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entitled 'Horse Welfare: Action Needed to Address Unintended 
Consequences from Cessation of Domestic Slaughter' which was released 
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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

June 2011: 

Horse Welfare: 

Action Needed to Address Unintended Consequences from Cessation of 
Domestic Slaughter: 

GAO-11-228: 

GAO Highlights: 

Highlights of GAO-11-228, a report to congressional committees. 

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 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. 

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. 

View [hyperlink, http://www.gao.gov/products/GAO-11-228] or key 
components. For more information, contact Lisa Shames at (202) 512-
3841 or shamesl@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

U.S. Slaughter Horse Market Has Changed Since Domestic Slaughter 
Ceased in 2007: 

Horse Welfare Has Reportedly Declined, Although the Extent Is Unknown, 
Straining the Resources of State and Local Governments, Tribes, and 
Animal Welfare Organizations: 

USDA's Oversight of the Welfare of Horses Transported for Slaughter Is 
Complicated by Three Challenges: 

Conclusions: 

Matters for Congressional Consideration: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Results of the Econometric Analysis of Horse Sale Prices: 

Appendix III: Comments from the U.S. Department of Agriculture: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

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: 

Table 2: Semi-log Coefficients for Hedonic Quantile Regression of 
Horse Prices: 

Figures: 

Figure 1: USDA Owner/Shipper Certificate to Document Horses' Fitness 
to Travel to a Slaughtering Facility: 

Figure 2: Number of Horses Slaughtered in the United States, 1990 
through 2007: 

Figure 3: U.S. Exports of Horses Intended for Slaughter and Other 
Purposes, 2004 through 2010: 

Figure 4: Distribution of Horse Prices from the Horse Auctions Used in 
the Analysis, Spring 2004 through Spring 2010: 

Figure 5: Average Horse Prices Before and After Cessation of Horse 
Slaughter for Each Price Category, Spring 2004 through Spring 2010: 

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: 

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: 

Figure 8: Wild Horse Herd on Degraded Land Owned by the Yakama Nation 
in Washington State: 

Figure 9: Slaughter Horse Transport Program's Budget Obligations, 
Fiscal Years 2005 through 2010: 

Figure 10: Sections of USDA Owner/Shipper Certificate to be Completed 
by Shippers or Canadian or Mexican Officials: 

Figure 11: Number of Investigation Cases and Alleged Violators of the 
Slaughter Horse Transport Program Regulation, Fiscal Years 2005 
through 2010: 

Figure 12: Example of Transport of Horses to Slaughtering Facilities 
Before and After Domestic Slaughter Ceased: 

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: 

[End of section] 

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 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.[Footnote 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 program implemented by USDA in February 
2006.[Footnote 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.[Footnote 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 and slaughter. In addition, we visited border crossings, 
horse auctions, and tribal lands to observe how horses are handled and 
processed. More specifically, to examine the effect on the U.S. horse 
market since domestic slaughter ceased in 2007, we collected and 
analyzed horse trade data for fiscal years 2005 through 2010--to cover 
the 2 years before and after domestic slaughter ceased--from USDA and 
the Department of Commerce and horse sales data from three large, 
geographically dispersed, U.S. livestock auctions for spring 2004 
through spring 2010. Using these data, along with other data, 
including economic data from the Department of Labor, we developed an 
econometric model to analyze the effect of the slaughter cessation on 
horse prices while controlling for other factors, such as the U.S. 
recession that began in December 2007. We selected five academic 
experts who have published studies of the horse industry to review our 
model specifications and results for any fatal flaws; they generally 
found the model and results credible. To examine the impact of horse 
market changes on horse welfare and states, local governments, tribes, 
and animal welfare organizations, we also used semi-structured 
interviews to systematically collect the views of the State 
Veterinarian in each of a sample of 17 states that generally have the 
largest horse populations and economies.[Footnote 4] In some cases, 
this official 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 on the situations faced by these 17 states. We 
performed a content analysis of the results of these interviews to 
identify common themes and the frequency with which certain issues 
were raised regarding the impacts of changes in the horse market. 
Furthermore, to examine the challenges to USDA's oversight of the 
transport of U.S. horses exported for slaughter, we identified and 
analyzed a generalizable sample of about 400 horse shipping forms for 
fiscal years 2005 through 2009 that are maintained by the transport 
program. Each form represents one load or shipment of horses. Using 
the data from these forms and mapping software, we estimated distances 
that horses traveled to slaughter before and after domestic slaughter 
ceased. Appendix I provides further detail on our scope and 
methodology. 

