I oppose the proposal to…

I oppose the proposal to allow hunting for Double Crested Cormorants. It is poorly thought out and wrong.

1. The proposal background states: "There continues to be concerns expressed by some groups (commercial fishing industry, property owners) and individuals that cormorants have been detrimental to fish populations, island forest habitats, other species and aesthetics."

a) In my view, merely expressing a concern is insufficient grounds for changing the regulations in such a fundamental way, or even bringing a desire to the level of a proposal by a government agency, and as a formal proposal in the Environmental Registry. Using concerns voiced by only a small segment of Ontario residents, or concerns voiced only by small and limited-number special interest groups sets a very bad precedent.

i. I am an angler for trout, and I sometimes fish in lakes that are stocked at great expense, but I and fellow anglers are aware that Loons take a huge toll on freshly-stocked Brook Trout; should I and fellow anglers propose that there should be spring and summer hunting on Loons both to protect trout stocks, stop Loon impact on sport fish stocks that are exploited by myself and other anglers, provide more fish on more lakes for a longer period each year so that the fishing industry (makers and retailer of tackle, bait sales, etc) can sell more and contribute more to the economy, and provide a higher return in fish caught by anglers from the expensive hatchery and stocking program?

ii. It does seem that MNRF is supporting this proposal, if my interpretation of the wording is correct. But there does not seem to be any standard for what number of groups, or number of individuals, is sufficient for the MNRF to take the time to create this proposal. How many individuals are required to voice a concern about the aesthetics of a treeless island that was formerly treed- 1,000, 500, 50, or only 10? If a group of citizens, with evidence supported by a group of doctors, gets together in various Ontario cities and voices a concern that Pigeons are a health hazard to people, ruin statues and buildings with excrement, and are just generally unsightly, will the government float a similar EBR proposal to allow sport hunting in cities, over-riding municipal restrictions on discharge of firearms? I don't see any effective difference between cormorants and pigeons in this regard. Can my friends and I, and like-minded individuals across the province, propose a catch and kill at any time, by any means, without a limit or need to take them home to eat, everywhere on Lake Superior and its tributaries, on Rainbow Trout can legitimately be classed as an Invasive Species that effectively supplanted the native Brook Trout in Lake Superior since Rainbow were planted around 1900.

b) There is no actual evidence of the level, if any, of cormorant impact on fish populations, islands, other species and aesthetics provided in this proposal. If such evidence exists, it should have been made available; not providing some actual facts to support this statement suggests that such evidence of harm is either totally lacking or so minimal as to not be significant. If the harm was significant, why is it not provided?

i. MNRF has whole network of biologists and fisheries managers who have been monitoring both fish stocks and commercial and sport fish catches and their impacts, all over the Great Lakes and inland waters for many years. Surely this proposal could have found some supporting evidence for the statement that cormorants are, or have been, or might be, detrimental to fish stocks. There is no supporting detail at all in this statement. What species of fish, and was the impact localized or general? If the impact was only on sculpins on Lake Superior, it doesn't seem that cormorant control is warranted. if the impact was very significant, on a prime sport or commercial species, there is no indication of it in the proposal. It may be that there has been a detrimental impact on Yellow Perch in shallow waters around some nesting islands, but if so that is not provided as part of the proposal rationale, giving us the opportunity to weight the proposal against perhaps the only real fisheries and economic detrimental impact.

ii. Cormorants are not randomly or evenly distributed across Ontario. They tend to concentrate where there are suitable nesting islands. This suggests that the detrimental impact of cormorants, if any, are localized rather than general across the province. But, the proposal neither provides any evidence of exactly where these impacts are located, nor why the proposed hunting season should be in effect across the whole of Ontario. If there are a few cormorants nesting on a tiny rock in the middle of some northern lake in the boreal forest, why would the open season need to apply to them? If on the other hand there are ten thousand cormorants nesting at one location on Lake Ontario, where perhaps an argument could be made that they must be having a detrimental impact on fish, why not restrict the hunting proposal to those specific locations? Modern GPS navigation devices allow very precise metes and bounds descriptions of areas where hunting might lawfully take place, so there is no need for an Ontario-wide hunt in this proposal.

