Herbert Spencer's Contribution to Solar Physics

Spencer H. to Airy G. B. , 26 April 1851, Royal Greenwich Observatory, Airy papers, File 845, section 7.

Airy G. B. to Spencer H. , 28 April 1851, ibid.

Duncan David , The life and letters of Herbert Spencer (London, 1908), 425. Hereafter cited as Duncan , Life and letters….

Spencer H. , “Recent astronomy and the nebular hypothesis”, Westminster review, lxx (1858), 185–225.

Laplace Simon Pierre , Exposition du système du monde (Paris, 1796). This work appeared in six different editions between 1796 and 1835. Two English translations were made as follows: (i) The system of the world, trans. by Pond J. (London, 1809). From the first French edition of 1796. (ii) The system of the world , trans. by Harte H. (Dublin, 1830). From the fifth French edition of 1824. Sections of this work that deal with the nebular hypothesis are reproduced in: (i) Numbers Ronald L. , Creation by natural law: Laplace's nebular hypothesis in American thought (Seattle, 1977), 124–32. Harte's translation. (ii) Whitney Charles A. , The discovery of our Galaxy (New York, 1971), 137–53. This is an edited and composite translation from all six editions of the original work. It demonstrates how Laplace expanded and altered his hypothesis to better fit advances in contemporary astronomy.

For a detailed review of these modifications see Jaki Stanley L. , “The five forms of Laplace's cosmogony”, American journal of physics, xliv (1976), 4–11. Also see Merleau-Ponty J. , “Situation et rôle de l'hypothèse cosmogonique dans la pensée cosmologique de Laplace”, Revue d'histoire des sciences, xxix (1976), 21–49.

From the fourth edition onwards.

For a full discussion of Herschel's ideas about the nature of the nebulae, including reproductions of his most important papers on the topic, see Hoskin Michael A. , William Herschel and the construction of the heavens (London, 1963), espec. ch. 3: “The construction of the heavens: The first synthesis”, and ch. 4: “The construction of the heavens: True nebulosity and the second synthesis”. An essential supplement to this discussion is the same author's “William Herschel's early investigation of nebulae: A reassessment”, Journal for the history of astronomy, x (1979), 165–76. Also see Schaffer Simon , “Herschel in bedlam: Natural history and stellar astronomy”, The British journal for the history of science, xiii (1980), 211–39.

Parsons William [ Rosse Lord ], “Observations on some of the nebulae”, Philosophical transactions, cxxxiv (1844), 321–3.

Mayer J. R. , “Die Entstehung der Sonnenwärme”, 1848, in Robert Mayer: Beiträge zur Dynamik des Himmels and andere Aufsätze, Ostwald's Klassiker der exakten Wissenschaften, no. 223, ed. by Hell Bernhard (Leipzig, 1927), 9–25. Mayer first introduced the idea of a meteoric source of solar heat in 1845, see Tyndall J. , “Notes on scientific history”, Philosophical magazine, (4) xxviii (1864), 25–51, pp. 47, 35.

Thomson William [ Kelvin Lord ], “On the mechanical energies of the solar system”, Transactions of the Royal Society of Edinburgh, xxi (1854), 63–80.

von Helmholtz H. L. F. , “On the interaction of natural forces”, in Popular lectures on scientific subjects, 1st series, new edn, trans. by Atkinson E. (London, 1893), 137–74. A lecture delivered at Königsberg on 7 February 1854.

Ibid., 156.

Op. cit. (ref. 4). The books under review were listed by Spencer as follows: 1. Oeuvres de Laplace. Paris: Imprimerie Royale. 1843.

Outlines of Astronomy. By Herschel John F. W. Sir , Bart., K.H. London: Longman and Co. 1849.

Results of Astronomical Observations at the Cape of Good Hope, &c. By Sir John F. W. Herschel, Bart., K.H.

Cosmos: Sketch of a Physical Description of the Universe. By Alexander von Humboldt. Vols 1, 2, 3, Murray's edition; vol. 4, Bohn's edition.

Popular Astronomy. By Fran&çois Arago. Translated from the original, and edited by Smyth Admiral W. H. and Grant Robert , Esq. Longman and Co. 1855.

The Recent Progress of Astronomy: Especially in the United States. By Elias Loomis, L.L.D. Third edition. New York: Harper Brothers. 1850.

