessation of slaughter in 2007, when the volume of horses exported to Canada increased significantly and APHIS became
more dependent upon cooperation from Canadian border officials and
CFIA inspectors in slaughtering facilities.
Regarding Mexico, APHIS lacks a written agreement with its relevant counterpart, Mexico’s Secretaría de Agricultura, Ganadería, Desarrollo
Rural, Pesca y Alimentación (SAGARPA), to promote cross-border
cooperation.25 APHIS officials said that they drafted an agreement in 2002,
similar to the one with CFIA, and that APHIS had contacts with SAGARPA
23All estimates from our review of owner/shipper certificates are subject to sampling error.
The 95-percent confidence intervals for our estimates of 52 percent and 29 percent are 44 to 61 percent and 21 to 36 percent, respectively.
24The 95-percent confidence intervals for our estimates of 48 percent and 60 percent are 28 to 69 percent and 49 to 71 percent, respectively.
25In English, this would be the Secretary of Agriculture, Livestock Production, Rural

Development, Fishery, and Food; this is Mexico’s agriculture department.

Page 36 GAO-11-228 Horse Welfare
about finalizing it during 2002 and 2003. However, according to APHIS
officials, the Mexican agency did not provide a response consenting to the
agreement, and APHIS has not renewed the effort to get an agreement
since 2003. Thus, these officials said, enforcing the transport regulation
along the southern border is more difficult than along the northern border
with Canada. Moreover, while shippers on the northern border can drive
their conveyances directly into Canada, U.S. shippers generally are not
insured to travel into Mexico. As a result, shippers unload their horses
before crossing the border, where SAGARPA officials inspect the horses.
The horses are subsequently loaded onto a Mexican conveyance for
transport to a Mexican slaughtering facility.
In the absence of a formal, written agreement between APHIS and
SAGAPRA or the Texas Department of Agriculture, APHIS does not
receive official cooperation from Mexican or Texas officials. As a
consequence, owner/shipper certificates may not be correctly filled out by
the shippers and collected, completed, and returned to APHIS from either
the border crossing or the Mexican slaughtering facility with information
about shipment dates and times and horse conditions. In some cases,
APHIS had an informal understanding with SAGARPA officials at a border
crossing that they would collect and return the certificates to APHIS. In
other cases, at Texas border crossings, employees of the Texas
Department of Agriculture informally cooperated with APHIS by collecting
and returning the certificates to the agency and alerting it to possible
violations of the transport regulation. However, these informal
arrangements have not been sustained over time and have not been
sufficient to ensure the return of certificates to APHIS. For example, as of March 2011, APHIS transport program officials said they have not received
any owner/shipper certificates from Texas border crossings in more than a
year. Although some U.S. horses intended for slaughter are exported
through a border crossing in New Mexico, the majority of horses bound
for Mexico pass through the Texas crossings.26 Thus, program officials said
their ability to enforce the transport regulation for shipments of horses
exported through these border crossings has been severely hampered.
In addition to the more recent problem with certificates not being returned
from the Texas border crossings, we reviewed a generalizable sample of
owner/shipper certificates returned from the southern border from 2005

26Regarding the New Mexico border crossing, the transport program relies on the help of the APHIS Port Veterinarian to collect and return owner/shipper certificates.

Page 37 GAO-11-228 Horse Welfare
through 2009 to determine the extent to which they were correctly
completed by shippers and SAGARPA officials. Based on the results of our
review, we estimate that about 48 percent of these certificates from 2005
through 2009 were missing key information to be provided by either
shippers or SAGARPA officials. Moreover, about 54 percent of certificates
from 2008 through 2009 were missing such information, suggesting an
increase in problems associated with the recent increase in exports to
Mexico of horses intended for slaughter. In addition, we estimate that
about 39 percent of certificates returned to APHIS were missing some or
all information, including the date and time the horses were unloaded at
the border, to be provided by SAGARPA officials.27
Legislative prohibitions have impeded USDA’s ability to protect horse welfare since fiscal year 2006. First, as discussed, appropriations bills for
fiscal years 2006 through 2010 have prohibited APHIS from using federal funds to inspect horses being transported for slaughter. As a result, according to agency officials, the transport program’s compliance officer
may only inspect the owner/shipper certificates associated with the shipment of horses and the conveyance on which the horses are
transported. That is, only while inspecting these items may the officer also incidentally observe any potential violations of the transport regulation regarding the physical condition of the horses because of the
annual prohibition on the expenditure of federal funds on inspecting
horses. The compliance officer said this makes it difficult to ensure that horses are transported humanely to slaughter and to collect information
on potential violations that is needed for APHIS to pursue enforcement actions. For example, while inspecting a conveyance being used to
transport horses intended for slaughter in 2010, the compliance officer
found that a mare in the shipment had given birth to a foal. Because the
transport regulation requires shippers to verify that horses are not likely to give birth during shipment, the birth of a foal in transit represented a potential violation. However, because of the prohibition on using funds to inspect horses, the officer was unable to inspect the horses to determine which mare had given birth. Thus, the opportunity was lost to document a potential violation of the regulation by the shipper. Moreover, according to the officer, compliance probably has suffered because shippers are aware that transport program officials cannot
27The 95-percent confidence intervals for our estimates of 48 percent, 54 percent, and 39
percent are 36 to 60 percent, 37 to 71 percent, and 27 to 50 percent, respectively.
Legislative Prohibitions
Impede USDA’s Ability to

