Above: California wildfire smoke blows into northern Nevada during roundup. The roundup does not pause even though warnings have gone out to stay indoors and not to exercise your domestic horses. 

The record is now undeniable: BLM has not earned the public’s trust on animal welfare. Through Freedom of Information Act (FOIA) litigation WHE has obtained long sought after proof that BLM has repeatedly failed to create acceptable welfare standards. 

WHE broke that story last week. You can see more HERE. 

BLM has stonewalled required public participation and external review. This article illustrates the impact on wild horses and burros and why external (public) review is vital.

Scroll to red text to find the sign on letter to Secretary Burgum.

BLM’s Animal Welfare Program for Wild Horses and Burros: Failures Demand Urgent Reform 

For generations, Americans have stood together to protect wild horses and burros and to ensure their humane treatment. Inspired by the tireless advocacy of Wild Horse Annie, Congress unanimously passed the 1971 Wild Free-Roaming Horses and Burros Act, directing the Bureau of Land Management (BLM) and the U.S. Forest Service to preserve, protect, and treat these iconic animals humanely. The law was born from outrage over abuse—yet, for decades after its passage, the agencies operated without any binding humane standards in place.

BLM’s creation of the Comprehensive Animal Welfare Program (CAWP) was presented as a promise to uphold humane care for wild horses and burros under federal management. In reality, vague language, minimal transparency, and the absence of enforcement have allowed suffering and preventable deaths to persist.

Roundups and removals are the most visible symbol of this failure. In this one narrow area is just one example that reveals an alarming gap in welfare protections—the lack of enforceable standards for temperature and humidity, heat index, air quality, and wildfire smoke exposure.  CAWP is supposed to govern all phases of wild horse and burro management—from life on the range, through roundup, transport, holding, adoption, and sale. Yet its safeguards frequently exist only on paper.

Americans must once again raise their voices for humane treatment—demanding accountability, transparency, and meaningful reform.

Historically, the BLM has denied allegations of abuse and resisted independent oversight, acting only when compelled by litigation, public advocacy, and mounting outrage. Recent BLM emails obtained through Freedom of Information Act (FOIA) investigation expose agency negligence toward both wild horses and the public trust. Beginning in 2011, Wild Horse Education (WHE) litigation revealed widespread cruelty in roundups, pressuring BLM to announce they were beginning to create CAWP in 2013.

By 2015, the agency claimed to take a long-overdue step by developing CAWP—but failed to take the critical next step to finalize it through public rulemaking.  Without that process, the program lacks the legal force and public participation necessary to create binding, science-based welfare standards.  Instead, BLM has relied on internal “policy” that cannot be enforced and does not invite public or independent expert review.

BLM also pledged to conduct annual assessments, incorporate evolving science, and formalize CAWP through open rulemaking (a process in which public participation occurs).  None of those commitments have been honored.

By 2020, the agency quietly merely characterized CAWP as “policy,” excluding independent veterinarians, data and science, and advocates from shaping how “humane treatment” is defined or applied. The result: CAWP serves as a shield protecting the agency from accountability, rather than protecting horses and burros from harm.

A clear example is BLM’s disregard for environmental factors such as temperature and humidity (Heat Index), poor air quality (AQI), and wildfire smoke—conditions that can cause profound and preventable suffering and death. BLM’s internal report rated the Blue Wing roundup excellent on meeting applicable CAWP standards overall—an obvious argument for urgent reform.

WHE members have pushed for years to get BLM to include these standards. WHE participated in every avenue open to us (and even attempted to create avenues) to provide data and documentation proving the lack of this basic veterinary standard was causing unnecessary suffering, long-term illness and immediate injury and death. We are simply ignored or, in some instances literally yelled at. 

Capture during heat event and dangerous air quality from wildfire smoke, Blue Wing.

Blue Wing Complex Roundup, 2024 — A Case Study

From July 8 through August 1, 2024, the BLM conducted the Blue Wing Complex wild horse and burro helicopter-driven roundup near Lovelock, Nevada, ending weeks ahead of schedule.  “July 2024 was the warmest month on record in Reno’s history.” During this period there were extended Heat Index rises, and wildfire smoke pushing air quality into repeated AQI warnings levels.

Even as the public and advocates urged BLM to postpone or suspend for animal safety, roundups continued uninterrupted.  Wild Horse Education (WHE) has repeatedly documented how CAWP’s current standards fail to offer basic protections in such conditions, renewing calls for reform.

At Blue Wing, BLM was taking captured equines from trap site and loading them onto a semi truck where they stood in the heat for up to three hours. At least three horses/burros dropped dead in the heat during transport.

