IFAW, with approximately 22…

IFAW, with approximately 22,000 Ontario supporters, thanks you for the opportunity to comment on the proposed hunting of the Double-crested cormorant (Phalacrocorax auritus) in Ontario, EBR 013-4124.

Founded in Canada in 1969, IFAW is a global non‐profit organization that protects animals and the places they call home. We believe that individual animals matter to species conservation, and our work seeks to link the value of individual animals to the health of the population and ecosystem at large. IFAW believes that in order to be effective, conservation efforts must include, and have the support of, local communities.

We also believe that wildlife management should be based on the best available science. Where lethal management of wild animals is being considered, it should be justified by scientific evidence and conducted with rigorous monitoring and evaluation to ensure the desired objectives are being achieved.

The proposal to establish a hunting season for double-crested cormorants (DCCO) in Ontario is concerning for a number of reasons. This proposal appears to be a cull: a targeted reduction in the cormorant population in response to “concerns expressed that cormorants have been detrimental to fish populations, island forest habitats, other species, and aesthetics.” Where culls of wild animals are being considered, they should be justified by science. A cull of DCCO is not supported by any available scientific evidence.

Second, the proposal appears to be an attempt to disguise an unscientific cull as a legitimate hunting activity. The proposed changes to classify the DCCO as a game bird and to then amend the Fish and Wildlife Conservation Act to allow game meat to spoil undermine the very basis of ethical hunting principles and the North American model of wildlife conservation . As such, the proposed changes will almost certainly have negative impacts on the public perception of hunters in Ontario.

Third, the proposed bag limits are excessive by any calculations and, if achieved, would vastly exceed the estimated population size of DCCO in the entire world. The calculations and scientific basis for these limits should be made transparent so that Ontarians can be assured that they have been thoughtfully developed and will not affect sustainability, as the proposal claims.
We elaborate on our concerns below:

1. Lack of scientific basis for a cull of double crested cormorants.
The double crested cormorant is a native species to Ontario and the Great Lakes, whose population has only recently recovered from declines caused by DDT between 1950-1970. Despite this increase, there is no indication that DCCO have exceeded historical population size or their carrying capacity. The EBR proposal states that the latest information suggests the population has stabilized or declined slightly. There is nothing to suggest the species is “overabundant” in a historical or scientific sense.

Concerns that DCCO are negatively impacting fish stocks are not supported by science. According to the Canadian Wildlife Federation, fish species targeted by anglers such as trout and salmon comprise less than 2% of DCCO diet. Nor does there appear to be competition between fishermen and cormorants for the prey of commercially important species, with cormorants consuming only 0.5% of critical prey fish compared to 13% taken by sport fishermen. There is no indication that the fish consumed by cormorants has a negative impact on what is available to commercial and recreational fishers. It has also been noted that cormorants consume much greater quantities of invasive species such as the alewife and round goby.

Lethal management of piscivorous birds does not address root causes of fish stock fluctuation or decline, and is out of step with modern wildlife management and conservation practices. Nonlethal mitigation methods should be attempted first, and lethal control of wildlife, when adopted, should be justified scientifically and instituted by trained wildlife professionals.

There is also no evidence to suggest that cormorants are threatening island forest habitats, nor having detrimental consequences for any other waterbird species.

There is no evidence that DCCO are “overabundant” or a threat to ecological integrity or biodiversity. According to the proposal, the DCCO population has stabilized on its own and may already be at a point of zero population growth and population decline. This necessitates further examination of any proposal to cull, as lethal removals may, in fact, put the DCCO population into a state of more rapid growth, and will completely fail to address the concerns it intends to address.

2. Culls should not be disguised as hunting. The government of Ontario must be transparent and acknowledge the lack of scientific basis for any proposed cull of wildlife. Culls based on subjective criteria such as “aesthetics”, or political convenience, have no place in modern, science-based wildlife management. Such culls should also not be disguised as legitimate hunting activity, as this is misleading and further confuses the public.

Listing a wholly inedible, migratory species as a “game bird” in attempt to disguise an unscientific cull as a hunting activity is dishonest and misleading. To then change the Fish and Wildlife Conservation Act to permit the spoilage and waste of the killed “game” is alarming from a conservation perspective, and does a great disservice to the ethical hunting community in Ontario. Ethical hunting aims to achieve full utilization of any animals killed. Allowing game meat to spoil is in direct contravention of the core principles of ethical hunting and the North American Model of Wildlife Conservation. Further, the prospect of piles of dead cormorants left to rot will have impacts on other wildlife species, not to mention highly negative social consequences and impacts on “aesthetics”.

Conflating a politically motivated cull of wildlife with traditional hunting as for food and sustenance will confuse the general public and will likely generate unnecessary antipathy and anger towards hunting in general.

3. The proposed bag limits and other measures are arbitrary and unacceptable
The proposed bag limit of 50 cormorants per day demands additional scrutiny. If only 1% of Ontario hunters killed only 50 cormorants over the entire season, this would result in over 350,000 cormorants killed – more than the entire Great Lakes population. If the bag limit of 50 birds per day were actually achieved, over 8 million birds – at the most conservative estimate-would be killed. This is four times the estimated global population.

Despite this incredible calculation, the proposal goes on to state that “anticipated levels of harvest aren’t expected to affect sustainability”. Clearly the proposed bag limit requires review and modification.

Allowing an open hunting season from March to December across the entire breeding season of the species could be particularly detrimental and result in far more birds dying than those killed by hunters. Hunting permitted at nesting colonies could lead to disturbance and nest abandonment, resulting in chicks dying from starvation or exposure. Such a proposal is unacceptably inhumane.

Conclusion:
The proposal to establish a hunting season for double-crested cormorant in Ontario appears to be a scientifically unjustified cull intended to address concerns about perceived competition for fish and subjective concerns such as aesthetics. This proposal is being portrayed as a “hunt”, but the proposed amendment to the Fish and Wildlife Conservation Act allowing meat to be wasted destroys one of the core tenets of wildlife conservation and ethical hunting. And while little scientific information is provided in the proposal, the incredulity of the suggested bag limits make it clear that more research on DCCO and the ecological impacts of this proposal must be conducted before proceeding with any further management action.

Double-crested cormorants are an important component of a healthy and functioning Great Lakes ecosystem. We appreciate that the government of Ontario must consider conflicting values for wildlife held by voters in this province, but lethal removal in response to ecologically unfounded complaints of perceived competition, or worse- “aesthetics” - is an archaic policy response that has no place in modern wildlife management. Thank you.