Deposition of Dr. G. Brent Dalrymple - Page 2

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A. I don't think there is any such thing as a minority scientific theory and I will tell you why. Because by the time a hypothesis reaches the status of a theory, there has to be a preponderance of evidence supporting it. It has to be almost overwhelming. Now at some later date the situation may change so that that theory has to be modified. But in terms of a minority theory, I can't think of any. Sometimes you will get minority hypotheses.

Q. What's the difference between a hypothesis and a theory?

A. Well, a hypothesis basically has less, much less support than a theory and it often encompasses a smaller chunk of something.

For example, I might hypothesize that this table is six feet long and I might perform an experiment to determine whether that hypothesis is correct. But I don't think that would ever become a theory just because I proved the table is six feet long.

So there is a difference in both the weight of evidence, and there's usually a difference in scale.

Q. If you have a hypothesis which rises to the level of a theory, at some point is it possible for the theory to rise to the level of a fact?

A. I don't — well, the way I think of a fact is essentially an observation or a set of observations that

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are virtually universally accepted. I think, again, a fact would be that this table is six feet long or however long it is. Now, that's kind of a personal definition. Usually in science we use things like hypothesis and theory. Facts are primarily a set of data. That's the way I think of fact.

Q. Well, trying to recall one of the more prominent examples from the history of science. When Copernicus hypothesized, I guess, first that we did not have a geocentric universe. But in fact, the planets revolved around the sun. And then at some point I suppose that was tested. Is that to you today a fact or a theory?

A. Well, I think that is sufficiently a simple concept and has been measured to the degree that I would probably consider that a fact. I don't know of anyone who disputes that.

Q. And that was, at one time, a theory was it not?

A. I presume it was, yes. I don't really know the history of evolution of that particular line of thought as well — well enough to tell you at what point it was a hypothesis and at what point it was a theory. I think today most people would regard the fact that — well, I just used the word didn't I? Would regard that as a fact that the planets go around the sun.

Q. All right. So to take your position that there is

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no such thing as a minority view of scientific theory, at one time the thought that we do have a geocentric universe. The earth is the center around which everything else revolves. Did that hold sway in the scientific community? Are you aware of that?

A. As far as I know, that's correct.

Q. And when Copernicus offered this new theory or hypothesis, whatever you want to term it, it was not immediately and fully accepted within the scientific community. Are you aware of that?

A. That's correct.

Q. So under your view, until such time as the scientific community accepted, by a general consensus, Copernicus' theory, you would not have wanted that to be taught in a public school science classroom.

A. I think that depends on whether I were living in Copernicus' time or whether I were living today. If you asked me that — if that evolution and thought were going on today, I think we would recognize that Copernicus' hypothesis was a reasonable alternative that did not conflict necessarily with any data. And you might hold those two as an alternative hypothesis for a short period of time.

You do have occasionally some overlap when one theory or hypothesis replaces another one. There will be

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a time when it is difficult to decide between the two.

Q. Uh-huh.

A. There is seldom one definitive experiment, one breakthrough that happens at an instant in time so that you switch instantaneously from one theory to another. The theory of plate tectonics, for example in geology took several years to become accepted and replace the old ideas. So there was a brief period of overlap.

Q. Uh-huh.

A. But it only becomes an alternative when it becomes a reasonable explanation and when it doesn't conflict with an overwhelming amount of fact that opposes it or data.

Q. Well, during the time that there was this overlap or when both were being discussed — both being these two theories of the earth and of the universe — would it have been useful for those students who were studying science to study both theories you think?

A. Well, I don't — I don't know. That's difficult because in those days science and philosophy were mixed up together and I think with religion, too. Degrees in science weren't given, I think, until after Darwin graduated.

I don't think you could go to school and study science and get a degree in it when Darwin went to school. So part of the difficulty in answering that question is because I think there's been an evolution in the way

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science operates. It's separated from philosophy and religion in a way that it wasn't in Copernicus' time.

Q. The methods of radiometric dating which you have previously listed, are any of those methods — can two of those methods be used to date some geologic formation or rock or whatever — the same type? I mean can you use more than one method to arrive at a conclusion as to the age of something?

A. Sometimes you can, yes.

Q. Are the methods, to any degree, conflicting?

A. I don't quite understand —

Q. Well, is there a conflict in the methods of radiometric dating?

A. I still don't know what you're —

Q. Can you answer the question? Is there a conflict?

A. Well I don't understand the question. That's why I can't —

MR. WOLFE: I guess I find the question ambiguous as well. I'm not certain whether you mean do the methods they use, are in some sense not the same? Are they conflicting? Or are you asking whether the results arrived at, whether they occasionally give conflicting dates, for instance. I'm afraid I would object to the form of the question as presently posed as ambiguous.

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Q. All right. Let me see if I can rephrase it. Let me ask maybe a different question. Are you aware of generally some of the theories of evolution?

A. Only in the most general sense and primarily as a layman.

Q. All right.

A. I'm not prepared to answer any detailed questions on evolution at all. It is out of my field of expertise.

Q. Are you aware that there is something called the modern synthesis theory of evolution?

A. I'll just have to repeat my previous statement. I'm not an expert on evolution. I'm —

Q. I'm not asking you — I'm asking you as a layman are you aware — a layman in that field are you aware of that?

A. No.

Q. Are you aware of something called the punctuated equilibrium?

A. I have heard about it, yes.

Q. What do you understand that to be?

A. Well, my understanding is that — again, this is a layman's interpretation — is that evolution proceeds by a series of spurts and then long periods of stasis or non-change.

Q. And that is opposed — that theory would be as opposed to a slow gradual change; is that correct?

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A. That's my general understanding, yes.

Q. Do you know as to whether one is held by a majority of people within this field of expertise or not?

A. You'd have to ask a biologist. I don't know that.

Q. Basic mathematics would tell you that both can't be held by a majority. Would you agree with that?

A. Both could be held as alternative explanations, alternative models until such time as there is enough evidence to decide which is which. I'm speaking now in a general sense.

Q. I understand.

A. I don't know about these specific things at all.

Q. Sure. Do you think it would be appropriate in a public school science classroom to study both of these theories?

A. Well, you're really asking me now I think what the — a question that's related to what the present state of biological science is. And I'm not sure enough of what that is. I think that science classes should teach the present state of science as it is perceived by scientists. Now I don't know whether scientists perceive those as being equal or whether more people are in favor of one or the other. So it is difficult for me to answer the question if that's enough of a qualification to explain my difficulty.

Q. Okay. If there is one that is held by more of a

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majority of scientists and one that is held by a minority of scientists, do you think that the minority view should not be discussed in a science classroom?

A. Well, I suppose that depends on why it's a minority. If it's a minority because it's absurd, then I think it should not be discussed in the classroom. If it's a minority simply because there is slightly more evidence for one than the other and perhaps you have 60% of the people thinking that one may be correct and 40% thinking that the other is correct, then I would suggest that those things probably, then, should be both discussed in a classroom.

Q. Doesn't that conflict with your previous answer that there's no such thing as a minority scientific theory?

A. No, it doesn't. I think I said at time of transition when one theory might be replacing another one or when it is difficult to decide between the two, there may be periods of overlap. But I think those are rare. I'm not even sure that either one of those models has the status of a theory.

Q. Why do you say that?

A. Just because of my own ignorance. I'm not saying they don't have that status. What I'm saying is I don't know what the status of punctuated equilibrium versus gradual and continual evolution is. This is out of my

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field.

Q. Was your earlier answer, though, to one of my questions that if a hypothesis is held by only a minority of the scientific community, then it cannot be a scientific theory?

A. Would you repeat that for me again?

Q. Okay. Let me rephrase it. I have it down earlier that you said there's no such thing as a minority view scientific theory.

A. I think I later qualified that to say that at times, perhaps, there might be.

Q. Now how do you define — how does science define when there is an overlap, this transition that you mentioned?

A. Well, usually when there's active debate on both models in the traditional literature then there's an overlap. When science has a difficult time deciding between two models or two hypotheses, that's usually fairly obvious because the literature reflects that disagreement or that uncertainty.

Q. So if there is an overlap, do I understand you to say that you would not, at that point, object to two perhaps conflicting theories being taught in a public school science classroom?

A. No, provided they're both scientific theories or hypotheses and provided they're both substantiated with

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enough fact or observation that they — that both should be taken seriously, at least to a degree. Then I wouldn't object at all.

Q. Well, that last qualification you put on there of — of — could you read that back? That last part of that statement.

[Thereupon the court reporter read back the last answer given by the witness.]

Q. Okay. If there is a debate or publications in the scientific journals on both, would that not be sufficient evidence to you that there is enough facts or evidence for both as you said there?

A. Not necessarily. Every once in awhile a scientist will get an absolutely crazy idea and, publish it in the scientific literature as, uh, "Here's my crazy idea, colleagues. What do you think about it?" Just because that paper appears in the scientific literature does not give it the status of a hypothesis.

I think hypotheses have to be — have to be reasonable. They have to have some reasonable chance of being true before they're worth spending much time on.

Q. How do you define whether they're reasonable?

A. Well, when I think enough scientists look at that and say, "Yeah, that's a possibility." May I use an example?

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Q. Sure

A. I think today if a scientists published a hypothesis that said that the earth was flat, I think we now have enough data and have had enough data for so long that that's absurd. Now you could frame that proposition in terms of a scientific hypothesis. But it really is not because it's absurd and because it is so totally disproved.

Q. Let's go off the record.

[Off the record discussion.]

BY MR. WILLIAMS:

Q. Dr. Dalrymple, do you favor teaching all scientific evidence on theories of origins?

MR. WOLFE: I'll object to the form of the question unless you specify whether it's to high school students, graduate students, whatever.

MR. WILLIAMS: Oh. I really want to find out generally. I think we can qualify it later of if he wants to qualify it, he certainly can. But I want to — let's say generally teaching all scientific evidence.

MR. WOLFE: Well, then I want to object to the question.

Q. Okay. You can answer the question.

A. I guess I need to know before I do that what you mean by origin?

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Q. Talking about theories of origin of the universe, the earth, of life and man.

A. You don't necessarily mean ultimate origin? You see, this is the problem I have. If you ask me how a particular rock originated in its present state, that's a fairly simple question. It might be scientifically complex, but its a fairly simple question. If you're asking me how matter and energy came into being in the beginning, whatever that means then that's a difficult question that I'm not sure is within the realm of science. So that's my difficulty.

Q. Well, please remember that in my question it's a given that we're talking about scientific evidence.

MR. WOLFE: Well, I'll object to the form of the modified or restated question because it may not, in fact, be possible to assume that there is scientific evidence on a — on a, by definition, a non- scientific question.

A. You know, there's scientific evidence that goes back to the "Big Bang" if I can use that phrase. It doesn't go beyond that.

Q. Well, for example the scientific evidence on the Big Bang. Do you think that should be taught or do you favor it being taught?

A. Yes. Yes. Those are scientific observations.

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Q. What is the scientific evidence of which you are aware which supports the Big Bang theory?

A. Well, you're asking a question in astronomy and astrophysics and this is, again, out of my field. So if you want an answer, it would have to be a layman's answer. And as far as I know, the ideas or the data are primarily based on the fact that the galaxies are mutually receding away from each other and away from a common point in the universe.

Q. What happened to your resolution after you drafted it and circulated it?

A. Well, there's been no action on it yet. It has not been introduced to the council. I don't know whether it will be introduced to the council.

