Title: "The Controversial Fate of Wild Horses: A Closer Look at the Pryor Mountains Incident and BLM Policies"
Two young foals rest in the shade of the Pryor Mountains. The remote range, which straddles the Montana-Wyoming border, is home to one of the most closely watched wild horse herds in the U.S.
Editor’s note: This story is the first in a two-part series funded by the Aspen Daily News Journalism Fund, which supports in-depth, independent reporting on issues that impact our region. Part Two, exploring federal policy, political fault lines and the broader implications for wild horse management in the American West, will appear in Monday’s newspaper.
On April 22, a mustang was shot and killed in Montana’s Pryor Mountains, on the northwest Wyoming border, by a Bureau of Land Management employee. According to an April 30 BLM Facebook post, the horse was in bad shape:
The stallion was found alone, no longer with his band, and was observed with a Henneke Body Condition score of 2 (on a 9-point scale, with 1 being “poor” and 9 being “extremely fat”). He displayed labored breathing, minimal mobility, and did not react when approached within close proximity. These signs pointed to significant suffering and a poor prognosis for recovery.
The BLM has set the Pryor Mountain range carrying capacity — what the agency calls appropriate management level, or AML — at 91-121 horses. The herd roams about 40,000 acres. Habitat is varied, from desert shrubland to sub-alpine forests and meadows. Water is unpredictable.
Ginger Kathrens, Emmy award-winning videographer and founder of The Cloud Foundation, knows that herd well and the range like her own backyard. She started following and filming the Pryor mustangs in 1993 and introduced the world to a white foal whom she named Cloud. He was the grandsire of the stallion who was shot in April. Advocates called him Echo.
BLM employee Jace Stott pulled the trigger. It is uncertain if Stott is a range specialist or a wild horse specialist.
Kathrens told the Aspen Daily News that it’s not unusual for a wild horse in the Montana mountains to be thin at the end of a cold winter. “[Stott] doesn’t understand that it’s this boom-and-bust economy I’ve talked about for decades,” she said. “You know, [the horses] make it just through winter, just in time to be back up and fine by summertime. And when winter comes again, the horses start to lose weight little by little by little.”
She added that minimal mobility is expected this time of year, particularly with a 15-year-old stallion. “It takes a little longer to beef up and probably it’s a little faster when you thin down, but, in any case, that’s just the way it is there.”
Kathrens and Jesse Daly, operations manager for The Cloud Foundation, went to see the stallion’s remains about 10 days after the incident. They didn’t hear about it for close to a week and then spent another 48 hours driving to the range, which is just outside Lovell, Wyoming. They said they also spoke with Jace Stott.
Contrary to what BLM reported on Facebook, Kathrens said the horse appeared to be in good condition — for a corpse. “He looked pristine other than, you know, he had a bullet hole in his forehead,” she observed. “His coat was in good condition. His feet were in great condition. His teeth were perfect.”
The Pryor herd is quite accustomed to human presence, thanks to thousands of visitors annually. According to the most recent numbers from the Pryor Mountain Wild Mustang Center in Lovell, close to 4,000 tourists visited the herd in 2017. Kathrens said the Pryor horses have little reason to fear humans.
“There are a tremendous number of tourists there on the weekends through the summer, and the horses on top of the mountain do not bother about people in general at all,” she said. “Sometimes they like to examine your car.”
She believes there is a certain level of trust between wild horse and human on the Pryors and questions Stott’s observation that Echo did not move away. “It’s like, well, no. Why would he have to move away? You know, we don’t get too close, and we’re cool,” she continued. “So it really is sad that he was so trusting of us, and then he came to this kind of demise.”
In a follow-up post on Facebook — in response to the backlash over Echo — the BLM states that the “employee in the field” called someone, who was not identified, before shooting the horse. Yet it is not clear that a veterinarian was consulted.
The decision was not made alone nor by the BLM employee in the field. The field staff member observed the stallion’s condition and contacted the Authorized Officer who is delegated to make the decision. Due to limited cell service, staff traveled over one hour to the top of the mountain to get cell phone coverage and then returned to retrieve equipment. Over two hours later, the stallion still had not moved and remained in distress. Euthanasia was carried out in accordance with BLM policy and veterinary guidance.
Daly disagrees. He observed the stallion’s remains more than 400 feet below a ridge where Daly said Stott originally saw the horse. “[Stott] took a picture to get permission to kill [the horse] at least 440 feet from where he shot him,” Daly said. “So the horse moved that distance.”
