55-3 Declaration of Eric P. Illston, Captain U.S. Navy

Case 2:19-cv-01059-RAJ-JRC Document 55-3 Filed 03/16/20 Page 1 of 17
6
IN THE UNITED STATES DISTRICT COURT
7
FOR THE WESTERN DISTRICT OF WASHINGTON
8
AT SEATTLE
9
10
10 STATE OF WASHINGTON, et al.,
61]., No. 2:19-cv-01059-RAJ-JRC
2:19-cv—01059-RAJ—JRC
11
11 Plaintiff,
Plaintiff
DECLARATION OF ERIC P. ILLSTON, CAPTAIN
12
12 v.
V. U.S. NAVY
13
13 The UNITED STATES DEPARTMENT OF
THE NAVY,
NAVY, et al.,
al.,
14
14 Defendants,
15
15
16
16 I, CAPT Eric Illston, US.
U.S. Navy, do hereby declare as follows:
17
17 1.
1. As the Commanding Officer
Officer of
of Electronic Attack Wing, US.
U.S. Pacific
Pacific Fleet, IIam
am
18
18 responsible
respon31ble for ensuring EA-18G
EA- 18G Growler aircrews are trained and effective flying EA-
eifective in safely flying EA—
19
19 18G
18G Growlers as combat-ready Airborne Electronic Attack (AEA) forces. Those forces provide
20 combatant commanders with more than just the technological capability of

of an aircraft and its
21
21 weapons; AEA personnel must also be ready to succeed and win in battle. I have a duty to
22 provide my squadrons with realistic and effective

eifective training that will enable them to deploy in
23 support of
of military operations around the world. The scope of
of my command spans fourteen (14)
24
25
ILLSTON
ILLS TON DECLARATION -1-
1 squadrons consisting of
of over 3,500 personnel operating 160
160 EA-18G aircraft in support of
of
2 national strategic-level
strategic-1evel combat and non-combat operations around the world.
3 2. IIwas
was raised in Woodinville, Washington and graduated from the University of
of Puget
4 Sound in 1992
1992 with a Bachelor of
of Science degree in Business. Commissioned in 1996,
1996, I earned
5 my wings as a Naval Aviator in 1999, flying the EA-6B

1999, and began flying EA- 6B Prowler and its successor the
6 EA-18G
EA—18G Growler. I served with the squadrons VAQ-141
VAQ-141 and VAQ-140, as well as the Air Wing
7 Landing Signals Officer

Oflicer for Carrier Air Wing NINE. IIhave
have deployed onboard the aircraft
8 carriers USS ENTERPRISE (CVN 65), USS THEODORE ROOSEVELT (CVN 71), USS
9 JOHN C STENNIS (CVN 74), and USS DWIGHT D EISENHOWER (CVN 69) in support of
of
10
10 Operations SOUTHERN WATCH, IRAQI FREEDOM, and ENDURING FREEDOM. I have
11
11 also served as an Instructor Pilot, responsible
respons1ble for qualifying junior officers
oflicers to land and operate
12
12 from aircraft carriers. I also served as the Commanding Officer
Oflicer of
of VAQ-130, deploying with
13
13 Carrier Air Wing THREE onboard USS HARRY S TRUMAN (CVN 75) in support of
of Operation
14
14 ENDURING FREEDOM. IIhave flight hours in the EA-18G, EA-6B,
have logged over 3000 flight EA—6B, F-18F,
15
15 T-45 and various other aircraft, accumulating 750 arrested landings onboard aircraft carriers at
16
16 sea. As a naval aviator and wing commander, IIam
am intimately familiar with the equipment,
17
17 manpower, doctrine, and training necessary to prepare aircrews to deploy aboard aircraft carriers.
18
18 3. Carrier aviation is unlike any other type of
of military or commercial aviation. The ability
19
19 flom the flight
to safely operate an aircraft from flight deck of
of an aircraft carrier is the culminatio n of
of
20 years of flight training in four broad phases: Ground school is the gateway to training
of intense flight
21
21 jets, followed by specialized training in assigned aircraft, and ultimately assignment to
22 operational squadrons that deploy to combat. Student Naval Aviators and Naval Flight
23 first formative months in Pensacola, Florida, learning basic

Officers (NFOs) spend their first
24
25
ILLSTON
1 aviation ground school topics and water survival training. Shortly thereafter, these young
2 officers flight school instruction by gaining foundational skills operating the T-6
officers begin basic flight T—6
3 Texan II, a propeller aircraft designed for initial basic aviation training. If
If they successfully
4 complete this phase, they move to an intermediate level of

of training to expand their skills.
5 During this phase, Student Naval Aviators begin operating the T-45 Goshawk jet trainer while
6 our Student NFOs are introduced to advanced navigation procedures and tactical problem sets,
7 which teach them how to make decisions in combat. If

