United States Government Accountability Office

GAO Report to the Chairman, Committee on 

Natural Resources, House of 

Representatives 

BUREAU OF LAND 

MANAGEMENT 

Effective Long-Term 

Options Needed to 

Manage Unadoptable 

Wild Horses 

October 2008 

 

GAO-09-77 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

October 2008

BUREAU OF LAND MANAGEMENT 

Effective Long-Term Options Needed to Manage 

Unadoptable Wild Horses

Highlights of GAO-09-77, a report to the 

Chairman, Committee on Natural 

Resources, House of Representatives 

The Department of the Interior’s 

Bureau of Land Management 

(BLM) manages about 33,100 wild 

horses and burros on 199 Herd

Management Areas (HMA) in

10 western states. Under the Wild

Free-Roaming Horses and Burros 

Act of 1971, as amended, BLM is to

protect wild horses and burros, set 

appropriate management levels

(AML), maintain current inventory 

counts, and remove excess animals 

to prevent overpopulation and

rangeland damage. Over the years,

various stakeholders have raised 

issues about BLM’s management of 

the animals on and off the range. 

GAO examined (1) BLM’s progress 

in setting and meeting AML; 

(2) BLM’s management of animals 

off the range through adoptions, 

sales, and holding facilities; 

(3) BLM’s controls to help ensure

the humane treatment of animals; 

and (4) what challenges, if any, 

BLM faces in managing for the 

long-term sustainability of the

program. GAO surveyed and 

analyzed documents from 26 of the

44 BLM offices that manage wild 

horses and burros. 

What GAO Recommends

To improve the program, GAO is 

recommending, among other 

things, that BLM establish a formal

policy for setting AML, develop 

alternatives for long-term holding

facilities, and initiate a discussion 

with Congress and other 

stakeholders on how best to 

comply with the act, as amended.

The Department of the Interior

concurred with GAO’s findings and 

recommendations. 

BLM has made significant progress toward setting and meeting AML (the 

optimum number of animals which results in a thriving natural ecological 

balance and avoids range deterioration). BLM has set AML for 197 out of 199 

HMAs. Most of the field offices GAO surveyed considered similar factors in 

determining AML, such as rangeland conditions; however, BLM has not 

provided specific formal guidance to the field offices on how to set AML. 

Without clear guidance, BLM cannot ensure that the factors considered in 

future AML revisions will be consistent across HMAs. At a national level, in 

2007, BLM was closer to meeting AML (about 27,200 animals) than in any 

other year since AMLs were first reported in 1984. The extent to which BLM 

has actually met AML depends on the accuracy of BLM’s population counts. 

Nineteen of the 26 field officials GAO surveyed used a counting method 

which, researchers say, consistently undercounts animals and does not 

provide a statistical range of population estimates. Undercounting can put 

animals at risk and lead to increased program costs.

The number of animals removed from the range is far greater than the number 

adopted or sold, which has resulted in the need for increased short-term and 

long-term holding. Since 2001, over 74,000 animals have been removed from 

the range, while only about 46,400 have been adopted or sold. Thirty-six 

percent fewer animals were adopted in 2007 than compared to the average 

adoption rates in the 1990s. As of June 2008, BLM was holding 30,088 animals 

in holding facilities, up from 9,807 in 2001. To accommodate the increased 

removals and declining adoptions and sales, BLM has increased the number of 

short-term and long-term holding facilities. 

BLM has implemented multiple controls to help ensure humane treatment, 

including random checks on adopted horses and agreements with adopters 

and buyers to prevent slaughter. Although BLM state offices collect data on 

the treatment of the animals, BLM does not always compile the information in 

its central database or report it to the public. Providing additional information 

to the public on the treatment of these animals could help inform the public 

about their treatment and improve transparency. 

The long-term sustainability of BLM’s Wild Horse and Burro Program depends 

on the resolution of two significant challenges: 

• If not controlled, off-the-range holding costs will continue to overwhelm 

the program. The percentage of the program’s direct costs for holding 

animals off the range increased from $7 million in 2000 (46 percent) to 

$21 million in 2007 (67 percent). In 2008, these costs could account for 

74 percent of the program’s budget. 

• BLM has limited options for dealing with unadoptable animals. The act 

provides that unadopted excess animals shall be humanely destroyed or, 

under certain circumstances, sold without limitation. However, BLM only 

manages these animals through sales with limitations. BLM is concerned 

about the possible reaction to the destruction of healthy animals. 

To view the full product, including the scope 

and methodology, click on GAO-09-77. 

For more information, contact Robin M. 

Nazzaro at (202) 512-3841 or 

nazzaror@gao.gov. 
Contents 

Letter 1

Results in Brief 7

Background 11

BLM Has Made Progress in Setting and Meeting AML, but Guidance 

Is Lacking and Meeting AML Has Proven Difficult 23 

Declining Adoptions and Sales Have Increased the Need for ShortTerm and Long-Term Holding Facilities, and Holding Costs Have 

Increased 40

BLM Has Controls in Place to Help Ensure the Humane Treatment 

of Wild Horses and Burros, but It Could Better Track and Report 

These Data to the Public 46 

Challenges to the Long-Term Sustainability of the Program Include 

Growing Holding Costs and Limited Options for Dealing with 

Unadoptable Animals 56 

Conclusions 61

Recommendations for Executive Action 63 

Agency Comments and Our Evaluation 64 

Appendix I Objectives, Scope, and Methodology 65 

Appendix II Fertility Control and Genetic Variability 69 

Fertility Control 69 

Genetic Variability 69 

Appendix III Wild Horse and Burro Survey Results 71 

Section I: Field Office Responses Specific to Selected HMAs 71 

Section II: Field Offices’ Responses to General Questions 

Regarding All of the HMAs They Manage 77 

Appendix IV Comments from the Department of the Interior 80 

Appendix V GAO Contact and Staff Acknowledgments 81 

Page i GAO-09-77 BLM’s Wild Horse and Burro Program 
Tables 

Table 1: Major Legislation Governing BLM’s Wild Horse and 

Burro Program 11 

Table 2: Summary Statistics on BLM’s Wild Horse and Burro 

Program, by State, February 2008 15 

Table 3: Years in Which Current AMLs Were Set for BLM’s 199 

HMAs 25

Table 4: Extent to Which BLM Field Office Staff Considered 

Each of the Four Key Factors in Making the Most 

Recent AML Determination for Surveyed Field Offices 26 

Table 5: Factors Considered by BLM Field Office Staff in Making 

the Most Recent AML Determinations for Surveyed 

Field Offices 27 

Table 6: Age of Data Used to Make Current AML Determinations 

for Surveyed Field Offices 30 

Table 7: Extent to Which BLM Field Office Staff Considered 

Each of the Five Key Factors in Making Their Most 

Recent Gather Determination 36 

Table 8: Factors Considered by Field Offices in Decisions to 

Gather Wild Horses and Burros from the Range 37 

Table 9: Age of Data Used by Field Offices to Determine the 

Need for Most Recent Gather 38 

Table 10: Number of Wild Horses and Burros Sold under the 

December 8, 2004, Sales Directive 43 

Table 11: Number of Wild Horses in Long-Term Holding, by Year, 

Since 2000 44 

Table 12: BLM Long-Term Holding Facilities, June 2008 45 

Table 13: Number and Percentage of Wild Horses and Burros 

That Died During Gather Operations, (for 6 of 10 

States) Fiscal Years 2005 through 2007 49 

Table 14: Results of Random Inspections of Wild Horse and 

Burro Adoptions, 2005 through 2007 54 

Table 15: BLM Field Offices and HMAs Included in GAO’s Survey 66 

Table 16: Number of HMAs Managed at Various AMLs, February 

2008 70

Table 17: Current and Initial AML and Year of Determination per 

HMA Surveyed 71 

Table 18: Level of Data Sufficiency Used to Determine Current 

AML 72

Table 19: Respondents’ Opinions about Current AML 73 

Table 20: Population Level in Comparison with AML Range 73 

Table 21: Primary Challenges in Meeting or Maintaining AML 73 

Page ii GAO-09-77 BLM’s Wild Horse and Burro Program 
Table 22: Impact on Rangeland Resources in HMA When Herd 

Populations Exceed the Upper Limit of AML by Less 

Than 25 Percent 74 

Table 23: Impact on Rangeland Resources in HMA When Herd 

Populations Exceed the Upper Limit of AML by 25 to 50 

Percent 74

Table 24: Impact on Rangeland Resources in HMA When Herd 

Populations Exceed the Upper Limit of AML by 51 to 

100 Percent 74 

Table 25: Number of Field Offices That Have or Do Not Have 

Procedures in Place to Distinguish Impact of Wild 

Horses and Burros, Cattle, and Wildlife on Rangeland 

Condition 75

Table 26: Actions Taken to Manage HMAs Since 2000 75 

Table 27: Number of HMAs with a Herd Management Area Plan 75 

Table 28: Primary Physical Method Used in Most Recent 

Census/Inventory 75

Table 29: Primary Statistical Method Used in Most Recent 

Census/Inventory 76

Table 30: Level of Accuracy of Most Recent Census/Inventory 76 

Table 31: Level of Data Sufficiency Used to Support Most Recent 

Gather 76

Table 32: Timing of Gather in Relation to Scheduled Date of

Gather 76

Table 33: Level of AML to Which HMA Is Typically Gathered 77 

Table 34: Actions Taken to Manage HMA’s Since 2000 77 

Table 35: Field Offices Whose HMAs Have Herd Management 

Area Plans 77 

Table 36: Field Offices Working to Develop Herd Management 

Area Plans for All of Their HMAs 77 

Table 37: Actions to Help Field Offices Achieve Healthy Herd

Populations in Balance with the Range and Other 

Multiple Uses 78 

Table 38: Major Challenges Facing Field Offices in Managing 

HMAs to Achieve Healthy Herd Populations That Are in 

Balance with the Range and Other Multiple Uses 78 

Table 39: Major Challenges Facing BLM’s Wild Horse and Burro 

Program As a Whole 79 

Page iii GAO-09-77 BLM’s Wild Horse and Burro Program 
Figures 

Figure 1: BLM Herd Areas and HMAs in the Western United 

States 14

Figure 2: Drought Conditions and HMAs, February 2008 18 

Figure 3: BLM Management of Wild Horses and Burros on and off 

of the Range 20 

Figure 4: BLM’s Wild Horse and Burro Program Funding, Fiscal 

Years 2000 through 2007 23 

Figure 5: Estimated Population of Wild Horses and Burros on the 

Range 32

Figure 6: Number of Field Offices Who Reported Negative 

Impacts When Populations Exceed the Upper Limit of 

AML 34

Figure 7: Comparison of Removed and Adopted Wild Horses and 

Burros, 1989 through 2007 42 

Figure 8: Helicopter Used to Gather Wild Horses Near Ely, 

Nevada, c. 2006 48 

Figure 9: BLM Contractor Trimming Horse Hooves Using a

Special Holding Chute at a Contract Short-Term 

Holding Facility in Fallon, Nevada, October 2007 51 

Figure 10: BLM Estimated Wild Horse and Burro Direct Program 

Costs, Fiscal Years 2000 through 2008 57 

Abbreviations 

AML appropriate management level 

BLM Bureau of Land Management 

HMA Herd Management Area 

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Page iv GAO-09-77 BLM’s Wild Horse and Burro Program 
United States Government Accountability Office

Washington, DC 20548 

October 9, 2008 

The Honorable Nick J. Rahall, II 

Chairman 

Committee on Natural Resources 

House of Representatives 

Dear Mr. Chairman: 

Wild horses have long been a symbol of the independence of the American 

West, but today, the health of their population depends heavily on 

government management. At their peak, in the mid-1800s, an estimated 

2 million wild horses roamed America’s rangelands. Populations decreased 

as development reduced habitat for wild horses and native grazers and as 

horses and burros were rounded up to make room for livestock and 

farming operations. By the early 1900s, most wild horses had disappeared 

from the Great Plains and those that remained were found primarily in the 

remote mountains, deserts, and badlands of the West. By 1971, only about

9,500 wild horses were thought to live on public rangelands. Public 

concerns about abuse and wild horse population declines swelled in the 

1950s and 1960s. Subsequently, Congress enacted the Wild Free-Roaming 

Horses and Burros Act of 1971 to protect wild horses and burros from 

abuse and death and to manage them to achieve and maintain a thriving 

natural ecological balance on the public lands.1

 The 1971 act declared 

these wild animals to be “living symbols of the historic and pioneer spirit 

of the West; that they contribute to the diversity of life forms within the 

Nation and enrich the lives of the American people; and that these horses 

and burros are fast disappearing from the American scene.” Since the

passage of the act, wild horse and burro populations have increased, but

the way they are managed on public lands has been controversial and wild 

horse advocates continue to voice concerns about horses being 

slaughtered.

The 1971 act authorized and directed the Secretary of the Interior, on 

public lands managed by the Bureau of Land Management (BLM), and the 

Secretary of Agriculture, on public lands managed by the Forest Service,

“to protect and manage wild free-roaming horses and burros as 

 1

Pub. L. No. 92-195, 85 Stat. 649 (1971) (codified as amended at 16 U.S.C. §§ 1331–1340). 

Page 1 GAO-09-77 BLM’s Wild Horse and Burro Program 
components of public lands.”2

 The act also directed the Secretaries to 

manage them “to achieve and maintain a thriving natural ecological 

balance on the public lands.” BLM field offices are responsible for 

determining where the animals are to be managed within areas where they 

were found as of 1971.3

 In fiscal year 2007, the program was funded at 

$36.4 million under BLM’s Management of Lands and Resources 

appropriation. Forty-four BLM field units manage approximately 

33,100 wild horses and burros on 199 Herd Management Areas (HMA) 

covering over 34 million acres in 10 western states—Arizona, California, 

Colorado, Idaho, Montana, New Mexico, Nevada, Oregon, Utah, and 

Wyoming.4

 BLM’s Nevada State Office manages about half of the land and 

animals in the Wild Horse and Burro Program. 

In the mid- to late 1970s, population counts indicated that there was a 

large increase in wild horses and burros and that they were contributing to 

overgrazing of the rangeland. Congress amended the 1971 act in 1978 to 

protect the range from wild horse overpopulation, among other things. 

The Public Rangelands Improvement Act of 1978 directed the Secretaries 

of the Interior and Agriculture to determine appropriate management 

levels (AML), maintain a current inventory of wild horses and burros, and 

determine whether and where overpopulation exists.5

 AML has been 

defined as the “optimum number of wild horses which results in a thriving 

natural ecological balance and avoids deterioration of the range.”6

 Each 

BLM field office is responsible for determining AML for each of the HMAs 

it manages. The aggregate AML for BLM’s 199 HMAs is approximately 

27,200. Because wild horse populations can double every 4 years and few 

 2

This report focuses solely on BLM’s Wild Horse and Burro Program. BLM is responsible 

for managing over 90 percent of the wild horses and burros on public lands. The Forest

Service is responsible for managing 2,200 wild horses and about 300 burros in 37 Wild 

Horse Territories that cover about 2.5 million acres of Forest Service land. 

3

Shortly after the 1971 act, BLM conducted a wild horse and burro population census and 

estimated the number of wild horses to be about 17,300 and the number of wild burros to

be about 8,000. 

4

The 44 BLM field units include 39 field offices, 4 district offices in Oregon, and 1 field 

station—the Tonopah Field Station in Nevada. We will refer to these 44 BLM field units 

collectively as field offices. BLM’s count of the number of offices that manage HMAs may 

differ because the 4 district offices in Oregon manage 7 resource area offices. 

5

Pub. L. No. 95-514, § 14, 92 Stat. 1803, 1808 (1978) (amending 16 U.S.C. §§ 1332–1333). 

6

Animal Protection Institute of America, 109 IBLA 112, 119 (1989) (internal quotes 

omitted). 

Page 2 GAO-09-77 BLM’s Wild Horse and Burro Program 
natural predators remain, managing wild horse and burro populations at 

AML has become a primary objective of the program. To reach and 

maintain AML, BLM primarily conducts “gathers” to remove excess 

animals from the range. From 1971 through 2007, over 267,000 wild horses 

and burros were removed.7

 In 2001, BLM began implementing its most 

recent management strategy, to reach AML by increasing removals. Since 

then, about 10,600 animals have been removed, on average, per year. 

Maintaining current and accurate inventories of wild horses and burros is 

a key component of on-the-range management. BLM has traditionally 

counted animals using the direct-count method, which involves flying over 

the HMA and reporting on each individual animal they see. BLM generally 

conducts this type of animal count or “census” every 4 years or so, leading 

up to a removal of excess animals. To produce annual population 

estimates between counts, BLM adjusts these census figures for each HMA 

based on an estimate of the herd’s annual population growth. If the census

numbers are inaccurate, particularly if they underestimate the actual 

population, BLM runs the risk that adequate forage or water may not be 

available for the wild horses and burros or for livestock and wildlife in the 

area. 

After being removed from the range, excess animals are managed in shortterm holding facilities, where they are either prepared for adoption or sale, 

or in long-term holding facilities, where they will live out the remainder of 

their lives. The preferred outcome for healthy animals removed from the 

range is that they be adopted through BLM’s Adopt-a-Horse-or-Burro 

Program. As of 2007, approximately 235,700 animals have been adopted by

the public since the start of the program in 1971. On average, about 

6,300 wild horses and burros have been adopted annually since 2001.

Under the act, as amended, BLM is required to assure that adopters can 

provide humane treatment and care.8

 When adoption demand is not 

sufficient to absorb all the animals removed, the act, as amended, directs 

BLM to either destroy the remaining healthy animals in the most humane 

and cost-efficient manner possible or, under certain circumstances, sell 

 7

This total does not include the number of burros removed from the range in 1981. BLM

was not able to verify older data or estimate the number of burro removals for 1981. The

total number of wild horses and burros that BLM could verify were removed from the range 

between 1971 and 2007 was 249,489. Officials verified that the number of animals removed 

between 1977 and 1980 was 18,009; however, they were unable to further specify this 

number by year or by species. When added together, this total equals 267,498. 

8

16 U.S.C. § 1333(b)(2)(B). 

Page 3 GAO-09-77 BLM’s Wild Horse and Burro Program 
them without limitation.9

 BLM has not destroyed any animals since 

January 1982, when a former BLM director issued a moratorium to end the 

destruction of excess unadoptable animals. To manage for the growing 

number of unadoptable animals, BLM began opening long-term holding 

facilities. Unlike the rangelands of the West where the animals normally 

live, the long-term holding facilities use Midwest grasslands that generally

provide the animals with abundant forage and decreased stress. This 

allows most of the animals to live far longer than they would in the wild. 

BLM pays the private contractors that operate the long-term holding 

facilities a fee per horse per day. The sales directive, which was enacted 

on December 8, 2004, directs BLM to sell excess wild horses and burros 

without limitation if the animal is more than 10 years of age or has been 

offered unsuccessfully for adoption at least three times.10

Since the passage of the 1971 act, there has been controversy over the 

number of wild horses and burros that BLM manages in the wild and the 

amount of public land available for their management. There is concern by

some, including wild horse and burro advocacy groups, that the number of 

animals managed in the wild is too low to protect their genetic integrity;

that the numbers are based on insufficient rangeland monitoring data; and 

that BLM gives preference to other users of the range, primarily livestock 

and wildlife. For instance, groups often point out that BLM permits far 

more cattle and sheep to graze on BLM managed lands than horses. 