It was for these arguments that Spencer earned his only acknowledgement in Clerke Agnes M. , A popular history of astronomy during the nineteenth century, 4th edn (London, 1908), 422.

This problem had been discussed earlier by Whewell William in Of the plurality of worlds: An essay. Also a dialogue on the same subject (London, 1854), 211–14.

Op. cit. (ref. 4), 185–95.

Ibid., 191–3.

Ibid., 195–9. Laplace expressed various opinions on the nature of comets in the six editions of Exposition du système du monde. He had not consistently held to the belief that they were captured wanderers from outside, as Spencer supposed.

Ibid., 203–5.

Ibid., 205–21.

Ibid., 210–20.

Ibid., 221–3.

Herschel William , “Observations tending to investigate the nature of the Sun…”, Philosophical transactions, xci (1801), 265–318.

Herschel John F. W. , Results of observations made during the years 1834, 5, 6, 7, 8 at the Cape of Good Hope; being a completion of a telescopic survey of the visible heavens, commenced in 1825 (London, 1847), 431–7.

Op. cit. (ref. 4), 223–4.

Duncan , Life and letters…, 426, emphasis in original.

Spencer H. to Herschel J. , 10 January 1859, Royal Society Herschel papers (H.S.16.483).

Herschel J. to Spencer H. , 16 January 1859, Royal Society Herschel papers (H.S.16.485).

Spencer H. to Herschel J. , 31 December 1859, Royal Society Herschel papers (H.S.16.486). In this letter Spencer mentions Tyndall's approval.

Herschel J. to Spencer H. , 12 January 1859 [sic], Royal Society Herschel papers (H.S.16.484). The date should be 1860 as it is clearly a reply to the letter cited in ref. 30.

Spencer H. to Herschel J. , 18 January 1860, Royal Society Herschel papers (H.S.16.487).

Airy G. B. to Spencer H. , 14 January 1860, Royal Greenwich Observatory, Airy papers, File 849, section 6.

Loc. cit. (ref. 25).

In a letter dated 21 February 1865 appearing in the The reader, v (1865), 227–9.

Kirchhoff G. R. , “On the physical constitution of the Sun”, 1861, in Researches on the solar spectrum and the spectra of the chemical elements, trans. by Roscoe H. E. (London, pt 1, 1862; pt 2, 1863), pt 1, 26–29.

Wilson A. , “Observations on the solar spots”, Philosophical transactions, lxiv (1774), 7–11.

The additions made to this revised version are quoted in The reader, v (1865), 228.

Ibid., 228–9. For details of the 'willow-leaf doctrine see Bartholomew C. F. , “The discovery of the solar granulation”, Quarterly journal of the Royal Astronomical Society, xvii (1976), 263–89.

Op. cit. (ref. 38), 229.

An editorial comment in Guillemin Amedée , The heavens: An illustrated handbook of popular astronomy, 7th edn, ed. by Lockyer J. N. (London, 1878), 45.

Faye H. E. A. E. , “Sur la constitution physique du Soleil”, Comptes rendus, lx (1865), 89–96, 138–50.

Carrington Richard C. , Observations of the spots on the Sun from November 9, 1853 to March 24, 1861, made at Redhill (London, 1863).

Faye H. , “On the physical constitution of the Sun”, trans. and ed. by Lockyer J. N. , The reader, v (1865), 107, 140–2.

Op. cit. (ref. 35), 227.

Ibid., 228.

The reader, v (1865), 141 (in a footnote).

Lockyer J. N. , Contributions to solar physics (London, 1874), 57.

Faye H. , “Sur quelques objections relatives à la constitution physique du Soleil”, Comptes rendus, lxiii (1866), 234–7. In this paper Faye responded to criticisms expressed by Spencer and Lockyer (refs 46, 47). The debate continued in print with Kirchhoff acting as Faye's opponent. The course of the argument may be followed in Kirchhoff G. , “Sur les taches solaires”, Comptes rendus, lxiv (1867), 396–400; Faye H. , “Remarques sur la lettre de M. Kirchhoff et sur l'hypothèse des nuages solaires”, Comptes rendus, lxiv (1867), 400–7; Faye H. , “La cause et l'explication du phénomène des taches doivent-elles être cherchées en dehors de la surface visible du Soleil?”, Comptes rendus, lxv (1867), 221–9 (in which Faye suggests that the variation of density with depth in the transparent nucleus might cause light to be refracted in such a way as to leave sunspots dark); Kirchhoff G. , “Sur les taches solaires”, Comptes rendus, lxv (1867), 644–6; Faye H. , “Simple remarque sur la dernière lettre de M. Kirchhoff”, Comptes rendus, lxv (1867), 661–2; Kirchhoff G. , “Taches solaires: Réponse aux dernières remarques de M. Faye”, Comptes rendus, lxv (1867), 1046.

