I am writing to express…

I am writing to express concern and opposition to the proposal to establish a hunting season for Double-crested Cormorants in Ontario. My opposition is based on the following:

1. Dubious scientific rationale for the proposal;
2. Specifics of the proposal that deviate from accepted (or morally acceptable) hunting practices; and
3. The likelihood of unintended consequences.

For a government Ministry that purports to make science-based decisions and management recommendations, the current MNRF recommendation smacks of pandering to ill-informed but vocal special interest groups, with little regard for science or social norms. There are no targets expressed, and no apparent science. The rationale, such as it is, is three lines long and avoids any reference to data.

1. Double-crested Cormorants are top predators. Populations have partially recovered from past human-caused impacts, and their rebound has been fueled in large part by human-caused mismanagement of the Great Lakes fishery. The most recent population information shows that populations of these birds are stable or slightly declining on the Great Lakes. It is also significant to note that populations are not believed to be what they were at the point of European contact, in fact not to have returned to historical levels.

Cormorants eat a variety of fish species, including some fish that are valued by sport fishermen (documented in many studies, including DeBruyne et al. 2013). As declines of certain fish species have coincided with the rise in Cormorant numbers, many people have leapt to the conclusion that the cormorants are the reason for the collapse.

Cormorant numbers have recovered to the extent that management programs have been enacted to control their numbers in several jurisdictions, so we actually have some case studies to inform us. The Department of Environmental Conservation in New York implemented a control program that succeeded in significantly reduced bird numbers (Farquhar et al. 2012), notably without impacting the diversity and numbers of co-occurring waterbirds, through methods such as egg oiling, nest removal, and limited killing of adult birds (carcasses disposed of by burial). Target levels reached, the program shifted toward a less intensive program aimed at maintaining those levels. Other examples of adaptive management come from the state of Michigan (Dorr et al 2012). Again, short-term management goals were met through non-lethal harassment, supplemented by limited lethal take of spring migrating cormorants. Some of these programs were implemented despite evidence that the overall impact of cormorants on certain valued fish species was low. One thing that all these programs had in common was a carefully implemented program supported by research, and an adaptive management response.

The proposed Ontario program is embarrassingly lacking in any sort of considered implementation or assessment. Instead, a nine-and-a-half month open season is proposed, a massive bag limit of 50 birds daily, and no possession limit. A single individual could therefore kill over 14,000 birds annually, a blatantly unsustainable harvest. Added to this, it appears that hunters would be allowed to let the meat spoil, meaning that they can leave wounded birds to die and dead birds to rot, with no concern for exceeding these ostensible limits. (A confusing side note in the proposal information suggests that hunters might be required to gather fallen birds, adding trespass onto private lands to the list of unacceptable hunting practices.) Having failed to propose any reasonable steps to gather accurate information on the number of birds killed, such as those taken by other management agencies, the Ministry proposes an after-the-fact cormorant monitoring program. How this vastly underfunded Ministry, sorely lacking in equipment and staffed by people who have been told for years to stay in their offices, proposes to implement such a program is left to the imagination. Binoculars from behind their desks?

2. The proposed policy would characterize Double-crested Cormorants as “Game Birds.” The Fish and Wildlife Conservation Act defines a “game bird” as a species prescribed by the regulations - a masterful piece of circular wording. In the real world, the accepted definition of a game animal is one that is under pursuit or taken in hunting, especially wild animals hunted for food. It is clear, however, that the intent of this proposal is no such thing. Under it, cormorants can be shot in essentially unlimited numbers, no effort has to be taken to collect the corpses or indeed to ensure that the bird has been humanely killed and, as if to ensure that this is the case, hunters can shoot from stationary motorboats (eliminating the need to obtain permission from the landowner). It is crystal clear that the Ministry knows perfectly well that nobody will eat these birds, but that a certain element will be eager to slaughter them. This smacks of catering to the lowest common denominator, those with no claim to be termed “sportsmen.” Each one of these three deviations from normal hunting practices is deplorable, and should not be acceptable in the Province of Ontario.

3. One of the oddest things about Double-crested Cormorants is their capacity to generate irrational hatred in humans. This is not something new, but goes back centuries (Wires and Weseloh 2018). Most of what people think they know is based on myth and misinformation. Study after study has shown that they do not normally have any significant impact on fisheries.
As mentioned, cormorants eat a variety of fish species, and studies have shown that they are flexible in their prey selection habitats.