Specifically, in fiscal year 2007, approximately 567,000 head of cattle or 

sheep grazed BLM public lands.11 However, livestock are managed on

160 million acres of BLM lands, compared to the 29 million BLM acres that 

 9

16 U.S.C. § 1333(b)(2)(C) (destroy excess animals for which an adoption demand does not 

exist) and 16 U.S.C. § 1333(e) (sell without limitation excess animals under certain

circumstances). 

10Pub. L. No. 108-447, Div. E, Title I, § 142, 118 Stat. 2809, 3070 (2004) (amending 16 U.S.C. 

§ 1333). In 2005, shortly after the 2004 sales directive was enacted, legislation was 

introduced in the 109th Congress that would have prohibited the sale of wild horses and

burros for processing into commercial products (H.R. 297 and S. 576). Neither of these bills

were enacted. More recently, in the 110th Congress, H.R. 249 was introduced to prohibit 

the sale of wild horses and burros for processing into commercial products. The bill was 

passed by the House of Representatives on April 26, 2007. As of August 31, 2008, the Senate

had not acted on the bill. 

11The number 567,000 represents the cattle yearlong equivalent derived by dividing the

actual number of animal unit months billed in fiscal year 2007 by 12 months. An animal unit 

month refers to the amount of forage needed to sustain an adult cow and her calf or horse 

for 1 month. In reality, few livestock grazing permits are issued for yearlong grazing. 

Page 4 GAO-09-77 BLM’s Wild Horse and Burro Program 
are available for wild horses and burros.12 Additionally, advocacy groups 

are concerned that the animals removed from the range are too often 

adopted into abusive homes or are ultimately sold for slaughter. Some 

livestock and wildlife groups argue that the population of wild horses and 

burros has far exceeded the level that provides ecological balance and 

equitable forage distribution for competing users, such as cattle and sage

grouse. 

We first reviewed BLM’s Wild Horse and Burro Program in 1990.13 At that 

time, regarding on-the-range management activities, we found that BLM’s 

decisions on how many wild horses to remove from federal rangelands 

were not based on direct evidence that wild horse populations exceeded

what the range could support and that removals were often not 

accompanied by reductions in livestock grazing levels or range 

management to increase the land’s capacity. We recommended that BLM 

develop carrying capacity and range condition data and, in locations 

where overgrazing was occurring, that BLM implement range management 

techniques designed to give vegetation more opportunity to grow and, 

when necessary, remove wild horses and reduce livestock grazing in 

proportion to the numbers of each species on the range. Regarding off-therange management activities, we found that “BLM’s wild horse sanctuaries 

[long-term holding facilities] are likely to be much more expensive than 

originally envisioned and may represent only a temporary solution to the 

disposal of unadoptable horses.... If horse removals above levels that can

be handled by private adoptions are reinstituted, other disposal options 

will have to be considered.” We recommended that BLM consider a variety

of disposal options for unadoptable horses and, as necessary, make 

recommendations for congressional consideration. 

To update our 1990 report, we are reporting on (1) BLM’s progress in 

managing wild horses and burros on the range through setting and meeting 

AML; (2) BLM’s management of wild horses and burros off of the range

through adoption, sales, and holding facilities; (3) the controls BLM has in 

place to help ensure humane treatment of wild horses and burros; and 

(4) what challenges, if any, BLM faces in managing the long-term 

sustainability of the Wild Horse and Burro Program. We were also asked to 

 12BLM manages wild horses and burros on 199 HMAs that are comprised of 29 million acres 

of BLM land and an additional 5.35 million acres of non-BLM land.

13GAO, Rangeland Management: Improvements Needed in Federal Wild Horse Program, 

GAO/RCED-90-110 (Washington, D.C.: Aug. 20, 1990). 

Page 5 GAO-09-77 BLM’s Wild Horse and Burro Program 
review how and why the acreage available for wild horses and burros had 

changed since the 1971 act. We did not examine the acreage issue because

BLM is in the process of compiling a history of acreage determinations. 

BLM officials expect their review to be completed by March 2009. 

To examine how BLM manages wild horses and burros on and off of the 

range and to identify the challenges facing BLM, we reviewed relevant 

laws, regulations, BLM policies, and strategic plans. We also surveyed, and 

analyzed documents from, 26 of the 44 BLM field offices that manage wild 

horses and burros.14 We collected and reviewed relevant resource

management decision documents from the surveyed field offices to help

corroborate their responses about specific questions, including those 

about factors used to make AML determinations and gather decisions. In 

addition, we also conducted follow-up phone calls to clarify ambiguous or 

incomplete survey responses. We received usable responses from all field 

offices that we surveyed—a 100 percent response rate. We surveyed field 

offices in all 10 western states that have HMAs. The field offices we 

surveyed represented 82 percent of all BLM acres managed for wild horses 

and burros, 74 percent of all BLM managed wild horses, and 69 percent of 

burros on the range at the time of our survey. We interviewed BLM Wild 

Horse and Burro Program managers at the state and national levels and 

conducted site visits at two field offices that manage HMAs, two adoption 

events, three short-term holding facilities, and one long-term holding 

facility. To examine humane treatment, we collected information from 

BLM’s compliance database and interviewed public citizens, advocacy 

groups, and BLM officials. A more detailed description of our scope and 

methodology is presented in appendix I. 

We conducted this performance audit from September 2007 to October 

2008 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

 14We drew our sample of 26 field units from among the 44 field units that manage HMAs, 

which include 39 field offices, 4 district offices in Oregon, and 1 field station in Nevada. 

BLM’s count of the number of offices that manage HMAs may differ because the 4 district 

offices in Oregon manage 7 resource area offices. 

Page 6 GAO-09-77 BLM’s Wild Horse and Burro Program 
BLM has made significant progress in setting and meeting AML for the 

HMAs. As of February 2008, BLM has set AML for 197 out of 199 HMAs. 

Most of the field offices we surveyed considered similar factors in 

determining AML, such as rangeland conditions and climate data; 

however, BLM has not provided specific formal guidance to the field 

offices on how to set AML. BLM has been working on revising the 

program’s handbook to provide this guidance since 2006. Without clear 

guidance, BLM cannot ensure that the factors considered in future AML 

revisions will be consistent across HMAs, especially since the personnel 

most familiar with the current, informal practice of determining AML are 

retiring at an increasing rate. At the national level, BLM was closer to 

meeting AML in 2007 than in any other year since AMLs were first reported 

in 1984. Specifically, in February 2007, BLM estimated the population of 

wild horses and burros to be 28,563, about 1,000 animals over AML. To 

reach this level, BLM has reduced the nationwide population in the wild by 

about 40 percent since 2000. Our 1990 report was critical of BLM’s 

decisions on the number of wild horses and burros to remove from the 

range. At that time we concluded that the decisions were made without 

adequate information about range carrying capacity or the impact of the 

animals on range conditions. Since then, in August 2005, BLM updated its 

formal policy on gathers and removals and specified the key factors that 

should be considered in the decision making process. The extent to which

BLM has actually met AML depends on the accuracy of its population 

counts. Nineteen of the 26 field officials we surveyed used the direct-count 

method for their most recent gathers. This method, according to 

researchers, consistently undercounts animals and does not provide a 

statistical range of population estimates. Some BLM officials are 

concerned that other counting methods would require too much additional 

staff or are too expensive. However, undercounting is also costly since it 

often leads BLM to remove fewer animals than needed, which leads to 

overpopulation and costlier gathers in the future. For example, in the 

summer of 2007, BLM staff on an HMA in Nevada miscalculated the 

population by approximately 640 wild horses and found that the actual 

population was about five times greater than what they determined was 

sustainable. Many of the wild horses subsequently removed from this HMA 

were in poor condition due to severe drought, and about 150 animals 

ultimately died from disease in short-term holding as a result.

Results in Brief 

The number of wild horses and burros removed from the range is far 

greater than the number adopted or sold, which has resulted in a 

significant increase in the number of animals in short- and long-term 

holding and commensurate increases in spending for their care. Since 

2001, over 74,000 animals have been removed from the range, while only 

Page 7 GAO-09-77 BLM’s Wild Horse and Burro Program 
about 46,400 have been adopted or sold. Thirty-six percent fewer wild 

horses and burros were adopted in 2007, compared to average adoption 

rates in the 1990s. BLM officials attribute the steady adoption decline in 

recent years to the decreasing demand for horses in general and increasing 

hay and fuel costs associated with their care. As of June 2008, BLM was 

holding 30,088 animals in short- and long-term holding facilities, far more 

than in 2001 when it held 9,807. From 2001 through June 2008, the number 

of short-term holding facilities increased from 14 to 24 to accommodate 

more animals, while the average cost per animal increased from $3.00 per 

day to $5.08 per day. The total cost for short-term holding increased from 

$6.4 million in 2000 to $11.2 million in 2001. From 2001 through 2007, the 

cost remained relatively stable, but for 2008, costs are anticipated to 

increase to $16.2 million. Similarly, BLM has increased the number of longterm holding facilities from 1 in 1988 to 11 as of June 2008, and the average 

cost per animal has increased to approximately $1.27 per day. Warnings 

issued in the 1990s by us and the Department of the Interior’s Office of 

Inspector General about the potential for escalating costs for long-term 

holding have proven accurate, as spending on long-term holding has 

increased from about $668,000 in 2000 to more than $9.1 million in 2007. In

addition, with the long-term holding facilities at full capacity—they held 

22,101 wild horses as of June 2008 and had a capacity of 22,100—more 

wild horses are spending a longer time in the more expensive short-term 

holding facilities. 

BLM has implemented multiple controls to help ensure the humane 

treatment of wild horses and burros, including standard operating 

procedures, random checks on adopted horses, and agreements with 

buyers to help prevent slaughter. For gathers, it has established standard 

operating procedures and reporting systems to help ensure humane 

treatment. According to data from 6 of the 10 states that manage wild 

horses and burros, 1.2 percent of animals removed from 2005 to 2007 were 

either euthanized or died accidentally. While BLM state offices sometimes 

collect data on animals that die during gathers, the information is not 

compiled by BLM headquarters in its centralized database, nor is it 

reported to the public. For animals held after removal in short- and longterm holding facilities, staff from BLM and veterinarians from the 

Department of Agriculture’s Animal and Plant Health Inspection Service

inspect facilities on a regular basis to help ensure adequate care and 

treatment are provided. For wild horses and burros that have been 

adopted, BLM guidance directs field offices to make follow-up phone calls 

or visits for all adopters during the first year of the adoption, physically 

inspect a random sample of adopted animals, and conduct inspections of 

adopted animals whenever complaints are received. According to the 

Page 8 GAO-09-77 BLM’s Wild Horse and Burro Program 
results of BLM’s random adoption inspections, from 2005 through 2007, on

average about 9 percent of adopters did not comply with BLM standards of 

care for adopted wild horses and burros. The most common violations 

were failing to report changes in the animals’ status or location to BLM 

and failing to provide adequate facilities or care. For animals that are sold, 

since the spring of 2005, BLM has required buyers to sign a statement that 

they do not intend to slaughter the animals. Although BLM tracks 

information about the treatment of animals in short- and long-term holding 

and after adoption, it does not regularly report this information to the 

public. Doing so could help inform the public about the treatment of the 

animals and improve transparency. 

The long-term sustainability of BLM’s Wild Horse and Burro Program 

depends on the resolution of two significant challenges: 

• If not controlled, off-the-range holding costs will continue to 

overwhelm the program. The Wild Horse and Burro Program’s 

spending for off-the-range holding increased from $7 million in 2000—

46 percent of the program’s direct costs—to about $21 million in 

2007—67 percent of the program’s direct costs. In 2008, BLM 

anticipates that holding costs will account for about 74 percent of the 

program’s direct costs. As holding costs continue to increase, less 

funding is available for on-the-range management, which could result in

sharp increases to the animal population in the wild. To deal with its 

long-term holding problem, BLM has primarily sought increased 

funding to open additional holding facilities. However, funding is not 

likely to increase in the future, and limited funding is forcing BLM to 

make the difficult choice among managing the animals on the range to 

prevent overpopulation, destroying excess unadoptable animals, or 

selling them without limitation. If funding is not increased or if BLM 

does not dispose of animals in other ways, BLM projects that the 

number of wild horses on the range would reach about 50,000, or about 

80 percent over AML, by 2012. 

• BLM’s options are limited for dealing with unadoptable animals. The 

Wild Free-Roaming Horses and Burros Act, as amended, requires that 

excess animals, for which the adoption demand is not sufficient to 

absorb all the animals removed from the range, be destroyed in the 

most humane and cost-efficient manner possible or, under certain 

circumstances, be sold without limitation. From fiscal year 1988 

through fiscal year 2004, Congress prohibited BLM from using its 

Management of Lands and Resources appropriations to destroy excess 

healthy, unadopted wild horses and burros, despite the amended act’s 

directive to destroy excess animals. However, since the enactment of 

Page 9 GAO-09-77 BLM’s Wild Horse and Burro Program 
the sales directive in 2004, which provided BLM with another means of 

disposal for these excess animals, Congress has appropriated funds to 

BLM without the prohibition. BLM has still chosen not to destroy or 

sell excess animals without limitation because of concerns about 

public and congressional reaction to the large-scale slaughter of 

thousands of healthy horses. However, by not destroying or selling 

them without limitation, BLM is not in compliance with the 

requirements of the act. Legislation is pending in the 110th Congress 

that would repeal the 2004 sales directive but not the requirement to 

destroy excess horses. As of June 2008, budget constraints have forced 

BLM to reconsider all of its options, including humane destruction and 

sales without limitations. BLM has not formally considered other 

possible solutions to deal with the current number of wild horses in 

long-term holding other than one pilot project in Wyoming. Some BLM 

officials suggested that other options are possible, such as placing 

nonreproducing animals on vacant BLM grazing allotments or on other 

federal lands, but these actions would require legislative changes. 

To improve the management of BLM’s Wild Horse and Burro Program, we 

are recommending that the Secretary of the Interior direct BLM to finalize 

and issue the new program handbook to ensure that AML determinations 

are based on consistent factors across HMAs into the future, improve the 

accuracy of population estimates by continuing to adopt statistically based 

methods to estimate animal populations, improve public access to data 

about the welfare of wild horses and burros removed from the range, and 

develop cost-effective alternatives to caring for wild horses removed from 

the range in long-term holding facilities. We are also recommending that

the Secretary of the Interior direct BLM to initiate discussions with 

Congress to address BLM’s noncompliance with the act. In commenting on 

a draft of this report, the Department of the Interior concurred with our 

findings and recommendations and provided several technical

clarifications, which we have made as appropriate. Appendix IV presents 

the Department of the Interior’s comment letter. 

Page 10 GAO-09-77 BLM’s Wild Horse and Burro Program 
During the 20th century, tens of thousands of wild horses were either 

killed or captured for slaughter on America’s western ranges. Documented 

abuses suffered by wild horses led concerned individuals and national 

humane organizations to push for federal protections in the 1950s. 

Subsequently, Congress passed legislation in 1959 prohibiting the use of 

aircraft or motor vehicles to capture or kill wild horses or burros on public 

lands and polluting watering holes on public lands to trap, kill, wound, or 

maim wild horses or burros. Despite the 1959 act, wild horse exploitation 

continued, and some questioned whether the population would eventually 

be eradicated. To protect wild horses and burros, Congress passed 

additional legislation in 1971 to require the protection and management of 

wild free-roaming horses and burros on public lands. The 1971 act was 

amended in 1976, 1978, 1996, and 2004 (see table 1). The 2004 amendments 

directed BLM to sell, without limitation, excess animals more than 

10 years of age or that have been offered unsuccessfully for adoption at 

least three times. 

Background 

Table 1: Major Legislation Governing BLM’s Wild Horse and Burro Program 

Legislation Date Major relevant provisions

Public Law 86-234 

(Wild Horse Annie Act of 1959)

a

Sept. 8, 1959 Establishes criminal penalties for using an aircraft or motor vehicle to hunt wild 

horses or burros on public lands for capturing or killing and for polluting watering 

holes on public lands to trap, kill, wound, or maim wild horse or burros. 

Public Law 92-195 

(Wild Free-Roaming Horses 

and Burros Act of 1971)b

Dec. 15, 1971 Authorizes and directs the Secretaries of the Interior and Agriculture to protect 

and manage wild horses and burros as components of the public lands to 

achieve and maintain a thriving natural ecological balance. Authorizes the 

Secretaries, in areas found to be overpopulated, to order old, sick, or lame 

animals destroyed in the most humane manner possible and to capture or 

remove wild horses and burros under humane conditions and care. Authorizes 

the Secretaries to order wild horses and burros destroyed in the most humane 

manner possible when such action is deemed necessary to preserve and 

maintain the habitat in a suitable condition for continued use. The act also

establishes criminal penalties for a number of offenses involving wild horses and 

burros. 

Federal Land Policy and 

Management Act of 1976c

Oct. 21, 1976 Directs the Secretary of the Interior to prepare and maintain an inventory of

public lands and their resources and other values and to, with public 

involvement, develop, maintain, and revise land use plans, which provide for the 

use of public lands. Directs the Secretary to manage the public lands under 

principles of multiple use and sustained yield. Authorizes the Secretaries of the 

Interior and Agriculture to contract for the use of helicopters and for using motor 

vehicles to transport captured animals after a public hearing and in accordance 

with humane procedures. 

Page 11 GAO-09-77 BLM’s Wild Horse and Burro Program 
Legislation Date Major relevant provisions

Public Rangelands Improvement 

Act of 1978d

Oct. 25, 1978 Directs the Secretaries of the Interior and Agriculture to maintain a current 

inventory of wild horses and burros on given areas of public lands to determine 

whether and where overpopulation exists and whether to remove excess 

animals, the appropriate management levels, and whether appropriate 

management levels could be achieved by removal or destruction of excess

animals or through other options. Directs the Secretaries, upon finding that an 

overpopulation exists and that action is necessary to remove excess wild horses 

and burros, to restore a thriving ecological balance by first destroying old, sick, 

and lame animals in the most humane manner possible; then humanely 

capturing and removing wild horses and burros for private maintenance and 

care for which an adoption demand exists by qualified individuals; and then

destroying additional excess wild horses and burros in the most humane and 

cost-efficient manner possible. Authorizes the Secretaries, upon application, to 

grant title to excess wild horses and burros for which an individual provided

humane conditions, treatment, and care for a period of 1 year. Provides that a 

wild horse or burro is no longer a wild horse and burro for purposes of the 1971 

act once title has passed to an individual or in a number of other circumstances. 

No wild horse and burro or its remains may be sold or transferred for 

consideration for processing into a commercial product. 

Omnibus Parks and Public Lands 

Management Act of 1996e

Nov. 12, 1996 Attempts to clarify the effect of the 1976 amendment, which authorized the 

Secretaries of the Interior and Agriculture to use helicopters and motor vehicles 

in the capture and transportation of animals.

Department of the Interior and

Related Agencies Appropriations 

Act, 2005f

Dec. 8, 2004 Directs the sale, without limitation, of excess wild horses and burros, or their 

remains, if the animals are more than 10 years of age or have been offered 

unsuccessfully for adoption at least three times, until all excess animals are sold 

or until appropriate management levels are attained. It also provides that wild 

horses and burros, or their remains, once sold, are no longer wild horses and 

burros for the purposes of the 1971 act. Exempts animals sold under these 

provisions from the general prohibition under the 1971 act of processing the 

remains of wild horses and burros into commercial products. 