Faye H. , “Complément de la théorie physique du Soleil; explication des taches”, Comptes rendus, lxxv (1872), 1664–72.

Lockyer J. N. , “Spectroscopic observations of the Sun”, Proceedings of the Royal Society of London, xv (1866), 256–8.

Stewart B. De la Rue W. , and Loewy B. , “On the nature of the solar spots”, Proceedings of the Royal Society of London, xiv (1865), 37–39.

Duncan Duncan , Life and letters…, 431. A discussion of Young's theory, by Proctor R. A. , appeared under the title “The Sun a bubble” in the Cornhill magazine, xxx (1874), 403–16. This was Spencer's source of information.

Duncan , Life and letters…, 431–2.

Spencer H. , Essays: Scientific, political, and speculative (3 vols, London, 1891), i, 188–9. This claim was also made by Collins Howard F. (on Spencer's behalf) in Astronomy and astrophysics, xi (1892), 826–7.

Op. cit. (ref. 50), 1666.

Spencer , loc. cit. (ref. 55).

Op. cit. (ref. 4), 221–2.

This was Spencer's own assessment: See Spencer H. , An autobiography (2 vols, New York, 1904), ii, 13. He prepared his own brief intellectual history; it is included in Duncan , Life and letters… , 533–76, as Appendix B. Other useful sources that deal with Spencer's intellectual development are: Elliot Hugh , Herbert Spencer (1917; reprinted Freeport, N.Y., 1970); Kennedy James G. , Herbert Spencer (Boston, 1978); Young Robert M. , “The development of Herbert Spencer's concept of evolution” in Actes du XI^e Congrès International d'Histoire des Sciences (2 vols, Warsaw, 1967), ii, 273–8.

Duncan , Life and letters…, 536.

Spencer , An autobiography, i, 201. Spencer was not as isolated in this belief as may appear from this quotation: See Young R. M. , “Evolutionary biology and ideology: Then and now”, Science studies, i (1971), 177–206, p. 184.

Spencer , An autobiography, i, 339. Spencer mentioned in a letter to his father that Humboldt had a leaning to the ‘development theory’: An opinion gleaned from reading a review of Kosmos. Spencer himself reviewed Kosmos in his article “Progress: Its law and cause”, Westminster review, lxvii (1857), 445–85.

Duncan , Life and letters…, 541.

The book was Principles of psychology (London, 1855). A full, but not complete, list of Spencer's writings is included in Duncan, Life and letters…, 577–87, as Appendix C.

Spencer , An autobiography, ii, 15–16.

Ibid., 25.

Ibid., 26.

The treatment of Laplace's hypothesis in three different volumes of the Bridgewater Treatises is discussed in Numbers , op. cit. (ref. 5), 20–21.

Nichol J. P. , “State of discovery and speculation concerning the nebulae”, Westminster review, xxv (1836), 390–409; idem, Views of the architecture of the heavens (Edinburgh, 1838, and many later editions). When Spencer wrote: “Books of popular astronomy have familiarized even unscientific readers with his [Laplace's] conceptions” (op. cit. (ref. 4), 201), he was almost certainly referring to Nichol, among others.

For details see Numbers , op. cit. (ref. 5), passim.

For information on Spencer's social contacts and details of his extensive correspondence, see Duncan , Life and letters…, passim. In particular, Spencer was a member of the X Club. The significance of this may be judged from the following:…the small X Club was a significant cohesive group of leading scientists who successfully marshalled their efforts in the furtherance of the cause of science in the two decades after 1864. They exerted important influence in the Royal Society, in the British Association, in various other scholarly societies, in the Royal Institution, and in the publishing of scientific works. They exchanged helpful scholarly criticism, and they worked to ward off the attacks of conservative theologians and to further the views of the scientific community in the political arena. ( Jensen Vernon J. , “The X Club: Fraternity of Victorian scientists”, The British journal for the history of science, v (1970), 71–72.)

