1092 NORTH ATLANTIC COAST FISHERIES ARBITRATION. 



The charts of the Pacific coast and the atlas accompanying the British 

 Case are undoubtedly produced to support this assertion. 



A review of the Alaska Boundary dispute will establish that this 

 statement in the British Argument is without foundation, and will 

 also show that the British charts put forward in this submission to 

 prove it are founded on false premises. 



I refer to the British charts submitted to this Tribunal, found in 

 the volume of charts, and I shall first make a general statement con- 

 cerning charts numbered 13, 14, 17, and a portion of No. 16. I may 

 say that these charts submitted to the Tribunal, numbered 13, 14, and 

 17, and all that portion of No. 16 lying south of 54 40' north latitude 

 have nothing whatever to do with the district really involved in the 

 submission to the Alaska Boundary Tribunal. 



The lines on chart No. 15, and on that part of No. 16 north of 

 54 40' are, I respectfully submit, founded on an erroneous assump- 

 tion as to the position of the United States in that arbitration. 



One of the principal subjects discussed before the Alaska Boundary 

 Tribunal was the meaning of the word " coast," used in the Anglo- 

 Russian Treaty of 1825. which was construed by that Tribunal. 

 658 It was contended on the part of Great Britain that the coast- 

 line to be used as a base-line for the location of the boundary- 

 line on the mainland in accordance with the provisions of the treaty 

 of 1825 was a line extending along the mainland of south-eastern 

 Alaska cutting across the entrances of inlets. 



The proceedings of the Alaska Boundary Tribunal, Congressional 

 Reprint, vol. Ill, show that Great Britain invoked the rule of 

 measurement for this line cutting across inlets established by the 

 terms of the North Sea Fisheries Convention of 1882, and maintained 

 that this rule of measurement should be regarded by the Tribunal in 

 determining what was to be the coast-line for the purposes of de- 

 termining the boundary -line on the mainland. The British Case, at 

 p. 79 of vol. Ill, just referred to, quoted the 2nd article of the North 

 Sea Fisheries Convention, which reads as follows: 



" As regards bays, the distance of three miles shall be measured 

 from a straight line drawn across the bay, in the part nearest the 

 entrance, at the first point where the width does not exceed ten miles." 



In controverting the contention of Great Britain, the United States 

 maintained that the physical coast-line furnished the base-line for the 

 boundary on the mainland to be determined by the Tribunal, and, in 

 its Counter- Case, pointed out that such a coast line as that for which 

 Great Britain contended was a political coast line, in contradistinction 

 to the physical coast-line which the United States contended should 

 be used as the line from which the boundary on mainland should be 

 measured. The United States also maintained in its Counter-Case 

 that the sole purpose of such a political coast line was to determine 



