The draft management plan for grizzly bears is inadequate and does not protect Montana’s premier wildlife species. We need solid, quantifiable protections for grizzlies and their habitat, yet no substantial protections exist in the current draft. This plan needs many changes including the following:

1. PROVIDE ACCOUNTABILITY - The plan includes many "considerations" but few requirements for agency action. There is no program schedule or implementation plan to demonstrate that certain provisions of this plan will be carried out, and how. The plan needs to be changes to: 1. add details on how the plan will be implemented; 2. provide benchmarks for evaluating the success or failure of the plan, and a process for examining these yearly and releasing the results to the public; and 3. seek the authority to enforce sanitation/food storage orders and habitat protection for grizzly bears on public lands (e.g. road closure enforcement, illegal ATV use), which will be necessary to implement the plan.

2. NO GRIZZLY HUNT: Montana should throw out plans to renew a grizzly bear hunt. There is clear evidence that the Yellowstone grizzly bear population is at long-term risk due to the increasing human population increases in southwestern Montana, ongoing development of important grizzly habitat on public and private lands, threats to key grizzly bear foods, and the isolation of Yellowstone grizzly bears from other populations north and west. Furthermore, the high levels of human-caused mortality in Yellowstone must be brought under control before a hunt is considered. Montana must redouble current efforts to reduce the two greatest human causes for bear mortality: habituation and big-game hunting conflicts.

3. PROTECT HABITAT: Habitat protections must be strengthened in this plan. Grizzlies require large blocks of unfragmented and undeveloped wild lands in order to survive. Clear cutting, road building, oil and gas development, off-road vehicle use (ORV) and real estate development continue to degrade important grizzly bear habitat. This reduces their ability to forage and increases their chances of conflict with humans. The following changes/additions need to be made to the plan:

*Phase out sheep allotments in occupied grizzly bear habitat.

*Special protections should be afforded to bear habitat that connects Yellowstone to other ecosystems. Stronger directives should be given to leveraging FWP state private lands protection funds for this effort, perhaps matched with private and federal lands.

4) ENSURE ADEQUATE FUNDING: The state must commit adequate funding to ensure that the plan is implemented, recognizing the loss of ESA Section 6 funding after delisting, and this plan needs to document where additional funds will come from.