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The New York City carriage industry strongly opposes the moratorium imposed on
the Montreal caleches by Maire Denis Coderre, effective Tuesday, May 24, 2016, and
implores the court to grant the Montreal caleche industrys injunction. The
moratorium ordered by the Mayor of Montreal will have a real and extremely
damaging immediate impact on the people and horses who make up the industry. In
our view, there is sufficient evidence from both Montreal and New York City that the
carriage industry is a safe and humane industry, and should be allowed to continue,
as the Ville de Montreal studies possible reforms of regulations governing the

There is no question that caleches are an important part of Montreal history, culture
and tourism. In fact, no other citys horse-drawn vehicles rival New York Citys
famous Central Park carriages as the Montreal caleches. There is also no question
that commercial carriages are safe and humane for horses.

The carriage question has already been asked and answered in the affirmative in
New York City.

Mayor Bill de Blasio, backed by animal rights extremists, promised during his
campaign for mayor to ban horse-drawn carriages in New York City on his first day
in office, which was January 1, 2014. Legislation to ban carriages was introduced
into the New York City Council on December 8, 2014 (Int. 573). Lacking support in
the Council for a total ban of carriages, that legislation was revised in late 2015 to
instead move carriage horses into a stable to be built in Central Park, removing
them from city streets (Int. 573-A/B). Public hearings were held January 22, 2016
before the City Council Committee on Transportation.1

Due to overwhelming popular support for the carriages, support from many equine
veterinarians and horse groups, support from every major media outlet in New York
City, a lack of evidence showing carriage horses pose a danger to themselves or
others in traffic or simply by living in the city, and evidence that animal rights
groups had misled the public about the carriage industry, the City Council rejected
Int. 573-B on February 4, 2016. There are no further plans to revisit the carriage
issue in NYC.2

1 Text of Int. 573, Int. 573-A, and Int. 573-B, as well as transcripts of hearing
testimony can be found at this link:

2 Dana Rubinstein, Mocked, resented and now dead: De Blasios horse debacle
makes history, POLITICO New York (February 4, 2016)

Quick facts about the NYC carriage industry:

There are 68 licensed carriages in New York City. The carriages are driven by
licensed carriage drivers.

The carriage industry is overseen by five New York City agencies, and governed by
an extensive set of rules and regulations. These regulations have served as the
model for regulations in other cities where carriages operate.

The approximately 200 licensed NYC carriage horses live in 4 stables on the west
side of Manhattan. These stables were all built as stables in the late 19th and early
20th centuries, and house approximately 130-140 horses at any given time. The
remainder of the horses are on furlough outside of the city.

Among many other requirements, city law requires that each licensed carriage
horse receive at least 5 weeks furlough outside the city per year.

Carriage horses in New York City may not work if it is above 89 degrees Fahrenheit
or below 19 degrees Fahrenheit or in adverse weather conditions.

Carriage horses may only work 9 hours in any 24-hour period.

Carriage horses must be inspected by a veterinarian at least twice per year.

Veterinary Support and Science:

No equine veterinarian has found any evidence that NYC carriage horses are
neglected or abused. Instead, veterinarians have consistently reported that the
carriage horses are healthy and content.3

In March 2008, Dr. John E. Lowe of Cornell University conducted a body condition
exam and jogging inspection of 130 licensed New York City carriage horses. Dr.
Lowe found that all of the horses were in good body condition, with bright coats,
and calm, alert dispositions. He observed no respiratory issues. 96.8% of the

3 Dr. Harry Werner, Carriage Horses I Inspected Were Healthy And Content, New
York Times (January 17, 2014)
Dr. Mark Jordan, Vet: Carriage horses are healthy, happy and well-cared for New
York Daily News (April 20, 2014)

carriage horses examined at the trot were serviceably sound, indicating that
working on asphalt does not harm carriage horses.4

A 2014 retrospective study of carriage horse welfare in Charleston, South Carolina
demonstrated that horses in the commercial carriage industry there received
adequate care and were healthy, based on a review of veterinary records from 2009
to 2012. The study called for further research into carriage horse health, specifically
into stress levels in urban carriage horses. Animal rights extremists frequently claim
that simply living in urban areas, such as New York City, produces unseen stress in
carriage horses that is somehow inhumane.5

