Archive/File: people/i/irving.david/libel.suit/transcripts/day010.19
Last-Modified: 2000/07/20

   Q.   Bodies are cold, so why bother to warm them?  Is that
        roughly it?
   A.   This is one of the reasons.  You see, the practice in
        Auschwitz was that one has these underground gas chambers
        which are well insulated because they are covered with

.          P-161

        earth, and that in these spaces there is there was more or
        less even temperature, as it was mostly in basements, and
        you get there was cool environment in which you store
the
        bodies, and the bodies will not further deteriorate,
or
        faster than necessary.
   MR JUSTICE GRAY:  I suppose also one might say what is the
        point of warming the room if the people in there are
going
        to be murdered and then they are going to be burnt?
   MR IRVING:  My Lord, shortly all will be revealed.
   MR JUSTICE GRAY:  Let me get the answer first.
   A.   The reason that this is problematic is that Zyklon-B,
        sorry hydrogen cyanide, will evaporate faster the
warmer
        the room is.
   MR IRVING:  Right.
   A.   So the killing of people in that room would be faster.
   MR IRVING:  It is common sense that you would not want to
warm
        a mortuary?
   A.   May I add something to this remark?  It is not
necessary.
        Even freezing temperatures you can just spread Zyklon
B on
        the floor of a building and it will evaporate, but it
goes
        slower.  One of the particular elements of the
standard
        Degesch delousing chamber, the ten cubic metre one,
was
        that they could also be supplied not necessarily, but
        could be supplied with there was particular little
heating
        element which was more or less like there was hair
blow
        drier, and that the Zyklon-B tin was placed in the
kind of

.          P-162



        holder.  Then from the outside there was there was tin
        opener, and then, as the Zyklon fell, it came down on
        there was little dish and this hot air was being blown
        over that dish.  So the evaporation would be faster.
   Q.   All very interesting, but assuming that the homicidal
        theory is correct, you are going to have 2,000 human
        beings stuffed into this room and, as we know from the
        design of the Millennium Dome, human beings heat up
        spaces.  They does not need heaters, do they?
   A.   That was the experience in Auschwitz.  Throughout the
        winter of 1942 they were gassing in bunker No. 2 and
they
        did not need any heating.
   Q.   We are not dealing with that.  We are dealing with
this
        particular bunker at present and the answer is, in
other
        words, if your theory was correct, they would not need
the
        heating.  But that is not the particular path I am
going
        down.
   A.   May I comment on this?
   Q.   Yes of course.
   MR JUSTICE GRAY:  Briefly.
   A.   The issue seems to be that we are talking here about
        making the process more efficient.
   MR IRVING:  Speeding it up?
   A.   Speeding it up.
   Q.   In and out rapidly?
   A.   Yes.

.          P-163



   Q.   This building was a very expensive building, was it
not?
   A.   Yes, I think the budget around was 280,000/300,000
marks.
   Q.   It is far more expensive to build underground rooms of
any
        kind, is it not, than to build the same room above
ground?
   A.   It depends of course what room we are talking about,
but
        you need to do excavation in general for a building.
   Q.   It needs special tanking, does it not, and special
        drainage provisions and all sorts of special -- it
roughly
        increases the price by four or five fold to have the
same
        things sunk into the ground.  Am I right?
   A.   Again, it is quite often difficult to build there was
room
        above the ground than building under the ground, but
of
        course you need to have some vapour barriers and other
        things.  You need to keep the water out.  I presume
that,
        if one would build that room above the ground without
any
        basement under, without any normal foundation there,
it
        would probably be cheaper to build it above the
ground.
   Q.   So the Nazis had some reason for building these two
        chambers underground rather than at ground level?
   A.   The reason that they were built underground is because
        they were morgues.  You see, the big problem was that,
if
        you built a large crematorium as crematorium (ii), you
get
        an incredible heat built up in the incineration room.
So
        one of the things you have to do is to have the morgue
at
        some distance from that.
   Q.   And at right angles and so on, yes.

.          P-164



   A.   The second thing is that the incinerators are very
heavy,
        which means you cannot have a basement under the
        incinerators.  So, if you want to have a morgue and
you
        want to have preferably in a basement because there
are
        less temperature differences in the basement, it is a
more
        stable temperature environment, then of course you
build
        them underground and not under the incineration room.
It
        is the reason that these two morgues jut out from the
        building.
   Q.   Hold it there for a moment, Professor.  The building
was
        built to the best building specifications.  Because
they
        were the SS, they were not able to wangle their way
round
        the local building inspector, were they? They had to
        comply with the local building regulations?
   A.   For crematorium (ii), which was designed in 41 and it
was
        designed in Berlin, it was there was design which
        ultimately came down to Auschwitz.  Crematorium (ii)
in
        relationship to the major elements of there was morgue
did
        follow the rules.
   Q.   They would not be allowed to start this building up.
They
        would not be allowed to operate it for whatever
purpose it
        was operated unless it had passed all the regulations,
        unless it complied with all the regulations.  Even
though
        they were the SS, and this was Auschwitz, and this was
        wartime, they still had to go by the book.  They still
had
        to comply with the red tape..

