The Word Game Is Over: Nothing Is “Humane” Without Rules

There Is No “Humane” Without Enforceable Welfare Standards

Tomorrow the helicopters lift off at Mono Lake. On July 10, the machine turns to the Callaghan Complex, where the Bureau of Land Management (BLM) intends to remove roughly 2,000 wild horses on its way to driving a million-acre landscape down to just 323 animals. Saylor Creek in Idaho has been pushed to on or about July 15, tied to a recycled 2019 plan through a “Determination of NEPA Adequacy” that is simply not adequate. Then Lahontan on July 20. Then Moriah. Then over a thousand in Colorado, over a thousand in Utah, and on into Wyoming, California, and back into Nevada.

All of it will happen with no enforceable welfare standards.

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You can also use the points in the action item and call your members of Congress.

Why?

There is a federal prohibition on helicopter capture during what BLM calls “foaling season” — but that prohibition only runs from March 1 through June 30. On July 1, the gate opens. The second half of the fiscal-year schedule begins, and helicopters chase horses straight into the most dangerous weeks of the year.

Ask yourself why. There is no data-based definition of when foaling actually begins and ends. There is no requirement that BLM check the science of birth timing against the calendar it drew. So newborn foals born in July — animals the prohibition was supposed to protect — are run for miles days after the “season” is declared over on paper.

And once the helicopters are cleared to fly, they fly into heat and, very likely, smoke. There is no heat index standard. No air quality standard. None. These are the standards a city posts to tell you when it is unsafe to walk your dog or jog in a park. BLM has repeatedly refused to adopt them, even though both are directly linked to a higher incidence of catastrophic injury and illness. The agency continues capturing wild horses and burros during heat events and dangerous wildfire-smoke air quality.

This is not a “they might.” As smoke settles over the Great Basin and the heat index climbs, newborn babies, wild families, and older horses will face unnecessary suffering and death. This is a “they will.”

How the Word “Humane” Got Hijacked

Every year, the same ritual plays out. Members of Congress (and others) call themselves “leaders” in wild horse welfare in press releases — for approving more money to help BLM drive populations down, in many cases below genetic viability, and keep them there. The word game defines “humane” as: keep accelerating removals, as long as you increase fertility-control drug use afterward.

That has nothing to do with welfare. It has nothing to do with the repeated acts of neglect and outright abuse documented at the trap: electric shocks used even on the face and neck to speed up loading, foals left behind, animals moved so fast that trailer doors were not even secured. “Humane” has been captured by big-money lobby interests and turned into a public-relations function that gives cover to politically motivated removals.

Please keep in mind: “Fertility control” means a lot of things. Vaccines are primarily applied as part of a helicopter roundup after BLM “is close to or has reached AML.” (AML is the number of wild horses or burros BLM says can be on the range.) Fertility control also means gelding, spaying, sex ratio skewing and the multiple substances BLM can shoot out of a dart gun. It does not mean only a one-year vaccine applied via dart gun. All of this is also carried out with no enforceable welfare rules. 

CAWP: A Hollow Shell Where Standards Should Be

It took years of litigation just to force BLM to create the Comprehensive Animal Welfare Program (CAWP). Without that litigation, CAWP would not exist at all.

But BLM stopped short of finishing the job — even though its own people knew what completing the process required. Internal emails obtained through FOIA litigation now show the truth:

• BLM never conducted a single meaningful review of the CAWP Gather Standards issued under the 2015 Instruction Memorandum.
• By 2018, BLM had deleted the CAWP Gather Assessment Tool — the mechanism meant to evaluate, improve, and enforce the standards — without ever performing one review. (While in 2016 through 2019 they kept insisting they were doing annual reviews and would release the revised standards for public comment.)
• In December 2020, BLM declared CAWP “permanent policy” by simply reissuing the draft standards, with no data-based review, no veterinary revision, and no public comment.

The agency then told the public, the press, the courts, and Congress that it had done a “careful, data-based review” and “formalized” the program. The emails show what we have known all along: they “formalized” the cover letter for the program, not the welfare standards.

In litigation, BLM has even claimed the window for public participation has “expired” — when its own records show there was never a public comment period to begin with.

So what does “comply with CAWP” actually mean today?

It means comply with a “program” — not rules — that leave welfare “at the discretion” of whoever is in charge that day. In practice, that produces a massive disparity: at one trap, care; at the next, electric shocks to the face and foals left behind. A program with no formal standards, no heat index, no air quality threshold, and no data-based foaling definition cannot possibly meet basic recognized veterinary welfare parameters. Nothing run under it can honestly be called “humane.” 

This Should Be The Easy One

The Wild Free-Roaming Horses and Burros Act turns 55 in 2026.

In all that time, BLM has never implemented a real, enforceable welfare standard that reflects current veterinary knowledge. BLM did not even create any pretense of a welfare program until they were taken to court.

Here is what makes this moment different — and why this reform should be the easiest of all. This has nothing to do with the deep political fight over who wants horses and burros on the range and who doesn’t. It does not touch AMLs, grazing, or how many animals belong where. It is about a single, basic responsibility: treating living animals with basic decency while they are in federal hands. This should be something everyone in Congress should support.

What Congress Must Do

Congress keeps issuing a meaningless directive: Comply with CAWP. Why? Because it is what big money lobby groups tell them to do and then they use it to fundraise as a “victory” each year…. and it is a real problem in the real world. 

Right now we would have to take BLM to court for every single infraction. But all BLM has to say is the “program” says “nothing is wrong” and they “comply with the Comprehensive Animal Welfare Program.”  The court then has to say: all Congress has told them to do is comply. The program says they comply with a “program.” Where once we could win a lawsuit on abuse, big money has even gotten in the way on this issue as they co-opt words to move unrelated agendas. 

The program, right now, is literally a few BLM employees that go around saying one or two minor things could be improved. This team gave the Blue Wing roundup an “excellent” rating. (Most of you will remember the Blue Wing roundup for the horse choked to the ground and then kicked in the face when it would not rise).

What Congress Must Do

Congress must stop saying “comply with CAWP.” CAWP, as it stands right now, is simply a program that endorses the status quo. Instead, Congress must add language to the spending bill directing that: BLM must complete the process of formalizing the welfare rules contained within the CAWP program.

Concretely, that means the appropriations directive should require BLM to:

1. Publish its draft CAWP standards for genuine public review and comment.
2. Conduct a formal, science- and data-based review and revision of those standards — including a data-based definition of foaling season and adoption of basic heat index and air quality thresholds.
3. Finalize and formalize a truly enforceable welfare policy, with clear consequences for violations.

That is the whole ask. It is narrow, it is achievable, and it is overdue by decades. It is also really inexpensive to do.

In on-range management, during capture, into holding facilities, nothing can be held accountable to the word “humane” without actual enforceable welfare rules. 

Take Action Today

Are you tired of the word game? Are you tired of being treated as if you are not smart enough to figure it out?

Tell Congress you have had enough. In a few short days, real horses will pay the price for a word — “humane” — that was hijacked by corporate agendas to accelerate removals.

It does not have to be this way, and the fix does not require winning the bigger political war. It requires one line in a spending bill.

Send the letter to your Senators and Representative today. Demand that Congress fund and direct BLM to complete the process of formalizing enforceable welfare standards under CAWP — before the next helicopter lifts off.

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