SUPPLEMENT TO THE ENVIRONMENTAL ASSESSMENT:

REDUCING DOUBLE-CRESTED CORMORANT DAMAGE 

IN OHIO

June 2013

I. INTRODUCTION

Across the United States, wildlife habitat has been substantially changed as the human population expands 

and more land is used to meet human needs. These human uses often come into conflict with the needs of 

wildlife and increase the potential for negative human/wildlife interactions. Double-crested cormorants 

(Phalacrocorax auritus; hereafter, DCCOs; see Appendix A for a list of acronyms) are one of the wildlife 

species that engage in activities which sometimes conflict with human activities and resource uses. 

Conflicts with DCCOs include but are not limited to DCCO foraging on fish at aquaculture facilities, 

DCCO foraging on populations of sport fish, negative impacts of increasing DCCO populations on 

vegetation and habitat used by other wildlife species, damage to private property from DCCO feces, and 

risks of aircraft collisions with DCCOs at or near airports. Wildlife damage management is the science of 

reducing damage or other problems associated with wildlife and is recognized as an integral part of wildlife 

management (The Wildlife Society 1992). In 2006, the U.S. Department of Agriculture, Animal Plant 

Health Inspection Service, Wildlife Services (WS), the U.S. Department of the Interior Fish and Wildlife 

Service (USFWS) and the Ohio Department of Natural Resources Division of Wildlife (ODW) prepared an 

Environmental Assessment (EA) on alternatives for reducing DCCO damage to aquaculture, property, 

natural resources, and risks to human health and safety on private and public lands in Ohio (USDA 2006). 

Wildlife Services, the USFWS and the ODW have prepared this supplement to the EA to review the 

environmental impacts of cormorant damage management (CDM) carried out since 2006 in Ohio and 

proposed adjustments to compost monitoring activities. 

The alternative selected in the WS and USFWS Decisions and Findings of No Significant Impact (FONSIs) 

involves the use of an integrated wildlife damage management (IWDM) approach, including non-lethal and 

lethal methods to manage DCCO damage. Available methods include physical exclusion, habitat 

modification, nest destruction, harassment, shooting, egg oiling/addling/destruction, and euthanasia 

following live capture. Preference is given to practical and effective non-lethal methods, but non-lethal 

methods may not always be applied as a first response to each damage problem. The most appropriate 

response could often be a combination of non-lethal and lethal methods, or there may be instances where 

the application of lethal methods alone is the most appropriate strategy. All CDM actions in Ohio are 

conducted in accordance with USFWS Migratory Bird Depredation Permits (damage to property and risks 

to human health and safety), Scientific Collecting Permits or the Public Resource Depredation Order 

(PRDO) for DCCO management1 and applicable state and local regulations.

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 The PRDO was established by the USFWS after completion of a Final Environmental Impact Statement (FEIS) on 

DCCO management to reduce the actual occurrence, and/or minimize the risk, of adverse impacts of DCCOs to public 

resources including fish (both free-swimming fish and stock at Federal, State, and tribal hatcheries that are intended 

for release in public waters), wildlife, plants, and their habitats (USFWS 2003). It authorizes WS, State fish and 

wildlife agencies, and Federally-recognized Tribes to control DCCOs, without a Federal permit, in 24 states (AL, AR, 

FL, GA, IL, IN, IA, KS, KY, LA, MI, MN, MS, MO, NY, NC, OH, OK, SC, TN, TX, VT, WV, and WI). 

Regulations implementing the PRDO are codified at 50 CFR 21.48 (http://www.fws.gov/ 

migratorybirds/CurrentBirdIssues/Management/cormorant/cormorant.html ).

1

 
This supplement adds to and updates material in the 2006 EA and FONSI and all information and analyses 

in the 2006 EA remain valid unless otherwise noted below. 

II. SCOPE AND NEED FOR ACTION

The scope and need for action have not changed since the EA was written. Wildlife Services, in 

partnership with USFWS Ottawa National Wildlife Refuge (ONWR) and the Ohio Department of Natural 

Resources (ODNR), has been conducting CDM activities to reduce damage to native vegetation and 

wildlife including threatened and endangered species, fishery resources, aquaculture, property, and reduce 

the risk of collisions between aircraft and cormorants. Details on the need for CDM in Ohio are provided 

in the EA. 

III. SUMMARY OF ACTIVITIES

Since the completion of the EA in 2006, the agencies (WS, ODW, and ONWR) comprising the Ohio 

Double-crested Cormorant Coordinating Group (ODCCG) have met annually to discuss progress and 

challenges with DCCO management in Ohio. The ODCCG reviews DCCO population data, impacts of 

proposed CDM actions in Ohio individually and collectively, and information on regional and national 

CDM activities to ensure that CDM efforts in Ohio will not jeopardize the viability of State, regional or 

national DCCO populations. While each agency has set their own objectives on their individual areas of 

responsibility, the USFWS, WS and ODW have agreed that decisions on future PRDO CDM projects will 

be made only after consulting with the ODCCG. 

The 2006 EA established management objectives for each of Ohio’s 5 known DCCO colonies. Objectives 

for each colony are provided below with a summary of the results of DCCO management actions which 

have been conducted since the EA was completed. 

• West Sister Island. Managed by ONWR as a National Wildlife Refuge and Wilderness Area. 

Management Objective - 1,500 to 2,000 breeding pairs. The management objective for West Sister 

Island (WSI) was based on Habitat Objective 1 in the Comprehensive Conservation Plan (CCP) for 

WSI (USFWS 2000a) which calls for the refuge to maintain nesting habitat for approximately 1,000 

pairs of Great Blue Herons (Ardea herodias), 800 pairs of Great Egrets (Ardea alba), 500 pairs of 

Black-crowned Night-Herons (Nycticorax nycticorax) and 1,500 pairs of DCCOs. It was also based on 

observations from refuge biologists that damage to vegetation appeared more pronounced when DCCO 

numbers at WSI exceeded 2,000 breeding pairs, starting in 1999. 

The number of breeding pairs at WSI decreased annually between 2006 and 2009 and was within 

management objectives from 2007-2009 (Table 1, Appendix A). At WSI, population objectives were 

achieved for 3 consecutive years from 2007-2009. Using an adaptive management framework, control 

visits were limited to 1 per year from 2008-2011 to ensure the minimum population objective of 1,500 

nesting DCCO pairs was maintained. Additionally, take caps of 600-1,000 individuals per year were 

set during this time period, although these cap levels were never reached. Finally, “no-entry” zones 

were established on the Northeast portion of the island where no entry or take is allowed. One of the 

lessons learned during this time period was that take is self-limiting on WSI when DCCOs are within 

target population levels. Cormorants are dispersed, fewer birds are taken, and habitat damage is 

limited. These results are encouraging for long-term management of the cormorant population, and 

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maintaining island habitats in a healthy condition. However, it remains to be seen if population levels 

can be consistently maintained within target population goals, or if there will be periodic spikes in 

population numbers. The number of DCCO pairs at WSI increased in 2010 and 2011 (Figure 1). In 

2011 increases also occurred at other Ohio Lake Erie colonies. In 2012 following consecutive years of 

population increases, 2 control visits to the island were conducted and DCCO numbers decreased from 

the 2011 level. Adjustment of take levels and numbers of visits per year will continue as population 

levels warrant.

• Turning Point Island (TPI). Managed by the ODW. Management Objective - 400 breeding pairs. This 

goal involves maintaining the density of breeding pairs present at TPI in 2005. The 2005 DCCO 

density did not appear to be adversely affecting vegetation or co-nesting species on the island. 

However, given patterns observed on Middle Island in Canada and WSI, it was felt that adverse 

impacts could occur if the population increased much beyond 2005 levels. This management objective 

is the minimum number of birds to be maintained at the island. In all likelihood, the number of 

breeding pairs at the site was expected to be at or slightly above this level. Cormorant numbers 

increased in 2006 and have been over management objectives in all years with a substantial increase to 

1,221 pairs in 2011 and only a slight decline to 1,163 pairs in 2012. Despite management efforts, the 

number of nesting DCCOs on TPI continues to increase. Informal observations of the site by ODW 

staff indicate that there are signs the vegetation is being adversely impacted. 

• Green Island. Managed by the ODW as a State Wildlife Refuge. Management Objective – no breeding 

pairs. Green Island is used as a nesting site by Great Egrets and Great Blue Herons. The State-listed 

Lake Erie watersnake (Nerodia sipedon insularum) also uses the island. Additionally six State-listed 

plants including the rock elm (Ulmus thomasii) are located on the island and in close proximity to 

nesting DCCOs. The rate of increase in DCCO nesting population from 2003-2005 (0 to 857 pairs)

was a concern, especially given the relatively small size of the island (17.3 acres). The ODW was 

concerned that DCCO population increases and associated vegetation damage would be similar to that 

observed on other Lake Erie islands like Middle Sister Island (Hebert 2005, McGrath and Murphy 

2012). Given that Green Island is less than a quarter of the size of WSI, biologists were concerned that 

the island will be more easily overrun and degraded by DCCOs than the larger islands. Reducing 

DCCO impacts on vegetation is intended to help return the species composition of the breeding bird

community on the island to that observed in 2002. The number of DCCO pairs at Green Island has 

varied. Although the management objective for the site has not been reached, the number of DCCO 

pairs at Green Island has been lower than the initial levels observed in 2005. In 2010 a pair of bald 

eagles (Haliaeetus leucocephalus) initiated nesting on Green Island and CDM efforts were cut short in 

accordance with provisions in the EA and PRDO regulations for the protection of eagles. The reduced 

take in 2010 may explain some of the increase in DCCO pairs in 2011, but pairs declined again in 

2012. 

