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



Sir EicnARD Webster. — I am obliged to yon, my Lord. It has 

 been pointed out to me that there might be a difterenee between the 

 varions ports, San Francisco and Port-Townsend, and by to-morrow 

 morning- 1 will consider the distances. 



Senator Morgan. — Have you any evidence to show that an Indian 

 with his canoe could fish successfully in the Aleutian passes, and a 

 boat not? 



Sir EiCHARD Weester.— Strangely enough there is evidence of the 

 Indians from the shore catching some seals in one of the Aleutian 

 Passes but there is no instance that I know of a pelagic sealer sending 

 out a boat from his ship., I do not know, Senator, if among your other 

 acconiYdishments you are a sailor, but if so you would hardly think that 

 a schooner could remain with the water rushing through there, and pick 

 up a boat she had sent out in the morning, safely in the evening. 



All I can say is I do not think, as far as I am concerned it is possi- 

 ble. I do not think there is any pelagic sealing possible there. By 

 entering Behring Sea 1 mean entering the Passes — I do not draw any 

 distinction — I am willing to agree that the mouth of the Passes, should 

 be considered the Behring Sea. 



Marquis Venosta. — You think by the month of June the female seals 

 are practically in Behring Sea and there is no considerable number of 

 gravid females along the eastern shore of the Alaskan Peninsula, going 

 ont to Kadiak. 



Sir EiGHARD Webster. — On the evidence, by the end of May, the 

 gravid seals are, are least as far as the western side of the Kadiak 

 Island, and they then will be going into Behring Sea while the Pelagic 

 sealer will be starting in the middle of May and he will not catch them 

 up, and will have no temptation to, because in so far as he would want 

 to carry on his business, he would not go in till the month of July. 

 He will therefore utilize May and June. If we think of what the prac- 

 tical inducements are, he will not rush off to the neighbourhood of the 

 Passes to take the chance of a few seals and have the herd of male seals 

 which in the evidence are streaming up this place during the last part 

 of May all through June and in July, practically speaking the temp- 

 tation will be to hunt off the coasts of British Columbia (during May 

 and June and to go and hunt in Behring Sea when they go in. 



Mr. Justice Harlan. — Before you leave the map there is evidence in 

 the case showing in July and August over all the sea north of Aleutian 

 Islands and west of it are a great many seals. 



If the vessels entered Behring Sea on the 1st July, of course during 

 July, and August they would be at liberty to pursue those. 



Sir Richard Webster. — Except those within the zone. 



Mr. Justice Harlan. — But the sea would be clear from the Aleutian 

 Islands to whatever zone you spoke of? 



Sir KiCHARD Webster. — That is my submission. That is what I 

 wished and desired to bring to the Tribunal as a reasonable Regulation. 



I apologise to the Tribunal for having kept them so late today. 



The President. — The Tribunal will meet to morrow at 11 o'clock; 

 take the recess at one, and adjourn at half-past three. 



[The Tribunal thereupon adjourned till Friday, the 16th of June, at 

 11 o'clock.] 



