To Minister Yakabuski and…

To Minister Yakabuski and the Public Input Coordinator (Wildlife Section) of the Ontario Ministry of Natural Resources and Forestry (OMNRF),

I write with great disbelief and disappoint with respect to the “Proposal to establish a hunting season for double-crested cormorants in Ontario” (EBR Registry Number 013-4124) – disbelief because of the absurdity of the proposal contents and disappointment because the OMNRF has again lost substantial credibility with respect to science-based wildlife management. As well-phrased in a statement by the Ottawa Field-Naturalists’ Club (OFNC), the current proposal is “a legalized extermination of an ecologically important native species.” At best, the current proposal is a cruel, perverse, and misguided cull. At worst, the proposal risks significant ecological disturbance of sensitive ecosystems. Consistent with the stance of Bird Studies Canada (linked below), “the proposed changes pose significant harm to a native Ontario wildlife species, have the potential to negatively impact other wildlife species and habitats, and also lack scientific rationale or justification”.

In brief, the proposal wholly lacks science, from the setting of an absurd hunting quota, which strangely inflated a bag limit of 10/day to 50/day in back-to-back EBR postings, to the exceedingly vague monitoring proposal. It begs to be said that the absence of science in the proposal reads like a pander to a high-ranking and ill-informed government employee disgruntled over cormorants on their lakefront property.

My stance in opposition to the proposal is fully in line with that outlined by Bird Studies Canada and Professor Gail Fraser of York University (both sources linked below), with major flaws including but not limited to:
- The orphaning of young cormorants is a cruel and unusual allowance;
- Large potential of conflict between hunters and outdoor recreationalists over the geographically broad and lengthy hunting period;
- Furthermore, I am strongly opposed to amendment to the Fish and Wildlife Conservation Act that would allow for meat spoilage of a so-called games species;
- The threat of cormorants to sensitive habitats is localized (e.g., past lethal management in Presqu’ile Provincial Park). Thus, any such threats should be dealt with in a localized manner (e.g., hired sharp-shooter for local population reduction), rather than the blanket, geographically widespread and ‘public hunter call-to-arms’ strategy outlined in EBR Registry Number 013-4124.

I am particularly troubled by the absence of attention to protect other sensitive species that share double-crested cormorant habitat. It is noteworthy that Double-crested Cormorants in flight bear a very close visual likeness to rare visitors to Ontario, such as the Neotropic Cormorant and Anhinga. Only under ideal viewing conditions could these species be distinguished, never mind from the bow of a boat with an itchy trigger finger. I would argue that ducks, geese, herons, loons, grebes and just about anything else that flies over water is at risk due the inadvertent misidentification from a hunter, and with such a low likelihood of enforcement (due to the temporal and spatial breadth of this proposal) the killing of non-target species has the potential to be widespread.

Again, consistent with a statement from the OFNC, “the proposal has serious flaws that would be detrimental to the ecosystem and would undermine responsible conservation practices”. While I believe that it may be possible to instate a legal hunt for the Double-crest Cormorant in Ontario, the proposal presented in EBR Registry Number 013-4124 promotes an extremely poor framework. The allowance for spoilage is unacceptable would set a very misguided precedent for “game” species. I would be highly disappointed to see the OMNRF produce a response stating something of the like that “public comments here heard and changes were made in response”, whilst simply reducing the daily bag limit (e.g., from 50 birds/day to 10 birds/day), a shortened open season, and some modification of the spoilage allowance, for example. This is a proposal that needs to be redrafted in its entirety with the consultation of expert scientists and scientific resources. At present, I cannot reasonably support any part of EBR Registry Number 013-4124, “Proposal to establish a hunting season for double-crested cormorants in Ontario”.

Thank you for considering my feedback.