This report is the culmination of more than a decade of relentless advocacy and firsthand investigation. For years, our team knew the Bureau of Land Management (BLM) was misleading the public about its so-called Comprehensive Animal Welfare Program (CAWP). But knowing was not enough—we needed concrete proof from inside the agency.

While BLM continued to assure the public, Congress, and the courts that it was diligently reviewing and “formalizing” animal welfare standards, our investigation found those claims to be far from the truth.

To expose what was really happening, we filed a Freedom of Information Act (FOIA) request—one that BLM fought to keep buried until a lawsuit forced disclosure. What we uncovered reveals a deeply concerning pattern of misrepresentation at the heart of federal wild horse and burro management.

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BLM Emails Expose Agency Negligence Toward Wild Horses and Public Trust

New records pried loose through FOIA litigation expose internal BLM emails confirming what advocates have warned for years: the agency has failed to complete and formalize a Comprehensive Animal Welfare Policy (CAWP) to prevent needless suffering, injuries, and deaths of wild horses and burros. In doing so, BLM has fallen short of both public expectations and its humane responsibilities under the law.

The landmark case of Leigh v. Salazar sits at the intersection of First Amendment rights, the Freedom of Information Act (FOIA), and the fight for humane, transparent federal management of wild horses and burros. Together, these legal protections affirm that transparency and humane treatment are not just moral imperatives—they are constitutional and statutory rights of public oversight. Public trust can only be built on transparent, responsible conduct, not on secrecy and spin.

How We Got Here

The pursuit of humane treatment for wild horses and burros began with recognition of the public’s First Amendment right to observe BLM roundups. The founder of Wild Horse Education (WHE), Laura Leigh, enforced that right up and down the federal court system, securing a precedent-setting ruling that protects press and public access to vital government activities well beyond wild horse gathers.

Starting in 2011, WHE repeatedly took BLM to court over documented abuse at roundups—abuse BLM denied even as federal judges halted operations. At that time, there were no formal operating procedures or policies governing the care and handling of wild horses and burros. Litigation forced BLM to initiate the Comprehensive Animal Welfare Program (CAWP). Without that litigation, CAWP simply would not exist.

Today, roundups and removals are the most visible aspect of the Wild Horse and Burro Program—and the most visible symbol of BLM’s failure to ensure humane treatment.

CAWP is supposed to apply across five key areas where wild horses and burros are handled:

• • Gathers (roundups)

  • On-range management

  • Off-range corrals and pastures

  • Transportation

  • Adoption and sales

Why This Matters

Exposing BLM’s pattern of misrepresentation and neglect is essential to securing a legitimate welfare policy, meaningful consequences for abuse, and an end to preventable suffering and death.

In fall 2015, under pressure from litigation and pointed criticism from federal judges over the lack of any welfare policy, BLM issued a temporary Instruction Memorandum (IM) and draft CAWP standards. CAWP was born with three core components:

• • “CAWP Standards for Wild Horse and Burro Gathers” (Attachment 1)

  • A mandatory CAWP training course

  • A “CAWP Gather Assessment Tool” (Attachment 2)

The assessment tool was supposed to be completed after each roundup, evaluated annually by BLM and veterinary experts, and used to revise the standards before presenting them to the public for review and formal adoption. Only then would CAWP become a binding, enforceable policy.

Instead, after a brief period of improved transparency and on-site practices, the agency began sliding backward. By 2017, the backsliding was obvious.

By 2018, emails show the BLM simply deleted the Assessment Tool without ever performing a single review.

What the FOIA Emails Show

Beginning in 2016, WHE repeatedly requested the annual CAWP reviews and a timeline for public participation. Each year, BLM told us to “be patient.” In 2019, we filed a FOIA request for CAWP-related documentation—evaluations, training records, proposed changes, and any assessment of the program’s effectiveness. BLM stonewalled and only produced records in 2025, after we filed suit.

Those records, including heavily redacted and withheld pages, reveal a leadership culture more concerned with bureaucratic convenience and shielding itself from scrutiny than with animal welfare.

Key findings include:

• • BLM never conducted a single meaningful review of the CAWP Gather Standards issued under the 2015 IM.

  • BLM never properly used the CAWP Gather Assessment Tool as required to evaluate training, measure effectiveness, or ensure compliance by BLM staff and contractors.

  • The tool—which could have created internal accountability and external transparency—was effectively abandoned, despite repeated assurances to the public, press, and Congress that it was in use.

Nonetheless, in December 2020 BLM issued a 2020 “permanent” Instruction Memorandum (PIM), declaring CAWP to be “permanent policy” and incorporating:

• • CAWP Gather Standards

  • CAWP Standards for Off-Range Corrals, Transportation, and Adoption/Sale Events

BLM simply reissued the draft standards with no review and quietly eliminated the “CAWP Gather Assessment Tool”—the very mechanism meant to evaluate, improve, and enforce those standards.

