Comment
013-4124
In Opposition
The issue is the hunting season on cormorants proposed by the MNR at the apparent request of the Great Lakes Fisheries Commission Technical Advisory based on concerns expressed by some groups and individuals.
The proposal is for the hunting season to be open from March 15th to December 31st with a 50 bird per day limit with no restrictions on possession, allowing hunters to not retrieve the carcasses and allowing hunting from a motorboat.
According to the mandatory Regulatory Impact Statement, “The anticipated environmental consequences of the proposal are expected to be neutral. The double-crested cormorant is abundant in Ontario and anticipated levels of harvest aren’t expected to affect sustainability.”
This statement seems unsupportable given the lack of limits on possession and 50 bird per day quota. One motivated hunter over 76 days of open season (June 24th, 2019 to August 31st, 2019) could theoretically kill 3800 birds legally. A mere 10 hunters could kill 38,000 birds; 100 – 380,000 birds annually.
This additional anthropogenic pressure will ensure that another species will be extirpated from the Great Lakes if this goes through. Literature shows that historic cycles of a similar extirpation are recorded in the late 1800s (Wires, 2006). So history is literally repeating itself.
What happens when these native birds become a threatened species? Will they then have to be added to the Provincial Species at Risk list?
Given that numerous environmental contaminants will bioaccumulate in these birds, i.e. mercury, PCBs etc., it would be unlikely that human consumption would be recommended. This would therefore tend to characterize this not as a "hunting " plan but rather as a sport shooting, extermination plan. A proper population control management plan would address causative and connectivity issues raised and in the absence of these justifications, we are uncertain of the basis on which the Ministry scientists are supporting this proposal.
According to the included MNR&F background material, the latest information indicates that Great Lakes cormorant populations have stabilized or declined slightly since the 2000s. The justification for the “control measure” provided is based on “concerns expressed by some groups (commercial fishing industry, property owners) and individuals that cormorants have been detrimental to fish populations, island forest habitats, other species and aesthetics.”
There is no scientific support presented to establish any connection for the unsubstantiated causative linkages presented here and no reference to acknowledge the historical cormorant populations far exceeding those present today. Scapegoating and esthetics seem to play a major role here too as many people don’t like the rock islands covered in guano.
Basing a decision on concerns from one economic sector while ignoring evidence based impacts on that same sector and others is not recommended.
Food web interactions are complex. Anthropogenic interventions will have impacts that are not currently well understood. Many recently developed investigative tools (DNA, bio-tracers, stable isotopes, etc.) are available to document food web structure, but these have not yet been applied to the Great Lakes ecosystems widely enough to understand these complex relationships. There should be research specific to this issue before any extirpations are begun. This would be a perfect application for the tools developed at the University of Guelph and used in our ongoing work to establishing a genetic barcode library of all species in Georgian Bay housed in the International Biology of Life Database project at UofG.
Cormorants are a native species to the Great Lakes. Previous cormorant population growth in the 1950s to 1990s was linked to invasive alewives that have since collapsed due to intense predation, competition from quagga mussels and interaction complexities resulting from climate change impacts on thermal guild, prey and thermal habitat availability and increased upwelling events due to intensification of storm and seiches (Collingsworth, 2017; Stanley, 1971). Alewives are planktivores foraging for copepods and zooplankton. The MNRF has also previously suggested that their stocking programs were instead feeding the Cormorants and looked to curtail the practice.
There is no thought indicated in the proposal as to the recent role of invasive Goby in the suggested loss of fish species. Round Goby are abundant and present in large numbers in the Great Lakes (i.e. estimates suggested there were 9.9 billion in the Western Lake Erie basin as of 2002) but recent studies suggest some stabilization in their numbers. Some facts to consider:
• The round goby is extremely aggressive and is a prolific breeder, often spawning several (up to six) times each season.
• Once established, it can quickly become the dominant fish species in an area.
• The round goby prefers rocky, shallow areas but flourishes in a wide variety of habitats.
• They out compete native species, particularly other bottom-dwelling species like mottled sculpin, logperch, and darters, for food and space, and preys on eggs and fry of other fish. Goby forage on the bottom and are voracious fish egg eaters.
• The round goby also preys heavily on zebra mussels, which are often high in contaminants, leading to concerns about increased risk of contaminant exposure for sport fish and other round goby predators including cormorants.
The published literature shows that cormorants have been eating goby. This evolving ecological balance may in fact be protecting yellow perch and smallmouth bass populations from both cormorant predation and round goby egg foraging.
Further, the literature shows that cormorants are eating goby year round, likely due to the multiple times (up to six) per year that goby reproduce versus pre-goby eating patterns where cormorants food sources changed seasonally due to the once per year breeding cycles of our native Great Lakes species. This may again result in protections for other species to be less impacted by both the cormorants and the goby.
Therefore, it is highly likely that eliminating cormorants will increase invasive round goby numbers and their predation on the eggs of other fish species will have impacts on yellow perch, small mouth bass, whitefish, lake trout, etc. To add to the complexity, goby are also food sources for adult fish of these species.
In other words, eliminating either cormorants or goby might result in a detrimental impacts to native species at this time of flux.
Further, modifications to the Act allowing the cormorants to spoil means that hunters won’t have to retrieve the carcass of the dead birds:
The Fish and Wildlife Conservation Act currently prohibits anyone who kills game wildlife (including game birds), or who possesses game wildlife killed by hunting, from allowing that meat to spoil. Via this posting, the Ministry is also consulting on a proposal to amend the Fish and Wildlife Conservation Act to add provisions so hunters could allow cormorant to spoil. This proposal would add provisions to the Act, so that persons who lawfully hunt (or possess) cormorants could be exempt from this requirement and would be subject to conditions that require the person to retrieve and dispose of the carcass. Should this proposal proceed, it may be accompanied by regulations to implement the exemption and requirements.
