Who does night turnout?

Trees do count as shelter and lots of horses prefer them to something else.

So in your world, barns that do turn out with no shelter for some portion of the day are not OK because there is no shelter while the horse is out?
How about a REAL two sided shelter so there is no chance of the grumpy horse cornering the other horses?

So horses should only have level grass or sand footing?
For the record, they can hurt themselves just fine on that too.

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Mine are on night turnout year round in North Carolina. I prefer this so they can be out longer versus day time turnout. I ride in the mornings and it also makes its easier for me to cool them out in the winter. They can wear a sweat sheet/cooler while in their stall and then get blanketed again before turnout. They all have access to run in sheds. They are turned out from about 4:30pm and come in at 7:30 in the morning. In the winter I throw blankets on them. Even the body clipped ones do fine (although some people may say I over blanket).

I had to respond to the part bolded above. The horses living on our farm didn’t get this memo. All of my pastures have huge run-in sheds with ridge vents and cupolas. Where do they stand on a hot afternoon? In the woods. Where are they when it is raining? Usually out grazing quietly. On the rare occasion we get some snow in the winter what do they do? Run around and play like toddlers seeing their first snow. Most of the horses here were show horses, mainly h/j and dressage, that had little or no turnout during their showing lives as they were considered too valuable to risk getting hurt in turnout. Now that they have their chance to ā€œjust be horsesā€ they embrace it fully.

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I have been on my farm for five years. This spring we put up run in shelters in the pastures. The horses do use them, thankfully, and they assuage my guilt if I hear a big storm during the night. One of my horses will use the shelter for light rain or daytime shade but in the case of a bad storm he stands outside. Not much I can do about that. It does make me feel better to know that shelter is there if he wants it, and my other gelding always uses the shelter during storms.

I also disagree about the need for 3 wall shelters. I would think this is highly dependent upon local weather. I am in the Southeast and hot weather is much more of a concern than cold. My pasture run ins have no walls at all - just a roof. I have a pony who lives in a run in and hers has two walls that are solid to 5’ on the North and East sides and a fan for hot weather use. In the winter I blanket the pony anyway, as she is old and loses weight if not blanketed.