ARGUMENT OP CHARLES B. WARREN. 1093 



the 3-mile belt of the marginal sea bordering the territory of the 

 State over which municipal jurisdiction could be exercised. 



In vol. IV of the American reprint of the Alaska Boundary pro- 

 ceedings, on pp. 31 and 32, of the Counter-Case of the United States, 

 the different meanings of the word " coast " were defined, and it was 

 pointed out that the true political coast-line, in contradistinction to 

 the political coast-line proposed by Great Britain, would pass out- 

 side the islands lying along the mainland of south-eastern Alaska. 



I submit to the Tribunal a chart which shows the islands between 

 which the line that is referred to in the British Case before this 

 Tribunal is stated to have been drawn by the United States. 



The lines shown on the charts accompanying the British Case sub- 

 mitted to this Tribunal do not correctly show the line drawn by the 

 United States in pursuance of the principle laid down in the Case of 

 Great Britain submitted to the Alaska Tribunal which principle 

 was taken from the North Sea Fisheries Convention. 



In order to controvert the principle stated by Great Britain in its 

 submission to the Alaska Tribunal, the United States, in its Counter- 

 Case before the Alaska Tribunal, at p. 32 of volume IV of the Ameri- 

 can reprint, made a statement that shows most clearly the line that 

 would result from following the principle suggested for adoption by 

 Great Britain in that arbitration. 



Later, the line can be followed on the chart submitted to this Tri- 

 bunal, and it will be seen that the statement at p. 32 of the Counter- 

 Case of the United States, submitted to the Alaska Tribunal, is 

 clearly based on the principle brought into the Case by the Govern- 

 ment of Great Britain. 



I read now from the Counter-Case of the United States before that 

 Tribunal, at p. 32 : 



" In the present instance the political or legal coast line drawn 

 southward from Cape Spencer would cross to the northwestern shore 

 of Chichagof Island and follow down the western side of that island 

 and of Baranof Island to Cape Ommaney ; at this point it would turn 

 northward for a short distance an then cross Chatham Strait to the 

 western shore of Kuin Island; thence again turning southward along 

 that shore and along the outlying islets west of Prince of Wales Island, 

 the line would round Cape Muzon and proceed eastward to Cape 

 Chacon; thence following northward along the eastern shore of 

 Prince of Wales Island to Clarence Strait it would cross the latter at 

 its entrance and proceed south eastward to the parallel of 54 40' at 

 the point where it enters Portland Canal. Thus the political coast 

 line of South eastern Alaska does riot touch the mainland between 

 Cape Spencer and 55 of North latitude." 



If the Tribunal will do me the honour to take the map which I 

 have submitted and follow the line as laid down in the Counter-Case 

 of the United States, it will be seen that the United States adopted 

 the contention of Great Britain that 10 marine miles was the proper 