Kant Immanuel , “Of the origin of the structure of the world, etc.”, 1755, in Hastie W. (trans.), Kant's Cosmogony, rev. and ed. by Ley Willy (New York, 1968), 59–70, pp. 65–66.

[ Chambers Robert ], Vestiges of the natural history of creation (London, 1844), 12–13.

Ibid., from the 5th edn (1846) onwards. Revisions made by Chambers to the eleven editions published in his lifetime are discussed in detail in Ogilvie Marilyn B. , “Robert Chambers and the nebular hypothesis”, The British journal for the history of science, viii (1975), 214–32.

Brewster David , “Vestiges of the natural history of creation”, North British review, iii (1845), 470–515, p. 479. Also Sedgwick Adam , “Natural history of creation”, Edinburgh review, lxxxii (1845), 1–85, pp. 20–21. The quotation is from Ward James , Naturalism and agnosticism, 4th edn (1915; reprinted New York, 1971), 222.

Jaki , op. cit. (ref. 6). In his book Emile, Rousseau put into the mouth of one of his characters, the following words: Descartes sought to explain the formation of heaven and earth on the basis of a throw of dice, but he could not set those dice in motion, nor bring into play his centrifugal force, except with the help of a movement of rotation. Newton discovered the law of gravitation; but gravitation alone would soon reduce the universe to a motionless mass: To that law he had to add a propulsive force to make the heavenly bodies advance on their elliptical orbits. [Let Descartes reveal to us the physical law which caused his vortices to revolve.] Let Newton show us the hand which launched the planets on the tangent of their orbits. ( Rousseau Jean-Jacques , “The creed of a priest of Savoy”, 1762, in Beattie Arthur H. (trans.), Jean-Jacques Rousseau — The creed of a priest of Savoy (New York, 1956), 13. The section marked [] is missing from Beattie's translation). According to one of his biographers, Laplace may have been driven by this challenge to speculate that, contrary to “the almost universal opinion of philosophers and mathematicians”, the mutual attraction of bodies might, under certain circumstances, cause rotation. ( Fran&çois D. Arago J. , “Laplace”, in Biographies of distinguished scientific men, trans. by Smyth W. H. Powell Baden and Grant Robert (2 vols, 1859; reprinted New York, 1972), i, 303–67, p. 361.)

Comte A. , Cours de philosophie positive (6 vols, Paris, 1835), ii, 369–84. These results were first announced in August 1831 as part of a lecture course given to a group of working men in Paris. For the mathematical details see de Berrêdo Carneiro Paulo E. and Arnaud Pierre (eds), Auguste Comte: Écrits de jeunesse, 1816–1828. Suivis du mémoire sur la cosmogonie de Laplace, 1835 (Paris, 1970), 585–607. (This extract is a copy of the manuscript used by Comte when he gave two lectures to the French Academy of Sciences in January, 1835. He abandoned these arguments in subsequent publications on the same subject — his reasons for doing so are given in Écrits de jeunesse, 583–4.)

Herschel J. , “Presidential address”, Report of the British Association for the Advancement of Science, 1845 (London, 1846), pp. xxvii–xliv, p. xxxviii.

Brewster D. , “M. Comte's Course of positive philosophy”, Edinburgh review, lxvii (1838), 271–308, p. 300.

Mill J. S. , A system of logic (2 vols, London, 1843), ii, 28. Mill thought Herschel had judged Comte too harshly in his address to the British Association; some correspondence ensued between Mill and Herschel, Mill and Comte. See Minerka Francis E. (ed.), Collected works of John Stuart Mill (19 vols, Toronto, 1963), xiii, 673–9.

Op. cit. (ref. 73), 17–18. Reference to Comte was eliminated after the fourth edition.

Sedgwick , op. cit. (ref. 75), 22–23.

Op. cit. (ref. 4), 202.

Plateau J. , “On the phenomena presented by a free liquid mass withdrawn from the action of gravity”, 1843, in Taylor Richard (ed.), Scientific memoirs (5 vols, 1846; reprinted New York, 1966), iv, 16–43.

Ibid., 36.

Ibid., 43.

In the last six editions.

Op. cit. (ref. 4), 201.