Ensure Horse Welfare

Page 38 GAO-11-228 Horse Welfare
inspect horses in transit to substantiate potential violations. According to APHIS officials, another impediment to their investigations of potential violations of the transport regulation is USDA’s lack of subpoena
authority to access the records of alleged violators or to compel persons
to testify in administrative hearings and to produce documentary evidence for such hearings. Specifically, although USDA has such authority under several other APHIS-administered statutes (e.g., Animal Health Protection Act, Horse Protection Act, and Plant Protection Act), it does not have this authority under the authorizing legislation for the
transport regulation—the 1996 Farm Bill. According to APHIS officials,
the agency would welcome the addition of subpoena authority to promote enforcement of the slaughter horse transport regulation.
Second, USDA also has been prohibited from using federal funds to
inspect horses prior to slaughter for human consumption at slaughtering
facilities. As discussed, the Federal Meat Inspection Act requires
inspection of all cattle, sheep, swine, goats, and horses before they are slaughtered and processed into products for human food and to ensure
that meat and meat products from these animals are unadulterated,
wholesome, and properly labeled. Prior to the appropriations prohibition, and before the cessation of domestic slaughter, FSIS officials in U.S.
slaughtering facilities inspected the condition of horses before slaughter
as well as the horsemeat after slaughter. The prohibition on the use of
funds for required inspections has, in effect, banned the slaughter of
horses for food in the United States, and, as a consequence, moved this
slaughter to other countries where USDA lacks jurisdiction and where the
Humane Methods of Slaughter Act does not apply. Therefore, USDA is less
able to ensure the welfare of horses at slaughter. And, as was the case with
horses in transit to slaughter, APHIS officials speculated that compliance
with the transport regulation has suffered because shippers are aware that
the program can no longer leverage the assistance of USDA personnel in
slaughtering facilities to ensure the completion of shipping paperwork or
note the condition of individual horses in a shipment. This view seems
consistent with our analysis of shipping certificates which found, as
discussed, a statistically significant increase in incomplete certificates
after the cessation of domestic slaughter. In addition, these officials noted
that the loss of FSIS’s assistance in slaughtering facilities, as well as the
prohibition on APHIS’s inspections of horses in transit, has led to a general
decline in investigation cases since 2007. Figure 11 shows the number of

investigation cases and alleged violators for fiscal years 2005 through 2010.

Page 39 GAO-11-228 Horse Welfare
Figure 11: Number of Investigation Cases and Alleged Violators of the Slaughter
Horse Transport Program Regulation, Fiscal Years 2005 through 2010
Note: According to APHIS officials, the number of alleged violators exceeds the number of
investigation cases because some investigations may reveal that multiple violators were responsible
for a single violation and some investigations do not substantiate that a violation occurred.
According to APHIS and animal protection officials, horse welfare is likely
to suffer as a consequence of horses traveling significantly farther to
slaughter since the cessation of domestic slaughter, including an increased
possibility of injuries when horses are confined in a conveyance with other
horses over longer transport distances and travel times. As these officials
explained, horses are by nature fight or flight animals, and when grouped in confinement, they tend to sort out dominance. In the tight quarters of a
conveyance, weaker horses are unable to escape from more dominant and
aggressive animals and, thus, are more prone to sustaining injuries from
kicks, bites, or bumping into other horses or the walls of the conveyance. Moreover, once a shipment of U.S. horses has crossed the border into
Canada or Mexico, APHIS no longer has authority to oversee their welfare,
and these animals may be in transit for long distances in these countries
before reaching a slaughtering facility. For example, the slaughtering
facilities in Mexico that process U.S. horses are located near Mexico City, Cessation of Domestic
Slaughter Has Diminished

*GRAPH UNABLE TO POST ON THIS BLOG*
APHIS’s Ability to
Implement the Transport
Regulation to Protect
Horse Welfare
Alleged violators
Investigation cases
0
18
36
54
72
90
108
126
144
162
180
2005 2006 2007 2008 2009 2010
Number
Source: GAO analysis of USDA’s APHIS data.

Fiscal year


Page 41 GAO-11-228 Horse Welfare
Figure 12: Example of Transport of Horses to Slaughtering Facilities Before and After Domestic Slaughter Ceased

*MAP OF U.S. AND POINTS OF SALE TO SLAUGHTER FACILITIES, FEEDLOTS, AND TRANSPORT GRAPH UNABLE TO POST ON THIS BLOG*

In addition, since the cessation of domestic slaughter, USDA has been less
able to help BLM prevent the slaughter of wild horses and burros. Wild
horses and burros may be adopted, but title does not pass to the adopter
until 1 year after the adoption, upon a determination that the adopter has
provided humane conditions, treatment, and care for the animal over that
Source: GAO analysis of USDA documents; Art Explosion (images); MapArt (map).
Slaughtering facility
Feedlot/stockyard
Transport of horses before domestic slaughter ceased.
Transport of horses after domestic slaughter ceased.
Assembly point/farm

Auction/sale point

Page 42 GAO-11-228 Horse Welfare
period. Upon transfer of title, the animals lose their status as wild free-
roaming horses and burros. As we reported in 2008,29 from 2002 through
the end of domestic slaughter in September 2007, about 2,000 former BLM
horses were slaughtered by owners to whom title to the horses had
passed.30 When horses were slaughtered domestically, FSIS inspectors in
slaughtering facilities watched for horses bearing the BLM freeze mark
indicative of the wild horse and burro program. They would then alert
BLM officials so that the title status of these animals could be checked to
ensure that BLM horses were not slaughtered. As a result of FSIS’s
assistance during the same time period, at least 90 adopted wild horses
that were still owned by the government were retrieved from slaughtering
facilities before they could be slaughtered. However, now that the
slaughter of U.S. horses occurs in Canada and Mexico, FSIS can no longer
provide this assistance. Furthermore, shippers are not required to identify BLM horses on owner/shipper certificates, but in reviewing nearly 400
owner/shipper certificates, we found indications that six adopted BLM
horses had been shipped across the border for slaughter. Because
inspection officials in foreign slaughtering facilities have no obligation to
check with BLM or other U.S. authorities before slaughtering these
animals, it is unknown whether title for those animals had passed to the
adopter or how many more BLM horses may have been shipped across the
border for slaughter.
The slaughter of horses for any purpose, especially for human
consumption, is a controversial issue in the United States that stems
largely from how horses are viewed, whether from an historic, work,
show, recreation, or commodity point of view. As a result, there is tension
between federal law mandating the inspection of horses and certain other
animals at slaughter (i.e., the Federal Meat Inspection Act) and annual
appropriations acts prohibiting the use of funds to inspect horses at, or
being transported to, slaughtering facilities.
What may be agreed upon, however, is that the number of U.S. horses that
are purchased for slaughter has not decreased since domestic slaughter
29GAO-09-77.
30BLM is not required to protect animals after ownership has passed to adopters or buyers. However, since the spring of 2005, BLM has required adopters to sign a statement that they do not intend to slaughter the animals to help address concerns by horse advocates about