While many people decided that the cormorants are the reason for the collapse or declines in numbers of certain fishes, the Great Lakes form a hugely complex ecosystem, and we ignore other factors at our peril. One well-recognized change to the ecosystem has been the introduction of the invasive Round Goby - a fish from the Black and Caspian Seas in Europe, believed to have been introduced to Michigan in ballast water. It had spread to all the Great Lakes by 1994, and is a voracious consumer of fish eggs, a species with few or no predators, now working its way into inland waters. Except that Somers et al (2003) showed that cormorants had switched to a heavy reliance upon gobies in their diets. Work by Ross et al (2003) showed the shift in cormorant diets on Snake and Pigeon Islands in eastern Lake Ontario prior to and after the appearance of Round Gobies. Before, the cormorants ate mainly sport fish like Yellow Perch and Smallmouth Bass. In the years since gobies appeared, those species make only a small part of the diet, and the cormorants have shifted their attention to gobies. In the event of a wholesale slaughter of cormorants, gobies are one of the species that will benefit significantly, and that will thus be free to feed aggressively on insects and other small organisms, mussels, small fish and fish eggs, and to continue its push into inland lakes and rivers.

Another example of ecosystem complexity is the resurgence of Bald Eagles, another species rebounding from past human-caused impacts. A species of conservation concern (currently Special Concern), Bald Eagles are likely to become predators of cormorants. Indeed, this is occurring in areas where Bald Eagle numbers are better. These apex predators are known to kill both adult and young cormorants, and to cause the abandonment of colonies in some areas.

Another unintended consequence will be the impact to all the co-existing bird species. I volunteer time with the local Land Conservancy for Kingston, Frontenac, Lennox & Addington, including annual monitoring on the same Snake Island mentioned above, site of the third largest cormorant colony in the lake’s eastern basin. From annual monitoring, I know personally that this is not an island inhabited by cormorants alone. A few of the other species we have observed include: Herring Gull, Ring-billed Gull, Mallard, Black-bellied Plover, Sanderling, Least Sandpiper, Ruddy Turnstone, Spotted Sandpiper, Baird’s Sandpiper, Dunlin, and Semi-palmated Sandpiper. As well, the island has been the subject of annual studies by the Canadian Wildlife Service for over 40 years. The impact of indiscriminant shooting would be devastating to many bird species, not to mention the possible endangerment of research scientists on the island. This is a very valid concern, as the U.S. experience has shown that refuge, sanctuary, and privately-owned islands were targeted (cited by Wires and Weseloh 2018). Additionally, the killing of adults during the breeding season condemns unfledged juveniles to a lingering death without their parent caretakers.

In conclusion, I would like to see the proposal as presented scrapped in its entirety. I hate to use the term witch hunt in light of its overuse in a country to the south of us. But if a witch-hunt is an attempt to find and punish a particular group of people who are being blamed for something, that seems like exactly the right term. The only point of exception I would make is to support funding the MNRF to undertake the proposed cormorant monitoring program. If a number of years of monitoring showed actual evidence of increasing cormorant numbers, then a more reasoned approach to control should be considered. If a control program were deemed to be necessary, based on actual evidence, I would be able to support it, assuming that the presented program of control consisted of a multi-pronged approach largely based on non-lethal methods, combined with clear means of measuring success and impact.

Respectfully submitted,

Literature Cited (but a small sampling of available science):

Coleman, Jeremy, Robin DeBruyne, Lars Rudstam, James Jackson, Anthony VanDeValk, Thomas Brooking, Connie Adams, and Milo Richmond. 2016. Evaluating the influence of Double-crested Cormorants on Walleye and Yellow Perch populations in Oneida Lake, New York. In: Oneida Lake: Long-term dynamics of a managed ecosystem and its fishery, editors L. Rudstam, E. Mills, J. Jackson, and J. Stewart. Pages 397-426. American Fisheries Society, Bethesda, Maryland.

DeBruyne, Robin, Jeremy Coleman, James Jackson, Lars Rudstam, and Anthony VanDeValk. 2013. Analysis of prey selection by Double-crested Cormorants: a 15-year diet study in Oneida Lake, New York. Transactions of the American Fishery Society 152(2): 430-446.

Dorr, Brian, Shauna Hanisch, Peter Butchko, and David Fielder. 2012. Management of Double-crested Cormorants to improve sport fisheries in Michigan: three case studies. Human-Wildlife Interactions 6(1) 155-168.

Farquhar, James, Irene Mazzocchi, Russell McCullough, Richard, Chipman, and Travis DeVault. 2012. Waterbirds 35 (Special Publication1): 56-65.

Ross, R.M., J.H. Johnson, R.D. McCullough, and B. Edmonds. 2003. Diet composition and fish consumption of Double-crested Cormorants from the Pigeon and Snake Island colonies of eastern Lake Ontario in 2002. Report to Lake Ontario Committee of the Great Lakes Fishery Commission, Section 16, pages 1-12.

Somers, Christopher, Marie Lozer, Victoria Kjoss, and James Quinn. 2003. In invasive Round Goby (Neogobius melanostomus) in the diet of nesting Double-crested Cormorants (Phalacrocorax auritus) in Hamilton Harbour, Lake Ontario. Journal of Great Lakes Research 29(3): 392-399.

Wires, Linda and Chip Weseloh. 2018. Resolving conflicts with Double-crested Cormorants (Phalocrocorax auritus): the importance of knowledge-based and non-traditional approaches, an introduction.