Daly’s questions about the incident remain unanswered. The Aspen Daily News sent the Billings BLM field office a Freedom of Information Act request for incident reports and staff training on May 7, which the BLM confirmed it received but did not answer by press time.
Despite, or maybe because of, BLM’s statement that the Pryor stallion was euthanized by trained BLM personnel according to the law and agency policy, advocates are worried about a 2021 internal agency memo titled, “Euthanasia of Wild Horses and Burros Related to Acts of Mercy, Health or Safety.” Internal memos are low on the bureaucratic totem pole — but can carry a lot of weight.
Wild horse and burro euthanization protocol is governed first by policy — the 54-year-old 1971 Wild Free-Roaming Horse and Burro Act. It’s a dense read. Federal agencies implement policy through the Code of Federal Regulations. Title 43 within the CFR refers to federal laws and regulations for public land, range, minerals and forest in separate chapters.
Wild horse regulations fall under public lands Title 43 Subtitle B, Subchapter D, Part 4700. CFR 43-4700 — speaking directly about wild horses — gets its own BLM-issued agency handbooks to provide internal, more detailed guidance regarding implementation of the policy. The most recent handbook was published in 2010. The agency developed a temporary instruction memo more focused on preventative medical care and evaluating the animal’s overall health in 2015, but it expired in 2018.
Then came “Euthanasia of Wild Horses and Burros Related to Acts of Mercy, Health or Safety,” two years later. This new memo, referred to as PIM 2021-007, replaced the 2010 handbook, and it drills down even further into the topic of euthanasia. According to a former senior BLM official familiar with the memo — who spoke to the Aspen Daily News on condition of anonymity — the document came out of discussions among senior staff.
“We were interested in ensuring that the public knew of our intention to treat horses as humanely as we could,” they explained.
Take a roundup, for example: chaotic and fast-moving with helicopters flying low, wild horses thundering across the landscape, stallions trying to leap out of crowded temporary metal corrals or jostling and fighting while loading into livestock trailers. “I mean, they’re stressful for people, they’re stressful for horses, they’re stressful for staff who have to deal with injured animals,” they said.
It’s easy for a mustang to break its neck or leg or tear a hoof while running lickety-split over rough ground and into a narrow trap. If the injury is too severe or the horse has other problems, the animal is often euthanized on the spot, sometimes with a firearm.
“We wanted to make sure that every portion of that process was formally rationalized,” said the former employee. “Not only so the public could see that we were taking the issue seriously, but our own staff and our contractors and, of course, the veterinarians we worked with would all have a common set of protocols to help them sort through.”
One section of PIM 2021-007 is devoted to euthanizing large numbers of horses and burros — including how to reduce the psychological impact on workers who have to kill the animals.
The memo does not address preventive medical care. It adds a captive bolt gun as a euthanization tool — although there is no mention of circumstances under which a bolt gun would be preferable to a handgun or rifle. The memo includes detailed definitions of why the animals can be euthanized, including old age, blindness, Henneke body condition score and more.
The person taking on this responsibility must have the appropriate agency authorizations and be trained and certified to use recommended firearms, bolt guns or injections. Field offices in charge of wild horse and burro herd management areas must have a euthanasia plan. In any instance involving a euthanasia, whoever puts down an animal must consult with a veterinarian.
If euthanasia is not possible, “humane killing … may be performed as an act of mercy,” according to PIM 2021-007. The memo does not offer an explanation of the difference between euthanasia and humane killing except to say, “in the event that no qualified veterinarian is available within two hours … and the need for euthanasia is obvious, the authorized officer may load and transport the animal to a “safe and discreet location and humanely euthanize it in order to prevent further pain and suffering.”
Kathrens, The Cloud Foundation founder, said a vet should have been contacted before shooting the Pryor stallion. “If you’re gonna try and kill a horse just for being skinny or having a limp, I think that should pretty much require that you call the vet and get a professional opinion,” she said. “That’s a horse that probably could survive.”
Concerns run deep about the fate of the horses and burros in long-term holding facilities. Congress, at the behest of the American public, has been able to keep euthanization of healthy excess wild horses and burros at bay for close to 40 years; however, it is still an option under the 1971 Wild Free-Roaming Horses and Burros Act and particularly PIM 2021-007.
