Species currently listed as …

Species currently listed as "Game Birds" and having open seasons in Ontario are:
- Gray Partridge
- Ptarmigan
- Ring-necked Pheasant
- Ruffed Grouse
- Spruce Grouse
- Sharp-tailed Grouse
- Wild Turkey
(Source: Ontario open seasons regulation (670/98))

All of these species are edible and have historically been hunted for food as well as for sport. None of them are migratory. They all create hidden nests in forested areas, well separated from each other.

Open seasons for all these species are from Sept. to March (or Sept. to Dec. in some cases), except for Wild Turkey, which has a more limited open season. Daily bag limits range from 2 to 10, and possession limits from 6 to 15.

The bag limits and possession limits in place are designed to prevent any one hunter or group of hunters from depleting the population of game birds in an area. The hunting seasons are during the fall and winter to avoid killing the birds while they are breeding and replacing their losses from the hunting season.

These regulations exist because, historically, unregulated hunting depleted the populations of every species of bird, exterminated some species from settled areas (e.g. Wild Turkey from Ontario, Trumpeter Swan from the continental U.S. and Canada, and Canada Goose from southern Ontario (yes, really!)), and caused the extinction of other species (e.g. Passenger Pigeons and Eskimo Curlews).

The proposal under discussion is remarkably different from the existing regulations:
- open season from mid-March through December
- daily bag limit of 50
- no possession limit
- exemption from prohibitions against letting meat spoil

Double-crested Cormorants are also remarkably different from existing game birds. They are only technically edible (they taste horrible), have not historically been hunted for food (though their eggs have been harvested, and they have been hunted to be used as bait meat), migrate to the southern U.S. during the winter, and (importantly) nest together in the hundreds in obvious colonies.

Cormorants breed in Ontario from mid-April to mid-August. The proposed open season includes their entire breeding season in addition to the traditional fall and winter hunting season. The only time they would not be hunted, January to mid-March, they are not present in Ontario, having migrated to the southern U.S. and the Atlantic coast. During the breeding season, cormorant colonies are highly visible and contain dozens to thousands of pairs. With a 50 per day limit, one hunter could easily exterminate a small colony, and even the largest colony could be exterminated in a few days by a dozen hunters working together.

This seems to be the main aim of this proposal: to allow the culling of cormorant colonies by members of the public. Cormorants have historically been culled because their colonies are ugly (as are the birds themselves) and because they eat fish, which is perceived as competition by fishermen.

The reasons given for this proposal match these historical reasons:
- cormorants deplete fish populations, so they harm the commercial fishing industry
- cormorant colonies harm island forest habitats and other species (they strip sticks from trees for their nests, which kills the trees they nest in)
- cormorant colonies are ugly (the phrase used is "detrimental to ... aesthetics"), so they harm property owners

So, on to my actual comments about this proposal, now that the background has been covered. I oppose this proposal, partly because the arguments in favour are weak, partly because the impact is likely to be larger than estimated, but mostly because amending the Fish and Wildlife Conservation Act is entirely inappropriate for accomplishing (what I believe to be) the goals of this proposal.

The arguments in favour are weak:
- cormorants are far from the main driver behind declines in commercial fish stocks, to the point that it's still an open debate over whether cormorants have a negative effect (some believe they have a positive effect on commercial species because they primarily eat small non-commercial fish ("trash fish") which compete with commercial species), and there are a large number of other fish-eating bird species which nest right along-side cormorants, *yet are not being targeted*
- cormorant colonies are not known to have destroyed habitat critical for any globally threatened species (I ignore here species which are globally common but whose range just barely make it into Ontario; species like this probably shouldn't be listed as threatened or endangered in Ontario, or at least not in the same category as species which are globally rare)
- ugliness is not sufficient reason to kill birds, though it may be sufficient grounds to take non-lethal measures to prevent some specific locations from being used

The impact is likely to be larger than estimated:
- historically, birds which nest in colonies on islands have been by far the most vulnerable to extirpation and extinction due to human action, because a small number of people can harvest thousands of eggs and kill hundreds of birds in a few days, and repeat the process every year because the birds have only a few suitable islands on which to build nests, all of which can easily be scouted every year
- cormorants nest in the same locations as, and scattered among, other species including terns, gulls, herons, and egrets (several species of each type), and destroying a cormorant colony will necessarily involve quite a lot of collateral damage to these protected species (ideally only through disturbance and abandonment of nests, but likely also from accidental shootings and trampling of nests)

But these objections are sideshows. The Fish and Wildlife Conservation Act exists to put reasonable limits on hunting and fishing, so that no one can deplete wild populations and ruin things for everyone else. Its content is all written with this in mind, and deals almost entirely with common situations related to hunting and fishing for food, furs, and other material gain. Cormorants are not and have never been game birds in the common sense of the term, and the proposal is not aimed at instating them as game birds, but is instead intended for wildlife population control. The Fish and Wildlife Conservation Act is not written with wildlife population control in mind. Wildlife control in general, and cormorant culling specifically, is best carried out by the Ministry of Natural Resources and Forestry, not by the very members of the public who have the strongest motivations to over-cull. This is especially true because the Ministry does not require the aid of the public to cull cormorant populations. Double-crested Cormorant colonies are easy to find, few in number, and densely populated, which makes it easy for a small group of people to substantially impact the population with relatively little effort. Given this, the restrictions on their killing should be *more strict than those on existing game birds*, all of which are much more difficult to kill in substantial numbers. This proposal would instead have an open "season" of 10 out of 12 months, a daily limit 5 times larger than any existing limit, and declare cormorants to be an exception to several other existing limits and regulations.

So, I urge those reading this comment to seek a more sensible way to deal with cormorant control, and to actively oppose giving the job to members of the OFAH, some of whom have views on this issue that are out on one edge of the range of opinions held by the informed public of Ontario, and are highly unlikely to restrain themselves to actions which won't upset everyone else.