Orphan (Winnemucca facility) taken on the only public tour ever offered

After the winter roundups at Antelope and Owyhee, another scathing Freedom of Information Act (FOIA) report, the reality of foal deaths, miscarriages, and BLM’s disregard for foaling season has pushed welfare back into the public eye.

The Bureau of Land Management (BLM) once recognized this problem clearly enough to issue Instruction Memorandum 2014‑133, creating a separate system to record stillbirths and foals born dead precisely because they were not being captured in the main Wild Horse and Burro Program database. That was supposed to be the beginning of honest tracking, not the end of it.

Do you know what happened? 

In 2015, BLM launched the Comprehensive Animal Welfare Program (CAWP), after years of our relentless litigation, promising that documentation and tracking of injuries and deaths—including foals and spontaneous abortions—would be built into the heart of the program. When WHE pointed out that miscarriages were missing from the original welfare‑standards documentation, BLM said those metrics would be covered in the facility‑specific standards instead.

Meanwhile, organizations like WHE file Freedom of Information Act (FOIA) requests year after year and do great reports on what they find, but in Congress the “what can be done” keeps getting lost behind debates over more money for fertility control and roundups.

Formalizing BLM’s welfare rules—by finally turning CAWP’s underlying standards into enforceable regulations with public review and comment—could change that. It would not only fix the glaring lack of real data, especially on foals and miscarriages, it would start to build a system where needless suffering and death are actually reduced instead of hidden.

Right now, death statistics have not dropped even a fraction of a percentage point since BLM began CAWP; until the rules are formal, transparent, and enforceable, that is unlikely to change.

Send a letter to your Representatives Today! Click HERE.

“Hope” died after his feet literally began to fall off at Broken Arrow. photo copyright Laura Leigh

On paper, BLM now points to CAWP and Permanent Instruction Memorandum 2021‑002 as proof it has everything under control.

But because CAWP was never turned into a real regulation, these “standards” function more like suggestions than enforceable rules. A field office or contractor can ignore them with little more than a wrist‑slap, and the public has no clear, legal way to demand stronger protections or modern updates based on current science.

There is no formal process to fix gaps, no enforceable requirement to document and publish data that would show when things go wrong, and no built‑in consequences when BLM breaks its own guidelines.

In fact, the number one “noncompliance” issue with CAWP is the lack of documentation. At roundups the BLM CAWP team publishes “findings” before roundups are even completed never addressing the sheer lack of required documentation. At facilities a noncompliance” on record keeping can be noted in multiple “reviews” with zero consequence and, in fact, these facilities get bigger and bigger contracts.

PLEASE Read: BLM knew what they were supposed to do and simply rolled over draft standards with no public review and spent 4 years talking about what essentially amounts to the “cover letter” 

How Documentation Was Supposed to Work

The architecture BLM designed on paper recognizes that humane treatment is inseparable from documentation. The original gather standards and CAWP framework grew out of earlier directives like Instruction Memorandum 2014‑133, which focused on foal deaths and spontaneous abortions and emphasized the need to track those outcomes as part of welfare oversight.

That documentation mandate was supposed to “roll into” the broader CAWP and PIM 2021‑002 structure, so that foal losses at trap, miscarriages during winter roundups, and deaths in holding did not simply disappear from the record. The gather standards specify that any wild horse or burro that dies or is euthanized during operations must be documented, with responsibilities clearly assigned to BLM officials. The facility standards similarly state that facilities must maintain records of veterinary visits, treatment, and conditions as a major requirement of humane care, not an optional extra.

What BLM Actually Did on the Ground

The story of the baby burro at Palomino Valley Center shows how far BLM has strayed from even its own paper standards.

A heavily pregnant jenny was captured during the McGee Mountain removal; her foal, born in a BLM facility, was observed in obvious distress over several weeks with diarrhea, lethargy, and deteriorating condition. Despite repeated, documented requests from observers for veterinary attention and an identified adopter ready to provide intensive care, BLM staff dismissed concerns, blamed the jenny as a “bad mom,” and continued feeding practices (free‑choice alfalfa without nutritional analysis) that are specifically risky for burros and foals. When the foal died after the Thanksgiving weekend, BLM’s FOIA response stated that because the foal was never branded, “no records were created” and no veterinary documentation existed—directly contradicting CAWP’s requirement for routine veterinary presence and maintained records, regardless of whether an individual has been branded.

This is not a paperwork technicality; it is a structural erasure of the most vulnerable animals from the official record.

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Do you want things to change? 

Then we as an advocacy must not simply gasp at the next report we expose from BLM that fails to appropriately document miscarriages or another roundup where we watch them run another baby’s feet off. 

We must turn every single report into a “war cry!” Formalize welfare rules, now!

New babies sit in the target zone for July roundups when many mares will still be pregnant.

There must not be another roundup season where BLM operates without putting draft welfare standards out for public review, updating them to meet modern veterinary science for welfare and documentation, and finally, after 55 years of a law that already requires “humane” management, giving wild horses and burros a meaningful set of enforceable welfare rules.

Please help get this important issue in front of your lawmakers today! Do not let Congress claim they are working for “humane management” while every single year they ignore the need for enforceable welfare standards. 

Send a letter to your Representatives Today! Click HERE.

Every mile we travel to cover roundups or assess a herd, every court case we bring, every win, every action we take is only possible because of your support. 

We thank you for being an active advocate and standing up for Freedom, Mercy and Justice.