As an Ontario resident who…

As an Ontario resident who values nature, science-based policy, and sees the value in hunting as a management tool I am absolutely opposed to this proposal. The proposal lacks justification for the establishment of a province wide public hunt of this scale and fails to provide scientific evidence to defend the expressed concerns which have triggered the Ministry to pursue this proposal.

• The Double-crested cormorant is a conservation success story, with populations in North America recovering from relatively low numbers in the early 1970’s. In the current proposal the Ministry indicates that the Great Lakes populations have since stabilized or declined slightly, suggesting there is little justification in establishing a hunt to control population numbers.
• The proposal fails to provide scientific evidence to justify the hunt, including failing to provide information about the species population status at the provincial, regional and local level.
• The proposal fails to establish a clear problem statement other than suggesting that some groups and individuals have expressed generic concerns. A proposal made by the Ministry must be justified by the Ministry itself. The justification from the Ministry must be science-based, not based on generic comments.
• The proposal fails to establish a clear target or goal for which this solution (i.e. “management tool”) is to achieve. It is assumed that a decrease in Double-crested cormorant populations is the desired goal, but the proposal fails to specify a trigger which would indicate the goal was achieved. Along with failing to provide current provincial and regional population estimates, the proposal fails to indicate any provincial, regional or site level population target.
• The proposal provides no scientific evidence to indicate the perceived impacts of Double-crested cormorants on local fish populations are real and that this species plays a significant role in the decline of local fish populations. Local fish populations face myriad threats include habitat loss, habitat degradation, human predation, predation by other species, and competition with invasive species; the Ministry has not provided any evidence to indicate that Double-crested cormorants in Ontario have significantly contributed to the decline of local fish populations.
• The proposal indicates Double-crested cormorants have been detrimental to island forest habitats but fail to quantify the impact or acknowledge that this type of impact is a natural ecological process that occurs when high density colonially nesting waterbirds inhabit a portion of an island.
• The Ministry failed to provide evidence that any alternative solution was considered that could address the expressed concerns (e.g. fish recovery programs, habitat management and restoration projects, public awareness/outreach events).
• The proposal indicates the Ministry will establish a Double-crested cormorant monitoring program, signifying there is currently no population monitoring program which could provide adequate, scientifically supported baseline population data from which harvest targets could be derived. It would take several years before any statistically meaningful monitoring data could be used to assess population status and trends, meanings several years of hunting would go unchecked. The proposed monitoring plan also fails to indicate any other parameters that will be monitored including fish populations, island flora health, and aesthetics, all of which are being used as generic justification for the proposal.
• The proposal fails to justify the establishment of an open hunting season from March 15 to December 31 each year across the province, which represents nearly the entire window of time this species is present in Ontario. An open season of this length also effectively means the species can be hunted through its entire breeding season, which is inconsistent with wildlife management and hunting ethics. The killing of either parent bird will result in the death of young; how will this impact be factored into assessing the sustainability of this hunt?
• Double-crested cormorants are colonial nesters and are often found nesting in association with other non-game migratory species including Great Blue Herons, Black-crowned Night Herons, Common Terns, gull species, etc. Due to the overwhelming likelihood of disturbance to other wildlife species (including at-risk species), a high risk of indiscriminate take of non-target species, and a lack of method to evaluate non-target species impacts, hunting of Double-crested cormorants during their sensitive breeding season must be avoided.
• The proposal to amend the Fish and Wildlife Act to allow for hunters to leave Double-crested cormorant meat to spoil is both shocking and inconsistent with current hunting regulations and ethics. If aesthetic is a concern the Ministry has failed to demonstrate that potentially large numbers of bird carcasses left along shorelines will have anything but a pleasing aesthetic. The Ministry has also failed to address the human and environmental health risk associated with leaving large numbers of carcasses to spoil in the open. Additionally, by allowing hunters to let meat spoil it is assumed that the requirement to retrieve your quarry and ensure it is dispatched quickly and humanely is also voided; this represents blatant wildlife cruelty and a disregard for the intrinsic value of wildlife.
• The proposal to allow a 50/day bag limit with no possession limit in the face of the stated potential decline of the species, is nothing short of reckless. The Ministry failed to provide an explanation for how the limit was set. The statement by the Ministry that the environmental consequences of the hunt are expected to be neutral is both unfounded and speaks only to the potential impact on Double-crested cormorant numbers, not any of the other potential environmental impacts associated with such a large-scale hunt (e.g disturbance to other non-game protected bird species, risk of water quality issues from spoil carcasses and unlawful use of toxic shot, nestling success, public safety due to close proximity to active hunting, etc.). If the impact is expected to be neutral, then this solution/management tool will fail to address the perceived problems. What then will be the point, other than to simply allow people to hunt the species for the sake of killing them and not for any overall net benefit.