The proposal to establish a …

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013-4124

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16656

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The proposal to establish a "hunting" season for Double-crested Cormorants raises concerns for me. I am not averse to well planned, targeted culls by conservation professionals at specific sites (including shooting a set number of adult birds, egg oiling, and nest destruction), where there is a legitimate conservation concern, such as endangering populations of species at risk or rare vegetation communities. However, to call this a "hunt" undermines the meaning of the term. There is no one that I know of who would actually eat a cormorant. Thus, this proposal focuses on killing with no other purpose than to reduce the numbers of cormorants, but with no focus on legitimate conservation concerns. There is no valid evidence that Double-crested Cormorants have a negative impact on game or commercial fish populations. Declines in some fish populations pre-date the cormorant population increase, and are due to other factors, such as over-fishing. Cormorants tend to eat small fish, including some invasive aliens such as alewives and gobies. Large bag limits, no possession limits, an extended season, allowing the birds to be wasted, and allowing for the shooting of cormorants from boats, all add up to an unfocused, untargeted, unplanned assault on the Double-crested Cormorant, whether at a colony or not, with no obvious conservation benefit and dubious social benefit. In my opinion, this proposal should be withdrawn. If there are legitimate conservation concerns in specific locations, then a planned, focused, and targeted cull based on scientific evidence could be supported, but not a wholesale, unfocussed, and illegitimate slaughter.