Q. Have you had a meeting of the council?

A. There's been no meeting.

Q. I take it you did get some opposition to your resolution?

A. Basically to the wording. This draft was circulated to try to find out whether there was enough interest in the subject that a resolution in any form should be considered. And this is why I say I'm not sure the resolution will even be introduced.

I think I would also like to say that that is a rough draft. It has the same status as an unfinished

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manuscript and I fully expect that if it goes anywhere, it will be modified. I don't know in what way except that there'll be other people besides myself involved in it. They will have opinions of their own on how such a resolution might be worded.

Q. In some of your letters in here you state that if it should be defeated and not prevail or be defeated, you told the council that that would be, to paraphrase, disastrous. Why is that?

A. Well, I wouldn't use the term disastrous, but my guess is that the creationists would view that as a victory. That a scientific society has considered a resolution against scientific creationism and rejected it. In a sense, whenever you submit a resolution like this you are forcing a group to take a stand either yes or no. There is no in between. This is why I say I'm not even sure it will be introduced because I'm not sure they even want to consider the question. It maybe a subject in which there is not interest. And if that's so, it will be promptly dropped.

Q. Why would there perhaps be no interest in your opinion?

A. There is a — there are some people in the AGU who do not think that the AGU should become heavily involved in any public issues. That it should stick primarily to

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the dissemination of scientific information strictly for the consumption of scientists.

Q. Uh-huh.

A. And I anticipate that might be the major objection of considering such a resolution.

Q. In one of your letters, this one to Dr. Leslie Meredith, you state that "We..." and from the context of the letter-I think that's Carl Sagan and yourself.

A. Uh-huh

Q. "...think that this is appropriate for the AGU to go on record on this issue, particularly as it is primarily a science education issue and not a political one." Could you tell me why you feel it is a science education issue and not a political one?

A. Because I think the issue is really what is going to be taught in science. That's the only issue that concerns me. I'm only concerned with science education. I have no qualms or reservations about teaching creationism as part of a social science curriculum or as part of a religion curriculum or a philosophy curriculum. But I have objections to teaching it as a science curriculum because I sincerely believe it is not science. That's why I think this is primarily an issue of what is science and what is not science.

Q. You wrote a letter, according to Exhibit #3, to

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Dr. James A. Van Allen. Did you ever get a response from him on this?

A. No, I've not yet.

Q. Have you talked with him about it?

A. I've not.

Q. One of the letters that you did receive from someone by the name of C. T. Russell and he says that he thinks that Van Allen will be your main problem. Do you know why he has that opinion?

A. No, I don't.

Q. According to this letter, Van Allen strongly opposed the ERA resolution. And do you know from that — are you aware of that fact?

A. Yes, I'm aware of it. And my understanding of that is that Jim Van Allen is opposed to the AGU taking stances on public and political issues. And whether he would consider a resolution on creationism to be one of those or not, I will not know until I hear back from him or have. a chance to talk to him in person about it. The letter by Russell is obviously speculation based on what, I don't know.

Q. Let's mark this as Defendant's Exhibit #4 please.

[Thereupon State's Exhibit #4 was marked for the record.]

Q. I'd like to show you Exhibit #4 to your deposition

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which is a letter to you from someone and your letter to a Sister Neal I think it is.

A. Noel.

Q. Noel? Excuse me. Do you recall writing that letter?

A. Yes. I recall writing one of the letters. I think she wrote the other one.

Q. Why did you write the letter to Sister Noel Riley?

A. She had written a column in a Southern California newspaper. I believe it was the Los Angeles Times but I'm not sure. I thought it was very well done and I wrote to her to tell her essentially that. She wrote back telling me basically that she appreciated my letter.

Q. All right.

A. I often do that when people have done things I like. I will often write them and say, "Congratulations" or "I think that was fine." "I appreciate what you've done" and so forth. I try to make that a regular habit.

Q. You stated in your letter to her that "Fortunately the number of scientists who draw religious inferences from physical data and the number of religious leaders who use the Bible as a science text are very small minority."

A. Yes.

Q. Who are the scientists of which you are aware who draw religious inferences from physical data?

A. I'm not aware of any in my personal knowledge. Those

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were phrases taken out of her column. I don't personally know any who do.

Q. Do you know of any who do?

A. I do not know of any who do and the reason I phrased it the way I did is I'm perfectly willing to admit that there may be some. She, as I recall, said there were and I'm quite willing to grant that possibility. But from my experience they must be a very small minority because I don't know any of them.

Q. Do you recall what she was talking about and what kind of inferences, religious inferences scientists were trying to draw from physical data?

A. I don't recall the details of the column at all.

Q. Do you have an opinion as to whether religion can be based on science?

A. I'm not sure I have any opinion on that one way or the other. Let me think about that a minute. I guess the answer to that might depend on how religion was defined.

Q. How do you define religion?

A. Well, my — I guess my personal definition is belief in a supreme deity of some sort, or deities.

Q. Do you think it's necessary to have a supreme being or God in order to have a religion?

A. Well, within my upbringing in western culture, I guess the answer to that would be yes.

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Q. You mentioned western culture. Would you acknowledge that there are religions, particularly some of the eastern mystic religions which don't have a God in a sense. Are you aware of that?

A. No, I'm not aware of that, but I'm willing to take your word for it if you say it's so.

Q. Okay.

A. I'm not a student of religion.

Q. You also used the phrase "religious leaders who use the Bible as a science text."

A. Yes.

Q. Does your reading of Act 590 indicate to you that the Bible could be used as a science text under this law?

A. May I look at this?

Q. Certainly.

A. Well, it says that the teaching must not include any religious instruction or references to religious writings. And I would presume that would preclude using the Bible as a text.

Q. Mark this Exhibit #5 please.

[Thereupon State's Exhibit #5 was marked for the record.]

Q. Let me show you Exhibit #5 which is a letter dated June 4, 1981 to Niles Eldredge from you and I believe there is another letter attached as part of that exhibit which

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is from Niles Eldredge to you.

A. Uh-huh.

Q. Do you recall those letters?

A. Yes. I wrote them if that's what you're asking.

Q. What are the geophysical issues as you use that term in here as they relate to science and creationism?

A. Well, creationism has two geological propositions. One is that the earth is approximately 10,000 years old or less and the second is that all the sedimentary rocks in the geologic column were deposited during the great flood which lasted about a year and occurred sometime between 4,500 and 7,000 years ago. Those are the two propositions against which there is a preponderance of geophysical evidence.

Q. I'd like for you to look at Act 590 and tell me where the first of those propositions that the earth is approximately 10,000 years old is found in Act 590 if it is.

A. Well, it's not. But Section 4.(a)6 says, "relatively recent inception of the earth and living kinds." And from reading rather extensively in the scientific creationism literature, all of those writings seem to indicate — or most of them seem to indicate that the earth is less than 10,000 years old. There are numerous statements to that effect.

Q. However, as you personally understand the term

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"relatively recent" given the age which you believe the earth is of some like 4.6 billion years old, "relatively recent" could mean a lot older than 10,000 years old couldn't it?

A. It could but I don't think you would get any scientific creationists to accept that definition. If they would, I've not seen it written down by them.

Q. Is there scientific evidence that the earth is, while older, than 10,000, is younger than 4.6 to 4.8 billion years old?

A. None that I know of.

Q. In Niles Eldredge's letter to you he states, "Your manuscript told me something, with crystal clarity, that (though I knew) I had been sweeping under the table: I have been fond of saying that creation science isn't science — but this is not strictly accurate." And he goes on to talk about that creation-science is science, but it is what he says is "bad" science. Is that your opinion?

A. Well, my opinion is that it's not science because it's religiously based. I think what he was talking about was the kind of treatment I did in here (indicating). In the introduction I said that there were two geological corollaries of what they call their creation model. And we can examine those as if they were hypotheses and see

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whether they are absurd or whether they are reasonable.

Q. Uh-huh.

A. So often times you can treat things scientifically without them necessarily being science. Now if you look at these as religiously based, it's not science. If you divorce it from the religion, then it only becomes absurd. This is what I think he probably means by "bad" science. If you really want to know what he means in that letter you'd have to ask him.

Q. Well, earlier I think in discussing your draft resolution we talked about what was science and what was a scientific theory. And your resolution made statements about that a theory must be testable, capable of validation, that sort of thing. Now if you look at, for example, the statement that there has been a relatively recent inception of the earth and living kinds. Let's just take the portion dealing with the earth since that's really your area of expertise as I understand it.

A. Yes.

Q. What you are, in effect, I think saying here in this manuscript is that aspect of creation-science is subject to being tested and you have tested it and think it's false.

A. It's been tested. We've known for over 25 years that the earth was 4® billion years old and the solar system. And at this point, to say that it's very young regardless

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of whether you draw that line at 10,000 years or 1,000,000 years or even 10,000,000 years, it is an absurd hypothesis. It is in the class of the flat earth.

You see, when things become absurd they cease to be science. We simply can't afford to waste our time reproving things that are already proven.

Q. Now you've added another qualification I think to what is a scientific theory. That is that it must not be absurd.

A. Well, I think I said before that a theory had a preponderance of evidence to support, even though it was still undergoing tests and may undergo modification. I think what I said earlier was that a hypothesis may not be absurd. I think the same thing holds true of a theory. A theory may not be absurd.

Q. And it goes without saying that if it is absurd, it's not a scientific theory or hypothesis in your mind; correct?

A. I think that's a fair statement, yes.

Q. Who is to determine the absurdity of a theory?

A. Well, that's generally done by a collection of scientists, by consensus. There is no formal procedure for doing that.

Q. So that if someone says — a consensus or majority of scientists say a theory is absurd, then at that point the scientific community can dismiss it and not consider

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it further as a viable scientific theory?

A. That's basically correct, you see, but that's not just based on an opinion. People would come to the conclusion that it's absurd because they know of an overwhelming amount of evidence against it. That's what makes it absurd. It's not really a matter of opinion. It's a matter of evaluating the evidence.

Q. And you state in your letter to Eldredge that "Hypotheses that are clearly false, like above or a 10,000 year-old earth, are not scientific hypotheses — they're silly and the produce of emotionally and intellectually retarded minds." Is that an accurate representation of your beliefs and your feelings?

A. I wrote that, yes.

Q. So that anyone who believes in an age of the earth which is 10,000 years old is retarded?

MR. WOLFE: I will object to the characterization that counsel has just used. The letter was read into the record. The witness was asked whether he had, in fact, written it. He did say that he had, in fact, written it and I believe that it speaks for itself.

MR. WILLIAMS: The characterization is the witnesses, not counsel's.

MR. WOLFE: No, no. The

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characterization is clearly that of Mr. Williams. The letter is clearly that of Dr. Dalrymple. And I think the record now is perfectly clear as to that distinction. I suggest that you made an effort to blur that distinction, which I prefer you not to do.

Q. Well, let me make sure that the record is perfectly clear. It is your belief that anyone who thinks that the earth is approximately 10,000 years old has an emotionally and intellectually retarded mind?

A. Well, I wrote that and those terms are used very loosely. This was a personal conversation between two people. If I may rephrase it a little bit, I think that people who attempt to put that proposition over as science rather than a personal belief or a personal religious belief can't be very bright because there is a tremendous amount of scientific evidence. Thousands and thousands and thousands of data which tell us that is not true. It's absurd. And they simply can't understand that. Therefore, there is something wrong with their process of thinking scientifically. I'm only restricting that to scientific reasoning. I have no qualms about what people choose to believe as religion or philosophy or anything else. As a scientific proposition, it's absurd.

Q. Do you agree or disagree with this statement? This is from Eldredge. "So, when the ACLU says that the

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Arkansas law injects religion into the school curriculum, they're right, but they must avoid asserting that creation- science is pure religion. It's science — bad, bad science."