If students succeed in all of
of these areas,
8 they may be selected for the jet community. They will then begin advanced jet training and
9 flying more advanced aircraft, continuing to hone their skills at faster

start flying Ester speeds, higher
10
10 altitudes and with added capabilities. Near the end of
of the advanced jet phase of
of training,
11
11 Student Naval Aviators train for an opportunity to earn their Initial Carrier Qualification
Qualification by
12
12 operating a T-45
T—45 Goshawk training jet from the deck of
of an aircraft carrier solo, that is, without
13
13 an Instructor Aircrew in the aircraft with them.
them The demands of
of the near-end
near— end phase of
of training
14
14 are so great that during this phase the Student Naval Aviators are prevented from engaging in
15
15 any other type of
of training; carrier qualification
qualification is their singular focus. Via their Landing Signal
16
16 Officers
Officers (LSOs), the students are indoctrinated in all aspects of
of carrier aviation. LSOs are
17
17 experienced Naval Aviators, recognized for their exceptional knowledge of
of carrier aviation
18
18 procedures and are specially trained in instructing its principles.
19
19 4. The primary tool available to LSOs to inculcate safe carrier procedures to the students
20 flight training sessions known as Field Carrier Landing Practices (FCLPs).

are dedicated flight
21
21 flight operations conducted at a land-based airfield
FCLPs are flight airfield or strip that attempt to mimic
22 the conditions of
of an aircraft carrier and build the skills and decision making necessary to safely
23 land a jet aircraft onboard a moving aircraft carrier. Much like the carrier qualification
qualification phase,
24
25
ILLSTON
1 FCLPs are a single- focus mission. FCLPs allow students to practice the landing pattern the
2 students will use when they are at the aircraft carrier; no other training is conducted during
3 flights. If
these flights. If the Student Naval Aviators successfully
successfillly qualify at the aircraft carrier and
4 complete advanced jet training, they receive

receive their
their ‘Wings of Gold’ and
“Wings of and continue to the next
5 phase of
of their training at a Fleet Replacement Squadron (FRS) for the specific flont—line
specific front-line
6 fly. The FRS trains all new electronic attack aviators

aircraft they have been assigned to fly.
7 before they join either an expeditionary squadron or a carrier air wing squadron. The FRS also
8 non- flying tours.

trains aviators transitioning form other aircraft or returning from non-flying
9 5. The Growler community is unusual in that there is only one FRS for the EA-18G,
10
10 VAQ-129,
VAQ—129, located at Naval Air Station Whidbey Island (NASWI), and seven EA-18G carrier
11
11 squadrons are also located at NASWI. Thus, for Growler carrier aircrew, the FRS and
12
12 operational phases of
of training are accomplished at the same location. At the FRS,
13
13 replacement aircrew learn to operate the EA-18G beginning with a basic familiarization phase
14
14 flille st capabilities in combat and are
culminating in their ability to operate the aircraft to its fullest
15
15 then considered
considered “fleet
“fleet ready.”
ready.” The FRS is considered graduate
graduate level
level training
training as
as the
the ‘student’
‘student’
16
16 flom the Naval Aviator and NFO titles, and they are referred to as
moniker is dropped from
17
17 “replacement
“replacement aircrew.”
aircrew.” It
It is
is also
also important
important to
to note
note that
that the
the “crew
“crew concept”
concept” is
is introduced
introduced to
to the
the
18
18 replacement aircrew. In other words, the Naval Aviator and the Flight Officer
Oflicer are no longer
19
19 seen
seen as
as two
two distinct
distinct individuals;
individuals; instead,
instead, they
they are
are viewed
viewed as
as aa single
single “aircrew”
“aircrew” trained to
20 operate the EA-18G.

EA- 18G. Prior to this stage the Student Naval Aviators and NFOs experienced
21
21 different training syllabi; at the FRS their training syllabus is shared and made specific
specific to the
22 EA-18G.
EA- 18G. Similar to the advanced jet training stage, the biggest hurdle in the FRS for
23 replacement aircrew is carrier qualification.

qualification. For the Naval Aviators, who had previously
24
25
ILLSTON
ILLS TON DECLARATION -— 4 -
-
1 carrier qualified
qualified in trainer jets, this is their second time experiencing carrier qualifications
qualific ations with
2 a new aircraft. For the NFOS, first exposure to the carrier environment.
NFOs, this is their first
3 Additionally, for both Naval Aviators and NFOS first time they are expected to
NFOs this will be the first
4 operate safely around the aircraft carrier at night.
5 6. The replacement aircrew must successfully

successfiilly qualify in the EA-18G
EA— 18G at the carrier to
6 complete their training. Akin to the advanced stage of jet training, the replacement aircrew are
ofjet
7 not permitted to focus on other types of

