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I. INTRODUCTION <br /> The Great Bull Run (hereafter the "Event") is a stylized rodeo production in which participants <br /> run with live rodeo bulls and steers down a course constructed of a dirt ground cover and rodeo <br /> paneling. The Event is similar to the annual Running of the Bulls event in Pamplona, Spain, but with <br /> significant safety enhancements to promote the health and welfare of the animals and participants <br /> involved. On August 24, 2013,The Great Bull Run LLC(hereafter"GBR LLC"), in partnership with The <br /> Lone Star Rodeo Company(hereafter"LSR"), intends to hold the Event at Virginia Motorsports Park in <br /> Petersburg, Virginia. <br /> GBR LLC and LSR (collectively, hereafter, the "Promoters") believe that the Event falls under an <br /> exemption of 9 CFR § 1.1 for purposes of defining the term "Exhibitor" pursuant to the Animal Welfare <br /> Act (hereafter, "AWA") and therefore a USDA Class C License is not necessary or appropriate. 9 CFR §§ <br /> 1.1 and 2.1,See also 7 USC§ 2132(h). Pursuant to 9 CFR § 1.1, the term "Exhibitor" "excludes . . . horse <br /> and dog races . . . fairs, livestock shows, rodeos,field trials, coursing events, purebred dog and cat shows <br /> and other fairs or exhibitions intended to advance the agricultural arts and sciences" from the licensing <br /> requirements of 9 CFR §§ 2.1. Id. The Event, which operates as a standard rodeo using animals that <br /> have been bred and trained specifically for rodeo activities, and where participants engage with the <br /> animals for the purpose of sport, clearly meets this definition and is similarly excluded. Indeed, GBR LLC <br /> contacted the Animal and Plant Health and Inspection Services (hereafter "APHIS") Officer responsible <br /> for United States Department of Agriculture (hereafter"USDA") oversight in Virginia and, after <br /> explaining the event in detail, was informed that, absent a USDA designation to the contrary, a Class C <br /> License was not necessary or appropriate for the Event because for all intents and purposes, and <br /> concerning all animal care and transportation, the Event operates as a rodeo. Id. Accordingly, as further <br /> explained below,the Promoters have taken all steps necessary to ensure the Event complies with all <br /> local, state and federal laws governing rodeos or similar events excluded from the definition of <br /> "Exhibitor." <br /> Based on the following,the Promoters respectfully request a clarification of 9 CFR § 1.1 as it <br /> refers to the term "Exhibitor" and a designation of the Event as a "rodeo," or activity excluded from the <br /> definition of"Exhibitor" pursuant to that section, that will operate in accordance with all local, state and <br /> federal laws concerning such events. <br /> II. FACTS <br /> a. About The Event <br /> The Event is a one day event in which participants run down a dirt lane lined with rodeo <br /> paneling alongside bulls and steers in a reproduction of The Running of the Bulls in Pamplona, Spain. <br /> However, unlike in Spain,the animals will not be killed after the Event. The animals will not be <br /> harassed, hit, prodded or otherwise mistreated during the Event. Indeed,the event is safer for the <br /> animals and participants than the bull riding activities of certain rodeos. Also, there will be a team of <br /> 2 <br />