Regulatory Brief

 Migratory Bird Permits; Double-Crested Cormorant Management in the United States (November 2011)


Formal title: Docket Number [FWS-R9-MB-2011-0033]Migratory Bird Permits; Double-Crested Cormorant Management in the United States

The U.S. Fish and Wildlife Service (FWS) requested public comments to guide the preparation of a Supplemental Environmental Impact Statement or Environmental Assessment on the development of revised regulations governing the management of double-crested cormorants.


Brief Description:

On November 8, 2011, the U.S. Fish and Wildlife Service (FWS) requested public comments on the Double-Crested Cormorant (DCCO) Management in the United States. Under current regulations, cormorant damage management activities are conducted annually at the local level by individuals or agencies operating under USFWS depredation permits, the existing Aquaculture Depredation Order, or the existing Public Resource Depredation Order. The depredation orders are scheduled to expire on June 30, 2014. This analysis will update the 2003 Final Environmental Impact Statement (FEIS): Double-Crested cormorant management in the United States (USFWS 2003). Within the Federal Register Notice, the FWS asked questions regarding management practices. The AVMA responded to several questions posed by FWS and relevant to the veterinary profession.

AVMA Response:

The AVMA encourages relevant federal and state agencies that deal with the interactions of wildlife with domestic or other production animals to require the use of science-based evidence and peer-reviewed research to direct their health and resource management policies. Additionally, the AVMA is concerned about the possible extinction of many animal species and the conservation of wild animals in their native habitats.

The AVMA suggests that the FWS add "Minimize negative environmental impacts" as a means objective for the DCCO management. The Environment is a component of One Health, which is the integrative effort of multiple disciplines working locally, nationally, and globally to attain optimal health for people, animals, and the environment. The AVMA supports environmental responsibility, including control and prevention of the environmental impacts of chemicals, animal wastes, and other products that may negatively impact the environment, and is a proponent of education of the public on the importance of sustainability, conservation, and long term planning.

If cervical dislocation is to be employed as an optional means for take (euthanasia), the AVMA strongly recommends that the agents be trained and determined proficient at the technique before they utilize it; therefore, euthanasia or humane killing of the selected birds will be ensured.

Consistent with current scientific literature and the conclusions of the Pan American Health Organization (PAHO), the AVMA recognizes that animals that die from injuries, such as would be the case in cormorant population control takes, generally do not represent a health hazard for humans. The presence of an animal carcass resulting from an immediately fatal wound, without the presence of another risk factor, is not a cause for infectious disease spread. The subsequent decomposition of an uncollected cormorant carcass in a wetland ecosystem provides for the existence and interaction of multiple risk factors which may result in conditions that threaten other animals, the environment, and even people. The increased risk of a botulism outbreak is a prime example of a potential outcome if bird carcasses are not collected from aquatic environments.

Background Documents:

April 5, 2012 – Full AVMA Response (PDF)

November 8, 2011 – Federal Register Notice (PDF)

January 27, 2012 – Federal Register Notice Correction (PDF)

Relevant AVMA Policies