To whom it concerns. Re: EBR…

To whom it concerns.

Re: EBR ERO Number 013-4124 and OFAH’s Comments.

This is to urge in strongest terms to prevent the egregious plan to redefine “game” and how game is to be utilized in order to placate misguided individuals who want to kill off Ontario’s cormorants, returning to an era when the species was endangered in or extirpated from most of Ontario. The proposal ERO Number 013-4124, is unbelievable.

Assuming this terrible scheme is generated by the mistaken belief that the Ontario Federation of Anglers and Hunters (OFAH) speak with knowledge and authority, and knowing that real experts have already responded to this horrific plan, I shall restrict myself to commenting on OFAH’s letter of support, OFAH FILE 413C/794.

Under the heading, General Comments, OFAH uses the term “overabundant” for the Double-crested Cormorant population. I believe that the problem is encapsulated within the term “shifting baseline syndrome” https://en.wikipedia.org/wiki/Shifting_baseline, whereby, put simply as it relates to conservation, the experience of being familiar with an impoverished biomass during one’s formative years of exposure to the natural world forms a subjective “baseline” whose subjectivity tends not to be recognized. The assumption is that the number of cormorants remembered from one’s formative years was the “right” number, against which anything significantly over that number is seen as inherently wrong.

As Wires and Cuthbert (http://www.bioone.org/doi/abs/10.1675/1524-4695%282006%2929%5B9%3AHPOTD…) show, the species is less common now than it was in historic times. Ecosystems are not static. The carrying capacity of the Great Lakes, may be greater now, as a result of the presence various invasive fish species, but there is no way to know. Certainly cormorants were present in earlier eras.

OFAH states the “ecological damages caused by densely populated connorant (sic) colonies are well-documented”. In fact, “damage” is a naively subjective, value-laden term. Those not familiar with ecological interactions often assume “overabundance” is a biological term, but it refers only to what is subjectively determined by whomever uses it.

Wildlife can create habitat, and in the case of the double-crested cormorant, in the very few places where it occurs in nesting colonies of significant size, it can enhance habitat for other species. Great blue herons co-exist with cormorants and habitat that has been rendered devoid of trees is best suited for such island-nesting Ontario birds as the Caspian tern, common tern, ring-billed gull and American white pelican (now increasing and showing indications of expanding breeding range into the lower Great Lakes, but previously a provincially endangered species). These species are a part of the ecological whole whose presence contributes to biodiversity.

The same sort of argument OFAH makes against the double-crested cormorant has been levied against the savannah African elephant, on the grounds that its prodigious appetite for trees and shrubs prevents the growth of such vegetation to the benefit of the greater number of wildlife species who utilize forest habitat. But scientists have found that biodiversity is enhanced overall by virtue of the support given to savannah inhabiting wildlife species, and since they occur in larger numbers than forest species, biomass is also enhanced by this activity.

Similarly, it was once assumed that all fires should be totally suppressed, but we now know that in both prairie and forest habitat fire plays a pivotal role in enhancing biodiversity overall.

OFAH has stated that what is planned “has the potential to negatively affect the image of hunting…”

OFAH, the National Rifle Association (NRA), Safari Club International (SFI) and other proponents of hunting wildlife argue that hunting is “sport” that utilizes “game” as defined by dictionary and modern tradition both. It is often claimed that hunting is “humane”. The rubric that hunting is “necessary” to “control” species is increasingly doubted by a populace with enhanced access to information about wildlife and ecology and the importance of apex predators, in conjunction with increasingly broad and sophisticated knowledge about basic ecological interactions between predator, prey and habitat. This is all unfolding during a time of increased destruction of the natural world, with an unprecedented loss of species and individual wild animals and plants.

Since “civilization” began about ten thousand years ago, some 83 percent of all wild animals has been lost to anthropogenic causation. If we add the human biomass to livestock maintained in support of the humans we learn that some 96 percent of mammals are humans or domesticated species, and only about four percent are wild species, and yet we happily continue to persecute what is left if, in any way or to any degree, it is profitable to do so or if they annoy us.

Even among birds, some 70 percent of the bird biomass constitutes domestic poultry (mostly one species of pheasant, the chicken) and other domesticated birds in service of one species, us, while only thirty percent are wild, and yet the Ontario government, and OFAH, deems that to be too many.

The exact figures vary (see for example: https://www.theguardian.com/environment/2018/may/21/human-race-just-001… and for a technical analysis of world biomass overall see https://www.pnas.org/content/115/25/6506 ) but the bottom line is that we are experiencing the greatest extinction event in over sixty million years and it is of anthropogenic origin, and that fact is well known to educated people with access to social and mainstream media and various educational sources.