A. Well, I think there are two ways to look at that. It's hard to say whether I agree exactly with that or not. But scientific creationism is clearly religiously based, and in that sense, it's an introduction of religion into science teaching. On the other hand, if you want to try and divorce that and look at it as science, it is rotten, rotten, science. So there are really sort of two ways to look at it. I don't think we want to teach rotten science.

Q. He goes on to state, "But, unfortunately, it is not unconstitutional to teach bad science." Without asking for a legal judgement, do you agree with that?

MR. WOLFE: I would object to the form of the question. I would like to have some greater specification of whether there is any content to that question that does not call for a legal judgement.

MR. WILLIAMS: Okay. I think that's fair. I think that's probably inherently legal. WITNESS: I was going to say that the Supreme Court has enough trouble with that. I don't know why you're asking a poor geologist.

BY MR. WILLIAMS:

Q. This manuscript which we've previously discussed,

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for purposes of this deposition, why don't I have this marked as Exhibit #6. I don't want to make it an exhibit to the deposition, but just marked for identification. [Thereupon State's Exhibit #6 was marked for identification.]

Q. As I understand it, is Exhibit #6 going to be part of a book or is it going to be published as a book itself?

A. The present intentions are that it will be a chapter of a book.

Q. Who, if you know, are going to be the authors of the other chapters?

A. I'll try to remember who they are. Bill Mayer, Norman Horowitz of Cal Tech, Richard Dickerson of Cal Tech and I believe Tom Jukes of Berkeley, plus myself. There may be others that I've forgotten. There is one more. Everett Olson of UCLA.

Q. And is Mayer going to be the editor?

A. He has taken the responsibility of editing the volume, yes. The scientific editor.

Q. Do you know who he refers to in "our brave little band"?

A. I think he's referring to the people who were supposed to be the scientific witnesses in the Segraves trial for the State of California.

Q. I notice you have in here some correspondence which

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appears to be from Kelley Segraves. How did you come to have this correspondence?

A. That was sent to me by Tom Jukes if I recall correctly. Is there a letter attached to the front? I'm not sure but that came in a — I think that came from Tom Jukes. But I'm not sure.

Q. Do you plan to rely on this in your testimony?

A. No, it was put in there simply because it seemed to fit the description of the material that you asked for.

Q. Mark this please.

[Thereupon State's Exhibit #7 was marked for the record.]

Q. I show you what's been marked as State's Exhibit #7 to your deposition, which is a memorandum dated September 25, 1981 to the Assistant Chief Geologist, Western Region. from the Acting Assistant Director, Western Region.

A. Yes. Uh-huh.

Q. Do you recall receiving this document?

A. Yes.

Q. Was there a document which you sent to — is it Mr. Swinnerton —

A. Swinnerton.

Q. — in which he, in turn, gave you this one? I note Exhibit #7 says, "As requested, you are authorized to testify. . ."

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A. Yes. I wrote him a letter stating that I had been asked to testify by the ACLU, gave him the case number and so forth; and I could not find that letter. But it was a simple standard form request for permission to testify.

Q. Could you tell me what you understand to mean by this, the following language in his memo to you? "You are not authorized to testify on behalf of either party. However, you are authorized to present factual data and furnish records in regards to radiometric dating."

A. What he means by that?

Q. What you understand that to mean, particularly that first sentence.

A. That's basically I'm authorized to appear as an expert witness I think is what that means.

Q. But you can't testify on behalf of either party. What does that mean?

A. I don't really know what that means. I think that means is if you had asked me to come and testify, I would have been just as willing to come and testify at your request as at the ACLU's.

Q. It also says that you are authorized to present factual data and furnish record. Is it your understanding that you are not authorized to give opinions?

A. I think opinions that are within the realm of my

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experience as a scientist are quite appropriate. And what I answer depends on what questions you ask me, so. I should mention that that letter is more or less a standard form reply for request to give testimony in any legal proceedings.

Q. To your knowledge, have you ever reviewed — or have you in the past reviewed articles for publications in refereed journals?

A. Oh, yes. Frequently.

Q. Have you ever reviewed any on the subject of creation-science?

A. No.

Q. Have you ever reviewed any which, to your knowledge, would support the theory of creation-science?

A. No.

Q. What if you were to see one and would be asked to review it by one of the journals which you would review for and — while the scientific data looked competent and good, it did support creation-science.

A. Well, I would apply the same criteria to such a scientific article as I do to all scientific articles. Exactly what my recommendation to the author and the journal would be would depend on the details of the paper. Since that's a hypothetical question, I really can't tell you what my response would be.

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Q. Would you mark this, please, as Exhibit #8?

[Thereupon State's Exhibit #8 was marked for the record.]

Q. Was there a session on creation-science at the fall AGU meeting in San Francisco?

A. Well, the fall meeting will be next week and the answer is no, there will not be.

Q. Why is there not going to be a session — well, first of all. You did write some letters didn't you proposing that there, perhaps, be a session?

A. That was an initial — an initial attempt to see if there was enough interest to have one and I'm not sure yet whether there will be one in future meetings or not. I haven't decided.

Q. Wouldn't it be fair to say, from looking at these documents, that you have been trying to spearhead something within the AGU on the subject of creation-science?

A. That's correct.

Q. You have proposed a resolution. You have also proposed a seminar or some sort of a session on the subject; correct?

A. That's correct.

Q. And to date, at least, your efforts within AGU have not met with success.

A. Well, that's not correct.

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Q. Well, you've already said there's not going to be a session next week on the subject in the meeting. Is there going to be a resolution introduced?

A. I don't know whether it will be or not. I've not seen the agenda for the council meeting. My understanding is that the topic of whether or not the AGU should consider becoming involved in that will come up at the council meeting. But I'm not sure that's on the agenda. The reason there will be no seminar is because I'm the program chairman, and I decided I didn't have time to do it this fall.

Q. According to Exhibit #8, there is something in here entitled "Science and Creationism, Possible Subjects and Speakers." Was that your tentative outline for a proposal

A. That was just a rough —

Q. — for a program?

A. — list of ideas. It's not even what I would call an outline.

Well, you do have some — let's go off the record.

[Lunch break.]

DIRECT EXAMINATION CONTINUED

BY MR. WILLIAMS:

Q. Now before the break we took we were discussing Exhibit #8, which is a series of correspondence. There are several letters in there. Why don't you just generally

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identify what it is.

A. Uh-huh.

Q. Would you describe what it is?

A. That's a series of letters discussing the possibility or the desirability for a symposium or a special session on creationism at some future AGU meeting.

Q. And as part of this there is a proposed schedule or rough draft I think you said on a seminar or session on science and creationism.

A. Well, I think that's a list of possible ideas. I didn't intend it to be an outline.

Q. And there are certain ideas or topics and I notice that there are people referenced in parentheses. For example, "Introduction (Sagan, Dalrymple)" Is that correct?

A. Yes.

Q. These are the people who you were thinking about perhaps....

A. They're possibilities of people that might handle that aspect of the program.

Q. And you are chairman of the program committee?

A. I am program chairman for the VGP section.

Q. All right. And of the names you have on here of people you were thinking about being involved, are any of these people creationists?

A. Let me look at the list. No.

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Q. Is there any particular reason why you, in this tentative list at least, were not going to involve any people who consider themselves to be creation scientists to attend and present their views?

A. Well, my thinking was that this was not a debate on the subject. It was a program to inform people about what the issues — what the issues were.

Q. Really, my question was not whether you were going to have a debate, but it goes to the fact that you were going to try to present kind of what cre — what creation science is and how it might be viewed by the scientific community or at least these people. Why would you not want to have people of the creation-science community if there is such?

A. Well, they would be free to attend if they wished to.

Q. Well, why would you not want to ask them to attend and present some of their views?

A. Well, the way a symposium like this is organized — and this is one of about — this was a possible one of half a dozen or so that I organize for each AGU meeting. Those are held twice a year. The typical format is to have some people who are invited and other people who can apply and I was unsure in my own mind whether or not it would be appropriate to ask creationists to come at all.

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I think when you do that, you're immediately in to a debate. That was not the intention. The intention was to inform the AGU membership.

Q. In another letter to Carl Sagan you state that, "Incidentally, I just discovered (to my horror) that Henry Morris of CRI in San Diego is a member of AGU!"

A. Yes.

Q. Why do you make that comment?

A. I was very surprised that Henry Morris, who is the director of CRI in San Diego, would pay dues to a society, a scientific society that has presented a considerable preponderance of evidence to disprove what the man believes. And yet, he supports this organization through his dues. That, to me,- is surprising.

Q. Why is that "to your horror" though?

A. Well, that's a very loose — again, you're reading a conversation. Surprise might have been a better word to use.

Q. Do you think he could be booted out of the AGU?

A. No. Henry Morris is, by training, a hydrologist as I understand it. There is a section in hydrology. Also, anyone who expresses a sincere interest in science and has at least a Bachelor's degree in science is free and in fact, invited to join the AGU. It's a very open society. No one is precluded and I would be the last one

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to exclude Henry Morris or anyone else.

Q. Could you explain to me what you consider the term "uniformitarianism" to mean?

A. As presently used or in its historical context because the definition has changed considerably over the last 100 years.

Q. All right. Why don't we get both. Let's start with the historical context.

A. Well, this is just the time he took the two notebooks so I couldn't make some quotes.

Q. Oh.

A. Let me try to go from memory. When it was first formulated by Hutton and Lyell it had a variety of meanings. One was that supernaturalistic causes were not permissible explanations in science. One was that the present is the key to the past and that phrase has been interpreted in different ways. Another was that the rates of geologic processes were constant and another was that the physical laws of the universe were constant through time. Those four definitions have been used by different people in different times.

The current way the uniformitarianism is used by geologists has eliminated a good many of those and it boils down to only two propositions. One is that the physical laws are constant through time. And the second,

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which is really a corollary of the first is that supernatural explanations are not acceptable in science to explain physical phenomena or observations.

Q. Could you define for me "catastrophism" as you understand it.

A. Again, catastrophism is a word that sprang up during early days of uniformitarianism when there were two sort of schools of thought. One was that the rates of geologic processes were constant and the other was that the rates were not constant. That things happen in a series of catastrophes or steps. So that's the historical context as taken from the 1800s.

Today the word catastrophism is not really used very much except that I think we realize that geological processes are not constant and they happen in a series of both constant and catastrophic processes. As an example of that, in the oceans the sediments are raining down and being deposited at a rather constant rate over sometimes periods of millions of years. On the other hand, an earthquake is clearly a catastrophic event and so would a flood be. So we recognize that the rates of processes are not constant at all. That's been recognized for many many years.

Q. You said it has been recognized for many years that the rates —

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A. The rates of most geological processes are not the same, are not constant through time. And by that I mean things like sedimentation, erosion, uplift, motion of continents over hundreds of millions of years and so forth. I do not mean the rates of certain kinds of physical processes are not constant. I'd like to make that distinction.

Q. Is there a trend now in geology to discussing catastrophism more than there has been in the past?

A. Well, not since I was a student back in the '50s. Catastrophism in the sense that certain things geologically happen very rapidly has been — was — was a clear concept when I was a student in undergraduate school.

Q. Was a what? Clear —

A. Clear concept, sure. And we observed this by, say, observing floods and earthquakes. Those are clearly catastrophic. In other places like the long slow uplift and ocean basin sedimentation, we realize that at some times for certain periods of time processes of time can become constant.

This will be Exhibit #9.

[Thereupon State's Exhibit #9 was marked for the record.]