• Grand Lake-St. Marys. Management Objective - 15 breeding pairs. Grand Lakes-St. Marys is a 

13,657 acre lake and is a popular area for recreation and walleye fishing. The original location of this 

DCCO breeding colony was a small island near-shore and some cottonwood trees along the shoreline 

in the Mercer Wildlife Area managed by the ODW. The colony contained 80 DCCO breeding pairs in 

2005. The state-owned land is also home to a pair of nesting Bald Eagles and a Great Blue Heron 

rookery. The site contains only a limited number of mature trees and there were concerns that that the 

growing DCCO colony could eliminate the vegetation upon which the herons and eagles depend. The 

DCCO population at this site was at or near the management objective for 2006-2009. During 2010 the 

DCCO colony seemed to abandon the Mercer Wildlife Area and thus no CDM was conducted at this 

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site in 2010 and no nesting activity was observed. However, there was a substantial increase in 

breeding pairs in 2011 with 180 breeding pairs observed on nearby Safety Island. Following 

management conducted in 2011 and 2012, the number of breeding pairs was reduced to 30 in 2012. 

Since then, the Mercer Wildlife Area site has been abandoned by the cormorants and the nesting colony 

has relocated to Safety Island on Grand Lake-St Marys which is managed by the ODNR Division of 

Parks. In 2011, cormorants were observed nesting on Safety Island, located 2 miles offshore in the 

southwestern area of Grand Lake-St. Marys. The ODNR Division of Parks is concerned that DCCO 

nesting activity on the island will lead to a decline in the health of the trees on the island and that 

without trees the island will erode with wave action over time. In addition to its aesthetic and 

ecological role, the island is used as a safe haven for boaters when storms and other adverse weather 

threaten safety on the lake. Given the concerns at the new colony location, the agencies are retaining 

the management objective of 15 breeding pairs for Grand Lake-St Marys. This is the minimum number 

of birds to be maintained at the site. In all likelihood, the number of breeding pairs at the site would be 

at or slightly above this level. 

• Portage Lakes. Management Objective – at least six breeding pairs. This is the minimum number of 

birds to be maintained at the site. In all likelihood, the number of breeding pairs at the site would be at 

or slightly above this level. The Portage Lakes complex (478 ha) consists of a string of 10 lakes in 

northeast Ohio, near Akron. Cormorants initially established a small colony (6 pairs) on a 0.1 ha island 

in the West Reservoir managed by the ODNR Division of Parks. In 2011 DCCOs established an 

additional colony (64 pairs) on another small island nearby that is also managed by the ODNR Division 

of Parks. Because of the highly dynamic nature of colonies on the Portage Lakes complex (rising and 

falling nest counts from 2006-2008, shifting colony location), no CDM activities had been conducted 

within the Portage Lakes until 2013. Because the past 3 years have seen a gradual and steady increase 

in the number of nesting DCCOs on the Portage Lakes, the ODNR Division of Parks plans to conduct 

harassment measures during 2013 to protect the island vegetation at the second and larger island colony 

(64 pairs). The ODNR Division of Parks is concerned that DCCO nesting activity on the island will 

lead to a decline in the health of the remaining trees on the island (they have already lost several trees) 

and that without trees the island will erode with wave action over time. For the Portage Lakes complex 

as a whole, the ODW will continue to monitor DCCO nesting and migrant activity in response to public 

complaints regarding property damage or large flocks of migrating DCCOs utilizing this area. 

All CDM activities carried out by the ODCCG since 2006 have been consistent with the objectives listed 

above. Despite the annual removal of adult breeding DCCOs the breeding populations at Green Island, 

Turning Point Island and Grand Lakes St. Marys remained above the objectives; although there has been a 

general decreasing trend for Green Island (Figures 1 & 2). The agencies did achieve target population 

levels on WSI for three consecutive years (2007-2009). Consequently, the agencies reduced management

activities at WSI as part of an adaptive management approach to identify the minimum take needed to 

maintain management objectives at the site. Following rising population levels in 2011, additional visits 

and take resulted in a decline in 2012, although the WSI population was still above target level. Fine 

tuning annual take through adaptive management will continue for the foreseeable future as the ODCCG 

gains additional knowledge through experience and can better predict the amount of take necessary to 

maintain a desired population level.

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Figure. 1 Number of individual breeding Double-crested Cormorants (DCCOs, thick solid line), DCCO 

Management Objectives (thin solid line) and the number of DCCOs taken for damage management in Ohio (dotted 

line) for Ohio Lake Erie DCCO colonies 2006-2012.

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

2006 2007 2008 2009 2010 2011 2012

Double Crested Cormorants

Year

West Sister Island

Breeding Birds Birds Taken for Damage Management

Target Range 

for Population

0

500

1000

1500

2000

Double Crested Cormorants

2006 2007 2008 2009 2010 2011 2012

Year

Green Island

Breeding Birds Birds Taken for Damage Management

Management Objective:

No Breeding Birds

0

500

1000

1500

2000

2500

3000

3500

4000

2006 2007 2008 2009 2010 2011 2012

Double Crested Cormorants

Year

Turning Point Island

Breeding Birds Birds Taken for Damage Management

Management Objective: 

8oo Breeding Birds

5
Figure. 2 Number of individual breeding Double-crested Cormorants, DCCO Management Objectives and the 

number of DCCOs taken for protection of public resources at Ohio inland DCCO colonies 2006-2012. No birds have 

been taken for damage management at Portage Lakes.

Reasons for the difficulty in achieving management objectives at Green Island, Turning Point Island, and 

Grand Lake St. Mary’s are unclear, although it is noteworthy that increases in nesting DCCOs occurred at 

all Ohio colonies in 2011. Several different factors may contribute to challenges in managing DCCOs in 

Ohio, including: 

1) CDM actions initiated on Canadian Lake Erie Islands or in other areas. However, review of 

management actions on the Middle Island in Lake Erie and surrounding states did not reveal any 

changes in ongoing management strategy which would appear to explain the population shift in 

2011;

0

50

100

150

200

250

300

350

400

2006 2007 2008 2009 2010 2011 2012

Double Crested Cormorants

Year

Grand Lake -

Saint Marys

Breeding Birds Birds Taken for Damage Management

Management Objective: 30 

Breeding Birds

0

20

40

60

80

100

120

140

160

2006 2007 2008 2009 2010 2011 2012

Double Crested Cormorants

Year

Portage Lakes

Breeding Birds

Management Objective: 

12 Breeding Birds

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2) High fledging success for birds at the Ohio colonies. The majority of birds at the Ohio colonies 

nest in trees with other co-nesting species so egg oiling is often not a preferred option. Continued 

reproduction by the remaining birds could contribute to challenges in reducing colony size; 

3) Birds in the Ohio colonies born before the initiation of CDM returning to reproduce;

4) Other unquantified environmental variables including but not limited to food availability in and 

around the Ohio colonies and climate conditions elsewhere in the range of DCCO (e.g., Canadian 

breeding areas). 

IV. AUTHORITY OF FEDERAL AND STATE AGENCIES IN CORMORANT DAMAGE 

MANAGEMENT IN OHIO

Effective management of cormorants and cormorant damage requires coordination among state and federal 

agencies. The roles and authority of the primary agencies involved in cormorant management in Ohio are 

listed below and summarized in Table 1.

4.1 United States Department of Agriculture, Animal and Plant Health Inspection Service, 

Wildlife Services (WS)

Wildlife Services is the Federal program authorized by law to reduce damage caused by wildlife. The 

primary statutory authorities for the WS program are the Act of March 2, 1931 (46 Stat. 1468; 7 U.S.C. 

426-426b) as amended, and the Act of December 22, 1987 (101 Stat. 1329-331, 7 U.S.C. 426c). Wildlife 

damage management is the alleviation of damage or other problems caused by or related to the presence of 

wildlife, and is recognized as an integral part of wildlife management (The Wildlife Society 1992). 

Wildlife Services uses an IWDM approach, commonly known as Integrated Pest Management (WS 

Directive 2.105) in which a combination of methods may be used or recommended to reduce damage. 

Wildlife Services wildlife damage management is not based on punishing offending animals but as one 

means of reducing damage and is used as part of the WS Decision Model (Slate et al. 1992, USDA 1997, 

WS Directive 2.201). All WS wildlife damage management activities are conducted in compliance with 

relevant laws, regulations, policies, orders and procedures, including the Endangered Species Act of 1973.

4.2 United States Department of the Interior, Fish and Wildlife Service (USFWS)

The primary responsibility of the USFWS is conserving fish, wildlife, plants and their habitats. While 

some of the USFWS’s responsibilities are shared with other Federal, State, tribal, and local entities, the 

USFWS has special authorities in managing the National Wildlife Refuge System; conserving migratory 

birds, endangered species, certain marine mammals, and nationally significant fisheries; and enforcing 

Federal wildlife laws. The Migratory Bird Treaty Act (MBTA) gives the USFWS primary statutory 

authority to manage migratory bird populations in the United States. The USFWS is also charged with 

implementation and enforcement of the Endangered Species Act of 1973, as amended and with developing 

recovery plans for listed species.

