OPvAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 109 



outside 10G2 tliere are other instances of seals actually counted inside 

 the 20 miles which brings it up to the 1859, the total number, that is, 

 independently of the densely thick seals which they did not attempt to 

 count inside close up to the Islands. 



I therefore respectfully submit to this Tribunal asking them to 

 remember that these observations are addressed to them for their 

 assistance and not for the purpose of endeavoring- to produce an unfair 

 or distorted impression upon the mind of the court — 1 say that this 

 evidence points to the strongest corroboration of the British Commis- 

 sioners' judgment that there was a fairly defined area — it may be 20 

 miles, it may be 15 miles, it may be 30 miles for all I care — I dare say 

 it also varies with the weather, and with the fish and with other inci- 

 dents connected with seal life, but there is a certain defined area within 

 the immediate proximity of the I'ribilof Islands at the time that the 

 Fribilof Islands are densely crowded with seal life — outside that there 

 is a sparse distribution of seals which are not in attendance upon the 

 Islands but which are seals for reasons which I may have reason to 

 examine inhabiting the sea, passing through the sea, and to be found 

 from time to time under such circumstances that they can be occasion- 

 ally captured by the sealer. 



The President. — I suppose the information you have given us in 

 part concerning the Eussian Islands tends to show that the general 

 circumstances of seal life on the Commander Islands is the same. 



Sir Kif'iiAED Webster. — The intormation we have obtained — I 

 shall have to refer to it later on — from the Commander Islands is the 

 same, that under ordinary circumstances the seals do not go far from 

 the Commander Islands — it might be 10 miles it might be 15 miles, it 

 may be 20 miies, and that a zone of 30 miles suggested by the liussiaus, 

 for a special reason which does not ai)ply to Pribilof Islands, as I shall 

 show later on, is certainly an outside distance. But I address these 

 observations to the Court in order that they .may understand upon our 

 own independent investigation, quite apart from that which has been 

 subsequently discovered in regard to this matter, these are the consid- 

 erations that the Court ought to take in view when they decide what 

 are the limits to be i)ut upon a legitimate industry in order tliat it may 

 not be curtailed further than is necessary for a proper protection of the 

 life of the animals which are the subject of consideration. 



The President. — Have you any information as to the proportion of 

 the Commander i sland seals to the Pribilof Island seals. Is the Kussian 

 herd larger or smaller. 



Sir EiCHARD Webster. — Smaller. 



The President. — Do you know the proportions. 



Sir EiCHARD Webster. — Yes, I can tell pretty well. In an ordinary 

 year the Russians think tliey ought to kill 50,000 to 57,000 seals on the 

 island. In an ordinary year the United States contend, and I dare say 

 rightly they kill 100,000. My case is 100,000 is very much too large, but 

 I should think in all probability the correction of it Avould not bring it 

 down so low as the Russian. I think the evidence is as to the Com- 

 mander Island group or family, that the number of seals of the Pribilof 

 Islands is larger. 



The President. — Comprising Robben Reef, or is that a separate 

 flock. 



Sir Richard Webster. — I was speaking of it as a whole, but if I 

 am wrong it will not be taken against me. 



Mr. Phelps. — I observe that the last two years before the modus 

 Vivendi the Russians took about 30,000. 



