Subject: ERO number 019-4093…

Subject: ERO number 019-4093 — Amending the Darlington Provincial Park Management Plan to allow for the management of native species

This is in response to the “Invitation to Comment” on the “Proposed Amendment to the Darlington Provincial Park Management Plan”.

We wish to begin by thanking you for inviting public opinion and for the Ministry’s continued upgrade of the management plan, recognizing the increasing necessity to do so in light of the rapid changes that are occurring in the environment caused by climate change and other anthropogenic activities.

Introduction:

The language used by the Ministry staff in their document leaves us greatly concerned that the Ministry has accepted an extremely troubling narrative that demonizes a single species of native wildlife, the Double-crested Cormorant (Phalacrocorax auritus). As discussed in the book, The Double-Crested Cormorant: Plight of a Feathered Pariah, by Linda R. Wires, Yale University Press, 2014, there is something about the cormorant that triggers many people to have irrational reactions, exclusive of the analysis of numerous academics and others whose experiences lead them to a more accurate understanding of the species’ role within the ecosystem.
We fear, too, from its language, that the Ministry has failed to use basic ecological principles when considering management procedures in the interest of conservation of endangered species and achievement of other park management objectives.
We support conservation initiatives, including the continued implementation of the Ontario Species at Risk Stewardship Program (SARSP), the delivery of viable recovery strategies and other mandated conservation measures. Our focus, here, is entirely on the Ontario government’s avoidance of scientific objectivity in assuming that one Ontario species, the Double-crested Cormorant, is inherently not a natural part of our province’s ecological whole.

Our concern is assuredly bolstered by the fact that the government has taken the unprecedented step of amending the Ontario Fish and Wildlife Conservation Act to classify the cormorant as a gamebird and allow their carcasses to be wasted. Once the amendments passed, the government then allowed a bag limit of 15 birds per day from mid-September to the end of December, a take that could exceed the entire population of the species in the province. Finally, the government allowed the hunt to go forward without any management requirements such as monitoring populations before the hunt occurred and the number taken during the hunt. Those management requirements are recognized as essential by all game management authorities in the western world. The entire exercise is opposed by scientists and criticized for its lack of adherence to basic game management standards and these views have been well publicized. The hunt has been shown to be antithetical to the most basic principles of game management and has clearly triggered widespread opposition from the academic and conservation communities.

The opposition from the academic community manifested itself, through the means of a letter, currently containing 51 signatures, that says, in part, “Cormorants are a native species to Ontario [reference given]. Significant financial resources were invested in creating a healthier environment which allowed them to recover. Their abundance is a conservation success story. To avoid the species becoming endangered again, the population needs to be conserved using the best wildlife management practices and their populations carefully monitored. A public hunt is not the approach that should be utilized to ensure a sustainable population of cormorants in Ontario."
That the Ontario government ignored this, and other such concerns based on facts, certainly contributes to the concerns that generate the detail of this response. The history of the Double-crested Cormorant has proven it has significant vulnerability to persecution and environmental degradation. The species has twice in recorded history of the province been very nearly extirpated as a breeding species in Ontario.

Even though Darlington Provincial Park has only ever recorded 2 unsuccessful cormorant nests (2019) and flocks have been seen offshore, which is to be expected in the Great Lakes Basin area, the comment document only lists two species, cormorants and the endangered Piping Plovers. The document intimates that it is the cormorants that might interfere with the successful breeding of the Piping Plovers when cormorants don’t eat any birds, chicks or eggs and they don’t nest where Piping Plovers nest. The Park is home to other species that do search out and eat ground nesting birds yet they are entirely absent from the comment document and no explanation is given.