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. 

Background: 

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.[Footnote 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 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. 

Figure 1: USDA Owner/Shipper Certificate to Document Horses' Fitness 
to Travel to a Slaughtering Facility: 

[Refer to PDF for image: certificate] 

According to the Paperwork Reduction Act of 1995, an agency may not 
conduct or sponsor, and a person is not required to respond to, a 
collection of information unless it displays a valid OMB control 
number. The valid OMB control	umber for this information collection is 
05790160, The time	required to complete this information collection is 
estimated to average .29 hours per response, including the time for 
reviewing instructions, searching existing data sources, gathering and 
maintaining the data needed, and completing and reviewing the 
collection of information. 

OMB NO.	0579-0160: 

United States Department Of Agriculture	Animal And Plant Health 
Inspection Service Veterinary Services: 	 

Time Horses Loaded On Conveyance: 
Date:	
Vehicle License No. And Drivers Name:
Consignor (Owner/shipper) Name: 
Street Address: 
City, State, And Zip Code:	
Area Code And Telephone No. 

Owner/shipper Certificate: Fitness To Travel To A Slaughter Facility	
(Please type or print in ink): 

City And State Where Horses Were Loaded On Conveyance: 
Name Of Auction/market: 
Consignee (Receiver/destination/name:	
Street Address: 
City, State, And 2lp Code: 
Area Code And Telephone No.	 

Check The Box That Indicates The Following Is True For All The Horses 
On This Certificate:	 

Pregnant mares are not likely to foal (give birth) during the trip: 
Horses are able to bear weight on all 4 limbs: 
Foals are older than 6 months of age: 
Horses are not blind in both eyes: 
Horses are able to walk unassisted: 

Tag Prefix: 
Tag No. 
Color Description (Bay, Gray, Black, Pinto, Other): 
Breed/type (TB, QT, Draft, Pony, Other): 
Sex (Mare, Stal, Geld): 
Brands (tattoos, etc.): 
Remarks (include existing conditions): 

Horses have had access to food, water, and rest for a minimum of 6 
consecutive hours immediately before loading into conveyance. 
Signature: 
		
I hereby authorize the CFIA to disclose this document and the 
information in it as completed by the CFIA or DGIF to the USDA. 
Falsification of this form or knowingly using a falsified form is a 
criminal offense and may result in a fine of not more than $10,000 or 
imprisonment for not more than 5 years or both (16 U.S.C. section 
1001). 

Signature of Owner/shipper (I certify that the information contained 
in this form is true and correct to the best of my knowledge.) 
Date: 
Time: 

Canadian Food Inspection Agency (CFIA): 
Est: 
Date: 
Time: 

Direccion General De Inspeccion En Fronteras (DGIF): 
Est: 
Date: 
Time: 

VS Form 10-13:	
March 2010: 
Previous Editions Are Obsolete: 
																				
Source: USDA's Animal and Plant Health Inspection Service. 

[End of figure] 

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 discussed, the plants had already been shut 
down by state law that year.[Footnote 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.[Footnote 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 related to the transport program, and APHIS proposed 
specific actions and time frames for implementing the 
recommendations.[Footnote 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." 

U.S. Slaughter Horse Market Has Changed Since Domestic Slaughter 
Ceased in 2007: 

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. 

Horse Exports to Canada and Mexico Have Increased with the Cessation 
of Domestic Slaughter: 

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. 

Figure 2: Number of Horses Slaughtered in the United States, 1990 
through 2007: 

[Refer to PDF for image: vertical bar graph] 

Year: 1990; 
Number of horses slaughtered: 345,900. 

Year: 1991; 
Number of horses slaughtered: 276,700. 

Year: 1992; 
Number of horses slaughtered: 243,500. 

Year: 1993; 
Number of horses slaughtered: 169,900. 

Year: 1994; 
Number of horses slaughtered: 107,000. 

Year: 1995; 
Number of horses slaughtered: 109,200. 

Year: 1996; 
Number of horses slaughtered: 105,000. 

Year: 1997; 
Number of horses slaughtered: 87,200. 

Year: 1998; 
Number of horses slaughtered: 72,120. 

Year: 1999; 
Number of horses slaughtered: 62,813. 

Year: 2000; 
Number of horses slaughtered: 47,134. 

Year: 2001; 
Number of horses slaughtered: 56,332. 

Year: 2002; 
Number of horses slaughtered: 42,312. 

Year: 2003; 
Number of horses slaughtered: 50,062. 

