Re: ERO 013-4124: Proposal…

Re: ERO 013-4124: Proposal to establish a hunting season for Double-crested Cormorants in Ontario

Nature Canada strongly opposes the proposed regulatory changes, which would permit the slaughter of Double-crested Cormorants in Ontario. As an organization that prides itself on acting on behalf of wildlife through science-based research and collaboration, with almost a century of experience, we believe that the changes proposed by the Ministry of Natural Resources and Forestry (MNRF) are misguided and dangerous to both wildlife and the public. There is no scientific justification for the proposed extreme measures. The establishment of a hunting season for Double-crested Cormorants will undoubtedly cause substantial harm to a wildlife species that is native to Ontario, may cause disruptions and adverse effects in ecosystems and other wildlife species, and lacks the proper research and scientific justification to implement.

As one of Canada’s oldest national nature conservation charities, Nature Canada’s mission is to protect and conserve wildlife and habitats in Canada by engaging people and advocating on behalf of nature. Since the founding of Nature Canada in 1939, we have been connecting Canadians to nature by instilling appreciation and respect for nature, at the same time encouraging Canadians to act in nature’s defense. Since then, we have grown to become a national organization with over 90,000 members and supporters, with a network of more than 750 naturalist organizations all throughout Canada. Nature Canada has helped to protect over 255,000 km2 of parks and wildlife areas in Canada alone, along with the countless species of wildlife that depend on those environments for their habitat.

The Double-crested Cormorant is a native Ontario species, which has been a remarkable success story after the decimation of their populations in 1950’s-1970’s from exposure to toxic contaminants such as DDT and PCBs in their diet of forage fish. As was the case with other fish-eating species such as Bald Eagle and White Pelican, exposure to these chemicals cause many adverse impacts on their health, including the thinning of eggshells by almost 30%. However, since government ban on DDT and PCBs in the early to mid-1970s, the population of Double-crested Cormorants rebounded and recovered rapidly. Along with the decrease in toxic chemicals, there were other factors as well that may have helped them recover, including a dramatic increase in prey fish such as Alewives in the Great Lakes. MNRF indicates that Cormorant populations are now stable or even declining, suggesting that this proposal to dramatically reduce the species’ population is unwarranted.

Nature Canada is strongly against the proposed hunting regulations for Double-crested Cormorants for the following reasons: lack of scientific justification for the need for the hunting season; potential negative impacts on Double-crested Cormorants and other wildlife species; inhumane treatment of native wildlife, and danger to human life. Following is a brief description of the major points that Nature Canada has against the proposal:
1. Lack of scientific research in justifying the need for the hunting season
• In the proposal, the MNRF fails to justify the need for the hunting season with sound scientific
research, as is the norm when implementing such new regulatory changes.
• Not only are there no data on current population levels (births, mortality, breeding pairs) provided in the proposal, the MNRF actually suggests that populations of the Double-crested Cormorants are stable or declining, suggesting that the hunt is unnecessary.
• There is no scientific evidence indicating that Double-crested Cormorants are responsible for the decrease in commercial fish populations. The MNRF suggests that this proposal is being implemented as a response to concerns expressed by groups (e.g., commercial fishing industry, property owners) who believe that the Cormorants are competitors to sports fish and are detrimental to fish populations. However, a report by Canadian Wildlife Service indicates that Cormorants actually only consume about 0.5% of prey fish while sports fish consume approximately 13.4%. We believe that, if the issue is controlling predator species that negatively affect commercial fishing, OMNRF has the wrong villain. Their own introduced Salmon species are a much bigger problem.
• There are no objectives or goals outlined by the MNRF when it comes to the population numbers of the Double-crested Cormorants.
2. Impacts on Double-crested Cormorants and other wildlife species
• Currently, the MNRF is proposing a bag limit of 50 Double-crested Cormorants per day per hunter with no limits on possession, over a period of nine and a half months (291 days). This could mean that one individual hunter alone could potentially shoot and kill up to 14,550 cormorants a year, every year. This extremely unsustainable policy could lead to local/regional extinctions of Double-crested Cormorants.
• The proposal allows for hunting at breeding colonies. This could have unseen impacts on the mortality of other colonial water bird species such as Black-crowned Night Heron, Great Blue Heron, Great Egret, Ring-billed Gull, Common Tern and other species that often nest in or around Double-crested Cormorants colonies. While hunting on breeding colonies, hunters are likely to also disturb other wildlife species as well, as not only colonial water birds nest near cormorant colonies.
• Even though the MNRF states that they will ban toxic shot, there is no way to ensure that all hunters will abide by this law. Hunting from a motorboat (allowed in the proposal) can increase the level of toxic chemicals in lakes and rivers as well.
3. Inhumane treatment of native wildlife
• In the proposal, MNRF is suggesting to amend the current Fish & Wildlife Conservation Act to allow hunters to let their hunted cormorant meat to spoil. This is not the norm when it comes to hunted game, as it is currently illegal for hunters to let hunted carcasses spoil. This suggests that this proposal is not intended for sport hunting, but instead is a badly disguised excuse for large-scale slaughter of the native Double-crested Cormorants.
• Once the meat is spoiled and disposed of by the hunters, it would be virtually impossible to track how many cormorants have been hunted in one given season, thus negating the impact and usefulness of the monitoring program proposed by the MNRF.
• MNRF is also allowing Double-crested Cormorants to be hunted during their breeding season. Undoubtedly, some of the individual birds that will be hunted may have young chicks already. This will lead to the death of young chicks by starvation if their parents are hunted, as well as increased problems with the management of the cormorant populations.
4. Danger to humans
• Cormorant colonies are often located not far from human settlements and areas where humans are active. Such areas include Tommy Thompson Park in Toronto, Presqu’ile Provincial Park near Brighton, the Point Pelee National Park vicinity, Chantry Island near Southampton, and along the Ottawa River. These areas attract people pursuing a range of other recreational activities in all seasons, but particularly in summer. It seems extremely dangerous and misguided for the MNRF to permit hunting of Cormorants in places where potentially significant numbers of people are present, and thus at risk.
• The large scale of the hunt and the allowance to discard carcasses and let meat spoil renders the hunt unenforceable by Conservation officers, while also creating a public health risk to humans.

For the reasons identified above, Nature Canada opposes the regulatory changes allowing the slaughter of the Double-crested Cormorant, and therefore urges the Ministry of Natural Resources and Forestry to abandon the proposal.

Ted Cheskey

Naturalist Director
Nature Canada