Q. I'd like to show you what's been marked as Exhibit #9 to your deposition and ask if you can identify that?

A. Yes. This is a report of a meeting held at LSU at

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Baton Rouge accompanied by some correspondence several months later concerning that meeting. And the report of the meeting and all this occurred in EOS, which is the transactions of the American Geophysical Union. Those are copies.

Q. Is that a referee journal? EOS?

A. No. EOS is really a type of newsletter.

Q. As you understand it, what was this symposium held at LSU?

A. I don't know much about the symposium other than what's contained in that article. I had no involvement in the symposium and I only read about it in EOS sometime ago. The purposes I recall had something to do with engineering and the effect of measuring geologic time on engineering problems. Other than that, I really don't know much about it

Q. Why did you come to have this as a copy of these articles? Why did you keep it?

A. Bruce Ennis and Steve Wolfe and I were discussing Gentry's pleochroic halos and whether or not his evidence for polonium halos was conclusive. And I remembered that Paul Damon had written a letter to EOS surrounding this — excuse me. With regard to that meeting and had voiced some criticism of Gentry's idea. I told him I would see if I could find that article and copy it for them, which

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I did.

Q. Have you reviewed some of the articles that Gentry has written?

A. I've never reviewed any of his articles. As a referee for a journal?

Q. Well, yeah. First of all let me ask you that.

A. No, I've not.

Q. Have you read them?

A. I have read a few.

Q. Do you have an opinion as to the articles that you have read?

A. Um, Gentry's work that appears in the scientific literature seems to be based on very careful measurements and I think it's fairly highly regarded.

Q. Do you consider the work to be scientific? The work which you have seen which has been published in any scientific journals?

A. The work that I have seen which has been published in the scientific journals is scientific, yes.

Q. Do you have an opinion more specifically as to whether you agree or disagree with some of the data that are some of his conclusions.

A. You would have to tell me which conclusions specifically you're speaking of.

Q. Are you familiar with some of his studies of

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coalified wood from uranium bearing sands in the Colorado Plateau?

A. No, I'm not familiar with that at all.

Q. What articles do you recall reading?

A. The only one I read recently was the review article in the "Annual Reviews of Nuclear Science" on pleochroic halos. I should mention that this is a subject that I do not follow very close.

Q. Pleochroic halos you do not follow very closely?

A. That's correct. They are not of much interest to me.

MR. WOLFE: Off the record.

[Off the record discussion]

BY MR. WILLIAMS:

Q. Are you or have you reviewed the letter written by Paul Damon?

A. I read it over, yes.

Q. Do you agree with what he says in there about Gentry's work?

A. I'm inclined to agree with his conclusion that Gentry's assertion that those particular halos were formed by polonium may not be correct. Damon presents a rather convincing argument that that leads to a conclusion that is probably absurd. But again, I'm reading this as someone who is not really an expert at pleochroic halos and I'm trying to decide between two people who are

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debating it between themselves. I'm not involved in that debate.

Q. Would you regard Gentry as an expert on radioactive halos?

A. I think he's considered an expert on radioactive halos; yes.

Q. Do you know Ralph Kazmann — Raphael Kazmann?

A. No, I do not know him.

Q. Have you reviewed his letter in this exhibit?

A. I read through it briefly, yes.

Q. In his letter he says that "The point made by the participants in the symposium is that there are great uncertainties in the time scales used by solar astronomers, cosmologists and geologists. No single one of these uncertainties would be sufficient to affect engineering evaluation. However, all of them taken together, which indicate that we have overestimated the period of time that is required for geologic and cosmologic processes serve as a caution signal." That last sentence, the overestimation of the period of time required for geologic or cosmologic processes. Do you have an opinion on that?

A. I don't know what time he's talking about. If he is saying there, as I think he is, that our esti — our measurement of the age of the earth of between 4.5 and 4.6 billion years is an overestimate, then I would say

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categorically he is wrong.

Q. Do you consider Gentry to be a creation scientist?

A. Based on a couple of statements he made in that letter I would say yes.

Q. Would you mark this as Exhibit #10?

[Thereupon State's Exhibit #10 was marked for the record.]

Q. I show you a document which has been marked as Exhibit #10 to your deposition which you have provided me this morning entitled "Radioactive Halos" by Robert V. Gentry. You'll have to tell me what publication it's from.

A. It's from the "Annual Review of Nuclear Science", volume 23, page 347-362 dated 1973.

Q. That's the article you have previously read?

A. Yes. I've read through that within the last six months.

Q. If — well, first of all. Again, let me make sure I understand. Is this the article you referred to where you felt like his measurements were good and you would say that it was —

A. This is a review article of the state of — as of — well, probably really '71 or '72 considering publication time. This is a review article of the state of research on pleochroic halos.

Q. This is a review article rather than a — it does

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not contain any original research as such?

A. I don't know how much of it's original. But most of it's essentially a review of the state of that particular aspect of the science. This annual review series publishes such things. It's essentially to allow scientists who want to get up to speed on something or determine what the state of a particular field is to do that.

Q. What would be the implications for the dating or — excuse me. The age of the earth, if any, according to the findings in this article.

A. As far as I know there are none with one statement and let me see if I can find that for you. That's based on Gentry's own conclusion. He says, and I quote, "On the other hand, Gentry reference 24 has shown that even exact agreement between halo radii and corresponding CB sizes does not necessarily imply an invariant lambda," Lambda is the decay constant. "and in fact, uncertainties on radius measurements alone preclude establishing the stability of Lambda for 238U to more than 35%." And what I think he's concluding there is that the measurement of radioactive halos don't tell you whether or not decay rates have been constant, And therefore, in terms of radiometric dating, I think the research on pleochroic halos is probably irrelevant.

Q. Are you familiar with any articles he has written

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since 1973 on the subject of radioactive halos?

A. No. Not that I can recall.

Q. Do you know if he's written any?

A. Oh, I just don't know. He may well have. He's a fairly active researcher. I suspect that maybe he has. That's almost ten years ago that this article was written.

Q. Have you reviewed any of his work or any of his writings in preparation for this trial?

A. Just that.

Q. Other than this?

A. No. That plus I read his letter in response to Damon.

Q. Do you have an opinion as to whether the theory of evolution is a valid scientific theory?

MR. WOLFE: I'll object to the form of the question unless you ask whether or specify whether you're asking his opinion as to the validity of the content or whether it is a scientific theory as opposed to non-scientific.

MR. WILLIAMS: As to the validity of the theory as a scientific theory?

MR. WOLFE: Yeah. I think the question was ambiguous as to whether you were saying assume that the theory of evolution is a scientific theory. Is it correct or incorrect?

MR. WILLIAMS: No.

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MR. WOLFE: Or whether the question is is it a scientific theory or not.

Q. The question is is it a scientific theory or not?

A. My understanding of it is that it is.

Q. Do you know how it is testable?

A. Well, you're getting into a biological experiment and, out of my field of expertise. I'm afraid I'm not competent to design experiments in biology.

Q. Do you know if the theory of evolution is falsifiable?

A. I'd have to give you the same answer. That depends on the experimental design and I'm not competent to do that.

Q. Do you think that the earth's geology is explained by uniformitarianism?

A. Well, uniformitarianism doesn't say anything about the earth's geology. It only says that science proceeds on the basis that natural laws have not changed with time.

Q. Proceeds on the basis?

A. Well, uniformitarianism is a tool.

Q. Proceeds on the basis? Is that an assumption?

A. I think it's a necessary assumption of science. That is if we presume otherwise, then we are allowed to change natural laws any time we wished. And therefore we can have no logical development of science. I think it's a necessary condition of science that we presume that there is a set of laws that governs what we see, and that we can

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rationally figure out what those laws are.

Q. You say it is a necessary tool that you — well, on what do you base the assumption? What proof is there for the assumption?

A. Well, you're asking me things like what proof is there that the speed of light is constant, has been constant since the beginning of the universe. And my answer to that, I guess, is that I don't know except again I'll say it's a necessary condition of science. If science is to make any headway at all, we have to assume that we're dealing with rational physical laws that don't change in an irrational manner. That's simply one of the boundary conditions.

Q. Well, if the laws have changed, are you saying there could not be science?

A. I think if — if the fundamental physical laws of the universe have changed randomly or capriciously with time, then there is no physical basis for science at all. And I think the reason that we believe they have not changed is because there is fairly good evidence to think that most of them have been constant and there is absolutely no evidence to lead us to suspect that the physical laws have changed.

Q. What is the evidence that they have been constant that you're aware of?

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A. Well, I think most of it is — a good part of it is theoretical. Part of it, when you're talking about things like radioactive decay, is experimental. So there again, it depends on what physical laws you're talking about. When I say physical laws, I'm thinking of laws of radioactive decay and gravity, speed of light and things like that.

Q. Is it an assumption that radiometric dating methods, that the radioactive decay has been constant through time?

A. That's one of the premises upon which it works and there is evidence for that premise.

Q. What evidence is there for that premise?

A. Well, the first kind of evidence is theoretical. The evidence is that radioactive decay, the type of radioactive decay that is used in radiometric dating arises from the nucleus. And the nucleus is extremely well insulated from its surroundings to such extent that scientists have not been able to change decay rates in the laboratory except by minute, minute percentages even with extremes of temperature and pressure and so forth. So there is — the experimental evidence that we cannot now change decay rates significantly enough to affect any radiometric dating technique. As I say, there are theoretical reasons to believe that those laws should not change. And if you go back in time, there is sufficient

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concordance between dating methods that use different decay rates and different decay constants; and if rates had changed, you would not be able to get that kind of concordance.

Q. Now maybe you just told me, but I'm not sure. What are the theoretical reasons why you feel that there has been a constant rate of decay?

A. Well, as I just said, the radioactive decay arises. from within the nucleus of the atom.

Q. I thought that was the experimental reasons?

A. Well, theory tells us that it should be extremely difficult to influence radioactive decay rates by more than a tiny, tiny fraction because of the insulation of the nucleus from it's external surroundings and because of the very strong nuclear binding in the nucleus. Experimental evidence tells us that that theory is correct. That scientists who have attempted to change decay rates find that they can only do it by very, very small fractions of a percent.

Q. If I understand what you're saying, Dr. Dalrymple, it is that it is possible that the rate of decay has been constant because of these things that you've mentioned?

A. It's very probable —

Q. Probable?

A. — that it's been constant. I would say it's

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probably certain that it's been constant.

Q. All right. Is there proof, has it been proven that there has been a uniform rate of radioactive decay over time?

A. I think to the extent that different-decay schemes give us the same age for things like lunar rocks and meteorites when we apply those different types of radiometric dating tools that have different decays from different elements with different decay constants, sometimes different by an order of magnitude or more, we get the same answer on bodies that have simple history. And that kind of coincidence would not be true if those rates had changed with time because we have clocks ticking at different rates.

For example, the halflife of Rubidium-87 is about 48.8 billion years. And the halflife of Neodymium-147 is about 100 billion years. Those clocks are ticking at different rates and yet, they give us the same time. They give us the same answer. And if those rates had changed, we would not get the same answer. That's the nature of the proof.

Q. Can you envision a scenario where the rates would have — if they have changed, you could still come up with those coincidences that you mentioned?

A. No.

Transcript continued on next page

Deposition of Dr. G. Brent Dalrymple - Page 3

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Q. Is there also something called the — is there an assumption that the rate of decay has been constant throughout the geologic column?

A. No. The geologic column is essentially the system of rock units that represent geologic history on the earth. So it's remained constant through the geologic column, you're really saying it's remained constant with time. I think, if I understand you correctly, those are essentially equivalent statements.

