Comments on the EBR posting…

Comments on the EBR posting 013-4124 – Cormorants

I do not agree with the proposal to list the double crested cormorant as a “Game Bird”. In my opinion the cormorant simply does not fit the definition of a game bird. The game birds listed in Schedule 3 of the FWCA are hunted for recreation (sport), but most importantly, they are hunted for consumption. Section 36 of the FWCA is intended to ensure these Game Birds are not wasted and allowed to spoil and be unfit for human consumption. Shooting cormorants should not be for sport and they are generally not considered suitable for human consumption. Shooting should only be used as a means of population control.
Personally, I feel a more suitable approach would be to list the Cormorant as not protected Section 5 (2) under the FWCA, but regulated which I feel could be accommodated by Section 5 (2) (d). A small game license would still be required as it is now for crows, etc.
Shooting Cormorants as Game Birds presents a very negative image of hunters and hunting – totally unnecessarily. Quite frankly it reflects badly on the hunting community and on the MNRF itself.
Section 5 (2) (d) should also allow the Minister to apply restrictions and conditions. I am not concerned about the daily limit, but I am very concerned about the timing. Shooting Cormorants should not be allowed during the nesting period until the young are able to fly and fledge. I don’t know the exact dates, but birds could be shot late winter/early spring up until nesting season, then again after the young are able to fly (mid-August). The optics of shooting adult birds that are caring for their young, leaving the young to starve is very negative and simply wrong. It would also have potential for charges to shooters and MNRF under the Criminal Code. Sections 444 to 447 of Canada's Criminal Code constitute Canada's primary federal animal protection legislation. The Code prohibits causing "unnecessary pain, suffering or injury to an animal or bird" and "causing damage or injury by willful neglect". I believe there should be a period of protection from shooting. Cormorants are very vulnerable because they nest in very conspicuous colonies.
I am fine with the other parts of this proposal. Shooters should retrieve dead birds and properly dispose of them. Realistically, some birds will not be retrieved. Dead birds drifting in the water or floating to shore during the peak of vacation season on lakes and rivers would also look very bad on hunters and on the MNRF for allowing it to happen. The Ministry should be able to prescribe shot size, type, etc. Probably non-toxic shot since most birds would be shot over water. Having the ability to set a daily limit would be fine and allowing shooters to shoot from a stationary boat as per the MBCA is also appropriate.