Indian Lakes (aka Broken Arrow) where alkaline dust hangs in the air on a windy day. BLM CAWP has restrictions on alkaline soil that don’t seem to translate into practice (Alkaline soil can irritate sinuses and lungs when inhaled).
The BLM engages in a lot of effort to keep the Comprehensive Animal Welfare Program (CAWP) shrouded in public relations messaging, double-speak and busy-work (work that keeps a person busy but has little value in itself).
We know CAWP is careless, ambiguous, weak, puzzling. We hope this series of articles helps you navigate as you advocate. We are focusing on CAWP and facilities in this spotlight series and will address CAWP on-range and during capture in a future series.
Spotlight, Facilities:
Last week Wild Horse Education and Rewilding America Now filed a brief with the Ninth Circuit Court of Appeals to shed light on neglect and abuse in the current BLM system of holding focusing on the privately owned facility in Winnemucca, NV.
One short life. How the system failed a baby burro.
Facilities and the CAWP (this article)
Coming next: Alternatives and Repair
Above: Gelding complications
In 2015, after years of litigation, BLM released a draft Memorandum and Assessment Tool to begin formalization of a welfare policy (Draft Standards, June, 2015). In January of 2016, they drafted a set of standards for corrals and adoption events.
In 2020, BLM simply typed the word “permanent” on the draft without any review or public input period. Both a release of an assessment or review and a public input period are required before BLM formalizes any document that requires implementation (a proposed action) or any policy.
BLM is fighting really hard not to formalize any welfare rules. A program that began in a courtroom with BLM telling a judge (that had ruled against them in a pervious case because they simply denied doing anything wrong) that they were beginning to draft a welfare policy, devolved into a program that simply provides offenders with protection, left the public completely out of the process and fails to provide a mechanism that enforces welfare rules to stop undue suffering and death.
Rushing, BLM failed to determine if trailer doors were secure (fiscal 2025, Twin Peaks roundup, CA)
When it comes to roundups, issues are easy to see. (We will do a spotlight on CAWP and roundups when we complete the series on facilities.)
When it comes to facilities, things can get complicated because they are so well hidden.
There are different terms used to identify facilities you need to know when we talk about off-range holding: Preparation, Maintenance and Pastures. Both Preparation and Maintenance are facilities BLM used to call “short-term holding.” BLM also references these facilities as “corral facilities.” BLM also has a subset of “corral facilities” they call “adoption and sale centers” (BLM facilities, not private facilities, that have regular visiting hours, but not always). Pastures are the name BLM now gives to “long-term holding.” BLM has a habit of changing names, using interchangeable terms, inconsistent definitions and seemingly makes an effort to use this practice to try to confuse both the public and the courts.
During the Advisory Board meeting earlier this month, BLM presented statistics in holding facilities.The document at the highlighted text is useful to let you know what the official classification of a facility is. The document can also give you additional information beyond an inventory number. It is important to know that the inventory listed does not count unborn foals (even though they count the unborn in on-range inventory).
This simple inventory list can also demonstrate that as of December 2024, only 8.7% of all captive wild horses and burros are accessible to public view.
Several facilities that have regular visiting hours posted are closed after taking in captive wild horses from the range claiming it is necessary “for safety reasons.” If those facilities were open, only about 11% of all captive wild horses and burros could be seen by the public.
No matter how BLM shuffles “inventory,” at least 70% of all captives are off-limits to public view at any given time.
Your tax dollars. Public resources in the form of horses and burros. You cannot see a thing.
We are left with piecing information together from capture, FOIA requests and documents BLM creates for different venues. By simply looking at the off-range report BLM shared with the Advisory Board, we can accurately assess that BLM system of holding is not transparent in any way.
As noted in earlier articles, in the last 15 years BLM has only approved off-limits facilities.
This means we need to continue to compare “what they say” and “what they do” where we can see in order to determine if there is any hope that what we cannot see is remotely functional.
It is hard to see vaccination compliance, testing or record keeping without a FOIA request. At the Advisory Board meeting vaccination and testing compliance was skimmed over as if “of course, there is compliance.” In recent years there have been disease outbreaks due to a lack of compliance.
