The proposal to establish a…

The proposal to establish a hunting season for Double-crested cormorant does not explain to the public that this is a native species which is only now recovering from decades of decline. There is much misinformation surrounding this species and the potential impacts to fisheries which this proposal does not address.

There is no scientific evidence provided in support of these proposed actions. Since any impact of cormorants on fisheries has not been quantified, there also cannot be any meaningful threshold for control of the species. The 50 bird bag limit is arbitrary and there is no way to know how hunting is influencing fisheries or if over-hunting is occurring. There has also been no evidence suggesting how hunting could improve commercial fisheries which operate on only some of the largest waterbodies in the province. If impacts are occurring solely from cormorants these would be localized issues and control and management would be justified. A widespread hunting season is not the solution to something which may be an issue in one particular location, or potentially nowhere at all. It is acknowledged that cormorant control is a part of wildlife management in the Province, especially in areas with sensitive species. Hunting cormorants has the potential to cause impacts to sensitive bird species and other wildlife, especially as the proposed season is extensive and overlaps with breeding seasons.

The basis of ethical hunting is the humane procurement of food. Shooting cormorants is therefore not hunting or harvesting game, but simply killing an undesirable species. Changing the Fish and Wildlife Conservation Act and supporting regulations to allow cormorants to spoil will do great damage to how hunters are perceived in Ontario. Hunters already face much opposition and this unethical hunt will convince otherwise supportive citizens that hunting is not an acceptable practice. It is also not fair to hunters to have them engage in what many hunters believe is non-native, invasive species removal when ultimately there is no evidence of impacts and no mechanism to track if the hunting season is successful.

The proposal as written cannot address any of the concerns that some in the province have expressed and it will be detrimental to wildlife and hunting culture in Ontario. Therefore, the Ministry should not proceed with any such proposal.