Source: GAO analysis of laws pertinent to BLM’s management of the Wild Horse and Burro Program. 

a

Pub. L. No. 86-234, 73 Stat. 470 (1959) (codified as amended at 18 U.S.C. § 47). 

b

Pub. L. No. 92-195, 85 Stat. 649 (1971) (codified as amended at 16 U.S.C. §§ 1331–1340). 

c

Pub. L. No. 94-579, 90 Stat. 2743 (1976). Specifically, section 404 (90 Stat. 2775) amended the 

1971 act (codified as amended at 16 U.S.C. § 1338a). 

d

Pub. L. No. 95-514, § 14, 92 Stat. 1803, 1808 (1978) (amending 16 U.S.C. §§ 1332–1333). 

e

Pub. L. No. 104-333, Title VIII, § 803, 110 Stat. 4093, 4186 (1996) (amending 16 U.S.C. § 1338a). 

f

Pub. L. No. 108-447, Div. E, Title I, § 142, 118 Stat. 3039, 3070 (2004) (amending 16 U.S.C. § 1333). 

The passage of the 1971 act changed the way BLM managed wild horses 

and burros on public lands. Rather than considering them as feral species

that caused damage to the rangeland, the agencies had to change their 

mind-set to protect and manage the animals as an integral part of the 

ecosystem. One of the first tasks in managing the animals was to 

determine where they lived and their populations. According to the act, 

BLM is only authorized to manage wild horses and burros in areas where 

Page 12 GAO-09-77 BLM’s Wild Horse and Burro Program 
they were found in 1971.15 The areas where wild horses and burros were 

found, largely on public lands managed by the BLM and the Forest Service, 

as of the date of the act are called herd areas, and they comprise about 

53.5 million acres. Once the exact land status and ownership of the herd 

areas was verified, it was determined that most herd areas were on BLM 

administered public lands, but some also included private and state-owned 

in-holdings. The 1971 act states that the Secretaries of the Interior and 

Agriculture shall arrange for the removal of wild horses and burros that 

stray onto private land upon notification by the owner.16

Next, through its land management planning process, BLM designated 

HMAs within these herd areas. In making HMA designations, BLM 

determined whether or not the areas where wild horses and burros were 

found contained adequate forage and water to sustain the herds. BLM also 

designated some HMAs in such a way as to avoid conflicts with private 

landowners. Today, BLM is responsible for managing 199 HMAs covering 

34.3 million acres across 10 western states (see fig. 1).17 BLM is currently 

compiling a history of how BLM field offices made the determination to 

manage wild horses and burros on the current 34.3 million acres, 

compared to the 53.5 million acres where they were originally found in 

1971. According to BLM officials, they expect the review to be completed 

by March 2009. 

 15Pub. L. No. 92-196, § 9, 85 Stat. 649, 651 (renumbered as § 10 of the act and codified at 

16 U.S.C. § 1339). 

16Pub. L. No. 92-196, § 4, 85 Stat. 649, 651 (codified at 16 U.S.C. § 1334). 

17Three of the 199 HMAs are classified as Wild Horse Ranges—the Pryor Mountains Wild

Horse Range in Montana, the Little Book Cliffs Wild Horse Range in Colorado, and the

Nevada Wild Horse Range of south-central Nevada. One of the HMAs is classified as a Wild 

Burro Range—the Marietta Wild Burro Range located in Nevada. According to the 1971 act,

under certain circumstances, the Secretaries of the Interior and Agriculture may designate 

and maintain specific ranges on public lands as sanctuaries for the protection and

preservation of wild free-roaming horses and burros. 16 U.S.C. § 1333(a). Ranges are to be

devoted principally, but not necessarily exclusively, to their welfare in keeping with the 

multiple-use management concept for the public lands. 16 U.S.C. § 1332(c). BLM can also 

choose to close appropriate areas of public lands to grazing use by all or a particular kind

of livestock, if necessary, to provide habitat for wild horses or burros; to implement herd

management actions; or to protect wild horses or burros from disease, harassment, or 

injury. 43 C.F.R. § 4710.5. 

Page 13 GAO-09-77 BLM’s Wild Horse and Burro Program 
Figure 1: BLM Herd Areas and HMAs in the Western United States 

UTAH

CALIFORNIA

ARIZONA

IDAHO

MONTANA

OREGON

WYOMING

NEW MEXICO

COLORADO

WASHINGTON

TEXAS

NEVADA

Herd Management Area (HMA)

Herd Area

Source: BLM.

The number of HMAs and their acreage has changed over time for many 

different reasons, including BLM land being redesignated as National Park 

land and declines in forage or water that make an area unsustainable,

Page 14 GAO-09-77 BLM’s Wild Horse and Burro Program 
among others. About half the acreage managed under BLM’s Wild Horse 

and Burro Program is located in Nevada (see table 2). While most of BLM’s 

management activities for wild horses and burros occur within HMAs, 

BLM is responsible for removing populations of animals that stray onto 

public lands outside of HMAs, as well as those that stray onto private 

property. 

Table 2: Summary Statistics on BLM’s Wild Horse and Burro Program, by State, February 2008 

HMA acreage

State Number of HMAs Total AMLaPopulation estimate BLM acreage Other acreage Total acreage

Nevada 102 13,098 16,143 15,772,485 1,695,925 17,468,410

Wyoming 16 3,725 3,439 3,638,330 1,137,121 4,775,451

Arizona 7 1,676 2,173 1,756,086 1,327,777 3,083,863

Oregon 18 2,715 2,473 2,703,409 259,726 2,963,135

Utah 21 2,151 3,096 2,379,850 362,817 2,742,667

California 22 2,237 3,878 1,946,590 471,855 2,418,445

Idaho 6 617 703 377,907 40,287 418,194

Colorado 4 812 933 366,098 38,656 404,754

Montana 1 105 170 28,282 8,865 37,147

New Mexico 2 83 97 24,505 4,107 28,612

Total 199 27,219 33,105 28,993,542 5,347,136 34,340,678

Source: BLM.

a

This column represents the upper limit of AML according to BLM data. 

Wild horses and burros are to be managed as self-sustaining populations of

healthy animals in balance with other multiple uses and the productive 

capacity of their habitat. Because wild horses and burros reproduce at an 

estimated rate of 20 percent annually and no natural predators remain, 

except for in a very few isolated HMAs, BLM must actively manage the 

population of the herds. AML has been defined as the “optimum number of 

wild horses which results in a thriving natural ecological balance and

avoids deterioration of the range.”18 AML determinations can be made in a 

variety of land planning or decision documents, including, but not limited 

to, resource management plans, Herd Management Area Plans, and 

multiple use decision documents. The actual number set through an AML 

determination is predicated, in part, on (1) the number of acres set-aside 

 18Animal Protection Institute of America, 109 IBLA at 119 (internal quotes omitted). 

Page 15 GAO-09-77 BLM’s Wild Horse and Burro Program 
for the management of wild horses and burros within a specific resource 

planning area and (2) the proportion allocation of the available forage 

allotted for wild horse and burro consumption among other users, such as 

livestock and wildlife. After these two key multiple use decisions have 

been made, BLM field offices can then set the actual AML numbers. 

Available forage is based on range conditions and other data.

BLM’s Wild Horse and Burro National Program Office encourages field 

offices to establish AML as a range with an upper and lower limit.19 The 

upper limit of the range equals the maximum number of animals that can 

be sustained to result in a thriving natural ecological balance and avoid

deterioration of the range. The lower limit is generally determined as the 

number to which a population must be gathered to help ensure the 

population will not exceed the upper limit of AML within the established 

gather cycle. For example, if the established gather cycle was 4 years, it 

would be the number to which a population must be gathered to help 

ensure the population will not exceed the upper limit of AML within a 4 

year time period. BLM strives to maintain a national herd population level

that is at the midpoint of AML, where the recently gathered HMAs would 

be at the lower limit of AML, while those awaiting gathers would be closer 

to the upper limit of AML. As of February 2008, the upper limit of AML (the 

cumulative total for each of the 199 HMAs) was approximately 27,219, and 

the midpoint was about 22,588.20

Because AMLs are intended to reflect the population of animals that can 

be sustainably maintained in an HMA, they are subject to change over 

time. Changes in AML happen for several reasons, including when acreage 

is added to or subtracted from an HMA and when changes in rangeland

conditions result in improved or reduced forage and water availability 

sufficient to sustain a certain population level. In the arid ranges where 

most wild horses and burros are managed, conditions generally do not 

 19Some HMAs report AML as a single number rather than as a range; however, they also

calculate an upper and lower limit of AML to determine the level within which to manage

herds. BLM is drafting guidance to direct all field offices to identify AML as a range.

20According to BLM officials, as of February 2008, the upper limit of AML nationally was

approximately 27,219 animals, and the lower limit of AML was approximately 17,957. Based 

on our calculation, the midpoint between the two limits is approximately 22,588. These 

numbers are considered approximate because not all HMAs report AML as a range. AML 

for 7 HMAs are reported as the midpoint of AML, while 29 HMAs report AML as the upper

limit. Therefore, to account for the 36 HMAs that report a single AML number, BLM may

only approximate the true upper, lower, and midpoint of AML on a nationwide basis. 

Page 16 GAO-09-77 BLM’s Wild Horse and Burro Program 
improve rapidly and have been further degraded by drought conditions 

that have lasted for over a decade (see fig. 2). The effects of climate 

change are likely to exacerbate the poor conditions that many HMAs are 

already experiencing. 

Page 17 GAO-09-77 BLM’s Wild Horse and Burro Program 
Figure 2: Drought Conditions and HMAs, February 2008 

Utah

Arizona

Nevada

California

Oregon Idaho

Montana

Wyoming

New Mexico

Colorado

Washington

Source: BLM.

Herd Management Area (HMA)

Abnormally dry

Drought moderate

Drought severe

State boundary

Determining which type of animal is responsible for rangeland damage is 

important to properly managing an HMA and in determining the number of 

animals to permit on the range. BLM can control the number of livestock 

Page 18 GAO-09-77 BLM’s Wild Horse and Burro Program 
and wild horses and burros to permit on the range, but BLM is not 

responsible for managing wildlife numbers on the range. Because BLM is 

not the lead agency responsible for wildlife on public lands, they are to

coordinate with state wildlife officials about the forage allocation for 

wildlife populations. An increase in allocation of any species may cause 

increased competition for the remaining users of the range, especially

under severe conditions. For example, in severe drought conditions, 

grazing and browsing is concentrated in limited areas near water sources. 

This intense competition causes heavy use and perhaps depletion of the 

resources the animals are dependent upon. 

Throughout the life of the program, the population of wild horses and 

burros on the range has generally far exceeded AML. BLM has used the 

removal of animals from the range as a primary management tool for 

managing herd sizes. To gather animals for removal, BLM uses private 

contractors to herd the animals in an HMA into temporary on-site corrals.21

The animals are primarily gathered using helicopters. In some cases, when

gathering smaller numbers of wild horses and burros, BLM officials or 

contractors will use other trapping techniques, such as bait trapping, to 

capture the animals. Once collected into the temporary corrals, BLM 

officials use a selective removal process to determine which of those 

gathered animals to remove from the HMA.22 Animals that are not selected 

are returned to the wild. When animals are removed from the range, they

are taken to short-term holding facilities to receive vaccinations and other

treatment prior to either being adopted, sold, or sent to long-term holding. 

Figure 3 depicts BLM’s management of wild horses and burros on and off 

of the range.

 21BLM has gather contracts with two private companies. 

22The selective removal policy is used only for wild horses; it is not applicable to wild 

burros. When gathers are conducted, an emphasis is placed on removing the younger, more

adoptable animals from the range. However, the sex ratio and age structure of the herd

must also be considered to assure a healthy population.

Page 19 GAO-09-77 BLM’s Wild Horse and Burro Program 
Figure 3: BLM Management of Wild Horses and Burros on and off of the Range

1. On-the-Range Management

2. Short-Term Holding

On-the-range management of wild horses and burros

includes management activities such as range condition 

monitoring, population counts, and rangeland improvements. As of February 2008, the estimated on the range 

population was 33,105. 

Animals are periodically removed from HMAs to reach a

level that is sustainable with other uses of the range. BLM 

typically uses helicopters to herd animals into temporary 

corrals. In 2007, BLM removed 7,726 animals from the 

range.

Once animals are removed from the range, they enter short-term holding facilities

where they receive veterinary care prior to being adopted, sold, or sent to long-term 

holding facilities. As of June 2008, the number of animals in short-term holding was

7,987.

Page 20 GAO-09-77 BLM’s Wild Horse and Burro Program 
4. Long-Term Holding

33. Adoption and SSaless

BLM offers animals removed from the range for adoption to private 

citizens. In 2007, 4,772 wild horses and burros were adopted.

Wild horses can be sold if they are offered unsuccessfully for 

adoption at least three times or are more than 10 years of age. 

Wild horses and burros that are adopted or sold are used by some as

companions and by others as working animals.

Animals that are removed from the range and cannot be adopted or sold are placed in 

long-term holding facilities to live out the rest of their lives. Most of the facilities are 

located on Midwest grasslands in Kansas and Oklahoma. As of June 2008, the number 

of horses in long-term holding was 22,101.

Sources: GAO (photos, photo illustration), BLM (photos). 

Page 21 GAO-09-77 BLM’s Wild Horse and Burro Program 
For fiscal year 2001, BLM requested a budget increase for the program as 

part of a major initiative to reach the upper limit of AML by 2005.23

Subsequently, program funding allocated from congressional 

appropriations—what the agency refers to as “enacted funding”—

increased from $19.8 million in fiscal year 2000 to $34.4 million in fiscal 

year 2001, an increase of $14.6 million. In 2002, enacted funding for the 

program was $29.6 million, about $10 million over the 2000 congressional 

funding level. After reassessing the initiative in 2004, BLM estimated it 

needed an additional $10.5 million on top of their enacted funding level of 

$29.1 million in fiscal year 2004 to meet its revised goal of meeting the 

midpoint of AML by 2006. In fiscal year 2005, enacted funding was 

increased about $10 million for a total of $39 million in fiscal year 2005 

(see fig. 4). The President’s 2008 budget requested $32 million for the 

program, about $4 million less than enacted funding for fiscal year 2007. 

 23U.S. Department of the Interior, BLM, Living Legends in Balance with the Land, A 

Strategy to Achieve Healthy Lands and Viable Herds, The Restoration of Threatened

Watersheds Initiative (Washington, D.C., 2000). 

Page 22 GAO-09-77 BLM’s Wild Horse and Burro Program 
Figure 4: BLM’s Wild Horse and Burro Program Funding, Fiscal Years 2000 through 

2007 

Dollars in millions

Source: BLM.

0

5

10

15

20

25

30

35

40

45

Total program funding

Enacted funding

2000 2001 2002 2003 2004 2005 2006 2007

Fiscal year

Note: The enacted funding level, as reported by BLM, is the amount allocated from congressional 

appropriations minus rescissions for the Wild Horse and Burro Program. Total program funding 

represents the sum of the enacted funding; reprogrammed funding; and funding from other sources,

such as reimbursement for BLM’s management of parts of the Forest Service’s Wild Horse and Burro 

Program. 

BLM has made significant progress in setting and meeting AML for the 

HMAs. As of February 2008, BLM has set AML for 197 out of 199 HMAs. 

Most of the field offices we surveyed considered similar factors in 

determining AML, such as rangeland conditions and climate data; 

however, BLM has not provided specific formal guidance to the field 

offices on how to set AML. BLM has been working on revising the 

program’s handbook to provide such guidance since 2006. With increased 

retirements, field offices reported losing the experienced personnel most 

familiar with the informal practice of determining AML. Until BLM 

finalizes the handbook or issues other guidance, it cannot ensure that the 

factors considered in future revisions of AML determinations are 

consistent across HMAs. At the national level, BLM reported that it was 

closer to meeting AML in 2007 than in any other year since AMLs were 

documented in 1984. Specifically, as of February 2007, BLM estimated the 

BLM Has Made 

Progress in Setting 

and Meeting AML, but 

Guidance Is Lacking 

and Meeting AML Has 

Proven Difficult 

Page 23 GAO-09-77 BLM’s Wild Horse and Burro Program 
population at 28,563, which was about 1,000 animals over AML. To reach

this level, BLM has reduced the nationwide population in the wild by about 

40 percent since 2000. However, the population estimates are higher for 

2008, and BLM has not met its goal of meeting AML for each HMA. The 

fact that not all HMAs have met AML remains a concern because of the 

damage excessive populations can cause on the range. Twenty of 26 field

officials we surveyed told us that conducting gathers to remove excess 

animals is among their top challenges to maintaining AML because 

delayed gathers can cause animal populations to quickly exceed AML. In 

our 1990 report we concluded that BLM’s decisions on the number of wild 

horses and burros to remove were made without adequate information 

about range carrying capacity or the impact of the animals on range 

conditions. In August 2005, BLM updated its formal policy on gathers and 

removals and specified the key factors that should be considered in the 

decision making process. The extent to which BLM has actually met AML 

depends on the accuracy of BLM’s wild horse and burro population 

counts. Nineteen of the 26 field officials we surveyed used a method that 

consistently undercounts animals and does not provide a statistical range 

of population estimates. Alternative counting methods may be more 

expensive, but undercounting a population can lead to overpopulation and

costlier gathers in future years. 

BLM Has Set AML for 197 

out of 199 HMAs, but No 

Formal Guidance Exists on 

How to Establish AML 

BLM has made significant progress in setting AML using rangeland 

monitoring data for the HMAs. As of February 2008, BLM has set AML for 

197 out of 199 HMAs, compared to 2002 when about two-thirds of HMAs 

had set AML.24 Prior to 1984, many of the initial AMLs were not based on 

rangeland data but on factors such as initial herd population counts or 

administrative convenience. For example, the original AML established for 

Beaty’s Butte HMA in Oregon in 1977 was based on the number of horses 

found in that area on December 15, 1971. In Wyoming, AMLs for about 

one-third of the HMAs were based on agreements with local grazing 

interests because they owned private lands that were interspersed with 

BLM lands where wild horses were found in 1971. Only 10 out of the 

26 field offices we surveyed identified the use of rangeland data to 

determine their initial AMLs. But since 1984, in accordance with the Dahl 

v. Clark decision, BLM officials told us that field managers have generally

 24The number of HMAs managed by BLM has changed over time. In 2002, BLM managed 208

HMAs, 142 of which had set AML, or 68 percent. 

Page 24 GAO-09-77 BLM’s Wild Horse and Burro Program 
based AML decisions on monitoring data and an in-depth analysis.25 Most 

of the current AMLs for the 199 HMAs were set after 1984 (see table 3). 

Although some current AMLs were set many years ago, they are generally

reviewed every 4 years or so as part of the recurring process to gather and

remove excess animals. If during this process, and through monitoring, it 

is determined that an AML is no longer appropriate, field offices will 

consider changing it. For example, table 17 in appendix III shows how the

current AMLs for the 26 HMAs in our sample have been changed, as 

applicable, since they were initially set. 

Table 3: Years in Which Current AMLs Were Set for BLM’s 199 HMAs

Years in which current AMLs were set Number of HMAs

1975–1979a2

1980–1984 13

1985–1989 13

1990–1994 45

1995–1999 32

2000–2004 68

2005–2008 24

Not yet set 2

Total 199

Source: GAO analysis of BLM data. 

