RE: ERO 019-4093 – Proposed…

RE: ERO 019-4093 – Proposed Amendments to Sections 5.2 and 5.3 of the Darlington Provincial Park Management Plan (2014).

We the undersigned strongly oppose the proposed revision that provides for the control of native wildlife populations, specifically section 5.3 “Wildlife Management” with the focus on control of Double-crested Cormorants. The proposal to control and manage native species to “protect park ecosystems” is not only an inherent contradiction, but also based on unfounded and baseless assumptions of the impact of cormorants on natural habitats. Further, the specific focus on cormorants reveals this to be an extension of the provincial government’s persecution of this valuable native species through the recent amendments to the Fish and Wildlife Conservation Act. I encourage the MOECP to review and revise its policies on the management of cormorants in Ontario and consider a science-based approach to wildlife management.

1. Need for Proposed Revision

Currently, the DPP Management Plan section 5.3 “Wildlife Management” provides for:

• A controlled waterfowl hunt on McLaughlin Bay sanctioned through regulation under the Fish and Wildlife Conservation Act.
• Nuisance animal control, if necessary, under strict supervision of or directly by Ontario Parks.
The revision proposes to add “Native species with the potential to become hyperabundant (e.g., Double-crested Cormorants) may be managed, as required, to protect the park’s values and ecological integrity” and “Population management will consider the broader landscape and best management practices”.

It appears that the current wording more than provides for any measures required to take action to protect the “park’s values and ecological integrity”. It can only be presumed that the additional wording is intended to lay the groundwork for targeted lethal control of cormorants.

• The proposal does not provide any references, assessments, or scientific studies to form the basis for these additional provisions.
• The proposal does not clarify how to assess a species “potential to become hyperabundant”. Is it simply by being present and breeding?
• The proposal does not clarify the point at which a species is considered “hyperabundant”.
• The proposal refers to protection of the park’s “values and ecological integrity”.

Nowhere in the proposal, or in the existing Darlington PP management plan (2014) are Values and Ecological Integrity clearly articulated as a point of reference. One of the core “values” should be the conservation of native species like Double-crested Cormorants and the recognition of their natural role in the ecosystem.

It can only be concluded that the wording is deliberately vague and unclear for the purpose of unchallenged lethal cormorant control measures. Otherwise, the proposed revision is unnecessary, unscientific, and should be abandoned.

2. Inconsistency with the “Values” of the Darlington PP Management Plan (2014)

The proposal refers to the protection of the park’s “values and ecological integrity”. Nowhere in the current Darlington PP Management Plan are these explicitly stated or articulated.

Section 4.5.2 of the existing Darlington PP Management Plan describes the two “Natural Environment Zones” that includes the Robinson Creek stream valley and the western portion of the park that features McLaughlin Bay, its barrier beach, associated marsh/wetland, wet meadows, adjacent backshore areas, and Lake Ontario lakebed. The stated Natural Environment Zone Policies include a commitment to “take approved management initiatives to improve and enhance the environmental qualities and resources found in these areas”. Numerous scientific studies have demonstrated the positive ecological impact of cormorants and cormorant colonies as “ecosystem engineers” (Hobson 2021, Cooke 2021). These include:

• Defoliation at roosting sites increases habitat diversity and benefits small mammal populations which in turn, benefits other wildlife.
• Contribute to healthy fish populations through predation on unhealthy or invasive fishes. This can only benefit sport fishing, a stated priority of the Darlington PP Management Plan.
• Promote nutrient cycling via excretion and egestion and play an essential role in the nitrogen and phosphorus nutrient flux in freshwater systems.
• Cormorant colonies are often viewed as “sentinels”, alerting other species to the presence of predators such as foxes and coyotes. This could potentially benefit recent nesting by Piping Plover on the nearby beach.

Any proposed control of cormorants in Darlington PP needs to be scientifically validated and use an ecosystem approach to assessing impacts.

Section 5.0 “Resource Management” makes several statements regarding actions and projects related to landform and water management, vegetation management, and wildlife management. Resource management projects that may be undertaken to “restore and/or rehabilitate McLaughlin Bay” includes projects for

• Habitat enhancement or restoration (fish and wildlife)
• Restoring natural environments (vegetation)

The presence of cormorants and cormorant roosting sites supports these projects.