In the Invitation to Comment document, the Ministry is clear in its objectives:

• …allow us to “manage native wildlife populations [e.g. Double-crested Cormorants] with the potential to grow to the point that there may be a negative impact on the park’s ecosystems” (Source: Page 2.)
• The proposed changes will help the ministry preserve habitat for Piping Plover, a species at risk, and enable actions to prevent a Double-crested Cormorant colony from damaging the ecological integrity of McLaughlin Bay, which is a provincially significant coastal wetland. (Emphasis ours.) (Source: Page 2.)
• “Ontario Parks staff are monitoring the area and using pre-nesting control techniques (e.g. (example) noise deterrents) to try to deter cormorants from nesting in the park.” (Emphasis ours.) (Source Page 3.)
• “However, if the colony becomes established and continues to grow and nest in the park, this will threaten the ecological integrity of the wetland and we may need to consider to undertake cormorant population management.” (Emphasis ours.) (Source: Page 3.)
As these statements show, the direction taken by park staff is to prevent cormorants from nesting at Darlington and should they do so, lethal measure are likely to be employed. Cormorants are the only native wild species in Ontario to be forbidden to be part of the natural ecosystem of the park even though the park adjoins Lake Ontario with natural prey of the species of fish and potential nesting habitat. If cormorants are not allowed to nest on public land and if not private land, then where are they allowed?

WILDLIFE MANAGEMENT VS SCIENCE:

We recognize the difference between the relevant sciences, such as ecology, which must be value neutral, and wildlife management, which may or may not use science-based information, language and technology but serves politically determined objectives, thus is value-based.

The Invitation to Comment discussion document Ontario Parks provides, contains no scientific or wildlife management reasons to justify excluding cormorants (an Ontario species) from Darlington Provincial Park. We will elaborate below with regard to Piping Plovers and protection of McLaughlin Bay. However, the management plan should provide a reason why this one native species, cormorants, is not allowed to nest in the park and give the public an opportunity to comment.

THE PIPING PLOVER:

We support management options directed toward protection for such endangered species. But surely such management options are not necessary when directed against a species poses no threat to the endangered species.

The Piping Plover is endemic to North America, having its main centres of breeding distribution in the prairie states and provinces and along the temperate U.S. Atlantic coast, although it was once common in Ontario. It is an obligate shoreline nester requiring a substrate of sand adjacent shallow water -- typically an often ephemeral and always variable condition often characteristic of sand bars, barrier islands and beaches. At present, according to the Ontario Ministry of the Environment and Energy’s report titled “2019 review of progress towards the protection and recovery of Ontario’s species at risk” (Source: https://www.ontario.ca/document/2019-review-progress-towards-protection…), 24 populations of Piping Plover have been documented within Ontario, of which eleven are considered extant, having been seen within the previous two decades, including the well-documented pair at Darlington Provincial Park. Given that the species was listed as extirpated from the province by 1986, all nests significantly contribute to the protection of the species overall.
Population designations as defined legislatively vary jurisdictionally, but throughout its range the Piping Plover is listed either as threatened or at some other level of risk, or endangered, the latter designation applied to the Great Lakes population, which includes at least one nest each at Tiny Township, Sauble Beach, Manitoulin Island, Wasaga Beach, Darlington Provincial Park, Limestone Islands Provincial Park and Sable Island Provincial Park.

The Piping Plover is listed as “endangered” by the Species at Risk in Ontario (SARO), and under the Endangered Species Act. In 2015 the Toronto Island nest was washed away by high water but it is worth noting that, in fact, that nest site is literally a few kilometers from the largest colony of Double-crested Cormorants currently extant in eastern North America but neither there nor anywhere have cormorants ever been found to prey upon, displace or otherwise compromise the survival of Piping Plovers at any stage of their life cycles.

Both species suffered severe declines, often for overlapping reasons, such as the feather trade, up until the very early 20th century. According to the link above cited Ontario Ministry of the Environment and Energy, “With rapid increases in shoreline development and recreation, combined with natural weather events and predation, populations [of Piping Plovers] severely declined and by 1986, Piping Plovers were considered extirpated in Ontario.” Cormorants do not prey upon birds, or birds’ eggs, and do not contribute to storms or high water and are themselves prevented from nesting by “increases in shoreline development and recreation.”