of training. This process takes weeks of
of training
8 encompassing lectures, day and night simulators, and performing FCLPs at Ault Field and
9 OLF Coupeville, both day and night, to prepare the replacement aircrew to the point where
10
10 they have demonstrated to their LSOs the skills, safety margins, and predictability and
11
11 controllability to earn an opportunity to go to the carrier and try to qualify. After successful
12
12 completion of
of carrier qualifications and FRS completion, the aircrew graduate to their
13
13 operational Fleet squadron and continue to advance their tactical training and aeronautical
14
14 skills for combat and carrier operations.
15
15 7. first operational aircraft carrier, the aircrew must
Before an aircrew can deploy to their first
16
16 master the necessary skills to complete a carrier landing. What was once the sole focus of
of a
17
17 training syllabus at the FRS, quickly becomes routine as aircrews are expected to safely,
18
18 fly.
expeditiously, and successfully land aboard an aircraft carrier each and every time they fly.
19
19 Conducting FCLPs, which mimic the landing environment of
of an aircraft carrier, builds the
20 skills and decision-making necessary for aircrew to safely land a jet aircraft onboard a moving
21
21 aircraft carrier. FCLPs are the only tool available to LSOs that nearly replicate, though never
22 replace, the rigors of

of carrier based operations.
23
24
25
ILLSTON
1 8. Performing an arrested landing onboard a moving aircraft carrier is widely known to be
2 one of
of the most difficult
difficult and dangerous tasks in the American military and is an incredibly
incredlb 1y
3 perishable skill.
skill Nighttime carrier landings are even more challenging than daytime landings.
4 At night, aviators lack the visual cues they rely on during daytime landings. It is often
5 impossible
impos31ble to discern the horizon or the ocean due to the complete lack of
of ambient lighting out
6 at sea, and this inability to perceive relative motion can result in vertigo and confusion.
7 flight instruments and training. FCLPs allow aircrew to

Aviators must rely heavily on their flight
8 prepare to execute this maneuver at a location on land where risks that could be encountered at
9 sea can be mitigated to an acceptable level.

level To be clear, the risks inherent with landing at sea
10
10 cannot be overstated. FCLPs on land mitigate the risk of
of death at sea. The at-sea
at- sea environment
11
11 is unforgiving and demands that aircraft and aircrew adhere to an incredibly
incred1b 1y stringent set of
of
12
12 flightpath restrictions in order to land on a moving ship without
altitude, airspeed, and flightpath
13
13 final seconds of
crashing. During the final of the landing, aviators make constant power corrections to
14
14 achieve the exact descent angle, alignment and airspeed so that the aircraft arresting hook
15
15 fiom
touches down in a precise location on an aircraft carrier runway that is moving away from
16
16 them as well as pitching up and down and rolling side to side. No matter the seniority or
17
17 experience of
of the aircrew, FCLPs are required to be performed to qualify a pilot to deploy to an
18
18 aircraft carrier. This requirement cannot be waived and pertains to training squadrons and
19
19 fleet squadrons alike (though the requirements differ somewhat between the two
operational fleet
20 organizations). For example, an FCLP must be performed close in time (within10

(withinlO days) before
21
21 a squadron deploys to an aircraft carrier because the perishable skills needed to perform the
22 maneuver must peak just as they are needed.
23
24
25
ILLSTON
1 9. The entirety of
of an FCLP is designed to mimic as near as poss1ble
possible the metrics that the
2 aircrew will be expected to meet at sea. An FCLP refines pilot’s skills needed during the
refines the pilot’s
3 last 15-18
15—18 seconds of flying prior to the aircraft touching down. Essentially, the pilot must
of flying
4 perform a precise landing approach and touchdown to the simulated aircraft carrier deck
5 field), precisely touch its wheels on the correct spot of

(landing field), of the runway, and then increase
6 power and take off

ofl again without stopping1 . However, in order to reach those last 15-18
stoppingl. 15-18
7 seconds, the aircrew must have maneuvered the aircraft in such a manner to meet strict
8 airspeed, altitude, and distance parameters. The FCLPs enhance

enhance the
the aircrews’
aircrews’ ability
ability to
to
9 maneuver the aircraft to meet these demands.
10
10 10.
10. An FCLP pattern (landing pattern) is dramatically different than any landing pattern
11
11 flying because a typical recovery period at sea often has in excess
found in civilian or military flying
12
12 of
of a dozen aircraft trying to land within a short time frame. Throughout the aircraft recovery
13
13 process, the aircraft carrier itself
itself must maintain a constant course and speed. This restriction
14
14 on
on the
the aircraft
aircraft carrier’s
carrier’s maneuverability
maneuverability increases
increases the
the aircraft
aircraft carrier’s
carrier’s vulnerability
vulnerability to
to attack
attack
15
15 and other hazards. Therefore, aviators must land on the carrier in rapid succession in order to
16
16 minimize the amount of
of time the carrier is restricted in maneuverability. The procedures we
17
17 instill in our aircrew are designed to reflect
reflect the needs of fleet, which requires getting the
of the fleet,
18
18 aircraft aboard safely and expeditiously. The difficulty in safely and expeditiously landing is
19
19 compounded by the high-performance nature of
of our aircraft. It is no small feat to transition an
20 aircraft from 350 knots (approximately 400 m.p.h.)

