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DEFENDANT TER MEER: This statement is not correct. Air-raid
protection was ordered by Reich laws. This legislation of the National
Socialist government was issued during the years 1935 through 1939; but already
long before that time, silice 1931, the industrial plants were urged by the
Reich authorities to take steps for air-raid protection. The advising and
supervision of the plants was entrusted to the Reich Association of German
Industry, and that organization formed a special committee for industrial
airraid protection. This committee issued a number of leaflets, the first of
which, as far as I can remember, was printed in 1931; I shall have it
introduced later. It deals in detail with industrial air defense. In the same
pamphlet, the air-protection measures of the most important European states are
described; especially the countries France, England, Czechoslovakia, Holland,
Poland, and Russia are mentioned. Non-European countries mentioned were Japan
and the United States. The measures in those countries date back, in part, to
the year 1927. It is interesting that in France, according to a decree of the
French War Ministry, from the year 1926 the population of the frontier district
was instructed in protection against poison gas. Similar measures apply for
England, Poland, and Russia. As a result, Germany, too, concerned herself with
air-raid protection measures from 1932, and with the protection of the
population against gas attacks. The organization of civilian air defense was
expressly permitted to Germany on the basis of the Paris agreement on aviation,
of May 1926.
Q. Dr. ter Meer, you said that since 1932 Germany
concerned itself with air defense in the civilian sector. Weren't you perhaps
mistaken? Wasn't it in 1931?
A. I meant to say 1931, but I may have
been mistaken.
Q. What can you say generally about Farben's position in
regard to air defense and, in particular, about your own position and attitude
thereto?
A. Farben's attitude towards air defense was completely
reserved and reticent. Certain measures could not be evaded, and Farben's
endeavors were directed towards complying with these measures formally and
expending the money necessary, but keeping things on a modest and economical
basis. The prosecution presented Exhibit 170, Document
NI-8461,* in book 7, English page 14, and pages 2
and 3 of the German. This is the record of a meeting of various plant leaders
in Leverkusen on 21 April 1933. May I quote the following short excerpts
therefrom: "Schunk" — that was the man charged with air-raid protection
matters in the plant — "points out that * * * we must also start
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* Reproduced in part above
in subsection J 2.
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