Note: Although an AML may have been set years ago, they are generally reviewed every 4 years or

so as part of the reoccurring process to gather and remove excess animals. 

a

AML determinations were first required by the Public Rangelands Improvement Act of 1978. 

Most of the field offices we surveyed considered similar factors in 

determining AML.26 According to BLM National Program Office officials, 

field office staff should consider at least four factors in making AML 

determinations—climatic data, utilization data, actual use data, and trend 

data. Climate data measures the amount of precipitation within a specific 

area. In addition, temperature and wind data may be collected to evaluate 

 25Dahl v. Clark, 600 F. Supp. 585 (Dist. Ct. Nev. 1984). 

26For this report we reviewed BLM’s process for making AML determinations and the 

factors it considers during that process. We are not expressing a legal opinion as to

whether any individual AML established through this process would achieve and maintain a 

“thriving natural ecological balance,” as required by the act. 16 U.S.C. § 1333(a), (b)(2); see 

also, Animal Protection Institute of America, 109 IBLA 112, 115. 

Page 25 GAO-09-77 BLM’s Wild Horse and Burro Program 
the effect of climate on vegetation; utilization data measures the percent of

forage consumed by livestock, wild horses and burros, wildlife, and 

insects during a specified period; actual use data is the number of grazing 

animals that used an area within a certain amount of time; and trend data 

measures the direction of change in ecological status or resource rating 

observed over time. Our survey results indicate that these four key AML 

determination factors were considered by some, but not all, of the BLM 

field offices responsible for setting AML for our sample of 26 HMAs (see 

table 4). 

Table 4: Extent to Which BLM Field Office Staff Considered Each of the Four Key

Factors in Making the Most Recent AML Determination for Surveyed Field Offices 

Number of the four key factors considered Number of BLM field offices

4 16

3 6

2 2

1 1

0 1

Total 26

Source: GAO survey results. 

Almost all of the field offices considered trend (25) and utilization (23) 

data, but only 19 considered climate and actual use data for livestock, 

while 14 considered actual use data for wildlife (see table 5). 

Page 26 GAO-09-77 BLM’s Wild Horse and Burro Program 
Table 5: Factors Considered by BLM Field Office Staff in Making the Most Recent 

AML Determinations for Surveyed Field Offices 

 Factor Considered

Not 

considered

Don’t 

know 

Not 

applicable Blank

Factors BLM officials told us should be considered

Trend 25 1 0 0 0

Utilization 23 2 1 0 0

Climate data 19 3 4 0 0

Actual use: livestock 19 2 2 3 0

Actual use: wildlife 14 5 6 1 0

Other factors considered

Carrying capacity 23 1 2 0 0

Census/inventory 22 2 2 0 0

Water resources 21 3 2 0 0

Stakeholder influence 20 2 4 0 0

Production 19 2 5 0 0

Herd health 19 4 3 0 0

Genetic viability 16 6 3 1 0

Recreational use 14 6 3 3 0

Cultural resources 12 6 5 2 1

Archeological resources 12 6 5 2 1

Livestock agreements 11 4 7 4 0

Human safety issues 8 8 2 8 0

Community expansion 4 8 2 12 0

Court order 2 5 2 17 0

Mineral extraction 3 10 2 11 0

Other factors 7 1 0 1 17

Source: GAO survey results. 

In addition to the four factors mentioned by BLM National Program Office 

officials, field offices considered other factors to help make their AML 

determinations, including census inventory, water resource availability, 

herd health, and unique local conditions. For instance, in Arizona, one 

field office reduced the AML for burros on an HMA because they found 

Page 27 GAO-09-77 BLM’s Wild Horse and Burro Program 
that burros were foraging on the same willows critical to the survival of 

the endangered Southwestern Willow Flycatcher.27

In determining AML, field office staff must also consider rangeland 

conditions for wild horses and burros in conjunction with other users of 

the range, including livestock and wildlife. Determining which species is 

responsible for rangeland damage is an important task to properly 

managing the HMA and in determining the number of wild horses and 

burros to permit on the range. For example, if field staff determine that 

cattle are primarily responsible for damaging an area, they may pursue 

several management options, including fencing out cattle, reducing the

number of cattle, or changing the time of year cattle are allowed to graze 

in a particular area. BLM lacks similar management techniques to control 

wild horse and burro use due to their free-roaming nature. BLM’s direct 

management actions are limited to dealing with livestock and wild horses 

and burros, since individual states are responsible for managing wildlife. 

We recognized the difficulty in distinguishing the difference between 

impacts that wild horses and burros have on the range versus other users 

in our 1990 report.28 Some advocacy groups have criticized BLM because 

they believe that BLM unfairly faults wild horse and burros for damage to 

the range to justify their removal and reductions in AML. Several BLM 

officials told us ascribing range impacts can be difficult, but 20 out of the 

26 field offices that we surveyed said they had a procedure in place do so. 

When the damage is caused by all the user groups or when the damage can 

not be attributed to a specific user group, BLM will generally make acrossthe-board reductions in the number of animals allowed on the range based

on the historic proportion of each user group on the range. For example, if 

wild horses and burros historically accounted for 10 percent of the forage 

consumption on the range, then wild horses and burros would bear 

10 percent of the necessary reductions. 

BLM has also made steady reductions in cattle grazing on BLM land as 

drought conditions in much of the West have worsened, resulting in the 

reduction of forage and water availability. For example, in Nevada, the 

 27Under Section 7 of the Endangered Species Act, all federal agencies must ensure that any

actions they authorize, fund, or carry out are not likely to jeopardize the continued 

existence of a listed species or result in the destruction or adverse modification of its

designated critical habitat. 

28GAO/RCED-90-110. 

Page 28 GAO-09-77 BLM’s Wild Horse and Burro Program 
state that manages for the greatest number of wild horses, permitted 

livestock use was reduced from about 2.5 million animal unit months in 

1990 to a little over 2 million in 2006.29 The actual use during this same 

period, however, decreased from 1.8 million animal unit months to 

1.2 million. 

In addition to the factors considered in making AML determinations, the 

age of the data, or how current it is, can also be important. The meaning of 

“current” data collection depends on the ecosystem and may vary across 

HMAs. BLM national program officials explained that data used to support 

AML decisions should be collected on a frequent basis. In general, they 

told us climate, utilization, and actual use data should be collected 

annually and trend data should be analyzed and reviewed within 4 years of 

setting AML. However, of the respondents who provided the age for data

used, fewer than half collected their data for actual use for livestock and 

wildlife within 1 year of their AML determination; half collected their data

for utilization within 1 year of the determination; and more than half 

collected their data for climate within 1 year of the determination. Fifteen

of the 19 respondents who provided the age for data used considered 

trend data within 4 years of the determination (see table 6). 

 29An animal unit month refers to the amount of forage needed to sustain an adult cow and 

her calf or horse for 1 month.

Page 29 GAO-09-77 BLM’s Wild Horse and Burro Program 
Table 6: Age of Data Used to Make Current AML Determinations for Surveyed Field

Offices 

Age of the data 

Factor 1 year 2 years 3 years 4 years 5-10 years

11 years 

or older

Factors BLM officials told us should be considered

Trend 8 3 1 3 4 0

Utilization 9 2 1 3 3 0

Climate data 9 2 0 2 2 0

Actual use: livestock 6 3 0 2 3 0

Actual use: wildlife 5 1 0 2 2 1

Other factors considered

Carrying capacity 7 3 0 2 5 1

Census inventory 13 1 1 2 1 0

Water inventory 11 2 0 2 1 0

Production 6 1 0 2 3 2

Herd health 11 1 0 3 1 0

Genetic viability 8 0 0 3 1 0

Source: GAO survey results. 

Note: Some field offices that considered the factors listed in this table did not provide a year in which 

the data was collected. 

Although field offices use many factors to make their AML determinations, 

BLM has no guidance or policy about the specific factors they must 

consider in determining AML. This is in contrast to the BLM policy that 

exists for a similar type of analysis that is conducted for removals. 

According to BLM’s 2005 gather policy, the determination to remove 

animals must be supported by the following factors: climatic data, 

utilization data, actual use data, trend data, and current census data.30

While 22 out of 26 BLM field offices responded that the data used to make 

their AML determination were moderate to very sufficient, several BLM 

officials told us that with increased retirements, field offices are losing the

experienced personnel most familiar with the informal practice of 

determining AML. Therefore, without clear guidance, BLM cannot ensure 

 30U.S. Department of the Interior, BLM, Gather Policy and Selective Removal Criteria, 

Instruction Memorandum No. 2005-206 (Washington, D.C., Aug. 10, 2005). Although the

instruction memorandum had an expiration date of September 30, 2006, according to BLM

officials, it is still considered to be in effect until it is reissued. 

Page 30 GAO-09-77 BLM’s Wild Horse and Burro Program 
that the factors considered in future revisions of AML determinations will 

be consistent across HMAs. To make the informal AML determination 

process official and to help ensure consistency among BLM field offices, 

BLM officials have been working on drafting a new handbook for the 

program since 2006, which specifies the factors field offices should use in

making AML determinations.31 Due to higher priorities and limited 

resources, the handbook is still in draft form and is undergoing final 

revision. BLM officials told us they expect the handbook to be completed

in fall 2008. 

BLM Has Made Significant 

Progress toward Meeting 

AML, but Some HMAs 

Remain Far over AML 

Since 2000, BLM has made significant progress toward meeting AML. At 

the national level, BLM was closer to meeting AML in 2007 than in any 

other year since 1984 (when AML levels were first reported by BLM), with 

a population of 28,563, or about 1,000 animals over the upper limit of AML 

(see fig. 5). Meeting AML has been a challenge for most of the lifetime of 

the program. In 1985, in reporting on the Department of the Interior and 

related agencies’ appropriations, the Senate Committee on Appropriations 

recommended more than tripling the program’s funding above the original 

budgeted amounts to, according to the committee, permit BLM to maintain 

nearly 14,000 animals in corrals through the end of fiscal year 1986 and to

remove 17,000 excess animals during fiscal year 1986.32 The program’s 

funding was tripled in fiscal year 1986, and with the increased funding, 

BLM removed 18,959 excess animals. In fiscal year 2001, BLM began 

implementing a 4-year strategy to aggressively remove animals from the 

range to reach the upper limit of AML by 2005. However, just before 

initiating the strategy—which relied heavily on specific assumptions about 

the number of animals removed, adopted, and held in short-term and longterm holding—emergency drought and fire conditions called for the 

removal of wild horses and burros in numbers far greater than anticipated. 

These additional removals and decreases in adoption targets changed 

BLM’s assumptions and made it clear the agency would not be able to

meet the targets set forth in their plan. In 2004, BLM again revisited targets 

and management options that would help them to achieve and maintain 

the midpoint of AML by 2006. Over the past several years, the program is 

closer to meeting AML as a result of increases in the number of wild 

 31According to BLM, the effort to revise the Wild Horse and Burro Program Handbook was 

first initiated in 1997. The effort was restarted most recently in 2006 when the draft

handbook was significantly rewritten and expanded. 

32S. Rpt. 99-141, at 6, 121 (1985). 

Page 31 GAO-09-77 BLM’s Wild Horse and Burro Program 
horses and burros removed from the range, but it continues to face 

challenges in maintaining that level. According to BLM data, the 

population now exceeds the upper limit of AML by an estimated 

5,886 animals. BLM attributes most of the increase in population to more 

accurate population census counts. 

Figure 5: Estimated Population of Wild Horses and Burros on the Range 

Population 

Source: BLM.

Year

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

Appropriate management level (AML)

Total estimated population on the range

2008

200

2004

2005

2006

2007

3

199

1999

2000

2001

2002

8

199

1994

1995

1996

1997

3

19

1990

1991

1992

89

1988

1987

1986

19851983

1984

1982

1981

1980

197

1979

8

197

1974

1975

1976

1977

3

1971

Note: All population levels are estimated based on aerial surveys that likely undercount the number of

animals on the range. In 2000, BLM changed the time frame for its population counts from October 1

through September 30 of every year to March 1 through February 28 or 29 of every year. For AML 

levels prior to 1984, BLM was unable to provide estimated figures. For AML levels from 1984 through

1999, the figures are estimated and they do not necessarily reflect the upper limit of AML; from 

2000 onward, the AML figures represent the upper limit of AML. 

While the national statistics appear to indicate that BLM is close to 

meeting its goal, it is important to note that, under the act, BLM is required 

to maintain HMAs at a level that is at or below the upper limit of AML. To 

stay below the upper limit of AML, HMAs should be gathered to the lower 

limit of AML approximately every 3 to 5 years. However, only 7 of the 

26 BLM field offices we surveyed said they were typically able to gather to 

this low level. When animals are not gathered to the low level of AML, a 

population can quickly rise well above the upper limit of AML. Fewer than 

Page 32 GAO-09-77 BLM’s Wild Horse and Burro Program 
half (10) of the field offices surveyed said they were usually able to 

manage the population of wild horses and burros on their HMAs within the 

limits of AML. Fifteen field offices said they managed populations that 

were typically above AML. 

We are not reporting in detail on the extent to which individual HMAs have 

met AML because we do not believe that BLM’s data are precise enough to

accurately make such a determination. BLM’s estimates of the number of 

HMAs that are at or below AML may be overstated because, for reporting 

purposes, BLM considers the HMAs where the population is not more than 

10 percent over the upper limit of the AML to be at AML. BLM officials told

us that this is done to account for those HMAs that may slightly exceed 

AML. For example, in 2008, BLM reported that 61 of the 102 HMAs in 

Nevada were at or below AML. Without the 10 percent adjustment factor, 

we calculated that 52 HMAs were at or below AML. Because of this 

adjustment factor and questions about the accuracy of BLM’s animal 

counting methods, we concluded that the data on whether or not 

individual HMAs had met AML were not sufficiently reliable to report 

because an error of plus or minus one or two animals could change the 

status of an HMA from being under or over AML. Aside from the precise 

issue of whether or not an HMA is within or over AML, it is clear from the 

data that some HMAs are significantly over AML. For example, as of 

February 2008, BLM reported that 87 HMAs were over AML. About half of 

these HMAs were over AML by 50 percent or less, about a quarter were 

over AML by between 51 and 100 percent, and about another quarter of the 

HMAs were over AML by more than 100 percent. 

Populations that exceed AML can harm the health of the range. For 

example, in 2004, the Calico HMA in Nevada exceeded AML by about 

200 percent. The herds were found to concentrate in sensitive areas, 

affecting the threatened Lahontan cutthroat trout and contributing to the 

nonattainment of grazing allotment objectives and standards for rangeland 

health.33 As of February 2008, the wild horse population in this HMA 

exceeded the upper limit of AML by 160 percent. The excess population 

 33Rangeland health standards were developed to be consistent with the fundamentals of 

rangeland health, including watersheds that are in a properly functioning condition;

ecological processes that are maintained in order to support healthy biotic populations and 

communities; water quality that complies with state water quality standards; and habitats

that are being restored or maintained for federal threatened and endangered species,

proposed or candidate threatened and endangered species, and other special status 

species. 

Page 33 GAO-09-77 BLM’s Wild Horse and Burro Program 
levels and continued drought are expected to continue to negatively 

impact sensitive riparian areas relied upon by the Lahontan cutthroat 

trout. The overpopulation of wild horses and burros on the range may 

negatively impact herd health, rangeland health, and livestock and wildlife 

that depend on the range. An over-obligation of the vegetative resources 

can result in declines in the healthy vegetative condition that may take 

years to recover. See figure 6 for our survey results on the possible 

negative impacts of populations that exceed the upper limits of AML. 

Figure 6: Number of Field Offices Who Reported Negative Impacts When

Populations Exceed the Upper Limit of AML 

0 2 46 8 10 12 14 16 18 20 22 24 26

Negative impact on factor when AML is exceeded by less than 25 percent

Negative impact on factor when AML is exceeded by between 25 and 50 percent

Negative impact on factor when AML is exceeded by between 51 and 100 percent

Livestock habitat requirements

Wildlife habitat requirements

Horse and burro herd health

Rangeland health

Number of survey respondents

Source: GAO analysis of survey data.

Note: We asked survey respondents to identify the impact (positive, slightly positive, no impact, 

slightly negative, and negative) that populations that exceed the upper limit of AML would have on the 

four factors above. The figure is a graphic depiction of survey respondents who reported negative 

impacts when populations exceed AML. See appendix III for the number of survey respondents who 

reported positive, slightly positive, no impact, or slightly negative impacts when the upper limit of AML 

is exceeded by a certain percentage. 

In addition to the effects on the range, overpopulation in HMAs also 

results in costlier gathers because a greater number of animals would have 

to be removed to maintain AML in future years. 

Page 34 GAO-09-77 BLM’s Wild Horse and Burro Program 
Although there has been an increased effort to meet AML, there have been

many challenges in meeting and maintaining that level. Twenty of the 

26 field officials we surveyed identified limitations to gathers to remove 

excess animals as one of their top challenges to meeting or maintaining 

AML. One limitation identified by these respondents included limited 

funding available to conduct gathers. Another limitation identified by 

respondents was unplanned gathers that alter the gather schedule as 

resources are directed to HMAs in critical need. Reasons for unplanned 

gathers include escalating problems and emergencies. An HMA with an 

escalating problem is defined as an area where deteriorating rangeland 

conditions, such as declining availability of forage or water, will negatively 

affect animal condition and rangeland health. Emergency situations are 

unexpected situations that threaten the immediate health of wild horses 

and burros or their habitat, such as fire, disease, or other catastrophic 

events. 

In addition to using gathers and removals to manage the population on the 

range, BLM may also use fertility treatment to manage the reproductive 

rates of wild horses. BLM is using this tool on a limited number of HMAs. 

However, some animal fertility researchers and wild horse advocates 

believe that this tool should be used more widely. They say that unless the 

reproductive rate is curtailed, the need to gather a large number of animals 

from the range will continue. See appendix II for more information about 

BLM’s use of this treatment. 

BLM Has Established a 

Formal Policy on Gathers 

and Removals that 

Specifies the Key Factors 

that Should Be Considered 

in the Decision Making 

Process 

Removals are used as a primary method for managing wild horse and 

burro populations on the range; however, the data used to support these 

removal decisions have been criticized. Specifically, our 1990 report 

concluded that BLM’s decisions on the number of wild horses and burros 

to remove were made without adequate information about range carrying 

capacity or the impact of the animals on range conditions.34 In August 

2005, BLM issued an update to their 2002 policy on gathers that 

determinations to support gathers and removals must be based on a 

National Environmental Policy Act analysis and a gather plan that 

consider five key factors—utilization, trend, actual use, climatic data, and 

 34GAO/RCED-90-110. 

Page 35 GAO-09-77 BLM’s Wild Horse and Burro Program 
current census.35 Eleven of the 26 field offices we surveyed considered all 

five key factors in their most recent gather plan (see table 7). However, 

many of these field offices conducted their most recent gathers prior to 

the issuance of the 2005 policy that specified which factors to consider in 

their decision making process. Specifically, 11 field offices conducted their 

most recent gathers between 1990 and 2005. Additionally, some field 

offices’ most recent gathers were conducted as a result of an emergency 

situation. In those cases, a field office may not have had enough time to 

consider all five criteria due to the critical time response necessary to 

remove the animals.36 

Table 7: Extent to Which BLM Field Office Staff Considered Each of the Five Key 

Factors in Making Their Most Recent Gather Determination 

Number of the five key factors considered Number of respondents

5 11

4 4

3 5

2 1

1 4

0 1

Total 26

Source: GAO survey results. 