Ottawa National Wildlife Refuge Complex (ONWR). The ONWR was established in 1961 under the 

authority of the Migratory Bird Conservation Act "....for use as an inviolate sanctuary, or for any other 

management purpose, for migratory birds." The Refuge was also established to preserve a portion of the 

remaining Lake Erie marshes. Cedar Point National Wildlife Refuge was established in 1964 under this 

same authority and purpose. Today the Refuge Complex consists of three separate refuges (Ottawa, Cedar 

Point and West Sister Island) that total approximately 9,749 acres. The focus of the ONWR Complex is to 

7
protect, enhance, and restore habitat for threatened and endangered species; provide suitable nesting habitat 

for migratory birds; provide spring and fall migration habitat for waterfowl and other migratory birds; 

provide habitat for native resident flora and fauna; and provide the public with wildlife-dependent 

recreation opportunities.

West Sister Island National Wildlife Refuge (WSINWR) is the oldest member of the ONWR Complex and 

the most isolated. The 80-acre island became a national wildlife refuge by Executive Order 7937 on 

August 2, 1937, and in 1975 was designated as a Federal wilderness area under the Wilderness Act of 1964. 

The USFWS manages 77 acres of the island and the U.S. Coast Guard owns the remaining acreage and a 

lighthouse. The island is home to the largest Great Blue Heron and Great Egret rookery in the United 

States Great Lakes and is also home to snowy egrets and one of the largest Black-crowned Night-Heron 

colonies on the United States Great Lakes. In fact, data from the Great Lakes Colonial Waterbird Survey 

(Cuthbert and Wires 2010) show that WSINWR is the largest and most diverse wading bird colony in the 

U.S. Great Lakes indicating that it has significant regional importance. The island is not accessible to the 

public.

4.3 Ohio Department of Natural Resources, Division of Wildlife (ODW) 

As authorized by Ohio Revised Code (ORC) 1531.04, “the division of wildlife, at the direction of the chief 

of the division, shall do all of the following: (A) Plan, develop, and institute programs and policies based 

on the best available information, including biological information derived from professionally accepted 

practices in wildlife and fisheries management, with the approval of the director of natural resources; (B) 

Have and take the general care, protection, and supervision of the wildlife in the state parks known as Lake 

St. Marys, The Portage Lakes, Lake Loramie, Indian Lake, Buckeye Lake, Guilford Lake, such part of 

Pymatuning Reservoir as lies in this state, and all other state parks and lands owned by the state or in which 

it is interested or may acquire or become interested, except lands and lakes the care and supervision of 

which are vested in some other officer, body, board, association, or organization; (C) Enforce by proper 

legal action or proceeding the laws of the state and division rules for the protection, preservation, 

propagation, and management of wild animals and sanctuaries and refuges for the propagation of those 

wild animals, and adopt and carry into effect such measures as it considers necessary in the performance of 

its duties” (ORC §1531.04). 

WS is in the process of updating the current MOU that defines USDA-APHIS-WS participation in a 

cooperative wildlife damage management program in Ohio. The MOU establishes a cooperative 

relationship between WS, Ohio Department of Agriculture, Ohio Department of Health (ODH), Ohio 

Department of Natural Resources (ODNR), Ohio Department of Transportation (ODOT), The Ohio State 

University Extension (OSUE), and Ohio Agricultural Research and Development Center (OARDC), for 

planning, coordinating and implementing wildlife damage management policies to prevent or minimize 

damage caused by wild animal species (including threatened and endangered species) to agriculture, 

horticulture, aquaculture, animal husbandry, forestry, wildlife, public health/safety, property, natural 

resources and to facilitate the exchange of information among the cooperating agencies.

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All WS CDM actions are conducted in accordance with permits ODW which authorizes WS, on an annual 

basis to take, possess, and transport at any time and in any manner specimens of wild animals, subject to 

certain conditions and restrictions set forth by the chief of the ODW. 

Table 1. Roles and responsibilities for DCCO damage management in Ohio.

Management Entity Activities Covered by the PRDO DCCO Take Not Covered by the 

PRDO1

U.S. Fish and Wildlife 

Service -Migratory 

Bird Office

• Provides limited technical 

assistance.

• Has authority to deny approval 

for projects proposing to take of 

more than 10% of local colony.

• Monitors impacts of local, 

regional and national DCCO 

damage management efforts.

• Provides oversight to ensure 

action agency compliance with 

the PRDO regulations.

• Provides limited technical 

assistance.

• Issues scientific collecting and 

depredation permits1

.

• Monitors DCCO take under 

permits.

• Monitors regional DCCO 

populations.

U.S. Fish and Wildlife 

Service – Ottawa 

National Wildlife 

Refuge

• Approves/authorizes take of 

birds on WSINWR.

• Takes birds as agents of ODW or 

WS.

• Aids in monitoring local DCCO 

population.

• May take birds for research under 

scientific collecting permits. 

• Provides limited technical 

assistance.

Ohio Division of 

Wildlife

• Take birds (less than 10% of 

local colony) after notifying 

USFWS

• Take birds (more than 10% of 

local colony) with approval of 

USFWS

• Monitor state and local DCCO 

population

• Take birds for aquaculture damage 

and research with permits 

• Provide limited technical 

assistance

Wildlife Services • Takes birds at request of 

landowners/ managers.

• Provides technical assistance.

• Takes birds (less than 10% of 

local colony) after notifying

USFWS and ODW.

• Takes birds (more than 10% of 

local colony) with approval of 

USFWS and ODW.

• Aids in monitoring state/local 

DCCO populations.

• Provides technical assistance.

• Consults with depredation permit 

applicants regarding non-lethal and 

lethal alternatives for damage 

management1

. Provides WS Form 

37 for USFWS consideration when 

issuing depredation permits.

• May take DCCOs under federal 

scientific collecting and 

depredation permits.

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Management Entity Activities Covered by the PRDO DCCO Take Not Covered by the 

PRDO1

Others2 • Not applicable. • May take DCCOs under federal 

scientific collecting permits.

• May use non-lethal techniques to 

reduce DCCO damage without a 

depredation permit.

• May take DCCOs causing damage 

under federal depredation permits.

1

 Includes DCCOs taken under scientific collecting permits and DCCOs taken under federal depredation permits.for 

damage to property and management of risks to human health and safety. 

2

 Airports, private citizens with property damage, university researchers, etc. 

V. ALTERNATIVES

Five alternatives were developed in the EA to respond to conflicts with DCCOs and DCCO damage. The 

PRDO has been implemented in the state since the completion of the EA in 2006, so Alternative 1 has 

become the Current Action/No Action Alternative. The following is a summary of the Alternatives. Three 

additional alternatives that were considered but not analyzed in detail and are addressed in the EA. 

Alternative 1. Integrated CDM Program, including implementation of the Public Resource 

Depredation Order and Migratory Bird Depredation Permits (Current Action/No Action 

Alternative)

The lead and cooperating agencies propose to implement an integrated CDM program in the State of Ohio, 

including working under the PRDO and Migratory Bird Depredation Permits (MBPs). An integrated 

wildlife damage management (IWDM) approach would be implemented to reduce, as needed, DCCO 

damage to and conflicts with public resources, aquaculture, private property, and human health and safety. 

The IWDM strategy would encompass the use and recommendation of practical and effective methods of 

preventing or reducing damage while minimizing harmful effects of damage management measures on 

humans, target and non-target species, and the environment. Under this action, the lead and cooperating 

agencies could provide technical assistance and direct operational damage management, including nonlethal and lethal management methods by applying the WS Decision Model (Slate et al. 1992). When 

appropriate, physical exclusion, habitat modification, nest destruction, or harassment would be 

recommended and utilized to reduce damage. In other situations, birds would be removed through use of 

shooting, egg oiling/addling/destruction, or euthanasia following live capture. In determining the damage 

management strategy, preference would be given to practical and effective non-lethal methods. However, 

non-lethal methods may not always be applied as a first response to each damage problem. The most 

appropriate response could often be a combination of non-lethal and lethal methods, or there could be 

instances where the application of lethal methods alone would be the most appropriate strategy. The 

primary strength of this alternative and the IWDM approach is that it allows for access to the full range of 

CDM techniques when developing site specific management plans. However, under this alternative, the 

lead and cooperating agencies could decide to only use a subset of the possible CDM methods for the 

management of DCCO damage at a specific site. For example, it would be possible to use only non-lethal

techniques at specific sites. 

Double-crested cormorant conflict management activities would be conducted in the State, when requested 

10
and funded, on private or public property, after receiving permission from the landowner/land manager. 

All management activities would comply with appropriate Federal, State, and local laws. The USFWS 

would be responsible for issuing MBPs (with input from WS) and ensuring compliance with the PRDO and 

MBPs and that the long-term sustainability of regional DCCO populations is not threatened. Selection of 

this alternative by any of the agencies would not restrict the management options available to the other 

agencies.

Lake Erie: If this alternative is selected, the agencies would work to meet the management objectives set in 

EA Section 1.5.6.3 (USDA 2006) as quickly as possible. Consideration will be given to non-lethal 

techniques such as hazing to encourage the DCCOs to move to other areas (not on Lake Erie islands). 

