I am writing to oppose the…

I am writing to oppose the current proposal for a hunting season on Double-crested Cormorant in Ontario.
What is the current population of Double-crested Cormorant in the Great Lakes region? What is the basis for the Ministry of Natural Resources and Forestry’s view that the population is stable or declining? In the absence of an accurate determination of the population size, there is no rationale whatsoever for any sort of season on cormorants.
The proposal fails to describe a population management objective (population target) either for the province as a whole, or for any particular region.
I reject the concept of a hunting season that would run from March 15 to December 31. This is contrary to the fundamental principles of wildlife management and ethics of hunting. A key principle of wildlife management must be protection of wildlife during the breeding season.
The proposed bag limit of 50 Double-crested Cormorants per day per hunter with no possession limit through a season that extends more than 40 weeks of the year is exceptionally high. This proposal is also without precedent under the Fish and Wildlife Conservation Act for its failure to address the need for population sustainability. Hunting at this level would lead to local and/or regional extirpations. The suggestion that this proposal would have only a ‘neutral’ impact is completely unfounded.
The policy proposal allows for shooting of Double-crested Cormorants in breeding colonies. This could lead to disturbance and mortality of other nesting birds, including Great Blue Heron, Great Egret, and Black-crowned Night Heron. Shooting at nesting colonies could also cause disturbance and mortality to other species, notably Caspian Tern, Common Tern, and Great Black-backed Gull.
The policy proposal makes reference to concerns from some individuals that cormorants may cause adverse impacts on fish populations. The appropriate response to these concerns would be for wildlife managers to focus on a thorough and factual study to properly understand the food habits of the Double-crested Cormorant.