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Case 2:13-cv-01232-TSZ Document 46 Filed 05/29/15 Page 1 of
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6 District Judge Thomas S. Zilly
7 IN THE UNITED STATES DISTRICT COURT
8 FOR THE WESTERN DISTRICT OF W ASHINOTON
9 AT SEATTLE
10 CITIZENS OF THE EBEY'S RESERVE
11 FOR A HEALTHY, SAFE & PEACEFUL ENVIRONMENT,
12 Plaintiff,
13 v.
14 U.S. DEPARTMENT OF THE NAVY;
15 ADMIRAL PHIL DAVIDSON, in his official capacity as the
Commander, Fleet
16 Forces Command; and CAPTAIN MIKE NORTIER, in his official
capacity as
17 Commander Naval Air Station Whidbey Island,
18 Defendants,
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No. 2:13-cv-1232-TSZ
DECLARATION OF CAPTAIN BENJAMIN HEWLETT
I, Captain Benjamin Hewlett, U.S. Navy, Commander, Carrier Air
Wing ONE, do hereby 21 declare as follows:
22 1. As Commander, Carrier Air Wing ONE ("CAO"), I am
responsible for Airborne Electronic Attack Squadron 137, an EA-180
squadron home-based at NAS Whidbey Island. The EA-180
23 aircraft is essential to mission success. Field Carrier
Landing Practice ("FCLP") training
24 HEWLETT DECLARATION - 1 -
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Case 2:13-cv-01232-TSZ Document 46 Filed 05/29/15 Page 2 of
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1 provides EA-18G pilots with the necessary training that they
need to safely land on a carrier after flying demanding missions,
sometimes multiple times a day.
2 2. As CAG, I am responsible to the Commander of Carrier Strike
Group TWELVE (a one-star
3 Admiral) for the safe operation and mission accomplishment of
all military aircraft launched and recovered from the Nimitz-class
aircraft carrier USS THEODORE ROOSEVELT ("TR") (CVN
4 71).
5 3. I was designated a Naval Aviator following completion of
advanced aviator training in January 1995. Over the past 20 years,
I have served as an operational aviator and a flight
6 instructor, including duty as a Carrier Air Wing Landing
Signals Officer, where I was responsible for the safe and
expeditious recovery of all aircraft aboard the aircraft carrier. I
have
7 held several leadership roles at the squadron level, including
a tour as a squadron commanding officer. I have served six tours on
board aircraft carriers, including three deployments in support
8 of Operation ENDURING FREEDOM ("OEF") flying combat missions
into Afghanistan. I have flown approximately 3,500 mishap free
flight hours, primarily in the S-3 Viking and the
9 F/A-18C Hornet. I have personally flown the EA-18G "Growler"
on numerous occasions, and I have flown out of NAS Whidbey Island
and practiced FCLPs at Outlying Landing Field ("OLF")
10 Coupeville. I have 760 carrier-arrested landings.
11 4. As CAG, my air wing is broken up into seven "squadrons" of
aircraft. Each squadron is led by its own commanding officer and
has a slightly different mission and set of capabilities. There
12 is only one squadron on board that operates the highly
advanced EA-18G aircraft-Airborne Electronic Attack Squadron 137
(VAQ-137), which is home-based in Whidbey Island,
13 Washington. V AQ-137 has nine pilots and five jets. Due to
the highly specialized nature of the Electronic Attack mission and
the relatively small number of aircraft assigned, the EA-18G is
a
14 "high demand, low density" aircraft. VAQ-137 operates less
than half the number of jets as my other squadrons. Even though
they are small in number, they are critically important to not
only
15 major combat operations, but to the prevention of conflict.
They make an impact across the spectrum of U.S. military operations
that belies their small size.
16 5. EA-18G pilots fly daily in support of Operation INHERENT
RESOLVE ("OIR"), the
17 coalition military operation against the group commonly known
as the Islamic State of Iraq and the Levant ("ISIL"). These flights
are many hours in duration, supporting both U.S. and coalition
18 forces engaged in the fight against ISIL. It is not unusual
for a single aircraft to fly multiple missions in any given day. To
support this, aviators operate on an intense and exhausting
19 schedule. The EA-18G is critical to the success of the entire
effort at the tactical, operational and strategic levels, so much
so that if an EA-18G aircraft cannot support operations due to
20 needed repairs or aviator unavailability, it is frequently
the case that the mission is aborted.