Hazing could also be used to discourage high densities of migrating DCCOs from remaining in areas where 

they may contribute to damage to public resources. However, experience of the cooperating agencies

indicates that lethal techniques would also be needed to adequately reduce the number of birds nesting on 

Lake Erie. Carcasses of DCCOs killed at WSI and Green Island would be disposed of in composting sites 

on the respective islands. Carcasses of DCCOs killed for reduction of damage to public resources on TPI 

or other near shore areas would be transported for disposal in a landfill. Composting sites would be built 

and maintained in accordance with Ohio Division of Soil and Water (ODSW) requirements. The compost 

sites typically consist of an eight foot square area with a 3 foot tall perimeter fence consisting of 1⁄2 inch 

mesh hardware cloth with a sheet of plastic on the bottom. A one foot layer of wood shavings is placed on 

the plastic. Alternating layers of carcasses and wood shavings are then placed inside the perimeter fence 

with a foot of wood shavings over the top layer of carcasses. There currently is one compost site on Green 

Island and three sites on West Sister Island. Personnel from ODW and ONWR would be specifically 

trained in the design and maintenance of these sites by the Ohio State University Extension. Carcasses 

from other CDM activities would be disposed of in landfills in accordance with State and Federal 

regulations.

Alternative 2. Only Non-lethal CDM by Federal Agencies

Under this alternative, the Federal agencies would only use and permit non-lethal techniques for DCCO 

management. WS would not assist with the site evaluations and completion of WS Form 37 required by 

the USFWS for a MBP. The USFWS would not issue MBPs for lethal techniques to resolve conflicts with 

DCCOs. Permits are not required from the USFWS for non-lethal CDM techniques. Entities requesting 

CDM assistance for damage concerns from the lead and cooperating agencies would only be provided 

information and assistance with non-lethal methods such as harassment, empty nest destruction, resource 

management, exclusionary devices, or habitat alteration. Depending upon which agency(ies) select this 

alternative, information on lethal CDM methods could still be available through sources such as USDA 

Agricultural Extension Service offices, USFWS, ODW, universities, or pest control organizations. 

The USFWS FEIS on DCCO management permits PRDO actions that will result in the take of less than 

10% of the local DCCO population (USFWS 2003). Decisions made by the USFWS in this EA cannot 

affect this type of CDM action on non-Federal land. The ODW would use lethal methods to take up to 

10% of local DCCO in combination with non-lethal methods to try and meet management goals (EA 

Section 1.5.6.3; USDA 2006) at all sites under its jurisdiction (i.e., not at WSINWR). Only non-lethal 

methods could be used for CDM at WSINWR because Federal agency (USFWS) approval would be 

needed to work there. Overall management goals for the Lake Erie islands and near shore areas would be 

as described for Alternative 1.

Alternative 3. Only Technical Assistance by Federal Agencies

The lead and cooperating agencies considered two ways to design this alternative. In one design, the 

Federal agencies would not conduct operational CDM, but all permitting including giving other agencies 

11
(ODW) permission to work on Federal lands would be considered a form of technical assistance and would 

be allowed. Impacts of this alternative would have been similar to Alternative 1 and would have provided 

little new information. In the second design, the Federal agencies would not conduct operational CDM and 

would not permit CDM on Federal lands. The agencies selected this design for the EA because it allowed 

consideration of the impacts of an intermediate level of CDM not analyzed in any of the other alternatives 

and also allowed the agencies to consider the impacts of having CDM conducted at some but not all sites 

that were under consideration in Alternative 1. Analysis of the second design of this alternative also gave 

the agencies the opportunity to address concerns of individuals opposed to CDM on a National Wildlife 

Refuge (See EA Section 2.2.3; USDA 2006).

Under this alternative, the Federal agencies would not be able to conduct operational CDM in Ohio, and 

would only provide technical assistance. WS would be able to assist with site evaluations and completion 

of WS Form 37 documents required by the USFWS for MBPs. Issuing permits is a type of technical 

assistance, so the USFWS would still be able to issue MBPs and grant approval for PRDO projects 

anticipated to take more than 10% of local DCCO population. However, operational CDM would not be 

conducted on Federal lands (e.g., WSINWR). Cormorant conflict management for the protection of public

resources on the remaining Lake Erie islands and near shore areas and the inland colonies could only be 

conducted by ODW and would be the same as described for Alternative 1. WS would not be involved in 

operational CDM.

 

Alternative 4. No CDM by Federal Agencies

Under this alternative, the Federal agencies would not participate in CDM. WS would not conduct the 

consultations or complete the forms required by the USFWS to issue MBPs and the USFWS would not 

issue MBPs. Non-lethal CDM techniques could still be used without a permit. Depending upon which 

agency(ies) select this alternative, information on CDM methods would still be available through other 

sources such as USDA Agricultural Extension Service offices, ODW, universities, or pest control 

organizations. 

As with Alternative 2, the USFWS would not grant approval for actions conducted under the PRDO that 

propose the take of more than 10% of the local DCCO population. The selection of this alternative by the 

USFWS would not affect ODW’s use of lethal CDM methods under the PRDO that would result in the take 

of less than 10% of the local population. The ODW has made it clear that it would use lethal methods to 

take less than 10% of local DCCO in combination with non-lethal methods to try and meet management 

goals (EA Section 1.5.6.3; USDA 2006) at all sites under its jurisdiction (i.e., not at WSINWR). No CDM 

would be conducted at WSINWR because Federal agency (USFWS) approval would be needed for any 

activities at that location.

Alternative 5. Integrated CDM Program, Excluding Implementation of the PRDO 

As defined by the Council on Environmental Quality (CEQ), the no action alternative can be interpreted as 

the continuation of current CDM practices. At the time the EA was written, none of the action agencies 

had taken action under the PRDO. Consequently, this alternative evaluated the impacts of a CDM program 

in which the USFWS would not conduct/authorize CDM under the PRDO. The lead and cooperating 

agencies have been implementing Alternative 1 since the EA was completed in 2006 including managing 

12
DCCO in accordance with the PRDO. Consequently, Alternative 1 is now the “no Action” alternative and 

this alternative will not be analyzed further.

V. CDM STRATEGIES AND METHODOLOGIES

The strategies and methods employed thus far for CDM in Ohio have not changed and are discussed 

extensively in the 2006 EA. However, the lead and cooperating agencies are proposing a modification to 

the compost and vegetation monitoring program.

When the EA was prepared, there was concern that composting cormorants on the Lake Erie islands would 

concentrate unsafe levels of mercury in the soil that might harm the environment. In response to this 

concern the ODW and USFWS agreed to test the compost sites at WSI, Green Island, and TPI for mercury. 

Cormorants taken on WSI were composted within 3 sites on that island. A single compost site has been 

used at Green Island and at TPI, though composting has ceased on TPI in recent years. Cormorants taken 

at TPI are now collected and disposed of in a landfill. At each island, samples were collected under 4 

different conditions: compost sites, soil adjacent to compost sites, soil at locations of high cormorant nest 

concentrations, and soil at locations that have a history of little or no colonial bird nesting activity. 

Compost sites were tested for mercury levels in 2007 and 2010 and results show mercury levels below the 

legal threshold of 0.2 mg/L as set by the Ohio Environmental Protection Agency (EPA) (Table 2). Future 

composting at these sites (excluding TPI) is expected to continue to have a low level of impact. Given that 

current evidence appears to indicate that material in the compost sites is well below the legal threshold of 

0.2 mg/L as set by the Ohio EPA (Table 2) and the cost of testing is substantial, the agencies are proposing 

to increase the interval between tests to once every 4 years. This proposed change is contingent upon 

future management requirements as defined by the USFWS. The USFWS is currently working on a 

supplement to the 2003 FEIS on DCCO management. One of the issues to be addressed in the FEIS is the 

question of whether collecting carcasses should be required in situations where carcass retrieval could 

result in substantial disturbance of nesting nontarget birds. Leaving cormorants where they lay reduces the 

amount of time that biologists spend within the colony, thus reducing disturbance to co-nesters as well as 

eliminating the need to compost carcasses. If, after NEPA review, the USFWS no longer requires agencies 

to collect cormorant carcasses for some PRDO actions then the ODCCG may opt to leave cormorant 

carcasses on the Lake Erie Islands where they lay following CDM activities. For DCCO take outside of 

the Lake Erie Islands, carcasses will be collected and disposed of according to standard condition 7 for 

Migratory Bird Depredation Permits (50 CFR 21.41; i.e. burial, incineration, or donation to an 

approved/permitted institution). 

13
Table 2. Results from compost and soil testing for mercury levels by island for 2007 and 2010. An * indicates that no 

samples were tested for the site. Cormorants are no longer composted on TPI and thus no testing was conducted in 

2010. The red “X” illustrates where the soil samples were collected under 4 different conditions: compost sites, soil 

adjacent to compost sites, soil at locations of high cormorant nest concentrations, and soil at locations that have a 

history of little or no colonial bird nesting activity.

 

Site In Compost Near Compost Bird Colony

Lightly Impacted Areas

2007

mg/L

2010

mg/L

2007

mg/L

2010

mg/L

2007

mg/L

2010

mg/L

2007

mg/L

2010

mg/L

Turning 

Point 

Island 0.01315 * <0.00025 * <0.00025 * <0.00025 *

Green 

Island 0.02455 0.04700 0.00835 0.01650 <0.00025 0.01200 0.00640 0.00550

West 

Sister 

Island -

Site 1 0.06250 0.03550 <0.00025 0.00400 0.00545 0.00600 <0.00025 *

West 

Sister 

Island -

Site 2 <0.00025 0.06550 0.00530 0.00450 0.00565 0.00250 <0.00025 0.00300

West 

Sister 

Island -

Site 3 <0.00025 0.08600 0.00665 0.00600 <0.00025 * 0.00780 0.00450

Vegetation surveys and monitoring at WSI have occurred at both DCCO removal and non-removal areas in 

an effort to determine the effects of culling operations on the regrowth of herbaceous vegetation and 

canopy cover. Baseline canopy and understory herbaceous data were gathered in 2006 and subsequent 

surveys were conducted in 2007, 2008 and 2010. While no statistically significant conclusions can be 

made from the data, there does seem to be an overall, positive vegetation response to DCCO management 

island-wide. The ODW and ONWR staff will continue to monitor vegetation response to CDM and will 

cooperate with other agencies and organizations including Parks Canada on studies to assess the impact of 

CDM on island vegetation.