Regardless of when the most recent gathers were conducted, 25 of the 

26 field offices we surveyed considered the data used to support their 

removals for specific HMAs as moderately to very sufficient. See table 8 

for the number of field offices that considered each of the factors we 

asked about in our survey. 

 35U.S. Department of the Interior, BLM, Gather Policy and Selective Removal Criteria, 

Instruction Memorandum No. 2005-206 (Washington, D.C., Aug. 10, 2005). The 2005 policy 

updated BLM Instruction Memorandum No. 2002-095, dated February13, 2002. The 

2002 policy did not explicitly enumerate the key factors that should be considered as part

of the gather and removal analysis. 

36U.S. Department of the Interior, BLM, Establishment/Adjustment of Appropriate

Management Levels, and Managing Planned Escalating Problem and Emergency

Gathers, Instruction Memorandum No. 2004-151 (Washington, D.C., Mar. 16, 2004). When

gathers are conducted as a result of an emergency, such as a fire, a National Environmental 

Policy Act analysis and gather plans are still required prior to the animal removal, if time 

permits. If immediate action is required, emergency actions should be documented and a

report prepared after resolution of the problem. 

Page 36 GAO-09-77 BLM’s Wild Horse and Burro Program 
Table 8: Factors Considered by Field Offices in Decisions to Gather Wild Horses 

and Burros from the Range

Factor Considered

Not 

considered

Don’t 

know 

Not 

applicable Blank

Factors that should be considered 

Census/inventory 24 2 0 0 0

Utilization 21 3 1 0 1

Climate data 19 5 1 0 1

Trend 16 6 2 1 1

Actual use: livestock 11 8 2 4 1

Actual use: wildlife 8 10 3 4 1

Other factors considered

Herd health 21 4 1 0 0

Carrying capacity 17 6 2 0 1

Water resources 16 7 1 0 2

Stakeholder influence 16 3 3 2 2

Production 12 8 4 1 1

Livestock agreements 12 6 1 5 2

Cultural resources 12 7 1 4 2

Archeological resources 12 8 1 3 2

Genetic viability 11 11 2 1 1

Recreational use 8 8 1 7 2

Other factors 8 0 1 3 14

Human safety issues 7 10 1 6 2

Court order 3 5 1 14 3

Mineral extraction 3 9 1 11 2

Community expansion 1 11 1 11 2

Source: GAO survey results. 

Unlike our previous report, which stated that data to justify removals was 

outdated, most respondents who provided the year in which their data was 

collected indicated that their data was current as of the year of their most 

recent gather or less than 4 years old (see table 9). 

Page 37 GAO-09-77 BLM’s Wild Horse and Burro Program 
Table 9: Age of Data Used by Field Offices to Determine the Need for Most Recent

Gather 

Age of the data 

Factor 1 year 2 years 3 years 4 years 5-10 years

11 years 

or older

Factors that should be considered 

Census/inventory 14 2 3 0 0 0

Utilization 13 1 0 1 0 0

Climate data 15 0 0 1 0 0

Trend 8 1 1 1 2 0

Actual use: livestock 10 0 0 0 0 0

Actual use: wildlife 7 0 0 0 0 0

Other factors considered

Herd health 11 2 1 1 0 0

Carrying capacity 6 1 1 0 1 2

Water resources 8 0 0 1 0 0

Production 6 1 0 1 0 0

Genetic viability 1 1 1 2 1 0

Source: GAO survey results. 

Half of the survey respondents identified impediments to conducting 

gathers as a major challenge in managing their HMAs to achieve healthy 

herd populations that are in balance with the range and other multiple 

uses. Only 7 of the 26 field offices surveyed said that they were able to

typically gather to their lower limits of AML. While several BLM officials 

explained that gathers can be delayed as a result of funding restrictions or 

emergency gather priorities, only four of the field offices surveyed 

indicated that their most recent gather was delayed. 

Research and Experience 

Have Shown That BLM’s 

On-the-Range Population 

Estimates Are Too Low 

Accurate animal population counts are critical to BLM’s ability to properly 

manage wild horse and burro herds and in determining whether AML 

targets were met. However, many field offices use a population counting 

method—the direct-count method—that researchers consider inaccurate.

This method generally calls for one person to count each animal they spot 

from an airplane or helicopter. According to researchers, it consistently 

undercounts animals and does not provide a statistical range of estimates. 

Nineteen of the 26 field officials we surveyed used the direct-count 

method for conducting their most recent census. 

Page 38 GAO-09-77 BLM’s Wild Horse and Burro Program 
Regardless of which method is used, counting wild horses and burros can 

be challenging, particularly when the animals are obscured by trees or 

when the rangeland is covered with snow. Because counting poses such 

challenges, researchers are investigating alternative counting methods to 

assist BLM in collecting accurate population data to form statistically valid 

population estimates.37 Each method the researchers are evaluating 

includes some range of statistical error, whereas direct count only reports 

the raw number spotted on the ground. Researchers believe that the most 

effective method will likely be a combination of two or more counting 

techniques. BLM’s population counts of wild horses and burros have long

been questioned by managers and advocacy groups alike. By employing 

alternative methods that account for a range of error, BLM would have a 

more defensible way of determining population estimates. In the most 

recent 2008 BLM population estimates, for example, population counts 

exceeded those in 2007 by approximately 4,500 animals. As a result, on a 

nationwide level, BLM is once again well over the upper limit of AML, 

which brings into question earlier population estimates and whether or not 

those previous years were as close to meeting AML as once thought. BLM 

is working with the Department of the Interior’s U.S. Geological Survey’s 

Fort Collins Science Center and the Colorado State University to develop 

these methods to achieve greater accuracy in population counts. Some 

BLM offices have begun to employ some of these methods. For example, 

in Arizona, managers use the simultaneous double-count method to 

improve population counts and avoid underestimating burro populations. 

Some field offices, however, are reluctant to use alternate counting 

methods because they are concerned that they would require too much 

 37The five methods experts are investigating include the following: (1) Photographic markresight involves two or more separate counts. First, an aerial count is conducted, and each

group of animals photographed. This is followed soon after by additional aerial counts. The 

photographs from each survey are compared to determine which animals were seen on

each pass and which were missed. A statistical technique to estimate the number missed is 

based on the number missing on each pass. (2) Simultaneous double-count is a form of 

mark-resight that uses only one count where two observers in an aircraft independently 

observe and record a direct count of wild horses or burros. Sighting rates are estimated by

comparing sighting records of the two observers, and the number of horses that were 

missed by both individuals can be estimated. (3) Sightability bias correction involves 

observers that count animals but also records other factors about each sighting, such as if

the groups were large or small, terrain type, weather, and other factors that may have

prevented some animals from being seen. (4) Distance sampling estimates the number of

animals or herds based on the distance and location of the animals that are seen on the

ground. The data enables statisticians to predict the number of animals that are not seen 

because they are too far away. (5) Combined techniques utilize different combinations of

the aforementioned four techniques to mitigate known biases associated with each 

individual method. 

Page 39 GAO-09-77 BLM’s Wild Horse and Burro Program 
additional staff or would be too expensive. Researchers agree that other 

methods may be slightly more expensive, given the greater number of staff 

needed. 

When a population is undercounted, BLM is likely to remove fewer 

animals than is needed to control overpopulation. For example, in 2002, a 

direct count was used to census the wild horse population located on the 

Jackson Mountain HMA in northern Nevada, an area that has been affected 

by severe drought. When a gather was conducted in 2003, staff believed 

they removed the adequate number of wild horses to reach AML. Funds to 

conduct their scheduled census in 2006 were not available, and BLM was 

unable to conduct its population count until the summer of 2007. It was at 

this point that staff realized that their 2002 census was incorrect and that 

they miscalculated the population in 2007 by approximately 640 wild 

horses. They found that the actual population in 2007 was about five times 

greater than what they determined was sustainable. In the winter of 2007,

BLM began to monitor water availability more regularly. The BLM field 

staff member who managed that HMA told us that although the herd 

condition was weakened, the horses did not appear to be in extremely 

poor condition. Nevertheless, more than 150 of the wild horses removed 

from this HMA died in a short-term holding facility due to disease that was 

able to overtake the animals in their weakened state. 

The number of wild horses and burros removed from the range is far 

greater than the number adopted or sold. Since 2001, about 74,000 animals 

have been removed from the range, while only about 46,400 have been 

adopted or sold. This has resulted in significant spending increases due to

a greater number of animals in short- and long-term holding. Thirty-six 

percent fewer wild horses and burros were adopted in 2007, compared to 

average adoption rates in the 1990s—a trend BLM officials attribute to the 

decrease in adoption demand and increasing hay and fuel costs. Since 

2004, when BLM was directed to sell excess wild horses and burros 

without limitation, BLM has sold about 2,700 animals—far fewer than 

expected, despite the low average selling price of $15. As of June 2008, 

BLM was holding 30,088 animals in short- and long-term holding facilities, 

compared with the estimated 9,807 held in 2001. To accommodate the 

increase in animals removed from the range and the decline in adoptions 

and sales, BLM has increased the number of short- and long-term holding 

facilities. This has resulted in an increase in spending for short- and longterm holding facilities. 

Declining Adoptions 

and Sales Have 

Increased the Need 

for Short-Term and 

Long-Term Holding 

Facilities, and Holding 

Costs Have Increased 

Page 40 GAO-09-77 BLM’s Wild Horse and Burro Program 
BLM has historically managed wild horses and burros removed from the 

range through adoptions to the general public. Adoption has been 

regarded as the most economical way to provide humane long-term care to 

animals that have been removed from the range. In the 1990s, the number 

of animals removed from the range was about equal to the number of 

animals adopted. The average number of animals adopted each year in the 

1990s was about 7,500. Since 2000, the number of animals removed has 

outpaced the number of animals adopted or sold due to an increase in 

removals and a steady decline in adoption demand and sales. Since 2001, 

about 74,000 animals have been removed from the range, compared to 

about 46,400 adopted or sold. The average number removed annually from

2001 to 2007 was about 10,600, compared to the average adoption rate of 

about 6,300 annually. According to BLM’s 2004 Report to Congress, at least 

7,000 adoptions were needed annually to assist in achieving and 

maintaining AML. However, only about 4,700 animals were adopted in 

2007. Although BLM has increased efforts to market adoptions, demand 

continues to decline for wild horses, even though the price for adopting 

them has remained at the minimum fee of $125 since 1997.38 BLM officials 

attribute the steady wild horse adoption decline in recent years to 

increases in hay and fuel costs associated with horse care, the large 

number of domesticated horses that are currently flooding the adoption 

market,39 a general urbanization of rural areas, and a shift toward other 

forms of recreation. For example, according to one official, individuals 

who once had corrals with two or three horses may now own one horse 

and four all-terrain vehicles. Figure 7 compares the number of wild horses 

and burros removed from the range with the number adopted from 1989 

through 2007. 

Adoption Rates Have 

Declined Since the 1990s, 

and the 2004 Sale Directive 

Generally Has Not Been 

Used 

 38Demand for burros has stayed relatively stable from an annual average of 1,154 burros

adopted from 1990 through 1999 and an annual average of 1,092 burros adopted from 

2000 through 2007. 

39The last horse slaughterhouse in the United States closed in fall 2007. The number of 

domestic horses killed in slaughterhouses from 2000 to 2005 ranged from about 40,000 to

75,000 annually. Without these outlets, more domestic horses are available to the public, 

causing direct competition with wild horse adoptions and sales. 

Page 41 GAO-09-77 BLM’s Wild Horse and Burro Program 
Figure 7: Comparison of Removed and Adopted Wild Horses and Burros, 1989 through 2007 

Number of animals

Source: BLM.

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

Total removed

Total adopted

1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

Year

One alternative for managing unadoptable excess wild horses and burros, 

as provided for by the 2004 amendment to the 1971 act, is to sell the 

animals “without limitation.” The act directs BLM to offer excess animals 

for sale that are more than 10 years old or that have been offered 

unsuccessfully for adoption at least three times. At the time of the 

amendment, BLM estimated that approximately 8,400 animals were 

eligible for sale. To date, BLM has sold only about 2,700 animals—far 

fewer than originally expected, despite the low average selling price in 

2006 of $15 (see table 10). 

Page 42 GAO-09-77 BLM’s Wild Horse and Burro Program 
Table 10: Number of Wild Horses and Burros Sold under the December 8, 2004, 

Sales Directive 

Year Number sold

2005 1,468

2006 645

2007 420

2008a211

Total 2,744

Source: BLM.

a

As of June 2008.

In 2005, the first sale was made to a wild horse protection group in 

Wyoming who purchased 200 horses that would otherwise have likely 

ended up in long-term holding under BLM’s care. A few other animals that 

were sold, however, ultimately ended up in slaughterhouses. To reduce the 

likelihood that a buyer would purchase these animals and then sell them 

for slaughter, BLM changed its sales process to require buyers to sign a 

“statement of intent” that they do not intend to sell the animals for 

slaughter. This limitation, as well as a decrease in demand, has contributed 

to the small number of sales. 

BLM Manages 30,088 

Animals in an Increasing 

Number of Short-Term and 

Long-Term Holding 

Facilities, and Holding 

Costs Have Increased 

As of June 2008, BLM was holding a combined 30,088 animals in shortterm and long-term holding facilities, compared to 9,807 animals in 2001. 

To accommodate the increase in animals needing care once removed from 

the range, the number of short-term and long-term holding facilities has 

increased. Spending on combined short-term and long-term holding has 

also increased from about $7 million in 2000 to about $20.9 million in 2007. 

From 2001 through 2008, the number of short-term holding facilities 

increased from 14 to 24,40 and the number of animals held in these facilities 

increased from 6,514 animals to 7,987 by June 2008. These holding 

facilities provide the animals with vaccinations and other care prior to 

their being adopted, sold, or sent to long-term holding. The average cost of 

animals in short-term holding increased from $3.00 per horse per day in

2001 to $5.08 per horse per day in 2008. From 2000 to 2001, the cost for 

short-term holding increased from $6.4 million to $11.2 million. From 

 40Three of these facilities were added to incorporate horse gentling programs to improve 

the likelihood of adoption. 

Page 43 GAO-09-77 BLM’s Wild Horse and Burro Program 
2001 through 2007, the cost remained relatively stable, but for 2008, costs 

are anticipated to increase to $16.2 million. According to several BLM 

officials, the escalating cost for caring for animals in short-term holding is 

primarily a result of the dramatic increase in hay and fuel prices from 

2007 to 2008. For example, hay prices for one short-term holding facility in

Nevada increased from about $160 per ton in 2007 to almost $300 per ton 

in 2008. Decreases in adoption and sales and a lack of capacity in longterm holding has not only increased the number of animals held in shortterm holding, but has also increased the time animals are held there. 

According to one state official, animals in his state spent 45 to 60 days in

short-term holding facilities in the late 1990s. Beginning in 2000, this 

official told us, it was not uncommon to hold animals for more than a year. 

Nationwide, according to BLM, the average length of stay in short-term 

holding in 2008 has been 210 days. This is far longer than the 90 days BLM 

projected animals would spend in short-term holding in their 2001 

initiative to meet AML. 

Similarly, the number of long-term holding facilities has increased, as has 

the cost. The number of facilities increased from 1 in 1988 to 11 as of June 

2008, and the number of animals cared for increased from 1,500 in 2000 to 

22,101 as of June 2008 (see table 11). These long-term holding facilities 

have reached their capacity—currently 22,100—despite the increase in 

numbers of facilities. BLM anticipates it will need greater long-term 

holding capacity and is working to contract for additional facilities. 

Table 11: Number of Wild Horses in Long-Term Holding, by Year, Since 2000 

Year Number of facilities Capacity 

Number of horses 

in long-term holding

2000 1 2,000 1,500

2001 3 6,000 3,293

2002 5 10,000 7,311

2003 7 14,000 10,122

2004 7 14,000 13,151

2005 9 20,600 15,379

2006 8 19,700 18,198

2007 10 21,800 19,652

2008a11 22,100 22,101

Source: BLM.

a

As of June 2008.

Page 44 GAO-09-77 BLM’s Wild Horse and Burro Program 
BLM pays private contractors an average of $1.27 per horse per day to 

maintain the animals for the remainder of their lifespan, unless removed 

from long-term holding for adoption or sale. While this fee has increased 

by only 7 cents since 2000, the number of animals cared for has also 

increased, resulting in a significant increase in BLM spending on long-term 

holding.41 In 2000, BLM spent approximately $668,000 in 2000, compared to 

more than $9.1 million in 2007 to care for wild horses in long-term holding. 

The long-term holding facilities are primarily located in Oklahoma and 

Kansas, where forage is typically more abundant than on HMAs of the 

West. Table 12 lists the 11 long-term holding facilities. 

Table 12: BLM Long-Term Holding Facilities, June 2008 

Name of facility Location 

Year(s) animals 

first held in facility Capacity

Horses

held

Bartlesville Oklahoma 1989 2,300 2,066

Catoosa Oklahoma 2001 2,000 2,042

Teterville East Kansas 2001 2,200 1,913

Teterville West Kansas 2002 2,200 2,531

Foraker Oklahoma 2003 2,500 2,507

Pawhuska Oklahoma 2003–2004 3,400 3,646

Grenola Kansas 2004 2,200 2,269

Hulah Oklahoma 2004 2,200 2,203

Herd Oklahoma 2007 1,000 1,042

Whitehorse South Dakota 2007 1,100 1,169

Strohm Oklahoma 2008 1,000 713

Total 22,100 22,101

Source: BLM.

For at least two decades, BLM’s primary strategy to manage excess 

unadoptable wild horses has been to increase long-term holding, despite 

warnings in our 1990 report that these facilities were likely to be more 

expensive than envisioned and to be only a temporary solution to the 

disposal of unadoptable animals.42 In 1994, the Department of the Interior’s 

Office of Inspector General also issued a report that strongly discouraged

 41Long-term holding costs were, on average, $1.20 in 2000, $1.22 in 2001, and $1.25 per 

horse per day from 2001 through 2004. In 2005, the cost increased to $1.27 per horse per

day through 2007 and will increase to $1.28 per horse per day by the end of 2008. 

42GAO/RCED-90-110. 

Page 45 GAO-09-77 BLM’s Wild Horse and Burro Program 
long-term holding as a solution to managing horses removed from the 

range due to the large costs.43 BLM continues to look for more facilities but

faces difficulty attracting new contractors that can sustain a large number 

of animals and that will accept the fee BLM offers, compared to perhaps

more profitable land uses. 

BLM has implemented multiple controls to help ensure the humane 

treatment of wild horses and burros, including standard operating 

procedures and agreements with all three slaughterhouses in the United

States before they closed in 2007. A variety of controls are used at various 

stages in the management of wild horses and burros, including for those 

animals that are gathered, in short-term holding facilities, in long-term 

holding facilities, adopted, or sold. BLM’s controls for gathers include 

standard operating procedures, inspections, and data collection. While 

BLM state offices collect detailed data on animals that die during gathers, 

the information is not compiled by BLM headquarters in its centralized 

database, nor is it reported to the public. In addition, BLM does not 

regularly provide the information it tracks on the treatment of animals in 

short- and long-term holding and adoption inspections to the public. 