BLM’s reporting on equine deaths remains deeply opaque.  During the Blue Wing roundup, the agency failed to document fatalities as required by its own program standards, omitting details and photographic evidence (CAWP, p.18).  Captured animals are typically transported to BLM facilities within 48 hours, masking roundup-related deaths.  Once at BLM facilities, any fatalities are excluded from official roundup death counts. These facilities do not publicly disclose equine deaths, but FOIA research has uncovered a troubling surge in fatalities within the first month following the Blue Wing operation.   

Is it because tracking these indexes is complex that BLM refuses? No, it is really simple, the public can do it.

Public Tools for Heat Index, AQI, and Equine Health Guidelines

Anyone can track real-time heat stress and air quality risks through federal tools:

• • Heat index monitoring: National Oceanic and Atmospheric Administration (NOAA) calculator
  • Air quality tracking: NOAA  Air Quality Index (AQI) page and user-friendly AirNow

For equine-specific references, consult:

• • Mad Barn’s monitoring and Equine Heat Index Guidelines, assessing heat stress risk and care requirements
  • Mad Barn’s tracking and Equine AQI Guidelines, addressing exposure to wildfire smoke
  • UC Davis Veterinary Medicine’s Smoke Inhalation Quick Reference Guide, how smoke affects horse respiratory health*

The heat index assumes shade and light wind; direct sun exposure can increase heat index values by up to 15 F” (Mad Barn and NOAA).

The heat index measures what the temperature feels like by combining humidity and air temperature; values skyrocket in full sun.  Horses are at greater risk than humans due to their body mass and heat production, as well as limited capacity to dissipate heat via sweat. This measure provides a better representation of risk of heat-related illnesses.

*UC Davis was a paid contractor BLM used to help create the draft standards. Somehow all of the basic guidelines on cold and heat indexes and air quality UC Davis has for equines did not make the version of CAWP Standards BLM published. The amount BLM paid UC Davis is unknown. 

A Pattern of Neglect Across Years

The Blue Wing operation is not an isolated case.  Similar welfare gaps have recurred for years at both Blue Wing and Antelope Complex roundups including:

Antelope Complex, 2023 – Ely, Nevada

In July 2023, advocates monitored and publicly reported the heat index during the Antelope Complex roundup.

Antelope Complex, 2021 – Ely, Nevada 

In August 2021, during another Antelope Complex roundup, BLM proceeded even during health warnings for air quality. WHE did a long article on air quality, risks, and showed that BLM simply does not care as they ran horses in an AQI over the veterinary standards.

Blue Wing (Shawave HMA), 2020 – Lovelock, Nevada

During the 2020 Blue Wing (Shawave HMA) roundup, BLM continued capturing wild horses while wildfire smoke was so dense that visibility was reduced to the blinking lights on the helicopter (below). The AQI repeatedly reached “dark purple” levels, over 350.

Toward an Enforceable Welfare Policy

A meaningful welfare policy must include transparent, science-based standards subject to annual review and revision.  It must be built upon basic, widely accepted equine welfare practices, grounded in science, informed by independent veterinary expertise, and open to public participation.  Humane standards should be clear, concise, and enforceable—not subject to agency interpretation or convenience.  These standards must explicitly address worsening environmental threats such as elevated Heat Index, degraded air quality (AQI), and wildfire smoke—conditions that place the wild ones at increasing risk.

Until BLM reforms CAWP through a formal rulemaking process—anchored in science, transparency, and accountability—it will continue to fall short of both public expectation and humane obligation.

BLM must be accountable to the steps outlined when CAWP was first announced in 2015 under pressure from Congress and the courts.

Congress can create accountability through the next budget bill. We will push Congress to in the new year to create a line item that requires BLM to complete this process.

However, the Secretary of Interior could simply create a Directive to BLM to complete the promise of truly formalizing welfare standards and provide the public the opportunity to participate that was promised. The Secretary has always held this power and has never exercised that authority.

You can sign onto our letter to Secretary of the Interior Doug Burgum by clicking HERE.

The law to protect our wild horses and burros turns 55 in 2026. It is long overdue to fulfill the most basic promise of the 1971 law, humane management. 

WHE stands independent—without corporate sponsorships or federal funding, beholden only to the wild ones who depend on us. Together, we can protect their freedom, their families, and their future.

Your support fuels every mile, every courtroom battle, every victory for the wild.

All contributions will be matched up to $10,000. through the end of the year. This fundraiser provides critical funding to take our work into the new year.

Thank you for keeping WHE running for the wild!