horses being slaughtered. Conclusions

Page 43 GAO-11-228 Horse Welfare
ceased in 2007. Furthermore, an unintended consequence of the cessation
of domestic slaughter is that those horses are traveling farther to meet the same end in foreign slaughtering facilities where U.S. humane slaughtering protections do not apply. Their journey from point-of-purchase to
slaughtering facilities in other countries, with multiple potential stops in-
between at assembly points, feedlots, and stockyards, includes the
possibility of being shipped in conveyances designed for smaller animals
or confined in these conveyances for excessive time periods. The current
transport regulation, the Commercial Transportation of Equines to
Slaughter regulation, does not apply until a shipment is designated for
slaughter, which can be the last leg of a longer journey. A 2007 proposed
rule to amend the regulation, which would define “equines for slaughter”
and extend APHIS’s oversight and the regulation’s protections to more of
the transportation chain, has not been issued as final as of June 2011.
To adequately implement the transport regulation and oversee the welfare
of horses intended for slaughter, the horse transport program must ensure
that owner/shipper certificates are completed, returned, and evaluated for
enforcement purposes. Many certificates are not now returned, and others
are returned incomplete. Furthermore, because of limited staff and
funding and these missing and incomplete certificates, the program is less
able to identify potential violations of the transport regulation. The
program also stopped automating certificate data. Even with the present
limitations of incomplete and missing certificates, automating these data is important for management oversight of compliance with the regulation
and to direct scarce program resources to the most serious problem areas.
Moreover, in time, as corrective actions are taken, these data will likely
become even more useful for oversight purposes. If the proposed rule to
extend APHIS’s authority to more of the transportation chain is issued as
final, the program’s credibility will be further challenged unless APHIS
identifies ways to leverage other agency resources to ensure compliance
with the transport regulation.
With U.S. horses now being shipped to Canada and Mexico for slaughter,
APHIS depends upon cooperation with these countries, or state officials at the borders, to help it implement the transport regulation, but it does not
have effective agreements that make clear each party’s obligations and that
help ensure cooperation will continue as personnel change. APHIS
developed an agreement with Canadian officials in 2002, but recently the
agency has been receiving incomplete owner/shipper certificates from them,
raising questions about the current agreement’s effectiveness and whether

both APHIS and Canadian officials have the same understanding about the assistance APHIS seeks. Furthermore, APHIS does not have formal

Page 44 GAO-11-228 Horse Welfare
cooperative agreements with its Mexican counterpart and the Texas
Department of Agriculture—the entities that oversee most U.S. horses exported to Mexico for slaughter. APHIS has not received any
owner/shipper certificates from either of these entities in more than a year.
Recent, annual congressional actions to prohibit the use of federal funds to inspect horses in transit or at slaughtering facilities have complicated
APHIS’s ability to implement the transport regulation, thus horses now
travel longer distances to foreign slaughtering facilities. APHIS lacks
jurisdiction in these countries, and it can no longer depend on the help it
once received from other USDA officials present in domestic slaughtering
facilities to catch potential violations of the transport regulation. Even
after the recent economic downturn is taken into account, horse
abandonment and neglect cases are reportedly up, and appear to be
straining state, local, tribal, and animal rescue resources. Clearly, the
cessation of domestic slaughter has had unintended consequences, most
importantly, perhaps, the decline in horse welfare in United States.
In light of the unintended consequences on horse welfare from the
cessation of domestic horse slaughter, Congress may wish to reconsider
the annual restrictions first instituted in fiscal year 2006 on USDA’s use of
appropriated funds to inspect horses in transit to, and at, domestic
slaughtering facilities. Specifically, to allow USDA to better ensure horse
welfare and identify potential violations of the Commercial Transportation
of Equines to Slaughter regulation, Congress may wish to consider
allowing USDA to again use appropriated funds to inspect U.S. horses
being transported to slaughter. Also, Congress may wish to consider
allowing USDA to again use appropriated funds to inspect horses at
domestic slaughtering facilities, as authorized by the Federal Meat
Inspection Act. Alternatively, Congress may wish to consider instituting an explicit ban on the domestic slaughter of horses and export of U.S. horses
intended for slaughter in foreign countries.
Matters for
Congressional

Consideration

Page 45 GAO-11-228 Horse Welfare
To better protect the welfare of horses transported to slaughter, we
recommend that the Secretary of Agriculture direct the Administrator of
APHIS to take the following four actions:
• Issue as final a proposed rule to amend the Commercial Transportation
of Equines to Slaughter regulation to define “equines for slaughter” so
that USDA’s oversight and the regulation’s protections extend to more
of the transportation chain.
• In light of the transport program’s limited staff and funding, consider
and implement options to leverage other agency resources to assist the
program to better ensure the completion, return, and evaluation of
owner/shipper certificates needed for enforcement purposes, such as
using other APHIS staff to assist with compliance activities and for
automating certificate data to identify potential problems requiring
management attention.
• Revisit, as appropriate, the formal cooperative agreement between
APHIS and CFIA to better ensure that the agencies have a mutual
understanding of the assistance APHIS seeks from CFIA on the
inspection of U.S. horses intended for slaughter at Canadian
slaughtering facilities, including the completion and return of
owner/shipper certificates from these facilities.
• Seek a formal cooperative agreement with SAGARPA that describes
the agencies’ mutual understanding of the assistance APHIS seeks from SAGARPA on the inspection of U.S. horses intended for slaughter at
Mexican border crossings and slaughtering facilities and the
completion and return of owner/shipper certificates from these
facilities. In the event that SAGARPA declines to enter into a formal
cooperative agreement, seek such an agreement with the Texas
Department of Agriculture to ensure that this agency will cooperate
with the completion, collection, and return of owner/shipper
certificates from Texas border crossings through which most
shipments of U.S. horses intended for slaughter in Mexico pass.
Recommendations for

