Unofficial transcript: Day 3, Session 5
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Session 5 March 7, 2001 1:00 p.m.
AFTERNOON SESSION
CAPT MACDONALD: Please be seated.
Court is now in session.
VADM NATHMAN: Let the record
reflect that all members counsel and parties are
again present in addition to the court reporters.
Also I would like to remind everyone again that
please speak clearly and slowly into the microphone
so that our simultaneous interpretation will work.
Adm Griffiths, I would remind you again, sir,
that you are still under oath.
THE WITNESS: I understand.
EXAMINATION BY MR. GITTINS:
Q We were talking about the under-instruction
sonar technician before we broke, sir.
When the ship went from 150 feet to periscope
depth, the under-instruction sonar technician was
augmented at that point by a qualified sonar
technician; is that correct?
A I don't know.
Q You didn't know Mr. roads did you not, ST --
A -- Seaman Rhodes (phon.)?
Q Yes, sir.
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A Yes, I do. He was the under-instruction watch
there.
Q Yes, sir?
A Yes.
Q Did you interview the sonar chief or the sonar
supervisor?
A No.
Q That would be Petty Officer First Class
McGibney (phon.)?
A I did not personally interview them, but I
believe they were interviewed and I reviewed those
from Commodore Bias.
Q Did you ascertain that the under-instruction
sonar technician had been augmented by a qualified
sonar technician by the time the ship was at
periscope depth?
A I am willing to grant that I don't recall.
There were intermittent periods where he was
supervised by a qualified operative, and that could
have been one of them.
Q Were you able to determine how much of the time
he was supervised and not supervised?
A No. I was not.
Q Were you able to determine what the reasons
were that the advisory qualified watchstander was not
127
in sonar?
A Not to a degree where I consider it definitive
knowledge. I understand that he went to look for
reliefs for others in the sonar shack, such as the
supervisory, that he -- and other reasons that I am
not aware of.
Q But would those be appropriate things that
would be detected by the sonar supervisor given the
manning?
A If they were briefed, yes, he could say, go
quickly, get somebody, and then come back, yes, sir.
Q So, it would not be improper for these
qualified sonar technicians to be gone for short
periods of time during the course of this watch if
the sonar supervisor approved it?
A And it would also depend on circumstances, but
I can say there may be occasions when that would not
cause a problem.
Q That would be a judgment matter for the sonar
supervisor?
A Yes, which he would be subject to
accountability for.
Q Of course.
A But can I say, in general --
Q -- Yes, sir.
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A I think that it is a matter for this court to
determine further the degree to which the
under-instruction watch was supervised, and when.
Q Yes, sir.
A And I do not have good definitive knowledge on
the periods and the total length of time and the
fractional amount of time and how they relate to the
decisions that were made.
Q Just a general matter. Did you take notes of
the interviews that you conducted, sir?
A Yes.
Q What happened to those notes, those written
notes?
A I provided them to Commodore Bias and his staff
to use in creating the transcripts, and that's the
last that I know of them.
Q Thank you, sir. Sir, I'd like to take a
couple of minutes to talk about submarine Target
Motion Analysis techniques.
A All right.
Q You indicated during your direct testimony that
you believed that in Submarine Force Standard that a
TMA leg should be three to five minutes; is that
accurate?
A Yes.
129
Q That would be an accurate reflection of your
testimony?
A Yes.
Q Another name for TMA is Ekeland Ranging is that
accurate?
A Yes. That's a subset, really. It's not a
synonymous term. It's a subset of the other.
Q Are you aware that NWP 3-21.51.1 Revision A
states that, "Leg lengths greater than three minutes
do not significantly improve results in conducting
TMA?"
A No, I was not aware of that.
Q The NWP that I described -- that would be the
NWP that would govern the conduct of Target Motion
Analysis, would it not, sir?
A I will take your word for it, that was a
lengthy title.
Q Yes, sir. It would be a NWP that would cover
that issue, wouldn't it, sir?
