I oppose this proposal. The…

I oppose this proposal. The overarching reason is the lack of science supporting that there is a problem, and that the theoretical problems that cormorants may pose are not best addressed with this method of population control (thus the stated goal is not supported by the proposal). This proposal is written as a global solution to what may be a local problem that should therefore have local solutions.

1. There is no scientific research given as background information to support any of the claims made by this proposal. Indeed, the phrases used ('concerns expressed by some groups') indicates this is an emotional reaction to a perceived issue, instead of an issue documented by research. This is a problem because humans are not good at accurately judging when something is truly an issue, as in most cases people assume that correlation equals causation, and subjective biases all too easily come into play. Detrimental effects on native fish populations have been extremely hard to document, especially in large systems like the Great Lakes, where cormorants are feeding heavily on non-native alewife and round goby (e.g. see Andrews et al 2012). If the concern is about other lake ecosystems where non-native prey are not established, then the proposal should be focusing on those issues and not confound what is happening on the Great Lakes with what may happen in inland lakes.

2. The proposal states that Great Lakes populations have stabilized or slightly declined. If true, this indicates a possible carrying capacity has been reached. How will hunting result in any long-term and large-scale population reduction (see Lennox et al 2018)?

3. The ecologically sensitive areas that may be affected by cormorant's nesting behaviour are likely ones where hunting is prohibited. Thus hunting as a solution to habitat destruction in these areas cannot be achieved. A proposal for local solutions to these local problems would be much more sensible, likely using trained employees and not the general public.

4. There is no information given on population targets for reduction and how this will be measured. At what scale, especially as these mobile birds may simply move to another location when disturbed? For how long? Is there current monitoring to provide baseline data? Will population reduction of cormorants be the only targeted outcome? What about documenting increased fish abundance? Regrowth of vegetation? Nesting success of black-crowned night herons, great blue herons, etc, that cormorants supposedly impact? Seems that if the proposal claims cormorants are causing these negative effects, the ministry's goals should include establishing that reducing cormorants numbers actually reverses these effects. Otherwise it's just a hunt for the sake of shooting birds to make people feel better.

5. There is no information given on how shooting may affect non-target species, especially species at risk (e.g. nearby nesting birds that may be disturbed by firearm discharge).

For these reasons, the proposal does not meet the standards for burden of proof that cormorants have these effects, and that the proposal would result in these effects being reversed, and so it does not warrant being considered further.