Proposal to establish a…

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

The proposal details begin with the paragraph:

Double-crested cormorant (Phalacrocorax auritus) populations declined significantly in the Great Lakes from the 1950s to the 1970s primarily due to environmental contaminants affecting reproduction. Their numbers began to increase rapidly from the 1970s to the early 2000s, with the latest information indicating Great Lakes populations have since stabilized or declined slightly.

No further information is supplied to explain why the population allegedly “increase[d] rapidly”, nor why it might now be in decline. Nor is any evidence (population counts, for instance) supplied to support the statements in the paragraph.

In my view, the Ministry does a disservice by inviting public input without making readily available the data upon which you relied to make these statements. If you have statistics to back up these statements (and I would be very disappointed to learn that you don’t), you should provide them or offer a link(s) to the data. Not providing this information calls into question your claim that this is a species that needs to be ‘controlled’ in some manner (i.e. killed). You should back up your position with readily available, provable facts.

The proposal’s second paragraph reads:

There continues to be concerns expressed by some groups (commercial fishing industry, property owners) and individuals that cormorants have been detrimental to fish populations, island forest habitats, other species and aesthetics.

Presumably the word ‘aesthetics’ is a reference to the fact that, like every other species on earth, cormorants poop. But surely the Ministry cannot consider that sufficient cause for the proposed change under the Fish and Wildlife Conservation Act that would clearly create the potential of extirpating this species completely.

The primary driver of this proposed hunting season would appear to be, then, to satisfy complaints and concerns from commercial fishers. With respect, the science is abundantly clear that commercial fishers and cormorants are not seeking the same prey. Whatever other concerns commercial fishers might have, they can’t defend a position that cormorants are competing for the same fish as the fishers.

The proposed regulatory changes are unwarranted, ill-considered, and not in the public interest:

• The proposed changes are unwarranted because the Ministry has offered no evidence to support that this is a species that has worn out its welcome and needs to be dramatically cut down to size. Since you don’t offer any evidence to support the need for the hunt, I can presume it is being proposed simply to placate commercial fishers who don’t appear to understand who are their real competitors, and to satisfy hunters who enjoy the simple pleasure of killing things, just because they can.

• The proposed changes are ill-considered because of the cavalier way the Ministry proposes to implement them. Let’s begin with the numbers of cormorants hunters will be permitted to kill. The bag limit of 50 birds per day over a 291-day period (March 15 to December 31) means every hunter can kill at least 14, 550 cormorants per year “with no possession limit”. I say ‘at least’ because there will be no practical way to monitor how many they really kill, since it is also proposed to grant permission to just leave the birds lying around to rot. And since they can shoot the birds from stationary boats (your proposal says motorboat but I presume non-powered boats will also have this privilege), dead birds can bob along in the water until they wash up on a shoreline somewhere.

As well, shotguns fired into a cormorant colony are going to end up killing more than just cormorants. This will include many other species who nest or feed in close proximity to cormorants.

• The proposed changes are not in the public interest because they will allow for shooting of birds in Toronto. In case it has escaped MNRF notice, Toronto is a densely populated city and it will only be a matter of time before some hunter misses the birds and hits a kid. It is also not in the public interest because, frankly, why would the public be eager to have lots of dead birds lying on the ground, rotting and stinking (or floating in the water, rotting and stinking)?

You must realize as well those carcasses will attract a substantial rat population – perhaps you should canvass the public on whether they’d prefer to leave the birds alone or to invite an explosion of rats and other carrion-feeders.

Perhaps you should also survey the public to determine how they feel about the inevitable large numbers of birds who are shot, but not killed. Ask them how they feel about the birds being left to die from starvation or the lingering effects of bad marksmanship.

Your proposal also notes:

To accompany the proposed hunting seasons, the Ministry will implement a cormorant monitoring program to assess population status and trends. Monitoring of cormorants will allow the Ministry to assess the impacts of the hunting season and to adjust cormorant hunting regulations if necessary to address any concerns about population sustainability.

With respect, isn’t that the sort of survey that ought to be undertaken before the birds are killed?

In short, there is no merit to these proposed changes and the Ministry is encouraged to withdraw the proposal unless (or until) proper investigation is undertaken to determine that there is any supportable rationale to moving forward with it.