I am writing to ask you to…

I am writing to ask you to reconsider establishing a Double-crested Cormorant hunt at this time. This proposal does not provide sufficient justification for this hunt. It does not appear that sufficient studies have been conducted to evaluate the impacts of this hunt, if they have, they should be made available to the public for our review as part of this comment period.

As proposed this hunt appears to be intended as a cull, given the extremely high bag limits, no possession limit, allowance for hunting from a boat, and possibly including provisions to allow carcasses to spoil. The cormorants would not be hunted for their meat, rather solely for sport, and likely by individuals that perceive cormorants negatively impact fish populations and who may be motivated to hunt cormorants at very high levels.

I am concerned that this hunt would negatively impact cormorant populations. This proposal does not provide sufficient information to demonstrate that the population would remain stable with the hunt. I urge the government to estimate the likely capture rates from this hunt and conduct a population modeling study to analyze the impacts of hunting on Ontario’s cormorant population. You may wish to engage a third party, such as Bird Studies Canada or a University partner, to conduct the study and add credibility. Any bag limits, and hunting season, should be allocated based on the results of this work.

The proposal states that a monitoring committee would be established to review the impacts of the hunt and adjust the hunting regulations as necessary. Reasonably, it could take years to detect the trend of a population decline, and additional time to update regulations. The committee will likely be making decisions on lagging indicators and will be slow to respond to change. Hunting, combined with other unanticipated environmental issues (e.g., loss of nesting habitat, contamination, etc.) could exacerbate declines. It is easier to give things to people than to take them away. I anticipate that once the regulations are in place they will be hard to change and that hunters will resist lower bag limits. Please, proceed with caution and do the necessary population monitoring before establishing this hunt, not afterward.

Again, please do not move forward with this proposal, especially without doing the necessary science first.

Thank you.