Please let the U.S. Fish and Wildlife Service know that you strongly oppose this proposal. Comments are due by July 20th. You can comment on the EIS and proposed rule here. Comments can be made either through uploading a letter or typing or pasting comments into the portal. See below for a sample letter you can use or adapt.
This proposal perpetuates a tragic history of wanton slaughter. The U.S. Fish and Wildlife Service allowed the slaughter of more than 180,000 cormorants east of the Rocky Mountains before federal courts ruled that the killing was illegal and that the Service had failed to consider non-lethal options or demonstrate that the killing would actually benefit fish. During this same time period, the U.S. Fish and Wildlife Service approved illegal permits to use shotguns to kill nearly 11,000 cormorants and the destruction of more than 26,000 nests at East Sand Island at the mouth of the Columbia River. This colony which represented 40% of the Double-crested Cormorant population west of the Rocky Mountains eventually collapsed. The failure of the U.S. Fish and Wildlife Service with regards to Double Crested Cormorants has been monumental and it is time for this reckless and wanton killing to end.
Instead the Service is doubling down. Its new proposal would allow for the killing of up to 123,157 cormorants nationally each year. Nearly 9,000 of these birds could come from west of the Rocky Mountains meaning that the U.S. Fish and Wildlife would be allowing the killing of more than 14% of the western population of Double-crested Cormorants each year. To make matters even worse, the Service is proposing to hand control of the killing over to the States. As bad as the U.S. Fish and Wildlife Service has been, the states would be even worse. Oregon Department of Fish and Wildlife has previously sought permits to kill Cormorants up and down the Oregon Coast.
- The US Fish and Wildlife Service should adopt Alternative E (no action alternative). All four of the action alternatives will result in the unsustainable, inhumane and unnecessary slaughter of Double-crested Cormorants.
- Allowing the killing of as many as 123,157 cormorants each year (more than 14% of the entire population) in the United States is irresponsible and unsustainable.
- The proposal will put western populations of Double-crested Cormorants, which are much smaller than populations east of the Rocky Mountains, at extreme risk.
- The US Fish and Wildlife Service should retain complete oversight of the permitting process rather than transferring oversight to other entities with less capacity, expertise and accountability.
- Allowing entities to kill cormorants simply for eating fish is unacceptable—any lethal control must be tied to specific and verifiable conflicts and should always be a last resort.
- All four action alternatives are inhumane, allowing for the orphaning and starvation of young cormorants and inhumane methods of killing cormorants such as cervical dislocation.
- The use of lead shot which poses a well-documented threat to other wildlife that may scavenge dead cormorants should never be allowed.
- As extreme as this proposal appears on its face, its impacts could actually be much worse due to nesting colony disruption and failure due to lethal control activities in colonies.
- This proposal fails to meet the US Fish and Wildlife Services most fundamental obligation to protect our nation’s wildlife.
You can either use or modify the following language or write your own comment.
Dear U.S. Fish and Wildlife Service,
I am writing to express my strong opposition to the U.S. Fish and Wildlife Service’s proposal to allow the annual killing of upwards of 124,157 federally protected Double-crested Cormorants nationwide of which nearly 9,000 would occur in the Western United States where populations are already at risk due to previous mismanagement by the U.S. Fish and Wildlife Service. I also strongly oppose the U.S. Fish and Wildlife Service’s related proposal to delegate responsibility for overseeing the killing of Double-crested Cormorants to States. The proposal being put forth by the U.S. Fish and Wildlife Service amounts to wanton slaughter. I urge you to abandon this proposal and adopt the No Action Alternative.
Double-crested Cormorants are one of the most persecuted wild birds in the United States. The U.S. Fish and Wildlife Service has a long history of failing to meet its statutory responsibility to protect this species. This proposal unfortunately perpetuates that pattern. In 2016, Federal Courts found that the U.S. Fish and Wildlife Service had illegally allowed the killing of more than 180,000 cormorants east of the Rocky Mountains. During this same time period the U.S. Fish and Wildlife Service also permitted the killing of nearly 11,000 cormorants and the destruction of more than 28,000 nests at the world’s largest Double-crested Cormorant Colony at East Sand Island in the Columbia River Estuary. This action resulted in the complete collapse of this colony which represented an incredible 40% of the entire Double-crested Cormorant population west of the Rocky Mountains. It is time for the slaughter to stop.
I oppose the proposed rule and recommend the No Action Alternative for the following reasons:
- Allowing the killing of as many as 123,157 Double-crested Cormorants nation-wide each year perpetuates a long-term pattern of persecution of this species by the U.S. Fish and Wildlife Service and is in direct conflict with the agencies mission and mandate to conserve, protect and enhance fish, wildlife and plants and their habitats for the continuing benefit of the American people protect native bird species.
- Allowing the killing of as many as 123,157 Double-crested Cormorants annually violates the Migratory Bird Treaty Act which mandates that the agency only allow killing if it can ensure the continued viability of the species.
- Allowing the take of nearly 9,000 Double-crested Cormorant annually west of the Rocky Mountains (representing >14% of the western population) where populations are already as risk, in part due to prior actions by the U.S. Fish and Wildlife Service, would put the western population at extreme risk and could result in the need for a future listing under the Endangered Species Act.
- The U.S. Fish and Wildlife Service failed to consider any strategies other than lethal control of Double-crested Cormorants in any of the action alternatives.
- The U.S. Fish and Wildlife Service failed to include adequate monitoring in the proposal alternative to ensure that it would be able to modify killing levels if significant declines occur.
- The U.S. Fish and Wildlife Service failed to adequately address risks to non-target species.
- The U.S. Fish and Wildlife Service failed to address humane and animal welfare issues.
- The U.S. Fish and Wildlife Service failed to adequately address illegal take of cormorants and disruption of colonies in their modelling.
- The U.S. Fish and Wildlife Service has failed to demonstrate that killing Double-crested Cormorants would benefit imperiled fish species.
- Delegation of permitting authority to states is an abdication of a core responsibility of the U.S. Fish and Wildlife Service and would put management of cormorants in the hands of state agencies that lack both resources and expertise and which in many cases have explicitly expressed a desire to see even more aggressive control of cormorants than has been allowed to date by USFWS.
I am deeply disappointed that the U.S. Fish and Wildlife Service is continuing to pursue the unwarranted persecution of Double-crested Cormorants. Prior actions by the Service have put cormorant populations at risk, resulted in the deaths of tens of thousands of cormorants, wasted millions of taxpayer dollars and failed to achieve stated goals. It is time for the killing to stop. I respectfully urge you to adopt the No Action Alternative.
YOUR NAME HERE