The old way of thinking, characteristic of the era preceding the study of ecology, when animal species were deemed “good” or “bad” depending on their immediate value to us, is not working in the interests of conservation. With this loss of biodiversity, and with the results of climate change fueled by intentional, willful ignorance, even politically-motivated disdain, of science, we see a continuing loss of the ability of the environment to support us, to support human endeavor. In spite of OFAH’s unsubstantiated claims of high “membership” and “subscribers”, increasing numbers of Ontarians are turning away from consumptive wildlife use and increasingly valuing nature in its own right.
According to the 2016 U.S. Fish & Wildlife Service National Survey of Fishing, Hunting, & Wildlife-Associated Recreation, the licensed hunting population of American hunters has decreased from 17.9 million in 1975 to 11.4 million as of the time of the latest survey. The annual dropout rate is roughly 6.3 percent, while annual recruitment of about five percent. Particularly noteworthy is the fact that hunting participation is lowest among teenagers, and that is of concern to the hunting fraternity, and government workers whose jobs depend on them, because hunters are most likely to begin hunting in their early teens. That is why organizations such as OFAH are continually seeking to find some level of socially acceptable rationale for the act of killing wildlife.
OFAH’s letter claims it seeks to “promote a positive image of hunting as an important component of conservation” but OFAH is faced with two problems.

First, hunting is not an important component of conservation. The American eel, eastern sand darter, northern madtom, redside dace, river darter, shortnose cisco, spotted gar, warmouth, Allegheny mountain dusky salamander, Fowler’s toad, Jefferson’s salamander, northern dusky salamander, small-mouthed salamander, unisexual (small-mouthed dependent) salamander, blue racer, Butler’s gartersnake, common five-lined skink, gray ratsnake, massasagua rattlesnake, queensnake, spiny softshell turtle, spotted turtle, wood turtle, Acadian flycatcher, barn owl, golden eagle, Henslow’s sparrow, king rail, Kirtland’s warbler, loggerhead shrike, northern bobwhite, piping plover, prothonotary warbler, red knot (rufa subsp), yellow-breasted chat, American badger, eastern small-footed myotis, little brown myotis, cougar, northern myotis and tri-colored bat are all listed on the Ontario government’s own website as provincially endangered species.

It is not explained, nor do I see how, hunting can help conserve any of these species, although I can see how hunting, fishing and trapping – consumptive use – could harm some of them.

The only way hunting can conceivably contribute to the conservation of these species, is via the provision of funding for licence fees. But in a circular arrangement most such funding goes into the expenses required to regulate consumptive use because it is consumptive. The absence of constant monitoring and adjustment and habitat modification paid for out of consumptive use permitting revenues, will lead to endangerment.

How terribly ironic that two species of birds not on that list of provincially endangered species are the double-crested cormorant and the American white pelican, both formerly endangered in Ontario. Their recovery to date is the very thing OFAH is opposing: a conservation success story, albeit their opposition to such success is currently indirect in the case of the pelican. However, with regard to that last caveat, what is being proposed will certainly bring risk to pelicans as they co-habit and associate with cormorants. It opens the door for the elimination of any wildlife species, including the American white pelican, deemed undesirable by a small minority of the population.

OFAH claims the “…sole purpose [is] to use hunters to assist in the control of overabundant connorant (sic) populations.”

Within the hunting community there is great concern about the decline in hunters (see, for example: https://deltawaterfowl.org/wp-content/uploads/2017/03/LoomingCrisis.pdf) and understandably OFAH is fighting back, and in this case is doing so by lobbying to have a legislatively legitimized return to the kind of hunting that appeals to those who don’t hunt for food or sport, but for pleasure derived from killing birds in flight.

There are many ways to hunt, and many motives (see https://www.feelguide.com/2016/11/07/hunting-linked-to-psychosexual-ina…) but hunting game, as defined and regulated in Canada, requires use of the animals’ meat, elements of “fair chase”, and a variable degree of skill. Not all people who want to hunt want to be bothered with such impositions, and what is proposed allows, as does the (more American than Canadian) tradition of “varmint hunting”, to simply kill animals.

I fear that OFAH realizes the value of reversing the decline in hunters to its membership has led it to abandon the pretense of “wise use”, of hunters as “stewards” and “conservationists”, and appeal to that demographic within the hunting community who just want to kill. Ontario should not have any part in assisting this goal. There is nothing inherently wrong in people enjoying nature without need to kill anything, (see https://biodivcanada.chm-cbd.net/documents/canadian-nature-survey) and there are economic benefits to non-consumptive wildlife use that greatly eclipse those of consumptive users.

While OFAH says the purpose of their support for this appalling proposal is not to provide new hunting opportunities, obviously the proposal will do exactly that.

