Wildlife Section PUBLIC…

Wildlife Section
PUBLIC INPUT COORDINATOR
Ministry of Natural Resources and Forestry
Policy Division
Species Conservation Policy Branch
300 Water Street
Peterborough, Ontario
K9J 8M5

Re: EBR Registry Number 013-4124; Proposal to establish a hunting season for Double-crested Cormorants in Ontario

The proposal by the Ministry of Natural Resources and Forestry to establish an open hunting season for Double-crested Cormorants from March 15 to December 31 each year, with an exception for central and northern Ontario, where the open season would run from June 16 to August 31 each year, is ill-conceived, not based on scientific evidence, and threatens to adversely affect the future of this indigenous species in Ontario. Therefore, I do NOT support this proposal, for the reasons listed below.

1. The agenda for this proposal seems to be largely driven by self-serving people with game-fishing and sailing hobbies, who are putting human recreation ahead of the survival of an important native species which serves as a top predator in lacustrine and marine ecosystems. The cormorant is being blamed unfairly for taking game fish. See item 11 below.
2. The cormorant population is said to be stable at this time, after recovering very low numbers prior to 1970. Admittedly, there are large concentrations of cormorants on some islands in the Great Lakes, harbours, and other areas. However, the way to deal with large concentrations is not through an open 9.5-month-long hunting season that allows licenced hunters to kill 50 cormorants/day using shotguns, which does not focus specifically on areas of high concentration and could seriously deplete cormorant numbers in other areas where numbers are stable or low.
3. There is an unacceptable chance that co-lateral damage to other species of birds, such as egrets and herons, would occur when shooting of island-inhabiting cormorants from offshore “stationary motorboats” takes place.
4. The requirement for cormorant hunters to retrieve and dispose of the bird carcasses properly according to regulations as yet outlined, is likely to reduce the number of hunters who would be interested in hunting cormorants because of the expense they would incur in buying shotgun shells and the time they would have to spend in retrieval and disposal of birds. Therefore, a proposed daily bag limit of 50 cormorants seems unrealistic.
5. It would make more sense to have MNRF sharpshooters continue to reduce numbers of excessively large vegetation-destroying colonies of cormorants by culling on an annual basis, as has been happening on Middle Island in Lake Erie in recent years. This would be preferable to opening hunting to licenced game-bird hunters across the province, including areas where cormorant numbers are low. Other options would be oiling of eggs or disruption of nesting by loud noise in large nesting populations of cormorants.
6. Cormorants are part of ecosystems and their removal would upset the balance of the ecosystem especially where the cormorant numbers are stable or low.
7. Claims that cormorants are depleting game-fish stocks in the lake need to be supported by up-to-date scientific evidence provided by qualified people with knowledge about the management of cormorants. No references to such articles are posted on the Environmental Registry with the proposed policy.
8. The public should have been consulted prior to the proposal of this policy, alternative options should have been provided, and only after the MNRF had chosen the preferred option should the proposal have been posted on the Environmental Registry.
9. Current numbers of cormorants are not mentioned in the proposal, nor the areas of very large concentrations of the species. The 2010 census of the Double-crested Cormorant showed a downturn in the population.
10. The cormorants are facing threats from Newcastle Disease virus throughout the Great Lakes Basin. Newcastle disease virus has caused major mortality events in wild double-crested cormorants in North America (https://www.northeastwildlife.org/disease/newcastle-disease). In this way, Nature is controlling cormorant numbers, with declines in numbers said to be reaching 70% in some areas.
11. The MNRF should identify the exact areas where a problem exists with cormorants affecting the numbers of game fish, and provide scientific backing. Evidently, the Canadian Wildlife Service claims that cormorants do NOT take the fish species that game-fish hunters target. If the MNRF is stocking lakes with non-native predatory game fish for sport, why it is concerned about a native bird species that probably prefers to eat other fish species than game fish and is likely not having much impact on game fish numbers?
12. The MNRF states that monitoring of cormorant numbers will be done. If monitoring of the hunt is left to Conservation Officers, of which there are only about 40 in Ontario, the monitoring will likely be very inefficient and inaccurate.

It is my opinion that the MNRF has not made its case for the proposed hunt, and a serious review of the proposal is needed.

Thank you for the opportunity to comment.