Year: 2004; 
Number of horses slaughtered: 66,183. 

Year: 2005; 
Number of horses slaughtered: 94,037. 

Year: 2006 (Last full year of domestic slaughtering operations); 
Number of horses slaughtered: 104,899. 

Year: 2007; 
Number of horses slaughtered: 29,767. 

Source: GAO analysis of USDA’s National Agricultural Statistics 
Service data. 

[End of figure] 

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 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: 

[Refer to PDF for image: vertical bar graph] 

Calendar year: 2004; 
For slaughter: 23,782; 
For other purposes: 32,632; 
Total: 56,414. 

Calendar year: 2005; 
For slaughter: 25,145; 
For other purposes: 36,078; 
Total: 61,223. 

Calendar year: 2006; 
For slaughter: 32,789; 
For other purposes: 18,846; 
Total: 51,635. 

Calendar year: 2007 (May—-Two Texas slaughter facilities closed; 
September—-Illinois slaughter facility closed); 
For slaughter: 78,061; 
For other purposes: 21,111; 
Total: 99,172. 

Calendar year: 2008; 
For slaughter: 99,049; 
For other purposes: 55,077; 
Total: 154,126. 

Calendar year: 2009; 
For slaughter: 109,487; 
For other purposes: 39,340; 
Total: 148,827. 

Calendar year: 2010; 
For slaughter: 137,984; 
For other purposes: 30,027; 
Total: 168,011. 

Sources: GAO analysis of Department of Commerce Foreign Trade data and 
USDA Foreign Agricultural Service documents. 

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. 

[End of figure] 

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 figure 2) and those sent for 
slaughter in Canada or Mexico (i.e., 32,789, as shown in figure 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. 

Horse Sales and Prices Have Declined Since 2007, Especially for Lower- 
Valued Horses: 

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 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.[Footnote 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 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.[Footnote 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: 

[Refer to PDF for image: vertical bar graph] 

Median: $1,400 per head. 
Average: $2,140 per head. 

Price: $500; 
Percentage of horses: 17%. 

Price: $1,500; 
Percentage of horses: 37%. 

Price: $2,500; 
Percentage of horses: 20%. 

Price: $3,500; 
Percentage of horses: 10%. 

Price: $4,500; 
Percentage of horses: 5%. 

Price: $5,500; 
Percentage of horses: 3%. 

Price: $6,500; 
Percentage of horses: 2%. 

Price: $7,500; 
Percentage of horses: 1%. 

Price: $8,500; 
Percentage of horses: 1%. 

Price: $9,500; 
Percentage of horses: 1%. 

Price: $10,500; 
Percentage of horses: 0%. 

Price: $11,500; 
Percentage of horses: 1%. 

Price: $12,500 to $48,500; 
Percentage of horses: less than 2%. 

Source: GAO analysis of horse auction sales data. 

[End of figure] 

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.[Footnote 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). 

Figure 5: Average Horse Prices Before and After Cessation of Horse 
Slaughter for Each Price Category, Spring 2004 through Spring 2010: 

[Refer to PDF for image: multiple line graph] 

Lower price category (percentile): 20th; 
Before cessation (2004-2006):	$433; 
After cessation (2007-2010): $323. 

Lower price category (percentile): 40th; 
Before cessation (2004-2006):	$891; 
After cessation (2007-2010): $784. 

Higher price category (percentile): 50th; 
Before cessation (2004-2006):	$1,340; 
After cessation (2007-2010): $1,178. 

Higher price category (percentile): 60th; 
Before cessation (2004-2006):	$1,684; 
After cessation (2007-2010): $1,537. 

Higher price category (percentile): 80th; 
Before cessation (2004-2006):	$2,380; 
After cessation (2007-2010): $2,241. 

Source: GAO analysis of horse auction data. 

[End of figure] 

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.[Footnote 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. 

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: 

[Refer to PDF for image: vertical bar graph] 

Lower price category (percentile): 20th; 
Effect on price from closing horse slaughter facilities: -20.93%; 
Effect on price from economic downturn: -5.15%. 

Lower price category (percentile): 40th; 
Effect on price from closing horse slaughter facilities: -10.42%; 
Effect on price from economic downturn: -5.23%. 

Higher price category (percentile): 50th; 
Effect on price from closing horse slaughter facilities: -7.83%; 
Effect on price from economic downturn: -4.8%. 

Higher price category (percentile): 60th; 
Effect on price from closing horse slaughter facilities: -3% (not 
significant); 
Effect on price from economic downturn: -4.69%. 

