City puts requirement to create Advisory Board out to pasture
for 25 years!

Comptroller Suggests Possible Concession for Carriage and Pleasure Horses

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Releasing a new audit today, New York City Comptroller William C. Thompson, Jr. called on the City departments of Consumer affairs and Health & Mental Hygiene to strengthen their oversight of the City’s carriage-horse industry.

“The carriage-horse industry is an important part of our City’s charm and appeal for New Yorkers and tourists alike,” Thompson said. “The City must take its role more seriously to ensure the health and well-being of carriage-horses and the regulation of the industry in general.”

He continued:  “As part of any campaign to adequately provide for the health and safety of these beautiful working animals, and in light of the development of the West Side Yards, the City should consider creating an actual concession within Central Park, to house both carriage and pleasure horses.  Not only would this serve as a popular attraction, but it would keep the horses away from city traffic and allow their health and welfare to be more easily monitored. 

“Horses were invaluable to the development of New York City and provide a romantic glimpse of our history.  While alienation of parkland is a serious undertaking, the recent loss of the Claremont Stable and the pending development of the West Side could effectively conspire to remove horses entirely from Central Park,” Thompson declared.

The New York City Department of Health and Mental Hygiene (DOHMH) and the Department of Consumer Affairs (DCA) are responsible for overseeing and licensing the horses, carriage-horse drivers, carriages and stables. DOHMH’s Veterinary Public Health Services (VPHS) reviews and approves carriage-horse license applications and Certificates of Health stating that horses are able to work.

Thompson’s audit - which can be viewed at www.comptroller.nyc.gov - analyzed whether DOHMH and DCA had adequate controls over the licensing of carriage-horses, drivers, carriages, stables, and comply with the City’s applicable rules and regulations. The audit covered July 1, 2005 to March 30, 2007. 

The audit determined that, for more than 25 years, DOHMH has failed to create a City-required Advisory Board, which could help to ensure that rules overseeing the industry are current and cover topics such as the size of horse stalls and age limits for horses.

“With the lack of such a board, regulations promoting the health, safety, and well-being of the carriage-horses remain broad and general in scope,” Thompson said. “DOHMH, for example, has no written guidelines regarding when and how often stables should be inspected. The agency’s veterinarian consultant only visited each of the stables five times in calendar year 2006 and did not even examine the condition of any horses in the field.”

During the audit certain issues were brought to the auditors’ attention by the carriage-horse owners/drivers and American Society for the Prevention of Cruelty to Animals (ASPCA) officials that affect the well-being of the horses, such as: no established hack stands (areas identifying where carriages may pick up passengers); no water spigots in areas where carriages wait to pick up passengers; inadequate drainage where horses line up, leaving horses to stand in pools of dirty water; and, materials such as concrete should be considered to replace asphalt where horses lineup because it becomes very hot during the summer. These, as well as other issues, could be addressed by the Advisory Board. 

Additionally, while DOHMH and DCA have regulatory responsibilities, the ASPCA has voluntarily stepped in to perform much more monitoring over the last few years.  ASPCA officials told auditors they took it upon themselves to increase their oversight of the carriage-horse industry because they witnessed a decline in monitoring by the City. DOHMH and DCA rely on the ASPCA to voluntarily perform inspections of the stables and of the horses, drivers, and carriages in the field, which ASPCA performs without a formal agreement.

“Without a formal agreement, DOHMH and DCA have relied upon yet have no control over the ASPCA’s voluntary monitoring activities,” Thompson said. “Since there is no official agreement regarding inspections, it is possible that the ASPCA may need to reduce or curtail its activities at some point, leaving a void in the oversight of the industry.”

During Fiscal Year 2006, there were approximately 221 licensed horses, 293 licensed drivers, and 68 licensed carriages that provided horse-drawn carriage rides to the public.

Additionally, Thompson’s auditors uncovered the following:

• In a review of VPHS files, 6 of the 143 Certificates of Health needed to renew a license had notations on the back that stated the certificates were received from DCA. Since DOHMH is required to ensure that every licensed horse is examined by a New York State-licensed veterinarian and is physically able to perform the work or duties required of it, DCA should not have accepted these applications and certificates, nor should they have issued a horse license or renewal. Instead, DCA should have returned the documents to the owners for submission to DOHMH for approval.

• According to the Administrative Code, DCA should inspect all horse-drawn carriages at least every four months and the results of those inspections are to be on an inspection card displayed in the carriage. DCA officials, however, said that they are not performing the inspections because it would not be a good use of their resources and instead send inspectors to the hack lines twice a year to perform inspections. Further, when auditors visited carriages in the field, drivers stated that they were never told about, nor did they receive, the inspection cards.

• Descriptive information on health certificates issued by veterinarians attesting to the health of individual carriage-horses often differed from one year to the next. The differing information included age, color, breed and name of the horse. In one instance, a horse was listed as a gelding (male) one year and a mare (female) the next year.

Auditors, however, did cite some positive findings. Auditors made unannounced visits to hack lines adjacent to Central Park and found that carriages had current license plates, horses had brass tags with identification numbers that matched the numbers branded into the hooves, and drivers held current driver’s licenses.

Additionally, DOHMH files contained the required training program and examinations to drivers of horse-drawn carriages and maintained the Certificates of Health for the horses. DCA files showed that it issued and renewed licenses to horses, carriages, and drivers.

Comptroller Thompson made 11 recommendations, in which DOHMH agreed with the five made to the agency, and DCA officials agreed with five of six made to them. Among the recommendations:

• DOHMH should establish the required Advisory Board, as set forth in the Administrative Code, and set clear regulations to promote the health, safety and well-being of the carriage-horses;

• DOHMH should establish written guidelines that include how often their veterinarian should inspect the stables as well as how often the horses should be evaluated in the field;

• DOHMH should determine how oversight for the monitoring of the established guidelines will be accomplished in the future. Should the determination be that an organization other than DOHMH is to be responsible, then a competitive contract should be considered;
  
• DCA should return to owners any renewal applications for horse licenses and the original Certificates of Health that have bypassed prior DOHMH approval for the owners to submit to DOHMH; and,

• DCA should comply with the Administrative Code and the City’s Rules by conducting the required carriage inspections or by entering into a formal agreement with the ASPCA that requires the ASPCA to perform all required carriage inspections.

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