Our FOIA requests demonstrate instances where non-compliance is overwhelming. BLM policy requires Equine Infectious Anemia testing and freeze-mark application within 30 days of arrival. Only 41 (4%) of the Pancake horses residing at Indian Lakes (aka Broken Arrow) were in compliance, or 924 (96%) were not in compliance. 353 (37%) were 60-plus days overdue. These
horses were gathered in fiscal 22. Note: Subsequently, pursuant to WHE’s lawsuit, federal court’s
ruling rescinded the BLM’s authority to round up and remove these horses under the existing
EA (Environmental Assessment).
However, even though BLM cites CAWP in contracts as a standard that must be met and implies oversight, this is simply not the case. Not only is Indian Lakes continuing to receive wild horses and burros, the contract was expanded to hold more than twice the original number in the contract regardless of the numerous issues with noncompliance.
Slide from BLM CAWP presentation during the Advisory Board meeting.
Another document presented during the January 2025 Advisory Board meeting that can shed some insight into how CAWP can be misleading is the Powerpoint from the presentation given by Jerrie Bertola, CAWP Coordinator, “CAWP Priorities.”
One aspect of CAWP that the public finds particularly careless, ambiguous, weak, puzzling, is the shelter conundrum. BLM requires adopters to provide shelter, but does not require facilities to have shelter. BLM will use a lack of natural barriers like draws, trees and “big rocks” to remove all wild horses and burros from an area (zero-out) and make a determination not to manage horses or burros in an area. So based on those two statements it is obvious that under some circumstances BLM considers shelter important.
Besides the strange wording in the paragraph describing shelter and facilities, the shelter depicted gives an impression that pens have shade and shelter from harsh weather. This picture appears to be one taken of the “long pen” at Palomino Valley Center (NV). The shelter was installed during “shade tests” done back in 2013 as lawsuits and media focused heavily on welfare issues on the program. The National Mustang Association of Utah and The Humane Society of the United States (The HSUS) provided materials as BLM claimed they had no funding and “wild horses and burros do not need shade.” Many other organizations raised money to help BLM install shelter in other pens and BLM simply would not take organizations up on the offer.
The image used in the Powerpoint is of one pen in one facility.
BLM reviewed the “shade tests” and then installed a couple of additional structures like these fence walls… on the south side of a pen used most often for mare and foal pens that casts shade outside the pen and winds come from the north and west (in other words, this does not even function as a wind break). These high fences function more as a visual barrier than anything else. (see below)
BLM says structures like these go “far above and beyond any CAWP requirement.” To be “fair,” Palomino Valley Center is one of the better facilities the BLM operates. We have had numerous interactions where facility staff has responded to calls where we have seen injured or sick animals, even on holidays. They have facilitated placement of special needs, like Petunia. But there are tremendous inconsistencies (like the baby burro in distress).
The vast majority of pens in any BLM facility have no shade structures at all.
The only pens at Indian Lakes (and nearly every other private facility) that provide any actual shelter are “sick pens.” Not even plywood on the west side of a pen to provide shade in the hottest weather as they stand on reflective and alkaline soil.
It is painfully obvious that the CAWP requirements in contracts for holding facilities are not adequate. The oversight provided by the BLM CAWP team is inadequate.
There are alternatives that could help prevent needless suffering and death and save money. BLM will accept the “lowest bid” as the only criteria strictly adhered to when determining where to send wild horses and burros. Instead, BLM should be finding alternatives that provide a higher quality of care and oversight that could save money.
Our final article in this series will explore those alternatives and include an action item. (Publishing soon)
Spotlight, Facilities:
Last week Wild Horse Education and Rewilding America Now filed a brief with the Ninth Circuit Court of Appeals to shed light on neglect and abuse in the current BLM system of holding focusing on the privately owned facility in Winnemucca, NV.
One short life. How the system failed a baby burro.
Facilities and the CAWP (this article)
The final article Exploring Alternatives, coming soon.
Our team is working hard in the field and in the courts. Without your support, none of our work is possible. Thank you for keeping WHE running for our wild ones!
By request we have relaunched our shirts. You can order a sweatshirt or t-shirt to support our work. All proceeds go to keep out team in the field, at the table and in the courtroom. Just click on the image or click HERE if you would like to were your support for our wild horses and burros proudly while supporting our critical mission.
Categories: Wild Horse Education
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