December 30, 2018 RE: A…

December 30, 2018

RE: A proposed no-limit hunting of the Double-crested Cormorant (Phalacrocorax auritus) in Ontario, Canada.

EBR Registration number 013-4124

The Pacific Seabird Group strongly protests the proposed no-limit hunting of Double-crested Cormorants proposed by the Government of Ontario.

The Pacific Seabird Group (PSG) is an international, non-profit organization that was founded in 1972 to promote knowledge, study, and conservation of Pacific seabirds with a membership drawn from the entire Pacific basin, including Canada, Mexico, Japan, China, Malaysia, Australia, New Zealand, and the USA. Among PSG's members are biologists who have research interests in Pacific seabirds, government officials who manage seabird refuges and populations, and individuals who are interested in marine conservation. PSG members serve as scientific experts and conservation leaders within their local communities. Collectively, the Group’s members have a great deal of knowledge and experience with respect to seabird conservation.

There is no scientific evidence that a 10-month open season on Double-crested cormorants will bring the desired result. The analysis to support this management objective appears to be based on incomplete scientific information. Dozens of studies have repeatedly shown that cormorants do not have a significant negative impact on commercial fish populations, with most of these studies targeted specifically on the Great Lakes. For example, studies on Lake Ontario indicate that fish most attractive to human fishermen comprise less than 2% of cormorant diets, and that cormorants consume about 0.5% of critical prey fish, an insignificant number especially when compared against the 13% taken by sport fishermen (Weseloh & Collier 1995).

It is well known that cormorant diets consist of mostly non-sport fish species like the invasive Alewife (Alosa pseudoharengus) (Belyea et al. 1999, Reed et al. 2003), and the invasive round goby Neogobias melanostomus (Seefelt 2018). Indeed, the Great Lakes ecosystem has been severely damaged by more than 180 invasive and non-native species that ultimately degrading habitat, out-competing native species, and short-circuiting food webs. Using the Double-crested Cormorant as a scape-goat is inappropriate given the damage people have done to the Lake ecosystems.

The proposed hunting season for Double-crested Cormorants, March 15 to December 31, includes killing adult birds provisioning young during the breeding season. This amounts to unethical animal treatment. Untold numbers of carcasses would be left in the field, luring scavengers (e.g., vultures, eagles) into areas where they could be mistaken for target species and caught in the crosshairs. Additionally, widespread rotting carcasses pose a local threat to water quality and human health while negatively affecting the public’s access to wildlife viewing.

Lethal management tools are not effective at decreasing fish predation, and may simply allow other invasive species to take the cormorant’s place. The proposed management of cormorants does not address the root causes of fish population instability or decline, and directly contradicts current conservation measures, locally, regionally, nationally, and internationally.

The Government of Ontario should pursue a structured, adaptive decision-making approach and first test the effectiveness of alternative cormorant management (via egg control, etc.). The benefit of this formal, repeatable approach is that sensitivity analyses and monitoring programs pre/post management provide data on the impact of the decision. This is in contrast to the current, ad-hoc approach, which could lead to undesirable outcomes misaligned with the Government’s values and objectives surrounding the recovery of native fish populations.

Thank you for reconsidering this proposal.

Sincerely,

Mark Rauzon
Vice-Chair for Conservation
Pacific Seabird Group
4701 Edgewood Ave.
Oakland, CA 94602
conservation@pacificseabirdgroup.org

Literature Cited:

Belyea, G. Y., S. L. Maruca, J. S. Diana, P. J. Schneeberger, S. J. Scott, R. D. Clark, Jr., J. P. Ludwig, and C. L. Summer. 1999. Impact of double- crested cormorant predation on the Yellow Perch population in the Les Cheneaux Islands of Michigan. Pages 47–59 in M. E. Tobin, technical coordinator. Symposium on double-crested cormorants: population status and management issues in the Midwest. U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Technical Bulletin 1879, Washington, DC.

Reed, J.M., Causey, D., Hatch, J.J., Cooke, F., Crowder, L. 2003. Review of the Double-crested Cormorant management plan, 2003: final report of the AOU Conservation Committee’s panel. Ridgway, M.S., Dunlop, W.I.,

Seefelt, N.E. 2018. A disconnect between science and management for double-crested cormorants (Phalacrocorax auritus) in Northern Lake Michigan, USA, 2000-2016. Waterbirds. 41: 189-197.

Weseloh, D.V. & Collier, B. 1995. The rise of the Double-crested Cormorant on the Great Lakes: Winning the war against contaminants. Environment Canada Special Report, Environment Canada and Ontario Ministry of Natural Resources.