I am a member of Ontario…

I am a member of Ontario Nature, the Toronto Ornithological Club and the Ontario Field Naturalists - and although I am primarily a birdwatcher, I sometimes differ with some of the members (but by no means all) of these organizations because I have no issue with responsible hunting for the primary purpose of providing food. I do not support "trophy hunting", or the kind of gratuitous killing that shows no respect for the creatures that are killed.

As a former public servant, I find the timing of this consultation problematic, primarily over the Christmas holiday season, but I also suspect that this underscores the lack of evidence on which the proposal is based. This is not a criticism of the bureaucrats.

The Double-crested Cormorant is not a "game" bird - no matter what is put in a regulation - and allowing what is in effect a virtually uncontrolled "hunt", including during breeding season, would be a "cull" - and that is a kind way to put it. This species is not generally considered to be edible, so to call it a "game bird" is not an appropriate way to reduce or control its populations, if this is indeed required - based on evidence, not the opinions of people who simply don't like them.

I generally support the submissions of the organizations to which I belong, noted above. If there is to be a cull, it should be done properly, as was at least attempted for Middle Island at Pelee (also controversial - and I attended consultations on that). The experiences at Tommy Thompson Park and Presqu'ile have shown there are effective alternatives to reduce and control populations, e.g. egg oiling, promoting ground nesting.

The proposal, if implemented, would create a system of public hunting of a so-called game bird, in order to reduce the species' population in Ontario. It would more likely than not result in harm for other species, e.g., the Black-Crowned Night Herons, which nest in similar habitat alongside the Cormorants. The "hunt", especially during breeding season, would disturb and interrupt the breeding time of other species, not to mention other forms of "collateral damage".

If there is a concern about the population, which you acknowledge seems to have stabilized or declined slightly, then strategies for specific culling or oiling eggs or other methods should be used. To define this bird as a "game bird" and allow a public hunt, with few limits, is frankly horrifying and would be a tremendous setback in responsible policy-making in the environmental and conservation sector.

Thank you for your consideration. I look forward to a more evidence-based approach to dealing with the concern about this species.