Q. Would the Big Bang be a uniformitarian event?

A. Well, again that's a question in astrophysics. But if I understand what the Big Bang was, it was probably initially a catastrophic event.

Q. So it would not be an event of uniform laws that are in effect today?

A. No, that's not what I said.. Uniformitarian.— you can have catastrophism and uniformitarianism at exactly the same time. They do not preclude each other at all. So that it's possible that the Big Bang was caused by the same physical laws that operate today in the universe. In fact, I think the theoretical physicists who work on the Big Bang use that presumption.

Q. To your knowledge, has anyone been able to synthesize, in a laboratory, granite?

A. I don't know that anyone's ever crystallized granite

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in a laboratory.

Q. Would it be significant if they could?

A. It would be significant in the sense that it would allow experimental petrologists to perform new experiments on how rocks crystallize that they cannot now perform because of that limitation. But the reason they cannot synthesize granite in the laboratory is because of the kinetic problem. It's one of getting crystals to nucleate and start to grow. It's really an experimental problem. It may be that someday they'll find a way to do that. But the difficulty is in experimental technique.

Q. Well, if you could get a synthesis of granite in the labs, what would that tell you about the rate of decay, if anything?

A. Nothing.

Q. Nothing? Did you understand radioactive halos to be — since you read that one article, what significance do they have if you studied them? What can we determine from studying of radioactive halos of some of these granites or rocks or whatever?

A. Well, I'm not — you know, relevant to what? I suppose they learn how far an alpha particle will travel through mica and things like that. In terms of learning things about the age and history of the universe, I'm not sure there is much to be learned from those if I

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understand Gentry's conclusion correctly. That is insofar as it applies to decay rates.

Q. Uh-huh.

A. His statement was that the uncertainties in the measurements are simply too large. You can't tell whether they've changed or not.

Q. On page three of Exhibit #6, at the bottom of the page you point out that a small number of wrong ages are nearly all due to unrecognized geological factors, to unintentional misapplication of the techniques or to technical difficulties. Could you give me an example of the first where a wrong age has occurred due to unrecognized geological factors?

MR. WOLFE: I would like the record to show that the actual quote includes quotational marks around the word "wrong".

A. You want an example of something that's due to unrecognized geological factors?

Q. Right.

A. Okay. Often times when we want to date a rock by potassium/argon, for example, we look at the rock and see if we can see any evidence that the rock has been reheated. And we do that by certain petrographic criteria and geologic criteria. However, the state of that knowledge is imperfect and sometimes we will select a sample that

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we think has been a simple system that has not been reheated. And in fact, after performing a number of consistency tests, we may find out that all of the evidence indicates that that one rock may have, in fact, been reheated or in some way disturbed. That it has not been an unaltered system. So that would be a — that's an abstract example.

Q. How often does some unrecognized geological factor arise which renders a conclusion about the age of something wrong?

A. — Well, it's not — it's not very often because usually radiometric dating, the way it's done now, is done on large numbers of samples in a controlled experiment with internal checks and geological checks on the results so that we can look for consistency and spot errors. This is done in several ways. The simplest way is to do the measurements two or three times to make sure that there is no error there. We can compare whether rocks are amenable to it. We can compare ages from different decay schemes. We can do ages on rocks that are stacked in sequence so that they know what their proper order should be and so forth.

So I think it's extremely rare that a single age measurement will give us misleading information because usually they are not done singly. They are done in large

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groups with an experimental design in mind so that the results can be internally checked.

Q. Could you give me the example of where an unintentional misapplication of the techniques have resulted in an erroneous age for a rock or some other part of the earth?

A. Oh, that's a case where scientists will simply make a mistake.

Q. Have you ever made any of those?

A. Oh, sure. It's — this is why we try to build as many checks and balances into our experiments as possible. But if we go out to do a study on a volcano, for example, and collect 106 samples, I suppose there's a small percentage that sometime during the sample processing we may get some samples mixed up. And we may apply, for example, a potassium/argon method to a sample that we never intended to apply it to simply because there was a mix-up in sample numbers or something like that. This happens rarely, but it's still a problem. With any complicated technique people are going to make mistakes.

Q. And the third thing there mentioned is — are the technical difficulties.

A. Well, in isotopic age measurements we need to add a tracer of an amount of an isotopic substance of known composition and amount in order to make the measurements. That's simply a consequence of the techniques. If there

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is some technical difficulty with the way that isotopic tracer is metered out, for example, then we would not get the right answer. For example, if we thought we had twice as much of that tracer as we actually did in the experiment, then we would get a result that was incorrect. But there again, this is the reason for building redundancy, considerable redundancy in the experiments is to try to pick those things out.

Q. Why is radioactive decay a statistical process? Would you explain that?

A. Well, it's because if you take a single atom, you can't tell when it's going to decay. You can't tell when that particular atom is going to decay. What you can do is specify a probability that that particular atom will decay per unit time, per second and so forth. Therefore, if you have a large — well, that's where the statistical part comes in. But the statistical uncertainties disappear when you have large numbers of atoms. And even in very small amounts of a substance, like tiny, tiny fractions of a grain, you have billions of atoms. And so the statistical uncertainties in the radioactive decay process disappears as far as practical measurements are concerned.

Q. Your statement on page 10 is that radioactive decay must be constant and predictable. You say that's one of the requirements of each of the radiometric systems —

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methods, excuse me.

A. If the methods are to work that must be true.

Q. In other words, this is one of the — may also be termed one of the assumptions?

A. No, I think I've already explained the reasons for being sure that radioactive decay is constant within any limits that will affect our dating techniques. And by predictable, I simply mean that we must be able to predict that where ever those elements occur, those elements will always decay at the same rate. That's really simply a corollary of uniformitarianism in the sense that physical laws are constant. We can't say that Rubidium-87 decays at one rate in this rock and at another rate in the other rock. That must be predictable. Once we've measured in one rock or 100 rocks, then it needs to be the same everywhere. And again, there are theoretical and experimental reasons for thinking that has to be true.

Q. So to your knowledge, that is true? That where ever an element is found, it's going to decay at the same rate?

A. Within the set of physical circumstances that rocks on the earth and meteorites and the moon experience, that's true; yes.

Q. Was there something — I just recall reading something about some dates which were once determined, as I understand

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it, around some volcanos which later were determined to be inaccurate. Does that ring a bell with you at all?

A. Are you thinking of Hawaii? Submarine basalts?

Q. Perhaps so. Do you recall something that occurred like that? What happened that would cause the error that you're aware of?

A. The thing that I'm thinking of was not an error.

Q. Oh, okay. Well, you explain what you're thinking about. Maybe that's the same thing and my memory is poor.

A. Well, what I'm thinking about is an example that is used in some of the creationist literature. That is the submarine basalts off of the east rift zone of Kilauea Volcano.

Q. Uh-huh.

A. And these lava flows occur underwater. They're known with a fair probability that they're very young, they're still erupting. And the estimates are that these lava flows that occur right along the top of the rift zone are at most within a few hundred — formed within the last few hundred years or so.

A number of years ago Dr. Jim Moore and myself did an experiment. There was another group that independently did the same experiment to determine whether or not these types of rocks could be dated by the potassium/argon method. And the reason we did that was these types of

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basalts, types of lava flows form large — form most of the ocean crust. And we wanted to know if it was going to be possible to date these type of rocks in order to date the ocean crust in different places in the ocean basin. So in order to determine whether we could use submarine basalts to make these measurements, we first had to do a controlled experiment to see if the potassium/ argon dating technique would work on those types of rocks. So we went to Kilauea where we had samples that were of reasonably known age. That is zero age as far as the potassium/argon method is concerned, and had been dredged from various depths along the east rift zone. We found that these particular type of rocks trapped excess argon so that the potassium/argon system did not behave in such a way that it could be used for dating. And as a result of those experiments, those types of rocks are not dated.

Most of these radioactive dating techniques can be applied only to certain kinds of rocks and certain kinds of geological situations. And what those rocks and situations are depends on the particular technique

Q. Is that an objective decision where you can look at the type of rock that you have and if you wanted to could reduce it to a list and say this type of rock has to use this type of method?

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A. Yes.

Q. How have you arrived at that determination that it's objective?

A. Those are usually done by a series of controlled experiments similar to the one I just described to you. If you want to date submarine basalts, first you test the method under known circumstances and see if the technique works on those kinds of rocks. In this case it didn't. And through the years this has been a gradual learning experience. We do not have adequate tests on all kinds of rocks yet. There are still large numbers of rocks that we don't know whether the techniques will work or not. But there are also large numbers that we're very confident that they work on.

Q. The second thing on page 10, the second requirement for radiometric dating methods to work is that the rate of decay must be known.

A. Uh-huh.

Q. What, do you mean by that statement?

A. That means simply that we have to be able to measure that rate of decay independently in the laboratory so that we know what the rate of decay is. And for all the major dating techniques and apparent isotopes, those decay rates are known to within a percent or better by direct laboratory experiments.

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Q. Are there any factors which would influence the rate of decay?

A. Not that we know of. Let me qualify that. There are certain types of decay which can be affected by a very, very tiny percentage like a tenth of a percent or less in the laboratory. Theory predicts that these things should be affected very, very slightly.

So when I say the rate of decay is invariant, I mean within any limits that would affect radiometric dating.

Q. Have you written articles yourself, besides this one, which talks about the age of the earth as being approximately 4.5 to 4.6 billion years old?

A. No.

Q. Is that an area of your specialty? The age of the earth?

A. Well, the age of the earth was — the presently accepted age of the earth was made — that measurement was made some 25 years ago by Clair Patterson.

Q. Has anyone since that time done any work to either further that study or to confirm it?

A. There was a recent review of Patterson's model for the age of the earth in Carnegie Institution Yearbook in I think 1980 by Tera. I think it's referenced in there. He did a fairly careful reevaluation based on all the latest data and he came up with 4.54 billion years.

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Patterson's age I think was 4.55 or 4.56. So in 25 years it's not changed at all.

Q. All of the articles which you have written deal with some form of radiometric dating do they not?

A. Not all of them. I wrote one on the weather once.

Q. Okay. Besides that?

A. Certainly most of them, yes.

Q. And all of them do have these three factors which you-have mentioned as three requirements as part of the radiometric dating method?

A. Well, those requirements are fundamental to any radiometric dating.

Q. What would be the effect if the rate of decay or radioactivity was, in fact, not constant?

A. Do you mean what would be the effect on the results that we have obtained?

Q. Right.

A. I think we would get chaotic and uninterpretable results. We would find that there would be no consistency in radiometric dating. We would find that the geologic time scale, instead of all the radiometric ages agreeing with the paleontologists' determination we would get random results. We would find that the age of the earth as measured by different ways would not agree. It would be chaotic. And in that sense, it's really self-checking.

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Q. What would be the effect on the presently accepted age of the earth of 4.5 to 4.6 billion years if the rate of decay is not constant?

A. It depends on how much you want it to change?

Q. Well, I don't necessarily want it to change any. I'm asking what effect it would have.

A. Well, the effect is the function of the decay constant. I mean if you want to change the decay constant by one percent, then, that will have a proportionate effect.

But if you want to get the age of the earth down to 10,000 years, then you have to change the decay constant by many, many orders of magnitude. Factors of thousands and thousands.

Q. What if the rate of the decay simply has not been constant?

A. Do you mean if it varies?

Q. If it had varied at some point, it just simply had not been constant throughout the history of this planet.

A. Well, there again, if it has been varying by plus or minus one percent around the mean for the last 4® billion years, then the basic effect would be nil. If it's varied by thousands of percent at random times, then the effect would be unpredictable.

