Following a comprehensive research and interview process of stakeholders in the Dublin Carriage Horse industry, My Lovely Horse Rescue (MLHR) has identified certain issues with licensing and enforcement of legislation in the city.
We would like to thank everyone who gave us their time (carriage drivers, carriage owners, equine vets, farrier, equine dentist and physiotherapist, Gardaí, Carriage Driving Ireland and Dublin City Council) in identifying ways to improve on welfare and safety standards in the operation of horse drawn carriages in Dublin City and details on best practices.
The common goal of stakeholders we spoke to was for high standards of welfare, safety and professionalism in the industry.
We have now compiled a list of these recommendations, which, if implemented and enforced, could help reduce the risk of welfare issues and improve safety of passengers and ensure a professional and well-run industry:
Enforce Existing Legislation
Enforce Horse Licensing: Gardaí to carry out more inspections for horse licences under the Control of Horses Act 1996 and DCC Control of Horses Bye-laws 2014.
Compliance with horse licensing will ensure more horses have had their stabling and accommodation assessed by a veterinarian, that the premises they are kept at has an EPN and that the horse is passported and microchipped.
Greater enforcement of Horse Licensing could lead to improved traceability and accountability, higher standards of accommodation for equines and fewer healthy horses being impounded.
Enforce DCC Control of Horse Drawn Carriages Bye-laws 2011: Gardaí to enforce legislation to deter:
- Under age carriage drivers (under the age of 16)
- Unlicensed carriage drivers
- Unlicensed carriages
Enforce the Animal Health and Welfare Act 2013: Gardaí or Authorised Officers to use their powers under the Act, to deal with any issues of animal cruelty or welfare, if reported, to ensure that an equine is kept and treated in a manner which safeguards its health and welfare.
Gardaí to Prioritise Enforcement: weekdays, out of hours and weekends, for consistent period of time and specifically at the following locations:
- Designated hiring stands e.g. Bellevue (Guinness Storehouse) and surrounding area;
Non-designated hiring stands e.g. Temple Bar.
Introduce Welfare Checks to ensure compliance with the Control of Horse Drawn Carriage Bye-Laws etc.
Routine and ad hoc welfare checks by a DAFM Inspector, DSPCA Inspector or equine vet (trained in knowledge of carriage horse equipment/harnessing) at designated and non-designated stands.
Checks to include ensuring tack, harness and equipment is not causing any discomfort to the horse and that shoes and bit are fitted correctly etc. and that equipment is not worn or torn.
- Gardaí to enforce the Road Traffic Act 2016 and any other relevant legislation.
Facilitate Greater Ease of Enforcement
Improve Knowledge of Legislation within DMR: Suggestion: upskill a number of Gardaí on each shift in the DMR region where horses are stabled/operate on the abovementioned legislation.
Improve Knowledge of Processes with DMR: All Gardaí to be aware of other agencies they can contact for assistance when dealing with equines with regards to welfare (e.g. DAFM inspectors, DSPCA) vs. compliance (Council’s horse pound contractor) and the correct details for contacting same.
Suggestion: Use Garda Mounted Unit: The Garda Mounted Unit are located near the Guinness Storehouse and with their equine handling knowledge would be of assistance to Gardaí enforcing in the Dublin City area.
- More Robust Legislation: Council to Update Control of Horse Drawn Carriages Bye-laws to assist with greater ease of enforcement by Gardaí (see below for recommendations).
Recommendation to Amend the DCC Control of Horse Drawn Carriages Bye-Laws 2011
Improve Visibility of Carriage Licence: Replace the current metal carriage plate with a reflective square licence plate (similar format as per vehicle registration plates (see S.I. No. 318/1992 - Vehicle Registration and Taxation Regulations, 1992).
Plate to be clearly visible and affixed to the carriage and adequately lit. If possible, plate to also display the photographic headshots of each of the drivers licensed to operate the carriage.
Update Paper Carriage Licence: IDs of insured and licensed drivers for a particular carriage to be outlined on paper carriage licence for inspection.
Power for Gardaí to Seize Carriage and/or Horse: Introduce power for Gardaí to seize horse and/or carriage for offences by carriage driver or carriage owner.
- Carriage Horses - Certificate of Health: It is currently very difficult for Gardaí or to enforce Part IV, 7, b) of the Control of Horse Drawn Carriages 2011 Bye-laws (and Council staff are not suitably qualified to inspect for the following):
“Horses used to draw hackney carriages shall have a temperament and be in physical condition and of an age suitable to such work.”
In order to make it easier for this bye-law to be enforced, MLHR propose the introduction of a “Certificate of Health”, to be issued by an equine veterinarian, that certifies a horse has a suitable temperament, physical condition and is of a suitable age to draw the average carriage.
MLHR propose a certificate similar to New York City Rental Horse Certificate of Health for working example:
Certificate of Health to display microchip and UELN number of equine and to be renewed yearly. It should be an offence for a driver of a carriage for reward operating with a horse that does not have a Certificate of Health. Maximum penalty - horse can be seized.
Equine Premises where horse is ordinarily kept in DCC to be BHS or AIRE approved. The current Horse Licensing system does not provide for entire yards to be checked by a Council vet for compliance with DCC Control of Horses Bye-laws 2014 - only the particular stall/stable is reviewed for compliance and this check only occurs once per year on licence application.