OFAH wants to see the cormorant listed under Section 5(2) of the Fish and Wildlife Conservation Act. Each bird species listed under Section 6(2) of the Act, the American crow, brown-headed cowbird, common grackle, house sparrow, red-winged blackbird and starling (common starling, Sturnus vulgaris) has been so listed for many decades. Two are non-native. All are common and widely distributed. None has ever been listed as endangered or threatened. All are in the order Passeriformes (song birds). None are colonial nesting species. All occupy a broad range of habitats and most benefit directly from human presence.

None of that applies in any way to the double-crested cormorant. Unlike the species listed it is highly vulnerable, as history clearly shows, to persecution. OFAH (or the Ontario government) would have no claim to a conservation mandate by listing the cormorant under this section of the Fish and Wildlife Conservation Act.

OFAH claims that risks of conflicts with “other outdoor recreationists” (ie., the vast majority of Ontarians and out-of-province tourists) are “low” and “exaggerated” by those of us horrified by this proposal.

What is meant by “low”? Most recreationists will be where there are no cormorants for the simple reason that most of Ontario lacks cormorants at any given moment. Where cormorants are concentrated, however, they often are so in the kinds of places that attract “other outdoor recreationists”. Many thousands of visitors to Tommy Thompson Park come in close contact with the largest of the province’s colonies of cormorants.

As to the risks of orphaning, the young are cared for by both parents, and in the absence of either one, will be exposed to a very cruel death.

My biggest fear is that the whole MNRF-OFAH approach is designed to present a patently egregious, over-the-top proposal with the intent of dialing it back to look like a “compromise” while doing OFAH’s actual bidding. Thus OFAH makes the obvious proposal to reduce the season proposed in the EBR, from March to May. Closing the season at the end of May will assuredly not protect young, but leave them orphaned when they are most vulnerable.

But even earlier than May there is still the issue of both parents being required to tend the eggs and young. In other words, killing the female leaves the male to incubate, and then tend the young, and vice versa, which can’t be done. Re-mating is a possibility, but only if there is a surviving partner, and the whole idea is to remove as many birds as possible from the population thus reducing the potential for another pair bond to form, if, in fact, it would.

There is a particular naivete in saying, “Killing adult cormorants in the summer will remove individual birds, but those birds will likely have already bred and caused tree and vegetation degradation. Targeting the season to pre-nesting, when the birds first arrive in the spring, would prevent them from nesting in the first place and limit their impact before it occurs.”
It is true that a dead bird won’t nest, but it is not true that, minus a massive elimination of all birds, nesting won’t occur. Yes, in the absence of human persecution, natural attrition will result in the odd single bird left to tend nesting duties, but cormorant biological imperatives are predicted on the presence of large enough numbers of “bachelor” birds to compensate for such incidental losses as occur in nature. And dependent young continue to occur well into summer.