Higher price category (percentile): 80th; 
Effect on price from closing horse slaughter facilities: -1% (not 
significant); 
Effect on price from economic downturn: -4.76%. 

Source: GAO analysis of horse auction data. 

[End of figure] 

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. 

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: 

Type of change: Cessation of slaughter on horse prices (per head): 
[Empty]; Cessation of slaughter on horse prices (per head): [Empty]. 

Variable: Cessation of slaughter on horse prices (per head); 
Type of change: Price change; 
Effect by sale price category (percentile): 
20th: -$125.61; 
40th: -$104.24; 
50th (median): -$109.58; 
60th: [A]; 
80th: [A]. 

Variable: Cessation of slaughter on horse prices (per head); 
Type of change: Percentage change; 
Effect by sale price category (percentile): 
20th: -20.93%; 
40th: -10.42%; 
50th (median): -7.83%; 
60th: [A]; 
80th: [A]. 

Variable: Economic downturn on horse prices (per head); 
Type of change: Price change; 
Effect by sale price category (percentile): 
20th: -$30.90; 
40th: -$52.26; 
50th (median): -$67.22; 
60th: -$82.09; 
80th: -$142.91. 

Variable: Economic downturn on horse prices (per head); 
Type of change: Percentage change; 
Effect by sale price category (percentile): 
20th: -5.15%; 
40th: -5.23%; 
50th (median): -4.80%; 
60th: -4.69%; 
80th: -4.76%. 

Variable: Upper bound for category (price per head); 
Effect by sale price category (percentile): 
20th: $600; 
40th: $1,000; 
50th (median): $1,400; 
60th: $1,750; 
80th: $3,000. 

Source: GAO analysis of data from selected horse auctions and the 
Department of Labor's Bureau of Labor Statistics. 

[A] The effect on price was not statistically significant for that 
category. 

[End of table] 

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 Has Reportedly Declined, Although the Extent Is Unknown, 
Straining the Resources of State and Local Governments, Tribes, and 
Animal Welfare Organizations: 

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. 

Cases of Horse Abandonments, Abuse, and Neglect Have Reportedly 
Increased Since 2007: 

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. 

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: 

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. 

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"). 

State and Local Governments, Tribes, and Animal Welfare Organizations 
Are Affected by Neglected and Abandoned Horses, as Is the Federal 
Government: 

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. 

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: 

[Refer to PDF for image: photograph] 

Source: Larry Mayer/Billings Gazette. Photo used with permission. 

[End of figure] 

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. 

Figure 8: Wild Horse Herd on Degraded Land Owned by the Yakama Nation 
in Washington State: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

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 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.[Footnote 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.[Footnote 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.[Footnote 
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 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. 

States and Tribes Have Taken a Variety of Actions Related to Horse 
Welfare and Slaughter: 

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. In 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 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's Oversight of the Welfare of Horses Transported for Slaughter Is 
Complicated by Three Challenges: 

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. 

Management Challenges Affect APHIS's Implementation of the Slaughter 
Horse Transport Program: 

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 Has Not Issued a Final Rule to Better Protect Horses Transported 
for Slaughter: 

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. 

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[Footnote 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 significant under 
Executive Order 1286[Footnote 17]6. 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.[Footnote 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. 

Limited Staff and Funding Complicates Program Implementation: 

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 certificates for compliance with the transport 
regulation, with the remainder going to travel costs.[Footnote 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. 

Figure 9: Slaughter Horse Transport Program's Budget Obligations, 
Fiscal Years 2005 through 2010: 

[Refer to PDF for image: vertical bar graph] 

Fiscal year: 2005; 
Obligations: $306,475. 

Fiscal year: 2006; 
Obligations: $269,902. 

Fiscal year: 2007; 
Obligations: $216,456. 

Fiscal year: 2008; 
Obligations: $25,6505. 

Fiscal year: 2009; 
Obligations: $118,877. 

Fiscal year: 2010; 
Obligations: $204,189. 

Source: USDA’s Slaughter Horse Transport Program. 

[End of figure] 

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 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.[Footnote 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.[Footnote 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. 

Uneven Cooperation with Canadian, Mexican, and State Officials Impedes 
Oversight: 

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.[Footnote 22] 

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. 