21 6. The mission and tactical actions of the EA-18G in support
of this operation are classified, but are crucial to the U.S. and
coalition mission both in the air and on the ground. These aircraft
and
22 their highly trained aircrew deny the enemy freedom of action
in the electromagnetic spectrum. They achieve this through the
employment of their tactical jamming systems in support of both
23 ground and air forces engaged against ISIL.
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1 7. In order to effectively execute the mission against ISIL,
TR and her aviators must operate in very confined water and air
space in the Arabian Gulf. This water and air space includes
not
2 only all of the ships and aircraft from the Strike Group and
my Air Wing, but also ships and aircraft from other Gulf State
navies, air forces, and coast guards, as well as oil rigs,
commercial
3 shipping and air traffic. This complex operating environment
makes aircraft launch and recovery exponentially more challenging
than open-ocean operations. While the sequencing of aircraft
4 launches is predictable, occurring approximately every 30
seconds, the sequencing of aircraft recovery is highly dynamic. The
expeditious recovery of aircraft is absolutely critical to the
5 safety of the ship, her crew and all other vessels and
interests in the area. During aircraft recovery the aircraft
carrier must maintain a constant course and speed, thus restricting
the ship's
6 maneuverability. If it takes longer to recover aircraft
because undertrained aviators are unable to land on their first
approach it increases already substantial risks and makes it
difficult for the ship
7 to avoid the unpredictable hazards that can rapidly develop.
Aviators returning to the ship are especially taxed by the
intensity of operations, so their skills absolutely must be second
nature
8 and perfected before deployment. Any deficiency in an
aircrew's training prior to embarking on an aircraft carrier
increases risk not only the lives of the aviators, but those
sailors on the flight
9 deck that are mere feet from the aircraft as it takes off or
lands.
10 8. In any 24-hour period, over 100 jet and helicopter
launches and recoveries are performed by a team of hundreds of
dedicated sailors working together on the flight deck. The rapid
launch,
11 recovery, refueling, and rearming of aircraft from an
aircraft carrier is a complex task involving pilots, maintenance
personnel, and support personnel and represents a highly
specialized system
12 of operations unique to naval aviation, which must be
choreographed and executed with precision. Naval personnel must
learn how to launch, recover, refuel and rearm aircraft,
13 concurrently, at night, often in bad weather, on an aircraft
carrier flight deck. In those circumstances, safety is paramount:
the constant threat posed by jet engine intakes and exhausts,
14 turning propellers, and moving aircraft makes the aircraft
carrier flight deck an extremely dangerous work environment.
15 8. Night carrier operations are the highest risk operations
in aviation, but night combat
16 operations are critical to mission success because of the
diminished capability of the enemy to respond to coalition and U.S.
ground and air operations. Every night, EA-18G aviators land
17 aboard ship, often in a pitch-black environment with rolling
seas. Their combat missions are fatiguing and dangerous.
Periodically, storms will move through the area, making seas
18 unpredictable. Additionally, the environment in the Arabian
Gulf is frequently hazy with low visibility. These poor
environmental conditions significantly affect carrier flight
operations in
19 many different ways, and aviators must be well-trained and
proficient in order to respond to the unique requirements of the
different circumstances that are encountered. The dynamic and
high
20 risk nature of night carrier operations requires very strict
night Field Carrier Landing Practice (FCLP) periodicities for
aircrew proficiency prior to embarking the ship for any at sea
period in
21 order to ensure the an acceptable level of risk is
maintained. Carrier landings are a perishable skill, and Navy
policy mandates that FCLP training should be conducted within five
days of
22 landing on the aircraft carrier and must in no case be
conducted more than 10 days prior to landing on the carrier. Having
conducted FCLPs at OLF Coupeville, I believe OLF Coupeville
23 provides a realistic environment in which to practice FCLPs.
Any degradation of the ability for VAQ-137 to conduct FCLPs in an
environment as ideal as OLF Coupeville prior to embarking
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1 aboard ship will degrade U.S. and coalition combat
effectiveness while creating unacceptable risks for the aviators
and crewmembers aboard TR.
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I hereby swear under penalty of perjury pursuant to 28 U.S.C.
1746 that the foregoing information is true and correct to the best
of my k;wYl~~::::;:----Jr&n]~
Captain, U.S. Navy
HEWLETT DECLARATION -4-
