104 ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 



and regret to me that such passages as I shall have to read will be found 

 ill the Uuited States papers. I will only appeal to the fair judgment of 

 every member of this Tribunal, as I read this, as to whether on every 

 point this Eeport is not only fair but impartial and giving the authority 

 on for and against every statement whether it tells in favour of the 

 supposed view of the Commissioners or against it. Then paragraph 

 209 is ill these words : 



The distribution and mode of concurrence of the fur-seals at sea when congregated 

 in their winter habitats on the two sides of the North Pacific, and while migrating, 

 have already been noticed. While the information on these points is not as complete 

 as could be wished, it is sufficient to show in a. general way how the fur-seal is 

 affected in its movements by currents, drift, and winds. In speaking of its food and 

 feeding habits on a subsequent page, it further becomes apparent in what manner 

 the seals congregate and travel in following certain food fishes. It appears to be 

 rather in consequence of such circumstances, operating conjointly upon these pelagic 

 animals, than to any ruling gregarious tendencies while at sea that they become 

 collected into "schools " or groups of greater or less dimensions. This at least is the 

 result of the examinations made during the summer of 1891 in Behring Sea, where, 

 though two or three seals were often seen actually in company, and occasionally as 

 many as six or eigljt, the general rule seemed to be that each seal was pursuing its 

 own course, travelling, sleeping, feeding, or sporting in the water, without reference 

 to others in the vicinity. This is clearly shown by the observation that even when 

 passing through an .area at sea in which seals would be noted as abundant, they are 

 as a matter of fact usually sejiarated by distances much too great to enable any 

 single animal, or any group of two or three individuals, to be in any way cognizant 

 of the presence of the next adjacent individual or similar group. 



I should point out the remarkable corroboration of this presently when 

 I call attention to the United States evidence: 



A])art from seals met with near the shores of the breeding islands, the densest 

 "school " found by us was on one occasion about five miles to the westward of the 

 land of St. Paul Island, where about forty seals were counted in a distance ruu of two 

 miles. In all other cases, it was exceptional to meet with seals to the number of four 

 to a mile run, while two to a mile run was much above the average even when pass- 

 ing through areas of abundance. It is thus evident that the seals had been brought 

 together in such areas of abuedance by reason of common conditions rather than by 

 their own volition. 



Then follow some paragraphs which give some very important state- 

 meuts as to the sources of information, but are not sufficiently material 

 for me to read. I will now direct your attention to paragraph 214: 



214. Without attempting to enter into further details here as to the methods em- 

 ployed, the general results arrived at may now be briefly described : 



It is evident, in the first place, that the seals are most abundant in the water in the 

 immediate vicinity of the shores of the breeding islands, this abundance of seals 

 extending often not more than half-a-mile from the fronts of the breeding grounds, 

 and seldom for 3 or 4 miles in such a way as to be at all notable. In the case of the 

 Pribylof Islands, it is also observed that seals were numerous in both the monthly 

 periods in the tract included in a general way between St. Paul and St. George 

 Islands, though they differed much in this respect even at nearly approximate dates. 

 It is further clearly shown that the Pribylof and Commander groups form the main 

 centres of abundance of seals in Behring Sea during the summer; but that while this 

 is undoubtedly the case, the seals are not found to decrease in numbers with any 

 approximation to regularity in zones concentric with the islands, — always excluding 

 the seals in the immediate neighbourhood of the shores. 



215. It is therefore not possible to outline a series of zones in which the number 

 of seals present will bear an inverse ratio to the distance from the islands. It is, 

 however, possible to draw an approximate limit for a region about thePribilof group, 

 which will roughly define the area of abundant seals at sea during each of the two 

 monthly periods chosen. In the case of the region about the Commander Islands, 

 data though almost wanting for the first monthly period, and but scanty for the 

 second, are sufficient to indicate a general mode of distribution similar to that demon- 

 strable in the first case. Within the areas of abundant seals, these animals are, 

 however, by no means regularly distributed, even at any particular fixed date, but 

 are scattered in irregular patches in the diffuse character already described, and are 

 very often thichest locally towards the outer limits (M the area. 



31G. Beyond these areas, seals are found more or less sparsely scattered over a 

 great part of Behring Sea. 