A Yes.
Q And I would ask if that looks like it -- you
can't see it --
A Yes, that does look like a book I am familiar
with.
Q It's called, Target Motion Target Analysis TMA
130
Techniques.
VADM NATHMAN: May I ask you to
repeat that?
MR. GITTINS: NWP, 3-21.51.1,
Revision A. Submarine Target Motion Analysis paren
TMA clothes paren, Techniques.
THE WITNESS: I am assuming that
that quote that you provided is not taken out of
context.
Q Yes, sir.
A In other words, there are so many variables
that need to be evaluated when you determine the
length of a TMA leg, that you have to account for
those variables before you make the judgment three
minutes is all you need.
Q Yes, sir. Well, that's a note found in the
Ekelund Rating Section of the TMA Techniques Book.
What's the relationship between time on a
ranging leg, TMA leg, and signal-to-noise ratio, if
you know, sir?
A A general ratio would be, the higher the
signal-to-noise ratio, in other words, the stronger
the signal, the less time you would need to be
confident you have a good leg.
Q And in fact, the NWP that I just held up a
131
moment ago -- that indicates that depending on
signal-to-noise ratio a TMA leg of 1.0 (check number)
depending on whether or not it's a positive zero or
negative signal-to-noise ratio, would that be
accurate, sir?
A It may be an accurate quote.
I said it may be an accurate quote, but I
would like a chance to use my judgment and experience
to address the issue in a little broader sense.
Q Well --
A If you want to give me the opportunity.
Q I think I will, sir, but let me ask a couple
more questions, and if I haven't give you that
opportunity in those questions, I'll be glad to let
you do that.
In a high signal-to-noise ratio target, for a
positive, when you have a positive signal-to-noise
ratio, that means it's a louder contact, would you
agree with that, the target is easier to hear?
A Yes.
Q You are able to attain a more accurate bearing
on shorter leg, would you agree with that, sir?
A Yes.
Q And the purpose of doing a TMA is to obtain an
accurate bearing to the target, correct?
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A No.
Q What is it then, sir?
A It's to obtain a number of accurate bearings
over time, which devolves into a bearing rate -- rate
of change of bearing with time. That is the more
important parameter than the bearing itself.
Q Taking a series of bearings that provide you
with the information?
A Correct.
Q In this case, the two-minute leg and the
three-minute leg provided a solution to Sierra 13,
did it not?
A You can say that it provided a number of
solutions, because you can see that the ranges that
the fire control technician of the watch was
inserting into the machine, into the fire control
system, was variable over that time frame. But it
was providing potential solutions, yes.
Q In fact, it was a computed solution at time --
well, let me get the slides up.
That is a solution for S13, is it not, sir?
A All of those --
Q -- The system solution?
A Those are the ranges associated with system
solutions, yes.
133
Q That would indicate that the fire control
technician at time about 13:14 computed -- hit the
button, and created a system solution for Target 13,
is that correct?
A Yes.
Q So that would indicate that at 13:14, according
to slogger data, the information derived from the
legs that had been done provided sufficient
information to compute a system solution for the
Target S13, correct?
A Yes. Well, you can make the same case for all
the earlier dots, too, and all the later dots, too,
in the sense that you are using a system solution as
as opposed to to the system solution that would be
truth, or not the system solution, but the real
solution.
Q Well, this solution, 15,000 yards, at time
13:14, doesn't indicate closing. It's a flip -- a
flip course, is that accurate, sir?
A I believe it was, yes.
Q That's a flip course, but it is an accurate
system solution at time 13:14 at the appropriate
range for the reconstruction of the Ehime Maru,
correct, sir?
A It turns out that's close to the actual range
134
-- that particular choice of solution at that time in
the fire control system was close to the actual range
-- not the actual necessarily course or speed, but
range.
Q Right. It has a flip course.
Do you know what the speed was on that, sir?