Photography has also been used to capture snapshots of the vegetation at WSI beginning before 

management actions (2002) and continuing through to 2009. Photographs of WSI were taken during June 

or July in 2002, 2005, 2007, and 2011 from the same location offshore. Figure 3 shows the change in 

vegetation beginning before management began through to present including the increase in vegetation 

since the start of CDM. Perimeter photographs of this nature will continue to be taken and evaluated. 

X X X X

14
Figure 3. Perimeter photographs of the same point on West Sister Island documenting vegetative change from before 

management actions 2002 (top left) and 2005 (top right) and after management began 2007 (bottom left) and 2011

(bottom right). 

VII. ISSUES

The EA describes the alternatives considered and evaluated using the identified issues. The following 

issues were identified as important to the scope of the analysis (40 CFR 1508.25). The impact of 

Alternative 1on each of these issues is analyzed below.

• Effects on double-crested cormorants

• Effects on other wildlife species, including T&E species

• Effects on human health and safety

• Effects on aesthetic values

• Humaneness and animal welfare concerns of methods used

• Impacts on recreation

7.1 Effects on Double-crested Cormorants

15
Information on local, state, and regional DCCO populations and DCCO management activities is 

exchanged among WS, ODW and the USFWS. This coordination among agencies facilitates review of 

cumulative impacts on the DCCO population and helps to ensure that the viability of state and regional 

DCCO populations will not be jeopardized. 

The number of DCCOs taken under the Public Resource Depredation Order (PRDO) and other authorities 

in Ohio during 2006-2012 was within the estimated level of lethal take analyzed in the 2006 EA (Table 3). 

As discussed in Section III above the EA also established minimum numbers of breeding pairs that would 

be maintained at WSI, TPI, Grand Lakes – St. Mary and Portage Lakes in order to ensure the viability of 

the state DCCO population. The number of breeding pairs at each of these sites was either at or exceeded 

the minimums established for the protection of the state DCCO population. The objective at Green Island 

remains zero nesting pairs and thus there is no minimum breeding population objective for this site. Two

new breeding colonies have been located in Ohio. One colony is in Franklin County near the city of 

Columbus. Forty-three nests were counted within this colony in 2011. No plans to manage this colony are 

currently proposed. 

Table 3. Sumary of cumulative DCCO take for Ohio 2006-2012. 

Source of Take 2006 2007 2008 2009 2010 2011 2012

Maximum 

annual take 

anticipated 

under 

Alternative 1

PRDO WSI 4,320 1,932 579 328 423 968 1,694 N/A

PRDO Green 

Island 1,468 798 949 792 479 1,267 876 N/A

PRDO TPI 80 849 1,069 1,162 1,304 1,287 3,790 N/A

PRDO Grand

Lake 5 110 67 75 0 205 173 N/A

PRDO Portage

Lakes 0 0 0 0 0 0 0 N/A

Total PRDO 5,868 3,689 2,664 2,357 2,206 3,727 6,533 6,352

Scientific 

Collecting 

Permits

230 0 0 0 0 0 0 300

Migratory Bird 

Depredation 

Permits

99 8 116 33 28 27 54 300

TOTAL 6,197 3,697 2,780 2,390 2,234 3,754 6,587 6,952

At WSI, agency personnel monitored cormorant nesting activity in areas where removals occurred and in 

areas where removals did not occur to determine if culling operations are having an impact on the number 

of nests constructed and used by cormorants. For the years 2008, 2009, and 2010 the average number of 

cormorant nests per tree was higher (3.13, 3.27, 2.08 nests/tree respectively) in areas where cormorant 

removal did not occur than in areas where cormorants were removed (1.78, 1.48, 1.11 nests/tree

respectively). 

16
The 2006 EA concluded that the cumulative impact of all CDM actions could reduce the state DCCO 

population to between 1,921 and 2,421 breeding pairs, and that this level of reduction would not jeopardize 

the state, regional or national DCCO population. The estimated number of nesting DCCOs in the state has 

ranged from 3,279 to 5,302 breeding pairs over the period of 2006-2012. Implementation of the CDM 

program in Ohio has had less impact on the state DCCO population than anticipated prior to the start of 

CDM when an estimated 5,165 DCCO breeding pairs were in the state. 

Nationwide, the FEIS predicted that the implementation of the Aquaculture Depredation Order (AQDO, 50 

CFR 21.47), PRDO, and issuance of migratory bird permits would affect approximately 8% of the 

continental DCCO population on an annual basis or 159,635 DCCOs (USFWS 2003). Maximum annual 

take under the PRDO analyzed in the FEIS was 99,360. The FEIS concluded that the proposed level of 

take would be sustainable at the State, regional and national level (USFWS 2003). Table 4 summarizes 

cumulative DCCO take nationally since the implementation of the PRDO. Cumulative take has been well 

below the level analyzed in the FEIS.

Table 4. Double-crested Cormorant take in the 24 states included in the Public Resource Depredation Order 

(PRDO) and the 13 states included in the Aquaculture Depredation Order (AQDO). The AQDO is not 

applicable to Ohio.

Year PRDO Take AQDO and 

Depredation 

Permits Take

Total Take

2004 2,395 27,822 30,217

2005 11,221 23,869 35,090

2006 21,428 32,617 54,045

2007 19,960 18,818 38,776

2008 18,745 21,523 40,268

2009 24,973 20,192 45,165

2010 18,363 19,516 37,879

2011 28,389 16,146 44,535

2012 26,112 NA NA

Based on the above information, although the local DCCO breeding populations were reduced at several 

sites, the cumulative impact of CDM activities in Ohio did not reach levels that would jeopardize the state, 

regional or national DCCO population. Program activities and their impacts on target DCCO populations 

have not changed from those analyzed in the 2006 EA and will not have a significant adverse impact on the 

state, regional or national DCCO population. 

7.2 Effects on Other Wildlife Species

The 2006 EA concluded that the effects of CDM activities on other wildlife species would be insignificant. 

Moreover, the main objective for DCCO management in Ohio was protection of habitat for Great Blue 

Herons, State-listed Black-crowned Night-Herons, Great and Cattle Egrets, and rare plant communities, 

particularly those occurring on WSI and Green Island, from adverse impacts associated with high densities 

of nesting DCCOs.

Ohio CDM activities did not result in the direct mortality of any nontarget bird species. Agency employees 

17
are experienced in identification of avian species in the area and are trained in appropriate collection and 

management techniques. All lethal methods were conducted during daylight hours by trained personnel. 

Agency personnel implemented a variety of techniques, including use of suppressed .22 caliber rifles, slow 

movement, and camouflage clothing, in an effort to minimize indirect take through nest abandonment of 

co-nesting colonial waterbirds. 

It is possible that CDM activities might have an indirect impact on nontarget species by disturbing nesting 

birds. Shooters were paired with observers who studied the co-nesting species and recorded disturbance 

behavior (or lack thereof) at WSI during 2006-2010. Observations were used to improve management 

operations in order to reduce disturbance to co-nesting species. Data from the observers showed that 

approximately 60% of observed waterbirds did not leave their nests during cormorant removal and 

waterbirds that did leave were only away for an average of approximately 8 minutes (Division of Wildlife, 

unpublished data). Based on data collected, the ODCCG implemented additional management standards 

for minimizing risks to nesting waterbirds. These standards included minimizing number of trips to the 

colony during the nesting season and conducting management visits only when temperatures were warm 

enough to protect eggs if an incubating bird was flushed from the nest. Other standards included staying 

more than 30m from colonial wader nests whenever possible, and conducting research and culling trips as 

quickly and efficiently as possible. Additionally, on WSI, the ONWR has established 3 no-entry zones 

where no CDM was conducted. The northeast corner of the island is the core of the cormorant population, 

and a no-entry zone was established there to help ensure that the refuge does not go below the minimum 

population target of 1,500 nesting pairs.2 The second no-entry zone contains the core of the Great Blue 

Heron population. This zone was established to minimize disturbance to this species, which tends to be 

concentrated in one general area more than the other co-nesting birds. Finally, in general, we do not enter 

the area used by the Black-crowned Night-Heron population, which is concentrated within the habitat 

management area for the species. Within this area, trees are cut on a rotational basis to provide preferred 

shrub-nesting and early successional habitat for Black-crowned Night-Herons.

Nest counts for Great Blue Herons, Black-crowned Night-Herons and Great Egrets have varied since before 

the start of the CDM program at WSI (Table 5). Reasons for the annual changes are unclear. For Blackcrowned Night-Herons the answer may lie in the amount of suitable habitat on the island which has been 

decreasing in recent years. An area of the island historically used by the lighthouse keeper to graze 

livestock had changed to early succession growth suitable for Black-crowned Nigh-Heron nesting after 

grazing was discontinued. However, the area has subsequently matured, creating less than optimal habitat 

for the species. A new area on the island managed for optimal Black-crowned Night-Heron nesting habitat 

by the ONWR is actively used and can be seen in the breeding colony maps of WSI (Figures 4 and 5). 