As of April 1, more than 64,000 wild horses and burros are warehoused across the United States in off-range corrals and off-range pastures for animals the agency does not offer for adoption. Last year, the BLM reported that holding costs reached $101 million or 66% of the wild horse and burro program budget during the fiscal year. It’s a more-than 77% increase from five years ago, when those costs were $57 million.
The problem is underpinned by BLM’s reluctance to move away from the decades-long cycle of roundups, adoptions and warehousing excess horses and burros in long-term holding.
Until the early 1980s, removals were small. BLM generally adopted out as many mustangs removed from the range each year. But adoption rates declined in 1982, when the agency increased fees to defray program costs and dissuade the public from adopting large numbers of mustangs and selling them for profit. That same year, BLM initiated a self-imposed moratorium on killing excess, healthy wild horses and burros — and began putting those animals in holding facilities.
But after the adoption fee was reversed in 1983, BLM initiated a fee-waiver program, allowing for mass adoptions. Litigation stopped the program in 1984 but only after 20,000 wild horses were sold to slaughterhouses.
At the same time, Congress directed BLM to ramp up removal efforts, meaning more horses and burros were rounded up at a faster rate. To compensate, the agency expanded its adoption program nationwide. More animals were placed in private care, but adoption rates did not match removals and have never recovered pre-1982 levels. The BLM was, and still is, removing more animals than the adoption market can handle.
Fast-forward roughly four decades: From 2021 to 2024, according to program data, BLM removed 55,334 wild horses and burros and placed 30,570 into private care, including adoptions, sales and transfers to other government agencies. In 2023, more horses were placed into private care than were removed from the range, which could have been a result of fewer removals and the controversial Adoption Incentive Program, which paid adopters $1,000 per horse. The AIP was shut down earlier this year.
Still, unadopted horses remain a conundrum for BLM and wild horse advocates. Up to now, there has been little political will to resume destruction of healthy horses and burros, largely due to the efforts of protection groups and friendly congress members, but the threat remains ever-present and is always at the mercy of changes on Capitol Hill.
Congress stopped appropriating federal funds for the destruction of healthy excess wild horses and burros in the late 1980s, but the 2004 Wild Horse and Burro Sale Authority Law, also known as the Burns Amendment, gutted protections for wild horses and burros in captivity. It was passed without discussion on Thanksgiving eve as a rider to the 2005 Senate appropriations bill and allowed unconditional sale of horses and burros in long-term holding, as well as the sale of the animals or their remains for commercial products.
Efforts to repeal it have failed; however, Congress passed funding amendments to prohibit commercial sale or slaughter of wild horses and burros from 2005-2007 that eventually led to the closure of horse abattoirs in the U.S.
BLM announced plans in 2008 to euthanize a third of the animals in captivity, which was shouted down by the public. By 2009, horse abattoirs in the U.S. were a thing of the past but thrived across the northern and southern borders. A 2011 government report stated that U.S. horse exports for slaughter between 2006 and 2010 increased by 148% in Canada and 665% in Mexico.
Legislative amendments, agency requests and administrations have come and gone during the past tumultuous decade that included a government shutdown. Two Interior Department directors served during the first Trump administration. From 2017 through October 2021, five acting directors cycled through the BLM. National headquarters moved west to Grand Junction in 2019 only to return to Washington D.C. two years later under the Biden administration. Tracy Stone-Manning (who declined an interview for this story) was appointed BLM director during the Biden administration. The Wild Horse and Burro Program also fell prey to the chaos.
In early September 2016, the all-volunteer National Wild Horse Advisory Board recommended that “BLM follow the stipulations of the Wild Horse and Burro Act by offering all suitable animals in long- and short-term holding, deemed unadoptable, for sale without limitation or humane euthanasia.”
Ginger Kathrens was the sole dissenting vote.
The BLM stated that the annual federal appropriations bill does not fund the destruction of healthy, unadoptable wild horses and burros, and that the agency’s priority is to place the animals into private care. The BLM maintained that position the following year when the WHAB recommended phasing out long-term holding.
Another threat emerged when the House Appropriations Committee included the Stewart Amendment in the 2018 appropriations bill. Sponsored by Utah Rep. Chris Stewart, the amendment would have reversed Congressional euthanization prohibitions.
The amendment was praised by the Public Lands Council and the National Cattlemen’s Beef Association, representing cattle ranchers who have long been at odds with how the BLM manages wild horses. Advocates breathed a sigh of relief when the amendment went nowhere. And, the BLM beat went on.
