I have various academic and…

I have various academic and practical reasons for not agreeing with the creation of hunting opportunities for double-crested cormorants.

Other hunting opportunities involve things that people eat. I think this idea sets a negative precedent, not only because it is a negative trend in our “resource management” (cormorants are not a resource nor are they a trophy), but because it is the manifestation of negative feelings for this species. This is not the case for any other hunted species that I can think of in Ontario. Elsewhere, seals may be a good comparison, but there is no seal culling happening in Newfoundland and Labrador despite calls for it. There are some current calls for sea lion culls in BC at the moment also…

New Brunswick has a varmint hunting season for cormorant March to September, and then a regular hunting season starting in September. It would be good to know the effects of these policies on the cormorant population there: https://www.cbc.ca/news/canada/new-brunswick/shooter-targets-cormorants… . There has been very little background information posted about this proposal to help with evidence-based decision making. Opinions and concerns that cormorant populations are too high are not evidence.

Other examples of predator culls have not had positive or effective results. With advice from experts, Newfoundland is not considering opening a cull on seals like some are calling for (there is a hunt, though, which has been declining). The seal population is “stable” at the moment, and in fact, evidence suggests that climate change and humans are what are keeping the cod stocks low: https://www.cbc.ca/news/canada/newfoundland-labrador/seal-cull-science-… . My point is that eliminating the “competitor” has been shown as an inviable solution in more than one situation, despite the fact that it’s the most obvious course of action. In fact, having a variety of different predators has been shown in numerous circumstances to increase the overall biodiversity / resiliency of an ecosystem.

MNRF is proposing that the cormorant killing can occur during breeding when the birds are colonial – i.e., when there are adults, eggs and chicks all near each other. It seems to me with a shotgun, a hunter is bound to hit more than one animal without having to aim carefully. What happens if birds are injured or chicks are parent-less? There has been some bad press on this issue in the past (https://www.theglobeandmail.com/news/national/environmentalists-condemn… ) A hunter would maybe have to be about 5 m away to ensure the shooting and killing of only one bird at a time. Based on what they are proposing, one determined hunter with a small game licence could cull 2,250 cormorants in a season in central and northern Ontario.

Cormorants are a species very responsive to fish stocks, and would probably undergo population cycles, especially because the population can grow quickly. The recent increase was the most pronounced because of the starting low numbers that resulted from DDT, but the MNRF states that cormorant numbers have leveled off or even decreased slightly. Based on this information, hunting/culling might do one of two things (depending on how many are killed): it might accelerate a decline that has started, or, perhaps more likely, it may keep the numbers artificially higher than they would be if we just let cycles happen. In fact, human actions (fish stocking, taking of big fish (that eat smaller ones), culling some cormorant eggs) might already be keeping the cormorant populations higher for a density-dependent species that would fluctuate, if allowed. Basically, I agree with Jim Quinn as described in this article: https://www.thespec.com/news-story/9059210-nature-not-bullets-should-co… .

There is no guarantee that culling will affect the high population (unless it is extreme as modeled here: https://besjournals.onlinelibrary.wiley.com/doi/full/10.1046/j.1365-266… ) and further, there is no guarantee that killing the other fish predator will increase fish stocks (https://www.theguardian.com/environment/2012/nov/15/seal-cull-canada-co…) although I did find the following evidence that fish stocks could increase slightly after cormorant control measures are implemented in the Great Lakes (http://wildlife.org/the-rise-of-double-crested-cormorants-too-much-of-a… ). There is no mention of the other control measures on the same population of cormorants that is happening south of the border.

Evidence suggests that, because they are an effective generalist hunter, cormorants eat notable quantities of invasive species, for which we have very few control measures at the moment (e.g., https://www.sciencedirect.com/science/article/pii/S0380133015002750 )

The proposal lacks accountability measures: how will hunters count how many animals they’ve killed, how they will prove it, how they will prevent cruelty and ensure only the one species is killed?

I do not understand the following: Why have #1 if you already have #2?

1) Create an open hunting season for double-crested cormorant from March 15 to December 31 each year across the province.
2) 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.

In a paper from AB (Cost Effectiveness of Egg Oiling Versus Culling for Reducing Fish Consumption by Double-crested Cormorants in Lac La Biche, Alberta), cost per metric ton of fish-not-eaten-by-cormorants is much cheaper, and more predictable for egg oiling than for a culling program. Egg oiling targets only one species and prevents cruelty to the largest extent possible. Although not directly related to the proposal here, I think this paper provides good food for thought on how MNRF can competently manage cormorant populations without opening it up to a potentially vindictive public, who do not have the collective living memory to realize that the current population levels for the birds are natural and historical (http://www.bioone.org/doi/full/10.1675/1524-4695%282006%2929%5B9%3AHPOT… ).