Figures 4 and 5 represent population distributions and relative abundance for 2005 (pre-control) and 2012. 

The black dots and codes represent the permanently marked grid system where species nests are counted in 

a 25’ radius around the plot center. The nest counts at these plots are used to derive a population estimate 

for the island for each species. The populations of the 4 primary species are color and symbol coded (green 

triangle—Black-crowned Night-Heron, teal cross—Great Blue Heron, blue star—Great Egret, red circle—

DCCO). The two figures allow a visual comparison of the effects of cormorant control on their nesting 

patterns. An interesting note is the contraction of the Black-crowned Night-Heron population to the habitat 

management area for the species, which minimizes the chance of disturbance to this species because we do 

not enter the habitat management area during control operations. The figures also illustrate the variable 

2 As noted in the discussion of WSI in Section III above, DCCO take on WSI is self-limiting when the DCCO 

population is near the management objective. Consequently, the need for the no-entry zone for DCCO in the 

Northeast portion of WSI is being reevaluated in light of concerns about habitat impacts in accordance with adaptive 

management approach used for CDM.

18

 
nature of nesting patterns of Great Egrets, which shift around more than any other species on the island.

For Great Blue Herons and Great Egrets, nest numbers increased in 2006 when the most intensive control 

operations were being conducted and also the most trips were made to the island, so the sporadic declines 

do not seem to be related to the CDM program. Moreover, the minimal bird response to the shooting 

program mentioned above and the increased measures for minimizing disturbance of nontarget species 

indicate that the island has been more hospitable in subsequent years than it was in 2006.

Severe storm events on Lake Erie could also be cause for some declines. High winds during these storm 

events causes noticeable damage to trees on the islands and may have some impact on species which prefer 

nesting in taller trees (e.g., Great Blue Herons, Great Egrets), especially early nesters. Great Blue Herons 

are the earliest nesters on WSI establishing their nests usually during late March (Peterjohn 2001). Great 

Egrets and Black-crowned Night-Herons establish their nests 2-3 weeks later in late April (Peterjohn 2001). 

Alternatively, the variation in nest numbers could be a reflection of normal annual variability for the 

populations, a consequence of sampling error, or unknown environmental factors. It should be noted that 

due to the sub-sampling methodology used to arrive at population estimates, in conjunction with the patchy 

nature of colonial waterbird nesting locations, the annual population estimates have a high degree of 

variability. Thus, relatively large year-to-year changes in the point estimate for a species may not 

necessarily reflect a true change in actual population levels.

Table 5. PRDO Take of DCCO and Breeding numbers for all colonial waterbirds at West Sister Island National 

Wildlife Refuge, 2002-2012.

Year PRDO 

Take DCCO Great Egret

Great Blue 

Heron

Black-crowned NightheronSnowy 

Egret

Cattle 

Egret

2002 0 2,787 733 1007 393 13 0

2003 0 2,613 700 987 460 14 0

2004 0 3,780 707 1027 433 14 0

2005 0 3,813 827 927 500 14 10

2006 4,320 2,707 1067 1267 480 15 4

2007 1,932 1,967 760 953 460 12 16

2008 5,79 1,933 800 860 373 10 12

2009 328 1,860 907 793 460 15 7

2010 423 2,373 913 827 393 10 8

2011 968 3,160 1280 993 460 10 6

2012 1,694 2,407 740 927 480 8 0

 

19
Figure 4. West Sister Island waterbird colony data before cormorant damage management activities began (2005).

20
Figure 5. West Sister Island waterbird colony data for 2012 following 7 years of cormorant damage management. 

21
Efforts were made on Green Island to reduce disturbance to colonial waders using the same techniques 

employed on West Sister. Due to the smaller size of Green Island, shooters were not able to maintain a 

30m distance from the egrets and herons, but all other disturbance reduction strategies were employed. The 

numbers of both Great Egret and Great Blue Heron nests have shown a gradual increase over the past 7 

years (Table 6), thus it’s likely that CDM activities negatively affected the nesting waders. Black-crowned 

Night-Heron nests are spread throughout the island and are infrequently seen during CDM operations. 

Table 6. PRDO take of DCCO and breeding numbers for all colonial waterbirds at Green Island for a ten-year period, 

2002-2012. 

Year PRDO 

Take DCCO Great Egret

Great Blue 

Heron

Black-crowned NightHeronSnowy 

Egret

Cattle 

Egret

2002 0 0 no data no data no data no data no data

2003 0 0 no data no data no data no data no data

2004 0 0 no data no data no data no data no data

2005 0 857 4 91 0 0 0

2006 1,468 517 3 62 6 0 0

2007 798 686 51 122 4 0 0

2008 949 757 12 117 2 0 0

2009 792 431 85 179 13 0 0

2010 479 325 56 154 1 0 0

2011 1,267 628 104 227 2 0 0

2012 876 368 103 211 4 0 0

Turning Point is a small island, so there is not an opportunity to maintain a 30m distance from nesting waterbirds; 

however, all other disturbance reduction strategies mentioned before are utilized at Turning Point. The Great Egret 

numbers have shown a gradual increasing trend over the past 7 years while the Black-Crowned Night-Herons have 

remained around 50 birds the past 7 years with sporadic population fluctuations, thus CDM activities do not seem to 

be negatively affecting the colonial waders on this island. 

Table 7. PRDO take of DCCO and breeding numbers for all colonial waterbirds at TPI for a ten-year period, 2002-

2012.

Year PRDO 

Take DCCO Great Egret

Great Blue 

Heron

Black-crowned NightHeronSnowy 

Egret

Cattle 

Egret

2002 0 416 39 0 206 0 12

2003 0 401 31 0 187 0 6

2004 0 no 

data

no data no data no data no data no data

2005 0 409 41 0 47 0 0

2006 80 726 103 0 89 0 9

2007 849 934 132 1 53 0 0

2008 1,069 739 63 3 12 0 0

2009 1,162 952 171 4 73 0 0

2010 1,304 619 100 5 48 0 0

2011 1,287 1221 175 7 44 0 2

2012 3,790 1163 201 2 29 0 12

WS CDM activities did not result in the take of State or Federally listed Threatened or Endangered species. 

22
A review of the Federal list of threatened and endangered species indicates that there have been some 

changes to the list since the 2006 EA was completed. Four species of mussel have been listed since the EA 

was completed: Rayed Bean (Villosa fabalis - endangered), snuffbox (Epioblasma triquetra – endangered), 

sheepnose (Plethobasus cyphyus - endangered) and rabbitsfoot (Quadrula cylindrical –proposed 

threatened). In the 2006 EA and associated IntraService Section 7 consultation, the agencies concluded 

that the proposed action would have no effect on federally-listed mussels. After review of the newly listed 

species and the management methods proposed in the EA and this supplement, we conclude that the CDM 

program will also have no effect on the newly listed mussels.

Bald Eagles (Haliaeetus leucocephalus) were removed from the Federal list of threatened and endangered 

species in 2007. However, Bald Eagles are still protected under the Bald and Golden Eagle Protection Act 

and the MBTA. The 2006 EA and the 2003 USFWS EIS on cormorant management contained provisions 

for the protection of eagles. The lead and cooperating agencies have continued to implement the protective 

measures established while eagles were Federally-listed as a threatened species. In 2010, a pair of Bald 

Eagles nested on Green Island. Cormorant damage management activities on the island were curtailed in 

accordance with provisions of the EA and USFWS EIS. In 2011, the ODW obtained a take permit from the 

USFWS to address the risk that CDM actions could result in the potential incidental take of eagles 

(specifically, CDM could cause eagles to abandon a new nest site). The eagles were seen on the island 

during an early aerial DCCO survey, but were not observed on the island when ODW staff arrived to 

conduct CDM. Eagles were also not observed at the site during a post-treatment survey of DCCOs and, 

based on the presence of a DCCO on the edge of the eagle nest, it was assumed that the eagles had 

abandoned the site sometime during the spring. Given that no eagles were seen in the area by the staff 

conducting CDM it is unclear what role, if any, CDM had in the eagles leaving the site. However, even if 

the eagle departure from the site was associated with the CDM, based on the issuance of the take permit by 

the USFWS, the disturbance would not adversely affect the state, regional or national Bald Eagle 

population. No eagles were seen near the island in 2012.

The USFWS announced on August 16, 2011, the removal of the Lake Erie water snake (Nerodia sipedon

insularum) from the Federal List of Endangered and Threatened Wildlife. While DCCO control within 

Ohio colonies was determined to have no effect on this species and its habitat, it was a point of concern 

addressed within the original EA.