The list of mammals that might reasonably be expected to occur in Darlington Provincial Park and that prey upon birds, birds’ eggs and/or chicks, includes, but is not limited to, the Virginia Opossum, Red Fox, Coyote, Raccoon, Fisher, Short-tailed Weasel, Long-tailed Weasel, American Mink, Striped Skunk and possibly the River Otter, while the list of birds that might reasonably be expected to occur in Darlington Provincial Park that are known to, or certainly could, prey upon birds, birds’ eggs and/or chicks is much longer, and includes, but is not limited to, Great Blue Heron, Bald Eagle, Northern Harrier, Sharp-shinned Hawk, Cooper’s Hawk, Broad-winged Hawk, Red-shouldered Hawk, Red-tailed Hawk, Merlin, American Kestrel, Peregrine Falcon, Ring-billed Gull, Herring Gull, Long-eared Owl, Short-eared Owl, Great Horned Owl, Barred Owl, Eastern Screech-Owl, American Crow, Blue Jay and Common Raven. To this list should be added at least a few species of predatory snakes, and yet not one of all these species is named in the Ministry’s Invitation to Comment explanatory document, only a species that poses no threat, the Double-crested Cormorant. Some species are likely to kill Piping Plover adults, or chicks or their eggs, such as the Merlin, which patrols beaches and captures shorebirds, or the Striped Skunk or Raccoon, who specifically search for birds’ eggs, or the gulls or crows that patrol beach and other habitat in search of eggs and baby birds, but are all ignored while a species that does not prey upon adult or baby birds or their eggs, is mentioned.

Controlling cormorants in this park makes no sense; an absurdity literally beyond comprehension.
We are not advocating or in any way commenting on controls of Sharp-shinned Hawks because they preferentially prey upon birds, or gulls who share the Piping Plover’s habitat and are intelligent omnivores who search out baby birds and eggs, or the culling of Striped Skunks who regularly consume eggs of ground-nesting bird species, but we do demand that in the interest of factuality, in the interest of respect for Ontarians, that you remove all reference to cormorants that suggest or imply that they in any way threaten Piping Plovers, their habitat, their nests or their eggs.

Protecting endangered species is within Ontario Parks mandate. Misrepresenting any native species of wildlife is not.

According to the Handbook of the Birds of the World, (del Hoyo, J., A. & Sargatal, J. eds (1996) Handbook of the Birds the Birds of the World. Vol. 3. Hoatzin to Auks. Lynx Edicions, Barcelona), the Piping Plover “Came close to extinction around 1900, due to excessive hunting, with range decreasing considerably during second half of 19th century. Numbers now decreasing again, as result of expanding recreational use of beaches, increasing water levels and development of winter habitat. Protection measures involve closing nesting beaches to humans and restricting access of off-road vehicles; constructing predator exclosures around nests, avian and mammalian predator control; mitigation of water level policies; vegetation control; and creation of artificial habitat.”

Activities, such as hunting and development, promoted by the Ontario government, certainly can put Piping Plovers and many other Ontario wildlife species at risk but nowhere can we find any species of cormorants described as predatory on any species of bird or bird eggs, or described as a risk factor to the survival of the Piping Plover, and yet only the Double-crested Cormorant is mentioned (incorrectly) in conjunction with conservation of the Piping Plover.

HABITAT AND “ECOLOGICAL INTEGRITY”:

The Invitation to Comment document provided by the Ministry of the Environment, Conservation and Parks (https://ero.ontario.ca/notice/019-40930 pages 2 & 3) states its aim is to allow management of "native wildlife populations [e.g. Double-crested Cormorants] with the potential to grow to the point that there may be a negative impact on the park’s ecosystems. The proposed changes will help the ministry preserve habitat for Piping Plover, a species at risk, and enable actions to prevent a Double-crested Cormorant colony from damaging the ecological integrity of McLaughlin Bay, which is a provincially significant coastal wetland. Ontario Parks staff are monitoring the area and using pre-nesting control techniques (e.g. noise deterrents) to try to deter cormorants from nesting in the park. However, if the colony becomes established and continues to grow and nest in the park, this will threaten the ecological integrity of the wetland and we may need to consider undertaking cormorant population management.”