3. Scientific Basis for Cormorant Control

The specific mention and targeting of cormorants in the proposed revision to the Darlington PP Management Plan is presumptive that the presence of cormorants will have a negative impact on the park ecosystem. This is based on the unfounded belief that cormorants adversely impact fish populations and that cormorant colonies cause extensive property damage. It also overlooks the numerous scientific studies across North America that clearly demonstrate that:

• Cormorants target non-game species and have an insignificant impact on forage species.
• Property damage is usually quite localized and is part of a natural cycle of habitat diversity and restoration.

The proposed revision appears to be an extension of the uninformed policy by the province that is based on a simplistic and scientifically unfounded understanding of the complex role this native species plays in the Great Lakes ecosystem. Hobson (2021) emphasizes that cormorants are “scapegoats” for the catastrophic and long-term mismanagement of the Great Lakes fishery.

The justification for control of any native species, including cormorants should be based on sound science. In the case of cormorants at the Darlington PP, this justification needs to be based on local studies with clear evidence of significant adverse impacts on specific native species or habitats in the McLaughlin Bay Natural Environment Zone. The elements of any proposed control program should include:

• Baseline studies to quantify the level of impact (s).
• Clearly stated goals and objectives for any proposed population control.
• Robust monitoring and reporting program to track progress and assess impact.
• Principles of adaptive management to adjust measures and reassess.
• Implementation by skilled professionals (government or government contractors) and NOT by the public.

According to the proposed amendment, 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”. It further states that 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.”

There are many unanswered questions to these statements.

1. On what basis is the park trying to deter cormorants from nesting in the park? The proposal provides no studies to back up this presumption.
2. There is a presumption that growth of the colony will threaten the ecological integrity of the wetland. No information has been provided to support this statement or what specific aspects of the “ecological integrity” are threatened.
3. Since the park is already employing non-lethal methods, it can only be presumed that “cormorant population management” means lethal methods, i.e., a cull. The proposal should be clear about what it is proposing.

The proposal does not provide any information on the success of the current non-lethal measures and why there is a need for consideration of lethal measures. Non-lethal measures are employed at other conservation areas in the Lake Ontario region, including Tommy Thompson Park which has the largest cormorant colony in eastern North America. Presqu’ile Provincial Park, which also hosts nesting Piping Plovers, discontinued lethal measures in 2007 and employs non-lethal measures. Neither of these jurisdictions are currently proposing lethal control measures for cormorant control.

Summary

The provincial park system in Ontario provides many benefits for the people of Ontario but at its core is the conservation of Ontario’s natural heritage for the enjoyment of all Ontarians. This includes the conservation of native species and their historical ecological role. Cormorants filled an essential role in the ecology of the Great Lakes thriving fish and wildlife populations long before the arrival of the Europeans. The drastic impacts on the Great Lakes fish and wildlife populations are a consequence of a litany of short-sighted and misinformed human activities. The Ontario Parks system should prioritize, respect, and restore the historical role of native species, not further contribute to their displacement. The current and proposed intensification of the persecution and disturbance to a native species such as the Double-crested Cormorant should be reconsidered and abandoned.

References and Sources

Cooke, S. J. 2021. A fisheries take on the fishy decision to implement a Double-crested Cormorant cull in Ontario. Avian Conservation and Ecology 16(2):16. https://doi.org/10.5751/ACE-02017-160216 Copyright © 2021 by the author(s). Published here under license by the Resilience Alliance

Hobson, K. A. 2021. Ontario’s decision for the province-wide cull of Double-crested Cormorants. Avian Conservation and Ecology 16(1):24.

Wires, L. R. 2015. Migratory bird protection, a crack in the armor: the case of the Double-crested Cormorant. Avian Conservation and Ecology 10 (1): 8.

Great Lakes Cormorants (website). Great Lakes Cormorants

Ontario Ministry of Natural Resources. 2014. Darlington Provincial Park Management Plan. Government of Ontario. P4436_AMD_AMDdoc-final-I_formatted_WEB.pdf

Signed and Endorsed by 18 signatorees (full document in attachments).