I disagree with the proposal…

I disagree with the proposal and think that it should not proceed for the following reasons:
1. The proposal does not include any scientific evidence or justification indicating the need for this new hunting population management tool
a. The proposal indicates that the “latest information” indicates that “Great Lakes populations have stabilized or declined slightly.” There is no population explosion that requires the establishment of a hunting season.
b. The proposal states that it is to respond to concerns expressed by some groups and individuals that cormorants have been detrimental to fish populations; however, this is not supported by scientific evidence. Scientific evidence indicates the opposite to these concerns, specifically:
i. federal government Canadian Wildlife Service studies show that less than 2% of cormorant’s diet consists of sport fish
ii. federal government’s Canadian Wildlife Service studies show that less than 1% of the cormorant’s diet consists of fish that sport fish eat
iii. scientific studies indicate that cormorants mostly feed on fish that are a problem which are also fish that humans do not want to eat (i.e. non-native alewife and round gobies).
c. The proposal states that it is to respond to concerns expressed by some groups and individuals that cormorants have been detrimental to island forest habitats; however only a small number of islands (less than 3%) and peninsula sites are available for cormorants and other colonial waterbirds to nest on in Ontario. There is no widespread detriment to island forest habitats and no scientific evidence is cited to support this concern.
d. The proposal states that it is to respond to concerns expressed by some groups and individuals that cormorants have been detrimental to “other species” but no scientific studies are cited to indicate what species or how cormorants have been detrimental to these unknown species.
e. The proposal states that it is to respond to concerns expressed by some groups and individuals that cormorants have been detrimental to aesthetics, but no scientific studies have been cited to support this. While cormorants do produce guano and may not be the most attractive of birds, other species also can be described this way. No detailed or factual scientific support is provided for singling out cormorants for hunting. In addition, no consideration has been taken for the negative aesthetics of dozens, hundreds, or whole colonies of rotting cormorants in local waterway locations frequented by recreational water users.
f. No rationale is given for the high daily bag limit
g. There is no population management target or rationale for a population management target.

2. The proposal fails to recognize the environmental and social consequences of implementation of the proposal
a. The proposal states that the environmental consequences of the new population management tools are expected to be neutral in that the levels of harvest are not expected to affect sustainability; however, no scientific evidence is cited to support this.
b. Environmental consequences include:
i. Piles of dead cormorants left to spoil and contaminate recreational waterways with bacteria and foul smells
ii. Hunting in breeding season will cause disruption and mortality of other birds nesting nearby due to nest failure and chick starvation when other nearby nesting bird species abandon or retreat from caring for their young (e.g. Blue Herons, Great Egrets, Black-crowned Night Herons, Caspian Terns, Common Terns)
iii. The daily limit could easily enable a few hunters to eliminate a colony of double-crested cormorants in a day and there is no indication that the proposal has taken into consideration how this could affect the ecosystem in the areas where this occurs.
iv. Endangering public recreational waterbody users by allowing hunters to shoot from stationary boats throughout out the recreational boating season of spring/summer/fall.
v. Giving Ontario a black eye for tourism as a destination where birds are hunted not for food, but simply to cater to special interest groups who have no scientific grounding for their concerns.