Executive Action

Page 46 GAO-11-228 Horse Welfare
We provided a draft of this report to USDA for review and comment. In
written comments, which are included in appendix III, USDA agreed with the report’s recommendations. Regarding the first recommendation, USDA
said it will move as quickly as possible to issue a final rule, but first it must
formally consult with the Tribal Nations that are experiencing particularly
serious impacts from abandoned horses. USDA said that if it can
successfully conclude these negotiations in the next 2 months, it would
publish the final rule by the end of calendar year 2011. However, USDA
also said that it needs time to thoughtfully consider those consultations in
regards to the regulation’s implementation. Regarding the second
recommendation, USDA noted it is training additional APHIS port
personnel in Slaughter Horse Transport Program enforcement activities at
Texas ports of embarkation and plans to expand this effort in fiscal year
2012 within the allocated budget. USDA also stated it is training
administrative personnel to evaluate owner/shipper certificates for
enforcement purposes, and it will explore whether new technologies have
made the process of entering information from those certificates into a
database less costly in order to do so within existing funding. Regarding the third recommendation, USDA said it would consult with CFIA and
propose revisions to the current cooperative agreement. Regarding the
fourth recommendation, USDA indicated it will consult with SAGARPA
and the Texas Department of Agriculture and propose the development of
formal agreements with one or both. We are sending copies of this report to the appropriate congressional
committees, the Secretary of Agriculture, and other interested parties. In
addition, the report will be available at no charge on GAO’s Web site at
http://www.gao.gov.
If you or your staff members have any questions about this report, please
contact me at (202) 512-3841 or shamesl@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on the
last page of this report. GAO staff who made major contributions to this
report are listed in appendix IV.
Lisa Shames
Director, Natural Resources
and Environment
Agency Comments

and Our Evaluation

Appendix I: Objectives, Scope, and
Methodology
Page 47 GAO-11-228 Horse Welfare
Our report objectives were to examine (1) the effect on the U.S. horse
market, if any, since domestic slaughter of horses for food ceased in 2007;
(2) the impact, if any, of these changes on horse welfare and on states,
local governments, tribes, and animal welfare organizations; and (3)
challenges, if any, to the U.S. Department of Agriculture’s (USDA)
oversight of the transport and welfare of U.S. horses exported for
slaughter.
In general, to address these objectives, we reviewed documents and/or
interviewed officials from
• USDA, including the Animal and Plant Health Inspection Service
(APHIS), Food Safety Inspection Service, Foreign Agricultural Service,
National Agricultural Statistics Service, and the Office of Inspector
General;
• other federal agencies such as the Department of the Interior’s Bureau
of Land Management, Department of Commerce, Department of
Labor’s Bureau of Labor Statistics, and Congressional Research
Service;
• state and local governments, including the National Association of
State Departments of Agriculture, Montana Association of Counties,
National Association of Counties, National Sheriffs Association, and
Western State Sheriffs Association; and
• Native American tribes, including several Great Plains Tribes, the
Northwest Tribal Horse Coalition, and several Southwestern Tribes.1
We also reviewed documents and/or interviewed representatives from
• livestock industry organizations, including the American Association of
Equine Practitioners, American Horse Council, American Veterinary
Medical Association, Florida Animal Industry Technical Council,
Maryland Horse Industry Board, Livestock Marketing Association,
United Horsemen’s Front, United Organizations of the Horse,
Unwanted Horse Coalition, and commercial horse auctions located in
1The Northwest Tribal Horse Coalition consists of tribes from five reservations--the
Confederated Tribes of the Colville Reservation, Washington; the Confederated Tribes of
the Umatilla Reservation, Oregon; the Confederated Tribes of the Warm Springs
Reservation of Oregon; the Confederated Tribes and Bands of the Yakama Nation,
Washington; and the Shoshone-Bannock Tribes of the Fort Hall Reservation of Idaho.
Appendix I: Objectives, Scope, and

Methodology

Appendix I: Objectives, Scope, and
Methodology
Page 48 GAO-11-228 Horse Welfare
various states, including Alabama, Arkansas, Montana, Oklahoma,
Pennsylvania, and Virginia; and
• animal welfare organizations, including the American Society for the
Prevention of Cruelty to Animals, Animal Law Coalition, Animal
Welfare Institute, Equine Welfare Alliance, and Humane Society of the
United States.
In addition, we reviewed published literature related to the horse industry
and livestock slaughter, and we interviewed academic experts who have
researched and written about these issues. Furthermore, we reviewed
relevant federal and state legislation regarding horse inspection, slaughter,
transport, and/or welfare, including bills proposed but not enacted in the
111th U.S. Congress and by state legislatures, and related federal
regulations, including USDA’s Commercial Transportation of Equines to
Slaughter regulation and related guidance. To determine the extent to
which slaughter for non-food purposes occurs in the United States, we
identified facilities that had been reported to slaughter horses for other
purposes (e.g., food for animals at zoos and circuses) and interviewed the
Slaughter Horse Transport Program’s compliance officer about the
officer’s examinations into these facilities’ operations. We also visited
border crossings in New Mexico and Texas, horse auctions in Montana
and Pennsylvania, and tribal lands in the northwest United States to
observe the handling of horse shipments at the border, horse sale
procedures, and wild and abandoned horse management challenges,
respectively. To further examine the effect on the U.S. horse market, if any, since the
cessation of domestic slaughter, we used an econometric analysis and
regression methods to estimate the effect of the cessation on horse prices,
while considering the effects of the U.S. economic downturn (i.e.,
recession) and horse- and auction-specific variables.2 We did this analysis
because we found few current studies addressing the effect of the
cessation on horse prices in the economic literature. In undertaking this
work, we collaborated with Dr. Mykel Taylor, Assistant Professor and
Extension Economist in the School of Economic Sciences at Washington
2“Econometric” refers to the application of statistical methods to the study of economic
data, and “regression” is a statistical method used in econometrics that can isolate the impact of one variable on a particular outcome while considering the impact of other variables. In this case, the variable and outcome of particular interest are the cessation of

domestic slaughter and changes in horse prices, respectively.

