Dear Minister Yakabuski, Re:…

Dear Minister Yakabuski,

Re: EBR 013-4124: Proposal to establish a hunting season for double-crested cormorants in Ontario

I tried to separate my comments from the proposal wording using both colour and italics but neither worked, so I tried separating them.

I strongly oppose the proposal for a hunting season for the double-crested cormorant.

the latest information indicating Great Lakes populations have since stabilized or declined

If the latest information indicates that populations have even declined, perhaps focus should be on reasons for decline rather than on instigating a new reason. Following the instigation of the hunt, the Ministry says that it
will implement a cormorant monitoring program to assess population status and trends. Monitoring of cormorants will allow the Ministry to assess the impacts of the hunting season and to adjust cormorant hunting regulations if necessary to address any concerns about population sustainability.

This monitoring programme should be implemented before even considering instigating a hunt so that the hunt, its regulations and any amendments thereto are all based on the same good science!

Create a hunting season for double-crested cormorant beginning in 2019

This should be postponed until the monitoring programme is up and running and has produced some meaningful data.

As for the fishing industry, research has shown that cormorants feed mainly on non-game, non-commercial fish, and include alien and invasive, non-native species (e.g. round goby).

Some people complain about the smell of the bird's guano, yet the smell of dead and rotting birds will be much worse! Unlike for all other game birds, the proposed cormorant hunting season is right through the breeding season which means that baby birds will be left to starve to death, rot and stink much worse than the guano!

Proposed regulations include:
1. List the double-crested cormorant as a “Game Bird”. Hunters would be required to have an outdoors card and small game licence to hunt double-crested cormorants, similar to other species of game birds.

This is just a money grab that will encourage those who can't be bothered to do real hunting to, in some cases, just walk out their door and go on a shooting spree.

2. Create an open hunting season for double-crested cormorant from March 15 to December 31 each year across the province.
3. Create an exemption allowing small game licences to be valid for double-crested cormorant hunting in central and northern Ontario from June 16 to August 31 each year.

This is completely unacceptable! All other game bird hunts are conducted in autumn and winter and for a very few species or locations, into very early spring. This proposal is in violation of the federal Migratory Bird Convention Act which protects migratory species during the nesting season! Cormorants do not nest in solitude. They often nest with other colonial nesting species such as great blue herons, great egrets (listed provincially, as very rare in Ontario) and black-crowned night herons (listed as rare-uncommon in Ontario), as well as other bird species. Shooting will disrupt all the nesting birds and could certainly lead to nest abandonment by these other species. Eggs could be left unhatched and nestlings to starve or die of exposure when parents are frightened away or accidentally shot. Some cormorant colonies are located near bald eagle nests. Both species suffered dramatically from pesticide. Both eat fish. Much money, time and effort has been spent in bald eagle recovery. It is currently listed in Ontario as common in the breeding season. Both species are considered to be recovery success stories. The proposal's conditions that require the person to retrieve and dispose of the carcass will further disrupt and distress breeding birds. Further, this could lead to someone throwing the bodies into the nearest garbage can where they will rot with a most putrid smell! This would further chase residents and tourists out of the area. The breeding season must be omitted from the hunting schedule.

Hunters will likely not be savy enough to distinguish between the double-crested and other species of cormorants which occasionally visit Ontario. Any and all would be shot. And, as an unusual bird, of any sort, attracts many, even many hundreds of birders, they too could be at risk of being accidentally shot.

6. Allow hunting from a stationary motorboat.

Even a 'stationary' boat moves under the movements of the people therein and any waves. Collateral damage to non-target species must be avoided, especially to humans!
The proposed hunting season coincides with the peak in Ontario outdoor activity: whether strolling along a lakeside, swimming, boating, beach sunbathing, partaking in water sports, kayaking, bird-watching, photography, etc. No one wants to be shot or be shot at, or to have that happen to someone they know.
We cold be in a boat on one side of an island watching the birds, and someone in a boat on the other side could shoot toward us. Neither may have any way of knowing that the other is there until too late. Summer hunting will deter tourists and residents alike from enjoying Ontario summer.

4. Establish a bag limit of 50 cormorants/day with no possession limit.

This is outrageous! 50/day is a minimum of 5-fold higher than any other game bird (the closest being the non-native ring-necked pheasant with 10).
This would mean that one shooter daily could murder as many as 14,600 cormorants in a single year!
The no possession limit seems to imply that one could catch/trap additional birds beyond the bag limit. Surely this is unsustainable! Where is the data to back this up?

The Fish and Wildlife Conservation Act currently prohibits anyone who kills game wildlife (including game birds), or who possesses game wildlife killed by hunting, from allowing that meat to spoil.

Surely this was so that hunting had a food purpose and was not just wanton killing , not just for fun or for a few animal parts, but so that an animal lost its life for some 'semi-descent' purpose. Also it would not promote disease, smell or an unwanted increase in scavengers. Since cormorants are purportedly not good tasting, hunters may be tempted to shoot and leave, therefore the requirement of retrieving the carcass must be part of the regulation. However, because this would cause even more disruption to all breeding birds, the breeding season must be omitted from the hunting schedule!

This proposal would add provisions to the Act, so that persons who lawfully hunt (or possess) cormorants could be exempt from this requirement and would be subject to conditions that require the person to retrieve and dispose of the carcass.

This isn't a hunt. This is simply a cull. Some will be shot, others will die long agonizing deaths.

Regulatory impact statement
The anticipated environmental consequences of the proposal are expected to be neutral. The double-crested cormorant is abundant in Ontario and anticipated levels of harvest aren’t expected to affect sustainability.
At a maximum of 14,600/hunter/year, this may not be true.

Hunters will continue to be reminded to properly identify their targets to avoid conflicts with migratory game birds and other waterbirds.
Who will train them? Different cormorant species are difficult to tell apart, and grebes and loons are similar. If birders have difficulty how will hunters identify them?

I summary, I am against the proposed double-crested cormorant hunt, particularly for the length of time of the hunt, the bag limit and the unlimited possession.

K. B.