In August 2014, Dr. Joe Bertone of Western University conducted a cortisol study to
assess the stress levels of carriage horses living in New York City. Salivary and fecal
cortisol levels were measured in 12 carriage horses over 3 days, before, during and
after work. The study found that cortisol levels a measure of stress in carriage
horses working in New York City were very low, among the lowest levels in any
population Dr. Bertone has studied. Cortisol levels were also measured in carriage
horses on furlough in Pennsylvania, and found to be higher on the farm than in the
city. Dr. Bertones study confirmed that carriage horses are essentially stress-free
an observation that had previously been made by many equine vets through
examining carriage horse body language, health, and behavior.6

The carriage industry has opened its stable doors to dozens of equine veterinarians,
all of whom attest to the health and welfare of the carriage horses. The NYC carriage
industry has the support of a number of large veterinary and equine / animal
welfare organizations, such as the New York State Veterinary Medical Society, the
American Association of Equine Practitioners, the American Veterinary Medical
Association, the New York State Horse Council, the American Horse Council, the
Animal Welfare Council, and the American Farm Bureau Federation.7

4 Dr. Lowes summary jogging report can be found at

5 Julie M. Rosser, DVM, DACVS, and Anna Ardis, BS, BA, MAT
Clinic for Equine Surgery, Veterinary Medical University of Vienna, Vienna, Austria,
Retrospective Review of Carriage Horse and Mule Welfare in Charleston South
Carolina (2009-2012) Journal of Equine Veterinary Science June 2014, Vol. 34, Issue
6, pp. 816-819,


7 Statements of support from the following organizations:
New York State Veterinary Medical Society:

In sum, the veterinary and scientific evidence from observations of the NYC carriage
horses demonstrates that there is no harm that comes to horses from living in a
dense, urban environment and working pulling carriages, on shifts lasting up to 9
hours per day. The conclusion that carriage horses thrive living and working in
urban areas supports the conclusion drawn by Canadian veterinarians that carriage
horses in Montreal are healthy.

Public Support:

The carriage industry has overwhelming support from the public in NYC. Seven
consecutive scientific polls conducted by Quinnipiac University showed that New
Yorkers oppose banning carriage horses by a margin of 2 to 1.8

The editorial boards of all of the major newspapers in New York City, having toured
the carriage stables, having evaluated the (false) claims of anti-carriage animal
rights groups, and having met the men and women who work in the industry, all
support the continued operation of horse-drawn carriages. The New York Times, the
New York Daily News and the New York Post have all run multiple editorials in
support of the industry and in opposition to the proposed legislation.


The main concern about carriages in New York City expressed by Mayor de Blasio
and animal rights extremist groups has been that carriage horses work in traffic.
However, an examination of the data concerning carriage accidents reveals that
horse-drawn carriages are in fact the safest form of traffic on New York City streets.

The New York City Department of Transportation conducted a study from 2007
2014 of traffic in the Hells Kitchen neighborhood of Manhattan. The study area
included all but the last 4 blocks of the commute carriages make traveling between
the stables and Central Park everyday. The DOT, in studying congestion, accidents,
pedestrian concerns, and more, found absolutely no issues with carriages as an

New York State Horse Council:
American Association of Equine Practitioners:
American Veterinary Medical Association:
American Farm Bureau Federation:

8 7th Quinnipiac poll conducted January 2015, question #15.

ultimately miniscule part of Manhattan traffic. In fact, neither carriages nor horses
are mentioned at all in the extensive report.9

Meanwhile, traffic experts such as Charles Komanoff at Streetsblog determined that
horse-drawn carriages contribute very little to traffic congestion, although what
contribution they make may be seen as a positive. Carriages act as traffic calming
devices, ultimately making the areas where they work and travel safer for other
road users, such as pedestrians and bicyclists. Streetsblog also determined that
mile-for-mile, carriages in New York City are involved in fewer collisions than
yellow cabs, which already are the safest motor vehicles per mile traveled in