BLM had pledged to:

• • Conduct annual reviews

  • Revise the standards based on data and veterinary input

  • Provide public comment opportunities

  • Finalize and formalize a binding welfare policy

BLM did none of this.

To this day BLM insists they did a careful review and “formalized” the CAWP. They continue to claim “data-based” review and transparency…. and nothing could be further from the truth.

BLM has repeatedly refused to consider basic equine guidelines like air quality and heat index. Both of these are linked to a higher incidence of catastrophic injury and illness. Public participation could make an impact but BLM has repeatedly denied the opportunity.

Excluding Science, Experts, and the Public

The 2015 IM promised that, “The Bureau’s objective is to use the best available science, husbandry and handling practices applicable for WH&Bs and to make improvements whenever possible…”

In practice, BLM has blocked the very processes necessary to keep that promise. The agency has:

• • Failed to incorporate basic, widely accepted equine welfare practices, such as air quality and heat index thresholds.

  • Ignored public demand for stronger welfare standards, as reflected in our polling.

  • Excluded advocates, independent veterinarians, and outside experts from any meaningful role in defining what “humane treatment” actually means.

  • Refused to allow substantive public input on the conduct of gathers even during Environmental Assessment processes.

Most injuries, illnesses, and deaths at roundups are preventable. WHE maintains the largest roundup documentation database in the world and has developed concrete, science-based recommendations to reduce harm. Yet we have never been given a genuine opportunity to present or discuss these recommendations in any formal process.

Americans derive peace, enjoyment, and pride from seeing wild horses free on public lands. They also feel betrayed when the very agency charged with ensuring humane treatment allows abuse to continue through neglect and mismanagement. That betrayal is at the core of the growing crisis of public trust in BLM.

Litigation, Accountability, and Moving Forward

WHE continues to be on the ground documenting conditions at roundups and exposing prevalent, unnecessary abuse—evidence that underscores the urgent need for a real, enforceable CAWP.

In 2025, before BLM’s FOIA emails surfaced, WHE filed a new federal lawsuit seeking critical analysis and documentation related to CAWP. That information is essential to closing loopholes, forcing a formalized policy, and ending this entrenched pattern of abuse.

In that litigation, BLM has claimed that the window for public participation has “expired”—while its own internal emails show there was never any genuine public comment or participation period to begin with.

Advocates now intend to close these loopholes and secure an authentic, permanent CAWP policy with enforceable rules and real consequences for violations.

What You Need to Know

The newly released emails make three points unmistakably clear:

• • BLM failed to carry out its obligations to review, revise, and formalize a Comprehensive Animal Welfare Policy for gathers.

  • The agency misrepresented the status and use of CAWP tools and processes to the public, the press, and Congress.

  • In December 2020, BLM attempted to paper over these failures by issuing a so‑called “permanent policy” that lacked the required foundation of review, science, and public participation.

With transparency comes accountability—and the possibility of genuine reform.

What Needs to Happen Next

The evidence now on the record shows systemic negligence and underscores the urgent need for action. Congress can—and must—step in.

A simple, targeted directive in the Interior Appropriations bill could require BLM to:

• • Publish its draft CAWP standards for public review and comment.

  • Conduct a formal science- and data-based review and revision of those standards.

  • Finalize and formalize a truly enforceable welfare policy for wild horses and burros, with clear consequences for violations.

The Wild Free-Roaming Horses and Burros Act will turn 55 in 2026. In all that time, BLM has never implemented a real, enforceable welfare standard that reflects current veterinary knowledge or lessons learned from decades of roundups.

The record is now undeniable: BLM has not earned the public’s trust on animal welfare. Congress must take the lead.

As the next federal spending debate begins in January, lawmakers have a clear opportunity. All they need to do is direct and fund BLM to do what it promised long ago: review and revise the standards, open them to public comment, and finalize a comprehensive, enforceable welfare policy worthy of the wild horses and burros the law is supposed to protect.

Take the pledge!

Work with us to make 2026 the year we gain a real review that includes public participation and, after 55 years, a formalized set of enforceable welfare standards to stop needless suffering and death of our precious wild horses and burros. Enough. is enough.

Take the pledge today!

Sign on here!

Make sure to check out page 5 and page 11 to see emails that clearly show that the committee was aware that they did not complete any of the reviews, audits, revisions, public participation, that was to be a part of the CAWP. To this day, they have not completed them. (If the pdf reader is not working on your device, you can open the pdf in a new window HERE)

CAWP WHE FOIA FINAL_V1_ EmailsTimelineCommentary

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