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the professionals that work with them and the high value of the animals lends itself to an environment <br /> where the animals involved are properly cared for. <br /> The Event is conducted by a professional rodeo production company that uses trained rodeo <br /> professionals to handle animals that are specifically bred and trained for the Event's activities. For all <br /> intents and purposes,the event is a rodeo and falls into the class of activities excluded from the <br /> licensing requirements. Indeed, the event is significantly safer for the animals and participants than the <br /> bull riding aspects of certain rodeos. Accordingly, the Event is both a rodeo production and the type of <br /> activity intended for exclusion from the licensing requirements of 9 CFR § 2.1. <br /> IV. Request For Clarification and Designation <br /> For the reasons stated above, the Promoters respectfully request the USDA clarify the AWA as it <br /> applies to the term "Exhibitor" pursuant to 9 CFR § 1.1 and designate the Event as a rodeo, or activity <br /> intended to be excluded from the term "Exhibitor" pursuant to that section. As a rodeo,the Event will <br /> continue to follow all local, state and federal Laws governing rodeos to assure that the event is as safe as <br /> possible for both the animals and participants involved. If, however,the USDA should determine that <br /> the Event requires a Class C License pursuant to 9 CFR § 2.1, then the Promoters are happy to revisit <br /> their discussions with appropriate APHIS personnel to work toward obtaining that license. <br /> Sincerely, <br /> Bradford D. Scudder, Esq. <br /> Chief Executive Officer <br /> The Great Bull Run LLC <br /> (413) 522-0602 <br /> brad @thegreatbullrun.com <br /> MA BBO#: 673198 <br /> Robert C. Dickens III, Esq. <br /> Chief Operating Officer <br /> The Great Bull Run LLC <br /> (919) 370-2097 <br /> rob @thegreatbullrun.com <br /> NY ARN #: 4699740 <br /> 5 <br />