The following year — despite reassuring the public two years prior that euthanization was off the table — the agency presented four new wild horse and burro management options in a report to Congress. The goal was to reduce spending as well as the amount of wild horses and burros on the range as fast as possible. The first option suggested using all legal methods at BLM’s disposal with a focus on sale without limitation and euthanasia of unadopted or unsold animals.
Despite the report’s emphasis on reducing spending, in 2020, Congress gave a $21 million raise to the Wild Horse and Burro Program, influenced by The Path Forward, another Chris Stewart proposal. This management proposal was a group effort backed by a coalition of rangeland management groups, the National Cattlemen’s Beef Association, the Public Lands Council, the American Farm Bureau, the Humane Society, ASPCA, Return to Freedom Wild Horse Conservation and others.
Its primary goal was to establish a sustainable, humane and non-lethal management strategy for wild horses and burros on BLM-managed public lands, outlining methods such as targeted roundups plus fertilization control for up to 90% of gathered mares.
Proponents lauded the initiative, especially for its consensus-building. Return to Freedom Wild Horse Conservation issued the following: “Congressional representatives, tired of the back-and-forth arguing of very divergent stakeholders and the contentiousness surrounding wild horse and burro management, demanded that we all do something different and that we find a way to do it across the aisle, as it were.”
Kitty Block, CEO and president of Humane World for Animals, and Sara Amundson, president of the Human Society Legislative Fund, wrote in a co-authored piece: “Although this proposal requires some interventions for horses that the humane community has fought in the past, the comprehensive plan, as a whole, is the best path forward to protect America’s horses from an ineffective status quo.”
But critics challenged that assertion. In fact, some called it “The Path Backward,” citing how it prioritized roundups and removals of up to 20,000 wild horses and burros annually for three years — and up to 10,000 per year for seven years after that.
Kathrens (of The Cloud Foundation) blasted the plan for its lack of accountability and science-based practices, as did Suzanne Roy, director of American Wild Horse Conservation. “The BLM will now use tens of millions of tax dollars to round up 20,000 horses a year,” she said in a statement.
Roy added that the proposal ignored requests from the late Arizona Congressman Raul Grijalva to fund fertility control measures instead of roundups to reduce the amount of wild horses and burros on the range. Even though the Path Forward recommends fertility control as a tool, it’s in conjunction with roundups for at least 10 years.
Scott Wilson, award-winning photographer and AWHC’s director of strategy and outreach, described the BLM’s approach as a vicious cycle that undermines successful management of wild horses and burros. “Every wild horse adopted or put into holding makes room for a horse to be rounded up,” he said.
Removals increased from 10,000 in 2020 to 13,000 in 2021 and finally hit the 20,000 mark in 2022. That dropped a bit last year, when 16,140 wild horses were removed, compared to 1,038 fertility-control doses administered.
Wild horses and burros in holding have increased by 16,000 since 2019.
A historically large roundup in Colorado in 2021 grabbed headlines and the attention of Gov. Jared Polis. BLM gathered 684 wild horses from the Sand Wash Basin Herd Management Area that September — about 70% of the herd that roams close to 158,000 acres in the arid high desert of the northwestern part of the state. The agency said it was an emergency due to drought and poor range conditions.
In August, prior to the roundup, Polis sent a letter to Interior Secretary Deb Halland and BLM Deputy Director Nada Culver, calling for a six-month moratorium on roundups in the state and more agency collaboration with the state and other stakeholders.
The Colorado Chapter of the Sierra Club released a statement against the roundup, citing BLM livestock data on three allotments inside the HMA. “None of these allotments are meeting BLM’s Land Health Standards,” wrote Delia Malone, Sierra Club Wildlife chair. “Two of the three are not meeting standards due, in BLM’s own words, to livestock use and one (Lang Spring) due to historic livestock use.”
Malone recommended that no wild horses be removed from the Sand Wash Basin until livestock are gone and the range restored enough to allow for a scientific determination of the wild horse appropriate management level. Meanwhile, she added, fertility control should be used to help reduce the herd’s population.
The Sand Wash Basin roundup proceeded — costing taxpayers $289,000 — but ended early with fewer horses removed and 49 returned to the range. BLM officials said it could be the last helicopter roundup in the state.
But much to the consternation of the Polis administration and local advocates, the roundups just kept on coming.