mph.) to an approach speed of
of 135
135 knots
21
21
22
11As discussed in Para. 15,
15, a missed landing on an actual aircraft carrier requires the pilot to
23 immediately take off flom the carrier deck to re-attempt the landing. FCLPs
ofl from FCLPS train pilots in this
necessary skill.
skill
24
25
ILLSTON
1 (approximately 155
155 m.p.h.)
mph.) and safely land aboard an aircraft carrier with a landing interval
2 first pass. This process is truly a team

allowing for all other aircraft recovering to land on the first
3 sport and all aircraft in the pattern must know what the other is doing or about to do. Thus,
4 learning how to operate in a landing pattern with other aircraft is critical to the
the aircrew’s
aircrew’s
5 training. Aircrew must learn how to control spacing between fellow aircraft in the pattern to
6 avoid creating an airborne traffic jam. At sea, there is no divert airfield;

traflic jam airfield; all the airborne planes
7 must land on the carrier, and an airborne traffic

traflic jam can be deadly.
8 11.
11. The FCLP and aircraft landing pattern itself
itself is a left-hand turning racetrack pattern
9 oriented along a runway or ship's heading with one end of

of the ovals being a descent to landing.
10
10 At sea, the altitude of field has individual
of the landing pattern is 600 feet; ashore, each outlying field
11
11 course rules and restrictions in place to mimic that profile
profile as nearly as pos31ble.
possible. The process
12
12 begins when the aircraft enters the landing pattern by performing a maneuver called the
13
13 "break" flying upwind aligned with
'break" in which they arrive overhead the landing runway in use, flying
14
14 the runways heading, traveling at 350 knots, and then turn 180
180 degrees. Aircrews take
15
15 inventory of
of what other aircraft are in the pattern and plan their "break
'break turn" such that at the
16
16 end of
of 180
180 degrees of flying downwind at the appropriate distance behind the
of turn they are flying
17
17 aircraft preceding them and at the appropriate distance directly to the side of
of the center of
of the
18
18 fiom runway center
runway, which they were just moments ago directly above. The distance from
19
19 first of
is known as "abeam distance" and is the first of many metrics my aircrew are trying to refine
refine
20 fly. Depending on aircraft configuration,

throughout each FCLP pass they fly. configuration, gross weight, and
21
21 environmental factors such as cross wind components, the required abeam distance of
of the
22 aircraft will change from pass to pass. The abeam distance can range from 1.8-1.0
1.8-1.0 nautical
23 miles given changes in any one of

of the above factors. The abeam distance is vital to aircrew
24
25
ILLSTON
1 because their descending “approach flom that distance. The "approach turn"
“approach turn” is anchored from
2 flying that includes 180

is precision flying 180 degrees of
of change, precise control of
of aircraft bank angle,
3 integrated throttle movements, critical control of

of the aircraft's energy state, and controlled
4 descent rates.
5 12.
12. A properly executed approach turn will set an aircrew up for success in the last 15-18
15—18
6 seconds of flying before touching down. Due to the highly challenging and dynamic nature of
of flying of
7 the approach turn, we try to limit the number of

of variables that a pilot must control.
control For
8 example, ideally the only variable in the approach turn equation should be the aircraft's abeam
9 distance. All other aspects of

of the approach turn (bank angle, descent rate, aircraft energy state,
10
10 altitudes) should be more or less held constant throughout the turn. This is a process that does
11
11 flequent repetition to make it second nature.
not come naturally and requires frequent
12
12 13.
13. In the last 15-18
15—18 seconds of flight, the aircrew are solely focused on three things: the
of flight,
13
13 “meatball,”
“meatball,” line-up, and AOA. The "meatball" is the orange light source provided by the
14
14 Improved Fresnel Lens Optical Landing System (IFLOLS). The orange point light source is
15
15 referenced to a horizontal row of
of green lights known as the datums. The meatball is vertically
16
16 oriented and shows the pilot real-time where the aircraft is in reference to the datums, above or
17
17 below. These deviations directly correspond to where the aircraft is in relation to the ideal
18
18 glideslope. Too high and the aircraft misses all the arresting wires and has to quickly take off
OE
19
19 and attempt another landing. Too low and the aircraft runs a very significant risk of flying into
of flying
20 the back of
of the aircraft carrier—possibly
carrier—poss1bly killing the aircrew and personnel aboard the carrier.
21
21 During line-up,
line—up, the pilot is striving to maintain the aircraft on the centerline of
of the approach
22 corridor and the intended point of

of landing. Line-up
Line—up serves several important purposes. First
23 fiulty line up (left or right of

and foremost, a faulty of centerline) results in the IFLOLS showing
24
25
ILLSTON
1 inaccurate information to the pilot. That is to say, the only time the IFLOLS is providing
2 accurate glideslope data to the pilot is when the aircraft is on centerline. Additionally, unlike a
3 flight deck of
traditional runway, the flight of an aircraft carrier is packed on both sides with parked
4 aircraft. The landing area itself

itself is only approximately 90 feet wide. The wingspan of
of an EA-
5 18G flight position is approximately 44 feet. Travelling at 135

