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Comments of MARY CULPEPPER   
Member of the Coalition to Ban Horse-Drawn Carriages

A standing committee of The Coalition for New York City Animals, Inc.  

With regard to proposed changes to Chapter 4 of Title 24 of the Rules of the City of   New York and Article 161 of the NYC Health Code

February 3, 2010        

My name is Mary Culpepper and I am providing comments on behalf of the Coalition to Ban Horse-Drawn Carriages, of which I am a member.

I would like to thank the Department of Health and Mental Hygiene for its efforts to reappraise important issues that affect the carriage horses’ health and well-being. As others have said previously, the proposed amendments are based on a rationale of keeping the industry viable. As the proposed amendments suggest, the burden of enforcement falls largely on the industry itself, a circumstance that necessarily is problematic. Yet, clearly there has been little enforcement of existing laws.

Chapter 4 – Title 24

§ 4-04. Horse Care.

My comments focus primarily on the documented inadequacy of water for the horses. Predictably, the proposed amendments are sufficiently vague about:

·    how much water is needed for these work horses

·    how it is to be provided, and

·    how to bridge the gap between current and ideal practice.

The proposed amendments fall short.

The comptroller’s 2007 audit of the industry documented numerous problems stemming from inadequate oversight by both the Departments of Health, and the Department of Consumer Affairs—the two city agencies that have the charge of monitoring the industry.

Then-comptroller Thompson was quoted in 2007 as saying that the agencies entrusted with oversight have “dropped the ball.” As a result, it is the horses who suffer. The audit cited lax veterinary care, infrequent inspections, and one of the most basic unmet needs of all—an inadequate water supply.

The proposed amendments state that “adequate supplies of potable water” shall be available to the horses, and that “troughs shall be cleaned daily.” It further states that sufficient nutritional foods and water shall be provided “free of dust, mold, vermin and other contaminants” in accordance with the health code (§161.21), which concedes that bird droppings are a common contaminant in the horses’ troughs. 

As we have seen, and as others have commented, the Department of Health is unable to address the issues of adequate water supply for carriage horses.  The spigots for the two troughs in Central Park are turned off for half of the year, eliminating the possibility that horses may obtain necessary water. In hot weather when water may possibly be found in these troughs, it is likely to be a microbial soup that is tainted by rubbish and bird droppings.

Winter considerations

The consequences of water deprivation are high throughout the year.1 Despite industry shortcomings in providing water during the summer, the horses’ needs are equally acute during the winter. Inadequate water supply is a contributing factor in impaction colics—a serious illness in horses. A recent article from the equine veterinary service of Michigan State University on general horse health states that “many horses will suffer from impaction colics due to inadequate water intake. Older horses may require the water to not only be frost free, but warmed because they have sensitive teeth.”2,3

Dehydration is one of the most common causes of impaction colic.1,3

As the comptroller’s audit disclosed, and as any casual observer can see, lack of water is a problem year-round. I have provided some photographs that were taken last week [Wednesday, January 27, 2010] and these show empty water troughs, a common scenario. The Grand Army trough had a small amount of dirty water in it, and the 6th Avenue trough was empty. The photographer has told me that no horses were seen receiving water from buckets or hydrants during the approximately 30 minutes that the horses were observed. Carriage drivers often state that they carry buckets of water to give the horses. If this were feasible, it would be insufficient in terms of amounts. It is completely implausible, for obvious reasons.

Heat, humidity, and water

Adequate water consumption is critical during the hot weather months, in which heat stress is a risk for horses.  A 1000-pound resting horse needs at least 10 to 12 gallons of fresh, clean water daily. These needs increase as air temperature rises, even in horses who are not working. Veterinary experts have said that in temperatures 70 degrees Fahrenheit or higher, working adult horses can “easily consume 20 to 25 gallons of water per day.”4

These needs also underscore the importance of setting temperature limits that take into account relative humidity—a factor that is not addressed in the Administrative code. Sweating is the primary cooling mechanism in the horse, and relative humidity impairs the evaporation of sweat.

Substantial evidence from the veterinary world supports a rationale for setting meaningful monitoring standards for excessive heat—specifically, defining and enforcing an environmental heat stress index. This is the SUM OF TEMPERATURE AND HUMDITY. An environmental heat stress index above 140 has been identified as an indication for caution—especially for working horses.4

Advocates have made the case for years that the horses do not have year-round access to water in the park. A carriage industry bill has language that would require the city of New York to pay for the installation of piping to heat the water year round. The industry should pay for it. It is irresponsible to support a bill that would incur city expenditures to prop up a controversial, private, cash-only industry that should not be subsidized by the city.

It was around the time of the 2007 audit that national animal advocacy groups united in support of a ban. They said the industry cannot be made humane. Little has changed for the horses since then. There has been no meaningful reform or improvements in care.

The horses still don’t have water.

This industry is the essence of animal exploitation. The answer should be relatively simple in 2010. It is time to ban horse-drawn carriages. The industry is inhumane and dangerous to humans as well as horses.


1. Fluid balance in the horse. Michigan State University. My Horse University. Available at: Accessed February 2, 2010.

2. Surviving January: Tips for Deep Freeze Horse Care from Michigan State's Vet School Experts. Available at:

3. Equine colic: causes, symptoms, treatment, and prevention. Michigan State University. January 2010. Available at: Accessed February 3, 2010.

4. Marteniuk J. Hot Weather Care for Horses. Michigan State University College of Veterinary Medicine Website. Available at: Accessed February 2, 2010.

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