Rule Making:
The industry and its counsel and lobbyist were quite busy in the month of July and August addressing matters pertaining to APHIS regulations of the Tennessee walking horse show industry.
At the beginning of July, members of our Industry prepared for and met with OIRA (Office of Information and Regulatory Affairs). OIRA is the government entity that serves as a watch-dog to assure that other agencies properly consider various factors when promulgating proposed rules. Among those factors are the impact that the proposed rule would have on the participants in the industry affected by the proposed rule, whether the agency has considered less impactful alternatives to the proposed rule, and whether the costs of the proposed rule justify its benefits. Representatives of the industry met with OIRA in two separate meetings, and in those meetings and a subsequent detailed letter outlined various failures or deficiencies by APHIS that we identified when they developed the proposed Rulemaking.
We have continued to work diligently digesting and analyzing the notice of the proposed rule, collecting information, doing research and discussing the proposed Rulemaking and the Industry response. We also met with the Small Business Administration (SBA) Office of Advocacy in the rulemaking proceeding. The SBA Office of Advocacy is an independent executive branch office. SBA Advocacy’s mission is to be an advocate for small businesses in addressing the impacts of proposed agency rules. APHIS determined that the proposed rule would not impact a significant number of small businesses; we strongly disagree. It was important for us to engage SBA Advocacy and to demonstrate to it that, in fact, the proposed rule will negatively impact a significant number of small businesses – from shows, to farriers, to trainers, to DQPs and so on.