Q. If there had been or if there were a worldwide flood

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several thousand years ago or more, would that have any effect on the dating methods?

A. No.

Q. How do you date fossils?

A. Well, fossils are datable because certain types of igneous rocks occur either below or above or intermixed with or they may crosscut sedimentary rocks that contain the fossils. There are virtually no dating techniques that work well on sediments with a couple of minor exceptions. But for radiometric dating purposes, sediments are kind of garbage piles. They're pieces of other rocks that have been thrown into the sea or lakes or rivers. So we have to get a rock that we can date in juxtaposition with a sedimentary bed that contains fossils. And we have to know what that relationship is.

In fact, these were the kinds of experiments that were done to check the geological time scale when radiometric dating techniques became available.

Q. I'm sorry. What was that last statement again?

A. I said these are the types of experiments that were done to check the geological time scale when radiometric dating techniques became available. It was one of the first problems that was attacked was the age of the geologic time scale and all of its parts.

Q. Can you date fossils by taking the fossil out and

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subjecting it to these tests or any other tests that you're aware of?

A. There are some kinds of techniques for dating very young fossils that work sometimes. These include amino acid racemization, which is not a radiometric dating technique, and some of uranium thorium disequilibrium techniques. But they only work on things over the last few hundred thousand years and they often work poorly. Scientists use them because there's nothing else to use. But there are very few circumstances in which a fossil can be dated directly because of the types of rocks in which they occur in and the types of the fossils.

Q. Since fossils are normally found in sediment, if there had been a world wide flood would that have affected where they would be found and then where these igneous would be and then the resulting age which you could determine? Would it affect the accuracy of that at all?

A. Well, I'm not quite sure I understand the question. But if the creationists were right and that all the sedimentary rocks were deposited by a great flood within a period of about a year, then the geologic column would be chaotic. And in fact, we should get the same age for all sedimentary rocks.

I thought you said you really can't date sedimentary rocks?

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A. We can date them when we find an igneous rock whose relationship to the sedimentary rock is known. There are lots of circumstances in which that happens. That's how the geologic time scales, the various geologic time scales have been dated. Those circumstances are still true. So what I'm saying is if the creationists were right, then all of the dates on the geologic time scale should be the same. And in fact, with our radiometric dating techniques, a very long half life should get zero because we can't — with things like potassium/argon or Rubidium/strontium you can't measure ages of a few thousand years. So we should effectively get zero for everything dated in the geologic column. We almost never get zero except on historic things.

Q. Well, you said — when you say we should get zero, is that based on the assumption that if there was a flood it occurred approximately 7,000 years ago?

A. Yes, that's based on the assumption that — I think I said if the creationists were right and such a flood occurred and, although I didn't say it as part of that, but that it had occurred very recently

Q. What if there was a flood long — a longer time period — longer ago than 7,000, would that still be true?

A. Well, if the flood was — took place 100 million years ago, then we should get an age of 100 million years

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for all of the rocks that are related to the geologic time scale. If it was 50 million years ago, then all of those rocks should give us 50 million years ago. And in fact they don't.

Q. Without telling me what was contained in your letters, could you describe the letters that you have written to the attorneys in this case?

A. Well, they were basically just letters of transmittal of requests for papers and information. I don't know how to describe them in general any more than that.

Q. What about notes that you have written? Anything else?

A. Well, what do you mean notes?

Q. Well, one of the categories of documents which your lawyer — not your lawyer, but Mr. Wolfe has mentioned was letters and notes from you to Bruce Ennis and to himself.

MR. WOLFE: Perhaps I can clarify this. The distinction between letter and note mean this. One of these documents was typed on stationery and I call that a letter. A couple of them were written by hand on memo size sheets of paper and I call those notes as opposed to letters.

A. It would be things like, "Here is the information requested by the Attorney General's office in Arkansas covering correspondence relating to evolution." Those

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are the sorts of things they were, I believe.

Q. Have you written and said to the attorneys for the Plaintiffs any sort of explanation of radiometric dating and the age of the earth, your area of expertise, other than this document, Exhibit #6?

A. This is the only one that involved radiometric dating. I can't think of any.

Q. The witness list which the Plaintiffs filed in this case states that you are going to testify concerning evidence relevant to the age of the earth, relevance of geology to evolution and creation-science, catastrophism and your reasons for opposing the teaching of creation- science. Do you know at this point what opinions you're going to be giving concerning the relevance of geology to evolution and creation science?

A. It will depend on the questions, and I don't know what those will be.

Q. Well, you have seen a set of proposed questions and answers based on that, do you know what opinions or answers you will be giving?

A. I was handed that list last night and I've not looked at it. So yes, I've seen it I've not read it. I stuck it in my suitcase.

MR. WOLFE: I would be happy to add that the list — I'm sorry. The description of the

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testimony, I don't know the date of it but it's a couple of months old now. And I would say that the present expectation is that Dr. Dalrymple's testimony will be more narrowly confined than is that description, specifically to geochronology and the age of the earth. At least I can represent that as my present state of knowledge and expectations.

MR. WILLIAMS: So to the extent of your present knowledge, Dr. Dalrymple will not be discussing generally the relevance of geology to evolution and creation-science, catastrophism or his reasons for opposing the teaching of creation-science?

MR. WOLFE: Well, there may well be some testimony about the — his reasons for opposing the teaching of creation-science. And we've discussed that here today. And to the extent that geochronology is the relevance of geology to catastrophism or to creation-science. That is, I don't expect that Dr. Dalrymple will give testimony about the fossil records, for instance, except as he has today. That is that he knows something about dating fossils. I think that the things we talked about today are an accurate picture of the things that we would expect that Dr. Dalrymple will talk about at the trial.

Q. Dr. Dalrymple, let me be sure that I understand.

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Could you define for me what the term "geochronology" means?

A. Oh, age measurements on rocks of the earth. And that's usually extended to include the moon and meteorites, objects within the solar system, objects that are accessible to us.

Q. What's your opinion of the publication by Slusher on the critique of radiometric dating?

A. Well, I don't think it's a very good critique of radiometric dating. It's not balanced and it's unscientific.

Q. Are you aware of scientists — let's for convenience sake take creation-scientists out of this question and place them over here and not consider them. Are you aware of scientists who you would consider to be a scientist who do not agree with your view of the accuracy of radiometric dating methods?

A. I don't know of any. I might disagree with some of my colleagues over whether the errors are 2% or 3%. I'm not talking about that kind of disagreement. I'm talking about the kind of disagreement that the creationists propose.

Q. I'm not talking about necessarily the agreement of whether the earth is 10,000 or 4.6 billion years. I'm talking about who question the validity and the accuracy of the radiometric dating method.

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A. I don't know of any scientists who do that now. All the earth scientists that I know or know of through their writings accept the general accuracy of radiometric dating. I don't mean that they don't look critical at each individual result. Everybody does. But as a general tool, its accuracy and its utility is accepted.

Q. What is your opinion of the article written by Akridge which you read on the Faraday-disc dynamo angeomagnetism?

A. Well, I think that paper involves a "straw man". That paper sets up a "straw man" which has no meaning.

Q. How so?

A. Well, first place, Akridge claims that the Faraday- disc dynamo has been advanced to explain the earth's magnetic field and that's not true. I don't know of any scientists dealing with the magnetic field that's ever said the Faraday-disc dynamo is a reasonable model for the earth's magnetic field.

Second, he claims that the Faraday-disc dynamo will not reverse polarity and that's not true either. There are mathematical models which demonstrate conclusively that the Faraday-disc model can, under certain conditions, reverse polarity. The reason I say it's a "straw man" is because nobody really seriously considers that dynamo model as a

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realistic model for the earth's magnetic field. The reason scientists work on Faraday-disc dynamos and similar disc dynamos is because dynamo theory is extraordinarily complex and you have to start with the simplest kinds of dynamos and understand the mathematics of those before you can go on to the more complicated ones.

Q. What is this Critique of the Principle Uniformity by M. King Hubbert?

A. That's a summary of the history and current thinking about the usage of the word "uniformity" and the principle of uniformity. It's a very scholarly review.

Q. What are the conclusions as you recall of the article if there are any?

A. Well, it's — I guess the conclusions are that the historical usage of uniformity has varied and some of the definitions are not now acceptable. Probably were not terribly reasonable when they were advanced and that uniformity now means only two things. One, that natural laws are variant with time and two that supernatural agents are not an acceptable explanation for any part of the physical world.

Q. Is this where you derived your definition of uniformitarianism?

A. Yes.

Q. In this article Hubbert says — speaks of the

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limitations imposed by the law of Thermodynamics. Are you aware of what he is talking of there as it relates to uniformity?

A. I'd have to see the context.

Q. I'm looking at close to the end of the article and just ran across that.

A. I'm not sure what he means by that. It may be that if I were to reread the entire article, that would — but just taking that one paragraph, I'm not sure what he means.

Q. He later says, "A major part of this emancipation" referring to an emancipation from the assumptions of special creation, by divine providence. Again, "a major part of this emancipation has been accomplished by the employment of the principle of uniformity. But this rests upon insecure grounds due, in large part, to its having been formulated in ignorance of the later developed laws of thermodynamics."

A. May I look at that?

Q. Certainly.

A. Which paragraph is that?

Q. Right there.

A. I think in that sentence he's talking about the principle uniformity in its historical connotation. Uniformity is really not a term we use very much anymore because it lost virtually all of its original meaning.

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That is that the rates are constant rates of geological processes were constant. Things like the second law of thermodynamics tells you that ultimately systems run down. I would guess that's what he's talking about there. See, what he's basically saying is that if you have to define uniformity today, you must define it simply in terms of constancy of physical laws and its corollary of not allowing supernatural explanation. And that is really a principle that doesn't need a name.

Also, I think there's been such confusion because of the historical context of uniformity that it would be better to do without the name entirely.

Q. Do you generally agree with this paper?

A. I think it's a very scholarly review, yes.

Q. Are you familiar with the laws of thermodynamics?

A. Yes.

Q. You are aware then, no doubt, that's one of the things some creation scientists have relied on in trying to say that creation-science is as reliable or more reliable than evolution, that the second law of thermodynamics dictates that there will be increasing entropy?

A. Yes, I'm aware of that argument.

Q. What is your response to that argument?

A. That argument is incorrect. It's a misinterpretation of the second law of thermodynamics.

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Q. Could you tell me why you feel that way?

A. Yes. The second law of thermodynamics says that heat will not, of itself, flow from a colder body to a hotter body. There's a mathematical expression of that, but that's the most concise best definition of that. A corollary of that is that in any isolated system, the entropy or degree of randomness of a system must increase. That is it must become more disordered. But the fact is that the earth, and biological systems are not isolated systems. That is you can reverse entropy as long as you're willing to put energy into the system. And if that were not true, we would not have automobiles and ice cubes. And the creationists claim that evolution violates the second law of thermodynamics is simply wrong because biological systems are open, they receive energy, they are not isolated.

Q. Well, the example you mentioned that we wouldn't have automobiles. That goes a step further, I think, of what some of the creation-scientists have said that there you have a mechanism to convert the energy into something else. In this case, taking gasoline and converting it into power. Is there a mechanism for converting the energy in the earth as a whole into order? To increasing order?