The agencies also reviewed the 2010-2011 state list of threatened and endangered animals. Comparison of 

the list used in the preparation of the 2006 EA and the current list indicates there have been status changes 

for several species. Bald Eagles, Osprey (Pandion haliaetus), and Peregrine Falcons (Falco peregrinus) 

changed from endangered to threatened species. Blue catfish (Ictalurus furcatus) changed from 

endangered to species of concern, and the river jewelwing (Calopteryx aequabilis) changed from 

threatened to endangered. Evaluation of risk does not vary if a species changes from threatened to 

endangered or vice versa and the review in the 2006 EA remains valid for these species. Two mayflies 

(Rhithrogena pellucida and Litobrancha recurvata) were added to the state list of endangered species. The 

Blanding’s turtle (Emydoidea blandingii), cavespring crayfish (Cambarus tenebrosus), harlequin darner 

(Gomphaeschna furcillata), green-faced clubtail (Gomphus virifrons), Boreal bluet (Enallagma boreale), 

northern bluet (E. cyathigerum) and marsh bluet (E. ebrium) were added to the state list of threatened 

species. The proposed action will not have an adverse impact on newly listed insect species or their 

habitat. In general, cormorants do not nest near small streams and caves used by cavespring crayfish 

(NatureServe 2011). Therefore, the proposed action is not anticipated to have any effect on the cavespring 

crayfish. In Ohio, Blanding’s turtles are primarily limited to the northern counties along Lake Erie and 

could, theoretically, occur in areas where CDM may be conducted. The proposed action will not result in 

23
direct take of Blanding’s turtles or alteration of turtle habitat. In areas where CDM is proposed to reduce 

vegetation loss caused by high concentrations of DCCO, CDM may have a beneficial impact on Blanding’s 

turtle habitat.

Review of the 2010-2011 state list of rare plants, lichens and mosses identified several status changes for 

Threatened and Endangered species and some species listed at the time the 2006 EA was completed are no 

longer listed. As noted above, no additional review is necessary for species which are removed from the 

list and species which have their status changed from threatened to endangered and vice-versa. Fifty-eight 

new species were added to the list (Section XII below). Species which are known to occur in counties 

where the proposed CDM currently occurs (Auglaize, Erie, Franklin, Lucas, Mercer, Ottawa, and Summit) 

are listed below (Table 8; Ohio Biodiversity Database 2011). Because the proposed CDM is intended to 

protect vegetation on the Ohio Lake Erie islands, this action is likely to have a beneficial impact on statelisted plant species. Prior to any control action at a new site, the lead and cooperating agencies will consult 

with the ODW to ensure that no actions taken under this plan will adversely affect Ohio’s listed threatened 

and endangered species. 

 

Table 8. State-listed plant species which occur in counties where CDM currently takes place 

(Auglaize, Erie, Franklin, Lucas, Mercer, Ottawa, and Summit).

Scientific Name Common Name Status

Buxbaumia aphylla Bug-on-a-stick Threatened

Cardamine pratensis var. palustris American Cuckoo-flower Endangered

Carex argyrantha Silvery sedge Threatened

Carex brunnescens Brownish Sedge Endangered

Carex diandra Lesser panicled sedge Threatened

Cinna latifolia Northern wood-reed Endangered

Eleocharis tenuis Slender spike-rush Threatened

Fallopia cilinodis Mountain Bindweed Endangered

Hesperostipa spartea Porcupine Grass Endangered 

Hieracium umbellatum Canada Hawkweed Threatened 

Ophioglossum pusillum Northern adder’s-tongue Endangered 

Packera paupercula Balsam Squaw-weed Threatened 

Persicaria robustior Course Smar tweed Threatened 

Phragmites australis spp. americanus American Reed Grass Threatened

Potamogeton zosteriformis Flat-stemmed Pondweed Threatened 

Prunus nigra Canada plum Endangered

Ranunculus fascicularis Early buttercup Threatened

Symphyotrichum drummondii Drummond's Aster Threatened 

Symphyotrichum dumosum Bushy Aster Threatened 

Tetraneuris herbacea Lakeside Daisy Endangered 

Trillium recurvatum Prairie wake-robin Threatened

Utricularia minor Lesser bladderwort Threatened

Veronica fasciculata Prairie Ironweed Threatened

The 2006 EA concluded that the proposed CDM activities would not adversely affect the viability of any 

24
wildlife species populations and would not have a significant cumulative adverse impact on non-target 

species. Review of the available information indicates that this is still the case.

7.3 Effects on human health and safety

The 2006 EA concluded that the effects of the WS IWDM activities on this issue would be insignificant. 

Program activities and their potential impacts on human health and safety have not changed from those 

analyzed in the EA. WS implementation of the program activities did not result in any adverse impacts to 

human health and safety. Impacts of the program on this issue are expected to remain insignificant.

7.4 Effects on aesthetic values

The 2006 EA concluded that public reaction to the IWDM program would be variable and mixed because 

there are numerous philosophical, aesthetic, and personal attitudes, values, and opinions about the best 

ways to reduce conflicts between humans and wildlife. Program activities and their potential impacts on 

this issue have not changed from those analyzed in the EA. 

7.5 Humaneness and animal welfare concerns of methods used

WS personnel are experienced and professional in their use of management methods, and methods are 

applied as humanely as possible. Program activities and their potential impacts on this issue have not 

changed from those analyzed in the 2006 EA. Impacts of the program on this issue are expected to remain 

insignificant.

7.6 Impacts on recreation

The 2006 EA concluded that impacts to recreation from IWDM activities would be insignificant. Program 

activities and their potential impacts on recreation have not changed from those analyzed in the EA. WS 

implementation of the program activities did not result in significant adverse impacts to recreation. 

Impacts of the program on this issue are expected to remain insignificant.

VIII. CUMULATIVE IMPACTS 

Cumulative impacts, as defined by the CEQ (40 CFR 1508.7), are impacts to the environment that result 

from the incremental impact of the action when added to other past, present, and reasonably foreseeable 

future actions, regardless of what agency (federal or non-federal) or person undertakes such other actions. 

Cumulative impacts may result from individually minor, but collectively significant, actions taking place 

over time. 

Under Alternatives 1, 2, and 3,WS would address damage associated with cormorants in a number of 

situations throughout the State. The WS CDM program would be the primary Federal program with CDM 

responsibilities; however, the state agency will conduct CDM activities in Ohio as well, and governmental 

agencies and private individuals can take birds under migratory bird depredation and scientific collecting 

permits. Through ongoing coordination with these entities, WS is aware of such CDM activities and may 

provide technical assistance in such efforts. The potential cumulative impacts analyzed below could occur 

either as a result of WS CDM program activities over time, or as a result of the aggregate effects of those 

activities combined with the activities of other agencies and individuals. 

25
8.1Cumulative Impacts on Wildlife Populations 

Cormorant damage management methods used or recommended by the WS program and the other action 

agencies in Ohio could result in a reduction in the State DCCO population, but the reduction will not 

jeopardize the health or viability of the state or regional DCCO breeding population. The proposed action 

will likely have no cumulative adverse effects on non-target wildlife populations. The intent and expected 

result of this program is to address specific DCCO damage problems occurring within each of the colonies 

mentioned above and throughout the State as necessary. The action agencies’ limited lethal take of DCCOs 

is anticipated to have minimal impacts on DCCO populations in Ohio, the region, and the U.S. Population 

trend data and information provided in the FWS FEIS (USFWS 2003) indicate that cormorant populations 

have increased for Ohio, the region and the U.S. over the past 20 years. When control actions are 

implemented by WS the potential lethal take of non-target wildlife species is expected to be minimal to 

non-existent. Conversely, there are expected beneficial impacts to non-target wading birds co-located 

within the DCCO colonies in that the goals of DCCO management are to protect critical habitat and 

minimize adverse impacts to vegetation by DCCO. Reduction in DCCO breeding numbers is expected to 

curb the degradation of habitat observed before management actions commenced in 2006.

8.2 Cumulative Impact Potential from CDM Methods 

Cormorant damage management methods used or recommended by WS and the other action agencies in

Ohio may include exclusion through use of various barriers, habitat modification of structures or 

vegetation, live trapping and euthanasia of birds, harassment of birds or bird flocks, nest and egg 

destruction, and shooting. No cumulative or long-term adverse effects are anticipated from implementation 

of these CDM methods.

8.3 Summary

No significant cumulative impacts on the human environment are expected from any of the alternatives. 

Lethal removal of DCCOs under the PRDO and Migratory Bird Permits would not have an adverse impact 

on the long-term sustainability of DCCO populations in the State, region or nation, but some local 

reductions would occur. Given the standards for the protection of nontarget species described in Section 7.2 

above and the ODCCG’s commitment to adhere to all USFWS and ODW recommendations and 

requirements for the protection of State and Federally-listed threatened and endangered species, the 

Proposed Action will not adversely impact nontarget species populations. No risk to public safety is 

expected when WS’ services are provided and accepted by requesting individuals in Alternatives 1, 2, and 

3, because only trained and experienced wildlife biologists/specialists and designated agents would conduct 

and recommend CDM activities. There is a slight increased risk to public safety when persons who reject 

WS assistance and recommendations conduct their own CDM activities, and when no WS assistance is 

provided in Alternative 4. In all four alternatives, however, this increase would not result in significant 

impacts. 

