Subject: EBR Registry Number…

Subject: EBR Registry Number 013-4124: Proposal to established a hunting season for double-crested cormorants in Ontario

I am writing to request that the Ministry of Natural Resources and Forestry (hereafter MNRF) withdraw the proposal on the EBR, Registry number 013-4124, to establish a hunting season for double-crested cormorants (hereafter cormorants). My objections to the proposal are generally two-fold: 1) lack of sufficient documentation, lack of use of evidence, and lack of demonstration of need; and 2) fundamental flaws in the approach to and description of the proposed activities, specifically the mis-characterization of the activities as "hunting", rather than as what it really is: population reduction or culling.

Lack of documentation, evidence and demonstration of need:

The only statement in the "Description of the Policy" that relates to any underlying need (or purpose) for a hunting season ('cull')is the one that refers to continued "concerns expressed by some groups ... and individuals that cormorants have been detrimental to fish populations". Wildlife and fisheries policy in Ontario and North America is generally based on a combination of assessments of biological science, economics and social concerns, and thus this type of general opinion is insufficient on its own to support a major change in policy, certainly one involving the reclassification of a species and an essentially uncontrollable and unenforceable regulation invoking the public as agents of population reduction. The lack of any evidence in the proposal demonstrating the need for population reduction at any scale is particularly egregious because the MNRF is a science-based organization and because double-crested cormorant populations have been extensively and intensively studied in the Great Lakes, including by the MNRF, other governments, and universities in Canada and the United States.

The wealth of information available to the MNRF about the diets of cormorants and the potential effects of cormorant foraging on fish populations has not been presented in this proposal. If there is compelling evidence that supports the assertion that there is a cause-and-effect relationship between cormorant population size and fish population size at the relevant management scale, it should be presented in the proposal and used as support for any active population management. Because the hunt is proposed at the provincial level and because the proposal is silent on the scale of any effect, it must be assumed that MNRF is making the case that fish populations in the Great Lakes as a whole have been affected. This is improbable and it is much more likely that effects on fish are local. However, even at the scale of a basin within an individual lake, cormorants alone are unlikely to drive fish populations, rather they have been shown to track fish populations (e.g., the collapse of alewife in Lake Huron and Georgian Bay in the early 2000's was followed by a significant decline in the number of breeding cormorants in those water-bodies).

It is stated in the "Description of the Policy" that the "latest information" indicates Great Lakes populations have "stabilized or declined slightly" since the early 2000's. Rather than support a need for a reduction, this implies that the issue of concern to "some groups" may have self-corrected and no longer be valid. In any case, no population estimates for the Great Lakes as a whole or any of the individual Great Lakes or their basins are provided. Without baseline population estimates, there is no way of measuring outcomes of the proposed hunt. This insufficiency is critical, as it indicates a departure from evidence-based management, one of the MNRF's basic guiding principles, and it weakens any attempt to measure or claim to achieve sustainability of the activity. The proposal purports to having adjustments of the hunt regulations in future based on monitoring. The establishment of "a cormorant monitoring program to assess population status and trends" is a worthwhile and essential activity, but such a program needs to be established and operated for several years before any management activity such as the population reduction of this proposal is undertaken.

Fundamental flaws in the approach to and description of the activity proposed

While technically/legally the province can designate the cormorant as a "game bird" by regulation under its Fish and Wildlife Conservation Act (FWCA), the broadly accepted definition of a game species is a species that is pursued for the purpose of consumption as food, or less commonly, as a trophy. The designation of cormorants as "game" species under FWCA as laid out in this proposal is contradictory to that broad definition, as neither of those uses is mandated for this hunt. In fact, although the proposal indicates that the FWCA's requirement for retrieval of killed game birds would be maintained, the use of the term "disposal of carcasses" and the proposal's specific statement that an exemption to the general requirement that prohibits spoilage of game meat would be sought or regulated are clear indications that the MNRF does not anticipate the birds would be consumed for food or deemed to be trophies, and thus does not sincerely believe this to be a hunt in the traditional and commonly accepted sense (e.g., as game bird hunting equivalent to that for ducks, geese, grouse, etc). The proposed re-designation of cormorants would be highly detrimental to the integrity of the FWCA and to the credibility of MNRF, both in its setting of precedence and its devaluing of this and other species and of the process (i.e., the hunting regulations process).

The proposed "hunting season" is a euphemism for a population reduction or cull. The intent (or inadvertent effect) appears to be the downloading of the responsibility of population control to the general "hunting" public at its expense. Like the designation of the cormorant as a game bird, this is fundamentally contradictory to the North American Model of hunting and conservation of wildlife. While some hunters might participate in a season if this proposal were to proceed, it is hard to believe that many of them would be motivated by conservation principles. The harm done to the image of hunters as conservationists in the eyes of non-hunters and the vast majority of urban Ontarians by such a spectre would be great indeed. For example, the hunting of cormorants during the breeding season on or near their breeding sites inevitably means that the death of adult breeders would lead to the death of eggs, embryos, and pre-fledged young. Such treatment would not be tolerated for any other wildlife species, certainly no other game species. The MNRF also stands to lose its credibility as a science-based conservation agency which uses socially acceptable practices, if this proposal proceeds as it is.

There are both provincial and international precedents for culling of cormorants for the purpose of conservation of other natural resources. In Ontario, the successful implementation of a cormorant cull by Provincial Parks demonstrates that acceptable tools are already available and will be accepted by the public where need is demonstrated. In the Great Lakes in general, federal culling programs have also been implement in Canada and the United States with due process and public consultation and acceptance. These have been location-specific and have allowed targeting of control where negative ecological effects have been demonstrated, rather than a wide-open population reduction with no basis in ecosystem management, another of MNRF's guiding principles.

The "Regulatory Impact Statement" that states the "anticipated environmental consequences" are expected to be neutral is neither quantified nor logically supportable. Firstly, the proposed season completely overlaps the presence of the species in the province, allowing their killing without respite. Secondly, there are no statements regarding the protection of breeding colonies or mature breeding birds during the breeding season, indicating that contrary to all other hunting of game species, the reproductive portion of the population during reproductive activities could be killed. Basic principles of population biology indicate that this is a prescription for negative population growth, despite the claim of neutrality or sustainability. Thirdly, the proposed bag limit of 50 per day per hunter effectively allows killing without constraint. Many of Ontario's breeding cormorant colonies include small enough numbers of breeding adults that they can reasonably be expected to be wholly eliminated by the kind of persistent hunting that would be allowed by this proposal.

Conclusion

In summary, I believe this proposal to be fundamentally flawed and without merit. I request and urge the MNRF to withdraw the proposal. If cormorant population reduction is the MNRF's management goal for the species and the Great Lakes ecosystem that it inhabits, then MNRF should develop an approach suitable to that purpose which does not include reclassification of the species as game, the devaluation of hunters and hunting, and the devaluation of its own reputation. Any such program should include specific, measurable objectives for acceptable and sustainable cormorant population sizes at scales and for locations where negative ecological effects of cormorants have been demonstrated or can be reasonably expected.