ARGUMENT OF ELIHU ROOT. 1959 



" Secondly. There has also been conceded to the United States 

 the enormous privilege of the use of the Newfoundland coast as a 

 basis for the prosecution of those valuable fisheries in the deep sea 

 on the banlcs of that island capable of unlimited development, and 

 which development must necessarily take place to supply the demand 

 of extended and extending markets. That the United States are 

 alive to the importance of this fact, and appreciate the great value 

 of this privilege, is evidenced by the number of valuable fishing- 

 vessels already engaged in this branch of the fisheries." 



That is to say, in 1877, and with the rights of the treaty of 1818 

 only. They said, further: 



" We are -warranted in assuming the number at present so engaged 

 as at least 300 sail, and that each vessel will annually take, at a 

 moderate estimate, fish to the value of 10.000 dollars. The gross 

 annual catch made by United States fishermen in this branch of 

 their operations cannot, therefore, be valued at less than 3,000,000 

 dollars." 



1186 That bait is an absolute necessity for the continuance of 

 that important industry is also shown by the statements of 

 these Halifax counsel. They said, at p. 551 of the same Counter- 

 Case Appendix, beginning near the foot of the page : 



" It is impossible to offer more convincing testimony as to the value 

 to United States fishermen of securing the right to use the coast of 

 Newfoundland as a basis of operations for the bank fisheries than is 

 contained in the declaration of one who has been for six years so 

 occupied, sailing from the ports of Salem and Gloucester, in Massa- 

 chusetts, and who declares that it is of the greatest importance to 

 United States fishermen to procure from Newfoundland the bait 

 necessary for those fisheries, and that such benefits can hardly be 

 overestimated; that there will be, during the season of 1876, up- 

 wards of 200 United States vessels in Fortune Bay for bait, and 

 that there will be upwards of 300 vessels from the United States 

 engaged in the Grand Bank fishery; that owing to the great ad- 

 vantage of being able to run into Newfoundland for bait of dif- 

 ferent kinds, they are enabled to make four trips during the season." 



Further down on the page, they said : 



" It is evident from the above considerations that not only are the 

 United States fishermen almost entirely dependent on the bait sup- 

 ply from Newfoundland, now open to them for the successful prose- 

 cution of the Bank fisheries, but also that they are enabled, through 

 the privileges conceded to them by the Treaty of Washington, to 

 largely increase the number of their trips," &c. 



But Sir Robert Bond himself has given evidence on that subject. 

 I read from his speech of the 12th April, 1905, beginning near the 

 foot of p. 447 of the United States Counter-Case Appendix : 



" I hold in my hand papers relating to Canada and Newfoundland, 

 printed by order of the Canadian parliament in the session of 1892, 

 and on page 28 of that report I find a letter addressed by C. Edwin 

 Kaulbach, esq., to the Hon. Charles H. Tupper, minister of marine 