Appendix I: Objectives, Scope, and
Methodology
Page 49 GAO-11-228 Horse Welfare
State University, who was studying this issue at the time we began our
work and previously had modeled and written about the determinants of
horse prices.
We obtained data for our analysis from multiple sources. Regarding horse
prices, we obtained sale price and horse characteristic data on 12,003 sale transactions from spring 2004 through spring 2010 at three large horse
auctions located in Montana, Oklahoma, and Virginia. Specifically, we
extracted data from price sheets and catalogue information published or
otherwise provided by the owners of these auctions. We chose these
auctions because they were located in geographically diverse parts of the
country. In addition, these auctions regularly sell lower-value horses, as
well as more expensive horses valued for leisure, work, or show purposes.
Some, but not all, of the lower-valued horses in the data are bought for
slaughter, including some referred to as “grade” or “loose” horses. We
assumed that if there was an effect from the cessation of domestic horse
slaughter, prices for lower-valued horses would be most impacted.
Consequently, we did not include data in our analysis from auctions
catering to very high-priced racing and show horses. We also obtained
data from the Department of Labor’s Bureau of Labor Statistics on
changes in unemployment in each of the regions in which the horse
auctions we selected are located. We used these unemployment data as a
proxy for the economic downturn experienced in recent years. We
performed quality tests and interviewed knowledgeable agency officials
and auction representatives about the sources of the data and the controls in place to maintain the data’s integrity, and we found the data to be
sufficiently reliable for the purposes of this report.
Using these data, we analyzed whether there was a significant reduction in average sale price per head after the cessation of domestic slaughter. For
purposes of our analysis, the period prior to cessation included spring
2004 through 2006, and the period after cessation included 2007 through
spring 2010 (because most domestic slaughtering facilities were closed by early 2007). To evaluate the potential reasons for this reduction in price,
we also developed a hedonic model, which allows one to describe the
price of a good (e.g., a horse) as a function of the value of intrinsic
characteristics of that good (e.g., a horse’s breed, age, and gender).3 Thus,
we specified a horse’s sale price as a function of variables that describe its
3In a hedonic model, the individual coefficients of the regression variables represent the

implicit price of each characteristic found in that good.

Appendix I: Objectives, Scope, and
Methodology
Page 50 GAO-11-228 Horse Welfare
physical attributes, such as breed, age, and gender; auction-specific
variables, such as region of the country and season of the year; and other
variables, such as the cessation of domestic slaughter and economic
downturn. We used the quantile regression technique to derive coefficients
to explain the impact on horse prices for each variable in the model.
Quantile regression is a statistical method that provides information about
the relationship between an outcome variable (e.g., horse prices) and
explanatory variables (e.g., cessation of slaughter) at different points in
the distribution of the outcome variable.4 This type of regression is more
appropriate than standard linear regression for several reasons. For
example, we wanted to determine the estimated effects of the cessation at
various points across the entire distribution of sales prices in our data,
instead of on just the average value (i.e., mean), as in linear regression.5
Also, the approach is more appropriate when using data from separate
sources, such as the three auctions in different parts of the country. In
addition, because our price data were highly skewed (i.e., included mostly
lower- and mid-priced horses), we transformed prices to a natural
logarithmic scale in the regression in order to obtain a better statistical fit
for our model.6
There are several potential limitations to this type of modeling. For
example, all of the variables influencing an outcome may not be known,
and there are likely to be limitations in the data available for the analysis.
For example, the price of a horse may also be related to other attributes
such as quality of pedigree and performance characteristics (e.g.,
championships or titles won), but information on these variables was not
available for all horses in our analysis. In addition, other characteristics of
a horse, such as health, demeanor, and general appearance may also affect
the price buyers are willing to pay, but those characteristics are difficult to
measure and, therefore, were not available for our analysis. Nevertheless,
despite these limitations, this type of regression is useful for developing 4Quantiles and percentiles are synonymous—for instance, the 0.80 quantile is the 80th percentile. The median, or the middle value of the ranked dataset, is the 0.50 quantile or
50th percentile.
5Standard linear regression models the relationship between one or more explanatory variables, X, and the mean of an outcome variable, Y. In contrast, quantile regression
models the relationship between X and the quantiles of Y, and it is especially useful in
applications where low and high values in the distribution of Y are important.
6One common transformation of data used in econometric (or regression) analysis is the
natural logarithmic scale (ln). It is often used to transform highly-skewed data into a more

normal (or symmetric) distribution.

Appendix I: Objectives, Scope, and
Methodology
Page 51 GAO-11-228 Horse Welfare
estimates of the impacts from, and an indication of the relative importance
of, various variables to an outcome.
In our analysis, we estimated the impact of the cessation on horse prices,
while considering other relevant variables, on horse sale price for five
price quantiles (20th, 40th, 50th, 60th, and 80th percentiles). As discussed,
the other variables in our analysis included a horse’s physical characteristics, such as breed/type, age, and gender. Regarding breed, the
data contained a total of 27 horse breeds, but for purposes of our analysis, we categorized horses into one of seven variables—Quarter horses, Paint
horses, Appaloosas, ponies and miniature horses, Thoroughbreds,
combined “other,” and “grade.” Grade horses are sold without breed
designation, are often sold in groups, and are usually the lowest-priced
horses available at an auction. Regarding age, horses in our data ranged
from 1 to 32 years old, and we included age as a continuous variable in our
analysis. We also used a related variable, the square of a horse’s age, to account for changes in a buyer’s willingness to purchase a horse as its age
increases. Regarding gender, we used “indicator” variables for mare,
stallion, and gelding (a neutered male horse).7 In addition, we used two
interactive variables to explain how the gender and age of a horse could
interact to affect its sale price—(1) interacting mare with age and (2)
interacting gelding with age. For example, the price of a mare may
increase early in her life as she is able to produce foals but may decline
when she becomes too old to breed consistently.
To capture information that was auction-specific, we included several
additional variables in our analysis. First, we measured the percentage of “no-sale” horses at each auction. In general, these horses were not sold by
their owners because they did not receive high enough final bids for these
horses at auction. We also included a variable denoting whether an
auction was in the western, southern, or eastern region of the United
States. In addition, we included variables to delineate whether an auction
was held in the spring or fall seasons. Industry experts we contacted said
spring auctions generally are larger and bring higher prices than fall
auctions, when owners may be more anxious to sell their horses rather
than have to feed them through the winter.

