Attn: Ministry of Natural…

Attn: Ministry of Natural Resources and Forestry and the Ontario Government,

I would like to submit my strong formal objection to this proposal. I believe this is purely a political move, bending to whim of certain stakeholders, such as those in the commercial fishing industry, who's general beliefs about the Double-crested Cormorant are not founded in scientific study, but in generational myths.
Double-crested Cormorants (DCCO) are a native Ontario bird who's population is just recently stabilizing after nearly being wiped out by the use of environmental contaminants several decades ago. Their return to the Great Lakes has been heralded as one of the greatest environmental success stories in recent times. As the proposal itself states, the population is considered "stable or declining". If that is the case then why is this CULL, being disguised as a hunt, even being proposed?
DCCO are social colony nesters, and just like most other seabird colonies, they can nest in great numbers and reduce vegetation in very localized areas in their nesting sites. Perhaps to some it may be unsightly, but it is a natural ecological process, and aesthetics alone is a very weak reason to cull a native species. These barren nesting sites and dead vegetation benefit other species of plants, animals and insects, which thrive in that type of environment.
Cormorants rarely nest alone - they often co-nest with other species which are protected under the Migratory Bird Convention Act, such as Great Blue Herons and Black-crowned Night Herons, Great Egrets, Ring-billed Gulls, Herring Gulls, Caspian and Common Terns and Ontario's only American White Pelicans. Many of these other sensitive species are declining in Ontario, and hunting activity surrounding Cormorant colonies are likely to disturb or incidentally kill these other birds, which would be a direct violation of the Migratory Bird Convention Act. Also of concern is the close resemblance on the water that cormorants bear with other protected diving birds, such as Common Loons and Grebes, and rare visitors during migration such as Red-throated and Pacific Loons.
I am frankly shocked with the so-called "season" proposed (March 15 - Dec. 31). This would have it open before these migratory birds return to the Great Lakes to breed, and well after most of them they have migrated south in the winter. Allowing these birds to be culled during their nesting season, besides the disturbance to other sensitive co-nesting species, is incredibly unethical and inhumane, as both parents are required for nest success. If even one parent does not return to the nest the chicks are likely to starve to death.
The changes that are proposed to be made to the Fish and Wildlife Conservation Act which will allow hunters a bag limit of 50 per day, no possession limit, and allow the meat to spoil, are alarming and unprecedented. With the excessive bag limit, and no proposed mass hiring of new Conservation Officers or Wildlife Enforcement Officers, these limited regulations are just simply not enforceable.
Furthermore I strongly disagree with the Double-crested Cormorant being designated a "game bird", as it is largely considered inedible. Even so - all other game bird species in Ontario, including Canada Geese (which many people believe to be a nuisance) - have a well-defined season from September - December which does not overlap with their main breeding season.
My greatest concern, which I'm sure will be shared by many people - even those who do not necessarily favour Cormorants - is the potential public health issues surrounding the dead birds washing up on shorelines all across Ontario, especially throughout the summer months. Who will be paying for the proper disposal of these carcasses which will inevitably be left behind on the water? Public safety seems to have also been overlooked, since hunters will be allowed to shoot these birds from the water during the summer months. At the very least, waterfront recreation will suffer in many communities, particularly smaller municipalities which rely on it to fuel their local economies.
If further scientific study indicates a need for local population control of colonies of Double-Crested Cormorants, I compel the MNRF to consider the alternative control methods which have proven to be successful in the past, such as egg-oiling, ground-nesting encouragement and localized pre-breeding season culls carried out by MNRF technicians or contractors.
It is irresponsible and entirely inappropriate to leave the population control of a native species up to the general public, and open an indiscriminate hunting "season" without clear rules and regulations, or regard for public health and safety. I find it extremely disappointing that the current Ontario Government would push forward such a proposal without scientific evidence and the backing of the scientific community. I strongly urge the government to do further scientific study, and to work to reduce or eliminate the many other factors that present far greater threats to our lakes, watersheds and fisheries.
As a taxpaying citizen of Ontario, a public servant by profession, an avid conservationist and environmentalist, as well as angler by hobby, I whole-heartedly reject this ridiculous proposal as it stands, and I plead with all other Ontarians to do the same.