January 3, 2019 Public Input…

Re: Environmental Registry of Ontario #013-4124 – Proposal to establish a hunting season for double-crested cormorants in Ontario

Attn: Public Input Coordinator, Species Conservation Policy Branch

We would like to thank you for the opportunity to comment on ERO #013-4124 - Proposal to establish a hunting season for double-crested cormorants in Ontario. As an animal welfare organization in Ontario that advocates for all animals, the Guelph Humane Society is strongly opposed to the proposal due to the potential ecological, conservation, and welfare impacts. Here is a summary of our main concerns:

1. The proposal does not present any scientific evidence to support the need for reducing cormorant populations.
As outlined in the proposal, cormorant populations are stable or potentially decreasing. This statement is substantiated by data presented in an Environment Canada Great Lakes Fact Sheet on cormorants. In addition, the proposal goes on to state that there have been 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. To respond to these concerns, the Ministry is proposing to create a hunting season for double-crested cormorants in Ontario.” This statement suggests that the proposal is not being driven by scientific research or evidence, but merely the conjecture of special interest groups with no scientific basis.

As a species that is native to Ontario, it is inappropriate to describe double-crested cormorants as “detrimental”. In fact, scientific studies have repeatedly demonstrated that the primary diet for cormorants is largely non-commercial, shallow-water fish, and cormorants likely have little, if any, impact to fish populations harvested commercially. Furthermore, including concerns about “aesthetics” as a factor in the need for implementing a hunting season for cormorants is especially worrisome, as it has no basis in sound conservation management decisions.

The Ministry must ensure that changes to policy affecting wildlife is made based on solid scientific evidence. Public policy on environmental issues cannot be made based on the desire of special interest groups to expand hunting opportunities. To implement policy changes without scientific basis is contrary to responsible environmental stewardship.

2. The proposed length of the hunting season and the high daily bag limit.
The proposed hunting season of March 15th to December 31st is excessively long and would make cormorants a potential target of hunting activity throughout the time that they spend in Ontario, including during the nesting season. Sound conservation management strategies generally protect birds during the nesting season, and a failure to do so is indefensible when considering both the conservation and welfare implications. In addition, there is also a great risk to other bird species that share habitat with double-crested cormorants, such as various species of gulls and herons. These species could be negatively affected by both hunting activities, as well as carcass retrieval during their nesting season, which could inadvertently create conservation and welfare concerns for these species as well.

In addition, the proposal fails to identify any population reduction targets that are meant to be achieved through the implementation of a hunting season. Instead, the proposal sets a daily bag limit of 50 birds/day, with no possession limit, over a nine-month period. This approach creates the potential for a staggering number of birds to be killed within a short time frame. Without identified population targets, and continued monitoring of cormorant populations, this policy change has the potential to exploit and decimate these birds.

3. The proposal would lead to the unnecessary suffering of many cormorants, as well as serious ethical and animal welfare implications.
Given that this proposal would permit cormorants to be shot from a distance, and permitted to “spoil” (i.e. not be collected), birds could be wounded but not fatally shot and left to suffer. In addition, given that aesthetics has been mentioned previously as a factor in the proposed hunting season, the sight of injured or deceased birds in recreational areas is certainly not aesthetically pleasing and could be traumatizing to other members of the public that use the area recreationally.

The proposal also fails to recognize other management strategies that would reduce the cormorant population and are much preferred from an ethical perspective, such as egg oiling, egg addling, or replacing eggs with false eggs. Employing culling strategies as a population management tool when less invasive (and more effective) options are available is immoral and should be avoided without exception.

And from a broader conservation management perspective, while hunting, trapping, and capturing animals have been commonplace management strategies for decades, the concept of Compassionate Conservation is a rapidly growing transdisciplinary field that fully considers animal welfare and ethics in conservation, research, policy, and practice. The following principles are fundamental to Compassionate Conservation*:
• Respecting wild animals for their inherent value, not just as a resource for people
• Recognizing the importance of individual animals within their population as they provide stability for groups
• Avoiding using labels like “pest” because the label reflects attitudes
• Understanding that co-existence is often a more effective management option
*Source: British Columbia SPCA - https://spca.bc.ca/ways-to-help/take-action/wild-animals/compassionate-…

As such, the indiscriminate killing of cormorants, and the welfare implications that these birds will suffer as a result, is unethical and demonstrates a disturbing lack of compassion and respect. We urge the Ministry to instead implement a policy that embraces the concepts of Compassionate Conservation, and utilizes the expertise of both conservationists and animal welfare scientists to develop meaningful policy.

Due to the concerns identified above, the Guelph Humane Society strongly encourages the Ministry to reject the proposal. Policy decisions must be based on scientific evidence, and must ensure that ecological, ethical, and animal welfare implications are considered and evaluated.

Sincerely,
Guelph Humane Society