Proposal: ERO number 013…

Proposal: ERO number 013-4124

Dear Ministry of Natural Resources and Forestry:

I am a Canadian citizen, an Ontario resident, and a taxpayer who is vehemently opposed to the proposal to establish a hunting season for double-crested cormorants in Ontario (ERO number 013-4124).

Canadian wildlife is under attack from urbanization, climate change and ignorance. Permitting hunters to kill an arbitrary number of 50 cormorants per day from March to December will decimate cormorant populations; initiate a cascade of negative environmental impacts; and endanger birds sharing the same habitat; e.g., great blue herons, egrets, the endangered American while pelican and threatened least bittern. I question how you can state environmental consequences are ‘expected’ to be neutral with such a widespread, long-term open hunting season on double-crested cormorants without first conducting a thorough scientifically-based investigation on similar culls throughout Canada and the United States of America.

In 2015, a portion of the 39th Annual Meeting of the Waterbird Society was dedicated to Recent Advances in Biology and Management of Double-crested Cormorants. At a talk titled, Double-Crested Cormorant Culling in the St. Lawrence River Estuary: Results of a 5-Year Program, scientists determined, “Culling should be considered a last-resort form of intervention whenever softer techniques (egg spraying, mechanical nest destruction, and carefully planned disturbances to the nesting colonies to enhance predation and abandonment) are not sufficient or practical to produce population control.” Their studies showed, “Furthermore, our work has shown how easy it is to decimate a cormorant population.”

Scientists at the Waterbird Society meeting also shared their findings that contrary to public opinion, the double-crested cormorant is actually an ally to the commercial fishing industry and the sports fisherman. Exploring Potential Effects of Cormorant Predation on the Fish Community in Saginaw Bay, Lake Huron revealed, “Respectively, the three most common prey species observed by number (%) and biomass (%) pooled across years and sites were round goby Neogobius melanostomus (56.6%, 42.1%), emerald shiner Notropis antherinoides (25.2%, 12.5%), and yellow perch (8.0%, 14.1%).” By feasting primarily on the round goby invasive species, double-crested cormorants are facilitating a healthy ecosystem where both native species of fish and Ontario’s commercial fishing industry can thrive.

Additional studies conducted at York University in Ontario, have demonstrated that double-crested cormorant tree nesting and subsequent tree mortality reduced an invasive fire ant population in Toronto’s Tommy Thompson Park; “At this particular site an invasive fire ant appeared to be negatively impacted in areas where tree mortality occurred.” (Double-crested Cormorant Tree Nesting Habitat Modification and Impacts on Invasive European Fire Ants)

Another York University study titled Non-traditional Management of the Largest Great Lakes Cormorant Colony in Toronto, Canada discovered a management strategy to encourage double-crested cormorants to build nests on the ground rather than in trees. “To date the strategy has successfully limited the expansion of tree-nesting cormorants and, as of 2014, 63 percent of the population nests on the ground where they are not affecting tree canopy, compared to pre-management when only 15 percent of the colony nested on the ground.”

The above references provide scientific evidence of sound, environmentally conscious methods of managing double-crested cormorants that do not involve killing the species. Links to PDFs and websites with supporting information have been submitted with this comment.

The negative effects of hunting on wildlife in general have not been considered. Frequent shotgun blasts and increased hunting will disrupt other breeding waterbirds, reducing their populations and causing injury and sometimes death due to stray bullets, bad aim and incorrect double-crested cormorant identification. Also, hunters continue to use toxic shot. This proposal will kill opportunistic scavengers through lead poisoning, including species at risk, such as the bald eagle of special concern, threatened species (gray fox and the Algonquin wolf), and endangered species (American badger, mountain lion and golden eagle).

It is doubtful that the many hunters who shoot 50 cormorants each day will dispose of all the carcasses. Ontarians are in a hurry. It is reasonable to assume that numerous carcasses will spoil and rot, polluting waterways and forested areas, and causing a greater stench than the excrement of an equal number of live cormorants.

A hunting season is unwarranted. As you state in the proposal details, double-crested cormorant populations have stabilized or declined. I ask that my tax dollars be invested in educating Ontarians on how to coexist with wildlife, and in alternative methods of management that do not involve culling a species deemed aesthetically displeasing and wrongfully accused to be decimating fish populations. In my opinion, aesthetics should never be considered a reason to kill. I ask the provincial government to first determine if a proposal is scientifically valid before inviting Ontarians to submit comments.

In conclusion, I once again state I am opposed to the proposal to establish a hunting season for double-crested cormorants in Ontario and request it be stopped and not pursued in any manner.

Sincerely,
An Ontario resident and Canadian citizen