The proposed open season on…

ERO number

013-4124

Comment ID

16183

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The proposed open season on Double-crested Cormorants is shocking in its cruelty towards a native species and dismaying in its lack of care for the environment.

It should not proceed, for the following reasons:

1 It has no scientific rationale: Where is the research to support this change? None is cited. There is reference to “concerns” with only the sketchiest of anecdotal evidence provided. It really is stunning that the Ontario Ministry of Natural Resources, which one presumes still has qualified and knowledgeable biologists on staff, would put forward such a weak justification for so drastic an intervention in the management of our natural heritage.

2 It is unethical: Failing to protect the species during the breeding season, allowing game meat to spoil, shooting birds on the nest – these all violate an ethical framework that has made hunting an acceptable element of wildlife management in Ontario.

3 It is cruel: Hunters are to be allowed to kill the birds during the breeding season, ensuring that young will be left to starve. Unlike other waterfowl, both members of a cormorant pair are required for nest success, so the chicks and fledglings will starve even if one parent is left alive.

4 It is punitive: The exceptionally long open season covers the entire time this migratory species is under the stewardship of the province of Ontario. Taken as a whole, the proposal appears designed to inflict the maximum amount of suffering on a bird that belongs here and has a role to play in the ecosystem.

5 It is based on confusion about natural processes: Just as some confuse weather and climate, supporters of this measure extrapolate the localized effects of colonial bird nesting sites to the entire Great Lakes. They refuse to take into account research that indicates:
a. The Great Lakes cormorant population has stabilized and even declined;
b. A very small proportion of available island forest sites are occupied;
c. Cormorant diets include little sport or commercially desirable fish, or their prey, and do include invasive fish species.

6 It lacks perspective on the issue of vegetation: The destruction of vegetation by cormorants and other colonial birds is extremely localized. In comparison, development and agriculture devastate native plant and animal communities with effects that spread far beyond their immediate footprint. Guano accumulation is a natural process that plays out over a long timeframe, so we should not allow “aesthetics” to lead us into making unjustified and naïve assumptions. In situations where it’s felt action should be taken to protect unique species of trees or plants, non-lethal measures are the best response. Tommy Thompson Park has demonstrated that these work.

6 It fails to consider ecosystem effects: Removing a species from an ecosystem – and this measure has the potential to cripple if not eradicate the Great Lakes cormorant population – will have unintended consequences if not undertaken with great care and forethought.
a. We know for sure that other colonial birds – American pelicans, great egrets, great blue herons, black-crowned night herons, various gulls and terns - that share cormorant nesting sites will be disturbed and their breeding will be disrupted; that the cormorant is a prey species for bald eagles that may be adversely affected; that fewer invasive fish will be consumed.
b. Will scavenger populations be boosted if large numbers of dead birds are left on the land and in the water, and will this adversely affect other species or be a nuisance?
c. Will the kill promote the spread of Newcastle disease, presently found in a small number of cormorants, to other wild birds, domestic poultry or other species by disseminating the virus through decomposition or removal of contaminated carcasses, or on footwear or equipment?
d. What will the destabilizing effect of the kill be on a population that has levelled off?
We need answers to these and other questions before this highly disruptive measure is approved.

7 It fails to set out a monitoring program: Where is the baseline? If the killing begins before a baseline is established, how will the sustainability of this measure be assessed? Will ministry staff count the starving chicks? How will the ministry ensure hunters appropriately report their kills? These questions need to be answered - so the public can comment on whether the monitoring is likely to work - before, not after, the proposal is approved.

8 It is politically motivated: In the absence of any evidence of scientific thought driving this proposal, politics becomes the obvious explanation. The Ontario Federation of Anglers and Hunters, whose members appear have a visceral hatred of this beautiful and interesting bird, made addressing the “overabundance” of cormorants one of its key demands in the June 2018 election.

9 It does not serve the interests of Ontarians: I’m a birder, I enjoy seeing cormorants – and birding is nearly four times more popular than hunting in Ontario. Those who aren’t interested in either pastime still want the ministry to protect wildlife from cruelty and carry out its stewardship according to scientifically supported principles.