Figure 10: Sections of USDA Owner/Shipper Certificate to Be Completed 
by Shippers or Canadian or Mexican Officials: 

[Refer to PDF for image: illustration] 

Completed by shippers: 

United States Department Of Agriculture	Animal And Plant Health 
Inspection Service Veterinary Services: 	 

Time Horses Loaded On Conveyance: 
Date:	
Vehicle License No. And Drivers Name:
Consignor (Owner/shipper) Name: 
Street Address: 
City, State, And Zip Code:	
Area Code And Telephone No. 

Owner/shipper Certificate: Fitness To Travel To A Slaughter Facility	
(Please type or print in ink): 

City And State Where Horses Were Loaded On Conveyance: 
Name Of Auction/market: 
Consignee (Receiver/destination/name:	
Street Address: 
City, State, And 2lp Code: 
Area Code And Telephone No.	 

Check The Box That Indicates The Following Is True For All The Horses 
On This Certificate:	 

Pregnant mares are not likely to foal (give birth) during the trip: 
Horses are able to bear weight on all 4 limbs: 
Foals are older than 6 months of age: 
Horses are not blind in both eyes: 
Horses are able to walk unassisted: 

Completed by Canadian or Mexican officials: 

Canadian Food Inspection Agency (CFIA): 
Est: 
Date: 
Time: 

Direccion General De Inspeccion En Fronteras (DGIF): 
Est: 
Date: 
Time: 

Source: USDA’s Animal and Plant Health Inspection Service. 

Note: Direccion General de Inspeccion en Fronteras is the agency 
within Mexico's agriculture department that conducts inspections at 
the border. 

[End of figure] 

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.[Footnote 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.[Footnote 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.[Footnote 25] APHIS officials said that they drafted an 
agreement in 2002, similar to the one with CFIA, and that APHIS had 
contacts with SAGARPA 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.[Footnote 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 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.[Footnote 27] 

Legislative Prohibitions Impede USDA's Ability to Ensure Horse Welfare: 

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 
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. 

Figure 11: Number of Investigation Cases and Alleged Violators of the 
Slaughter Horse Transport Program Regulation, Fiscal Years 2005 
through 2010: 

[Refer to PDF for image: multiple line graph] 

Fiscal year: 2005; 
Alleged violators: 166; 
Investigation cases: 114. 

Fiscal year: 2006; 
Alleged violators: 71; 
Investigation cases: 47. 

Fiscal year: 2007; 
Alleged violators: 117; 
Investigation cases: 57. 

Fiscal year: 2008; 
Alleged violators: 56; 
Investigation cases: 43. 

Fiscal year: 2009; 
Alleged violators: 85; 
Investigation cases: 51. 

Fiscal year: 2010; 
Alleged violators: 64; 
Investigation cases: 32. 

Source: GAO analysis of USDA’s APHIS data. 

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. 

[End of figure] 

Cessation of Domestic Slaughter Has Diminished APHIS's Ability to 
Implement the Transport Regulation to Protect Horse Welfare: 

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, well within the interior of the 
country. In addition, the conveyances that horses are transferred to 
for travel in Mexico are not subject to the requirements of the 
transport regulation. 

Our analysis of a sample of owner/shipper certificates for 2005 
through 2009 showed that, in 2005 and 2006, before domestic slaughter 
ceased, horses traveled an average of 550 miles after being designated 
for slaughter. In contrast, in 2008 and 2009, after domestic slaughter 
ceased, our analysis showed horses intended for slaughter traveled an 
average of 753 miles--an increase of about 203 miles.[Footnote 28] 
(The actual distances that the horses traveled, on average, before and 
after the cessation is likely to be greater than what our analysis 
showed because some shippers were prone to designate horses intended 
for slaughter close to the slaughtering facility before cessation, or 
near the border after cessation.) Over the longer distances horses now 
travel to Canadian and Mexican slaughtering facilities, APHIS is less 
able to effectively implement the transport regulation to protect 
horse welfare. Figure 12 provides an example of contrasting shipping 
routes and relative travel distances from before and after domestic 
slaughter ceased. 

Figure 12: Example of Transport of Horses to Slaughtering Facilities 
Before and After Domestic Slaughter Ceased: 

[Refer to PDF for image: illustration] 

The illustration depicts the following in the U.S. and Mexico: 

Transport of horses before domestic slaughter ceased; 
Transport of horses after domestic slaughter ceased; 
Auction/sale point; 
Assembly point/farm; 
Feedlot/stockyard; 
Slaughtering facility. 

Source: GAO analysis of USDA documents; Art Explosion (images); MapArt 
(map). 

[End of figure] 

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 period. Upon transfer of title, the animals lose 
their status as wild free-roaming horses and burros. As we reported in 
2008,[Footnote 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.[Footnote 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. 

