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Dead Foals and Missing Numbers: What the BLM Isn’t Telling the Public
Behind the fences of federal holding facilities, wild horse foals are born — and some die — with little public accounting of their fate. Yet on its own website, the Bureau of Land Management (BLM) insists it “cares deeply about the well-being of wild horses, both on and off the range,” and rejects concerns that its program harms horses.
But FOIA records recently obtained by American Wild Horse Conservation (AWHC) and Animals’ Angels (AA) raise serious questions about what happens to foals once pregnant mares are removed from the range.
The documents suggest that births, stillborn foals, and facility deaths may not be consistently reported — leaving the public with little visibility into how many newborn wild horses survive — or how many die — inside the federal holding system.
Key Findings
- Foals are dying in BLM holding facilities — and the public is not told how many.
- BLM policies allow delayed birth reporting and eliminate required reporting of stillborn foals.
- FOIA records and disposal/rendering documentation show foal deaths that were not publicly reported.
- This is not new. AA exposed major mortality reporting discrepancies in 2013 — including “newborns” and “babies” listed on rendering receipts.
Background

The Bureau of Land Management (BLM) is legally required under the Wild Free-Roaming Horses and Burros Act of 1971 to manage and protect wild horses and burros on public lands. These animals remain federally protected until they are adopted or titled into private ownership.
When the BLM conducts helicopter roundups, pregnant mares are regularly swept into the system. The agency reports how many stallions, mares, and foals it captured — but not how many of the mares were pregnant.
Their foals are later born inside government holding facilities. These are federally protected foals born in federal custody, and the public deserves basic answers: how many are born, how many are stillborn, and how many die.
While the BLM has a limited WHBPS database online to look up foals born at holding facilities, the data does not report any foal deaths or stillborns.
The BLM also does not publish monthly facility-level foaling. And under current policy, facilities may wait up to six months before entering the birth of an “unmarked” foal into the federal Wild Horse & Burro Program System database (per Attachment 1 of Instruction Memorandum IM-2023-019).
During that window, newborn foals may exist in the system without timely documentation of their birth or fate. Without transparent reporting and tracking, these foals could potentially be transferred, sold, or otherwise moved without clear public accountability — creating the risk that some could eventually end up in rodeos, private sales channels, or even the slaughter pipeline.
A Decade of Evidence

Concerns about foal deaths and transparency inside BLM holding facilities are not new.
More than a decade ago, AA uncovered major discrepancies between the number of horse deaths reported by the BLM and the number of carcasses actually sent to rendering facilities.
In a 2013 investigation based on FOIA records and rendering invoices from the BLM’s Palomino Valley holding facility in Sparks, Nevada — the largest wild horse holding facility on BLM managed land — AA discovered alarming inconsistencies.
BLM mortality reports listed 291 deaths between January 2010 and May 2012.
But invoices from the rendering company Nevada By-Products documented 577 dead horses delivered from the facility during the same time period — a discrepancy of 336 animals.

Follow-up AA investigations across multiple states uncovered similar gaps in mortality reporting, raising broader concerns about how deaths within the BLM system are documented.
New FOIA Records Raise New Questions: Foal Deaths Continue Inside Holding Facilities

2025 rendering receipts obtained via FOIA request by AA from multiple BLM off-range holding facilities paint a troubling picture.
For example, rendering receipts from the BLM Palomino Valley Center in Sparks, Nevada indicate that 16 foals were transported to the RRC Companies rendering facility in Reno between March 3 and April 14, 2025 — a period of just six weeks.
EXHIBIT – pages 13–15 of DOI-2025-008570
These foal deaths were not publicly reported in any facility-level mortality summaries available to the public.
Another example appears in FOIA records from the BLM off-range facility in Bruneau, Idaho, operated by contractor J.R. Simplot Company.
Those records indicate that 101 stillborn fetuses and 34 foal deaths — 135 wild horse foals — occurred in less than seven months.
For federally protected animals under government care, such numbers demand public accountability.
Internal Emails Obtained by AWHC Reveal Troubling Attitudes
“We had about 8 still born… if that matters”
FOIA records also provide a glimpse into how foal deaths are discussed internally within the program.
In an internal report dated February 17, 2021, a BLM official wrote:
“Sometime Thursday night we had our first foal born at the facility. The foal was discovered frozen solid Friday morning. We do not know if it was stillborn or froze to death due to the extreme windchill… The result in the wild would have been the same.”
EXHIBIT – page 9 of FOIA #2022-0006434
Another internal email sent from a BLM facility manager at the Canon City off-range corral in Colorado stated:
“1 mare found dead in pen… birthing complications had a still born — Lost Creek HMA.”
The same message continued:
“We had about 8 still born that we know of on various days if that matters.”
EXHIBIT – document titled horse deaths
If personnel responsible for overseeing federally protected wild horses question whether stillborn foals “matter,” it raises troubling questions about how seriously the BLM treats the welfare of animals in its care — and whether foal deaths are being properly monitored, documented, and addressed.
A Quiet Policy Change: The End of Stillborn Reporting
FOIA records also suggest that reporting requirements for stillborn foals may have been quietly weakened.
The BLM issued an Instruction Memorandum (IM 2014-133) in August 2014 that required holding facilities to report stillborn foals to the agency.
However, that memorandum expired in 2015.
In a March 17, 2022 internal email, obtained through FOIA, BLM officials circulated revisions to reporting procedures that included the:
“removal of reporting requirement for stillborn fetuses and foals.”
EXHIBIT – page 1 of FOIA #2022-006434
Researchers reviewing the records were unable to locate any subsequent policy requiring consistent reporting of stillborn foals.
Questions the BLM Must Answer

Foal mortality can occur in any horse population.
But when federally protected foals are born inside government holding facilities, the public deserves a clear and accurate accounting of how many are born — and how many die.
Several basic transparency measures should be implemented:
- Public reporting of how many pregnant mares are captured during roundups
- Consistent and immediate documentation of foal births and stillborn foals in holding facilities
- Mortality records that can be independently compared with contractor disposal or rendering records
Additionally, off-range holding facilities should provide adequate shelter from extreme weather conditions, and roundup schedules should be designed to avoid foaling season whenever possible.
Wild horses are federally protected animals that belong to the American people. If the Bureau of Land Management truly “cares deeply about their well-being,” as it states publicly, that commitment should be reflected not only in policy — but in genuine care, accountability, and transparency.

About American Wild Horse Conservation
American Wild Horse Conservation is the nation’s leading organization championing humane, in-the-wild protection of wild horses and burros on our public lands. AWHC works to advance ethical and responsible conservation of wild horses and burros. In-the-wild conservation is humane, cost-effective, scalable, and based on rigorous science.
Contact: Press@americanwildhorse.org

About Animals’ Angels
Animals’ Angels is a U.S.-based nonprofit organization dedicated to exposing and addressing cruelty and neglect in the livestock and horse industries. Through undercover investigations, documentation, and advocacy, Animals’ Angels works to protect farmed animals and equines from abuse across auctions, feedlots, slaughter pipelines, and transport channels.
Contact: info@animalsangels.org
Animals’ Angels is there with the animals. We bear witness to their neglect and exploitation, making sure their suffering is not hidden. By exposing the truth and demanding accountability, we work tirelessly to end systems of abuse. We will not rest until no animal is harmed — and we will be their voice for as long as it takes.
With your support, our voice grows stronger. Together, we can bring change.
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