310 ORAL ARGUMENT OF FREDERICK R. COUDEET, ESQ. 



May I not say tlmt this is a very qualified denial and naturally a 

 qualified denial eomingfrom an honourable official who can simply con- 

 tent himself, not with denying that there is a pressing- and absolute 

 necessity, but simply that it is not clear from any information then pos- 

 sessed that that pressing necessity existed? The fact is, that wlien 

 the case was well understood and all the facts before the parties inter- 

 ested, it became absolutely clear that a pressing necessity existed — so 

 pressing that both sides arrived at a modus vivendi, and agreed that 

 their hand should be withdrawn from the sea, and that the herd should 

 be allowed to continue to increase and multiply in i^eace. 



From a Report made by the Special United States Treasury Agent in Alaska 

 dated the 31st July 1887, it appears. 



(1) That none but young male seals are allowed to be killed on the Pribilof Islands, 

 and of these only 100,000 annually. 



(2) That a careful measurement of the breeding rookeries on St. Paul and St. George 

 Islands showed 6,357,750 seals, exclusive of young males. 



That seems to be a very close calculation. It is not " 751 ", or " 753 " — 

 it is " 750". How that is arrived at, I do not know. 



Sir CnAELES Russell. — He is your own oftlcial representative. 



Mr CouDERT. — ]S"o doubt. That is what he says. Well, they are 

 all good guessers. 



(3) That 90 per cent of the pu]is bred by these go into the water, leaving a mor- 

 tality of but 10 per cent at the place of breeding. 



(4) That fully one-half of the above 90 per cent of pups returned the following 

 year as yearlings to the rookeries leaving thus a total mortality of 45 per cent, from 

 various causes at sea. 



It needs but a slight consideration of these figures to demonstrate that an addi- 

 tion of millions each year must be made tu the surviving seal life in the North Pacitio 

 Ocean. 



That is, it must be increasing enormously. 



The Agent in his Report says: ''This vast number of animals, so valuable to the 

 Government, are still on the increase. The condition of all the rookeries could not 

 be better?" 



This was the condition of things, if this Eeport is to be trusted, in 



1887. 



Against the enormous yearly increase of seal life may be placed the average annual 

 slaughter as given in the memorandum attached to Mr. Bayard's letter, viz, 192,457 

 for the whole world, or for the seals near to Behriug's sea as follows: 



Pribilof Islands 94,967 



Commander Islands and Robbon Reef 41,893 



Japan Islands 4,000 



Northwest coast of America 25,000 



Or a total of 165,860 



With an annual clear increase of millions, and an annual slaughter of less than 

 200,000 in the North Pacific Ocean, it surely cannot be contended that there is any 

 necessity for such stringent and exclusive measures as the one proposed in order to 

 preserve the seal fishery from threatened destruction. Not only would it appear 

 that the present rate of catch could be permitted, and a continual increase of the 

 total number of seals be assured, but it would seem that this annual take might be 

 many times multi])led without serious fears of exhaustion so long as the present 

 conditions of breeding on the Pribilof Islands are preserved. 



I can ask for no better praise of the system on the Pribilof Islands 

 than this — you may go on and take, and multi])ly the take, without 

 serious fears of exhaustion so long as the present conditions of breed- 

 ing on the Pribilof Islands are preserved. 



The time proposed as close months deserves consideration, viz, from the 15th April 

 to the 1st November. For all practical purposes, so far as Canadian sealers are con- 

 cerned, it might as well read from the 1st January to the 31st December. 



