I am completely opposed to…

I am completely opposed to the establishment of a hunting season for double-crested cormorants. This is an ill-thought-out, knee-jerk reaction apparently intended only to quell the self-centred "concerns" of the commercial fishing industry, property owners and other individuals, as is blatantly stated in the proposal. Evident in this goal is that the proposal provides no scientific data that would support any of the statements about populations of either affected fish species or cormorants nor of the overall significance of purported negative effects to island forest habitats or to other species, nor any reasoning why the unsupported "concerns" of a few should override the larger environmental conservation mandate. This proposal directly opposes the Ministry of Natural Resources' larger mandate to conserve and protect the natural environments and species and must be rejected.

The proposal presents no data to support any of the "concerns" that drive it. "Supporting materials" is labelled misleadingly; it consists only of hunting-related legislation. The proposal fails to provide any actual data on cormorant population and the currency and reliability of such data, and even admits that the population may be declining while failing to provide any analysis or even speculation as to causes. It fails to present any evidence of trends in fish populations nor any analysis of the effects on fish population of commercial and sport fishing, pollution and human-induced habitat changes; the same goes for the "other species" mentioned but undisclosed in the proposal. There is no assessment as to whether the purported "detriment" to "island forest habitats" has any overall environmental significance; there is no support given as to why the effects of the presence of nesting colonies should be a motivating factor at all in proposing population reduction, nor why the "aesthetic" concerns of a few (presumably reflecting on the presence of bird droppings and the aforesaid effects of the presence of nesting colonies) should drive conservation policy. In sum , it seems that the proposal responds only to the unsupported opinions of a sector of the public who resent the existence of cormorants and through misinformation or a lack of information, or simple greed, or a lack of appreciation for nature, are inclined to see the species as a scapegoat.

It can only be concluded that the proposal lacks foundation in scientific evidence. Despite the implied "concern" that cormorant population affects commercial fishing success, the proposal admits that "the anticipated economic consequences of the proposal are expected to be neutral", thus destroying one of the basic concerns it purports to address. Additionally, it fails to set out how "success" would be measured, apparently seeking only some undefined reduction in cormorant population while simultaneously claiming expected "neutral" environmental consequences. It can only be concluded that the proposal appears to punitive, rather than mitigative, and that success would likely be based on public opinion, not on scientific results.

For the reasons stated, the Ministry of Natural Resources should reject its proposal to establish a hunting season for double-crested cormorants.