Kirkwood's law was first announced in 1849 and widely discussed in the 1850s: See Numbers , op. cit. (ref. 5), ch. 4. It may be noted that Elias Loomis, in his book The recent progress of astronomy: Especially in the United States, refused to include any reference to Kirkwood's result (the reasons for this are discussed in Numbers, op. cit. (ref. 5) pp. 50–54). This was one of the books that Spencer included in his review list (ref. 14).

Details of these reports are provided in Agnes Clerke M. , Problems in astrophysics (London, 1903), 522–30. The first conclusive evidence that at least some of the nebulae were gaseous was obtained spectroscopically by William Huggins in 1864 (“On the spectra of some of the nebulae”, Philosophical transactions, cliv (1864), 437–44). His views on the significance of this finding for the nebular hypothesis were expressed much later (“The new astronomy: A personal retrospect”, Nineteenth century, xli (1897), 907–29, pp. 916–17). This result confirmed Spencer's original assumption, but he had never believed it to be crucial for Laplace's theory: “Indeed it might be argued that the still continued existence of diffused nebulous matter was scarcely to be expected” (op. cit. (ref. 4), 186).

Airy G. B. , “Presidential address”, Monthly notices of the Royal Astronomical Society, iii (1836), 167–74, p. 170. The occasion was the award of the Society's Medal to Sir John Herschel. Airy had supported William Herschel's views on the nebulae in an earlier address: See “Report on the progress of astronomy during the present century”, Report of the British Association for the Advancement of Science, 1831 and 1832 (London, 1833), 125–89, pp. 146–7.

Airy G. B. , “Presidential address”, Report of the British Association for the Advancement of Science, 1851 (London, 1852), pp. xxxix–liii, p. xli.

Op. cit. (ref. 78), p. xxxviii.

Ibid., pp. xxxviii–xxxix.

Herschel J. , “Humboldt's Kosmos”, Edinburgh review, lxxxvii (1848), 170–229, pp. 190–1.

Herschel's standing in the scientific community is discussed in Cannon Walter F. , “John Herschel and the idea of science”, Journal of the history of ideas, xxii (1961), 215–39.

Op. cit. (ref. 95), 182.

Ibid., 172.

Ibid., 190.

The intellectual observer, v (1864), 455.

The reader, v (1865), 8. The reviewer was probably J. N. Lockyer.

Herschel J. to Nasmyth J. , 21 May 1861. This letter is reproduced in Samuel Smiles (ed.), James Nasmyth Engineer: An autobiography (new edn, London, 1885), 370–1.

Herschel J. , Familiar lectures on scientific subjects (London, 1867), 84.

Ibid. The lecture was originally given in 1861 and first appeared in print in Good words, iv (1863), 273–84.

Astronomical register, ii (1864), 5. Herschel's remark was also referred to by Lockyer J. N. in The reader, iv (1864), 80.

Spencer , An autobiography, ii, 513.

Tyndall J. , Fragments of science, 6th edn (2 vols, New York, 1902), i, 3 (in the preface).

Ibid., ii, 222, in ch. 10: “Apology for the Belfast Address”. The term ‘nebular hypothesis’ was interpreted in a variety of ways in the nineteenth century — with Tyndall representing an extreme position. This spectrum of meaning is discussed in Brooke J. H. , “Natural theology and the plurality of worlds: Observations on the Brewster-Whewell debate”, Annals of science, xxxiv (1977), 221–86, pp. 269–70.

Loc. cit. (ref. 27). Note particularly: “He endorses all my conclusions: Though not prepared wholly to commit himself to them….” Spencer chose to emphasize the first, but not the second, part of this statement.

Turner F. M. , Between science and religion: The reaction to Scientific Naturalism in late Victorian England (New Haven and London, 1974), ch. 2.

Tyndall J. to Spencer H. , 1873. This letter is reproduced in Duncan , Life and letters…, 428.

Tyndall J. , “Presidential address”, Report of the British Association for the Advancement of Science, 1874 (London, 1875), pp. lxvi–xcvii, p. xc. This compliment was paid in recognition of Spencer's contribution to psychology.

Tyndall J. , “On force”, in op. cit. (ref. 107), 389–406, pp. 399–402. Lecture delivered at the Royal Institution, 6 June 1862.

Ibid., 402–4.

