244 OKAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 



friends simply the references in each case to the affidavits where they 

 will find my statement supported, that these lines have been drawn by 

 people who have been absent in all but one case 10, 12, or more years 

 from the Island and from memory without notes. It is the United 

 States Case, Appendix n" 2, pages 3, 44, 00 and 167. Those are the 

 affidavits of the gentlemen, Mr. Morgan, Mr. Mclntyre, Captain Bryant 

 and Mr. Stanley Brown, Mr. Stanley Brown, of course, being responsi- 

 ble only for the plotting of what he saw in the year 1891. 



Senator Morgan. — Did Mr. Stanley Brown's report have no reference 

 to Mr. Elliott's previous surveys"? 



Sir Richard Webster. — None whatever, Mr. Senator; it was made 

 entirely upon his own surveys; in fact, it does not appear from any 

 reference in Mr. Stanley BroAvn's affidavit, so far as direct reference is 

 concerned, — you cannot tell if he had it or not. 



Senator Morgan. — Mr. Elliott surveyed the same rookeries'? 



Sir EiCHARD Webster. — Mr. Elliott surveyed the same grounds; 

 but no reference is made anywhere to Mr. Elliott's Rei^ort as I said the 

 other day by Mr. Stanley Brown. 



Now, Mr. President, I was challenged the other day with regard to 

 the Russian figures of killing. I know now they will not dis]mte the 

 figures, but they say that we made an improper use of them. My point 

 is that prior to 1867 and 1868 no experience of the Islands would have 

 justified a killing of anything like 100,000. May I remind you for a 

 moment of how the matter stands! We say that the average of the 

 figures given on page 132 of the British Commissioners' Report, showing 

 the killing prior to 1868, shows an average of less than 40,000 a year. 

 They do not now dispute the authenticity of the figures so far as they 

 appear, of course, a few years were only estimates, but all the figures 

 come from United States sources. But what they say is, that you, the 

 British Commissioners, have behaved very unfairly and very improj)- 

 erly in estimating the figures at something less than 40,000 and your 

 case is an unfair case, because you have made that statement. I desire 

 to tell the Tribunal that in the United States Executive Documents, 

 N" 36 of the 41st session, Mr. Mclntyre, the witness referred to many 

 times by the United States reporting to Mr. Blaine in the year 1809, or 

 rather reporting to Mr. Boutwell, the Secretary of the Treasury, and 

 Mr. Boutwell sending it on to Mr. Blaine who was then the speaker of 

 the House of Representatives, — it is on page 15, — uses this language 

 with regard to tlie Russian killing, which, at any rate, show that the 

 British Commissioners were not less accurate thau Mr. Mclntyre, in 

 fact they have been more liberal. 



From the same autliovity (that appears to be Vemianodoff), we learn that during 

 the lirst few years following the discovery of the Islands in 1781 over 100,000 skins 

 were annually obtained; but this it seems was too large a number, for the decrease 

 in the yearly return was constant until 1842, when they became nearly extinct; and 

 in the next decade the whole nuuiber secured was 129,178, being in 1852 but 6,564. 

 But from 1852 under judicious management, there a])pear8 to have been an increase, 

 and, in 1858, 31,8 LO were taken which was the largest catch in any one year until 

 1867, when, as I am informed, some 80,000 or 100,000 were secured under the supposi- 

 tion that the territory would soon be transferred to the United States. 



Now that was the statement made perfectly impartially in 1869 by 

 Mr. Mclntyre that the largest annual catch in any year from 1842 down 

 to 1869 had been between 31,000 and 32,000. 



Lord Hannen. — That is not in accordance with all these figures 

 because some are larger. 



Sir Richard Webster. — In the year 1865— Yes — That is the first 

 that I see- 



