This proposal is not…

This proposal is not evidently based on any science beyond the self-described anecdotal accounts of commercial fishing industry, property owners, and "individuals" who believe (surely not objectively) that cormorants are bad for industrial fishing or recreation. The United States FWS has estimated that the entire population of cormorants nesting across the Great Lakes region at 200-240,000 birds, having made a substantial recovery since the 1970s, and holding stable since the early 2000s. Under the limits set by this proposal (which would conceivably permit the taking of 14,550 cormorants per person per year), one single hunter could conceivably extirpate the entire Great Lakes population of cormorants in less than two decades. This proposal is, quite simply, an eradication plan for Double-crested Cormorant masquerading as a "sustainable" wildlife management strategy. Furthermore, the suggestion that the implementation of this management plan would be "neutral" completely disregards even the most fundamental aspects of biology, and since cormorants are colonial nesters with other, protected waterbirds, hunting throughout the nesting season places a host of other species at unnecessary risk.
Even the most cursory analysis of its basis, methods, and suggested limits makes it an unconscionable management plan; rather, this is a cormorant eradication proposal masquerading as wildlife management.