ARGUMENT -PART I. 



Argument addressed to the first four Questions for Decision 

 under Article VI of the Treaty of Arbitration. 



NATURE, EXTENT, AND GEOaHAPHICAL POSITION OF 



BEHRINa SEA. 



Beliriiiff Sea is the northernmost part of the Pacific united states 

 Ocean. ^'^^'''P-''- 



It washes the north-western parts of the coasts of Amer- 

 ica and the north-eastern part of Asia. 



The Pacific and Arctic Oceans are connected by Behring 

 Strait, 48 miles in width.* 



From east to west, Behring Sea has an extreme width of 

 1,200 miles; from north to south, it extends over about 14 

 deji'rees of latitude, or more than 800 miles. 



The area of Behring Sea is stated in the United States ibid.,p.ii. 

 Case to be 873,128 square statute miles. 



The Aleutian and Commander Islands are recognized as 

 marking the southern hmits of Behring Sea. Between the 

 Aleutian and Commander Islands, and between the latter 

 and the Kamtschatkan coast, are stretches of open sea 190 

 -iind 95 miles wide respectively. The western part of the 

 Aleutian chain forms a widely scattered archipelago, with 

 tliree open sea stretches of 50 miles or more in width each, 

 and many navigable channels and passes through all parts 

 of this group. So large are the spaces of sea as compared 

 with the lengths of the islands, that from the western end 

 of the Fox Islands to the coast of Asia, a distance of some 

 1,000 geographical miles, there are about 660 miles of sea, 

 being nearly two-thirds of the entire distance. 



The free navigation of the Pacific northward to the Arc- 

 tic Ocean is, in fact, in no sense interfered with by the 

 intervening islands, but is, and always has been, exercised 

 by all nations through and over all iJarts of Behring Sea 

 and through Behring Strait. 



15 NO NATION CAN CLOSE BEnRING- SEA J NOR CLAIM 



DOMINION OVER IT. 



The geographical conditions of Behring Sea, its enor- 

 mous size, the wide open navigable jjasses through and to 

 the west of the Aleutians, together with the great width 

 of the northern opening through Behring Strait, renders 



* Geographical miles iu all cases, unless otherwise stated. 



15 



