As a professional biologist…

As a professional biologist and angler, I would like to formally register my opposition to this proposed legislation in its current format. Recent research and anecdotal evidence from current researchers indicates that cormorants currently foraging in the Great Lakes predominantly consume alewife and gobies, both non-native invasive fish species which are now abundant. Cormorants do indeed consume commercially/recreationally important fish species, but research indicates these species are not the bulk of the Great Lakes cormorant diet presently. As a result, culling large numbers of cormorants "en masse" is not guaranteed to have a significant positive impact on commercial/recreational fisheries, and may even have a negative impact as gobies are direct competitors with native fish species. More information is required to understand the relationship between cormorants and invasive fish species and whether cormorants are a controlling factor.

Cormorants nest in colonies, often shared with a number of other waterbird species, nearly all of which are afforded protection under the federal Migratory Birds Convention Act (MBCA). As a result, anyone hunting cormorants nesting in a colony with other species will be in contravention of the MBCA by disturbing protected nesting birds, not to mention the high likelihood for incidental take to occur in the form of accidental harvest of non-target species and loss of eggs and chicks through abandonment. Federal and provincial agencies struggle to enforce current wildlife laws effectively and there is no additional capacity to enforce either this new legislation or its impacts on existing legislation (MBCA). Additionally, hunting during the nesting season will cause cormorants to seek out new nesting sites, possibly creating conflict situations with additional landowners.

If the main goal of this legislation is to improve commercial and recreational fisheries, there should be provincial data presented with this proposal to indicate that foraging by cormorants is a leading cause of declining fish stocks and that control is warranted. Anecdotally, the combined effects of irresponsible and illegal harvest of fish, as well as loss of spawning and nursery habitat and direct competition and ecosystem modification by non-native fish species are equally likely causes of poor fishery health. Reduction of cormorant populations may lead to an increase in goby populations, which, in turn, may have a negative impact on commercial and recreational fish through direct competition for food resources.

Cormorant control measures (culls) have been conducted in Ontario in the past to protect and preserve rare vegetation communities. Having worked on Great Lakes colonial waterbird colonies, I am well aware of the damage and odor that can accompany a cormorant colony and I am supportive of cormorant control measures when conducted within strict guidelines to accomplish specific goals.

Assuming that the province can collect or collate data that biologically justifies that cormorant control on this scale will accomplish its intended goals, I suggest that this proposal should be reconsidered and refined based on the following points:

1. To reduce the potential for contravention of the MBCA, no hunting of cormorants should occur during the nesting season for colonial waterbirds, resulting in a season restricted to the late summer and autumn.

2. Develop an alternative designation for cormorant rather than "game bird" as this insinuates cormorants are hunted for food or sport. Cormorants are not likely to be considered food by many (any?) and are certainly not "sporting" to hunt, as they are clumsy and spend parts of the day unable to fly.

3. Specific colonies or areas should be targeted on an annual basis to focus control efforts on areas that require it most.

4. Some main points of the proposed monitoring program should be included in the proposal. At a minimum, this should include some provincially-supported assessment of the current diet of cormorants, as well as population estimates and a process to allow hunters to report their harvest data. Monitoring of fish populations in the vicinity of cormorant colonies (both controlled and uncontrolled) also should also be included in the monitoring program.

Currently, I believe there are too many unknowns with regard to this proposal and I feel the government requires more information before it can draft responsible, effective cormorant control legislation that will benefit all Ontarians.

Thank you for providing me with the opportunity to comment.