Making more of this data available to the public may help inform them 

about the treatment of the animals and improve transparency. Beginning 

in 1998, until the last horse slaughterhouse in the United States shut down 

in 2007, BLM sought agreements with all three slaughter facilities to alert

BLM of wild horses that entered their facilities. According to BLM data, 

since 2002, about 2,000 wild horses whose legal titles were obtained by 

private citizens either through adoption or purchase were slaughtered. 

During that same period, another 90 wild horses whose title still belonged 

to BLM were retrieved from slaughterhouses by BLM and by wild horse 

groups. We reviewed the basic controls BLM has in place, but we did not 

evaluate their effectiveness. While BLM is required to implement controls 

to help ensure the humane treatment of wild horses and burros, such 

BLM Has Controls in 

Place to Help Ensure 

the Humane 

Treatment of Wild 

Horses and Burros, 

but It Could Better 

Track and Report 

These Data to the 

Public 

 43U.S. Department of the Interior, Office of Inspector General, Selected Aspects of the Wild

Horse and Burro Program (Washington, D.C., May 1994). 

Page 46 GAO-09-77 BLM’s Wild Horse and Burro Program 
controls cannot provide absolute assurance that all agency objectives will

be met.44

BLM Internal Controls 

Help Ensure Humane 

Treatment, but BLM Could 

Improve Data Gathering 

and Reporting in Some 

Areas 

A variety of controls are used at various stages in the management of wild 

horses and burros, including for those animals that are gathered, in shortterm holding facilities, in long-term holding facilities, adopted, or sold. 

BLM’s controls for gathers include standard operating procedures, 

inspections, and data collection. Data collected from 6 of the 10 states 

from fiscal years 2005 through 2007 indicate that mortality as a result of 

gathers is about 1.2 percent. Similarly, controls for short- and long-term 

holding include standard operating procedures, inspections, and data 

collection. BLM did not report any deaths due to neglect or abuse at 

holding facilities, aside from one animal that was repossessed by BLM 

after having been abused by an adopter. BLM has controls over the 

adoption of wild horses and burros, and data indicate that from 2005 to 

2007, about 9 percent of adopters were not in compliance with BLM’s 

standards of care. BLM’s controls over humane treatment primarily apply

to horses and burros before ownership is passed to private individuals, but 

BLM has also implemented some controls to protect horses and burros 

once ownership passes, such as when wild horses and burros are sold. For 

animals that are sold, since spring 2005, BLM has required buyers to sign a 

statement that they do not intend to slaughter the animals. BLM does not 

consistently track information on treatment during gather operations 

through a central database, nor does it report information about the 

treatment of animals during gathers, holding, or adoption inspections to 

the public. 

BLM has established controls, such as standard operating procedures and 

tracking systems, to help ensure humane treatment during gather 

operations. BLM hires contractors to remove wild horses and burros from

the range. These contractors generally use helicopters to herd the animals 

into capture pens on the range (see fig. 8). 

Gathers 

 44Standards for internal control in the federal government describe internal controls as “a 

series of actions and activities that occur throughout an [agency’s] operations and on an 

ongoing basis” used “to regulate and guide [the agency’s] operations.” See GAO, Standards

for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: 

November 1999). 

Page 47 GAO-09-77 BLM’s Wild Horse and Burro Program 
Figure 8: Helicopter Used to Gather Wild Horses Near Ely, Nevada, c. 2006 

Source: BLM.

Due to the stress caused to wild animals by gathering them into pens, 

gather operations have the potential to cause harm to wild horses and 

burros, such as nervous agitation; conflict between captured animals; or 

more rarely, animal death. Because of the potential for harm and to help

ensure the safe and humane handling of all animals captured, BLM has 

implemented a range of standard operating procedures for its gather 

contractors. Prior to the start of gather operations, BLM personnel 

evaluate the site of the gather to determine whether it is suitable based on

environmental and safety concerns. They also approve gather facility plans 

ensuring, among other things, that they do not present puncture or 

laceration hazards and that they prevent animals from seeing humans, 

vehicles, and other perceived threats. During the herding of the animals, 

BLM sets limitations on the distance and speed the animals will travel, 

depending on the condition of the animals and other factors. As the 

animals are herded into the gather site, BLM requires contractors to 

segregate horses by age and sex to reduce the possibility of conflict and to 

ensure that very young horses and burros are not left behind to fend for 

themselves on the range. Finally, as the captured animals are transported 

from the gather site to short-term holding facilities, contractors are 

required to follow procedures to ensure animal safety, such as using 

adequately sized motorized equipment that has been inspected for safety. 

BLM has managed gathers with standard operating procedures since the 

passage of the act in 1971. 

Page 48 GAO-09-77 BLM’s Wild Horse and Burro Program 
Although BLM’s controls are designed to enhance the safety of wild horses 

and burros during gather operations, some animals are accidentally killed 

in the course of gathers or are euthanized because of ill health or prior 

injury. Six of the 10 BLM state offices reported data about the number of 

animals that die as a result of their gather operations. Data collected from

6 of the 10 states from fiscal years 2005 through 2007 indicate that, of the 

24,855 animals removed from these states during this period, about 

1.2 percent were either euthanized or died accidentally (see table 13). 

Horses and burros sometimes die due to accidents during gather 

operations on the range or after they are brought to the holding pens. For

example, wild horses will sometimes panic and break their necks against 

capture pens. Animals found with conditions that make it unlikely they 

will be able to live their life without significant pain, such as lameness or 

club feet, are euthanized. 

Table 13: Number and Percentage of Wild Horses and Burros That Died During

Gather Operations, (for 6 of 10 States) Fiscal Years 2005 through 2007 

Fiscal 

year 

Number 

removed

Number of 

accidental deaths Percentage 

Number 

euthanized Percentage

2005 9,830 25 0.25% 46 0.47%

2006 8,081 64 0.79 79 0.98

2007 6,944 28 0.40 60 0.86

Total 24,855 117 0.47% 185 0.74%

Source: GAO analysis of BLM data. 

Note: This chart is based on data reported by 6 of 10 states: California, Colorado, Idaho, Nevada, 

New Mexico, and Wyoming. The data provided could not be verified for its reliability. We requested 

this information from the other four states (Arizona, Montana, Oregon, and Utah), but the information 

was not provided. 

Although BLM national and state officials told us that they sometimes 

record data about the animals accidentally killed or euthanized during 

gathers at the BLM state office level, BLM does not centrally compile or 

report these data to the public on a regular basis on a national level. A 

BLM official told us that although their main tracking database has the 

capability to record the number of animals that are killed or euthanized 

during gathers, they generally do not use the database to do so because it 

was originally intended to track adoptions. Moreover, BLM has not 

regularly reported to the public how many wild horses and burros are 

killed in the course of gathers, although BLM officials have cited the data

during public hearings. Some advocates and members of the public believe 

that gathers are held in secret and highlight individual cases of apparent 

mistreatment as evidence that inhumane treatment is widespread. 

Page 49 GAO-09-77 BLM’s Wild Horse and Burro Program 
However, a BLM official told us that it is BLM’s standard practice to allow 

the public and the media to observe gather operations, and BLM is 

required to hold public hearings prior to scheduled gathers using 

helicopters. If BLM does not improve its transparency by presenting 

reliable data to members of the public, BLM will continue to be vulnerable

to accusations that gathers are generally cruel and inhumane. 

BLM has issued standard operating procedures to help ensure that wild 

horses and burros held in short-term holding facilities are well cared for. 

They include procedures for minimizing the excitement of the animals to 

prevent injury; separating horses by age, sex, and size; observation of the

animals on a regular basis; and recording information about the animals 

that BLM later uses for tracking the animals in BLM’s database. BLM’s 

short-term holding facilities are mostly maintained and directly managed 

by BLM, either on government property or on leased property. Several are 

at state prisons, and a few others are maintained by contractors in 

privately-owned feedlots or ranches that BLM has leased. According to 

BLM staff, they regularly inspect the short-term holding facilities and the

animals they hold. They inspect to see that the corral equipment is up to 

code and that animals are treated with appropriate veterinary care. For 

example, staff check to see that the horses’ hooves are regularly trimmed 

so that they do not become too long and cause injury. At two of the shortterm holding facilities we visited, we observed specially constructed 

chutes that hold and rotate horses in place so that horses’ hooves can be 

trimmed more quickly, easily, and with less risk to the animals and the 

employee than other methods, such as using tranquilizer darts or roping 

(see fig. 9). 

Short-Term Holding 

Page 50 GAO-09-77 BLM’s Wild Horse and Burro Program 
Page 51 GAO-09-77 BLM’s Wild Horse and Burro Program 

Figure 9: BLM Contractor Trimming Horse Hooves Using a Special Holding Chute at 

a Contract Short-Term Holding Facility in Fallon, Nevada, October 2007 

BLM data indicate that the wild horses and burros held in short-term 

holding facilities from 2003 to 2007 had a mortality rate of about 5 percent. 

Specifically, for 2007, BLM reported 936 deaths in short-term holding 

facilities out of a total of 17,363 animals that passed through short-term 

holding facilities in that year.45 BLM reported that none of the animals in 

its care died of neglect or abuse between 2005 and 2007, aside from one 

case in 2006, where a reclaimed adopted horse died in BLM care due to the 

effects of abuse suffered while it was in the care of an adopter. BLM data 

showed that the animals generally died due to sickness, broken limbs, or 

injuries sustained accidentally during gathers. BLM does not report this 

information regularly to members of the public who remain concerned 

that the agency does not adequately care for animals in short-term holding. 

BLM has similar controls in place for its long-term holding facilities. BLM 

staff inspect long-term holding facilities annually to count the number of 

animals held. Staff also monitor pasture conditions, winter feeding, and 

 45For 2007, BLM also reported 616 births in short-term holding facilities. 

Long-Term Holding 

Source: GAO.
animal health throughout the year. According to BLM staff, during these 

visits they ensure the contractors comply with BLM provisions and discuss 

possible problems that can be corrected. In addition, veterinary staff from 

the Department of Agriculture’s Animal and Plant Health Inspection 

Service inspect long-term holding facilities annually; these inspections 

involve a full count of the horses held there, an inspection of the horses’ 

general health, and written reports. Animal and Plant Health Inspection 

Service reports from 2007 indicate that the horses kept in long-term 

holding sanctuaries are generally in “good” or “excellent” condition. These 

reports, however, highlight some areas for possible improvement. At one 

facility, one area of improvement included the proper disposal of the 

remains of animals that have died of natural causes. To help ensure the 

animals are well cared for, a contract veterinarian provides care when 

needed at BLM direction and expense. In addition to inspecting the 

facilities for the well being of wild horses in long-term holding, contractors 

are required to count and report the number of horses held on a weekly 

basis for billing and payment purposes. In 2007, long-term holding 

contractors were paid an average fee of $1.27 per horse per day, or about

$460 per horse per year. While this contract fee structure is not in itself a 

control that guarantees humane treatment, it provides a profit incentive 

for contractors to ensure the continued health of the horses. According to

one BLM official, BLM does not regularly document the results of its 

inspections. This official told us that the agency would take actions and 

record them if it found problems, but the official generally has not found 

problems with the contractors that have warranted action beyond informal 

conversations to address minor issues. 

BLM collects data on how wild horses are cared for in long-term holding, 

including the number of animals that die in long-term holding. The average

mortality rate of wild horses in long-term holding from 2003 through 2007 

was about 8 percent, but it fluctuated from a low of 5 percent to a high of 

14 percent during that time period. Specifically, for 2007, BLM reported 

938 deaths in long-term holding facilities.46 The number of wild horses in 

long-term holding in 2007 was 19,652. The animals that die in long-term 

holding are generally found in the pastures, and unless there is evidence of 

foul play, BLM does not investigate the cause of death. According to BLM, 

barring any evidence to the contrary, it is assumed that the animals in 

 46For 2007, BLM also reported 303 births in long-term holding facilities. Although studs are

gelded prior to being sent to long-term holding and the wild horses are separated by sex,

pregnant mares may be transferred from short-term holding facilities into long-term 

holding facilities. 

Page 52 GAO-09-77 BLM’s Wild Horse and Burro Program 
long-term holding die of old age. Officially, BLM reported about 95 percent 

of the animal deaths in long-term holding as “undiagnosed.” Some of the 

other causes of deaths reported included old age and respiratory illness. 

No animals in long-term holding died from neglect or abuse, according to 

BLM reports. While BLM collects this data, it does not report this data 

regularly to the public. In the absence of this data, some members of the 

public who advocate greater protection for wild horses have repeatedly

expressed their concern that BLM does not adequately care for animals in 

long-term holding. 

The act requires BLM to determine that adopters have provided humane 

conditions, treatment, and care for adopted animals for at least 1 year 

before BLM transfers ownership to the adopter. To implement the act,

BLM has established policies for inspecting adopted horses or burros in 

this first year through telephone calls or personal visits. BLM inspections 

focus on the condition of the animal; the condition of the facilities; and 

whether the adopter has notified BLM if the adopted animal has been 

moved, was stolen, has escaped, or has died. Prior to taking possession of 

an adopted animal, BLM requires that adopters describe the facility where 

they will maintain the adopted animal. This is documented in their 

application, which confers penalties for providing false information. 

Adoption 

According to BLM data, from 2005 through 2007, an average of about 

9 percent of adopted wild horses and burros that still belong to the 

government have not been treated in compliance with BLM standards (see 

table 14). BLM randomly selects a sample from the universe of 

approximately 5,000 adopters per year who have not yet received title of 

their adopted animal for inspection. BLM inspects these adopters in order 

to generate a statistical sample of the likely percentage of adopted animals 

kept under conditions that do not comply with BLM’s policies and 

standards. The most common conditions in need of improvement included 

the failure to report changes in the animal’s location or status and 

substandard facilities, such as inadequate fencing or shelter. Less common

conditions included lack of care of the animal, such as inadequate feeding 

or failure to trim the animal’s hooves before they grew too long. 

Page 53 GAO-09-77 BLM’s Wild Horse and Burro Program 
Table 14: Results of Random Inspections of Wild Horse and Burro Adoptions, 2005 through 2007 

2005 2006 2007 

Result of random adoption inspections Number Percent Number Percent Number Percent

No violation 395 94% 614 91% 805 89%

Failure to notify BLM of change in status 10 2 24 4 36 4

Failure to provide adequate facilities/care 4 1 3 0 30 3

Failure to produce animal 5 1 13 2 19 2

Unauthorized transfer/sale 0 0 6 1 15 2

Commercial exploitation 0 0 0 0 4 0

Inadequate facility 4 1 6 1 0 0

Unauthorized destruction 0 0 5 1 0 0

Inhumane treatment 2 0 0 0 0 0

Total 420 100% 671 100% 909 100%

Source: GAO analysis of BLM data. 

In addition, BLM policy directs that officials or certified volunteers 

conduct personal inspections of all adopted animals whenever BLM 

receives complaints about mistreatment or when an individual or 

organization adopts more than four wild horses or burros at one time. 

Similar to the data collected on the animals in short- and long-term 

holding, BLM does not provide information on the results of its adoption

inspections to the public. The information regularly provided to the public

on the treatment of these animals is in contrast to the comparatively large 

amount of information BLM provides on the program’s Web site regarding 

information on AML and population estimates for each HMA. 

In the case of animals that were legally sold, BLM has implemented 

limitations to prevent these animals from being resold to slaughter 

facilities. In 2004, the act was changed and directed BLM to sell, “without 

limitation,” excess wild horses and burros more than 10 years of age or 

that had been offered unsuccessfully for adoption at least three times, 

until all excess animals for sale are sold or until AML is met in all HMAs. 

However, shortly after BLM began to sell wild horses and burros without 

limitation, in early 2005, it was discovered that 41 of these wild horses had 

been slaughtered. In April 2005, BLM suspended its wild horse sales 

program and resumed sales in May 2005, after adding controls intended to 

restrict the sale of animals for the purpose of selling them for slaughter. 

These controls included BLM’s requirement that buyers sign a statement 

Sales 

Page 54 GAO-09-77 BLM’s Wild Horse and Burro Program 
they do not intend to sell the animals for slaughter and verification that 

potential buyers would provide adequate care for the animals. 

BLM Implemented 

Controls to Prevent 

Slaughter of Wild Horses in 

the United States 

Although BLM is no longer required to protect animals after ownership has 

passed to adopters or buyers, BLM implemented controls to help prevent 

their slaughter beginning in 1998. BLM had negotiated agreements with all 

three U.S. facilities that operated horse slaughterhouses. The 

slaughterhouses agreed to alert BLM to all wild horses that entered their 

facilities and refrain from slaughtering those wild horses whose title still 

belonged to BLM. According to BLM data, which it was able to provide 

since 2002, about 2,000 wild horses whose legal titles were obtained by 

private citizens through adoption or purchase were slaughtered. During 

that same time period, at least 90 adopted wild horses that were still 

owned by the government were brought to these slaughterhouses, and all 

were retrieved by BLM and interested wild horse groups. 

As of fall 2007, all horse slaughter facilities in the United States had been 

shut down following unsuccessful legal challenges to state laws effectively 

banning the practice. In January 2007, the U.S. Court of Appeals for the 

Fifth Circuit ruled that a 1949 Texas law banning the sale, possession, or 

transfer of horsemeat applied to the two slaughterhouses in Texas.47 In 

September 2007, the U.S. Court of Appeals for the Seventh Circuit upheld 

an Illinois ban.48 These rulings effectively closed the plants and ended 

horse slaughter in the United States. 

Even though all horse slaughter facilities in the United States have been 

closed, it is still possible for wild horses and burros to be sold to facilities 

outside the United States.49 Prior to the closure of all U.S. horse slaughter 

facilities, about 50,000 domestic horses were brought to slaughter in the 

United States annually between 2001 and 2004. Generally, exporting 

horses and burros to other countries for slaughter, such as Canada or 

Mexico, is not prohibited; for example, about 3,000 horses per month were 

exported for slaughter in 2007, according to Department of Agriculture 

 47Empacadora de Carnes de Fresnillo v. Curry, 476 F.3d 326 (5th Cir. 2007), cert. denied, 

75 U.S.L.W. 3569 (U.S. May 21, 2007). See also, Tex. Agric. Code Ann. §§ 149.001-149.007. 

48Cavel Int’l, Inc. v. Madigan, 500 F.3d 551 (7th Cir. 2007), cert. denied, 76 U.S.L.W. 3410 

(U.S. June 16, 2008). See also, 225 Ill. Comp. Stat. 635/1.5. 

49Current legislation pending in the 110th Congress (H.R. 503 and S. 311) would prohibit the 

commercial sale of horses to foreign countries, such as Canada and Mexico, to be 

slaughtered for human consumption. 

Page 55 GAO-09-77 BLM’s Wild Horse and Burro Program 
information. We attempted to determine how many of these horses were at 

one time wild, but we were not able to do so. The Department of 

Agriculture, which certifies the inspections of horses and other livestock 

exported to other countries, is not required and does not report how many 

of the horses exported to other countries were once wild horses. 

