I was initially dismayed to hear about the widespread opposition to the 'strengthening' of the HPA. This includes the American Morgan Horse Association, which in the articles I have found issued a statement of blanket opposition. I can only hope that the actual letter was more nuanced (does anybody have a copy?). I do have some faith in the AMHA, and I thought I should read the proposed changes before making a judgement. I dug up the proposed changes with some trepidation. Within the last decade, the AMHA has severely relaxed their shoeing rules.* But, they have also made strides in enforcing their own rules (which are generally much stricter than the HPA) at shows.
I can see many good reasons why the AMHA would oppose these changes. I still hope they do (or already have) lay out plainly why they oppose these regulations, because that is important for coming up with better alternatives. But here are some of the issues I see:
First is the call for “Horse Protection Inspector (HPIs)” to inspect horses. For the AMHA, and even the ASHA (Saddlebred), these inspectors would mean an additional cost for a redundant office. Rated shows already have inspectors for USEF, which again has stricter regulations than the HPA. Tennessee Walking Horse shows are not regulated by USEF, which is why these outside inspectors have been deemed necessary. Currently the HPA specifies Walkers, Racking Horses, "and related breeds" as being required to give notice 30 days before the show, and supply records to APHIS within 72 hours. Who is considered a related breed? I expect there is also some concern as to the availability of these HPIs, considering other staff shortages within the USDA. This concern would be heightened by the proposal that these inspectors be required at all "Tennessee Walking Horse, Racking Horse, or related breed class or event at any horse show or exhibition" of any size. In effect, any show of any size, rated or not, that wanted to have saddleseat classes could be required to have two licensed inspectors on site. This is regardless of whether or not they had other inspectors, because HPIs must be "outside the industry." This is despite that fact that the proposed changes also state that only vets or vet techs can serve as HPIs- and vets are, assuredly, part of the industry.
Shippers (including commercial) would be required to have the address of the horse's regular farrier. While I appreciate the desire to be able to be able to penalize farriers who perform illegal shoeings, most farriers don't have a business address. You are asking them to make their home address public. And, not every horse that is being moved may have a regular shoer. What if they've been recently sold (the provision includes auctions)? These are minor issues, but it would be just as easy to require the information of the owner in the case that a horse be found in violation of the HPA.
The use throughout of the phrase "or can reasonably be expected." This grey area is, I think, meant to allow conscientious trainers some leeway, but it is in fact the root of how the previous inspection setup could fail. Inspectors didn't need to lie to allow soreing to continue, because the inspections had a large element of subjectivity.
The prohibition of pads (while still listing allowed hoof packing materials). I've had more than one horse who needed a pad or pads to remain sound, either to support a congenital abnormality (such as club foot) or protect a sensitive sole (not many Morgans for this, but I'm sure many Arabs).
In all, the HPA is long, contradictory (prohibits all action devices in one area, but only those that might cause irritation in another, etc.), and puts a great deal of pressure on trainers and exhibitors who already follow stricter regulations while leaving loopholes that allow for abuse.
There is no simple solution. I do think many breeds would benefit from being brought under USEF, though I understand the resistance to the cost involved. The prior iteration of the HPA lead to splintering of Walking Horse groups, as some folks took a stand and others tried to find ways around regulations. I'm not sure these proposed changes would be any more successful. I also think that education is a stronger, and more lasting, force than regulation.
*I was discussing this with another exhibitor. I find the long feet and weighted shoes being allowed in hunter and western classes now to be problematic. But, AMHA has not changed the maximum hoof length or weight in total, but rather allowed their maximums in more divisions. As the other exhibitor pointed out, the same horses are just now allowed to cross enter. As I am a fan of Morgans "doing it all," I can't be upset with horses crossing divisions. With turnbuckles and stacks already illegal, as well as action devices on show grounds, the rule changes of the last decade don't significantly impact the horse. I do choose to support shows that pick judges who more strictly adhere to the criteria of each division, rather than picking the 'flashiest' horse regardless of the class. This, to me, also includes penalizing park horses who are out of control or have the lopsided, jerky action associated with shortcuts.
UPDATE: It looks like AMHAs official statement was sent via email (that's what I get for letting my membership lapse). Their main issues with the amendments seem to be the APHIS inspectors and the banning of all pads.