This creates a significant potential issue of unretrieved rotting, contaminated bird carcasses washing up on the shores of Georgian Bay adversely impacting residents and cottagers.
Further, the allowance of hunting from a boat coupled with the nature of these birds as surface skimming flyers and swimmers raises safety concerns in the highly populated shorelines and heavily trafficked waterways in Georgian Bay.
In summary, as near apex predators, cormorants bio-accumulate anything in the water i.e. mercury, PCBs etc. therefore, this would counter indicate human consumption. The "hunting" season, therefore, must be being proposed as a management practice to achieve an objective. If that is the case, the management objective would need to be clearly articulated so that this management action could be measured for effectiveness and it should be a part of an overall management strategy. Additionally, prior to this implementation there would need to be an actual linkage proved for cormorants as the causation of the fish declines. We do not see this rational posted with the proposal.
These linkages are complex and the Great Lakes ecosystems are in a time of great flux due to invasive mussels too. More research is needed to avoid anticipated detrimental impacts to the sport and native fishery. The food web tracing mentioned above provides an applicable methodology to prove the linkages.
In the absence of such a rational for a management plan, establishing a “hunting” season would seem premature at best and ill advised given the absence of environmental connectivity impacts data.
It seems clear that this is a socio-political approach and not a sound management plan based on ecological factors (Wires, 2006).
Respectfully,
David Sweetnam
Executive Director
Georgian Bay Forever
References:
Invasive Round Goby are being eaten by Cormorants, The Invasive Round Goby (Neogobius melanostomus) in the Diet of Nestling Double-crested Cormorants (Phalacrocorax auritus) in Hamilton Harbour, Lake Ontario Christopher M. Somers, Marie N. Lozer, Victoria A. Kjoss, and James S. Quinn*
J. Great Lakes Res. 29(3):392–399 Internat. Assoc. Great Lakes Res., 2003
Diet shift of double-crested cormorants in eastern Lake Ontario associated with the expansion of the invasive round goby, James H. Johnson, Robert M. Ross, Russell D. McCullough, Alastair Mathers
Journal of Great Lakes Research Volume 36, Issue 2, June 2010, Pages 242-247
Historic Populations of the Double-Crested Cormorant (Phalacrocorax auritus): Implications for Conservation and Management in the 21st Century, Linda R. Wires and Francesca J. Cuthbert
Waterbirds: The International Journal of Waterbird Biology, Vol. 29, No. 1 (Mar., 2006), pp. 9-37
Density and habitat use by the round goby (Apollonia melanostoma) in the Bay of Quinte, Lake Ontario, Ana Carolina Taraborellia, Michael G. Fox, Ted Schaner, Timothy B. Johnson
Journal of Great Lakes Research, Volume 35, Issue 2, June 2009, Pages 266-271
Climate change as a long-term stressor for the fisheries of the Laurentian Great Lakes of North America, Paris D. Collingsworth, David B. Bunnell, Michael W. Murray, Yu-Chun Kao, Zachary S. Feiner, Randall M. Claramunt, Brent M. Lofgren, Tomas O. Höök ,Stuart A. Ludsin
Rev Fish Biol Fisheries, May 20, 2017
Effects of temperature on electrolyte balance and osmoregulation of the alewife (Alosa pseudoharengus) in fresh and sea water, Jon G. Stanley and Peter J. Colby
Transactions of the American Fisheries Society, Volume 100, Issue 4, 1971, Pages 624-638
From the ERO
https://ero.ontario.ca/notice/013-4124
1. List the double-crested cormorant as a “Game Bird”. Hunters would be required to have an outdoors card and small game licence to hunt double-crested cormorants, similar to other species of game birds.
2. Create an open hunting season for double-crested cormorant from March 15 to December 31 each year across the province.
3. Create an exemption allowing small game licences to be valid for double-crested cormorant hunting in central and northern Ontario from June 16 to August 31 each year.
4. Establish a bag limit of 50 cormorants/day with no possession limit.
5. Prescribe shotgun and shot size/type requirements consistent with migratory bird hunting regulations outlined in the federal Migratory Birds Regulations. This would include use of shotguns that are not larger than 10 gauge, that cannot hold more than three shells and use non-toxic shot as described in the migratory bird regulations.
6. Allow hunting from a stationary motorboat.
Allowing the cormorants to spoil means that hunters don’t have to retrieve the carcass of the dead birds:
The Fish and Wildlife Conservation Act currently prohibits anyone who kills game wildlife (including game birds), or who possesses game wildlife killed by hunting, from allowing that meat to spoil. Via this posting, the Ministry is also consulting on a proposal to amend the Fish and Wildlife Conservation Act to add provisions so hunters could allow cormorant to spoil. This proposal would add provisions to the Act, so that persons who lawfully hunt (or possess) cormorants could be exempt from this requirement and would be subject to conditions that require the person to retrieve and dispose of the carcass. Should this proposal proceed, it may be accompanied by regulations to implement the exemption and requirements.
Submitted January 3, 2019 12:42 PM
Comment on
Proposal to establish a hunting season for double-crested cormorants in Ontario
ERO number
013-4124
Comment ID
16606
Commenting on behalf of
Comment status