ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 251 



The President. — May I beg to put a question to you, Sir Eicbard, 

 in regard to the statement you made a few minutes ago. 



Sir Richard Webster. — Wliich is tliat"? 



The President. — The statement with regard to the abundance of 

 fur-seals at sea. You say that the driving and ill-treatment of the seals 

 on the islands may have driven a great quantity of seals to the sea. 



Sir Richard Webster. — Possibly. 



Tlie President. — Do you mean to say they would resort to any land 

 during tbe time they were at sea? 



Sir Richard Webster. — Oh no; I think there would be more found 

 at sea. Of course I do not want to reargue the question. My conten- 

 tion is that except for the purpose of reproduction, as with the bulls, 

 there is no evidence of the absolute necessity of going to land at all, 

 that a large number of the holluschickie do go, possibly by gregarious 

 habits, and possibly for other reasons ; but that I suggested to you that 

 it is not a vital necessity except in the cases to which I have referred. 



The President. You admit, then, that they must go for those few 

 purposes. 



Sir Richard Webster. — Certainly. It seems to me fair upon the 

 evidence to point out that in all probability a less number of these 

 animals would be likely to be found on the islands, and a larger num- 

 ber at sea if there was the amount of disturbance on the islands to 

 Avhich attention has been called; but of course. Sir, that they would 

 go back again in large numbers is equally plain when the disturbing 

 element was removed. 



I was asked to hand in and before I conclude I propose to hand in 

 the paper of regulations. These, Sir, are the regulations which I, in 

 conjunction with my learned friend the Attorney General and my other 

 learned frieuds, submit to the Tribunal as the regulations which upon 

 the evidence, ought to be laid down by this Tribunal, assuming there 

 be proper management upon the islands; and I can only repeat that 

 which he put before you, Sir: these have not been framed as a bid in 

 order that they may be the subject of further expansion. They have 

 not been framed from our point of view of considering what is the least 

 we would oft'er, thinking the Tribunal ought to order more. Rightly or 

 wrongly, these have been framed with the intention of putting before 

 the Tribunal what would appear to be fair regulations, having regard 

 to the evidence as to the seals that ought to be protected in Behring 

 Sea, by which 1 mean the gravid females passing from through the 

 Aleutian Passes to the Pribilof Islands and the females in immediate 

 attendance upon the islands nursing their young. They are as follows : 



Regulations. 



1. All vessels engaging in pelagic sealing shall be required to obtain licences at one 

 or other of tbe following ports: 



Victoria, in the province of British Columbia. 



Vancouver, in tbe province of British Columbia. 



Port Toionsend, in Washington Territory in tbe United States. 



San Francisco, in the State of California in the United States. 



2. Such licences shall only be granted to sailing vessels. 



3. A zone of twenty miles around the Pribilof Islands shall be established, within 

 which no seal hunting shall be permitted at any time.. 



I do not propose to reargue, Mr. President, that that means a very 

 much larger zone in reality, because of the absolute necessity of observ- 

 ing the zone. 



Senator Morgan. — You mean, sir Richard, that it shall be estab- 

 lished by law in both" countries'? 



Sir Richard Webster.— Certainly. 