IX. PREPARERS AND PERSONS CONSULTED

Tara E. Baranowski, Wildlife Biologist USDA, APHIS, Wildlife Services

Chris Croson, Resource Management Coordinator USDA, APHIS, Wildlife Services

26
Ron Huffman, Refuge Wildlife Biologist USFWS, ONWR

Dave Kohler, Wildlife Management Administrator ODNR, ODW

Jason Lewis, Refuge Manager USFWS, ONWR

Steve Lewis, Regional Nongame Bird Coordinator USFWS

Andrew J. Montoney, State Director USDA, APHIS, Wildlife Services

Dave Sherman, Wildlife Biologist ODNR, ODW

Kimberly Wagner, Resource Management Coordinator USDA, APHIS, Wildlife Services

X. ACRONYMS

APHIS Animal and Plant Health Inspection Service

CDM Cormorant Damage Management

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

DCCO Double-crested Cormorant

EA Environmental Assessment

EIS Environmental Impact Statement

FEIS Final Environmental Impact Statement

FONSI Finding of No Significant Impact

IWDM Integrated Wildlife Damage Management

MBP Migratory Bird Permit

MBTA Migratory Bird Treaty Act

NEPA National Environmental Policy Act

OARDC Ohio Agricultural Research and Development Center

ODA Ohio Department of Agriculture

ODCCG Ohio Double-crested Cormorant Coordinating Group

ODH Ohio Department of Health

ODNR Ohio Department of Natural Resources

ODOT Ohio Department of Transportation

ODSW Ohio Division of Soil and Water

ODW Ohio Division of Wildlife

ONWR Ottawa National Wildlife Refuge

ORC Ohio Revised Code

OSUE Ohio State University Extension

PRDO Public Resource Depredation Order

T&E Threatened and Endangered

TPI Turning Point Island

USDA U.S. Department of Agriculture

USDI U.S. Department of Interior

USFWS U.S. Fish and Wildlife Service

WS Wildlife Services

WSI West Sister Island

WSINWR West Sister Island National Wildlife Refuge

XI. LITERATURE CITED

27
Conover, M.R., W.C. Pitt, K.K. Kessler, T.J. Dubow, and W.A. Sanborn. 1995. Review of human injuries, 

illnesses and economic-based losses caused by wildlife in the United States. Wildlife Society 

Bulletin 23:407-414.

Cuthbert, F. J. and L. R. Wires. 2010. Distribution and abundance of colonial waterbirds in the U.S. Great 

Lakes: 2007-2009. Final Report to U.S. Department of the Interior, Fish and Wildlife Service, Fort 

Snelling, MN.

Linnell, M.A., M.R. Conover, and T.J. Ohashi. 1996. Analysis of bird strikes at a tropical airport. Journal 

of Wildlife Management 60: 935-945.

NatureServe. 2011. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. 

NatureServe, Arlington, VA. Available at http://www.natureserve.org/explorer. (Accessed March 

9, 2012).

Ohio Biodiversity Database. 2011. Ohio State-listed Species by County, from Data in the Ohio Natural 

Heritage Database. Available at 

http://www.dnr.state.oh.us/Home/wild_resourcessubhomepage/ResearchandSurveys/OhioBiodiver

sityDatabase/rareplantsbycounty/tabid/23654/Default.aspx (Accessed August 29, 2012).

Peterjohn, B. G. 2001. The Birds of Ohio. The Wooster Book Company.

Robinson, M. 1996. The potential for significant financial loss resulting from bird strikes in or around an 

airport. Proceedings of the Bird Strike Committee Europe 22: 353-367.

Slate, D.A., R. Owens, G. Connolly, and G. Simmons. 1992. Decision making for wildlife damage 

management. Transactions of the North American Wildlife and Natural Resource Conference 57: 

51-62.

Thorpe, J. 1996. Fatalities and destroyed civil aircraft due to bird strikes, 1912-1995. Proceedings of the 

International Bird Strike Conference 23: 17-31.

USDA (United States Department of Agriculture). 1997, Revised. Final Environmental Impact Statement. 

USDA, Animal and Plant Health Inspection Service, Wildlife Services Operational Support Staff, 

4700 River Road, Unit 87, Riverdale, MD 20737.

USDA (United States Department of Agriculture). 2006. Environmental Assessment: Reducing doublecrested cormorant damage in Ohio. United States Department of Agriculture, Animal and Plant 

Health Inspection Service, Wildlife Services, 6929 Americana Parkway, Reynoldsburg, Ohio

43068. http://www.aphis.usda.gov/wildlife_damage/nepa.shtml. 

USFWS (United States Department of the Interior, Fish and Wildlife Service). 2003. Final Environmental 

Impact Statement: Double-crested Cormorant Management. U.S. Dept. of the Interior, USFWS, 

Div. of Migratory Bird Management, 4401 N. Fairfax Drive MS 634, Arlington, VA 22203. 

http://migratorybirds.fws.gov/issues/cormorant/cormorant.html.

The Wildlife Society. 1992. Conservation policies of the Wildlife Society: A stand on issues important to 

wildlife conservation. The Wildl. Soc., Bethesda, MD. 24 pp.

28
XII. Plant and Lichen Species State-listed as Threatened or Endangered Since the 

Completion of the EA in 2006.

Lichens and Mosses

Anomodon viticulosus – Long tail moss – endangered 

Anomobryum filiforme – Common silver moss – endangered 

Buxbaumia aphylla – Bug-on-a-stick – threatened

Canoparmelia amabilis – Obed shield lichen – endangered 

Canoparmelia carolinia – Carolina shield lichen – endangered 

Dichelyma capillaceum – Awned dichelyma moss – endangered 

Lycopodiella appressa – Southern bog club-moss – endangered 

Phaeophysicia leana – Lea’s shadow lichen – endangered 

Thuidium allenii – Allen’s fern moss – endangered 

Plants

Ageratina aromatica - Small White Snakeroot - endangered

Aronia arbutifolia – Red chokeberry – endangered 

Cardamine pratensis var. palustris - American Cuckoo-flower – endangered

Carex argyrantha – Silvery sedge – threatened

Carex brunnescens - Brownish Sedge – endangered

Carex diandra – Lesser panicled sedge – threatened

Carex gigantean – Large sedge – endangered 

Carex gynandra – Nodding sedge – endangered 

Carex mitchelliana – Mitchell’s sedge – endangered 

Carex reznicekii – Riznicek’s sedge – endangered

Cinna latifolia – Northern wood-reed – endangered

Eleocharis tenuis – Slender spike-rush - threatened

Fallopia cilinodis - Mountain Bindweed – endangered

Hesperostipa spartea - Porcupine Grass – endangered 

Hieracium umbellatum - Canada Hawkweed - threatened 

Magnolia tripetala – Umbrella magnolia – threatened 

Minuartia patula - Spreading Sandwort - endangered

Muhlenbergia glabrifloris – Hair grass – endangered

Ophioglossum pusillum – Northern adder’s-tongue – endangered 

Packera paupercula - Balsam Squaw-weed - threatened 

Paspalum repens – Riverbank paspalum – threatened

Passiflora incarnata – Maypop - threatened 

Persicaria robustior - Course Smartweed - threatened 

Persicaria setacea - Bristly Smartweed - endangered 

Phragmites australis spp. americanus – American Reed Grass - threatened

29
Piptochaetium avenaceum- Black-seeded Needle Grass - endangered 

Pityopsis graminifolia - Silk-grass - endangered 

Placidium sqaumulosum - Brown Stipplescale - endangered

Porteranthus trifoliatus – Bowman’s root – threatened 

Potamogeton zosteriformis - Flat-stemmed Pondweed – threatened 

Prunus nigra – Canada plum – endangered

Pseudognaphalium macounii - Winged Cudweed – endangered

Ramalina farinacea - Dotted Ramalina – endangered

Ranunculus fascicularis – Early buttercup – threatened

Rhododendron periclymenoides - Pinxter-flower – threatened 

Rubus trivialis – Southern dewberry – endangered 

Sagina decumbens – Southern pearlwort – endangered 

Sagittaria platyphylla – Elliptic-leaved arrowhead – endangered 

Schoenoplectus saximontanus – Rocky Mountain bulrush – endangered 

Schoenoplectus torreyi – Torrey’s bulrush – endangered 

Sericocarpus linnifolius - Narrow-leaved Aster – threatened 

Symphyotrichum drummondii - Drummond's Aster – threatened 

Symphyotrichum dumosum - Bushy Aster – threatened 

Symphyotrichum oblongifolium - Shale Barren Aster – threatened 

Tetraneuris herbacea - Lakeside Daisy – endangered

Trillium recurvatum – Prairie wake-robin – threatened

Utricularia minor – Lesser bladderwort – threatened

Veronica fasciculata – Prairie Ironweed – threatened

Viburnum alnifolium – Hobblebush – threatened

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APPENDIX A

Number of breeding Pairs of Double-crested Cormorants (DCCO) in Ohio by colony and year 2006-2012.

Colony

Breeding Pair 

Objective

Breeding 

Pair Count

20051

Breeding

Pair Count

2006

Breeding

Pair Count

2007

Breeding

Pair Count

2008

Breeding

Pair Count

2009

Breeding

Pair Count

2010

Breeding

Pair Count 

2011

Breeding 

Pair Count 

2012

West Sister Island 1,500-2,000 3,813 2,707 1,967 1,933 1,860 2,373 3,160 2,407

Green Island 0 857 517 686 757 431 325 628 368

Turning Point Island 400 409 726 934 739 952 619 1,221 1,163

Franklin County N/A No Data No Data No Data No Data No Data 252 43 No Data

Grand Lake- Saint 

Mary’s 15 80 20 20 16 15 No Data3 180 30

Portage Lakes 6 6 3 15 9 21 41 70 70

TOTAL 1,921-2,421 5,165 3,973 3,622 3,454 3,279 3,383 5,302 4,038

1 2005 was the maximum state population estimate prior to the initiation of CDM in 2006.

2 A new DCCO colony was discovered in 2010 in Franklin County on private property.

3 A count of breeding pairs was not conducted during the normal breeding season at Grand Lake-Saint Mary’s in 2010. Supposed nests 

were observed post-breeding/fledging and thus no reliable inferences could be made about the breeding population. It was thought

that the colony had abandoned the site; however observations in 2011 showed that it had grown and moved nearby to an island.

31