Conclusions: 

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 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 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. 

Matters for Congressional Consideration: 

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. 

Recommendations for Executive Action: 

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. 

Agency Comments and Our Evaluation: 

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 [hyperlink, 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. 

Signed by: 

Lisa Shames: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

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. 
[Footnote 31] 

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 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. 
[Footnote 32] 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 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 catalog 
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).[Footnote 33] Thus, 
we specified a horse's sale price as a function of variables that 
describe its 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.[Footnote 34] 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.[Footnote 35] 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. 
[Footnote 36] 

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 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).[Footnote 37] 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. 

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.[Footnote 38] 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.[Footnote 39] 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 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 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. 

[End of section] 

Appendix II: Results of the Econometric Analysis of Horse Sale Prices: 

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 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.[Footnote 40] 

Table 2: Semi-log Coefficients for Hedonic Quantile Regression of 
Horse Prices: 

Explanatory variable[B]: Age of horse; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: 0.218***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 0.233***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 0.241***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: 0.243***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 0.221***. 

Explanatory variable[B]: Age of horse squared; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.007***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.007***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.007***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.007***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.006***. 

Explanatory variable[B]: Gender mare (female); 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: 0.220***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 0.180**; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 0.086; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: 0.103; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 0.129. 

Explanatory variable[B]: Gender gelding (neutered male); 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: 0.879***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 0.882***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 0.780***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: 0.767***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 0.568***. 

Explanatory variable[B]: Interaction of mare with age; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.061***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.071***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.068***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.073***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.075***. 

Explanatory variable[B]: Interaction of gelding with age; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.059***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.081***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.086***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.094***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.094***. 

Explanatory variable[B]: Southern auction; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: 0.488***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 0.532***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 0.477***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: 0.504***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 0.535***. 

Explanatory variable[B]: Eastern auction; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: 0.860***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 0.924***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 0.878***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: 0.813***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 0.809***. 

Explanatory variable[B]: Fall auction; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.274***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.204***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.201***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.173***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.126***. 

Explanatory variable[B]: Auction no-sale percentage; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.020***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.020***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.016***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.016***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.012***. 

Explanatory variable[B]: Breed Quarter horse; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: 0.216***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 0.291***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 0.321***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: 0.323***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 0.381***. 

Explanatory variable[B]: Breed Paint horse; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.138**; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.134***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.092*; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.068; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.094*. 

Explanatory variable[B]: Breed Appaloosa horse; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.111; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.156; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.272*; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.348*; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.392**. 

Explanatory variable[B]: Breed ponies & miniature horse; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: 0.075; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 0.117; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 0.132; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: 0.217**; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 0.201**. 

Explanatory variable[B]: Breed Thoroughbred horse; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.437***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.667**; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.385; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.430; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.407**. 

Explanatory variable[B]: Breed other (misc.) horse; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.082; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 0.017; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 0.023; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.054; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.011. 

Explanatory variable[B]: Economic downturn; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.053***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.054***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.049***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.048***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: -0.049***. 

Explanatory variable[B]: Cessation of domestic slaughter; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: -0.235***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: -0.110***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): -0.082***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: -0.028; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 0.034. 

Explanatory variable[B]: Constant; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 20th: 5.817***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 40th: 6.136***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 50th (median): 6.276***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 60th: 6.450***; 
Estimated coefficients by quantile (percentile) of horse price 
distribution[A]: 80th: 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. 

[A] The 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). 

[B] In 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. 

[End of table] 

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. 

[End of section] 

Appendix III: Comments from the U.S. Department of Agriculture: 

USDA: 
United States Department of Agriculture: 
Office of the Secretary: 
Washington, D.C. 20250: 

June 20, 2011: 

Ms. Lisa Shames: 
Director: 
Natural Resources and Environment: 
United States Government Accountability Office: 
441 G Street, NW: 
Washington, D.C. 20548: 

Dear Ms. Shames: 

The United States Department of Agriculture (USDA) appreciates the 
opportunity to review and provide comments on the GAO's Draft Report, 
"Horse Welfare: Action Needed to Address Unintended Consequences from 
Cessation of Domestic Slaughter" (GAO 11-228). We have addressed the 
Recommendations for Executive Action. 

To better protect the welfare of horses transported to slaughter, GAO 
recommends that the Secretary of Agriculture direct the Administrator 
of APHIS to take the following four actions: 

Recommendation 1: Issue as final a proposed rule to amend the Commercial
Transportation of Equines to Slaughter regulation to define "equine 
for slaughter" so that USDA's oversight and the regulation's 
protection extend to more of the transportation chain. 

