Page:Alaskan boundary tribunal (IA alaskanboundaryt01unit).pdf/107

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ARGUMENT OF THE UNITED STATES.
97

the Aleutian I-lands to the eastern coast of Siberia, as well as along fhe Kurile Ishin: from Behrings Straits to the south cape of the Islaudlof Crap, namely, te the 45° MY northern latitude, is exclusively granted to Russian subjects.

and then added:

Again, the Trilmmal will see that the whole line of that coast is indicated bw the general description of Russian assertion of dominion, '

In discussing the treaty of IS2band the rights sectred ly the United States under Article LV of that Treaty, he says:

Thore it ia stated without any qauitication whatever; acd this ts written, as T say, six days after the Treaty; it extends without any qualification the whole way vp; and the importance of Article four is that it gives a temporary advantage te the Unite! States—that ix to say, it gives to United States sulijeet= rights af access to interior seas, to eulfs, to harbors, and ty ereeks, all of which, or the greater part of which, would he in strietly territorial waters; and, therefore, to which, mpon the general rule of international law, the United States wonld not haye any right of access at all. }

Thus he shows that the United States and Russia, in treating in regan to the northwest coast which had been claimed by Russia, meant by **eoust” the shores of interior seas, ealfs. harbors and creeks, “all of whieh or the greater part of which would be in strictly tervi- torial waters.”

It is the coast of these waters that Great Britain now seeks to

7

exclude from the meaning of the word **edte” in the treaty of [s25, and on the evound that they embrace strictly territorial waters. This is urged as to a treaty in which, for the purpose of vetting the same rights as the United Stites got in respect of such inland waters, Great Britain insisted upon inserting Article TV of the treaty of Is24, adopted almost word for word. This treaty of 1824, as above expounded by Lord Russell, eave to the United States for ten years rights in strictly territorial waters alony the northwest coast, rights corresponding to which Creat Britain demanded for herself, but whieh under the present contention she got as to some of those waters exclusively and forever as against both Russia and the United States.

When Sir Charles Russell comes to speak of the right secured to Great

  • For Seal Ardttration, Vol. 13, 10,

® Por Seal Arbitration, Vol. 15, 142,