Wild Horse Education

“Guidance for Euthanasia” (policy change)

Broken Arrow (Indian Lakes) BLM “closed door” facility in Fallon, Nevada. photo: LLeigh

Our team member Marie Milliman has spent several days exploring the new “Guidance for Euthanasia” from the Bureau of Land Management (BLM). This policy change applies to all wild horses from range through long-term holding.

The document is what BLM calls an “Instruction Memorandum” or “IM.” IMs outline policy for the agency. The BLM now publishes two types of IMs: permanent and temporary. Permanent IMs provide lasting guidance that is short in scope. Permanent IMs remain in effect until superseded or deleted.  Temporary IMs offer operational, incident-specific, project-related or one-time policy or guidance for evolving activities. Temporary IMs expire at the end of the third fiscal year following issuance.

Like most documents the BLM calls policy, specific definitions are vacant leaving such a vague description that from district-to-district, facility-to-facility, carrying out the “policy” translates into whomever is on-site making the rules.

The “new” euthanasia policy can leave any horse advocate stunned. The examples here are simply a few from our volunteer who spent days combing the directive.

Captive Bolts Added and Wild Horses Should Not Get Old

Reaction Editorial Review by Marie Milliman

WARNING: Serious SNARK alert due to sincere outrage

Broken Arrow (aka Indian Lakes, Fallon NV)

The sweeping list of broadened/vague definitions and more restrictive recovery “options” are included in the updated: Permanent Instruction Memorandum No. 2021-007 (Revised) Subject: Euthanasia of Wild Horses and Burros Related to Acts of Mercy, Health or Safety. This IM replaces expired IM 2015-070, Animal Health, Maintenance, Evaluation and Response. https://www.blm.gov/sites/blm.gov/files/docs/2021-05/PIM2021-007%20att%201%20WHB%20Euthanasia%20Policy%20%28Updated%29.pdf

Join me in a condensed review of the new spit and polish on the BLM euthanasia policy. BLM has planted a plethora of alarming/murky language and here is just a few of the “ingenious” updates. Prepare your stomach and your heart to learn more about the updated: “Guidance for Euthanasia” for the wild ones.

Ever wonder what the origin of the word; euthanasia is? Originally a Greek word, euthanasia means “an easy or happy death,” as eu- means “good” and thanatos means “death.”

Does anyone think death by captive bolt is an easy death, happy death, or a good death? How can one not ponder with the increased removals, expanding short- and long-term holding facilities “inventory” of which BTW, BLM has also updated these terms to try to sound more “pretty.” The updated terms for facilities are now; short-term holding = off range corrals (ORC) and long-term holding = long-term pasture (LTP). BLM does not like the image of wild horses in iron bar pens in holding facilities? Changing the name does not change reality.

Following, is just a few of my “oh my god they didn’t” moments I had reading this:

Captive Bolt added. Anyone else have a heart palpitation? We all know where this form of “euthanasia” is/has been customarily used, and it’s a shock to my eyes with the hideous visions forming in my head of livestock/horse slaughterhouses. You too? What are they thinking? Why is this even in here?

II. Authorized Delegations and Required Training: C. excerpt: “Only persons trained by a veterinarian on how to perform euthanasia will be authorized to perform euthanasia. All personnel authorized to perform euthanasia will be trained to use gunshot. Only those specifically trained on the techniques for injection or captive bolt are authorized to use these techniques.”

Oh, what a “relief” they are required to be trained, whew. Trained like they were in the Comprehensive Animal Welfare Policy (CAWP) so no one needs to be concerned?

BLM instructions VI 3.: 3. “Penetrating captive bolt shot to the brain of an animal that is humanely and adequately and restrained.

BLM: Only persons authorized by BLM and specifically trained by a veterinarian in the use of a captive bolt will use this technique. The procedure will only be applied under the supervision of a veterinarian. The supervising veterinarian is not required to be on site every time a captive bolt is applied, but this supervision will include monitoring by the veterinarian to ensure euthanasia is performed humanely. 

Newsflash BLM, the captive bolt method was not designed for horses. BLM clearly states a veterinarian will not be on-site but notes that sedation is required which would require a veterinarian? Records of euthanasia of routinely buried by the agency and each time a captive bolt is used and misused will never see the light of public scrutiny. Will BLM allow public observation?

Horses have an intense fight or flight response, they are agile, “attempting to restrain a horse’s head results in more anxiety and fear, and their long neck makes complete head restraint almost impossible to do safely.” (ref 1.) Not to mention that it’s a Wild Animal therefore increasing the probability of missing the limited “target zone” in making the first shot “count.” “If there is any error in placement when the gun is fired the results are disastrous as the bolt may cause extreme pain without inducing unconsciousness, and a further shot is immediately required. The brain of the horse is surprisingly small (about the size of a grapefruit), within a large skull, which makes it challenging to achieve accurate placement, especially if there is any movement of the head. When fully conscious, most horses will have a tendency to raise their head if they are anxious or an unfamiliar object is advanced towards their head, and this makes correct height and angling of the captive bolt even more challenging.” (“Recommended guidelines for placement of the captive bolt can be difficult to interpret and, if placement is slightly low, it may result in the bolt entering the frontal sinus cavity and missing the brain. The author recommends placing the captive bolt slightly higher on the skull. The surface of the skull begins to curve at this level, so it is slightly harder to position the captive bolt firmly against the skull.” Illustrations courtesy of Horses and People magazine. To read the original article by Dr Andrea Harvey click here)

The illustration above shows the skull of a horse from slaughterhouse where the captive bolt did not cause death and the horse likely died in extreme pain during exsanguination (bled out).

