New & Announcements

February 3, 2010

Testimony of Holly Cheever, DVM

Department of Mental Health and Hygiene
Commissioner of Health and Hygiene

Public Hearing re: Amending Chapter 4 of Title 24 of the Rules of the City of New York,
including Section 161.21 of the New York City Health Code

To whom it may concern:

As an equine veterinarian, licensed in the state of New York, and as a past consultant retained to examine New York City’s carriage horses at work and in their stables between 1988 and 1995, I would like to submit my comments on the proposed amendments cited above, whose purpose is to establish “more modern and humane standards for management, care and treatment” of rental horses involved in the tourist trade in this city. Though the intent of these amendments is laudable in attempting to make the carriage horses’ lives less stressful, inhumane and unnatural, they face an insurmountable obstacle in that there is no way that Manhattan street life can provide a humane, as opposed to survivable, existence for a carriage horse in my opinion.

As I have published in magazine articles and in Shelter Medicine for Veterinarians and Staff (2004, Blackwell Publishing, pp.504-5), New York’s high-rise canyons and unyielding city street surfaces, coupled with the high volume of vehicular traffic and the temperature extremes of both cold and heat, combine to create a setting in which the horses can show respiratory damage, exacerbation of lameness and experience traumatic accidents. Furthermore, in my opinion most of their stabling is antiquated, inadequate, unsafe, and, by housing horses on upper (second and third) floors, essentially condemns them to a wretched death in case of fire, since their panic will preclude getting them down their narrow ramps to safety in any conflagration.

For this reason, for the duration of the time that carriage horses remain a tourist attraction in this city, I concur with the new requirement in Article 161.12 of the New York City Health Code that states that beginning July 1, 2011 no new stables may be built with stalls above the first floor. The problem remains that New York needs to eliminate the dozens of stalls currently existing on second and third floors that are potential deathtraps for their occupants; the Department of Health clearly recognizes, with this amendment, that such upper level housing is unacceptable.

In addition, the amended Chapter 4-04, subdivision (d) requires that all stalls be at least 8’ x 8’, or 7’ x 10’ beginning July 1, 2011 in both old and new stables. Though this is better than the current tie stalls that restrict the horses unreasonably between the sides of their stall (after they have been restricted between the shafts of the carriage for their entire work shift),  the suggested size is still unacceptably small, especially when the breeds used in the carriage industry are taken into account. Many are of large draft horse stock requiring large housing space (12’ x 12’ or even 14’ x 14’) and, even more important, all require the essential benefit of daily turn-out into a paddock with appropriately matched companions. Since these horses never get the chance to stretch out on the turf, nor roll on their backs for the pleasure of scratching their harness rubs, nor stand together to mutually groom one another, the least they should be provided is a stall sufficient enough to allow them sufficient room to lie fully stretched out. My own horses have the ultimate heaven for horses in the northeast: their shelter is a deep run-in shed, and when their bedding is changed and there is a thick layer of soft shavings on the floor, every one of them lies down with limbs fully extended, flat on their sides, to get the benefit of a deep rest. New York City carriage horses are never given that pleasure.

Chapter 4-02, subdivision (b): microchipping.
I would like to recommend against the replacement of the visible-to-all hoof tattooing with microchipping, which will preclude the public and the enforcement agencies from being able to instantaneously and readily identify a horse. If microchipping is adopted as the means to track the carriage horses’ work shifts and ultimate dispositions, then hoof tattooing needs to continue as well since the agents and observers will not be able to readily scan the horses for their correct identity without the visible hoof tattoo. I fear that this change will make monitoring these animals’ well-being all the more challenging and fraught with abuse.

Adminstrative Code #17-330: this provides for once-annual physical examinations of the carriage horses. It is my opinion, due to the unnaturally stressful and challenging environment that these horses face, that they should be examined every 6 months instead.

Chapter 4-05, subdivision (b), paragraph (2): provides that carriage drivers carry  thermometers with them to enable them to determine when the ambient temperatures are too high or too low for the horses’ safety and comfort. There is a strong disincentive for drivers to put an end to their fares for the day by withdrawing their horses and returning them to the stables, so I cannot approve of an amendment that essentially puts the fox in charge of the henhouse. I recommend that the enforcement agencies be the ones to continue to monitor the temperatures since I do not trust the drivers to make that assessment for the horses’ best interests in every case. As it is, the upper limit of 90 degrees Fahrenheit, lacking the recommended factoring of the humidity as well (known as the Temperature-Humidity Index, or THI), in itself constitutes a health risk for the horses since, if the humidity is also high on a 90-degree day, horses are at greater risk for suffering heat stroke since they cannot cool themselves by sweating in hot, humid weather. The use of ‘wet bulb” readings, which reflect the degree of moisture in the air, provide a better monitoring system. All responsible monitors of equine competitions (e.g. cross country jumping) factor in both the temperature and humidity together: the sum of degrees Fahrenheit and the percentage humidity is the “THI” and should not exceed 140, ideally, or 150 absolutely. That would mean a 90 degree day with 60% humidity could become an overwhelming stressor on the horses’ ability to cool themselves sufficiently on hot days.
 I strongly urge that the assessment for when horses should leave the hack lines not be left in the hands of those who lose profit thereby.

Chapter 4-03 (e) Furloughs: the amendment proposes a rest period for each carriage horse of at least 5 weeks per year, with a minimum duration of at least one week per furlough. While the rest period is well-intended and better than none, it is not a substitute for the more critical need, from a physical and psychological/behavioral stand point, for daily “turn out”. There is no way that New York’s stables can provide an adjacent paddock for the horses to both relax physically and interact with one another, as social herd animals need to do. Unfortunately, this turn out is as necessary for a humane life for these horses as it is impossible to provide, and without it, these horses live an existence which is survivable but not humane, in my opinion.

In conclusion, I hope to see these horses taken out of New York City’s inhospitable environment for good someday. Until that time, I hope that you will consider my recommendations above as a means to try to improve their quality of life to the greatest extent under their hostile circumstances. I thank you for your attention in this matter and will be happy to answer any questions you may have.


Holly Cheever, DVM

Vice president, New York State Humane Association
Leadership Council, Humane Society Veterinary Medical Association
Consultant, Coalition to Ban Horse Drawn Carriages


Coalition To Ban
Horse-Drawn Carriages

A Committee of the Coalition For New York City Animals, Inc.

The Coalition for
NYC Animals, Inc.

P.O. Box 20247
Park West Station
New York, NY 10025


To honor
Bobby II Freedom
previously known as Billy
ID# 2873 rescued by the Coalition to Ban Horse-Drawn Carriages and Equine Advocates on June 25, 2010 from the New Holland auctions.

In memory of
Lilly Rose O'Reilly
previously known
as Dada ID# 2711
R.I.P.August, 2007