7An indicator variable takes the value of 1 or 0, depending on whether an event is true or present (i.e., 1), or not (i.e., 0).

Appendix I: Objectives, Scope, and
Methodology
Page 52 GAO-11-228 Horse Welfare
We included the cessation of slaughter as an indicator variable in our
analysis, with “0” indicating the period prior to the cessation of domestic
slaughter in 2007, and “1” for the period after. For purposes of our
analysis, the period prior to cessation included spring 2004 through 2006,
and the period after cessation included 2007 through spring 2010 (because most domestic slaughtering facilities were closed by early 2007).
To measure the effect of the economic downturn, we used a variable
based on average monthly unemployment rates from the Bureau of Labor
Statistics for the 12-month period prior to the date of each auction. These
data are compiled by Census Divisions or by geographic region; we used
the data for those Census Divisions or regions that correspond to the
locations of the three auctions.8 More specifically, we averaged the
unemployment rate data for the 12-month period prior to the date of each auction because we assumed that buyers and sellers would make
transaction decisions based on economic conditions for a period before
the date of the auction, not just on conditions at the time of the auction.
In order to review the soundness of our methodology and results, we
asked five academic experts in agricultural economics to review a draft of our model specifications and discussion of results for fatal flaws. We
chose these experts because they have published articles related to the
horse industry and livestock slaughter issues. These experts generally
found the model specifications and results credible. Several offered
specific technical comments related to the presentation of the model
results, which we incorporated, as appropriate. Additional information
about the results of our analysis is in appendix II.
To further examine the impact, if any, of horse market changes on horse welfare and states, local governments, tribes, and animal welfare
organizations, we used semi-structured interviews to systematically collect
the views of the State Veterinarian (an appointed position) in 17 states.9
8For the eastern auction, we used unemployment data for the “Mid-Atlantic” and “South
Atlantic” regions, consisting of Delaware, District of Columbia, Florida, Georgia, Maryland,
New Jersey, New York, North Carolina, Pennsylvania, South Carolina, Virginia, and West
Virginia. For the southern auction, we used data for the “West South Central” region,
consisting of Arkansas, Louisiana, Oklahoma, and Texas. For the western auction we used
data for the “Mountain” region, consisting of Arizona, Colorado, Idaho, Montana, Nevada, New Mexico, Utah, and Wyoming.
9These states are California, Colorado, Florida, Indiana, Kentucky, Louisiana, Maryland, Missouri, Montana, New Mexico, New York, North Carolina, Ohio, Oklahoma,

Pennsylvania, Texas, and Wyoming.

Appendix I: Objectives, Scope, and
Methodology
Page 53 GAO-11-228 Horse Welfare
These states included the 10 with the largest horse populations, and the 10
with the largest horse economies—a total of 14 states. In addition, we
added Montana, New Mexico, and Wyoming at the suggestion of
representatives of the horse industry and animal welfare organizations,
who indicated that these states had unique perspectives on border or tribal
issues related to horses. In some cases, the State Veterinarian was joined
by other state officials, such as members of the state livestock board, for
these interviews. The results of the interviews are not generalizable to all
State Veterinarians but provide information about the situations faced by these 17 states.
Semi-structured interviews follow a standard structure to systematically
gather information from the target audience. In our case, we wanted to
systematically collect information from these 17 states on (1) horse sales
and prices; (2) export, trade, and transport of horses; (3) abandoned and adopted horses; (4) horse abuse and neglect cases; (5) legislation related
to horse slaughter and welfare; and (6) other factors generally affecting
horse welfare. Using software called NVivo, we then performed a
qualitative content analysis of the results of these interviews to identify
common themes and the frequency with which certain issues were raised.
Content analysis is a methodology for structuring and analyzing written
material. Specifically, we developed a coding and analysis scheme to
capture information on factors that may explain changes in the horse
industry in these states. Such factors included the cessation of domestic
slaughter; economic conditions; restrictions on the use of certain drugs in
horses slaughtered for human consumption; and changes in horse
breeding, disposal, care and maintenance, prices, sales, and such inputs as
the cost of feed. We also developed a coding and analysis scheme to
capture information on factors related to horse owners’ potential
responses to those changes, including abandoning, neglecting, abusing,
and hoarding horses, as well as factors related to horse welfare such as
being harmed by unfamiliar herds and traveling farther to slaughter. In
addition, we developed a coding and analysis scheme to identify state and local responses to changes in the horse industry, including impacts on
resources, costs, investigations, and legislation. The content analysis was
conducted by two GAO analysts with the assistance of a GAO
methodologist. Discrepancies in coding were generally discussed and
resolved between the analysts; on occasion, the methodologist weighed in
to resolve a discrepancy. To further examine challenges, if any, to USDA’s oversight of the transport