Fish Creek, 2021

BLM has further defined, expanded their descriptions, to include pretty much any “chosen” physical trait to justify “euthanasia.”  (note: The bold text is an immediate reaction by the writer to reading the language in the policy)

I. A. 3. Permanent blindness; particularly double eye blindness or single eye blindness that involves an injury or condition that would require treatment or single eye blindness to which the animal is not well adjusted. **Frankly BLM, I am “not well-adjusted” to the ambiguous and expanded descriptions of a “justification”  that at face value simply appears to reduce the number of horses in holding.  Which includes when their eye is “injured” in the chutes/alleyways/trailers, etc. and processing due to blowing off CAWP on gate latches (or any other hazard they injure their eyes on?) and it is deemed a “chronic condition”? Or, heaven forbid it is a cremello, or a palomino, and has a blue eye, and/or has thrived and adjusted in the wild.

Captive stallion after last day of Humbolt roundup, severe eye injury caused in holding

I. C. Old age characterized by physical deterioration, the inability to fend for itself, suffering, or closeness to death. **Like, on what planet does a body not deteriorate to some degree with age? Is it a requirement for a wild horse, or burro to transform into an immortal being, to retain an upright, breathing, “non-euthanized” status? Exactly what is your definition of “physical deterioration”?

I. D. Direction from a state or federal animal health official ordering the humane destruction of the animal as a disease control measure. **Like when domestic livestock have been known to possess, and transmits said diseases to the Wilds on the range, like that kind of disease? Does that include Salmonella horses picked up after grazing in an area it was introduced by livestock? Or Strangles caught in a contaminated BLM facility? 

I. F. The animal poses a public safety hazard (e.g., loose on a busy highway), has escaped from a facility or pasture or is otherwise roaming freely in an unauthorized area and an alternative remedy (capture, relocation, or return to a herd management area (HMA), pasture or facility) is not immediately available. **Because the horses were not born with an innate GPS system and they did not receive the memo including the HMA map with the coordinates? Or the inability to be able contain themselves within the invisible boundaries that they are permitted to reside in? Or, did the livestock permittee/county commissioner that you just had a beer with call and make a complaint?

A lot of wild horses do not respond well to being captured. Will that be an excuse to kill them using this vague language?

III. B. Euthanasia During Gather Operations

During gather operations, the Contracting Officers Representative (COR), as delegated by the AO prior to the gather, will authorize the release or euthanasia of any wild horse or burro that they believe will not tolerate the handling stress associated with transportation, adoption/sales preparation, or holding. **Can we assume that the BLM will first be conducting an individual survey and personality tests with the Wilds? Will any horse that attempts escape or panics after capture be subject to death?

Calico foal born in holding, separated from mom, starved before being euthanized by BLM.

III. D. Euthanasia at Off-Range Pasture and Public Off-Range Pasture Facilities (excerpts)

WH&B program management and operations responsible for oversight will evaluate all horses and burros and establish their body condition, particularly if the facility is experiencing drought or some other event, which might limit forage availability.

  1. Animals with a body condition score of three, or less that do not appear to be acutely suffering or have a fair or better prognosis for improvement will be rechecked in 30 days. Those that remain below BC 3 will be euthanized within 72 hours of the second evaluation.**If drought is in the vicinity of the long-term pastures, potentially necessitating supplementation of hay in what has been a “more affordable” alternative to warehouse the wilds, how will the agency pay/budget for the increased maintenance of the exploding holding population? Or, will you just “euthanize” them? 
  1. Euthanasia of a Large Number of Animals(excerpt)

Euthanasia of a large number of animals for reasons related to acts of mercy, injury, disease or safety, should be identified and outlined in advance whenever possible.

**GAG! The “acts of mercy” are endless… Less Wilds = lower operating costs, got it.**

Antelope roundup, 2021

Note from the author: I have never been motivated to see the horse slaughter details as I have been vehemently against it. I have never researched “captive bolt” until now.  This was a difficult path for me, I had no choice as I read the BLM has approved “captive bolt” and it appears it will be used by “trained” personnel in the same fashion I have seen “trained” personnel carry out CAWP.

Once again, my faith in humanity is assaulted.


There are so many layers moving in the wild horse world with over 7000 approved for capture in just 60 days as the fiscal year races to a close. Our legal team is busy with multiple cases and comments on a new avalanche of EAs. We will update you soon.

The new leadership of the Wild Horse and Burro program is busy crafting new directives. (note: we found a severe deficit in experience in the new leadership and will share that in our upcoming CAWP series shortly.)

This new euthanasia policy is worth a look by every advocate out there that cares. Permanent Instruction Memorandum No. 2021-007 (Revised) Subject: Euthanasia of Wild Horses and Burros Related to Acts of Mercy, Health or Safety. This IM replaces expired IM 2015-070, Animal Health, Maintenance, Evaluation and Response. https://www.blm.gov/sites/blm.gov/files/docs/2021-05/PIM2021-007%20att%201%20WHB%20Euthanasia%20Policy%20%28Updated%29.pdf


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Categories: Wild Horse Education