iii. Detrimental to aesthetics? When did this become a cornerstone of fish and wildlife management in Ontario? This is a 'beauty in the eye of the beholder' issue. There is no detail provided on just what aesthetics are involved. Who gets to choose on such a subjective decision as aesthetics? If we start going off in this kind of non-game-management direction, why not accept proposals from motorists, and the economically-vital trucking industry, for a year-round season to control the ugly moose that cause human carnage and huge costs on Ontario's highways, year after year? A fatal moose accident involving multiple vehicles can close a northern highway for 8 or 12 hours to allow OPP accident reconstructionists to examine the scene, with a huge economic impact. Aesthetics- what about those pigeons crapping all over our beautiful statues? Snakes-many people are frightened to death of them, even the useful and harmless Garter Snake; why not have an open season on all snakes, as most people can't tell the difference between an endangered Rattlesnake and any other loathsome-appearing species.

iv. What other species are being impacted by cormorants. Are they other birds? If so, that would appear to have been the easiest area on which to provide some details; are cormorants taking the place of Common Terns or Caspian terns, or Great Blue Herons or Night Herons on nesting islands? Some of those are species of concern; if cormorants were displacing them why not provide such evidence? The lack of evidence to back up such a claim in the proposal suggests that no such evidence exists, or is very weak. Are the other species trees on some islands in the Great Lakes? For all we know, from the lack of specifics in the proposal, some Poplars that are extremely common all over the province were killed by cormorant nesting activity, but is this really a concern?

v. There is no pro vs. con evidence or discussion. If the invasive species Roundnose Goby are displacing native species, but they live in the shallows around the islands where cormorants nest, is there not a benefit in having a high cormorant population to control the gobies? I don't know the answer to that, but was the question even on the radar when the proposal was written. In my view, the lack of information provided on this and the other parts of my answer alone, is sufficient to have this proposal withdrawn and if it is to be re-submitted, it must have good evidence to support it. At this juncture fish and wildlife management should be evidence-based, not concern-based.

2. The proposal lists a number of changes that would be made to the F&W Conservation Act and regulations to permit the licenced hunt for cormorants.

a) But, there is no assessment of how this will affect law enforcement by MNRF, or how conservation officers will enforce the new regulations. Do Ontario officers have the tools (boats) to conduct enforcement in offshore areas where cormorants nest? Will budgets be increased to deal with this new hunt? Will man-hours and budget, already limited, be diverted from existing enforcement efforts to this new area of work? Given that this whole proposal smacks of a political gift to certain interest groups, will there even be a will to enforce and direction from managers to enforce this hunt?

b) There is no assessment of how much genuine interest there will be in a lawful (following the new regulations) hunt. Surely a randomly-distributed questionnaire could have been sent to Ontario hunters; the MNRF have computerized records of all hunters in the province. I have held a resident hunting licence in Ontario for some fifty years; I did not receive a questionnaire nor was asked for my opinion on this. The MNRF keeps records: just how many hunters expressed a specific interest in hunting cormorants? Was there even a "straw vote" among selected groups of hunters in some part of Ontario. If there are only a handful of hunters who plan to sit in a boat near nesting islands, these planned changes to the legislation do not seem warranted at all.

c) Judging by the "some groups (commercial fishing industry, property owners) and individuals" listed in the proposal, these are not typical of people who hold small game hunting licences.

i. What evidence is that these people, who are behind the proposed changes, will take the required hunter safety training and then take time from their commercial fishing business and summer barbeques, as the case may be, to sit in a boat near a nesting island with a shotgun and box of shells? The groups and individuals who are pushing for this must be well known, through this proposal, to MNRF; what level of participation has been expressed by them to take the training and buy the licences required, and how much actual time to they plan to spend in this hunt? As a hunter who talks to other hunters, I am not aware of any genuine interest by grouse hunters to spend time and effort on this hunt.

ii. Will this turn into a carte blanche allowing of commercial fishers without hunting licences to shoot cormorants from their fishing tugs? Is it a carte blanche for commercial fishers to go onto cormorant islands and destroy eggs and nestlings? Has this been considered in the law enforcement planning? Has there been any law enforcement planning or assessment on this?

