Description of the issue…

Description of the issue
According to your proposal to introduce a hunting season for the double-crested cormorant, “There continues to be concerns expressed by some groups (commercial fishing industry, property owners) and individuals that cormorants have been detrimental to fish populations, island forest habitats, other species and aesthetics.”

Your web site outlining the proposal gives the impression that observations of non-specialists are sole the basis for introducing this hunting season of cormorants, and it is not clear if any wildlife management research has been consulted and integrated into the proposed approach.

Wildlife management and ecological balances are complex issues that require measured approaches that can only be attained through rigorous scientific study. Implementing high-density widespread hunting permitted without any scientific method being applied to me is putting the cart before the horse. We should not in our society be implementing untested policies that could have unintended and severe consequences, resulting in ecological damage that cannot be reversed.

Concerns
My specific concerns relate to the effects on the environment, cormorants, and taxpayers:
1. The extent of the hunt: 50 cormorants/day over 9.5 months of the year. That represents over 14,000 birds per hunter per year. It also runs through the cormorant’s breeding season and appears to have no boundaries; in other words, it doesn’t matter whether an area has a “cormorant problem” that needs to be managed in order for it to be included in this cull. Has the government decided that the survival of cormorants is of absolutely no concern? Have you researched the ramifications on the ecosystem of the species disappearing? To me, it appears that you are not proposing a population management plan but an uncontrolled slaughter. Have other population management methods other than hunting even been considered?
2. The Ministry is looking to enable hunters to permit the meat to spoil, which is not the case for any other game species. How will carcass disposal be managed? Will bodies be left to rot or will taxpayers have to foot the bill for Conservation Officers to monitor the entire province of Ontario to ensure proper disposal methods are being undertaken? How many Conservation Officers or other officials will be required to monitor this and would it mean that their attention is being diverted from other important issues?
3. Hunters will be allowed to shoot cormorants from standing boats during recreational and cottage season. What effect will this large of an uncontrolled cull taking place in our shared waterways have on the public’s rights to safety?

Research
There is a variety of research papers on wildlife management, in general, and the effect of these cormorants on fisheries. I include some of them below:

Specifically on double-crested cormorants, Diana et al. (2006) conducted a study on the effect of double-crested cormorants in a case study of Les Cheneaux Islands in Lake Huron. They determined that cormorants resulted in <6.3% of mortality for all ages of perch and they concluded that control measures to limit their populations were not warranted at that time. http://www.bioone.org/doi/abs/10.3394/0380-1330(2006)32%5B306:DICPTS%5D…

Ostman et al. (2013) studied the effects of cormorants on fisheries of the Baltic Sea. Their study indicated “that the degree of competition between cormorants and humans varies substantially between areas”. They concluded “that for the commercially most important species, eel and cod, the estimated economic impact of cormorants on fisheries was low.” https://journals.plos.org/plosone/article/comments?id=10.1371/journal.p…

Canadian researchers have given thought to fisheries management and should be consulted by the Government of Ontario before implementing any population control for double-crested cormorants.
• Lennox et al. published a review paper in 2018 and concluded that management must consider the role of the predator within the ecosystem and potential consequences of its removal. In their review of the literature, they determined predator removal was typically an ineffective and costly approach to conflicts between humans and predators. (http://www.fecpl.ca/wp-content/uploads/2018/05/1-s2.0-S0006320717310418…)
• Post et al. (2002) felt that Canada requires “(1) fishery independent assessments of the status of fish populations, and (2) changes in the management of recreational fishing that increase the visibility of fish population declines to agency biologists, the public, and politicians. We must also recognize, quantify, and incorporate depensatory processes, where and when they exist, into dynamic management models to identify thresholds of population abundance that are necessary to sustain fish populations and the social and economic value that they provide. Only then can fisheries management, and society as a whole, hope to respond in a timely fashion to avoid the collapses and costly mistakes that have characterized the science and management of many of the world’s commercial fisheries.” http://faculty.forestry.ubc.ca/hinch/486/2015/Post%20et%20al.%202002%20…

Conclusion
The proposal being put forth by the Ontario Government to introduce an extended hunting season for the double-crested cormorant is a whole-sale cull that appears to have no planning or metrics in place to manage the severe ramifications that will likely occur. I expect our government to make evidence-based policy decisions that are measured and in consultation with expert advice, in this case wildlife researchers. I urge you to delay your decision to introduce this hunting season until you’ve had an opportunity to work with wildlife management specialists on a restricted hunt that focuses on an area where cormorants and fisheries are in conflict and have success metrics in place that will allow you to measure the effect of the cull on the entire ecosystem. I appreciate the opportunity to provide comments.