18G with wings spread in a flight 135 knots,
6 this leaves little room for error.
7 14.
14. Lastly, the pilot is concerned with AOA, or Angle-of-Attack. AOA is a measure of
of the
8 angle between the chord line of

of a wing and the relative wind hitting it. AOA is the Navy’s
the Navy’s
9 best representation of
of the energy state of
of the aircraft. Airspeed alone is not an accurate
10
10 depiction of
of the energy state of
of the aircraft and does not sufficiently account for wing
11
11 performance; AOA on the other hand does. Because AOA is angular in nature, it reflects
reflects not
12
12 only the aircraft's energy state but its attitude (nose high or nose low) as well. The AOA
ADA of
of the
13
13 aircraft is critically important to manage because the aircraft should move neither too slowly
14
14 nor too fast. From the perspective of
of energy management, if
if an aircraft is too slow it is
15
15 underpowered, sluggish, and prone to settling ("falling" below ideal glideslope). If
If an aircraft
16
16 fist or above ideal AOA, it tends to float
is too fast float and has a higher overall approach speed, which
17
17 upon engaging an arresting gear wire, imparts a higher than designed or anticipated load on
18
18 both the aircraft and the arresting gear system.
system AOA deviations are also critical when
19
19 discussing the aircraft's attitude. An aircraft that is again too slow (below ideal AOA) presents
20 a high pitch profile

profile (nose higher than optimal) which in turn lowers the arresting hook point
21
21 underneath the aircraft. This can lead to the hook engaging the very back of
of the aircraft carrier
22 or an earlier than anticipated arresting gear wire. An aircraft which is too fast (above ideal
23 flatter (nose lower) attitude upon landing and can result in the arresting hook
AOA) presents a flatter
24
25
ILLSTON
ILLS TON DECLARATION - 10
10 -
1 fiiling to stop. Lastly, as with lineup,

failing to contact any arresting gear wires and therefore failing
2 any deviation from ideal AOA presents inaccurate meatball information to the pilot as the light
3 flying optimum
source is only programmed to provide accurate information to a pilot who is flying
4 AOA and lined up on centerline. All of

of these factors must be visualized, processed, corrected
5 for, and assessed within that last 15-18

15 -18 seconds of flying before the aircraft touches down.
of flying
6 Everything the aircrew did prior to this 15-18

15- 18 seconds (the break maneuver, abeam distance
7 management, approach turn

tum mechanics, and aircraft spacing) is designed to get them to as good
8 a start as poss1ble
possible for that last 15-18
15—18 seconds of flying. During this time, the
of high intensity flying.
9 pilot is in rapid- fire fashion taking in "meatball, lineup, AOA" inputs and making appropriate
rapid-fire
10
10 adjustments in order to land safely.
11
11 15.
15. One of
of the goals of
of an FCLP is to ingrain into the pilot's muscle memory the need to
12
12 filll power upon
immediately select full power upon touchdown. Immediately selecting full
13
13 touchdown is a crucial and lifesaving act that must become second nature. By immediately
14
14 fly away from
selecting full power upon touchdown, the aircrew can safely fly fiom the carrier deck in
15
15 the event the arresting hook fails to engage any wires (called a "bolter"),
'bolter"), a wave-off
wave-off (when the
16
16 LSO, who is standing on a catwalk next to the carrier deck, aborts the landing), or a
17
17 catastrophic failure of
of the arresting hook or wires to safely "trap" the aircraft. Within that
18
18 moment of
of a failed landing or touch-and-go
touch— and- go landing the aircrew must learn to instantly
19
19 transition back from focusing on landing to focusing on other aircraft in the pattern and re-
20 flow with proper interval to attempt another landing. If

establishing themselves in the flow If the
21
21 fiils to immediately select full power upon touchdown, and the aircraft misses the
aircrew fails
22 arresting wire or the arresting wire fails, the aircraft will be unable to regain enough airspeed to
23
24
25
ILLSTON
11 -
Case 2:19-cv-01059-RAJ-JRC
2:19-cv-01059—RAJ-JRC Document 55-3 Filed 03/16/20 Page 12 of 17
1 fly, crashing into the sea or into the aircraft carrier . The FCLPs help aircrews to avoid such
fly,
2 catastrophic consequences.
3 16.
16. Successfully accomplishing aaproperly flown pass results in the aircraft's arresting hook
properly flown
4 engaging one of
of three or four arresting gear wires strung across the landing area. These wires
5 flight deck by leaf

are spaced roughly 50 feet apart, held approximately four inches above the flight leaf
6 spring devices, and designed to bring a 48,000 pound aircraft travelling 135
135 knots to full stop
7 within roughly 2.5 seconds and less than 200 feet.
8 fiom the Final EIS provides a graphical representation of

