I am writing to express my…

I am writing to express my opposition to the proposal to establish a hunting season for double-crested cormorants in Ontario. I have watched these birds for some time in both Toronto and Eastern Ontario, and I am fully opposed to the proposed regulatory change.

My opposition is based on the following grounds:

1. There is no clear rationale for the proposal. "Concerns expressed by some groups" is not a rationale.
2. There is no data supporting the supposed rationale.
3. The proposal's description of the health of double-breasted cormorant populations is inconsistent. In the first paragraph of the proposal, population numbers are described as "stabilized or declin[ing] slightly." However, the regulatory impact statement describes cormorants as "abundant."
It is not possible for a population to be both declining and abundant.
4. There is no data supporting the reference to population numbers.
5. The proposal fully reflects the views of a very small group and does not at all reflect the views of a large number of Ontario residents (birders, conservationists). There is no balancing act to this proposal. It is entirely one-sided.

Most significantly, the number of birds allowed to be killed per day (50), combined with the specific permission granted for allowing the corpses to rot, is 18th century in its approach. There is a cruelty to this proposal. It means killing an almost unlimited number of birds for no reason.

There are other more humane, and less grossly one-sided, ways to manage a species. I sincerely hope this proposal does not advance.