The park staff fail to provide any evidence that a species native to a given ecosystem can cause damage to the “ecological integrity” of that ecosystem by virtue of its presence. Cormorants are part of the ecosystem. Their actions help define the ecosystem. Native waterbirds are meant to be where there is water and fish. There is no “ecological integrity” that is violated. Healthy ecosystems displaying biodiversity can feature very large assemblies of one or a few species, as the historical record makes very clear.

Another way to assess the undefined concept, “ecological integrity”, draws upon another commonplace meme in popular use: “biodiversity”. Here is a definition, “Biodiversity is the shortened form of two words "biological" and "diversity". It refers to all the variety of life that can be found on Earth (plants, animals, fungi and micro-organisms) as well as to the communities that they form and the habitats in which they live.” (Source: https://www.pbl.nl/en/en/topics/biodiversity/introduction-biodiversity)
Thus, when Piping Plovers began nesting at Darlington Provincial Park, biodiversity within the park was enhanced. A species has been added to the list of species of vertebrates breeding in the park, and has been so at no loss of another species. Biodiversity would be enhanced even if the Piping Plover were not endangered. If Double-crested Cormorants nest there, they would enhance biodiversity; they would increase the number of bird species known to nest in the park by one, as did the plover.
The Ministry’s concern appears to be that the presence of cormorants at Darlington McLaughlin Bay could happen at the expense of another species.

We see no reason, and certainly the Invitation to Comment document provides none, to think that loss of another species would, or could, happen as a result of cormorants nesting in Darlington Provincial Park.

While it is implicitly stated that the Double-crested Cormorant somehow puts the Piping Plover at risk, it clearly does not. Cormorants do not prey upon plovers, their eggs or chicks, or compete with the plover for food. At worst, roosting cormorants might temporarily occupy a few square meters of beach otherwise available to the plover, but so might any other bird species that might stand on the beach and cormorants, unlike gulls, do not tend to stand on sand beaches.

The cormorant is both a tree and ground nesting species. Most ground nesting colonies start in trees and move to ground nesting when trees are not available. Conceivably cormorants could nest on the beach and could displace the plover, but cormorants don’t nest on beaches where there are people. In fact, they don’t really nest on bare expanses of open sand, the “micro-habitat” essential to the Piping Plover. At the East Toronto Headland, in Toronto, the only places cormorants nest is where people are not allowed. The presence of people deters cormorants from nesting on the ground or from starting nests in trees. Researchers studying the nesting cormorants keep hidden by use of blinds.

Ironically, the management objective at the East Toronto Headland is to reduce or prevent cormorants from nesting in trees, and the success achieved was recently reduced by vandals who wiped out half the ground nesting colony, apparently just by entering the colony.

At Presqu’ile Provincial Park, the presence of cormorants not only increased the park’s biodiversity by virtue of their own presence, but they paved the way for Great Blue Herons, who often co-inhabit cormorant nesting colonies, and have never before nested there.

Again ironically, the addition of two new species to the birds breeding in PPP was reduced to one when parks staff, attacking cormorant nests, wiped out the only Red-tailed Hawk nest in the park!
Presqu’ile is famous for its sandy beaches potentially suitable for nesting Piping Plovers, but they are not occupied by cormorants. It is people that are the deterrent to Piping Plovers in an otherwise viable habitat.

TREES:

Generally speaking, in a very broad sense, nutriment in ecosystems follows the flow of water via streams, rivers and lakes and ultimately the sea. Cormorants are a means by which nutriment can be transferred from the water back to the land, via the birds’ digestive systems. Cormorant excrement, called guano, is highly rich in nutriment, in turn derived from their aquatic diets. Such high concentrations will, through time, be diluted enough by rain and snowmelt to be beneficially accessible to plant life, but initially it can be very deleterious to plant-growth, not unlike over-fertilizing a bed of flowers or the front lawn.

