Dear Public Input…

Dear Public Input Coordinator,

This comment concerns the Proposal to establish a hunting season for double-crested cormorants in Ontario, ERO/EBR Registry Number 013-4124.

I wish to voice my strong opposition to this wrongheaded policy proposal and respectfully urge the Ministry not to allow it to proceed.

As implicitly acknowledged in the description, the proposed cull of double-crested cormorants (Phalacrocorax auritus) is not based on scientific evidence, but rather on the concerns—unfounded, misleading, anecdotal—of groups such as the commercial fishing industry.

You are no doubt aware that the best available evidence points to the cormorant population having no perceptible effect on commercial fishing, since cormorants rarely eat large, commercially-harvested fish.

Says Environment Canada:

“Studies have repeatedly shown that in a natural environment, cormorants feed primarily on small, largely non-commercial, shallow-water fish.”

“…concerns do not appear to be valid, since studies of cormorant diets in Lake Ontario show that less than 2% of the prey found in cormorant pellets is Lake Trout or salmon. Also, cormorants consume only about 0.5% of the prey fish, which is insignificant when compared to about 13% taken by sport fish.”

What is being proposed is unnecessary and outrageous. The Ministry acknowledges that “the latest information [indicates that] Great Lakes populations have since stabilized or declined slightly” since their peak in the early 2000s.

Even during the period of population recovery and growth from the 1970s to the early 2000s, threats to cormorants continued to be of concern. In 1992, an outbreak of Newcastle disease killed nearly a third of juvenile cormorants in several colonies. A future viral outbreak could potentially devastate the population, especially if it were to come on the heels of a massive cull.

The proposed bag limit of 50 birds per day with no possession limit is unprecedented and dangerously high. Furthermore, it is shameful that the Ministry would allow the spoilage of killed cormorants. This calls to mind the worst hunting excesses of the previous two centuries. It is easy to imagine mounds of dead cormorants rotting. It would be disrespectful of our natural environment and unbecoming of who we are as Ontarians.

Allowing the hunting of cormorant would also present a grave threat to other species, including those protected under the Migratory Birds Convention Act. The common loon (Gavia immer), for example, cannot be easily distinguished from the cormorant on the water. Gail S. Fraser, an Associate Professor at the York University Faculty of Environmental Studies, and an expert on the double-crested cormorant, has been quoted as saying, “An open season on the cormorant is an open season on the loon.”

Even without additional pressures, loon numbers are expected by scientists to decline through much of southern and central Ontario in the coming decades.

To conclude, everything about this proposal is wrong. It is unscientific, unnecessary, and it does not reflect the principles of the Ministry’s Statement of Environmental Values, which calls on the Ministry to apply a “sound understanding of natural and ecological systems” when making decisions.

Thank you for your consideration of my comments.

Sincerely,

[signed]