and welfare of U.S. horses exported for slaughter, we identified and

Appendix I: Objectives, Scope, and
Methodology
Page 54 GAO-11-228 Horse Welfare
analyzed a generalizable sample of about 400 horse shipping forms, known
as owner/shipper certificates, for the period 2005 through 2009, to
determine whether (1) the certificates were properly completed and (2)
horses were traveling farther to slaughter since the cessation of domestic
slaughter in 2007 than they were traveling prior to the cessation. Each
owner/shipper certificate represents one load or shipment of horses.
APHIS maintains these forms at its headquarters offices in Riverdale,
Maryland, in hardcopy, sorted by year and shipper.
As there were no electronic records of the sample frame (i.e., the universe
of certificates) from which we could randomly sample and we initially did not know the total number of certificates on file, we selected a stratified,
systematic random sample from the hardcopy certificates for the period. We chose to stratify the sample frame into three strata (i.e., time periods)
so we would be able to compare estimates of certificate completeness and
the distances horses traveled before and after 2007. Specifically, we
systematically selected 396 certificates, including 192 for 2005 through
2006, the 2 years prior to the cessation of domestic slaughter; 84 for 2007;
and 120 for 2008 through 2009, the 2 years after the cessation. In the
course of selecting this sample, we determined that there were nearly
16,000 certificates on file for these years, including 7,671 certificates for
2005 through 2006, 3,378 certificates for 2007, and 4,787 certificates for
2008 through 2009.
Because we followed a probability procedure based on random selections
of our starting points (e.g., first select the 25th certificate in the 2005
through 2006 strata and every 40th certificate thereafter), our sample is
only one of a large number of samples that we might have drawn. Since
each sample could have provided different estimates, we expressed our
confidence in the precision of our particular sample’s results as a 95
percent confidence interval. This is the interval that would contain the
actual population value for 95 percent of the samples we could have
drawn.
To estimate the degree to which owner/shipper certificates were properly
completed by the shipper and by Canadian and Mexican officials, we
extracted information from the certificates that APHIS uses to help
determine compliance with the Commercial Transportation of Equines to
Slaughter regulation, such as the loading date, time, and location;
certification that the horses were fit for transport; the identity of the
receiving slaughtering facility; and the date and time the shipment arrived.
Using our sample of certificates, we calculated estimates of the degree of

completeness of all certificates returned to APHIS from slaughtering

Appendix I: Objectives, Scope, and
Methodology
Page 55 GAO-11-228 Horse Welfare
facilities or border crossings from 2005 through 2009 and tested the
change over time for statistical significance.
In order to estimate the distance that horses traveled, on average, we
extracted information on each shipment’s origination (i.e., loading) point and destination (i.e., off-loading) point from the certificates. Regarding
shipments that went to former U.S. slaughtering facilities, we used the
Transportation Routing Analysis Geographic Information System
(TRAGIS) model developed by the Department of Energy to estimate
driving miles between the origination point, such as an auction, farm,
feedlot, or stockyard, and the slaughtering facility. Because TRAGIS
includes only U.S. roads, we used a different approach for calculating
distances beyond the U.S. border to foreign slaughtering facilities. First,
based on USDA information on the border crossings most often used to
export shipments of horses intended for slaughter, we used TRAGIS to
calculate the distance from an origination point to several border
crossings. Then, for each border crossing, we used commercial software
available on the Web to estimate the distance from these crossings to a
foreign slaughtering facility. We then combined the results and selected
the combination that resulted in the shortest potential distance traveled
from the origination point to the slaughtering facility. As a result, our
estimates of the total distance traveled to foreign slaughtering facilities are
likely to be underestimates.
We conducted this performance audit from April 2010 through June 2011,
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and

conclusions based on our audit objectives.

Appendix II: Results of the Econometric
Analysis of Horse Sale Prices
Page 56 GAO-11-228 Horse Welfare
For our econometric analysis of horse sale prices from three large
geographically-dispersed horses auctions, we conducted a hedonic
quantile regression to estimate the impact of a number of explanatory
variables, including the cessation of domestic horse slaughter; the
economic downturn (i.e., recession); horse attributes such as breed, age,
and gender; and the location and timing of horse auctions, on the full
range of values of the outcome variable—horse sale prices. We were
particularly interested in the impact of the cessation and economic
downturn, as these factors have been cited as reasons for recent changes
in the horse industry. Appendix I includes a detailed explanation of our
methodology for this analysis.
A discussion of the results for the separate variables in the model follows:
• Age of horse. The results show that age is an important variable in
explaining horse prices in these auctions. The positive sign for a
horse’s age and negative sign for the age squared, indicate that young
horses will increase in price as they age, but older horses will start to
decline in price as they age. Moreover, the positive effect of age
becomes zero for mares and geldings between 11 and 12 years of age,
while stallions continue to increase in price for approximately 5 more
years.
• Gender of horse. The results indicate that the value of horses varies
both by their gender and the interaction of their gender and age.
Specifically, the results show that the price of geldings is initially
higher than both stallions and mares. This premium holds until
approximately age 12, when the premium relative to stallions has gone
to zero. Mares do not sell at a premium relative to stallions at any point
in the age distribution.
• Location and timing of auction. The results indicate that a horse sold
at either the eastern or southern auctions would fetch a higher price
than an identical horse sold at the western auction. The premium for
horses sold at the eastern auction is greater than the premium for
horses sold at the southern auction. The timing of an auction—spring
versus fall—was also statistically significant and suggests that horses
sold in the fall tend to sell at a discount, although this effect diminishes
for the higher price categories. This may be because owners may be
more anxious to sell their horses in the fall rather than feed them
through the winter.
• Auction no-sales percentage. The results suggest that for every 1
percent increase in an auction’s “no-sales” percentage, price decreased
Appendix II: Results of the Econometric

