Dear Minister: I am writing…

Dear Minister:

I am writing to you to express my concern—and my disgust—with the proposal to allow “hunting” of Double-Crested Cormorants in Ontario, as outlined at https://ero.ontario.ca/notice/013-4124. A daily bag limit of fifty birds per hunter, over a nine-and-a half-month hunting season, with an unconscionable dispensation allowing them to discard the carcasses to spoil, is an unreasonably permissive license, especially since the proposal fails to provide any indication of the motivation for this drastic measure. It is certainly a dramatic about-face from the celebration of this species’ recovery from the effects of pollution, as expressed in the Environment Canada fact sheet The rise of the Double-crested Cormorant on the Great Lakes: Winning the war against contaminants (http://publications.gc.ca/collections/Collection/En40-222-2-1995E.pdf).

In her comment on this proposal posted at https://gsfraser.blog.yorku.ca/research/conservation/proposed-cormorant…, Professor Gail Fraser expresses better than I could the ecological concerns regarding this proposal’s impact on the species population and on the overall ecology; I refer you to her very direct and readable article.

As this concerns a migratory species, this is a matter of not only provincial and federal environmental and ecological concern, but also is relevant to our compliance with international treaties. Specifically, the Double-Crested Cormorant is covered by the 1916 Migratory Bird Treaty, the Migratory Bird Treaty Act (1918), and the Ramsar Convention (1971), as described in The Cormorant Conflict (https://www.animallaw.info/article/cormorant-conflict), a 2006 brief by Nathan LaFramboise. The risks outlined by Professor Fraser show that the proposed regulations almost certainly violate the terms of these treaties to which Canada is a signatory.

The most absolutely unacceptable element of the proposal is the waiver of the normal hunting requirement that the killed birds not be allowed to spoil. Eliminating this dispensation would likely reduce hunters’ impact significantly, because as the Minnesota Department of Natural Resources notes in https://www.dnr.state.mn.us/birds/doublecrestedcormorant.html, cormorant meat is usually considered unappetizing due to their diet of fish. Nevertheless, it is edible, and with some effort, can apparently be made palatable, according to an article by Adam Nicholson in The Telegraph (https://www.telegraph.co.uk/comment/personal-view/3614362/Cormorant-ste…) and another (unattributed) in The Irish Times (https://www.irishtimes.com/opinion/yes-people-do-eat-cormorants-1.128380).

At the webpage linked in the previous paragraph, the Minnesota Department of Natural Resources outlines much more reasonable measures for managing the impact of these birds on property and fisheries. They have demonstrated due consideration for the birds’ welfare as a species and individual dignity as animals deserving humane treatment, while also addressing human priorities for safety and property. I urge you to follow their example, and will be monitoring the issue as policy is set and regulations are updated—and I vote.

Yours sincerely.