Demand congressional oversight of wild-horse and burro population targets, habitat plans, animal welfare, and taxpayer spending.

Before BLM Rewrites the Rules, Congress Must Investigate

Demand a public oversight hearing on wild horses, burros, habitat, animal welfare, and taxpayer spending—before revised regulations become final.

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The federal government has formally placed a rewrite of wild-horse and burro regulations on its regulatory agenda. Now Congress must open the record on the program those regulations would govern.

The official agenda identifies “Regulations for the Protection, Management, and Control of Wild Horses and Burros,” RIN 1004-AE83, as a proposed revision of 43 CFR part 4700. The administration classifies the effort as “deregulatory” and says it would add “regulatory tools reflecting BLM’s current statutory authorities.”

In plain language, we see an effort to make it easier to drive wild-horse and burro populations down to targets whose scientific foundations remain unresolved—through accelerated removals, reproductive suppression, and potentially fewer safeguards against disposal through the slaughter pipeline. This concern does not arise from the word “deregulatory” alone. The White House’s FY2026 and FY2027 budget requests omitted longstanding language prohibiting the killing of healthy wild horses and burros and their sale to slaughter. Those requests did not themselves repeal the protections, but they reveal what the administration was willing to leave unprotected. Karen Budd-Falen, Interior’s associate deputy secretary, has also publicly described rewriting the regulations; Wild Horse Education’s reporting on her Wyoming remarks identifies sales and killing restrictions as subjects of that effort.

At Wild Horse Education, this is not an abstract concern. We went to court to confront BLM’s unlawful delay of herd management planning—and won. Now we are carrying numerous cases because BLM continues to resist meaningful herd and habitat management, producing documents we are challenging as population-suppression plans dressed up as management plans. We are fighting to make the agency disclose the evidence behind its population targets, explain its resource allocations, and address habitat protection. BLM is spending taxpayer money defending decisions that we contend sidestep those responsibilities while advancing the same agenda: remove animals to unjustifiably low numbers and suppress reproduction, including through sterilization.

We know what is at stake because we are fighting these battles—in the administrative record, in the courtroom, and on the ground. Our concern is that this regulatory rewrite will weaken the very obligations we have fought to enforce, making it easier for BLM to remove animals and harder for the public to demand lawful management. Congress must not allow “new tools” to become an escape hatch from accountability. Before this administration changes the rules, it must answer for the program it is running.

That is why oversight must come before revised regulations become final.

A formal rulemaking—not a confirmed publication date

For decades BLM has denied the public the opportunity for rulemaking for an enforceable welfare policy. But not when it comes to moving to gut protections.

The agenda lists the effort at the Proposed Rule Stage, shows a July 2026 target for a notice of proposed rulemaking, and leaves final action “To Be Determined.” It identifies no legal deadline and provides no Federal Register citation for a published proposal. The listed target date is not proof that publication occurred.

Congress should require Interior to disclose its actual timetable now. If a proposed rule is published before a hearing can be held, Congress should examine it during the public-comment period, with sufficient time afterward for informed public comments. We are asking Interior not to finalize revised regulations before that public examination. A hearing request does not itself legally suspend rulemaking.

A hearing must examine the foundation—not simply removal targets

The dedicated Senate program hearing on July 16, 2019, had five witnesses: a BLM official, a rangeland scientist, a rangeland-management coalition representative, a county commissioner, and Nancy Perry of ASPCA. Perry supported the Path Forward approach. The panel did not include an independent wild-horse and burro protection organization litigating BLM’s herd-management decisions.

Support for a population growth suppression plan (removal, vague fertility control) is not a substitute for testimony from advocates testing the legality of that management in court. A new hearing must examine why animals are placed on removal lists—not simply how quickly BLM can take them away and suppress any recovery growth.

1. Show the evidence behind every population target

BLM uses appropriate management levels, or AMLs, to determine how many wild horses and burros it considers excess. But an agency target is not automatically a scientific finding. In 2013, the National Research Council reported that it “could not identify a science-based rationale used by BLM to allocate forage and habitat resources to various uses.” BLM has never rectified this error and is simply refusing to disclose this information through Herd Management Area Plans (HMAP).

Congress must examine the records behind individual AMLs.

For every herd management area, require BLM to disclose the original AML and revisions; supporting decisions, data, calculations, and methodology; forage and water allocations; the role of negotiated agreements and inherited decisions; and whether current evidence supports the target.

Where evidence is missing, BLM should say so. Repeating an old number does not validate it.