Analysis of Horse Sale Prices

Appendix II: Results of the Econometric
Analysis of Horse Sale Prices
Page 57 GAO-11-228 Horse Welfare
by about 2 percent across quantiles. That result was highly statistically
significant and consistent across all horse price quantiles. This phenomenon may result from sellers having certain expectations of
acceptable bid prices, and, if those expectations are not met, they may
be willing to wait for a later auction date to try selling the horse again.
Horse buyers may have expectations, as well, that prices will be falling
even lower and wait until the next auction. This may be especially true
during a period of economic slowdown, according to experts.
• Horse breed/type. The results suggest that Quarter horses sold at a
premium, relative to grade horses, which do not have a declared breed
registry. Ponies also tend to sell at a premium relative to grade horses,
for those ponies sold in the higher categories (i.e., quantiles). An
unexpected result was that other breed types, Paint horses,
Appaloosas, and Thoroughbred horses sold at either a discount or did
not show statistically significant difference in price, relative to grade
horses. This could have been due to the small number of observations
compared to other breeds and that for certain breeds, such as
Appaloosas, there could be a lack of buyers for these types of horses.
• Economic downturn. The results show that the recession or downturn
in the general economy caused a consistently negative effect on horse
prices across the range of price categories. This effect was greater, in
dollar terms, for the higher price categories. Across the five price
categories, we estimate that for each percentage point increase in
average unemployment in the relevant regions, horse prices decreased
by 5.2, 5.2, 4.8, 4.7, and 4.8 percentage points, respectively.
• Cessation of domestic slaughter. The results show that the cessation
was related to declines in prices for lower- to middle-value horses but
diminished for higher-value horses (i.e., horses in the higher price
categories in the table). For example, in the first three price categories,
horse prices declined by 21, 10, and 8 percentage points, respectively.
Table 2 lists the results, expressed as semi-log coefficients, of the hedonic
quantile regression for five categories of horse sale prices—the 20th, 40th,
50th (median), 60th, and 80th percentiles.1
1A semi-log model specification is one in which the outcome variable (Y) is transformed
into logarithms and the explanatory variables (X) are unchanged. The model coefficients of
the explanatory variables from this type of specification are then in semi-log form. The
semi-log specification has been widely used in the economic literature to estimate horse

and other livestock prices in hedonic models.

Appendix II: Results of the Econometric
Analysis of Horse Sale Prices
Page 58 GAO-11-228 Horse Welfare
Table 2: Semi-log Coefficients for Hedonic Quantile Regression of Horse Prices
Estimated coefficients by quantile (percentile) of horse price distributiona
Explanatory variableb 20th 40th50th (median) 60th80th
Age of horse 0.218***0.233*** 0.241*** 0.243***0.221***
Age of horse squared -0.007***-0.007***-0.007*** -0.007***-0.006***
Gender mare (female) 0.220***0.180** 0.086 0.103 0.129
Gender gelding (neutered male) 0.879***0.882***0.780*** 0.767***0.568***
Interaction of mare with age -0.061*** -0.071***-0.068*** -0.073***-0.075***
Interaction of gelding with age -0.059***-0.081***-0.086*** -0.094***-0.094***
Southern auction 0.488***0.532*** 0.477*** 0.504***0.535***
Eastern auction 0.860***0.924*** 0.878*** 0.813***0.809***
Fall auction -0.274***-0.204***-0.201*** -0.173***-0.126***
Auction no-sale percentage -0.020*** -0.020***-0.016*** -0.016***-0.012***
Breed Quarter horse 0.216*** 0.291*** 0.321*** 0.323***0.381***
Breed Paint horse -0.138** -0.134***-0.092* -0.068 -0.094*
Breed Appaloosa horse -0.111 -0.156 -0.272* -0.348* -0.392**
Breed ponies & miniature horse 0.075 0.117 0.132 0.217** 0.201**
Breed Thoroughbred horse -0.437*** -0.667**-0.385 -0.430 -0.407**
Breed other (misc.) horse -0.082 0.017 0.023 -0.054 -0.011
Economic downturn -0.053***-0.054***-0.049*** -0.048***-0.049***
Cessation of domestic slaughter -0.235***-0.110***-0.082*** -0.028 0.034
Constant 5.817***6.136*** 6.276*** 6.450***6.963***
Source: GAO analysis of horse sale price, horse characteristic, and auction-specific data from three horse auctions, and unemployment
rate data from the Department of Labor for regions where these auctions are located. Notes: The estimates in the table that are statistically significant at the 0.05, 0.01, and 0.001 percent
levels are noted by one, two, or three asterisks, respectively.
Although the sales data included 27 breeds, the primary breed types were Quarter horses, 73.9
percent of the horses; grades (low-valued horses without breed designation), 12.1 percent; and Paint
horses, 11.9 percent; with a small number of observations for breeds such as ponies, 0.57 percent;
Appaloosas, 0.45 percent; and Thoroughbreds, 0.25 percent.
aThe upper bounds for the quantiles correspond to horses priced at $600 (20th), $1,000 (40th),
$1,400 (50th or median), $1,750 (60th), and $3,000 (80th).
bIn creating categorical variables, one category must be omitted from the analysis to prevent
dependencies (where one variable is highly related to another). For instance, to create the seasonal
categorical variable, we omitted the spring auction variable from the analysis. However, the effect of
the spring auction season is represented in the regression, because the coefficient for the variable fall
auction is interpreted as relative to the reference variable (the one left out of the analysis—spring
auction). Other categorical variables in the model include horse gender, region, and breed/type.
From the table, we see that most of the regression estimates for the model
have the expected directional signs and are statistically significant. The
retransformed results, from the semi-log form back to dollar and percentage
changes, are presented for our two variables of interest—cessation of

domestic slaughter and economic downturn—in table 1 of this report.

DEPARTMENT OF AGRICULTURE LETTER TO GAO IS NOT POSTED HERE. IT CAN BE FOUND ON THE ORIGINAL GAO DOCUMENT.

Appendix IV: GAO Contact and Staff
Acknowledgments
Page 61 GAO-11-228 Horse Welfare
Lisa Shames (202) 512-3841 or shamesl@gao.gov
In addition to the contact named above, James R. Jones, Jr., Assistant
Director; Jim Ashley; Mark Braza; Antoinette Capaccio; Barbara El Osta;
Emily Gunn; Terrance N. Horner, Jr.; Armetha Liles; Kimberly Lloyd; Jeff
Malcolm; John Mingus; Kim Raheb; and Carol Herrnstadt Shulman made
key contributions to this report.
Appendix IV: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff

Acknowledgments

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