A2A Cormorant Submission Dec…

A2A Cormorant Submission Dec 20, 2018
Re: ERO # 013-4124

The Algonquin to Adirondack Collaborative is an environmental charity which works to protect wildlife and to maintain habitat connectivity for wildlife through the broad region from Algonquin Park in Ontario to the Adirondack Park in New York State. We envision an Algonquin to Adirondacks region that is a resilient, with an ecologically connected landscape which sustains a full range of native wildlife. A critical component of this vision is conserving natural ecological functions and based on objective scientific evidence and respect for wildlife.

The Algonquin to Adirondacks Collaborative (A2A) is strongly opposed to the proposal to establish a hunting season from March to December for Double-crested Cormorants in Ontario with a bag limit for individual hunters of 50 per day, to reclassify cormorants as “game” birds, and to permit hunters to leave the carcasses of dead cormorants to rot.
Double-crested cormorants are an important component of natural ecosystems in Ontario. There is no scientific evidence to support the need for a mass slaughter of cormorants that will result from the proposed hunting season and bag limit.
The Great Lakes cormorant population of the Great Lakes region suffered a steep decline from the 1950’s to the early 1970’s, largely as the result of the introduction of toxic contaminants such as DDT and PCBs. Following a ban on most DDT uses in the 1970’s and the phase out of PCBs, and aided by the expansion of the aquaculture industry in the United States, the population experienced a large and rapid increase. Since the early 2000’s, the cormorant population in the Great Lakes has been stable or declining slightly (as described in the Ontario government’s own ERO posting for the current proposal). Clearly there is no need to conduct a massive cull of a population that is currently stable or in slight decline!
Indeed, the government, in its ERO posting, has provided no scientific rationale as justification for proposing a cormorant hunting season.
The proposals in this ERO posting must be rejected for many reason, including those summarized below:
(1) Permitting individual hunters to kill up to 50 cormorants per day (ie. up to ~14,000 cormorants per year) amounts to a slaughter, not a hunt.
(2) A slaughter of cormorants will have significant negative effects on natural ecosystems in Ontario of which cormorants are an important element.
(3) The proposed cormorant slaughter will result in the death of many cormorant young as the hunt includes the nesting period. It will also result in the death and disturbance of other species that share the same habitat and/or nesting sites.
(4) Based on studies by Environment Canada, cormorants do not consume large numbers of “sport” fish as sometimes alleged. Rather they feed in large part on ”non-sport” species such the Alewife, a species native to eastern North America that has invaded the upper Great Lakes, and the Round Goby, an invasive species that is native to the Black and Caspian seas region of Eurasia.
(5) The proposal to classifying cormorants as a “game” species is illegitimate and appears to be simply to facilitate the proposed slaughter. Game species are those that are hunted for food or other products (e.g. fur), and for sport. This does not apply to cormorants, which are not normally eaten by humans.
(6) Allowing carcasses of cormorants that are killed to be left to rot, as in the current proposal, is unethical (as it is for other species) and must not be permitted.
(7) The cormorant population in Ontario is not out of control, and indeed is stable or slightly decreasing in the Great Lakes region, as described in the government’s own documentation. Habitat suitable for cormorant nesting sites occupy only a very tiny fraction of the Great Lakes region, mainly on a few small islands and peninsulas.
(8) The government in it’s ERO posting has provided no scientific rationale for the proposed cormorant slaughter.
(9) There are major safety concerns for Ontario residents and tourists because the proposed hunting season will include the summer period when large numbers of residents and visitors pursue recreation activities in the outdoors.
For all of the above reason we ask that the current ERO proposal be rejected.