d) Will the proposed hunt be effective in producing the desired result, namely a reduction in cormorant numbers? I have been to cormorant islands on Lake Superior when they were nesting, for the purpose of counting Herring and Ringbill Gull nests and eggs; they often nest in the same places. When you come close with a small boat, all the cormorants lift off the island and fly around in wide circles around it. They don't come particularly close to the people. My recollections now are that, although I was not at the time contemplating a shotgun hunt, they did not come close enough to shoot. My belief, based on my experiences on those islands, is that a boat-based pair of hunters floating near a nesting island might not be very successful in bagging any cormorants. Has MNRF looked at this at all in Ontario or other jurisdictions around the world? Has MNRF done any "test hunting" to see if indeed this is a viable hunt form the hunter's point of view? Will a poor hunting experience, after one or two outings, result in word getting around among hunters that this is just a waste of time, resulting in the long run in a non-useful bunch of legislation on the books that might be difficult to get rid of?

3. Generally, in Ontario we protect fish and game species when they are nesting or caring for their young. For instance, we have closed seasons on many species of fish during the spawning and nesting times, to ensure successful and sufficient recruitment of fish stocks.

i. It is clear from the open season dates provided, that much of the hunt will take place when cormorants will be nesting on eggs, or feeding their nestlings, on the nesting islands. In fact, around the nesting islands at exactly those times would be the only time and place that cormorants can be effectively hunted. After the nestlings fledge, cormorants raft on open water. To suggest that a lone hunter will put out cormorant decoys on a beaver ponds, and sit there all day waiting, is ludicrous.

ii. There is still a lot opposition in Ontario to a spring bear hunt, because some cubs might be orphaned. But in the case of cormorants, the hunt specifically targets adults that are returning to their nesting islands to sit on their eggs or feed their young. On the face of it, this is inhumane. If a farmer leaves a chicken to die of starvation, he can be charged with a criminal offence. In the case of a "very successful hunt" around nesting islands, it is possible, even likely, that many orphaned nestlings will be left to starve to death. Has this issue been addressed by MNRF, or even thought of, when writing this proposal. It is possible that the level of adverse public reaction to the proposal will far outweigh any favourable public reaction by a small number of interest groups and individuals. Has MNRF run this proposal past any other agencies to determine if there is a "humane hunting" issue or conflict?

4. The proposed changes would allow for hunters not to have to eat their cormorants. I suppose if they HAD to eat them, nobody would hunt for them. I wouldn't. I know a person who years ago was part of an expedition to collect bird specimens for the Royal Ontario Museum; because they were way up north with limited food they ate what they shot, and my friend said that Loons are just awful and fishy tasting. Cormorants must taste the same. But so do the mergansers, which are lawfully hunted ducks that eat fish. Will hunters who mistakenly kill a merganser instead of a Mallard be allowed to just chuck it in the bush because of the awful taste, using cormorants as a precedent? I have cooked Spruce Grouse that made the whole house smell of turpentine; will there be a change in regulations to permit them to be left in the bush because they don't taste good?

5. This proposal, if implemented, would set bad precedent in so many ways.

a) If commercial interests (fishing) are the main driver of this proposal, when can we expect an open season on elk in Algoma, of whom many farmers have complained in Algoma for eating grass and hay intended for cattle. Similarly, Algoma farmers complain about Sandhill Cranes that congregate in immense flocks every autumn on local farms. Both farmers and farm groups, and hunters and hunting groups, might want a year-round open season on Elk and Cranes. If Wild Turkeys start destroying crops, can concerned groups of hunters and farmers propose an all-year hunt? In all these species, there is not even the 'waste of flesh suitable for food' issue at play.

b) The proposal to leave the flesh of cormorants taken under a small game licence, to spoil, sets a bad precedent for future proposals from the public about the flesh of mergansers, Spruce Grouse, pike taken from muddy water, etc.

c) It opens fish and game management and the regulations for proposals by small interest groups, when, as in this case, there is no larger need or desire by the public. Heartened by any success in this endeavour, small groups may start to demand their own changes to the legislation.

d) This proposal is not evidence-based. If there is evidence of harm by cormorants, it has not been expressed. No change to the legislation affecting any Ontario fish or wildlife should be contemplated without good and sufficient evidence to back it up. This proposal could open the field to other evidence-lacking proposals.

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