The long-term sustainability of BLM’s Wild Horse and Burro Program 

depends on the resolution of two significant challenges. First, holding 

costs are overwhelming the program’s ability to manage animals on the 

range and will continue to do so if BLM does not consider alternatives to 

holding. Second, BLM has limited options for dealing with unadoptable 

animals off of the range because its alternatives under the act—humane 

destruction of the animals or selling the animals without limitation—are 

thought to be unacceptable to the public. As a result, BLM has placed over

30,000 wild horses and burros in holding. 

The portion of the Wild Horse and Burro Program’s spending that is 

directed toward short- and long-term holding has increased from

46 percent of the program’s direct costs in 2000 to 67 percent in 2007. This 

increase leaves a smaller portion of the budget available for on-the-range

management activities. Much of the increase has occurred because 

accelerated removals implemented to reach AML have coincided with a 

decline in adoption demand. Because long-term holding facilities are at 

capacity, BLM has had little choice but to hold excess unadoptable horses 

in more expensive short-term holding. BLM’s spending on short- and longterm holding has increased from about $7.0 million in 2000, or 46 percent 

of the program’s direct costs, to about $20.9 million in 2007, or 67 percent 

of the program’s direct costs (see fig. 10). In 2008, BLM anticipates that 

holding costs will account for about 74 percent of the program’s direct 

costs. To deal with its long-term holding problem, BLM has primarily 

sought increased funding to open additional long-term holding facilities. 

However, funding is not likely to increase in the future, and limited 

funding is forcing BLM to make difficult choices. For example, in January 

2008, BLM considered canceling all remaining removals scheduled for the 

fiscal year because of the amount needed for short- and long-term holding. 

As of July 2008, BLM was seeking the funds to continue these removals by 

redirecting money from other BLM activities to the Wild Horse and Burro 

Challenges to the 

Long-Term 

Sustainability of the 

Program Include 

Growing Holding 

Costs and Limited 

Options for Dealing 

with Unadoptable 

Animals 

If Not Controlled, Off-theRange Holding Costs Will 

Continue to Overwhelm 

the Program 

Page 56 GAO-09-77 BLM’s Wild Horse and Burro Program 
Program. As a result, under current funding levels, BLM must now choose 

between either managing the range to prevent overpopulation or exercise

one or both of its other options—destroying animals or selling them 

without limitation. 

Figure 10: BLM Estimated Wild Horse and Burro Direct Program Costs, Fiscal Years 

2000 through 2008

0

10

20

30

40

50

60

70

80

90

100

Range management

Adoptions and compliance

Short-term holding (estimate)

Long-term holding (estimate)

2008

projected

2000 2001 2002 2003 2004 2005 2006 2007

Source: GAO analysis of BLM data.

Percentage

Fiscal year

Note: This chart represents direct program spending. It omits spending on overhead items—which 

average about $7 million per year—such as administrative costs, vehicle costs, and other nondirect

program related costs. 

To continue to reduce overpopulation on the range by using gathers alone, 

BLM projects that the program’s budget would have to increase to about

$77 million by fiscal year 2012, from about $36 million in 2008. If BLM does 

not receive this increase or exercise its other options to reduce 

populations off the range, then it will not have sufficient funds to manage 

wild horses and burros on the range, and populations will sharply 

Page 57 GAO-09-77 BLM’s Wild Horse and Burro Program 
increase. BLM’s current projections indicate that caring for unadoptable 

animals would reduce the agency’s ability to gather horses to an average of

about 4,500 animals per year, which would only be enough to prevent 

animals from dying from the effects of overpopulation and drought. At 

these removal levels, BLM projects that the on-the-range population would 

reach 50,000 animals by 2012—about 80 percent greater than the upper 

limit of AML. This on-the-range population level would be greater than the 

population level prior to the beginning of BLM’s 2001 strategic plan. 

Since 2004, BLM has had the goal of reducing the total population on the 

range to the midpoint of AML. If it were to reach this level, which is 

currently about 22,588 animals, an annual population growth rate of 

20 percent would require the annual removal of about 4,500 animals to 

maintain that level, approximately equal to the recent adoption rate. 

Assuming that rate remained constant, fewer animals would be sent to 

long-term holding. However, even if BLM is able to reach a balance

between animals removed and those adopted, it still has the challenge of 

dealing with 30,088 animals that are currently held in short-term and longterm holding facilities across the country. Furthermore the number of 

animals held in holding would exceed 40,000 animals if BLM were to 

remove the approximately 11,000 animals necessary to reach the midpoint 

of AML. 

BLM has a number of research projects under way and ideas in

development that could slow the increase in the population on the range. 

These include fertility control efforts, such as the development of a 

fertility vaccine (see app. II for more information on this vaccine) and 

releasing sterilized male horses back to the range after capture. Given that

many existing HMAs are already over AML, releasing a large number of 

sterilized male horses or nonreproducing herds back to the range as a 

means of trying to reduce future holding costs would likely require 

changing existing land use decisions within BLM’s existing authority to 

increase AMLs, expand existing HMAs or designate new HMAs; or through 

seeking new legislative authority. Under the 1971 act, the land available for 

the management of wild horses and burros is limited to the areas where 

they existed at the time of the act. The originally designated herd areas 

consisted of 53.5 million acres compared to the existing HMA acreage of 

34.3 million, a difference of 19.2 million acres. Specifically, the BLM 

owned acreage managed for wild horses and burros has changed from 

42.2 million acres to 29.0 million acres, a difference of 13.2 million acres. 

As we mentioned earlier, BLM is in the process of compiling a history of 

actions that led to these changes. At this point, however, it is not clear 

how much of the 13.2 million acres is still public land under BLM’s control. 

Page 58 GAO-09-77 BLM’s Wild Horse and Burro Program 
While BLM could change AMLs, expand existing HMAs, or designate new 

HMAs within its existing authority, BLM is a multiple use agency and it 

weighs the needs of wild horses and burros against other competing uses. 

Alternatively, should BLM chose to do so, new legislative authority could 

be pursued to allow nonreproducing herds to be relocated to areas where 

they were not found at the time of the act. We believe that it is important 

to consider increasing AML or expanding HMA acreage only as a means to 

accommodate nonreproducing herds. Increasing the number of 

reproducing animals on the range without corresponding solutions for 

fertility control or declining adoption demand will, in the long run, only 

exacerbate BLM’s problems with dealing with excess animals. 

Under Current Law BLM’s 

Options Are Limited for 

Dealing with Unadoptable 

Animals 

Despite these budget problems, BLM has avoided using two options in the 

act for dealing with unadoptable animals because of concerns over the 

public and congressional reaction to the large-scale slaughter of thousands 

of healthy horses. The Wild Free-Roaming Horses and Burros Act, as 

amended, requires that excess animals, for which the adoption demand is 

not sufficient to absorb all the animals removed from the range, be 

destroyed in the most humane and cost-efficient manner possible or, 

under certain circumstances, be sold without limitation. The 1978 

amendments to the original 1971 act directed that “[t]he Secretary shall 

cause additional excess wild free-roaming horses and burros for which an 

adoption demand by qualified individuals does not exist to be destroyed in

the most humane and cost efficient manner possible.”50 From 1981 to 1982, 

BLM destroyed at least 47 excess animals. BLM decided not to destroy 

excess unadoptable animals in 1982 after the Director issued a policy

prohibiting the destruction of healthy animals because of public dismay. 

Furthermore, from fiscal year 1988 through fiscal year 2004, Congress 

prohibited BLM from using its Management of Lands and Resources 

appropriations to destroy excess healthy, unadoptable wild horses and 

burros. 

In our 1990 report, we found that keeping excess animals in long-term 

holding was costly and recommended that BLM examine alternatives, such 

as sterilizing animals and releasing them back into the wild.51 Although 

BLM was prohibited from using its Management of Lands and Resources 

appropriations for humanely destroying excess animals through 

 5016 U.S.C. § 1333(b)(2)(C). 

51GAO/RCED-90-110. 

Page 59 GAO-09-77 BLM’s Wild Horse and Burro Program 
euthanasia at the time of that report, we also recommended that BLM 

consider this action as a last resort in the event that Congress lifted the 

prohibition in the future. The recurring prohibition in the annual 

appropriations bills ended after fiscal year 2004. Since then, BLM has no 

longer been prohibited from using its Management of Lands and 

Resources appropriations for carrying out the requirement to destroy 

excess animals. BLM still has not used this option. 

In 2004, Congress provided BLM with an alternative to destroying 

unadoptable excess animals by amending the act to state that “[a]ny 

excess animal or the remains of an excess animal shall be sold if—(A) the 

excess animal is more than 10 years of age; or (B) the excess animal has 

been offered unsuccessfully for adoption at least 3 times.”52 Furthermore, 

the amendment stipulated that the excess animals “shall be made available 

for sale without limitation.”53 BLM has instead imposed limitations on the 

sales of excess animals in an effort to reduce the risk that animals 

purchased at a low price would be resold to slaughterhouses for profit. 

As a result, BLM is not in compliance with the act. BLM officials told us 

that they have chosen not to destroy excess animals or sell them without 

limitation because of concerns about public and congressional reaction to 

the large-scale slaughter of thousands of healthy horses. Various BLM 

officials at different levels of responsibility also told us that the agency has 

not complied with these provisions because doing so would cause an 

immediate threat to the careers of any officials involved, due to the 

anticipated negative reaction of the public and Congress. Nevertheless, as 

of June 2008, budget constraints forced BLM to reconsider all of its 

options, officials told us. Specifically, for fiscal year 2009, BLM is 

considering euthanizing about 2,300 horses from short-term holding—

about one-third of the animals currently in short-term holding. In addition, 

they are considering selling without limitation about 8,000 animals from

both short- and long-term holding. However, as of August 31, 2008, 

legislation was pending in the 110th Congress that would repeal the 

directive for BLM to sell animals without limitation, but not the 

requirement to destroy unadoptable excess horses.54

 5216 U.S.C. § 1333(e)(1). 

5316 U.S.C. § 1333(e)(2). 

54H.R. 249, 110th Cong. (2007). The bill was passed by the House of Representatives on 

April 26, 2007. As of August 31, 2008, the Senate had not acted on the bill.

Page 60 GAO-09-77 BLM’s Wild Horse and Burro Program 
Other than one pilot project, BLM has not initiated strategies to reduce the 

number of horses they currently manage in long-term holding and has not 

formally considered other possible solutions to indefinitely caring for 

horses in long-term holding. BLM officials who lead state Wild Horse and 

Burro Programs suggested several actions that could be taken to alleviate 

off-the-range costs to the program, but many of these changes would 

require changes in the law or BLM regulations. The most common 

suggestion, made by 4 of the 10 state leads, was that the federal 

government should provide incentives for private individuals or 

organizations to care for unwanted wild horses, such as monetary 

incentives or tax deductions. In 2003, BLM initiated a pilot project in 

Wyoming to pay private ranchers a one-time lump sum to care for 

unadoptable excess animals. This pilot project ended because of a lack of

up-front funds. In addition, a BLM official familiar with the project told us

that private ranchers had less interest in the project as the market for 

cattle grazing improved. Implementing tax deductions would likely require 

changes in the tax law. Another suggestion made by three of the state 

leads was that the act should be changed to allow the government to 

manage unadoptable wild horses and burros on public or private lands 

outside areas where they were originally found. The act currently does not 

allow BLM to relocate wild horses and burros to areas of public lands 

where they were not found when the act was passed. To date, BLM has not 

sought the legislative changes that would make these suggestions possible. 

The management of a program consisting of wild free-roaming animals is 

unique within BLM, and it presents distinct management challenges. While

BLM has made significant progress in increasing the number of HMAs that 

have set AML and in moving toward meeting AML, its recent removal 

efforts have resulted in the agency managing almost the same number of 

animals off of the range as they manage in the wild. By spending an ever 

increasing amount of funding on caring for animals off the range, little 

funding is left to conduct important on-the-range management activities, 

as originally envisioned in the act. Now that BLM is closer to meeting 

AML, it is important for field offices to have the resources necessary to 

maintain those levels and to monitor whether those levels indeed create 

the “thriving natural ecological balance” called for in the act. 

Conclusions 

Future changes to AML determinations should be based on consistent 

factors across HMAs. With the turnover of the more experienced senior 

BLM staff that set the existing AMLs to newer more junior staff, it is 

important that the newer staff have clear official guidance to follow on 

making AML determinations. It is also important for the management of 

Page 61 GAO-09-77 BLM’s Wild Horse and Burro Program 
the program that BLM have the most accurate population estimates 

possible. While counting wild free-roaming animals is an inherently 

challenging task, the widespread use of statistically based counting 

methods across more HMAs, as appropriate, would provide a scientifically 

sound basis for compensating for possible undercounts. BLM provides a 

great deal of information about the Wild Horse and Burro Program 

through its Web site, including information on AML and population 

estimates for each HMA. However, despite public concerns about the 

humane treatment of these animals, BLM has not provided the public with

easily accessible information about their treatment. In some cases, BLM 

headquarters does not centrally compile information on the treatment of 

animals during gathers. Providing the public with additional information 

on the treatment of animals during gathers and once they are removed 

from the range would help inform the public about their treatment. 

In our 1990 report, we noted that given the amount of federal resources 

needed to maintain unadoptable excess horses in long-term holding, BLM 

would need to seek alternative options. At the time, we recommended that 

BLM consider a variety of disposal options for these horses that were not

being used, including sterilization and euthanasia. Today, about 20 years 

after the first long-term holding facility opened, with adoption demand 

declining and alternative disposal options still not being used, BLM is 

continuing to open new long-term holding facilities to care for 

unadoptable wild horses, and the costs continue to escalate. Cost-effective 

alternatives for long-term holding are still needed. 

BLM is faced with a dilemma as it attempts to comply with the act. On one 

hand, the act directs BLM to protect and preserve wild horses and burros, 

and on the other hand the act directs BLM to destroy excess animals for 

which an adoption demand does not exist or, under certain circumstances, 

to sell them without limitation, which has led to the slaughter of some 

animals. BLM has committed to caring for these animals, even though the 

law requires their humane destruction or sale without limitation and the 

cost for their care off-the-range is now overwhelming the program. The 

program is at a critical crossroads. Within the program’s existing budget, 

BLM cannot afford to care for all of the animals off the range, while at the 

same time managing wild horse and burro populations on the range. 

Resource limitations are forcing BLM to reconsider all available 

management options, and a workable solution must be developed to bring 

BLM into compliance with the act. 

Page 62 GAO-09-77 BLM’s Wild Horse and Burro Program 
We make five recommendations to the Secretary of the Interior. 

To improve the management of BLM’s Wild Horse and Burro Program, we 

make four recommendations that the Secretary of the Interior direct BLM 

to: 

Recommendations for 

Executive Action 

• finalize and issue the new Wild Horse and Burro Program Handbook

that establishes a policy for setting AML to ensure that AML is 

determined based on consistent factors across HMAs into the future; 

• continue to adopt and employ statistically based methods to estimate 

animal populations across HMAs, such as those being evaluated by 

animal population researchers, to improve the accuracy of population 

estimates integral to BLM’s management of wild horses and burros on 

the range and in planning for capacity needed for excess animals once 

they are removed from the range;

• track the number of animals harmed or killed during the gather process 

in a centralized database system and determine what information on 

the treatment of gathered animals, short-term and long-term holding 

animals, and adopted animals could easily be provided to the public to 

help inform them about the treatment of wild horses and burros; and 

• develop cost-effective alternatives to the process of caring for wild 

horses removed from the range in long-term holding facilities and seek 

the legislative changes that may be necessary to implement those 

alternatives.

To address BLM’s noncompliance with the act, as amended, we 

recommend that the Secretary of the Interior direct BLM to discuss with 

Congress and other stakeholders how best to comply with the act or 

amend it so that BLM would be able to comply. As part of this discussion, 

BLM should inform Congress of its concerns with (1) the act’s requirement 

for the humane destruction of excess animals and (2) the possible 

slaughter of healthy horses if excess animals are sold without limitation, 

under certain circumstances, as the act requires.

Page 63 GAO-09-77 BLM’s Wild Horse and Burro Program 
We provided a draft of this report to the Department of the Interior for 

review and comment. The department concurred with our findings and 

recommendations and believes they will help to improve the Wild Horse 

and Burro Program. In addition, the department provided several technical 

clarifications, which we incorporated as appropriate. Appendix IV 

contains the Department of the Interior’s comment letter. 

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the Secretary 

of the Interior, the Director of BLM, and other interested parties. We will 

also make copies available to others upon request. In addition, the report

will be available at no charge on the GAO Web site at http://www.gao.gov. 

Agency Comments 

and Our Evaluation 

If you or your staff has any questions about this report, please contact me 

at (202) 512-3841 or nazzaror@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix V. 

Sincerely yours, 

Robin M. Nazzaro 

Director, Natural Resources and Environment 

Page 64 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix I: Objectives, Scope, and 

Methodology 

Page 65 GAO-09-77 BLM’s Wild Horse and Burro Program 

Appendix I: Objectives, Scope, and 

Methodology 

We examined (1) the Bureau of Land Management’s (BLM) progress in 

managing wild horses and burros on the range through setting and meeting 

appropriate management levels (AML); (2) BLM’s management of wild 

horses and burros off of the range through adoption, sales, and holding 

facilities; (3) the controls BLM has in place to help ensure humane 

treatment of wild horses and burros; and (4) what challenges, if any, BLM 

faces in managing for the long-term sustainability of the Wild Horse and 

Burro Program. We were also asked to review how and why the acreage 

available for wild horses and burros had changed since the 1971 act. We 

did not examine the acreage issue because BLM is in the process of 

compiling a history of acreage determinations. BLM officials expect their 

review to be completed by March 2009. 

To examine how BLM manages wild horses and burros on and off of the 

range and to identify the challenges facing BLM, we reviewed relevant 

laws, regulations, BLM policy, and BLM strategic plans. We also surveyed,

and analyzed documents from, 26 of the 44 BLM field offices that manage

wild horses and burros.1

 We collected and reviewed relevant resource 

management decision documents from the surveyed field offices to help

corroborate their responses about specific questions, including those 

about factors used to make AML determinations and gather decisions. We 

surveyed field offices in all 10 western states that manage HMAs. The field

offices we surveyed represent 82 percent of all BLM acres managed for

wild horses and burros, 74 percent of all BLM managed wild horses, and 

69 percent of burros on the range at the time of the survey. Our survey 

sample included 100 percent of the BLM field offices that manage HMAs in 

Nevada, including the Tonopah Field Station (seven offices); three 

randomly selected field offices from each of the five states whose field 

offices or district offices manage a population of wild horses and burros 

that fall between 1,000 and 10,000 horses (Arizona, California, Oregon, 

Utah, and Wyoming); and one randomly selected field office from each of 

the four states whose field offices manage a population of wild horses and 

burros that is less than 1,000 (Colorado, Idaho, Montana, and New 

Mexico). Because most of our survey questions focused on the 

management of a particular HMA, we judgmentally selected an HMA for 

each field office to consider in responding to our survey. We considered a 

 1

We drew our sample of 26 field units from among the 44 field units that manage Herd 

Management Areas (HMA), which include 39 field offices, 4 district offices in Oregon, and 

1 field station in Nevada. We will refer to these 44 BLM field units collectively as field 

offices. BLM’s count of the number of offices that manage HMAs may differ because the 

4 district offices in Oregon manage 7 resource area offices. 
Appendix I: Objectives, Scope, and 

Methodology 

variety of factors in making these HMA selections, including herd 

population size and whether the HMA had met or not met AML (according 

to 2007 BLM Statistics). Table 15 lists the 26 BLM field offices and HMAs 

we selected as part of our survey. 

