Wild Horse and Burro Comprehensive Animal Welfare Program

PIM 2021-002
Permanent Instruction Memorandum

December 18, 2020

In Reply Refer To:
4700 (260) P



Permanent Instruction Memorandum No. 2020- 002


To:                  All Headquarters Officials and Field Office Officials

                       Attn: State and Center Directors

From:              Assistant Director, Resources and Planning

Subject:           Wild Horse and Burro Comprehensive Animal Welfare Program


Program Area:  Wild Horse and Burro Program

Purpose:  The purpose of this Permanent Instruction Memorandum (PIM) is to re-affirm the Bureau of Land Management’s (BLM’s) longstanding commitment to ensure the humane treatment of wild horses and burros (WHB) in all on-range and off-range management activities through the Comprehensive Animal Welfare Program (CAWP).  The humane treatment of wild horses and burros outlined in this policy reiterates the BLM’s longstanding practices but also provides additional clarification to BLM employees.  This PIM consolidates current humane practices, incorporates the existing Standard Operating Procedures (SOPs) outlined in Attachments 1 and 2 to ensure humane care and handling of the animals, and increases transparency concerning the humane treatment of wild horses and burros.

Policy/Action:  The BLM is committed to continue protecting animal welfare and providing humane care and treatment to WHBs both on and off the range.  Consistent with long-standing policies and practices, the handling and treatment provided by the BLM, its contractors, and its partners is based on compassion and concern for the animals’ well-being at all times.  Animals are managed and cared for to optimize animal condition, health, and safety.

All state, district, and field offices will continue to comply with the WHB CAWP policy within their jurisdiction at all times.  The WHB CAWP policy includes:

  1. CAWP Standards for Wild Horse and Burro Gathers (Attachment 1):  These standards include requirements for trap and temporary holding facility design, capture and handling, transportation, and care after capture.  The standards are also incorporated into helicopter gather contracts as specifications for performance.
  2. Training for gather operations:  All BLM staff associated with gather operations (incident commanders, contracting officer representatives, project inspectors, public affairs officials, and law enforcement officers) and contractor crews are required to complete online training annually for CAWP – Gathers (BLM-TC-4700-13), which is available through DOI Talent.
  3. CAWP Standards for Off-Range Corral Facilities, Transportation, and Adoption/Sale Events (Attachment 2):  This includes requirements for holding of animals in off-range corrals, transportation, and adoptions/sales events.  These SOPs are incorporated into off-range corral contracts as specifications for performance.
  4. Training for the Care, Handling, and Transportation of Wild Horses and Burros at off-range corrals and adoption/sales events:  All personnel, including contractors and partners  involved in the care, handling, and transportation of wild horses and burros at off-range corrals and adoption/sale events are required to complete online training annually.  Development of this training will begin following issuance of this PIM. 
  5. CAWP Standards and SOPs (to be developed) for animals on the range, in off-range pastures, and public off-range pastures:  All personnel, contractors, and partners involved in management of WHBs on the range, in off-range pastures, or public off-range pastures are required to complete online training annually following the development of these guidelines and SOPs.

The purpose of this PIM is to continue to ensure that the humane care and treatment of WHBs remains the priority for the BLM, its contractors, and its partners. The BLM will continue to use the best available science, husbandry, and handling practices applicable for WHBs.  Whenever possible, the BLM will make improvements to its practices while also meeting planned objectives in accordance with current BLM policy, SOPs, as well as contractual and cooperative agreement requirements. The CAWP will be reviewed periodically by WHB program leadership and modified as necessary to strengthen public trust, transparency, and effectiveness in assuring the humane care and treatment of the WHBs.

The authorized officer is the primary party responsible for immediately addressing any actions that are inconsistent with the CAWP.  Consistent with applicable BLM delegation of authority manuals, the authorized officer may delegate responsibility to an alternate individual.  The authorized officer should promptly notify the employees, contractors, and partners of actions that are not compliant with the CAWP and correct all issues immediately.  It is the responsibility of all individuals engaged in actions throughout the WHB program to implement all aspects of the CAWP.

The WHB CAWP Coordinator will lead the implementation, development, and modification of all aspects of the CAWP, including those developed to date as well as future components of the CAWP.

Timeframe:  This policy is effective immediately.

Budget Impact:  This PIM codifies long-standing policy, practice, and guidance to include mandatory annual training and reporting requirements for BLM personnel, contractors, and partners associated with gather operations.  The cost for the required training is approximately $100 per person per year.  This PIM also formalizes SOPs for off-range holding, adoptions, sales, and transportation of excess WHB.  When fully developed, the CAWP program implementation, oversight, data compilation, and reporting requirements will require an additional 12 to 18 work months per year.

Background:  Public Law-195, Wild Free-Roaming Horses and Burros Act of 1971 (as amended) and 43 CFR 4700.0-2 provide the authority for a CAWP for WHB.

This CAWP policy provides a comprehensive approach to long-standing policies and practices within the BLM WHB program.  Despite these policies and practices, the BLM has been criticized by some animal protection organizations on its handling and care of wild horses and burros, especially during the gathering activities and transitioning of the horses from public lands to off-range facilities.  Some of the criticisms include concerns as to the transportation conditions of the horses, facility design, environmental conditions, handling practices, and nutrition.  Similar to policies adopted by other organizations in agricultural and animal research industries, this PIM establishes a framework to ensure there are programs in place to verify humane care and handling of animals.  It provides transparency on how the animals are assured humane care and proper handling.  This framework seeks to confirm that the WHB program is conducted in a humane and caring manner.

The CAWP for WHB consolidates and highlights the BLM policies, procedures, and ongoing commitment to protect animal welfare; provides training for employees, contractors, and partners on animal care and handling, and implements assessment tools to evaluate adherence to the CAWP SOP by the agency, contractors, and partners.

Manual/Handbook Sections Affected:  This PIM affects policies in BLM Manual/Handbooks H-4700-1 “Wild Horse and Burro Management” and H-4750-2 “Adoption of Wild Horses and Burros”.

Coordination:  This PIM was coordinated among HQ-100, HQ-200, HQ-260, HQ-600, Deputy State Directors, WHB State Leads, APHIS Veterinarian, WHB Facility Managers, and WHB Specialists.

Contact:  If you have any questions, please contact the Wild Horse and Burro Division Chief, at 866-468-7826 or wildhorse@blm.gov.


Signed by:                                                                   Authenticated By:

David Jenkins                                                             Ambyr Fowler

Assistant Director                                                       Division of Regulatory Affairs (HQ-630)

Resources and Planning

2 Attachments

  1. - CAWP Gather Standards (20 pp)
  2. - Comprehensive Animal Welfare Program Standards for Off-Range Corrals, Transportation and Adoption/Sale Events (24 pp)