ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 457 



Lord Hansen. — Have you got any one of the maps which would 

 illustrate what is meant by this collocation of Behring Straits and 

 North Pacific Ocean? 



Sir EiCHARD Webster.^I will find out, my Lord. I cannot answer 

 it offhand, because the work of examining them is so heavy that I 

 cannot say for certain whether any of those are actually accessible. 



Then, Mr. President, a great deal of information is given on page 105 

 as to the meaning of the words "Northwest Coast"; and again tbere 

 is not any evidence to be found of Northwest Coast being used in this 

 limited sense in any of the existing books. It simply is a question of 

 instance after instance of either Northwest Coast being specially defined 

 for the purposes of the book, indicating a particular part, or Northwest 

 Coast being used as including the whole. Nowhere is there any evi- 

 dence of Northwest Coast being recognized as being the piece between 

 latitude 60° and latitude 54° 40'. I will now give you a reference to 

 the pages. You will find that fully examined on pages 105 to 108 of 

 that Appendix; but I can put that a little more briefly before the Tri- 

 bunal, if they will kindly refer to page 60 of the British Case. This 

 is a book published in 1840 by Mr. Greenhow, whom you will find is 

 admitted by the United States people, at that time, at any rate, to be 

 a great authority. At page 66 is set out the extract from his work of 

 the year 1840 : 



The Northwest Coast — 



And these italics are Greenhow's own. 



is the expression usually employed in the United States at the present time to dis- 

 tinguish the vast portion of tbe American continent which extends north of the 40th 

 parallel of latitude from the Pacific to the great dividing ridge of the Rocky Moun- 

 tains together with the contiguous islands in that ocean. The southern part of this 

 territory, which is drained almost entirely by the River Columbia, is commonly 

 called Oregon. — 



I believe the Columbia Eiver comes in — I see it marked there a little 

 way down the red color, Mr. President. — 



From the supposition (no doubt erroneous) that such was the name applied to its 

 principal stream by the aborigines. To the more northern parts of the continent 

 many appellations which will hereafter be mentioned, have been assigned by navi- 

 gators and fur traders of various nations. Tbe territory bordering upon the Pacific 

 southward, from the 40th parallel to the extremity of tbe Peninsula which stretches 

 in that direction as far as the Tropic of Cancer, is called California, a name of 

 uncertain derivation, formerly applied by tbe Spaniards to tbe whole western sec- 

 tion of North America, as tliat of Florida was employed by them to designate the 

 regions bordering upon the Atlantic. The Northwest Coast and the West coast of 

 California, together form the iceM coast of North America; as it has been found 

 impossible to separate the history of these two portions, so it will be necessary to 

 include them both in this geographical view. 



Mr. Greenhow here gives the following note: 



In the following pages the term "coast" will be used sometimes as signifying only 

 the seashore, and sometimes as embracing the whole territory, extending therefrom 

 to the sources of the river; care has been, however, taken to prevent misapprehen- 

 sions, where the context does not sufficiently indicate tbe true sense. In order to 

 avoid repetitious, the vortlmest-coast will be uuderstood to be the north-west coast of 

 North America; all latitudes will be taken as north latitudes, and all longitudes as 

 west from Greenwich, unless otherwise expressed. 



The Memoir continues as follows: 



The northern extremity of the west coast of America is Cape Prince of Wales, in 

 latitude of 65 degrees 52 minutes, which is also the westernmost spot in the wliole 

 continent; it is situated on tbe eastern side of Bebring's Strait, a channel 51 miles 

 in width, connecting the Pacific with the Arctic (or Jcy or North Frozen) Ocean, on 

 the western side of which strait, opposite Cape Prince of Wales, is East Cape, the 