For details of this dispute see Knott C. G. , Life and scientific work of Peter Guthrie Tait (Cambridge, 1911), 209–13. Also Tyndall J. , “Notes on scientific history”, Philosophical magazine, (4) xxviii (1864), 25–51. Fuller documentation is given in Siegel Daniel M. , “Balfour Stewart and Gustav Robert Kirchhoff: Two independent approaches to ‘Kirchhoff's radiation law’”, Isis, lxvii (1976), 591, footnote 122.

See Heimann P. M. , “Mayer's concept of force: The ‘axis’ of a new science of physics”, Historical studies in the physical sciences, vii (1976), 277–96.

An interesting commentary on the progress of solar physics, with particular reference to energetics, appears in Brayley E. W. , “Physical constitution and functions of the Sun, and sources of its heat and energies, as recently investigated”, Companion to the British almanac for 1865, 41–70; and for 1866, 75–113.

Tyndall , op. cit. (ref. 115), 51.

Tyndall J. , Essays on the use and limit of the imagination in science (London, 1870), 16.

Ibid., 54. This is from an address to the Mathematical and Physical Section of the British Association meeting at Norwich on 19 August 1868.

Ibid., 41. Both this quotation and the one referred to in ref. 119 are revised versions of those originally included in a lecture given to the British Association meeting at Liverpool in 1870.

Turner Steven R. , “Mayer, Julius Robert”, Dictionary of scientific biography, ix (New York, 1974), 235–40. In his support of Mayer, Tyndall also noted: “Mayer probably had not the means of making experiments himself, but he ransacked the records of experimental science for his data, and thus conferred upon his writings a strength which mere speculation can never possess” ( Tyndall , op. cit. (ref. 115), 42).

Duncan , Life and letters…, 91.

Herschel John was earlier criticized for giving too much time to popularization: Time that, in the opinion of one reviewer, could have been more profitably used in research. See [ Galloway Thomas ], “Sir John Herschel's Astronomy”, Edinburgh review, lviii (1833–34), 164–98, pp. 164–5.

Maxwell J. C. , “On the stability of the motion of Saturn's rings”, 1858, in Niven W. D. (ed.), The scientific papers of James Clerk Maxwell (2 vols, Cambridge, 1890), i, 288–376. This paper is a version of an essay awarded the Adams Prize at Cambridge University, June 1857.

Op. cit. (ref. 4), 209–10.

This opinion is expressed by Jaki S. L. in Planets and planetarians: A history of theories of the origin of planetary systems (New York and Toronto, 1978), 156. However, Spencer's appeal to authority here was not to Maxwell (as Jaki supposes) but to John Herschel and Airy (see Spencer Herbert , First principles, 6th and final edn (1900; reprinted Westport, Connecticut, 1976), 370–1, 480). Even so, Jaki's conclusion is quite plausible.

Babinet J. , “Note sur un point de la cosmogonie de Laplace”, Comptes rendus, lii (1861), 481–4. This result tended to discredit a particular version of Laplace's hypothesis.

Spencer , op. cit. (ref. 127), 443–4 (in a footnote). Spencer appears to have learned of Babinet's result through a citation made by David Brewster.

For a retrospective view of Spencer's grasp of thermodynamics, see Ward James , Naturalism and agnosticism, 4th edn (1915; reprinted New York, 1971), 186–9, 593.

Duncan , Life and letters…, 104, 555.

Tyndall's attitude is discussed in Jaki S. L. , Science and creation (New York, 1974), 295–7.

Burchfield J. D. , Lord Kelvin and the age of the Earth (London, 1975).

Spencer H. to Thomson W. , 3 January 1890. Quoted in Duncan , Life and letters…, 438. It was an incident involving Spencer's poor mathematics that caused a friend and fellow X Club member to remark with exasperation: “What a pity Spencer's ingenuity was not based on sounder elementary instruction!” ( Hirst T. A. to Tyndall J. , 9 April 1890, Royal Institution, Tyndall correspondence, 11F5.271).

This same point is made by Yeo Richard in “Science and intellectual authority in mid-nineteenth-century Britain: Robert Chambers and Vestiges of the natural history of creation”, Victorian studies, xxviii (1984), 5–31, pp. 22–24.

Tait treated Spencer as something of a joke! See Knott , op. cit. (ref. 115), 278–88.