188 ORAL ARGUMENT OF JAMES C. CARTER, ESQ. 



continnously on the islands about four months; the breedinjj cows remain ahont six 

 moutlis, and part of the non-breediug male seals about eiglit or nine mouths, and 

 sometimes throughout the entire year. 



'Z2. Duriug the northward migration, as has been stated, the Last of the body or 

 herd of furseals leave the North Pacilic and enter Behring Sea in the hitter part of 

 June. A few scattered individuals, howeser, are seen during the suuimer at vaiious 

 points along the Northwest Coast; these are i>robably seals that were so badly 

 "wounded by pelagic sealers that they could not travel with the rest of the herd to 

 the Pribilof Islauds. It has been alleged that young furseals have been found in 

 early summer on several occasions along the coasts of British Columbia and south- 

 eastern Alaska. While no authentic case of the kind has come to our notice, it 

 would be expected froiu the large number of cows that are wounded each winter and 

 8]iriug ailing these coasts and are thereby rendered unable to reach the breeding 

 rookeries and must perforce give birth to their young — perhajis prematurely — 

 ■wherever they may be at the time. 



23. Tiie reason the Northern fur-seal inhabits the Pribilof Islands to the exclusion 

 of all other islauds and coasts is that it here tinds the climatic and physical condi- 

 tions necessary to its life wants. This species requires a uuitbrmly low temperature 

 and overcast sky and a foggy atmos])here to prevent the sun's rays from injuring it 

 during the long snunner season when it remains upon the rookeries. It re(|uire8 ;ilso 

 rocky beaches upon which to bring forth its young. No islauds to the Tiorthward or 

 southward of the Pribilof Islands, with the possible exception of limited areas on 

 the Ali'utian chain, are known to possess the requisite combination of climate and 

 physical conditions. 



All statements to the effect that fur-seals of this species formerly bred on the 

 coasts and islands of California and Mexico are erroneous, the seals remaining there 

 belonging to widely diti'ereut species. 



Their miorations as described in this report are roitghly represented 

 on this map {indicating on map). When they leave the l*nl)iIof Islands 

 in the autnran to go on their Southern migration they take this general 

 course (iiidicdfiiu/) to the coast of California and, comparatively s])eak- 

 ing, widely disperse; on their return, following a course nearer the 

 shore, they pass through the Eastern passes of the Aleutian chain 

 back to the Pribilof Islands {indtcailitg on map). 



The President. You mentioned that they pass nearer the coast on 

 their return. Do you mean that tliey follow the territorial waters"? 



Mr. Carter. Do you mean by "territorial waters" within three miles 

 of the shore? 



The President. Yes. 



Mr. Carter. I believe never. Scattered seals may occasionally go 

 in, but as a herd, never, I think, so near the shore as that. When they 

 go through the passes of the Aleutian Chain — those narrow passes — 

 very likely they pass within that distance of the shore. 



Senator Morgan. I think, Mr. Carter, there is some testimony to 

 show the fur seals sometimes have entered ami been captured in the 

 Straits of San Juan de Fucca. 



Mr. Carter. Oh, yes; there is a great deal of snggestion here and 

 there in the Case and Counter Case of Great Britain, evidence of a 

 conjectural character, that seals visit this place, and haul out at that 

 place, and breed on other places than tiie Pribilof Islands; but I am 

 taking now, as correctly rei)resenting tlie facts as established by the 

 evidence, the rei)<)rt, the views, of the American Commissioners. I 

 feel tolerably certain that when their report comes to be compared with 

 the evidence, and when all the evidence is thoroughly sifted, it will be 

 found that their statement will stand in the main as a truthful and 

 accurate account. 



Senator MORGAN. Is their statement based upon the same evidence 

 that this Tribunal has to consider, or is it based upon facts which have 

 come to their knowledge as ex])erts? 



Mr. Carter. Upon both sorts of evidence. Their statements have 

 the character of evidence. They were appointed for the purpose of 