Power for Garda to Demand Evidence of Insurance: Evidence of insurance for both carriage insurance and carriage driver insurance.
Abolish "Letter of Competence" and "Recognised Stables/Equine Centres". Replace with an assessment of Carriage Driving Skills: Driver to be assessed manoeuvring the the horse and carriage) or provide evidence of recognised skills/course in carriage driving.
The Council could work with agencies such as Carriage Driving Ireland who are part of Horse Sport Ireland (funded by the Department of Agriculture). HSI are the National Governing Body For Equestrian Sport In Ireland.
Example: See Horse Drawn Operator's Course (see New York system - video tutorials and written exam).
In future years, for newcomers, a more detailed course such as the British Driving Society Road Driving Assessment could be a requirement and this is perhaps something that could be discussed among stakeholders for review.
Motor Licence: Carriage Drivers to produce evidence of EDT at a minimum or ideally a full motor driving licence on application for a Carriage Drivers Licence.
Raise minimum age of carriage driver to 17 when driving with passengers. Until such time when carriage driving ability is fully assessed, amend the minimum legal carriage driving age to 17.
Equine Care Knowledge: Carriage Driving Licencing and Carriage Licence Applicants to provide evidence of the following:
- Basic horse health care (foot balance, knowledge of basic horse anatomy, fitness to work) and care for the horse after use.
- Emergency care of horses e.g. basic horse injuries such as tendon injuries, muscle tears, back spasm, musculoskeletal issues
- Stable Management - stabling, grooming, feeding, bedding, hydration.
- Proper harnessing and preparation of horse and carriage for use.
Evidence may be in the form of British Horse Society (BHS) Stable Management Course BHS Care Award or BHS Equine First Aid course etc.
Mechanical inspection of carriage to include when carriage is in motion.
Equine Working Hours: Until such time as enforcement and welfare checks are regularly carried out on carriage horses, MLHR recommend that carriage horses should temporarily only be permitted to operate in DCC administrative area between the hours of 8am and 11pm.
- Set maximum number of passenger spaces to "6". The driver is not counted as a passenger - a co-driver is a passenger. Under Part VII Miscellaneous 11 of the Bye-laws, insert the following paragraph:
Clarify Legislation - Public vs Private Hire: Make it clear in the Control of Horse Drawn Carriages Bye-laws that the bye-laws apply to public and private hire so that there is no ambiguity. The bye-laws cover all carriages used in carriage for reward within the functional area of DCC.
- Clarify Legislation - Licence Type: In Part Iv, 7 A) of the Control of Horse Drawn Carriages Bye-laws MLHR recommend clarifying the type of licence required by the addition of the word “horse” after the word “current”:
“No person shall keep or have charge of control of a horse in a control area without a current horse licence issued by Dublin City Council or other Local Authority”.
Amend Part Ii Section 5 G) of the DCC Control of Horse Drawn Carriages Bye-laws as follows:
“A proprietor shall not operate or permit to be operated his/her hackney carriage without holding a current licence in respect of it.”
“A Proprietor shall not operate or permit to be operated his/her Hackney Carriage without holding a current Carriage Licence in respect of it.”
Create a Public Register of Licensed Carriage Drivers and Carriage Owners: Align Carriage for Reward with Taxi Licensing system - create an online public register that the public can check to verify driver is fully licensed.
- Driver Attire: All the drivers we interviewed suggested drivers wear smart attire, possibly a cap/hat - no casual wear e.g. tracksuits.
General Recommendations for Council
Access to water: Council to provide access to water for drivers at designated hiring stands by the Council to enable drivers to offer water to horses, to clean down horses and clean standing area (horses do not like standing in urine/dung). Lack of access to water is a major issue for drivers and MLHR.
Signage at designated and undesignated hiring stands advising the public:
- Any licensed carriage they prefer can be chosen;
- How to recognise a licensed driver/carriage/horse;
- Who to report welfare issues to;
- Who to report compliance issues to.
- Garda Cameras: Install Garda camera at major junctions e.g. Christchurch, Thomas Street etc. to assist Gardaí with enforcement.
Signs for Motorists: Council to install signage on popular routes horses and carriages operate, to advise motorists horses may be in traffic.
Horse microchip number to be cited on public DCC Horse Licence Register. Other Councils (e.g. SDCC) cite the microchip number on their public registers, DCC does not. This information should be available especially for Gardaí/Authorised Officers or Authorised Persons.
Education: Provide funding for equine education and welfare events in the city centre area to promote responsible horse ownership and horsemanship.
Ongoing Review/Advisory Board: Stakeholders (including licensed carriage drivers/carriage owners) to engage on a regular basis to review or improve systems. The Dublin Region Horse Welfare Forum (DRHWF) could be one such opportunity for stakeholders to engage.
Members of the DRHWF include MLHR, Gardaí, DCC, SDCC, Fingal Co Co, DLR Co Co, DSPCA, DAFM, Irish Horse Welfare Trust, Fettercairn Youth Horse Project, UCD Veterinary College and a number of councillors.
On the “Control of Horses” page of the DCC website, the 2010 bye-laws are incorrectly referred to and linked to - the link should be to the 2014 bye-laws.
- Make all links to legislation documents on Council’s website indexable and searchable - not images - therefore easier for users to access information