I am assuming the current…

I am assuming the current population of Double-crested Cormorants (DCCO) is above its threshold and that's why these harvest regulations seem similar to that of the Snow Goose (SNGO; 50/day, unlimited poss.)- that's a lot of birds. 50 birds/day, I don't think is as attainable as one may think. In the SNGO example, we can harvest 50 birds/day because they are gregarious feeders. large groups typically mean large amounts of food, which in tern allows us to harvest large numbers. Is this the same for the DCCO? Sure, they nest and loaf in colonies, but do they feed in large groups? That raises some serious concern for harvest, which would likely target nesting colonies- areas with large numbers of birds. However, I don't know of many people who would go out to shoot 50 birds/ day. Again, to put things into perspective, I can go to a nesting colony, shoot 50 birds, and leave every carcass where it lies. I can do this every day of the season. I think this aspect leaves room for kickback from the public. In my opinion, shooting 50 birds and allowing meat to spoil is a cull. Putting lipstick on a pig and calling it your girlfriend does not make it a pretty lady who loves you dearly. Obviously, the above is entirely dependant on hunter participation.

There is also a concern regarding legislation amendments. Once we start making alterations to provincial legislature, will we see a cascade of other changes; and, will these amendments be made using sound, scientific evidence? I think this should be avoided. As conservationists we owe it to the birds. Spoiled meat is not acceptable. If this species is to be managed as a game bird, then no meat should go to spoil- period. I'd like to see the "spoil amendment" kyboshed. If not, and they have the ability to amend the FWCA, why not allow the commercial sale of the harvested birds. At the very least, an application for a commercial permit which allows a set number of individuals to harvest and sell the birds for profit. The permit would allow commercial harvest to take place in the March-December season; while small games license holders could harvest during regular season (September-December). This way, managers can keep a closer eye on purposeful harvest during commercial seasons, while hunters retain the ability to do their part. This could even be used as an additive management tool with less "cull-like" appeal.

Season timing and length are another concern. The season would be open during the spring migration various migratory waterbirds/waterfowl. Harvest would focus on and around colonies where other, FEDERALLY PROTECTED colonial birds’ nest, increasing the possibility of misidentification and accidental harvest. Furthermore, the colonial behaviour means they also share nesting sites with Gulls, Terns, and other water birds. The proposed hunting season overlaps with their nesting periods, which is not ideal as colonial species don't typically take well to disturbance while nesting. This should be a concern for managers, especially when the Black-crowned Night Heron (Species at Risk) is involved.

The timing poses additional risk for negative interactions between hunters and recreationalists (fishing, boating, kayaking, etc.). Primarily, during the summer months when there is an increase in watersport activities. This isn't a concern during the regular waterfowl season, as most individuals who partake in boating activities have retired for the season. A simple strategy may be to prohibit harvest in specific areas; or, make the cormorant-specific season line up with the regular waterfowl season. This addresses the misidentification issue, making it "acceptable"; it separates the two recreational groups; and alleviates all unwanted pressures on other nesting species. Of course, a separate set of rules/regulations would need to be developed for commercial permit holders.

A couple additional questions come to mind when I read the proposal:
- Enforcement in particular, are there even enough provincial officers to enforce the alternate regulations during open fishing seasons? We barely have enough enforcement to cover fishermen standing on shorelines, let alone new migratory bird hunters spread throughout the province.

- Do we have sufficient evidence that they are even impacting sport/commercial fisheries; and, if we do, at what spatial scale is it occurring? It sounds like this is a provincial wide cull on the DCCO. I think we should be assessing these impacts case by case. I also think that understanding the DCCO colonies’ interspecific interactions on the landscape at given time periods may be something mangers need to investigate further, especially before we implement a province-wide harvest.

o Example: Is colony (A) more of an inter-species competition concern, whereas colony (B) is simply and overabundant breeding colony. We may find that different management tools work better for the different colonies. If we intend on designating these birds “Game Birds”, we need to manage them as such.

Harvest is useful, especially when disturbance isn’t a concern for managers. However, targeting the breeding adults on a colony can be difficult- this is what is needed if we intend on reducing overall numbers. Inversely, management could become a provincial responsibility. This would benefit areas where interference and disturbance of nesting birds is a concern. Simple techniques such as egg oiling or egg and nest removal have worked in the past (Canada goose and various Gulls).

These are just a couple things that come to mind. I’m at a stand still. I don’t think we have enough supporting evidence to warrant the development of a species-specific harvest with extremely liberal limits. Though, at the same time, I agree that something needs to be done. I would be in favour of a government-based intervention that does not require the province to revise legislature. I also think the spoiling of meat issue needs to be addressed pending the implementation of the hunting season.

Overall, the proposal is unique. As a hunter, it does not seem like something I would be interested in participating in. By no means would this be a hunting season, the management strategy proposed seems more like a killing spree. And to be honest, it almost seems like the government wants hunters to do their dirty work; and unfortunately, the public will paint all hunters with the same brush. However, if it comes down to a cull-like management practice, I would hope the evidence supports the decision; and, that managers are open to alternative forms of professional, though resourceful management.

If it makes any difference in the credibility of my arguments, I am a future graduate student studying the effects of development on nesting waterfowl. I have my Honours degree in Biology, and my Fish and Wildlife Technician and Technologist diplomas.