USDA Response: The Department will move as quickly as possible to 
issue a final rule. Because, as this report indicates, Tribal Nations 
are experiencing particularly serious impacts from abandoned horses, 
it is crucial that we enter into formal consultations with them on 
this rule. If we can successfully conclude those negotiations in the 
next two months, we will publish the rule by the end of this calendar 
year. But, USDA needs time to also thoughtfully consider those 
consultations in regards to the regulation's implementation. 

Recommendation 2: 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 actions. 

USDA Response: USDA is training additional Veterinary Services port 
personnel in Slaughter Horse Transport Program enforcement activities 
at the Texas ports of embarkation. In fiscal year 2012, we will expand 
this effort within the allocated budget. We are also training 
administrative personnel to evaluate certificates for enforcement 
purposes. USDA stopped entering information into a database in 2005 
because the process was labor intensive and costly. USDA will explore 
whether new technologies have made the process less costly and, if we 
find that we can conduct this activity within existing funding, we 
will do so. 

Recommendation 3: 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. 

USDA Response: USDA will consult with CFIA and propose revisions to 
the current agreement. 

Recommendation 4: Seek a formal cooperative agreement with SAGARPA 
that describes the agencies' mutual understanding of assistance APHIS 
seeks from SAGARPA on 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 crossing through which most shipment of 
U.S. horses intended for slaughter pass. 

USDA Response: USDA will consult with SAGARPA and the Texas Department 
of Agriculture and propose the development of formal agreements with 
one or both. 

Once again, we appreciate the opportunity to respond to GAO's draft 
report "Horse Welfare: Action Needed to Address Unintended 
Consequences from Cessation of Domestic Slaughter" and hope that our 
comments will help GAO in the preparation of its final report. If you 
have any questions, please contact Dr. John Clifford at (202) 720-5193. 

Sincerely, 

Signed by: 

Edward Avalos: 
Under Secretary: 
Marketing and Regulatory Programs: 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Lisa Shames (202) 512-3841 or shamesl@gao.gov: 

Staff Acknowledgments: 

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. 

[End of section] 

Related GAO Products: 

Live Animal Imports: Agencies Need Better Collaboration to Reduce the 
Risk of Animal-Related Diseases. [hyperlink, 
http://www.gao.gov/products/GAO-11-9]. November 8, 2010. 

Humane Methods of Slaughter Act: Weaknesses in USDA Enforcement. 
[hyperlink, http://www.gao.gov/products/GAO-10-487T]. March 4, 2010. 

Humane Methods of Slaughter Act: Actions Are Needed to Strengthen 
Enforcement. [hyperlink, http://www.gao.gov/products/GAO-10-203]. 
February 19, 2010. 

Humane Methods of Slaughter Act: USDA Inspectors' Views on 
Enforcement. [hyperlink, http://www.gao.gov/products/GAO-10-244SP]. 
February 19, 2010. 

Veterinarian Workforce: The Federal Government Lacks a Comprehensive 
Understanding of Its Capacity to Protect Animal and Public Health. 
[hyperlink, http://www.gao.gov/products/GAO-09-424T]. February 26, 
2009. 

Veterinary Workforce: Actions Are Needed to Ensure Sufficient Capacity 
for Protecting Public and Animal Health. [hyperlink, 
http://www.gao.gov/products/GAO-09-178]. February 4, 2009. 

Bureau of Land Management: Effective Long-Term Options Needed to 
Manage Unadoptable Wild Horses. [hyperlink, 
http://www.gao.gov/products/GAO-09-77]. October 9, 2008. 

Humane Methods of Handling and Slaughter: Public Reporting on 
Violations Can Identify Enforcement Challenges and Enhance 
Transparency. [hyperlink, http://www.gao.gov/products/GAO-08-686T]. 
April 17, 2008. 

USDA: Information on Classical Plant and Animal Breeding Activities. 
[hyperlink, http://www.gao.gov/products/GAO-07-1171R]. September 13, 
2007. 

National Animal Identification System: USDA Needs to Resolve Several 
Key Implementation Issues to Achieve Rapid and Effective Disease 
Traceback. [hyperlink, http://www.gao.gov/products/GAO-07-592]. July 
6, 2007. 