Table 15: BLM Field Offices and HMAs Included in GAO’s Survey 

BLM field office by state HMA 

Arizona

Yuma Field Office Cibola–Trigo 

Hassayampa Field Office Lake Pleasant 

Kingman Field Office Black Mountain

California

Surprise Field Office High Rock 

Alturas Field Office Red Rock Lakes 

Ridgecrest Field Office Centennial 

Colorado

White River Field Office Piceance–East Douglas Creek

Idaho

Four Rivers Field Office Four Mile 

Montana

Billings Field Office Pryor Mountain Wild Horse Range 

Nevada

Tonopah Field Station Montezuma Peak 

Battle Mountain Field Office South Shoshone 

Carson City Field Office Flanigan 

Elko Field Office Rock Creek 

Ely Field Office Dry Lake 

Las Vegas Field Office Red Rock 

Winnimucca Field Office Granite Range

New Mexico

Socorro Field Office Bordo Atravesado 

Oregon

Prineville District Office Liggett Table 

Lakeview District Office Beaty’s Butte 

Vale District Office Coyote Lake–Alvord Tule Springs 

Page 66 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix I: Objectives, Scope, and 

Methodology 

BLM field office by state HMA 

Utah

Richfield Field Office Canyon Lands

Vernal Field Office Hill Creek 

Fillmore Field Office Conger 

Wyoming

Rock Springs Field Office Divide Basin 

Cody Field Office McCullough Peaks 

Lander Field Office Dishpan Butte

Source: GAO.

The survey included several open-ended responses aimed at determining 

the primary challenges associated with meeting and maintaining AML, the 

primary challenges facing the Wild Horse and Burro Program as a whole, 

and suggestions for ways to improve the program. Two GAO analysts 

independently reviewed these open-ended survey responses, agreed upon 

the categories for coding each response, and resolved any disagreements 

in coding to determine what the respondents as a whole thought about 

these issues. 

The practical difficulties of conducting any survey may introduce errors, 

commonly referred to as nonsampling errors. For example, difficulties in 

how a particular question is interpreted, in the sources of information that 

are available to the respondents, or in how the data are entered into a 

database or were analyzed can introduce unwanted variability into the 

survey results. We took steps in the development of the questionnaire, the 

data collection, and the data analysis to minimize these nonsampling 

errors. For example, survey specialists designed the questionnaire in 

collaboration with GAO staff with subject matter expertise. Then, the draft 

questionnaire was pretested with officials from five BLM field offices in 

four different states to ensure that the questions were relevant, clearly 

stated, and easy to comprehend. We also conducted follow-up phone calls 

to clarify ambiguous or incomplete responses. We received usable 

responses from all field offices that we surveyed—a 100 percent response 

rate. See appendix III for a summary of the survey responses not 

presented elsewhere in the report. 

We also interviewed agency officials at BLM Headquarters; the National 

Program Office in Reno, Nevada; and Wild Horse and Burro Program State 

Leads from each of the 10 states that manage wild horses and burros. In 

addition, we conducted site visits at two field offices that manage HMAs in 

Nevada and Colorado; one long-term holding facility in Oklahoma; three 

Page 67 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix I: Objectives, Scope, and 

Methodology 

short-term holding facilities in Colorado, Nevada, and Wyoming; and 

attended two adoption events in Arizona and Colorado. 

To examine humane treatment, we reviewed relevant laws, regulations, 

and BLM policies. We collected and analyzed reports from BLM 

Headquarters, state offices, and data from BLM’s compliance database. We 

also interviewed BLM compliance officials from two states, a veterinarian 

from the Department of Agriculture’s Animal and Plant Health Inspection 

Service, and public citizens and advocacy groups that work to promote the 

well being of wild horses and burros. 

As part of our overall methodology, we interviewed a range of 

stakeholders interested in BLM’s management of the Wild Horse and Burro 

Program, including, but not limited to, the American Wild Horse 

Preservation Campaign, the Animal Welfare Institute, the Cloud 

Foundation, the Humane Society of the United States, the National 

Cattlemen’s Beef Association, and Nevada Bighorns Unlimited. 

We conducted this performance audit from September 2007 to October 

2008 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Page 68 GAO-09-77 BLM’s Wild Horse and Burro Program 
A

Var

ppendix II: Fertility Control and Genetic 

iability 

Page 69 GAO-09-77 BLM’s Wild Horse and Burro Program 

Appendix II: Fertility Control and Genetic 

Variability 

In addition to the information provided in this report to answer our 

primary objectives, we encountered two other issues related to BLM’s 

management of the Wild Horse and Burro Program. The issues primarily 

relate to BLM’s on-the-range management activities, including fertility 

control and genetic variability. 

BLM has been pursuing a fertility control vaccine called porcine zonae 

pellucida since 1992 to use as a tool for slowing the reproductive rate in

wild horse populations. A slower reproductive rate would reduce the 

number of animals that would have to be gathered and removed, adopted, 

and held. BLM officials do not consider this treatment as the best shortterm management tool to achieve AML but believe that once HMAs are at 

AML, fertility treatment can help to maintain that level. Much research has 

been conducted about the use of the vaccine in domestic and wild horses. 

The Department of the Interior’s National Park Service has used this 

treatment to successfully manage wild horse populations at two national 

seashores. BLM field offices have been directed to consider the use of 

fertility control as an alternative in their gather plans, but they are not 

required to choose this research tool. The vaccine is considered 

experimental, and as such, there are barriers to its use. Since 2004, 

47 HMAs have used fertility treatments, and a total of about 1,800 wild 

horses have been injected with the treatment. BLM considers the use of 

this treatment as a research tool; however, according to a prominent wild 

horse fertility researcher, BLM should more actively pursue its use as a 

management tool. According to BLM officials, fertility control may offer 

the possibility of reducing reproduction rates and costs, but BLM will still 

need to place horses in long-term holding in the future. 

Herd health is another important component of BLM’s on-the-range 

management of wild horses and burros. Specifically, it is important to 

maintain a degree of genetic variability to decrease the likelihood of 

disease and to maintain the biological fitness of the population. The 

amount of genetic variability that is sufficient to maintain a healthy 

population, however, is difficult to discern. Some groups have criticized 

BLM for setting AMLs at levels that are less than 100 or 150 animals. As of 

February 2008, 135 of the 199 HMAs had an upper limit of 150 or less for 

AML (see table 16). Several of these smaller HMAs, however, are part of a 

complex of HMAs that are managed as one unit where there is regular 

genetic interchange. For example, 13 complexes in Nevada encompass 

45 of their 102 HMAs. According to a leading researcher in the field of wild 

Fertility Control 

Genetic Variability 
Appendix II: Fertility Control and Genetic 

Variability 

horse genetics, however, a herd that has a population of less than 100 can 

be maintained with the introduction of at least one or two horses every 

6 to 7 years, including those whose herd size are as small as 10 to 

15 horses. 

Table 16: Number of HMAs Managed at Various AMLs, February 2008

Upper limit of AML Number of HMAs

0 8

1–100 102

101–150 25

151–200 16

201–300 25

301–500 16

501–1,000 5

Not yet determined 2

Total 199

Source: BLM.

BLM manages a few herds that show strong evidence of old Spanish 

heritage which no longer exists outside of the Americas. For example, the 

Kiger Mustangs of Oregon and the Pryor Mustangs of Montana have some 

colonial Spanish traits. For most of the HMAs, however, genetic variability 

is important primarily in maintaining the health of the herd, rather than 

managing for a specific genetic trait or bloodlines. 

Page 70 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix III: 

Results 

Wild Horse and Burro Survey

Page 71 GAO-09-77 BLM’s Wild Horse and Burro Program 

Appendix III: Wild Horse and Burro Survey 

Results 

The following tables summarize responses collected through our survey 

instrument that was sent to 26 BLM field offices that manage HMAs. See 

appendix I for a complete explanation of which offices were chosen and 

the methodology used to select those field offices and specific HMAs. Our 

survey was divided into two sections. The first asked questions specific to

the field offices’ management of particular HMAs. The second section 

asked questions related to the field offices’ general management of all 

HMAs.

1

Table 17: Current and Initial AML and Year of Determination per HMA Surveyed

HMA, by state

Initial

AML

Year initial 

AML was set 

Current 

AML

Year current 

AML was set

Arizona

Cibola–Trigo 315 1980 a a

Lake Pleasant 80 1988 208 2000

Black Mountain 148 1978 478 1996

California

High Rock 70–100 1981 78–120 2001

Red Rock Lakes 16–25 1981 a a

Centennial 168 1980 168 2005

Colorado

Piceance–East Douglas 

Creek 90–140 1981 135–235 1999

Idaho

Four Mile 37–60 2001 a a

Montana

Pryor Mountain Wild Horse 

Range 121 1984 95 1992

Section I: Field Office 

Responses Specific to 

Selected HMAs 

 1

Eight of the 26 field offices surveyed manage only one HMA. 
Appendix III: Wild Horse and Burro Survey

Results 

HMA, by state

Initial

AML

Year initial 

AML was set 

Current 

AML

Year current 

AML was set

Nevada

Montezuma Peak 161 1974 0 2007

South Shoshone 78 1986 60–100 2005

Flanigan 83–125 1990 a a

Rock Creek 119 1987 250 2003

Dry Lake 82 1983 94 2001

Red Rock 116 1982 41–76 2004

Granite Range 155–258 1993 a a

New Mexico

Bordo Atravesado 20–30 1980 50 1991

Oregon

Liggett Table 10–25 1989 a a

Beaty's Butte 234 1971 100–250 1983

Coyote Lake–Alvord Tule 

Springs 198–390 1978 a a

Utah

Canyon Lands 60–100 2001 a a

Hill Creek 195 1985 a a

Conger 34 1977 40-80 1987

Wyoming

Divide Basin 425–588 1979 415–600 1997

McCullough Peaks 70–140 1985 70–140 1990

Dishpan Butte 35–50 1983 50–100 1993

Source: GAO survey results. 

a

At the time of our survey, AML for 9 of the 26 HMAs we selected had not been revised since it was 

initially set. For those 9 HMAs, the initial AML and the year initial AML was set is also the current AML 

and the year current AML was set.

Table 18: Level of Data Sufficiency Used to Determine Current AML

Level of sufficiency Number of respondents

Very sufficient 15

Moderately sufficient 7

Moderately insufficient 2

Very insufficient 1

Unsure/don’t know 1

Source: GAO survey results. 

Page 72 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix III: Wild Horse and Burro Survey

Results 

Table 19: Respondents’ Opinions about Current AML 

Current AML Number of respondents

Too high 3

About right 17

Too low 2

Unsure/don’t know 4

Source: GAO survey results. 

Table 20: Population Level in Comparison with AML Range

Population level Number of respondents

Above 15

Within limits 10

Below 0

Unsure/don’t know 1

Source: GAO survey results. 

Table 21: Primary Challenges in Meeting or Maintaining AML

Challenge Number of respondents

Impediments to conducting gathers 20

Lack of sufficient removal outlet 12

Inability to conduct range management 9

Limitations to accurate population counts 8

HMA boundary issues 5

Public pressure to not remove animals 4

Multiple use balance 4

Staffing limitations 3

Litigation 2

Habitat limitations 2

High reproductive rates of the animals 2

Other 2

Source: GAO survey results. 

Page 73 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix III: Wild Horse and Burro Survey

Results 

Table 22: Impact on Rangeland Resources in HMA When Herd Populations Exceed

the Upper Limit of AML by Less Than 25 Percent 

Level of impact 

Rangeland resource Positive

Slightly 

positive

No 

impact 

Slightly 

negative Negative Blank

Horse and burro herd 

health 1 2 10 10 3 0

Rangeland health 0 1 5 10 10 0

Livestock habitat 

requirements 0 1 10 9 5 1

Wildlife habitat 

requirements 0 1 8 9 8 0

Source: GAO survey results. 

Table 23: Impact on Rangeland Resources in HMA When Herd Populations Exceed

the Upper Limit of AML by 25 to 50 Percent 

Level of impact 

Rangeland resource Positive

Slightly 

positive

No 

impact 

Slightly 

negative Negative Blank

Horse and burro herd 

health 1 1 4 10 10 0

Rangeland health 0 0 0 8 18 0

Livestock habitat 

requirements 0 0 4 9 12 1

Wildlife habitat 

requirements 0 0 3 8 15 0

Source: GAO survey results. 

Table 24: Impact on Rangeland Resources in HMA When Herd Populations Exceed

the Upper Limit of AML by 51 to 100 Percent 

Level of impact 

Rangeland resource Positive

Slightly 

positive

No 

impact 

Slightly 

negative Negative Blank

Horse and burro herd 

health 0 1 2 4 19 0

Rangeland health 0 0 0 0 26 0

Livestock habitat 

requirements 0 0 3 3 19 1

Wildlife habitat 

requirements 0 0 3 2 21 0

Source: GAO survey results. 

Page 74 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix III: Wild Horse and Burro Survey

Results 

Table 25: Number of Field Offices That Have or Do Not Have Procedures in Place to

Distinguish Impact of Wild Horses and Burros, Cattle, and Wildlife on Rangeland 

Condition 

Procedure to distinguish impact Number of respondents

Yes 20

No 6

Unsure/don’t know 0

Source: GAO survey results. 

Table 26: Actions Taken to Manage HMAs Since 2000 

Action taken Yes No

Don’t 

know 

Not 

applicable Blank

Conducted population inventory 24 2 0 0 0

Conducted gathers and removals 23 3 0 0 0

Reduced or modified livestock use 15 7 0 4 0

Increased resource monitoring 14 10 2 0 0

Vegetative/riparian restoration 14 11 1 0 0

Other land management actions 12 2 1 2 9

Changed AML 7 18 1 0 0

Source: GAO survey results. 

Table 27: Number of HMAs with a Herd Management Area Plan

Plan Yes No

Unsure/don’t 

know

Herd Management Area Plan 16 9 1

Plan to develop a Herd Management Area Plan 8 2 5

Source: GAO survey results. 

Table 28: Primary Physical Method Used in Most Recent Census/Inventory 

Primary method Number of respondents

Fixed-wing aircraft 3

Helicopter 20

Horseback/on foot 2

Don’t know 1

Source: GAO survey results. 

Page 75 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix III: Wild Horse and Burro Survey

Results 

Table 29: Primary Statistical Method Used in Most Recent Census/Inventory 

Primary method Number of respondents

Direct count (single number) 17

Direct count (range) 2

Simultaneous double-count 3

Sightability bias correction model 2

Other 2

Source: GAO survey results. 

Table 30: Level of Accuracy of Most Recent Census/Inventory 

Level of accuracy Number of respondents

Greatly over counted 0

Over counted 0

Counted about right 15

Undercounted 10

Greatly undercounted 0

Unsure/don’t know 1

Source: GAO survey results. 

Table 31: Level of Data Sufficiency Used to Support Most Recent Gather 

Level of sufficiency Number of respondents

Very sufficient 21

Moderately sufficient 4

Moderately insufficient 0

Very insufficient 0

Unsure/don’t know 1

Source: GAO survey results. 

Table 32: Timing of Gather in Relation to Scheduled Date of Gather

Timing of gather Number of respondents

Conducted earlier 2

Neither earlier nor delayed 18

Delayed 4

Unsure/don’t know 2

Source: GAO survey results. 

Page 76 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix III: Wild Horse and Burro Survey

Results 

Table 33: Level of AML to Which HMA Is Typically Gathered

Level of AML Number of respondents

Upper 7

Middle 7

Lower 7

Unsure/don’t know 5

Source: GAO survey results. 

Table 34: Actions Taken to Manage HMA’s Since 2000 

Action taken Yes No

Don’t 

know 

Not 

applicable Blank

Conducted population inventory 19 0 0 0 0

Conducted gathers and removals 18 1 0 0 0

Reduced or modified livestock use 14 2 1 2 0

Vegetative/riparian restoration 14 5 0 0 0

Increased resource monitoring 12 7 0 0 0

Changed AML 11 8 0 0 0

Other land management actions 6 2 1 0 10

Section II: Field 

Offices’ Responses to 

General Questions 

Regarding All of the 

HMAs They Manage 

Source: GAO survey results. 

Table 35: Field Offices Whose HMAs Have Herd Management Area Plans 

Plan All Some None Unsure/don’t know

Herd Management Area Plan 11 6 8 1

Source: GAO survey results. 

Table 36: Field Offices Working to Develop Herd Management Area Plans for All of 

Their HMAs 

Response Number of respondents

Yes 6

No 8

Source: GAO survey results. 

Page 77 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix III: Wild Horse and Burro Survey

Results 

Table 37: Actions to Help Field Offices Achieve Healthy Herd Populations in 

Balance with the Range and Other Multiple Uses

Actions Number of respondents

Increase range management activities 15

Reach and maintain AML 9

Improve staff capacity 7

Improve census/inventory 7

Increase funding 6

Improve adoption outlet 3

Improve coordination in management 3

Improve access to HMAs 2

Solve long-term holding situation 2

Source: GAO survey results. 

Table 38: Major Challenges Facing Field Offices in Managing HMAs to Achieve 

Healthy Herd Populations That Are in Balance with the Range and Other Multiple

Uses 

Major challenges Number of respondents

Impediments to conducting gathers 13

Staffing limitations 11

Limitations to accurate population counts 8

Inability to conduct range management 8

Multiple use balance 7

Lack of sufficient removal outlet 6

Ability to maintain AML 4

Habitat limitations 4

Other 4

Planning process 3

Public pressure 3

HMA boundary issues 3

Source: GAO survey results. 

Page 78 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix III: Wild Horse and Burro Survey

Results 

Table 39: Major Challenges Facing BLM’s Wild Horse and Burro Program As a 

Whole

Major challenges Number of respondents

Lack of sufficient removal outleta18

Staffing limitations 11

Inability to conduct range management 8

Public pressure 7

Impediments to conducting gathers 5

Unwanted horses released to BLM lands 5

Funding 3

Lack of support 3

Limitations to accurate population counts 2

Habitat limitations 2

Lack of management flexibility 2

Multiple use balance 2

Poor public perception 2

Source: GAO survey results. 

a

Removal outlet limitations include decreased options for animals once removed from the range, such 

as decreased adoptions, expense of caring for animals removed from the range, and limited capacity 

in long-term holding facilities.

Page 79 GAO-09-77 BLM’s Wild Horse and Burro Program 
Appendix IV: Comments from the Department of the 

Interior 

Page 80 GAO-09-77 BLM’s Wild Horse and Burro Program 

Appendix IV: Comments from the 

Department of the Interior 
Appendix V: 

St

GAO Contact and 

aff Acknowledgments

Page 81 GAO-09-77 BLM’s Wild Horse and Burro Program 

Appendix V: GAO Contact and Staff 

Acknowledgments 

Robin M. Nazzaro, (202) 512-3841 or nazzaror@gao.gov

In addition to the individual named above, Jeffery D. Malcolm, Assistant 

Director; Ulana Bihun; Kevin Bray; Lee Carroll; Benjamin Shouse; Gregory 

Wilmoth; and Elizabeth Wood made key contributions to this report. Also 

contributing to the report were Beverly Ross and Monica Wolford. 

 

GAO Contact 

Staff 

Acknowledgments 

(360883) 
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