Re: EBR 013-4124 – Notice of…

Re: EBR 013-4124 – Notice of Objection

First, it should be pointed out the Notice contains confusing contradictory information that will prevent members of the public of engagement in this public consultation process.

The Notice states "On-line submission of comments on this proposal is not permitted.". However, further down in the same notice its states;
"To comment on the proposal, please submit your comments online by clicking the ‘Submit a comment’ button, or by reaching out to the contact(s) listed….."

Rationale and Eye of the Beholder:

If the double-crested cormorant (Phalacrocorax auritus) was considered ‘cute and cuddly’ or ‘majestic’ or ‘beautiful’ in the court of public opinion, this proposal would not even be considered.

In New York State, the Department of Environmental Conservation recently proposed culling mute swans. Unlike native double-breasted cormorants, mute swans are an exotic invasive species native to Europe and their populations have grown dramatically in some areas. Like the double-breasted cormorant, they are huge birds with seven-foot [two-meter] wingspans and can have a significant impact on local ecosystems. But because mute swans are big and beautiful and people form emotional attachments to these birds, a huge public outcry forced the agency to reconsider.

This Notice incredibly, states one of the primary reasons to maim and kill these sentient creatures is because of concern over ‘aesthetics’. The Notice indicates that those who want these birds killed are property owners because these birds are not cute and attractive but are large, noisy and smelly and interfere with recreational enjoyment which arguably can be just as noisy and unattractive.
This proposal is just another example of our hubris and ignorance. This plan to cull these inedible birds under the guise of designating them as ‘game birds’ is more than deceptive and flies in the face of the MNRF’s Statement of Environmental Values that the Ministry is there to :
“To protect, conserve and where reasonable, restore the integrity of the environment”, as well as, “The protection and conservation of biological, ecological and genetic diversity.”

The very wildlife the Ministry is charged with protecting will fall victim to the greedy cosmetic whims of us humans. Before Europeans became a major presence, double-crested cormorants lived throughout much of their current North American range, in populations far greater than 21st century observations. After birdwatching near Natchez, Mississippi in December 1820, John James Audubon reported:

“We saw today probably Millions of those . . . Cormorants, flying Southwest—they flew in Single Lines for several Hours extremely high”

It is not clear why cormorants have to be added to the shoot-to-kill list since cormorants can already be killed by a landowner if they damage or are about to damage private property.

It should be noted that in a comment posted to an online media article regarding this proposal, the commenter stated once this proposal comes into effect, he and his cottage neighbours plan to wipe out the colony near them. The MNRF has no way to prevent this from happening under this proposal and it is entirely possible that the entire population could be wiped out in a single year.

Environmental Impact:

The Ontario Federation of Anglers and Hunters, and angling community argue the cormorants consume fish that might otherwise be caught by humans. However, according to the federal government’s Canadian Wildlife Service, that is not true. Studies presented to the CWS indicate that less than two per cent of a cormorant’s diet consists of ‘sport fish, such as lake trout or salmon’. The same reports indicate less than one per cent of a cormorant’s diet is made up of the fish that sport fish eat.

Furthermore a federal study concluded: “Studies have repeatedly shown that, in a natural environment, cormorants feed primarily on small, non-commercial, shallow-water fish.”

A 2010 study found that cormorants are actually an important tool in the fight against the invasive species round gobies:

Double-crested cormorants are feasting on round gobies, leaving more sport fish, especially small-mouthed bass and yellow perch, for anglers.
"Cormorants seem to be opportunistic feeders that take whatever is most available," said Russell D. McCullough, senior aquatic biologist for the state Department of Environmental Conservation. By studying the contents of cormorant pellets, regurgitated bones, scales and other undigested particles eaten by the birds, DEC officials reached the conclusion that in 2009, 91.6 percent of the cormorants diet consisted of round gobies from Lake Ontario. Cormorants consume almost 14 million fish during their stay in the north country. Round gobies, an invasive species in the lake, account for 12.7 million of that take.
The gobies are dominating the cormorant diet so the birds are eating a lot less of other species, Mr. McCullough said. http://www.ogd.com/article/20100825/OGD01/308259886/0/ogd01

The argument has also been made the excrement of the cormorants has resulted in the destruction of ecologically sensitive island habitats and as another reason to allow for the mass killing of these birds. This is rich coming from the MNRF who has approved hundreds of ‘overall benefit’ applications by commercial, industrial and residential developers and municipalities that will decimate a vast variety of species at risk populations as well as biological and genetic diversity province-wide. Furthermore, the ecological damage by the construction along shorelines for residential structures inevitably results in the complete removal of all pre-existing natural habitat and is far more destructive than these isolated bird colonies.
The Toronto Region Conservation Authority adopted a non-lethal management approach to mitigate cormorant-induced tree mortality in 2008. In one of the largest colony of double-crested Cormorants in North America, double-crested Cormorants were managed for space occupancy rather than population size, with the main objective of minimizing tree mortality while supporting the cormorant population.

It is reprehensible that those most responsible for the erosion of this province’s natural heritage will be allowed to further degrade it simply because these native birds who existed and thrived for thousands of years are now considered simply ‘offensive‘.