Workplace Safety and Health: Safety in the Meat and Poultry Industry, 
While Improving, Could Be Further Strengthened. [hyperlink, 
http://www.gao.gov/products/GAO-05-96]. January 12, 2005. 

Humane Methods of Slaughter Act: USDA Has Addressed Some Problems but 
Still Faces Enforcement Challenges. [hyperlink, 
http://www.gao.gov/products/GAO-04-247]. January 30, 2004. 

[End of section] 

Footnotes: 

[1] Federal law requires that all U.S. horses slaughtered for human 
consumption and placed in commerce be inspected. 

[2] This 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. 

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

[4] These states are California, Colorado, Florida, Indiana, Kentucky, 
Louisiana, Maryland, Missouri, Montana, New Mexico, New York, North 
Carolina, Ohio, Oklahoma, Pennsylvania, Texas, and Wyoming. Each state 
has a State Veterinarian who is hired by the state government to 
oversee animal health matters within the state. The duties of the 
staff in a State Veterinarian's office may include monitoring herds 
and flocks of animals for disease, regulating the movement of animals 
within and across state lines, animal welfare, and, in some states, 
meat inspection. 

[5] For more information on the Humane Methods of Slaughter Act, see 
GAO, Humane Methods of Slaughter Act: Weaknesses in USDA Enforcement, 
[hyperlink, http://www.gao.gov/products/GAO-10-487T] (Washington, 
D.C.: Mar. 4, 2010); Humane Methods of Slaughter Act: Actions Are 
Needed to Strengthen Enforcement, [hyperlink, 
http://www.gao.gov/products/GAO-10-203] (Washington, D.C.: Feb. 19, 
2010); and Humane Methods of Slaughter Act: USDA Inspectors' Views on 
Enforcement, [hyperlink, http://www.gao.gov/products/GAO-10-244SP] 
(Washington, D.C.: Feb. 19, 2010). 

[6] Two 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). 

[7] U.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). 

[8] APHIS's official response may be found at the end of the OIG 
report. 

[9] Ahern, 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. 

[10] The 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. 

[11] For the purpose of this discussion, we use the term "category" to 
refer generally to the quantiles of price from our analysis. 

[12] Specifically, we used an econometric model and hedonic quantile 
regression methods. For a more detailed explanation, see appendix I. 

[13] BLM 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. 

[14] GAO, Bureau of Land Management: Effective Long-Term Options 
Needed to Manage Unadoptable Wild Horses, [hyperlink, 
http://www.gao.gov/products/GAO-09-77] (Washington, D.C.: Oct. 9, 
2008). 

[15] This Web message is available at [hyperlink, 
http://www.blm.gov/wo/st/en/prog/wild_horse_and_burro/national/about/dir
ector.print.html]. 

[16] This proposed regulatory change is consistent with the definition 
of equine for slaughter in the Federal Agriculture Improvement and 
Reform Act of 1996. 

[17] Executive 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. 

[18] Shippers 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. 

[19] The 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. 

[20] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[21] Office of Management and Budget, Executive Office of the 
President, OMB Circular No. A-123, Management's Responsibility for 
Internal Control (Dec. 21, 2004). 

[22] GAO, National Security: Key Challenges and Solutions to 
Strengthen Interagency Collaboration, [hyperlink, 
http://www.gao.gov/products/GAO-10-822T] (Washington, D.C.: June 9, 
2010). 

[23] All 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. 

[24] The 95-percent confidence intervals for our estimates of 48 
percent and 60 percent are 28 to 69 percent and 49 to 71 percent, 
respectively. 

[25] In English, this would be the Secretary of Agriculture, Livestock 
Production, Rural Development, Fishery, and Food; this is Mexico's 
agriculture department. 

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

[27] The 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. 

[28] The 95-percent confidence intervals for estimates of 550, 753, 
and 203 miles are 492 to 608, 691 to 815, and 117 to 288, respectively. 

[29] [hyperlink, http://www.gao.gov/products/GAO-09-77]. 

[30] BLM 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. 

[31] The 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. 

[32] "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. 

[33] In a hedonic model, the individual coefficients of the regression 
variables represent the implicit price of each characteristic found in 
that good. 

[34] Quantiles 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. 

[35] Standard 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. 

[36] One 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. 

[37] An 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). 

[38] For 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. 

[39] These states are California, Colorado, Florida, Indiana, 
Kentucky, Louisiana, Maryland, Missouri, Montana, New Mexico, New 
York, North Carolina, Ohio, Oklahoma, Pennsylvania, Texas, and Wyoming. 

[40] A 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. 

[End of section] 

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