OFAH states, “It is essential to get robust data on corrnorant (sic) populations and distributions in Ontario, including accurate baseline data…” I agree, but what is meant by “baseline data”? Such data cannot be obtained when the baseline is being altered through the massacre envisioned by OFAH. We already know (as the EBR itself stated) the cormorant population has, according to best estimate, peaked and leveled off.
OFAH, in its letter, calls for the province to monitor not just the Great Lakes, but the entire province, however neither it, nor the EBR posting, states where the funding for such monitoring will originate. The private sector, with government support to be sure, already monitors breeding bird populations in Ontario but the need to do so would be enormously increased by the removal of significant numbers of birds.
What, exactly, would be the number of cormorants that would trigger a cease to them being “hunted”? Why have “robust data” if those data are not used? And if they are to be used, at what point would the number of cormorants satisfy OFAH and/or the MNRF that there are now not “too many”? At what point would protection kick in? How would it be determined that such a point had been reached and how would the protection be applied? What would seem to be a most essential consideration is missing from both the EBR, and concerns from OFAH, that seem to have led to its creation.
OFAH states: “A significant concern regarding growing connorant (sic) populations is their expansion to inland lakes and their potential impacts (e.g. sensitive Brook Trout lakes).” In the MNRF’s own website (http://www.latornell.ca/wp-content/uploads/files/presentations/2017/Lat… ), which lists many causes for actual or predicted declines in brook trout, cormorants are not mentioned. It does state: “Climate change models have predicated that the number of watersheds in Ontario with Brook Trout will be reduced by 50% in 2050.”
It’s clearly easier to kill birds than to combat climate change. There is no evidence, nor is any given, that brook trout are in any way vulnerable to cormorant predation. Worse, the casual allusion to a “growing” population of cormorants is disingenuous, given that the population of cormorants in Ontario has not, based on best available evidence, been shown to be growing, although if that were to be shown to be the case, it would be a good sign as the presence of cormorants, especially breeding colonies, indicates healthy fish populations, thus a healthy environment.
The OFAH letter states that understanding the current “distribution and relative abundance [of cormorants] will ensure we are preventing them from expanding into more vulnerable lake systems.” But that would already be assured if this horrific plan were to be enacted. Among other things it will justify, in the minds of many, the belief that cormorants are “bad” and should be eliminated. There can be no doubt that cormorants occurring anywhere the discharge of firearms is legal will be met with gunfire.
The OFAH letter states that “Closing the season at the end of May would have the additional benefit of removing the need for the proposed exception relating to Northern and Central Ontario’s June to August small game licence restrictions.” But cormorants have dependent young through May, so it would assure cruel deaths of orphaned young.
OFAH states that such a closed season would “…further align the corrnorant (sic) regulations with other game birds, minimizing confusion.” The OFAH letter then says such a season “would remove most adult birds before they get a chance to lay eggs (Ward 2000) and prevent the orphaning of chicks.” The reference given by OFAH is actually Kirschbaum and Ward, and is a simple species account that in no way implies or states that the birds would not have dependent young in May, when, in fact, there would be the peak number of the most dependent young.
The OFAH letter states that the proposal would allow cormorant control on Crown land, which, I remind you, is my land no less than OFAH’s and is land my children and I want to access free from gunmen killing nesting birds, and then goes on to state, “…the province also needs to control connorant (sic) overabundance, particularly when and where hunting will not be permitted.”
Actually, no; that already happens. The largest double-crested cormorant colony in eastern North America, perhaps anywhere, is very well managed in the absence of hunting, with its management goals well met. The use of “overabundance” is, as I’ve alluded, a value judgement. Even if “overabundant” is defined as meaning a species has surpassed carrying capacity and is starving, I know of no instances of such starvation among our cormorants. Food is not a limiting factor in cormorant population size in Ontario!
But OFAH continues, “Currently, control measures can be undertaken by municipalities, provincial parks, and landowners when they experience property damage from cormorants.”
Exactly. There is therefore no need for this legislation. In instances where property damage, including actual monetary loss, can be demonstrated. And while, as the situation in Toronto, where management is science-based, has shown, it need not be lethal.
OFAH wants to work with the MNRF but here is a better idea. Why would MNRF not work with actual experts, both stakeholders who have long been involved with protecting cormorants, and scientists and biologists, particularly from academia who, in theory, lack vested or political interests, to find out what the situation really is.
The OFAH letter just touches on “proper disposal of carcasses”, without saying where the funding for “outreach” will come, let alone how the carcasses are to be disposed of, which leads me to wonder why that was not determined before the decision was posted on the EBR? I expect a better level of competence from the government. The realty is that there is no simple way to dispose of the number of carcasses that will be produced in a way that does not cause health risks, let alone any means to come close to enforcing any such regulations even if they had been suggested, which they were not!
OFAH is absurdly naïve in saying “most conflicts can be easily avoided”, but is accurate in predicting that they will lead to what they call “unintended consequences” and what I would call invariable consequences, that will further exacerbate what they see as a problem, that being the understandable decline in public support for hunting. It has been my experience that there is tolerance for hunting when it involves skill and utilization but a decline in support for wanton killing.
Many people can easily be convinced that the effect that cormorant guano has on plant life can be ecologically damaging in absolute terms. But it is also true that people can be educated, and that naturalists’ organizations, scientists and animal protection groups will be motivated to provide such education, further undermining any belief, however ill-founded, that organizations like OFAH, NRA and SCI have credibility.
OFAH states, “In many areas, no control measures are taken.” Of course not. Why would they be? I get that OFAH members go out and kill wildlife, but a greater number of us do not; we go out to enjoy it, and a waterbird colony is exciting for us to experience.
OFAH states, “In other areas, control efforts are too small in scale or focus on ineffectual non-lethal actions.” The non-lethal methods used by the Toronto Region Conservation Authority have been very effective, while protecting a vibrant, mixed colony of double-crested cormorants, black-crowned night-herons, great egrets, ring-billed gulls, and herring gulls, with some welcome management success with breeding common and Caspian terns. The whole purpose was to increase ground nesting of cormorants, and yet OFAH presents the ability to do so as a failure. It is a resounding wildlife management success.
Along the lines of cherry-picking data, OFAH talks about the increase in ground-nesting at Presqu’ile Provincial Park, but fails to mention that the shift to ground nesting occurred only after lethal culling stopped, and that the presence of the tree-nesting cormorants attracted great blue herons as a nesting species for the first time in the park’s history. In both instances the goal was not to eliminate cormorants but to help maintain tree nesting habitat for heron species. This is a value-judgement, of course. The fact is that nature is not static, not a museum diorama, but always in a dynamic state of change.
The double-crested cormorant is a native bird. For reasons beyond the scope of this letter for me to explore, it can, like the wolf, the shark, and, in earlier times, the loon, hawk and owls and virtually any and every predatory animal, evoke primitive, irrational hatred. I understand all that. But that should not motivate the government in its wildlife management policies. Please reject this proposal out of hand.