Page:Alaskan boundary tribunal (IA alaskanboundaryt01unit).pdf/75

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ARGUMENT OF THE UNITED STATES.
65

THE “COAST” KEFEREED TO IN THE TREATY, TO WHICH THE MOUN- TAINS WERE TO BE PARALLEL, AND TO THE SINUOSITIES OF WHICH, IF THE MOUNTAINS FAILED, TILE LINE WAS TO BE DRAWN PARALLEL, WAX THE COAST OF ALL OF THE INTERIOR Waters, stcu AS ‘Taku Inver axp Lyxn~ Canat.

The Cnited States chins that the coast is an unbroken coust, and that this is the dominating fnetor, that the coast, ws meant by the treaty. must first be determined, and that there ean be no mountains parallel to the coast, us called for by the treaty. which are perpendien- lar to or trend across the coast leading around the heads of the bays and inlets. and that all mountains which so trend are to be rejected fron consideration. [f the coast. or as the treaty expressed it“ lisitre de céte,” is the controlliny feature, then there will be no diftienlty as to the meaning of **sinnosity.” The line must he parallel to the coast that is meant and mnst follow the sinnosities of that coust. No moun- ains and no crest of mountains enu divide sueh coast so as to deprive the United States of any part of it.

When the meaning of “const” shall be determined, the actual lovation of the line will he a secondary proposition. Just where it will be situated with reference to the heads of the Imys and inlets, is entirely subordinate to the proposition that it must. ut all events, he situated somewhere to the intevior of the heads of such bays and inlets.

The Treaty of 1525, in the third Article. provides that ‘tla ligne de démareation suivra la créte des montagnes situées parallélement aiola eéte” The fourth Article, paragraph two. provides that, “partout of la créte des montugnes qui Sétendeut dans une direction paralléle Ala edte * * * une ligne puralléle aux sinuosités de la cdte,” ete.

It is contended by the United States that the word *edte™ thus used tieans all the land boundiny bays and inlets as well as that bounding the more open waters.

It is conteuded by Great Britain that the neyotiators in using the word *cdte™ intended it to apply only to what in the British Case is styled in one place as **eonst outside of narrow inlets.” in another place. the *weneral coast.” and in another “the general trend of coast and in another the mainlind coast of the ocean.” and that it