Further, carriage horses work on the same streets as NYPD Mounted Unit police
horses do. Likewise, Maire Coderre has not demanded a moratorium on the SPVMs
Cavalry or RCMP Cavalry, despite those horses working the streets of Montreal.11

At the January 22, 2016 hearing on Int. 573-A before the Committee on
Transportation, the Citys own witnesses testified that between 2009 and 2016
there had been 15 reported incidents involving carriages traveling between the
stables in Hells Kitchen and Central Park, or working the streets of the Times
Square district. Of those 15 incidents, 10 involved other vehicles, resulting in 4
minor injuries and no deaths to horses (and no human casualties). This extremely
low incidence of collisions and injury was ultimately judged by councilmembers on
the Committee on Transportation to not be significant enough to justify a $25
million expenditure on stables in Central Park, or to otherwise alter the regulations
governing carriage operations.12

Carriage Horse Retirement

Another issue that led to the defeat of the legislation to ban or limit the New York
City carriage industry was concern over what would happen to the carriage horses
should they lose their homes and jobs. Currently, carriage horses are rehomed by

9 NYC-DOT, Clinton/Hells Kitchen Neighborhood Traffic Study, Final Report 2014

10 Charles Komanoff, Shutting the Midtown Stables Wont Do Zilch For Manhattan
Traffic (January 19, 2016)

11 Adam Wisnieski, The Horses of New York City: Central Park Carriages and NYPD
Mounted (June 18, 2014)

12 Sandi Bachom,

their individual owners when they are ready to retire. New York City carriage
horses generally retire sound and fit just a little slower from age and, being so
well-trained, are desirable horses for smaller wedding carriage companies or people
looking for family horses, trail horses or beginner driving horses. Contrary to what
animal rights extremist groups allege, carriage horses are not sent to slaughter; they
are our work partners and every effort is made to find them suitable retirement
homes. The carriage industry also partners with Blue Star Equiculture, a draft horse
sanctuary in Palmer, Massachusetts that understands the particular needs of
retiring carriage horses.13

The initial ban bill, Int. 573, would have immediately made 200 carriage horses
homeless. Horse rescues/refuges in the United States are already over-capacity, and
there are simply not enough homes for all the horses that need them. Between
100,000 and 150,000 US horses are exported to Canada or to Mexico annually for
slaughter, and horse rescue workers speak of a homeless horse crisis that has
arisen following the 2008 recession. Although there were horse rescues who
claimed they would be willing to take in NYC carriage horses, there was no
guarantee of funding for their continued care, which was estimated over their
remaining lifetimes at $20 million. Further, carriage horses who did find a spot in a
horse rescue would be healthy fit horses taking up room that could be used to
rescue other needy horses from slaughter or neglect.14

The revised carriage legislation, Int 573-A/B, which would have moved the carriage
horses into Central Park, would have cut the number of horses in the industry in
half, and capped the number of licensed horses at 95. This still would have posed a
risk to carriage horses who lost their homes, would have overworked the remaining
carriage horses, and would have eliminated 95-100 good homes for horses.15

13 Rich Schapiro, After retirement, Central Park carriage horses still get to do what
they love: work, New York Daily News (May 8, 2014)
14 Mara Gay, EXCLUSIVE: Both major mayoral candidates want to ban horse-drawn
carriage rides in Central Park, but the effort to rescue the horses could lead to their
slaughter instead, New York Daily News (October 29, 2013)

15 Christina Hansen, De Blasios carriage plan is made for horse haters, New York
Post (February 1, 2016)

In short, both versions of the anti-carriage legislation in New York City would have
been bad for horses. As a result, many equine welfare advocates who work in horse
rescue opposed the bills.16

The Montreal moratorium likewise will place homeless caleche horses at risk for
slaughter or neglect, or will displace other horses in need from refuges. They are
fine where they are now being cared for and properly exercised by their owners,
who currently can afford to provide them with everything they need because they
work together.