A My recollection is that the course was also in
error as well as being in the wrong direction, and so
therefore, the speed compensated for that course
error. I think it was a broader course at a slower
speed than reality.
So, if you will, it was compensating for more
speed across the line of sight to the Greenville with
a reduction in the target speed so that it was the
right bearing rate.
And of course, it was the opening Greenville
solution, not the closing Greenville solution.
Q Okay, sir. This represents an opening solution
which would have been in error at about 13:14?
A Well, the range would have been close, but the
other parameters would have been in error.
Q From slogger, Greenville at 650 feet at the
time this system solution is entered -- 13:14:02 --
does that sound about right, sir?
A Conducting the angles -- well, it was just
135
about to conduct angles at 13:16.
So 650 feet is very possible.
Q Yes, sir. And the system solution was course
024, Speed 11. From slogger, does that sound about
right?
A I will take your word for it. It was logging
solutions in the log, and it's all tabular data, so I
don't have it committed to memory but --
Q Well, this solution is the only solution,
system solution, computed to S13 in the time between
13:14 and just before the collision, correct, sir?
A I don't know if that is correct or not.
I'd have to review it.
Q What would you review, that would assist you,
sir?
A I would need to review the system fire control
solutions for times 13:14 until just before the
collision as printed out on slogger data which would
probably be pages and pages of printouts.
But the issue I will grant you is that the
system solution was a very consistent range of around
fifteen thousand yards for several minutes here.
And the question is -- there is only one moment
in time where it really is the range. Prior to that
it's closer than the real range, and after that, it's
136
farther than the real range -- so you know, they were
passing in the night, the real truth, and the system
solutions passed in the night here, but the range in
general was consistent for a long period of time in
the fire control system for a relatively long period
-- 13:14 until 13:40 or so, approximately -- 13:35
maybe. It was generally not changing very much.
And I would say that's because they may have
had a period where they didn't have any good data to
update this solution and make it better.
Q From your investigation you learned that
commanding officer walked through sonar at about
13:15, correct, sir?
A I know he went into sonar while they were
preparing to be their Target Motion Analysis to go to
periscope depth and that would have been at about
13:30 or later -- a little later than 13:30.
So the time prior to doing the angles -- is
that what the question was?
Q At about 13:15, the captain went from his state
room through sonar into the control room, isn't that
true, sir?
A That's very likely. I don't know.
But that would have been down in here prior to
the high speed -- just prior to commencing high speed
137
angles and the high speed turns, so fairly early in
this hour before the collision. But it is possible
even through sonar data.
Q And the point here is that this flat line
indicates not a closing target, correct, sir?
A That would be what the fire control system more
than the sonar system would be displaying, that would
be in the control room that would be displaying
that.
Q In the control room would be displayed a system
solution that indicated an opening target, one that
is not closing, correct, sir?
A Yes, yes.
Q Sir, between 13:14 when the system solution is
-- the button is hit that's what makes this line
right sir -- the fire control technician hits a
button, enter?
A Correct.
Q And when he hits the button, do you know what
happened between this time and the next time he hits
the button which gives the 4,000 yard solution?
Do you know what the fire control technician
was doing?
A Well, let's see. He would be doing his routine
assignment from 13:14 until just prior to that
138
collision, which would be trying to manage obtaining
parameters on all the targets that sonar was
providing him information on, and refining those
solutions, plus maintaining the CEP plot and
Responding to any other orders from the officer of
the deck or the captain.
Q The exhibits that you've brought to court, to
this court, only indicate what was happening with
Sierra 13, correct, sir?
A Correct.
MR. GITTINS: Petty Officer Levitt,
what Exhibit Number is that?
PO LEVITT: That would be Exhibit
22.
VADM NATHMAN: Thank you.
MR. GITTINS: I apologize to the
court, because I don't have a large viewer or
viewgraph. We don't have the budget the Navy has.
Q (By Mr. Gittins) I am going to hand you
Exhibit 22. Sir, the Exhibit 22 -- at about time
13:32, is when there is that bearing rate that you
were talking about -- the 6 degree bearing rate -- is
that correct, sir?