Below, Figure 3.1-6 from of an FCLP.
9 Aircraft touches down on simulated carrier deck and

Descending turn climbs back to 600' AGL pattern altitude
10
10 “mum"mmma Aircraft climbs straight ahead and turns
90° " '
'-"'" “r- ' A E... . .I.
left and downwindatfiDO'AGL
. , ' '. ”In.
.ii 500 A01. "fin... Do . _
11
11 '
a? .. . _ Wu... 3!? - Aircraft slows to approach
speed and descends to
300 AGL 600' AGL pattern attitude
12
12
13
13
14
14
15
15
16
16
17
17 KEY:
AGL Above Ground Level
NM Nautical Mile
18
18
19
19
17.
17. The purpose behind FCLPs can also be understood by watching video of
of aircraft conduct
20
actual landings on aircraft carriers. To watch a similar aircraft, an F/A-18
F/A- 18 Hornet, conduct a
21
21
carrier landing at real speed see https://www.youtube.com/watch?v=Sz7dluAFXb0
htts/www.voutube.com/watch?v=Sz7dluAFXbO.. To watch
22
another F/A-18 Hornet conduct a landing at night, see
23
https://www.youtube.com/watch?v=aV2A8cCG19E.
htts/www.youtube.com/watch?v=aV2A8cCG19E. These videos comport with my experience
24
25
ILLSTON
l2 -
1 conducting day and night carrier landings in an EA-18

EA— 18 G Growler, which shares the same
2 fiiselage and engines as a Hornet. They are a fair and accurate demonstration of
fuselage of the complexity
3 of
of safely landing on an aircraft carrier.
4 18.
18. FCLPs
FCLPS are conducted day and night in almost every weather condition and can occur
5 several times over a 24 hour period. Aircrew will typically spend approximately 45 minutes in
6 the landing pattern during the course of fly an average of

of an FCLP period and fly of 8-10 passes
7 (each pass being one complete trip around the pattern culminating in the last 15-18
15-18 seconds of
of
8 flying). During these sessions muscle memory and fine

"meatball, lineup, AOA" flying). fine motor skills
9 are practiced and instilled in our aviators. LSOs also use FCLPs as opportunities to test an
10
10 aircrew's responsiveness to their directions. Critical information pertaining to line-up, energy
11
11 state, and wave-offs
wave—oflis are transmitted to the aircraft via radio and non-radio signals which
12
12 aircrew must obey. LSOs
LSOS are continually assessing aircrew for their controllability,
13
13 flying passes. For their hard work, each individual aircrew
predictability, and safety in flying
14
14 receives a highly personalized and detailed debrief
debrief on not just the FCLP session as a whole,
15
15 but for each of flown. In an average FCLP session of
of their passes flown. five aircraft flying
of five flying 10
10 passes
16
16 each, my LSOs debrief
debrief 50 passes to aircrew. Through this process aircrew trends, weaknesses,
17
17 and strengths are identified
identified with tailored training plans and individualized feedback developed
18
18 by LSOs and provided to their aircrews. Personal and professional relationships are also
19
19 forged with the LSO, whose voice will be the only voice that aircrew hears while they're
20 landing on an aircraft carrier and one they will certainly want to hear ifif they are struggling to
21
21 bring their aircraft aboard.
22 19.
19. As an LSO, I observed and graded 8,000 FCLPs
FCLPS and 30,000 carrier landings, providing
23 fiom the ideal landing pattern.

precise feedback to each aircrew to correct any deviations from As
24
25
ILLSTON
13 -
1 an LSO on three combat deployments, I have waved off

off more than 100
100 different aircraft,
2 preventing mishaps and saving lives. Once IIhad

had to wave off
off an F-14 that was too low on
3 approach. As the pilot responded to my calls by engaging full afterburner, his aircraft went
4 below the level of flight deck and barely missed the back of
of the flight of the aircraft carrier as it was
5 climbing away from the water. That is just one example of