Involvement of Carriage Workers

It is the strong belief of the New York City carriage industry that the workers in our
industry should have input into the rules and regulations under which they work
with their horses. The carriage owners and drivers in New York City are
represented by Local 553 of the Teamsters Union. In 2010, the carriage industry
itself drafted a bill, Intro 35-A, that reformed the carriage regulations, increasing the
care and oversight given to the horses. The carriage industry also has a seat on the 5
member Rental Horse Advisory Board that reviews issues affecting carriage and
riding horses in the city as they arise.

Despite Int. 35-A passing the New York City Council by an overwhelming majority of
44-3 in April 2010, less than four years later, Mayor de Blasio insisted that these
strict regulations, the model for so many others elsewhere, were insufficient and
that only a ban could protect the horses from any and all harm. Int. 573, introduced
in December 2014, which would have banned all horse-drawn carriages entirely
from New York City, contained a provision to offer job retraining or green taxi
licenses to displaced carriage workers. This so-called compensation was rejected
by the union, because its members are horse people, not taxi drivers, and who have
done nothing wrong. Advocates of workers rights joined the Teamsters in support
of the carriage drivers. New York City Central Labor Council president Vincent

16 Dr. Janine Jacques, What you should know about the carriage horses in New York
City, Equine Rescue Network (December 12, 2013)
Dr. Janine Jacques, Do Carriage Horses need rescuing? (December 8, 2014)
Ginger Adams Otis, City horses are better off pulling carriages than ending up
homeless or slaughtered: rescue experts, New York Daily News (April 28, 2014)

Alvarez called the proposed carriage ban a bad solution to a non-existent


City Councilmembers and the public were disturbed by Mayor de Blasios
unwillingness to meet with or communicate with the carriage drivers or their union
for nearly two years. The Mayor has so far refused to visit the carriage stables to see
how the horses are cared for and where they live.18 During consideration of revised
legislation, Int. 573-A/B, it was made clear that the city administration was ignoring
the concerns of the carriage drivers about horse welfare and economic viability in
favor of animal rights groups input into the legislation, which would have crippled
the carriage industry, if not eliminated it, before a new stable in the park was built.19

There are many parallels to draw between the defeated legislation that would have
destroyed the livelihoods of New York City carriage operators and the currently
imposed moratorium in Montreal. Int. 573-A/B, while claiming to preserve the
historic carriage industry by building a stable in Central Park, would ultimately have
destroyed the existing industry, by imposing an undue financial burden on the
carriage operators by cutting their hours and available horses in half. There was a
high probability that the existing carriage owners would have gone out of business,
and their stable properties sold before a city-owned stable was built.

In Montreal, the immediate work stoppage will force carriage owners and drivers to
scramble to find some other employment. They may or may not be able to afford to
keep their horses, who may be sold, ending up who knows where. There is no
guarantee that those same carriage operators will be available to return to work in a
year when the moratorium is lifted, if it ever is lifted.

Like the New York City carriage drivers, cochers in Montreal have made carriage
driving a true vocation. There are multi-generational carriage families. There are
cochers who have been driving caleches for decades. Maire Coderre claims that this
moratorium is not a permanent ban, but merely a precaution while the city reforms
the regulations. He insists that Montreal wants to preserve the caleches as an
important part of the citys patrimoine equestre. But the Montreal cochers are also an
important part of Montreals patrimoine humain.


18 Jennifer Fermino, EXCLUSIVE: Bill de Blasio plans carriage horse stables visit, but
will not be changing his mind on ending industry, New York Daily News (December
19, 2014)

19 See January 22, 2016 testimony of Clinton Park Stable manager Conor McHugh, Letter in opposition to Int.
573-B from Conor McHugh,

If the moratorium continues for a year, Montreal risks losing its human capital, as
cochers are forced to either find new employment or leave the city to continue
carriage driving elsewhere. Instead, the cochers should be allowed to continue their
trade in Montreal, and they should be included in the legislative process to reform
the regulations governing their working conditions. The cochers are the true experts
on the caleches.

Montreal should do what New York City has done and consider its people and its
horses and keep them all employed.