A. When you're talking about the earth as a whole you're

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talking about an extremely large system. And I think you need to define it a little more narrowly than that. There certainly must be a mechanism for creating energy into order in the human body, for example. That's why we eat. We start as a single cell and we grow because we're given energy in the form of food. So there are mechanisms to do that. There are also mechanisms to order rocks, for example. You can take a sedimentary rock which is a garbage pile of particles from all kinds of rocks, essentially a highly disordered rock, and by applying heat and pressure — in other words, energy — you can convert that into a highly organized rock like a lava flow or like a granite.

So as long as you're willing to put some energy into your subsystem, the entropy is allowed to increase.

Q. Well, is there or is there not a need for a mechanism to convert the energy into order?

A. Well, there has to be some procedure for doing that, yes. You have to get the energy into the system. Let's take a short break.

[Short break.]

BY MR. WILLIAMS:

Q. You have with you an article by Melvin Cook on the Creation Research — excuse me. Radiological Dating and Some Pertinent Applications of Historical Interest,

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Do Radiological Clocks Need Repair. Do you intend to rely upon this in your testimony?

A. I have no present plans to do that. There again, I don't know what the questions specifically are going to be.

Q. Well, do you have an opinion as to this article? Have you read it?

A. I read that article many months ago. I think I would put it in the same class as Slusher's article about which you asked me earlier.

Q. That being?

A. It's a rather unscholarly critique of certain aspects of radiometric dating. There are numerous errors and serious scientific mistakes in it.

Q. Mark this as Exhibit #11.

[Thereupon State's Exhibit #11 was marked for the record.]

I show you Exhibit #11 to your deposition which is an article entitled "A Response to Creationism Evolves" from the November 6, 1981 "Science" magazine.

A. Uh-huh.

Q. How did you come to have a copy of that?

A. One of my colleagues copied it out for me. He saw it in Science magazine and made a copy of it for me. That was in that package simply because I had thrown it in there

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of things to read.

Q. Have you read this?

A. I read through it, yes.

Q. Are you going to have any involvement in writing a handy-dandy creationism refuter?

A. I have no plans to do that and I've not been approached.

Q. The response which is discussed in here, have you been any part of this, either directly or indirectly, yourself?

A. I think there were two groups. That National Academy and the National Association of Biology Teachers. I have no affiliation with either group and I was not involved in the issues reported there. I read that strictly for interest.

Q. And you have an article in here from the "Annual Review of Nuclear Science" on Perturbation of Nuclear Decay Rates by Emory?

A. Yes.

Q. Why do you have a copy of this article?

A. That's another review article on the state of scientific knowledge as of 1972 concerning whether or not decay rates change. What the experimental evidence is and what the theoretical evidence is.

Q. What is the conclusion that this article reaches

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if you recall?

A. It concludes that alpha and beta rates, theoretically, should not be changed in experiments. They have never been changed in the laboratory. It concluded that the electron capture, theoretically, should be changeable by a minute percentage, and in fact, small changes up to a tenth of a percent have been found, but no larger. It concludes basically that the theory and experimental evidence are in good agreement.

Q. I have another file here that you've given me which is entitled "the Woodmorappe Paper" that contains several articles.

A. Yes.

Q. What — first of all, why are all of these in something entitled the Woodmorappe paper?

A. Well, I was given a copy of a paper from a Creation Research Society Quarterly by Mr. Wolfe and Mr. Ennis asked to look at that and give a scientific opinion.

It has a list of some 300 and some odd wrong ages I forget how they're titled, but that's the essence of it. I went through and picked out five of the examples with which I was already familiar and had the literature at hand because some of these examples involved either myself or my immediate colleagues. I evaluated his criticism of

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each of those five examples. The information you have here are the reprints of the papers to which Woodmorappe refers for his examples.

Q. And you have, in a paper, critiqued this article by Woodmorappe which you have given to the attorneys; is that correct?

A. It's the other way around. They gave a copy to me.

MR. WOLFE: I can make this clearer perhaps. A copy of Woodmorappe's article that was a Xerox from the Creation Research Society Quarterly and on which Bruce Ennis had made notes was given to Dr. Dalrymple and he was asked to comment on the article. The reprint which was given to him and which was in the folder I have withheld as covered by work product doctrine, specifically for the fact that Bruce Ennis's comments are on the thing. The response that Dr. Dalrymple gave to us was partially oral and partially in the letter that I referred to of Bruce Ennis The folder and the other things I did not withhold because I do not regard them as covered by doctrine

MR. WILLIAMS: With respect to those documents, I'd like to request if you could, if there are portions of those letters which you feel are not covered by the work product privilege, that you excise those portions which are and turn those over to us.

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MR. WOLFE: Well, that's fair enough. I'll try to do that. I will look at the letter — there's only one letter — and I'll look at the letter and I try to — there are certainly parts of it that I don't regard as covered by work product. And I will try to mask the parts that I do so regard and send a copy of it down to you.

MR. WILLIAMS: Let's go off the record.

[Off the record discussion]

MR. WOLFE: I'm giving Mr. Williams now a three page letter dated November 23, 1981 from Dr. Dalrymple to Bruce Ennis from the second page of which I have masked two paragraphs and portions of two others which I regard as covered by the work product doctrine. I'll also add that on the second page I left the first sentence of where I began the masking to show that's it's the discussion of the paper of Woodmorappe.

BY MR. WILLIAMS:

Q. What is you opinion of the paper by Woodmorappe?

A. Well, I can only base my opinion on those five instances that I looked into in some detail. I didn't have time to go through his entire list. He either misunderstands or misrepresents the cases that he claims are anomalies.

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Q. Okay. Could you describe that in more detail why you think he either misunderstands or misinterprets?

A. Well, I went back to the original documents that he cites and, in fact, some of the things he said simply aren't true. In other cases he's not bothered to explain the reason for doing the experiment and the fact that some of them were controlled experiments to test certain types of materials under controlled conditions, He just cited the ages as anomalies.

Q. Do you know if Woodmorappe is considered one of the leading authorities as you understand it on creation- science?

A. I had never heard of him before this article. The footnote says that he studied geology and biology. It doesn't say whether he has a degree in either subject.

Q. So there were five out of the three hundred that you looked at?

A. Yes.

Q. So there were 295 that you didn't look at and have no opinion on.

A. I have no opinion on them one way or the other. I have a reasonable sampling I think.

Q. Would you mark this as #12?

[Thereupon State's Exhibit #12 was marked for the record.]

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Q. In your letter you do mention that you have enclosed a very rough draft of a paper on Barnes' magnetic field hypothesis.

A. Yes.

Q. Is this reference to this article?

A. Yes.

Q. What is the purpose of this article?

A. It's an evaluation of Barnes' claim that the magnetic field indicates that the earth is less than 10,000 years old.

Q. What is your conclusion in the article?

A. My conclusion is that Barnes doesn't know what he's talking about. He has ignored most of what is known about the magnetic field and in fact, the magnetic field cannot be used to date the earth.

Q. You say the magnetic field cannot be used to date the earth? Can't the magnetic field be used at all in dating in your professional opinion?

A. The reversal time scale has been used in some instances to tell ages under particular circumstances. But it can't be used to tell the age of the earth or to place limits on the age of the earth.

Q. How has it — can you describe how it's been appropriately used in your opinion?

A. Well, for example, we know that the last major

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reversal of the earth's magnetic field took place 730,000 years ago. And if you're studying very young rocks, you find that they are normally polarized and that confines their age to those times in the geologic past when the magnetic field has been normal. And if they have reversed polarization that tells you that those rocks are almost certainly older than 730,000 and it confines their age to those periods in the earth's past when the earth's magnetic field has been reversed.

There is a second way and that is these reversals are recorded on the sea floors. It spreads outward from mid-ocean ridges. And the ages of these magnetic stripes have been determined so that you can tell the age of a certain part of the ocean's crust if you have adequate magnetic data to match that up to the time scales. It's a similar type of matching as is done in tree rings.

Q. Do you plan to rely upon this article in your testimony?

A. If I get asked questions about Barnes' age for the earth or about the techniques he uses, possibly. But I think I have in my head everything that's in the article.

Q. Do you plan to have it published somewhere? Has it been accepted for publication?

A. No, it's a ver — yes, I do intend to have it published, but it is a very rough draft and won't be ready for review for at least another month, even for

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internal review.

Q. Would it be scientific in your opinion if a scientist, using the scientific method of inquiry, determined that it would be impossible for spontaneous generation to have occurred of the first life I'm talking about?

MR. WOLFE: I will object to the form of the question unless spontaneous generation is more fully defined.

Q. Do you know what the term "spontaneous generation" means?

A. No. You'll have to tell me more exactly what you mean.

Q. Are you aware of some of the theories concerning the origin of the first life on this planet?

A. I think you probably mean hypotheses. I'm not aware of them in detail, no.

Q. Are you aware of them in general terms, general outlines?

A. I know that people have been doing experiments to see if they could put together organic molecules from inorganic substances using electrical discharges and so forth. That's basically the extent of my knowledge.

Q. Is that part of Stanley Miller's works?

A. I don't know. You're out of my field again.

Q. Okay. Do you think it's scientific to study the origin of first life or can be scientific?

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A. If you mean creating life from inorganic substances by normal physical and natural processes, yes that's a legitimate scientific area of inquiry. In fact, as I said before, there are experiments being done on that.

Q. Uh-huh. If someone, in looking at that question of life coming from inorganic substances, concluded that it could not have happened by purely natural laws, do you think that could be scientific?

A. I don't think such a conclusion is possible. I think they might conclude that a certain mechanism was not possible, but then that would leave the way open for people to pose additional natural mechanisms. I don't know that you can categorically rule out all natural causes for something. I think that would be quite impossible.

Q. I'd like to have this marked as the next exhibit.

[Thereupon State's Exhibit #13 was marked for the record.]

Q. I show you Exhibit #13 to your deposition which is a letter from you to Robert Tyler, Deputy Attorney General, State of California. Do you recall that letter?

A. Yes.

Q. Do you recall making a comment in there that there appears to be a strong thread of conspiracy throughout the evolutionist material — creationist material?

A. Yes.

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Q. What do you mean by that?

A. I mean that the creationist literature makes rather frequent statements that evolutionists have somehow conspired to make radiometric ages and the age of the earth agree with biologists' need for long periods of time. And in fact, that's just not so.

Q. If you look at the response, particularly of late, to creation-science with like the article that we have marked as Exhibit #11 and some of the things that you're doing, the fact that you've got resolutions from Bill Mayer and all these other organizations. Looking at that objectively from someone who's not within the scientific community, would you not agree that there would appear to be some evidence that there is a concertive effort among the various disciplines of science to thwart creation- science?

A. No, that's not quite right. The conspiracy that the creationists talk about or allude to is the conspiracy of scientists to fabricate data and to misinterpret data to fit a preconceived notion. That's what they claim and that's the part that's wrong. I think what you're seeing in articles like this report in "Science" is the fact that science is getting alarmed that there is a group who are trying to get their religious views taught as a science subject. And they are very alarmed about the future of

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science in this country, and of science education if that should happen.

Q. The idea then — well, first of all, that does seem to be some sort of concerted effort.

A. It's an effort to answer the claims of the creation scientists that science is wrong. And that, incidentally, is a legitimate function of science. These articles that I've written are a legitimate function of science. When somebody comes out with an idea or ideas that are wrong, it's the obligation of other scientists to explain why they're wrong. This is commonly done in the scientific literature. So I think what you're seeing is part of the natural scientific process.

Q. Are you familiar with the "Structure of Scientific Revolutions" by Kuhn?

A. I've heard of it, but I've not read that work.

Q. So in other words, as I understand what you're saying, you see in the creationist literature a thread that evolutionists have, somehow, massaged the data or misinterpreted it so it would fit their own preconceived notions. Is that correct?

