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



Then in Vol. 1 of the Appendix to the BritivSh Counter Case, pages 

 138 and 139, you will find. Sir, very important and very strong evidence 

 with regard to this presence of food. This is what Mr. Macoun says : 



When I landed at the village on St. Paul Island on the 30th June, cod and halibut 

 were hanging before many of the natives' houses. In answer to my enquiry as to 

 where they had been caught, I was told that they had been taken less than 3 miles 

 from St. Paul Island, and between it and Otter Island. 



Up to the 12th of Seiitember, the date of my final departure from the Pribilof 

 Islands, natives went out fishing every fine Sunday, and, in fact, every day they 

 were not engaged on work for either the Government or the Company, and good 

 catches of fish were invariably made. 



When on St. George Island the 17th July a great many cod were seen hung up to 

 dry, and at dinner that day I asked the United States Treasury Agents and the 

 oflieers of the Company why they had not fresh fish on the table. I was told that 

 they could be had in abundance whenever wanted, but that they were all tired of fish. 



"H. M. S. Daphn6", while I was on board of her, was anchored during the fore- 

 noon of the 2l8t July in 18 fathoms of water, one-third mile off Dalnoi Point, St. 

 George's Island, and cod, small halibut and sculpin were caught in great numbers 

 at this time. 



A holiday was given the natives on St. Paul Island on Saturday, the 13th August, 

 and many of them spent the day fishing. Their boats were in sight all day between 

 2 and 3 miles off Lukannon rookery. They returned late in the afternoon with their 

 boats half full of fish; there were many more cod than halibut, though the latter 

 were much the larger fish. 



I asked the natives how far they went out for fish later in the season ; they replied 

 that they never had to go more than 5 miles from land to get all the fish they wanted, 

 and that it was only in September that they went that far. I was taken to south- 

 west Bay, St. Paul Island, by a crew of natives, on the 23rd Atigust. During the 

 brief time I was ashore they fished about half-a-mile off' Zapadnie rookery catching 

 two halibut and seven cod. These men told me that the fish were always very plen- 

 tiful near the island, biit that until 1891 they had never had time during the summer 

 mouths to catch them, when they were not driving or killing seals, there were the 

 skins to salt and re-salt, the Company's ship to load or unload, and coal and pro- 

 visions to be brought from the landing-place to the storehouses. 



The next day salmon were seen in tlie lagoon near the village. 



Then the next paragraph relates to Behring Island. I need not read 

 that. Then it goes on : 



Mr. Baldwin, who has been on St. Paul Island several years, told me that small 

 squid are very numerous close to the islands, and Mr. Townsend. — 



that is the United States gentleman — 



Who has for several years been employed as a naturalist on the "Albatross" in 

 Behring Sea, said more than once in my hearing that there was no part of Behring 

 Sea that did not abound with them. 



It is thus evident that should seals, whether males or females, require food during 

 the time they resort to the islands, (which has not been proved) it is to be had in 

 abundance close to the rookeries, while it is further apparent that the natives with 

 the exercise of but ordinary diligence on their own part are in no way dependent on 

 the slaughter of seals for food. 



Now, Mr. President, it must not be forgotten in this connection that 

 ex concessis, as I have said more than once to-day, the large proportion 

 of the animals during a considerable portion of their stay on laud do 

 not require to catch lish — that is to say the bulls, the holuschikie and 

 the females, — until such time as they are minded to go out again to sea. 



Now let us look at the United States evidence upon this point. I 

 refer to the evidence of Captain Tanner and I will ask the Tribunal 

 kindly to turn to it. It will be found at page 374 of volume 2 of the 

 Appendix to the case of the United States. 



He says: 



Seals killed in Behring Sea after the birth of the pups are largely mother seals 

 and the farther they are found from the islands the greater the percentage will be. 

 The reason for this seeming paradox is very simple. The young males, having no 

 family responsibilities can afford to hunt nearer home where food can be found if 

 sufficient time is devoted to the search. The mother does not leave her young except 