The concentrations of nitrogen and other nutriments that a waterbird colony can generate can kill trees, a process most likely exacerbated by another characteristic of cormorant excrement. Because it is opaque and sticky guano can coat leaves to a degree that can compromise photosynthesis, accelerating tree death. And while cormorants routinely carry dead branches found elsewhere to be used as nesting material, used either in trees or on the ground, when tree-nesting they also will sometime reach for nearby branches and break them off, which further compromises the tree’s health. As a result, cormorants can, through a few years of nesting activity, turn a green woodland into a splintered and at times unpleasantly odorous landscape of broken dead trees and jagged, guano-coated branches.

This effect is very disconcerting to many people and undoubtedly helps fuel that visceral antipathy the species seems to generate. But that antipathy again stems from a lack of understanding of basic ecological principles. Even excrement is part of the ecological whole.

Cormorants are classed by ecologists in a loosely defined group of disparate animal, plant and other species, such as kelps, as ecological engineers. Perhaps the most recognized member of this group in Canada is the Canadian Beaver.

While it is to be hoped that cormorants will some day nest in Darlington Provincial Park, and that the nests will be protected, it is unlikely, due to the amount of human disturbance, and even if they do, it would unlikely be in large enough numbers to cause deaths of many, if any, trees. Ground nesting is not likely an option given that cormorants don’t nest on the ground where there are people.
The widespread persecution of cormorants, encouraged by the current provincial government, has resulted in a reduction of viable nest sites for cormorants in Ontario, thus pushing them to try nesting in suboptimal locations. That would include the barrier beach at Lynde Shores Conservation Area, in Whitby, not too far west along the Lake Ontario shoreline from Darlington Provincial Park. There was a line of mature Black Willows along that beach, between Lake Ontario and the marsh, and a few years ago a small number of Double-crested Cormorants tried to nest in them. The colony could never have grown very large as there were only a few dozen trees and the ground below was not viable due to excessive human use.

But the colony failed abruptly when a severe windstorm blew down nearly every tree. That is how it is in ecosystems – they are dynamic. But there was, as a result of the loss of the trees, no compromise that an ecologist would see in “ecological integrity”. When mature willows fall, so long as the root remains they send out numerous shoots which form habitat for other species. In fact, Song Sparrows are now occupying the shrubbery created by the blowdown of the willows, and the habitat is potentially more suitable for other species of wildlife, including snakes, Eastern Towhees and Yellow Warblers, than it was at the time when the willows were at their peak maturity and the cormorants were yet to arrive.

Should cormorants start to successfully nest in Darlington, we can’t accurately predict the outcome of their influence on the ecosystem. But we would see a continuation of ecological integrity, and we would see a net gain, not loss, in biodiversity. We have compared Middle Island, where cormorants are culled, and East Sister Island, where they are not, both part of the Lake Erie Island Archipelago, and found that cormorants can show very little effect on vegetation, with species counts of flora about the same for both of these wooded islands.

It is ironic that if the cormorants did kill off their nesting trees, the outcome would be closer to habitat viable for nesting Piping Plovers, a species that does not nest in, or under, trees. However, cormorants avoid nesting on the flat, open, minimally or non-vegetated sand favoured by the plovers, and do enrich soil in the long run, so would neither hurt nor harm nesting habitat for the plovers.
Cormorant colonies are not permanent and so even if there is eventual tree loss, it only means that the cormorants will move on, leaving behind a changed nutriment balance in the soil where they once nested.

FISH:

In the past, part of the demonization of cormorants, arguably the major part, was the concern that they competed with commercial and sport fishermen for the same species of prey -- fish. This narrative still seems to hold sway in much of the United States. It is perhaps a credit to Canadians that for the most part, with the exception of the current government of Ontario, there is a general understanding that with isolated exceptions under the right, and usually quite contrived, conditions, cormorants and other fish-eating animals, such as otters, loons, grebes and mergansers, do not directly or indirectly impact negatively on populations of fish of concern to commercial or sport angling interests.

