RE: Proposal to establish a…

RE: Proposal to establish a hunting season for double-crested cormorants in Ontario -- ERO number 013-4124

I support the comments and position taken by Dr. G. Fraser, Faculty of Environmental Studies, York University (http://gsfraser.blog.yorku.ca/research/conservation/proposed-cormorant-…).
As a proposal coming from the Ontario Ministry of Natural Resources and Forestry (OMNRF), this proposed cull of a native species should be evidence-based with a strong justification based on scientific evidence, not on anecdotal evidence based on the self-serving interests of “some groups and individuals.”

If a disinterested needs analysis that takes into consideration impacts on bird and fish populations determines that a cull is justified, as Dr. Fraser has noted:

“The OMNRF should have a full and detailed rationale to provide justification for this proposal, as well as population modelling exercises, population level targets to support the extreme daily bag numbers being proposed, exactly how the cormorant population will be monitored to determine effects of a hunt and an evaluation of the negative impacts on non-target species.”

To call this potential wholesale, unprofessional slaughter “a population management tool” is an insult to anyone who has any respect for a principled, evidence-based approach to wildlife management, which should be the default modus operandi of the Ministry. If a cull is necessary, it should be carried out by trained professionals if for no other reason than to limit the collateral damage to non-target species.

As it stands, this proposal comes across as a reckless, badly thought-out draconian ad hoc approach to resolving a “problem” using a highly inappropriate and unnecessary “solution”—literally overkill. While appealing to some private interests, this proposal as it stands may very well not be in the public interest and, by the time this is demonstrated, it may be too late to rectify the error.

It seems too often that people create the problems and then the animals pay the cruel price.