MR. WOLFE; I will object to the form of the question as ambiguous unless it's made clear that the thread you're referring to is an assertion made by creationists on occasion within the literature rather

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than one made by Dr. Dalrymple.

MR. WILLIAMS: Yes. I think that's what I'm asking and I thought that was clear.

A. Yes.

Q. Okay. And in turn as I understand your testimony from some of the other articles we have reviewed today, you see in the creationist literature a misinterpretation of data or an effort to massage the data to fit their own preconceived ideas. Is that correct?

A. Yes. It's — most of their works are gross misinterpretations of the scientific data.

[Continuation of testimony on next page.]

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Q. So, we in a sense have two groups pointing their fingers at each other saying, "You're misinterpreting the data", is that right?

A. Well, yes. Except that I — I can give you my personal example because they they like to claim that person working in geochronology somehow fabricate the data to suit the biologist's need for a long time. Personally, I don't care how old the earth is. I have no desire to have it four and a half billion years old or ten thousand years old. The biologists are just simply going to have to make do with what ever we find out I have nothing at stake whether the earth is very old or very young. It just simply doesn't matter to me.

Q. Well —

A. It probably doesn't matter that much to the biologists.

Q. You say that you have nothing at stake. If — if you have written I think you said over a hundred technical articles and all of them to some degree have been on dating methods or the dates of some particular rocks or something.

A. Uh-huh

Q. I mean if there should be shown to be a — a fundamental error in radiometric dating, your hundred articles may be fundamentally all wrong, isn't that correct

A. That's possible, yes.

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Q. So to some degree you do have an interest, a professional interest in your own reputation, in your own stature within the scientific community in seeing that what you have written remains accurate in the eyes of the scientific community?

A. No. That's not right. Science is one of the few fields in which it is all right to be wrong. You can't be wrong as a surgeon. That's got serious consequences. And it's not good to be wrong as a judge. That's got serious consequences. Scientists are often wrong and it's perfectly acceptable as long as you admit your mistakes. In fact, if I could prove if I thought there were the remotest chance that I could prove that the earth was ten thousand years old then I would start that experiment today because it would make me instantly famous. I probably would win the Nobel Prize. So I've got a lot more to gain — I would have a lot more to gain if I thought there was the outside chance of proving that the earth were less than ten thousand years old.

Q. Okay. So if you thought you could prove that you would have a lot more to gain?

A. I am compelled to find my own mistakes and I have published papers where I have admitted my mistakes I have said, "I have found this error. Here is what the new measurements indicate". But that doesn't happen often.

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Q. If you could do a — do a reverse field (sic) and say, "No. I was wrong. It's ten thousand years.", would that make you famous?

A. No. Only if I could prove it with a preponderance of evidence.

Q. I understand. But if someone could turn around and prove it was ten thousand years and you're still out here saying 4.5 billion years. What would that do to your stature as one of the leading authorities on dating?

A. It would depend on how I handle that evidence — evidence. If I evaluated that evidence and if it was really overwhelmingly in favor of the hypothesis that the earth was less than ten thousand years old, and I — and I ignored those facts then it would damage my reputation. If I objectively evaluated it and — and came to reasonable conclusions based on those facts then it would do no damage at all. You — amongst other things, I would be in very good company.

Q. My — my point I think is just the larger point of one of human nature. That — that you have to date, you know, staked your — your professional reputation and in fact your life's work to date has been on articles which talk about the age of the earth as being this many, you know, billions of years old. And if — and if you were proven wrong and you — you didn't agree with that then, then, I mean, your own stature would be — would be necessarily

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be affected, correct?

A. Well, yes. But you see the chances of that happening are so infinitesimally small that — that it's not something that you worry about. I mean — I mean if the earth blew up from internal causes tomorrow we'd all be dead. But the chances of that happening are infinitesimally small and I'm just not going to worry about it. And so as far as damage to my scientific reputation is concerned, there is simply none to be had I don't think. It's — it's a hypothetical situation which I don't think will ever come true.

Q. But because you have devoted your life's work to this area and to the validity of radiometric dating and if it should be shown with it you have something of a vested interest is really the point?

A. I really don't, no. If someone showed — showed with good evidence that there was serious problem with radiometric dating I could- I would conduct experiments to show if they were right or they were wrong. And thus I would immediately become involved with the proof that they, themselves, had put out. And if right then that would be fine. I would have helped prove it. I — I really have no vested interest in this at all. I have nothing to lose.

Q. Are you aware that Gentry has in some of his writings, later than the ones that you have read, challenged someone

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to prove him wrong?

A. I am not aware of that, no.

[Thereupon State's Exhibit #14 was marked for the record.]

Q. I am going to show you Exhibit #14 which is a letter I think by you to Deputy Attorney General Tyler?

A. Yes.

Q. Is that written in the Segraves case again?

A. Yes.

Q. In response to information that he sent you

A. Yes.

Q. Do you know how he selected what books he sent you?

A. No.

Q. Do you know whether they're representative of creation-science?

A. From — from my readings they are, yes.

Q. Now, the two notebooks that you have in front of you creation — ones labeled, "Notes on Scientific Creationism, 1981," and the second is labeled, "Notes on Scientific Creationism, II, 1981," a copy of which has been supplied to me. Could you just generally describe to me the basis — the basis on which you have developed these notebooks?

A. Well — well, these were simply notes that I took while I was reading the information that Mr. Tyler sent me in particular Notebook # I so that I could refresh my

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memory about the literature that he had sent. And Notebook # II contains some, oh, things like listings of decay constants and a few quotes out of creationist literature that make reference to the Bible and God and other things like that.

Q. Well what I'm not fully understanding, I suppose, is if you have something in here is this necessarily that you — are these always your thoughts or are these things that you may have summarized from things that you have read?

A. Well, they're some of both. Some of it is — Notebook # I is primarily just summaries of their literature, just a summary of what those books and works are about. Number II are thoughts that I have had about — about some of their statements and a few other things that I didn't like to keep in my head that I would rather refer to like decay constants and whatnot.

Q. Let me just refer you to a page I just turned to and identify and I don't even know you can look at mine if you like there where there are, I believe, a quote or a chart taken from one of Morris' books talking there about the second law of thermodynamics?

A. Yes.

Q. At the bottom you state that one, two and four that being an open system. Number two there I can read it?

A. Available energy.

Q. And number four?

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A. Conversion mechanisms.

Q. Are always present.

A. That's basically true in a general sense for systems.

Q. All right. In three you say, "In a case of evolution which is genetic, this is unnecessary that — that evolution proceeds by mutation".

A. This mutation random changes and DNA, etc., this is another general conclusion that I get from talking to some of my biologist colleagues. That's a little note to myself. That's not the sort of thing I would use in testimony because that's out of my field.

Q. Who — what biologist would you be reliant when you make that -

A. That came primarily out of conversations with Tom Jukes and Richard Dickerson.

Q. If I showed you a writing by a leading evolutionist which talked about evolution as a religion, that evolution was simply a religion. Would that be a valid ground to keep that out of the public schools? Evolution I'm talking about.

A. No. I don't think one article by any person would it would have to be balanced against everything else.

Q. Okay. What do you mean bal — balanced against everything else?

A. Well, I mean that you might get any one person to

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say almost anything. If you have one person who has a crazy idea you need to balance that against perhaps thousands of others who have different ideas.

Q. Uh-huh.

A. We don't let the future of our society be influenced always by one person's opinion. If you're talking about keeping something out of the public schools then I don't think one person's opinion should he overriding.

Q. How many should it take?

A. Well, I don't know. I would say it would kind of depend on the subject and the — and the circumstances.

Q. Do you think that the notion of a creator is an inherently religious concept?

A. Yes. I think it is.

Q. Are you aware that, in origin — in The Origin of The Species, that Darwin says, to paraphrase in the conclusion, "that there is a grandeur in this form of life with the first few forms having life breathed into them by the Creator"?

A. Yes. I think he made statements similar to that.

Q. Do you think that's an appropriate subject for study in a public school science classroom, that book?

A. As a document that's important to the history of science, yes.

Q. You don't think it's important to study the scientific

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document itself?

A. Not opinions about a creator, no.

Q. Well, I'm talking about the book itself?

A. I think that The Origins of The Species is a — is a important document for the history of science and I can't say it any better than that.

Q. You're saying that you no longer think it's a scientific document?

A. No. I'm saying it's outdated. My understanding is it's simply outdated. It's over — it's a hundred years old.

Q. Well, do you think because it talks about a creator we shouldn't be studying that in the public schools?

A. I don't think we should be studying the creator in the public schools, in science classes.

Q. Well, Darwin had a concept of the creator in The Origin of The Species.

A. And that book was not written for classroom teaching.

Q. So, should — would you be, in your personal opinion, allow that to be in the public schools classroom?

MR. WOLFE: I — I will object to the form of the question unless it's specified in what — I don't know — are you asking about Dr. Dalrymple's personal opinion as a scientist or -

MR. WILLIAMS: A scientist.

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MR. WOLFE: — citizen or educational?

MR. WILLIAMS: As a scientist.

MR. WOLFE: All right. So, it's not either a personal opinion or a scientific opinion?

MR. WILLIAMS: His opinion as a scientist.

BY THE WITNESS:

A. Well, my own feeling as a geologist is that — and Darwin is writing on biology — is that — that document is primarily for historic interest. And studied in that way I see nothing inappropriate about it at all. It's an extremely important book.

MR. WOLFE: I don't like to interrupt but I think that only another 2, 3 minutes is all that we can allow.

MR. WILLIAMS: Okay. I'm sorry.

BY MR. WILLIAMS:

Q. The notebooks were they used in drafting this document?

A. Well, partly yes. They were used as one of many sources.

Q. If some — if you were teaching a class in science and some student asked you, "how did the first life come about?" What would you tell them?

A. I would have to tell him that I didn't know.

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Q. Do you think that science can provide an answer to that question?

A. It's possible. Ask me fifty years from now and I'll have a better answer.

Q. If creation-science could be studied in a classroom without incorporating religious teachings and writings, would you still oppose it's use in the classroom?

A. I don't think that's possible.

Q. But if it could? I — I — asking you -

A. You're — you're asking me an absolutely impossible — what I think is an impossible hypothetical question and I can't simply respond to a hypothetical question that is not within the realm of possibility.

Q. I'm asking you to — to assume that it could be taught without references to religious writings and religious doctrines? Would you oppose it?

A. I would oppose it on the grounds it would still be rotten science even if you could expunge all of the — all of the religious reference from the question but I don't think you could. It would be terrible, terrible science. And I don't think we should be teaching bad science to children. It's a difficult enough subject without confusing them further.

Q. Just briefly what is this article that you received a letter from Russell Arks (sic) do you recall this?

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A. Yes.

Q. Why did he send these to you, do you know?

A. I asked for them.

Q. What is your opinion of them?

A. I think he doesn't know what he is talking about. He's — he's not a geologist and he clearly does not understand the subject about which he is writing.

Q. What is this document here, "Problems with Mixing Models"?

A. Those are simply my notes on things that are wrong with his model for isochrons which are mixing models. Just a capsule summary of some of the relevant points.

Q. I have no other questions. Thank you Dr. Dalrymple.

MR. WOLFE: I would like to put one question to Dr. Dalrymple. Doctor, Exhibit #14 is dated February 1980, is that a correct date?

DR. DALRYMPLE: Yes. Oh, no. No. That should have been 1981. It's a typographical error.

[Thereupon the taking of the above deposition was concluded at 4:14 p.m.]