of how dangerous aircraft carrier
6 operations can be, and why FCLP training is so critically important to making it safer.
7 20. The ability to land on a carrier is a perishable skill that must be developed and
8 sustained, and
and one
one that
that is
is essential
essential to
to the
the United
United States’
States’ global
global military
military operations.
operations. Simulators,
9 while USCfill
useful and used extensively to train aircrews, are no substitute for aircrew conducting
10
10 actual FCLPs.
FCLPS. Simulators cannot replace the feel and physiological conditions experienced
11
11 during FCLPs,
FCLPS, and the Navy has determined that using simulators alone to certify aircrews for
12
12 carrier landings is far too dangerous to accept. Each aircrew must complete real FCLPs
FCLPS in
13
13 order to gain certification
certification to conduct an actual carrier landing, in order to mitigate the inherent
14
14 dangers of
of these difficult operations. In order to prepare EA-18G
EA- 18G Growler aircrews of
of
15
15 Electronic Attack Wing for carrier operations, each aircrew must complete the FCLP training
16
16 process close in time to a deployment to an aircraft carrier. The timing of
of the training is
17
17 crucial because each
crucial because each component
component of
of the
the aviator’s
aviator’s skill
skill set
set must
must come
come together
together at
at the
the correct
correct
18
18 Navy’s aviator
moment. As explained above, the Navy’s aviator training pipeline is
training pipeline is aa long
long and
and arduous
arduous path,
19
19 progressing from developing general military aviation skills to specialized platform—
platform-specific
specific
20 tactics and procedures. For a specialized aircraft such as the Growler, aircrew training can take
21
21 flying in an operational squadron.
up to three years or more from coming into the Navy to flying
22 21. As the Commander of

of Electronic Attack Wing, U.S.
US. Pacific
Pacific Fleet, all EA-18G Growler
23 aircraft are under my command. fimiliar with the equipment aboard this type
I am intimately familiar
24
25
ILLSTON
14 -
1 of
of aircraft and am competent to testify about its installed engines. All EA-18G Growler
2 aircraft are equipped with twin F414-GE-400

F414-GE—400 engines. The Navy has never equipped the EA-
3 18G
18G Growler aircraft with any other type of
of engines since the Navy began using the Growler at
4 OLF Coupeville. Nor has the Navy ever used the term ‘enhanced’
‘enhanced’ to describe
descr1be the Growler
5 engines, and my command has no plans or instructions to change to any engines other than the
6 F414-GE-400
F414-GE—400 engines currently installed in the aircraft under my command.
7 22. In order to meet the increasing battlefield

battlefield demand for AEA capabilities, the Navy
8 increased the complement of five (5) to seven (7)

of each EA-18G Growler carrier squadron from five
9 aircraft per squadron, and will establish two (2) new squadrons. These increases have created
10
10 greater throughput need for training the aircrews who will meet those combat needs.
11
11 Therefore, the Navy also increased the EA-18 fiom 17
EA—l8 G Growler FRS from 17 to 27 aircraft, so that
12
12 aircrews can more quickly develop the skills necessary to graduate to enlarged EA-18G
EA- 18G
13
13 Growler squadrons.
14
14 23. FCLPs are a crucial component of
of the United States’ increased AEA capacity and
15
15 capabilities. Without the necessary skill sets created by repeated FCLPs, the Growler
16
16 electronic airborne attack aircrews needed by combatant commanders will not be able to
17
17 deploy to aircraft carriers in support of
of those missions. The highly refined
refined and technical work
18
18 that occurs at OLF Coupeville and Ault Field is critical life-saving work that is necessary to
19
19 fulfill
fulfill mission requirements.
20 24. After completing the Environmental Impact Statement process, the Navy selected
21
21 Alternative 2A to meet the increased need for AEA capability. The Navy projects that up to
22 29,600 FCLPs annually (utilizing both Ault Field and OLF Coupeville) will be needed to
23 provide EA-18G
EA— 18G Growler aircrews with the requisite skills. These operational numbers are not
24
25
ILLSTON
15 -
1 determined by the number of

of aircraft but rather by the number of flying out of
of aircrews flying of the
2 NAS Whidbey Island complex and their training requirements for skill maintenance and
3 certification
certification prior to deployment. An inability to conduct up to 29,600 annual FCLPs would
4 cause my wing squadrons to be unable to deploy safely trained aircrews to meet the Airborne
5 Electronic Attack capability needed by combatant commanders. Furthermore, restricting or
6 inhibiting
inhlbiting the ability of
of aircrews to conduct FCLPs at the right scheduled moment in the
7 training cycle of
of that particular squadron in preparation for a carrier deployment, will disrupt
8 the years-long pipeline of fleX1bi1ity to complete up to 29,600

of naval aviation training. Without flexibility
9 annual FCLPs, my naval aircrews cannot perfect the skills needed to perform the most difficult
difficult
10
10 maneuver in all of
of aviation at the very moment in their training cycle when those skills are
11
11 needed most. As a result, aircrew deployment would be impacted, with national security
12
12 implications.
13
13 25. Sending aviators, instructors and maintenance personnel to detachments to other
14
14 airfields fine ly-tuned process of
airfie 1ds to obtain FCLP training disrupts the finely-tuned of training naval aviators.
15
15 fiom the detachment is a drain on our budget, as we must pay for travel, lodging
Travel to and from
16
16 and per diem for the detachment personnel
personnel. It reduces the service life of
of the aircraft,
17
17 accelerating required maintenance. It also disrupts activity at NASWI, as FRS instructors,
18
18 LSOs and maintainers must travel to support the detachment and are therefore unavailable to
19
19 support ongoing training and maintenance demands for the Growler community. This
20 interrupts the training of

