I have several concerns…

I have several concerns about the proposal to create a hunting season for Double-crested cormorants (DCCO) in Ontario:

- breeding season - can the OMNRF cite any other species (mammal or bird) that are allowed to be hunted during the time of year when they have young that are dependent on their parents for survival? Can the OMNRF point to any other locations in Canada or elsewhere that allow a bird to be hunted during its breeding season? I recognize that Ontario (and elsewhere) have had cormorant culls however I believe that this has typically been conducted by trained staff, not by creating an open hunting season. Is the OMNRF concerned about the outcome to cormorant eggs/young birds that are left orphaned in a nest when parents are shot or when parents abandon a colony due to the disturbance caused by the shooting and the disturbance caused by hunters roaming thru colonies retrieving shot birds?

- impact on non-target species that nest in same locations as cormorants - many species of birds utilize the island nesting locations favored by DCCO (colonial waterbirds such as gulls, terns, herons, egrets; songbirds; waterfowl; shorebirds). Has the OMNRF studied the negative impact that hunting DCCO will have on these other species of birds (some of whom are Species-at-Risk)? The impacts may include a bird being outright shot by a hunter (either on purpose or accidently by being in the wrong place at the wrong time), but will also include the impact of being disturbed during their breeding season (by the shots and by hunters wandering thru colonies retrieving their kills) which may cause these non-target species to abandon their nests leading to reproductive failure for that year.

- enforcement - does the OMNRF have the necessary resources/personnel to enforce the current hunting regulations for animals in Ontario? Does the OMNRF have the additional resources/personnel that will be required to enforce the hunting regulations proposed for cormorants? What is proposed is a very long hunting season (9.5 months) and since most of the hunting will occur offshore does the OMNRF intend to have enforcement officers out patrolling the Great Lakes and other inland lakes where hunting cormorants will occur?

- monitoring - does the OMNRF have the necessary resources/personnel to monitor the impacts of hunting cormorants in Ontario? How exactly will this monitoring be conducted? Will the OMNRF be instituting a survey of colony sites and colony sizes throughout Ontario (Great Lakes and inland lakes) to see where DCCO relocate too when they are disturbed from one colony location to another? Does the OMNRF have data from 2018 that they will be able to use to see the impact if hunting begins in 2019? If "no" would it not make more sense to have a cormorant hunting season begin in 2020 and use 2019 to conduct the above mentioned field studies and gather baseline data on the colony sites and sizes of DCCO throughout Ontario? Is the OMNRF concerned that one impact of hunting DCCO will be to displace them into urban nesting sites in southern Ontario (i.e. Toronto Harbour, Hamilton Harbour) where there are restrictions against discharging firearms and hence hunting will not be allowed to occur? These urban areas are already having human/cormorant conflicts as DCCO have begun nesting on shorelines (not just offshore islands) and hunting cormorants elsewhere in the province will lead to more DCCO nesting in these urban locations as they seek non-hunting areas. Hunting DCCO in the Great Lakes may also have the impact of dispersing DCCO to more interior/inland lake locations ... the same locations favoured by many Ontarians for their recreational opportunities (i.e. camping, cottages).

In conclusion I think that this proposal to allow hunting of cormorants is short sighted and has many negative impacts and will create many more problems than it will solve. If the OMNRF is concerned about DCCO they should try to solve the problem themselves in specific locations rather than opening it up to the public by way of a province-wide 9.5 month hunting season. If the decision has been made by the current provincial government to kill DCCO why not have a hunting period that matches the period when one is allowed to hunt waterfowl (ducks)? It would be easier to enforce and would not disturb non-target species during their breeding season.