Culling is Killing and Cruel and Does Not Work:

This proposal for the mass killing allowing dead and injured birds to spoil is appalling in its seeming assumption that these creatures will not suffer both physically and psychically. Jaak Panksepp, one of America’s leading neuroscientists, has concluded that both animals and humans have brains wired to feel emotions, and that animals have the capacity to experience pleasure and happiness. Those who will apply for licences will be those who hate these ‘nuisance’ birds especially since they are inedible as game. How humanely does the MNRF think these ‘culls’ will be carried out when there is obviously an intention to rid waterways of these birds.

While the proposal calls for the use of non-toxic shot as required by the federal Migratory Birds Regulations, non-toxic shot is much more expensive than toxic lead shot. So what are the chances that the safer, but more expensive shot will be used to kill off what is considered to be nuisance vermin? The MRNF will not have the means or staff to ensure that toxic shot is not being used. It is quite possible that scavengers will be exposed to lead contamination.

Studies world-wide conclude culled populations, in effort to ward off extinction, bear more young. This "compensatory rebound" effect is evolutionary; when there's a sudden decrease in the population; species survival kicks in to induce a high reproductive rate.

"The general theory of harvesting animals is based on the premise that when animals are not harvested at all, growth and recruitment are balanced by natural mortality and that the average growth rate of a population at its carrying capacity is zero. Harvesting reduces the population size, but the reduction results in an increase in the growth rate of the population. This increase in growth rate is brought about because of higher birth rates and lower death rates resulting from decreased competition for resources. This increased growth rate provides a surplus of individuals above the number required to replace the population, and this surplus can be harvested." William Robinson, Wildlife Ecology and Management

In 2004 and 2005, Ontario’s Liberal government authorized a mass cull of cormorants on two small islands in a provincial park near Trenton, technically to “protect the environment” and more than 11,000 birds were shot. Eggs in more than 3,000 ground nests were oiled to prevent hatching. More than 2,000 tree nests were destroyed but obviously were not effective.

The long-term ecological effects of cormorant culling are uncertain. It is unknown what the cumulative impact will be since other jurisdictions currently allow for cormorant killing or will adopt Ontario’s plan.

In 2016, it took the courts to stop this massive slaughter and indiscriminate persecution:

COURT ENDS CORMORANT SLAUGHTER IN ALL EASTERN STATES
“Depredation” Orders for Double-Crested Cormorants Rescinded Immediately
Posted on May 26, 2016
Washington, DC — A federal court has quashed “depredation” orders under which tens of thousands of double-crested cormorants are killed each year in 24 states east of the Mississippi, according to a ruling and order in a lawsuit filed by Public Employees for Environmental Responsibility (PEER). As a result, the nearly twenty-year legal regime of indiscriminately shooting these aquatic fish-eating birds for the supposed benefit of sports fishing and aquaculture has come to an end.
In March, U.S. District Judge John D. Bates found that the U.S. Fish & Wildlife Service (FWS) clearly violated the National Environmental Policy Act (NEPA) in giving open-ended approval for “lethal removal” of double-crested cormorants “committing or about to commit predation” on fish in Eastern states through
2019 without current data or adequate scientific analysis. But that earlier ruling stopped short of ending the depredation orders and instead called for additional briefing on a “remediation plan.”
In his May 25, 2016 ruling, Judge Bates concluded, after the two sides had made their case, that revoking or vacating these depredation orders was the appropriate remedy, by finding that – individual permits for removal, as are used for most other birds protected by the Migratory Bird Treaty Act, would be sufficient to alleviate any “any serious detrimental impact” caused by cormorants; the FWS had ignored the environmental benefits of cormorants, such as curbing invasive fish
populations, and helping co-nesting species. Moreover, its predictions of adverse eco-effects was unsupported and rested upon “abstract” and “tentative” assertions; and the FWS claims of economic disruption were “imprecise,” “speculative,” and not “compelling.” “We urge the Fish & Wildlife Service to abandon its myopic ‘predator bad – kill predator’ approach to perceived human-cormorant conflicts,” stated PEER Staff Counsel Laura Dumais, noting that FWS adopted depredation orders as a convenience over individual, situation-specific removal permits.

Summary:

This proposal is not based on scientific evidence but because some in the human population find these big, noisy, smelly birds to be objectionable. The animal which most greatly threatens and damages biodiversity is us humans. If we are not willing to cull our own species we cannot morally justify culling another.

Culling does not work and is cruel. The cumulative impact of culling is unknown.
It is humans that have caused the damage to fisheries and aquatic ecosystems through overfishing, introduction of exotic species and pollution.
Instead of trying to ‘manage’ cormorants through mass killing, reducing coastal pollution, securing conservation land and marine preserves, and assisting aquaculture producers and fishermen to develop new bird conservation practices would be not only be practical but also sustainable.

Colonial bird specialist, Linda Wires states in her book, “The Double-Crested Cormorant: Plight of a Feathered Pariah” these once numerous birds were driven to near extinction twice in Ontario”… so is the MNRF hopeful that the third time is the charm, so like the also once numerous passenger pigeon we can look at these amazing creatures only as images online or dead birds on display in museums?