A rabbit hole is a metaphor for a complex, time-consuming, or bizarre situation where pursuing one topic or task leads you deeper into a chain of related side-topics, making you lose track of time or stray far from your original goal.

We hit a rabbit hole and have not come up for air. We have filed two Freedom of Information Act requests this weekend regarding CAWP. Why?

Some of our team members are still dealing with issues resulting from wildfire (please keep them in your “good thoughts,” so we have new trainees in the field for the first time “flying solo.”

Our trainees usually get in-field experience with an existing member and, if they decide they want to do more than “observe,” begin training to join our welfare team. That training includes a lot of things; but it also includes current BLM policy and procedure.

So we began updating the packet for new team members. 

We found something that we thought you might like to know (as BLM never notified the public at large or the public onsite at roundups).

BLM changed the CAWP standards. 

Piceance

BLM changed the CAWP standards

You can read about some of the history of the fight to gain enforceable welfare rules and how BLM dropped the ball and never formalized enforceable rules HERE.

The Bureau of Land Management quietly reissued its Comprehensive Animal Welfare Program (CAWP) on June 29, 2026. Right before the helicopters flew on July 1, BLM weakened protections and told no one.

BLM calls the new document for “gathers”, PIM 2026-004, a “reaffirmation” of humane treatment and says it increases transparency. But a internal recommendation is not the same as enforceable law—and a rewrite that weakens  safeguards, broadens discretion, and relies on the agency to police itself is not meaningful reform.

It is a paper shield and a meaningless assertion of review. 

The public should not be asked merely to trust BLM’s assurances after documenting years of injuries, deaths, excessive heat, dangerous handling, inadequate care of vulnerable foals, and failures at traps, temporary holding, and facilities.

Congress must require enforceable, science-based welfare regulations, independent veterinary oversight, complete public reporting and process (including a comment period), and meaningful consequences when standards are violated… now. 

CLICK HERE TO TAKE ACTION

You can also use the points in the action item as a script, just click above and call your members of Congress.

• Senate Direct Line: Call (202) 224-3121 for U.S. Senators

Bible Springs: BLM knew a vet would not be present yet failed to obtain adequate supplies to care for orphaned or stressed foals in summer.

What the New CAWP Does

PIM 2026-004 replaces the 2021 CAWP memorandum (that simply made the 2015 IM permanent without review) and applies immediately to BLM field offices, contractors, and partners. BLM says the program will be reviewed periodically by Wild Horse and Burro Program leadership (again denying the public input required to create real enforceable rules… again).

The critical question is not whether BLM has a document called a “Comprehensive Animal Welfare Program.” The question is whether the document creates independently enforceable, measurable protections for the animals at the trap and after capture.

It does not.

Callaghan, 2026

Protections Should Not Disappear

BLM removed the requirement for a veterinarian to be at the trap site. Under the new CAWP language, a veterinarian can be merely “on call.” There have been no veterinarians onsite at operations this summer except for a few days when the state of Colorado sent their vet to Piceance.

That means when a wild horse collapses, breaks a leg, suffers heat stress, is injured in the wings, arrives at temporary holding in distress, or a vulnerable foal needs immediate care, the veterinarian does not have to be standing there. The veterinarian can be somewhere else—reachable by phone by a field manager that may be in charge that day. No hands on exam before a horse loses it’s life and no one there to treat immediate injuries or stress illness (like colic). This is probably why the vast majority of deaths this year have no underlying cause identified.

That is not stronger welfare protection. It is weaker protection.

BLM also loosened other basic safeguards. The new language gives more room for hot-shot use without the prior requirement to seek permission and again allows contact with a horse’s face if BLM decides the contact was “not intentional.”

Access to document handling is being is being unreasonably restricted this summer. The primary reason is that “cameras make the crew nervous.” First, that is not a narrowly-tailored lawful restriction. Second, is it because they get nervous when they do things they should not be doing and get caught? (This type of hotshot use would be allowed under the current changes to CAWP. Back then it was not allowed and still done in the presence of the BLM in charge of policing the operation.) Only public oversight is real oversight. (The video below was edited this way out of frustration. Normally there would be no “comic book” style text onscreen.)

These are not harmless edits.

The person in charge can say the veterinarian was available by phone. The contractor can say the prod was necessary. The agency can say face contact with electric shock was accidental. The operation can continue while BLM writes itself another report grading itself as “excellent.”

Meanwhile, the horse is still injured. The foal is still without immediate care. The public is still told to trust the same agency that wrote the loophole, ran the operation, scored its own compliance, and decided whether anyone did anything wrong. (As public access is being gutted to allow BLM to control the narrative of public opinion.)

The prior CAWP standards for euthanizing a horse or burro referenced the American Veterinary Medical Association (AVMA) Guidelines for the Euthanasia of Animals. That matters because the AVMA guidelines are an outside professional veterinary standard. They provide an independent, recognized benchmark for what constitutes humane euthanasia. The revised CAWP replaces that outside reference with an internal BLM policy reference (current standards include captive bolt). BLM also loosened documentation requirements.

That is not a neutral edit. It removes an external benchmark and puts BLM in the position of defining, applying, and judging its own euthanasia practices.

A wild horse or burro facing euthanasia deserves the highest available veterinary standard—not a standard BLM can revise internally or on-the-fly at the discretion of onsite personnel whenever it becomes inconvenient, embarrassing, expensive, or operationally difficult.

Wild horses soaked in sweat during dangerous heat at the Callaghan Complex (South Shoshone) roundup.

BLM also changed parameters for CAWP standards in holding

The Equine Infectious Anemia (EIA) testing changed from 30 days to 60. Change the electric prod strict “3 times” limit and now only limits “multiple times in an egregious manner.”

Earlier documents noted a preface that expressly framed the program as a response to scrutiny of handling, transport, facilities, nutrition, and a need for transparency, including reference to a 2008 GAO recommendation. None of that is recognized in the new format.

Who Decided to Weaken CAWP?

BLM has not publicly released the full drafting record for the June 2026 CAWP rewrite. They did not even tell the public that they rewrote it. So we cannot honestly state which individual ordered each specific change.

Who decided to review, change the standards and omit the public review before finalizing again?

We will have to wait until our Freedom of Information Act request is fulfilled.

These changes did not appear by magic. Someone requested the review. Someone decided what “problem” needed fixing. Someone selected the people in the room. Someone drafted the redlines. Someone removed the stronger language. Someone approved it. Someone signed it. And someone directed the field to follow it.

The public deserves every name. We are looking into it.

We will write more on this issue as we gain new information and time allows.

The public does not need another promise that BLM will review itself.

We need a formalized set of welfare rules that includes public participation and veterinary standards used today, not old myth. 

Did they do it because so many of you are pressuring your lawmakers asking for a review and formalization? Probably.

So please, keep up the pressure:

CLICK HERE TO TAKE ACTION

You can also use the points in the action item as a script (just click it to see) and call your members of Congress.