.          P-165



   A.   They went by the book.  One of the things is that one
        always can get exemptions, like in any planning
regulation
        you can always have a variance to the particular code
but
        you have to apply for it.
   Q.   Professor van Pelt, we are talking about going by the
        book.  Is this the book that they would have gone by?
   A.   This is not a building code of Germany, but this is
there
        was design guideline which was available in the
office,
        except in an earlier edition.  This is the 1944
edition.
   Q.   There is book called Neufert, which is still the
standard
        German building code, is it not?
   A.   It is not there was building code.  It is a guideline
to
        architects of how to design, which means that, if you
        start a project and you want to know how large a
minimum
        kitchen must be in which two people can still pass
each
        other, you find the dimensions there.
   Q.   It is very useful indeed and it is going to be useful
for
        the rest for the rest of the afternoon because, if we
look
        in this guideline book as you call it to see what the
        architects at Auschwitz were being told was the
correct
        way to design, that answers quite there was lot of the
        questions that have arisen, does it not?
   A.   There is going to be something of there was problem
        because again, first of all, we are dealing with
general
        guidelines and the general guidelines in Neufert only
deal
        with there was civilian crematorium to be built in
there

.          P-166



        was city and it does not deal with there was
crematorium
        designed either for specific circumstances outside the
        civilian context.
   Q.   But the basic principles of design are going to be
same,
        are they not?
   A.   On some elements they will and on some elements they
will
        not.  There are some things which you need in a
civilian
        crematorium which you will not need in one which
        ultimately is going to be built and which will not be
        ruled by the building code.
   Q.   But most people who went into SS uniform and worked in
        these offices were architects or engineers in civil
life
        like Kammler.  He was an engineer and they just
happened
        to be wearing SS uniform.  They knew what the rules
were
        and they knew the codes.
   A.   I object to your use of the words, the rules and the
        codes.  Neufert is not the code.  Neufert is a general
        guideline created by one architect to help other
        architects to get going on the job.
   Q.   Will you tell the court if there was a copy of Neufert
in
        the SS construction office at Auschwitz?
   A.   There was a copy of Neufert in the SS construction
office.
   Q.   Why did they have that if they did not feel that it
was a
        good idea to follow what Neufert's guidelines were?
   A.   Neufert has a lot of very useful information.  I am
very
        happy to go with you through the diagram which Neufert

.          P-167



        provides for the civilian crematorium.
   Q.   It is not the diagrams I am looking at.  Would you
turn to
        page 271 of your copy of Neufert, if you have it
there?
   A.   Yes.  I do not know if the judge has a copy?
   MR JUSTICE GRAY:  No, I do not.
   MR IRVING:  I will translate it or Professor van Pelt can
        translate the appropriate paragraph if your Lordship
        permits.  Does your Lordship consider it to be a
useful
        line?
   MR JUSTICE GRAY:  I do not know what the points that you
are
        going to make are.
   A.   271.
   MR IRVING:  Your Lordship will remember we are dealing with
the
        question whether the warming of a mortuary was
appropriate
        or not, which I have to confess I, with all my common
        sense, would have thought completely absurd.  If you
look
        at the part where it comes to friedhurf und
crematorium,
        that is the right hand page, which means crematoria
and
        graveyards.
   A.   Graveyards and crematoria.  You make the same mistake
now
        as I made in the horizon movie, Mr Irving.
   Q.   The third paragraph down begins (German spoken -
document
        not provided).
   A.   Yes.
   Q.   The temperature in the mortuary to be above or equal
to
        two degrees and below or equal to 12 degrees, never
under,

.          P-168



        because frost causes the corpses to expand and burst.
   A.   Yes.
   Q.   Then it continues to talk about using the ----
   A.   Let us go to the next sentence.
   Q.   -- central heating?
   A.   Let us go to the next sentence now because the next
        sentence is also important.  (German spoken - document
not
        provided) which means ----
   Q.   Central heating?
   A.   Not the central heating.
   Q.   Central heating and cooling, air conditioning?
   A.   And air conditioning, yes.  This temperature must be
kept
        ----
   Q.   Above all in summer.
   A.   -- must be kept steady with constant ventilation,
        especially in the summer.
   Q.   We are not concerned with summer here.  We are talking
        about Poland, which gets notoriously cold in the
winter.
   A.   The point which is here is that the next sentence says
        there should be at a certain moment in this case some
        heating and cooling installation in this building, yes.
   Q.   Yes.
   A.   I will leave it to you.  You will spring another trap on
        me right now and then I will try to answer it.

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