Put simply, in a naturally co-evolved predator-prey relationship, it is the population size of the prey that determines the population size of the predator, not vice versa. The dynamics informing population sizes, including recruitment rates, and the demands on the predator imposed by diminishing numbers of prey assure what is sometimes called a “balance” or carrying capacity, although really more of a dynamic, that assures continuation of both.

In Lake Ontario, the large number of non-native species of fish and invertebrates now found in the lake, including those intentionally placed there by the government of Ontario, helps to explain why there seems to be so many more Double-crested Cormorants nesting in the Great Lakes Basin than there were in more primal times. The assembly of fish species available to them has changed dramatically, with huge population sizes of species that were historically absent, but that meet the needs of cormorants, now present.

Those of us of a certain, advanced, age remember the great shoals of dead Alewives washing up on the Lake Ontario shoreline. That is a thing of the past because of species now present that were absent in those days. Those species include Salmonids – non-native species such as the Coho Salmon, and the native Atlantic Salmon once extirpated entirely but now being successfully restored, and also the Double-crested Cormorant. The cormorant was not planted there by governments but is recovering from extirpation following excessive persecution in the 19th century, and the population crash due to persecution and the advent of wide use of organochlorides, specifically DDT, following WWII. The second recovery is now threatened by government policy which we ask to not include Ontario Parks policies and practices.

But Alewives are not native. Nor is another species that has reached vast abundance in the Great Lakes, the Round Goby. These, plus many other species such as Rainbow Smelt, Gizzard Shad, some of the Sticklebacks, Sea Lampreys, etc., are all consumed by cormorants but were absent prior to the mid to late 19th century, or later. Some native species also consumed in what might be deemed significant numbers are probably more common, relatively, now, than historically, and this specifically includes the Yellow Perch.

CONCLUSIONS:

As Double-crested Cormorants:

• are native to Ontario
• are ecosystem engineers
• are part of dynamic ecosystems which includes taking branches for nesting material
• have lived with many species of fauna and flora for millions of years
• have only had 2 unsuccessful nests at Darlington Provincial Park in 2019 according to the Park Superintendent and none since
• never eat other birds, their chicks or eggs
• don't nest on beaches or areas frequented by humans
• are an important source of prey for recovering Bald Eagle populations which are in the area
• are major predators of invasive fish species including round gobies and alewives thus benefiting native fish species
• and all waterbird colonies provide wildlife observation opportunities for photographers, birders, hikers and boaters
• are scapegoated for a number of problems caused by humans
• after almost being wiped out twice, the return of cormorants to the Great Lakes Basin is a conservation success story to be celebrated

And, as “the Ministry of the Environment, Conservation and Parks has a responsibility to protect representative ecosystems, biodiversity and provincially significant elements of Ontario’s natural heritage in provincial parks.” (Source: Page 1 of Comment Document)

GREAT LAKES CORMORANTS’ RECOMMENDATIONS ARE:

1. That all effort be made to protect the Double-crested Cormorant, both individual birds and their nests, in Darlington Provincial Park, and to educate the public as to their role in nature and to present their survival as a conservation success story indicative of a healthy environment and healthy fish populations.

2. That there should there be a reason presented by Ontario Parks why this one species, the Double-crested Cormorant, not be allowed to nest in the park before any further “management” is devised or implemented. The need for management should be explained, with opportunity for public comment. Birds removing branches for nest building and excreting waste from eating fish is a normal behaviour.

3. That all efforts to discourage cormorants or any other native wildlife species from breeding and/or nesting in the park stop immediately, and not be resumed unless or until the need has been established through a process that includes public review and science-based assurance that it will be both necessary, non-lethal and that it will likely achieve the goal.

Respectfully submitted on behalf of Great Lakes Cormorants.