Wild Horse Education

FOIA Report (investigation continues)

The Freedom of Information Act (FOIA) was passed in 1967 for the purpose of  facilitating the public the right to request and obtain access to records from any federal agency. FOIA has become a valuable tool for media and advocacy.

One of the most important parts of the FOIA investigative process (after reviewing, analyzing, researching) is sharing what we find with the public. 

In October, WHE released a scathing report revealing that during Bureau of Land Management (BLM) roundups: Veterinary reports are not being completed during roundups, After Action Reviews (AAR) and Final Gather Data Reports are not being completed as required, there are no standardized reporting (or methods) in practice during roundup operations. (You can see the report HERE)

Our team is reviewing additional information obtained through FOIA (and has filed additional FOIA requests).

One project the WHE FOIA team is working on is the true cost in deaths related to roundups. 

One of the statistics that BLM is fond of using is that “less than 1%” of wild horses die due to a roundup. The most obvious way they manipulate that statistic is by claiming many injuries fall into an overly-broad (and often extremely suspicious) category of “pre-existing conditions.”

In the video below this foal is run for over 45 minutes across the valley, through a maze of barbed wire. It keeps up with family just fine. You can see the moment the foal is injured and lags behind (and then tried to limp home alone as BLM is more focused on capture than the damage they do) and then roped and walked more than a mile back to the trap where BLM euthanizes it. BLM claimed this death was “pre-existing.”

When BLM places a death into this category they do not count it as a “roundup-related death.” We find as the number of deaths rises, the type of death that falls into a category where it would not count as related to the operation also rises.

As our October 5 FOIA report found, BLM fails to keep any actual vet reports on an overwhelming majority of deaths and injuries. Even though the Comprehensive Animal Welfare Policy (CAWP) states clearly that BLM is to file a vet report and visual documentation, they don’t. Of 99 deaths reported in 5 operations, only 4 vet reports were produced through FOIA. (You can see the report HERE)

If BLM hides the true cause of death they can manipulate any other statistic to claim helicopter roundups are “safe.” So claims of being overworked, disorganized, not trained, or not “getting the memo” that all deaths need to be documented seems to serve a purpose.

This subject deserves a much closer look.

Foal falls and is trampled at Pancake, 2022.

A WHE FOIA investigation our team is currently working on is presented here in steps so you can follow a bit of our process. We will release the full report as soon as we receive records BLM has omitted from their response to our requests.

So what is the actual statistic representing the number of roundup-related deaths?

First you would need to define a “roundup-related death.” Two basic scientific statistical principles can be applied. First, when we look to create any scientific statistic, the phrase cause and effect is often applied (in science, the cause explains why something happens; the effect is the description of what happened). Second, in scientific evaluations a chain reaction is analyzed (a series of events so related to each other that each one initiates the next; a number of events triggered by the same initial event).

Using those two principles, we can look at the roundup as the triggering event that sets off a chain of events and create a layered report.

We are building on the October FOIA report by following the same wild horses into facilities. In 2023, we will bring you a detailed report that looks closer at deaths on-site at roundups, but also follows the chain of events triggered by the roundup and tracks deaths.

At the Pancake roundup, 26 wild horses were reported to have died onsite (those that may have died on-range from an injury after the operation, including any foals left behind, will never be fully known). At this link you can view the listed causes of deaths at the bottom of the page. Our October report confirmed that BLM only provided 2 incomplete vet reports during the roundup and failed to provide any details on 24.

Pancake wild horses seen at the Broken Arrow (Indian Lakes) tour in May 2022.

Following the wild horses from Pancake into facilities is not easy; physical observation and obtaining records have obstacles. Two of the facilities (Sutherland and Broken Arrow on Indian Lakes Rd) are off-limits to public view. These off-limits facilities also met with criticism of shoddy record keeping and/or timely freeze branding during BLM internal CAWP assessment, making tracking more difficult.

Draft, work-in-progress. BLM does not do compiling for you. They send you multiple lists you need to extrapolate from to create your own. We are still working on examining the information, double and triple checking.

The data above is found by correlating reported deaths, intake notes, render receipts and noting when a wild horse is received (but never freezemarked) and comparing to render receipts.

Since our earliest investigations into holding facilities, we found that BLM is inconsistent in reporting deaths of wild horses or burros prior to branding (sometimes they do, sometimes they do not) making the additional render receipt an important piece of information.

The process of tracking deaths can get a bit “sketchy.”

In fact, the render receipts we were given from Indian Lakes do not cover the entire period of the FOIA request. They simply provided receipts that matched the number of deaths they reported, with one receipt dated from before the Pancake horses ever arrived and stopped long before the death dates listed in the report provided. Was this intentional?

In another instance, an intake report at Indian Lakes (meaning the horses just arrived) lists 4 males as “dead,” but provides no date (or identifying information). Did they die during transport to the facility? Would you count that as a roundup-related death?

We are breaking the information down into categories. Example: a notation of “no gelding-related deaths” must consider that gelding may not have taken place yet (would the horse die of gelding complication if the triggering event, the roundup, had not taken place?). One of the reasons we are breaking this down into categories is to allow the reader to determine for themselves what is “roundup-related” and for our team to look for trends in each facility as we move this investigation further.

Additional questions come to light when you look further into how BLM categorizes wild horses (including those that died before branding) into “adoption or sale authority.” Overshadowed in recent years by the Adoption Incentive Program (AIP) that places younger horses in jeopardy of resale to slaughter, Sale Authority is the most vulnerable category and allows wild horses to be sold immediately to a kill-buyer. By beginning directly after a roundup and sorting through the inventories, we can create a baseline to track this subject as well through various FOIA requests.

When you run a FOIA investigation to find answers to one question, you often find pathways to answer others.

We will continue to analyze and compile the information and share the full report when completed. 

BLM should be required to include facility reports as part of the daily roundup update. These reports should be made available to the public, again. BLM used to provide facility intake and vet reports online.

They need to make them readily accessible to the public again. Look for action items in early 2023.

Our teams are hard at work and will have more info for you soon.


Year in Review in video (and words)

Reader’s Choice, top ten of 2022

Photographs and Memories, 2022


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WHE has been offered an end-of-year match challenge. If WHE can raise 10K before the year’s end, the funds will be doubled. These end-of-year contributions are critical for all non-profits, including WHE. Can you help us meet the match to keep our work running into 2023?

Categories: Wild Horse Education