Comment regarding EBR number…

Comment regarding EBR number 013-4124: Proposal to establish a hunting season for double-crested cormorants in Ontario.

This proposal, if enacted, would cause harm to Great Lakes ecosystems and would not have the effects hoped for by commercial fishing and property owner groups. The changes proposed would have unpredictable repercussions to fisheries and lake ecology, cause avoidable suffering to nesting birds and nestlings of many species, set several bad precedents that may open the door to poorly planned, reactionary wildlife management practices in the future, and reflect badly on hunters and the Province of Ontario.

While cormorant numbers are at a historically high level, the driving factors behind this increase are anthropogenic changes in the ecosystem, such as the addition of nutrients to the water, making the system more biologically productive and changing the system from a cold-water fishery to a warm-water fishery; the introduction of several invasive, non-native species; and climate warming. Energy and nutrients now flow through the food web, supporting more biomass in prey species through to the top predators like cormorants. There are now more shallow, warm-water fish species like yellow perch, sunfish, bass and pike, and exploding numbers of introduced species like round goby, white perch and alewife. Cormorant populations have reacted to this increased food availability and not suddenly become detrimental to fish populations.
Cormorants now play an important role as top predator in the new regime. They provide the ecosystem services of limiting prey populations and helping balance the food web as it reacts to changing conditions and human-caused perturbances, in fact making the system more stable and robust. In addition, cormorants help keep invasive species populations in check. For example, in a 2016 study on Lake Michigan, (https://www.sciencedirect.com/science/article/pii/S0380133015002750), Madura and Jones found that “Invasive species, most notably alewife, round goby, and white perch, contributed over 80% and 90% of the diet of cormorants by biomass and number, respectively.” The study concluded that its “results do not support the active management of the cormorants … to protect or recover local fisheries.” The significant reductions in cormorant populations that the proposed hunting season would cause would clearly allow an increase in populations of invasive species, which would have detrimental effects on fisheries and biodiversity in the Great Lakes and reduce the capacity of the system to “buffer” the effects of future invasive species introductions. Cormorant populations are ecologically important and should not be hunted in order to reduce their numbers.
The proposed changes to allow for a high bag limit, the spoilage of meat, hunting from a stationary motorboat and hunting during the bird breeding season are problematic on many fronts. This will enable hunters to approach island breeding colonies closely and kill hundreds of birds at a time from just one boat. This would cause panic, trampling, and abandonment of nests with young birds. Given the disturbance it would be impossible to keep tracked of bag limits. After the shooting, hunters would then have to go ashore, collect and properly dispose of carcases, causing even greater disturbance to breeding birds. Most cormorant breeding colonies contain other non-target species, including protected and declining species such as the common tern, which would also lose nests in the chaos. Nestlings of all species would die of exposure and starvation. This suffering would be seen publicly and internationally as extreme cruelty and probably violates laws protecting animals from such treatment. Additionally, many colonies are on protected islands such as the Limestone Islands in Georgian Bay (Killbear Provincial Park), nature reserves such as Snake and Salmon Islands in Lake Ontario, and on privately owned islands. It would be very difficult and expensive to regulate and enforce any hunt that would spill over to such lands. Summer hunting also has great potential to cause disturbance to cottagers, local residences and safety issues with recreational boating.
Many people view sport hunting as a legitimate activity that provides food and gets people out into nature. The proposed changes would darken this image and turn sport hunting into killing for killing’s sake, undermining the practice and image of hunting as disciplined, government-regulated and conservation-minded. This proposal harkens back to the disgraceful days of unregulated market and plume hunting and evokes the loss of the Great Auk, Passenger Pigeon and Carolina Parakeet.
Finally, these unprecedented changes would make it to too easy for similarly ill-conceived, reactionary management efforts to be levelled against other native species that are sometimes seen as competing with people for resources or considered unaesthetic. These changes would result in behaviour and levels of killing and cruelty that will be documented by the media and seen by the public as a massive wildlife cull. No sensible government ministry would proceed with this proposal, given these risks.