2. Require real herd and habitat management plans

A Herd Management Area Plan, or HMAP, must address herds and habitat—not simply repeated captures. Wild Horse Education went to court to enforce that duty. In March 2024, the court in Leigh v. Raby found that BLM had unreasonably delayed an HMAP for the Pancake Complex and ordered action. This finding was repeated in what is called Leigh v Raby II, at Blue Wing and again at Saulsbury.

We are now challenging the Callaghan Complex HMAP/Gather Plan, (Carter, Jackson Mountains and more) for what we contend is inadequate site-specific herd and habitat planning.

Congress must identify missing or outdated HMAPs and examine whether existing plans explain AMLs, forage allocations, habitat objectives, water access, monitoring, and competing uses. Why must the public repeatedly litigate these duties, and what does that cost?

Require Interior to explain every proposed regulatory change affecting HMAP obligations. A rewrite must not become an escape hatch from accountability.

3. Examine habitat and competing uses

BLM budget materials describe wild-horse and burro management across approximately 26.9 million acres, compared with livestock grazing administered across nearly 155 million acres. These acreages overlap; they are not exclusive land bases.

Congress should require an HMA-by-HMA accounting of horse and burro populations, actual livestock use, forage allocations, water availability, and monitoring findings—alongside existing and proposed mining and energy development, associated roads and infrastructure, and their effects on habitat and water access.

How does BLM distinguish horse and burro impacts from livestock, mining, energy development, drought, and wildfire? What habitat has been lost, fragmented, or made inaccessible? When were livestock reductions, development restrictions, or habitat protections considered instead of removals, and why were they accepted or rejected? Why is BLM failing to identify critical habitat needs of wild horses and burros and failing to address mitigation in HMAPs?

Wild horses and burros should not be the default animals removed—or blamed—when competing uses consume or degrade the resources they need. Congress must examine allocation, not simply population.

4. Put animal welfare under independent scrutiny

BLM’s June 2026 CAWP policy includes contract standards, but its gather standards require on-call veterinary support—not continuous on-site veterinary presence. They assign medical-treatment and euthanasia decisions to the on-site Lead COR/COR/PI under agency policy.

Congress must examine veterinary presence and response times, decision-makers’ qualifications, treatment and euthanasia decisions, injury and death reporting, contractor compliance, and consequences for violations. Congress must examine why BLM has refused to address rulemaking for an enforceable welfare policy.

Internal policies and contract provisions are not the same as publicly promulgated welfare regulations. The public deserves transparent, enforceable protections and independent veterinary scrutiny—not simply agency self-review.

5. Follow every animal through adoption and sale

An August 2026 investigation reported that BLM horse sales more than doubled to approximately 3,700 in 2025 and raised concerns about slaughter channels. BLM denies selling or sending animals to slaughter and says credible allegations are reviewed and referred for enforcement when appropriate. Congress must examine the records.

Require animal-level tracking from capture through adoption or sale and subsequent documented outcomes, including buyer histories, bulk-sale approvals, sale eligibility, transportation spending, complaints, investigations, and enforcement results.

What can BLM verify after ownership transfers? An animal disappearing from government inventory is not proof of a safe outcome.

6. Follow the money and update the independent science

BLM reports $142 million in FY2024 appropriations and $153 million in expenditures from multiple sources, including $101 million for off-range holding. In September 2026, it announced a $30 million USDA fertility-control investment. Congress should require disclosure of that funding’s terms and timing

Require a complete accounting from FY2018 forward of funding, transfers, contracts, expenditures, balances, and measurable results.

Commission an updated National Academies review of AMLs, resource allocation, population estimation, habitat, welfare, and implementation of the 2013 recommendations—before BLM expands its regulatory tools.

Independent voices must have a seat at the table

Alongside BLM officials, the witness panel must include independent advocates with direct field and litigation experience, independent scientists, and equine veterinary experts that are not under the thumb of livestock politics. Require disclosure of relevant contracts, financial interests, and participation in management proposals.

Congress needs the underlying records—not an agency slide presentation—and an explanation of every proposed change affecting planning, population targets, habitat, welfare, adoption and sales, and public participation.

Take action: request oversight of RIN 1004-AE83

Send the campaign letter to your U.S. representative and both senators. Ask them to request a dedicated oversight hearing and urge Interior not to finalize revised regulations before Congress and the public examine the proposal.

If a proposal is published first, demand a hearing during the comment period, with enough time afterward for informed comments. A hearing request does not replace an official rulemaking comment.

Before the rules change, open the record.

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. Sincere Gratitude.