Re: ERO 013-4124: Comment on…

Re: ERO 013-4124: Comment on Proposal to establish a hunting season for double-crested cormorants in Ontario

Thank you for the opportunity to comment on the proposed regulation.

I oppose establishing a hunting season for double-crested cormorants in Ontario because:

• The extreme bag limit allowing an individual to kill 50 birds a day for nine-and-a-half months of the year, including the breeding season, is without precedent, and is a virtually uncontrolled kill that may significantly harm both the cormorant species and other native wildlife.

• The proposal is not rooted in logic: Cormorant populations in the Great Lakes have stabilized or declined slightly since the early 2000s. This fact alone would suggest that the proposed hunt is unwarranted.

Bird Studies Canada has noted “such a level of hunting would lead to local and/or regional extirpations, as well as reduction provincially to token remnant populations.”

The following are just a few of the problems attending the proposal:

1. The proposal lacks scientific justification

The proposal fails to:
• establish the current population size
• specify the desired population size
• justify the high bag limit (practically speaking, no bag-limit)
• propose any means of monitoring the effect of the hunting on cormorants
• consider the complex of interactions that will be triggered (The claim that: “the anticipated environmental consequences of the proposal are expected to be neutral.” Is not justified and very likely to be incorrect)

Further to the last point above, Professor Gail Fraser at York University notes many factors that can impact the abundance of a fish population, including predation by humans, fish and waterbirds, competition from other prey, water temperature and climate change. (http://gsfraser.blog.yorku.ca/research/conservation/proposed-cormorant-… ).

Cormorants rely on small, non-commercial, shallow-water fish: non-native rainbow smelt, alewife and round goby (https://www.thespec.com/news-story/9059210-nature-not-bullets-should-co…).

The goby’s diet is 90% zebra mussels, so controlling cormorants may put downward pressure on invasive zebra mussels but, conversely, the introduced alewife feeds avidly on lake trout eggs and fry, so native lake trout populations that are not doing well now may suffer even more. – It’s complex! The “problem” needs a much more considered approach.

2. The proposed hunting will harm other species

The proposed will allow hunting to occur throughout the breeding season and at breeding colonies. When motor boats are close to breeding colonies, and guns are in use, other bird species will be stressed at their breeding sites and displaced, if not killed in error.

As noted by Professor Gail Fraser and by Bird Studies Canada, the proposed hunt poses a risk to great blue herons, great egrets, black-crowned night-herons, Caspian terns, common terns and great black-backed gulls.

3. This is a “one-size-fits-all” approach

There are regions of Ontario where breeding cormorant are out of the way of cottagers and commercial fishing interests but may still be subject to severe depredations by hunters on both a casual and an organized basis. If the regulation is adopted (It should not be!) the sites and regions where hunting is allowed should be specified. The default should be “no hunting”.

Regarding concerns about property damage, under section 31 of the Fish and Wildlife Conservation Act, property owners already have recourse to harass, capture or kill cormorants if they’re causing property damage, so is the regulation needed?:

31 (1) If a person believes on reasonable grounds that wildlife is damaging or is about to damage the person’s property, the person may, on the person’s land,
(a) harass the wildlife for the purpose of deterring it from damaging the person’s property; or
(b) capture or kill the wildlife. 1997, c. 41, s. 31 (1).

4. In the current fiscal climate of cut-backs, can the MNRF administer this regulation effectively?

As the Ontario Government’s priority is deficit-cutting, we may expect difficulties in administering this new and extra regulation.

5. Risk to the public and recreational economic impact

The proposal envisions amateur hunters shooting cormorants from stationary boats throughout the open water season – where boaters, cottagers, birders and other outdoor recreationists are also on the water.

Will large water areas be closed to the general public during the proposed hunt? What will be the economic effect on the recreation industry?

Will the regulation exclude cormorant hunting from provincial parks and provincial wildlife areas?
Conclusion

The proposed regulation should be abandoned. I concur with Bird Studies Canada that
“the proposed bag limit of 50 Double-crested Cormorants per day per hunter with no possession limit over a nine and a half month open season is exceptionally high, unsustainable, and without precedent under the Fish and Wildlife Conservation Act for its failure to address the need for population sustainability.”