of the students who remain behind in the FRS and the maintenance cycle
21
21 fleet.
for the overall Growler fleet.
22 26. In conclusion, FCLPs are a crucial component of

of EA-18G Growler training, and
23 without them, the Navy cannot provide our

cannot provide our nation’s
nation’s combatant
combatant commanders
commanders with
with the Airborne
the Airborne
24
25
ILLSTON
16 -
Electronic Attack capabilities they need to succeed in combat. Each FCLP teaches naval
aviators to land on an aircraft carrier in a relatively safe environment, so that each one is fully
prepared to perform a carrier landing under the most dangerous and demanding circumstances
possible. Without the ability to conduct up to 29,600 annual FCLPs, the Navy’s Electronic
Attack Wing will be unable to meet our nation’s demand for combat-ready Airborne Electronic
Attack forces, imperiling our military forces and the achievement of their objectives around the
globe.
I hereby swear under penalty of perjury pursuant to 28 U.S.C. § 1746 that the foregoing
10 information is true and correct to the best of my knowledge.
11
12
13 53.1749
14 can Us“
15
16
17
18
19
20
21
22
23
24
25
FCLP DECLARATION - l7 -

55-3 Declaration of Eric P. Illston, Captain U.S. Navy

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55-3 Declaration of Eric P. Illston, Captain U.S. Navy

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Case 2:19-cv-01059-RAJ-JRC Document 55-3 Filed 03/16/20 Page 1 of 17

20 combatant commanders with more than just the technological capability of

22 provide my squadrons with realistic and effective

5 my wings as a Naval Aviator in 1999, ﬂying the EA-6B

7 Landing Signals Officer

23 ﬁrst formative months in Pensacola, Florida, learning basic

4 complete this phase, they move to an intermediate level of

7 which teach them how to make decisions in combat. If

9 ﬂying more advanced aircraft, continuing to hone their skills at faster

20 ﬂight training sessions known as Field Carrier Landing Practices (FCLPs).

4 complete advanced jet training, they receive

6 ﬂy. The FRS trains all new electronic attack aviators

8 non- ﬂying tours.

20 operate the EA-18G.

23 replacement aircrew is carrier qualification.

4 operate safely around the aircraft carrier at night.

5 6. The replacement aircrew must successfully

7 not permitted to focus on other types of

22 replace, the rigors of

1 8. Performing an arrested landing onboard a moving aircraft carrier is widely known to be

7 ﬂight instruments and training. FCLPs allow aircrew to

9 sea can be mitigated to an acceptable level.

20 organizations). For example, an FCLP must be performed close in time (within10

22 maneuver must peak just as they are needed.

5 ﬁeld), precisely touch its wheels on the correct spot of

6 power and take off

8 airspeed, altitude, and distance parameters. The FCLPs enhance

9 maneuver the aircraft to meet these demands.

20 aircraft from 350 knots (approximately 400 m.p.h.)

2 ﬁrst pass. This process is truly a team

6 avoid creating an airborne traffic jam. At sea, there is no divert airfield;

7 must land on the carrier, and an airborne traffic

9 oriented along a runway or ship's heading with one end of

20 ﬂy. Depending on aircraft configuration,

23 miles given changes in any one of

2 ﬂying that includes 180

3 integrated throttle movements, critical control of

7 the approach turn, we try to limit the number of

9 distance. All other aspects of

22 corridor and the intended point of

23 ﬁulty line up (left or right of

4 aircraft. The landing area itself

5 18G ﬂight position is approximately 44 feet. Travelling at 135

6 this leaves little room for error.

8 angle between the chord line of

20 a high pitch proﬁle

1 ﬁiling to stop. Lastly, as with lineup,

4 AOA and lined up on centerline. All of

5 for, and assessed within that last 15-18

6 Everything the aircrew did prior to this 15-18

7 management, approach turn

20 ﬂow with proper interval to attempt another landing. If

5 ﬂight deck by leaf

7 within roughly 2.5 seconds and less than 200 feet.

8 ﬁom the Final EIS provides a graphical representation of

9 Aircraft touches down on simulated carrier deck and

1 conducting day and night carrier landings in an EA-18

6 the landing pattern during the course of ﬂy an average of

8 ﬂying). During these sessions muscle memory and fine

23 ﬁom the ideal landing pattern.

1 an LSO on three combat deployments, I have waved off

2 preventing mishaps and saving lives. Once IIhad

5 climbing away from the water. That is just one example of

22 21. As the Commander of