A Yes, it appears that's correct.
Q And that's represented right here on the
139
exhibit, the second page, right before the time
13:32?
A Should I be looking at the second page now?
Q The first page.
A The first page, okay.
Q Time, 13:32, the left side.
A Okay, I'm with you.
Q The bearing rate that you discussed, and you've
brought an exhibit to describe that -- Exhibit 7.
That happens at about 13:32, correct, sir?
A A little bit later than that, 13:32 and-a-half
-- yes. Short answer, yes.
Q And this is a much larger view than would be
provided to the fire control technician, would you
agree with that, sir?
A You mean the size of this --
Q It was taken and wildly expanded, correct?
A Yes.
Q That is not the view that the fire control
technician would see?
A No.
Q More like what you have in front of you on
Exhibit 22, is that correct?
A Yes, it's closer to this than to that.
Q Yes, sir.
140
VADM NATHMAN: Specifically to the
one on the left?
MR. GITTINS: On the wall, Exhibit
Number 8. I'll try to be more direct as to what
we're talking about.
Q (By Mr. Gittins) Right after that, on Exhibit
22 in Exhibit 7 in this 6 degree bearing rate, it
begins the baffle turn, is that correct?
A Yes, to Course 120, turning to the right to 120
from 340.
Q In fact, it's the baffle turn that generates
this bearing rate, correct?
A No, this should be a period when the ship is
not changing course, between the blue lines, the ship
is steady on course. The blue is the actual turning
and then beyond the blue is where it's steady again.
So this period right in here is at least on
this chart trying to indicate where there is a turn
in progress.
Q Yes, sir. And I'm sorry, sir, it was my lack
of technical expertise.
The turn happens here, just before 13:32 in
blue on Exhibit 8, correct, sir?
A Correct.
Q And once the turn is made, that turn is what
141
generated the bearing rate, correct, sir?
A Yes, and the orientation and speed through the
water to contacts.
Q And also, at about the time that they steadied
up on the new course, the Greenville steadied up on a
new course, on Exhibit 22, contact Sierra 14 is for
the first time identified by sonar, correct, sir?
A It appears so on this.
Q What would happen, based on your knowledge and
experience, sir, when sonar receives this piece of
information -- and the fire control technician
receives this piece of data?
A When Sierra 14 is first detected?
Q Yes.
A The sonar operator will tell the supervisor who
would then assign a tracker to it to give information
to fire control electronically if it's a strong
enough signal, and it appears it was. And so that is
called Automatic Tracker Follower, ATF, so it's going
to -- automatically going to take note of it in the
system. The supervisor would use the announcing
system to tell the officer of the deck he has a new
contact -- its nomenclature, its bearing, and if he
has a classification already by nature of sound, he
would add that in, sounds like a surface vessel or
142
something like that.
And then the fire control technician of the
watch would commence developing a solution as the
data develops on his fire control system.
Q So at the time -- at around the time that this
6 degree-per-minute rate should have been identified
according to your testimony?
A Mm-mm mm.
Q The overall tactical picture is complicated by
a new contact, isn't is that true, sir?
A Yes.
Q And in fact, in your interviews with the fire
control technician of the watch, he indicated that of
the two targets here, 14 was the target of interest
before the collision; isn't that true, sir?
A I don't know what you mean by the "target of
interest." It was a target of interest.
Q His interview notes indicate, in fact, that it
was the target of interest that he was working, isn't
that true, sir?
A He may have physically been working focusing on
that particular target to develop a solution at that
moment. Is that what you're asking?
Q Yes, sir.
A Possibly. I don't recall, but that would be
143
logical. If your point is that he had just had a new
contact while we're in this Right 6 bearing range,
and the other contact was distracting him as he was
developing a solution, I would say that's all true.
Q What I've produced to the court from slogger
data is information from the fire control technicians
console recorded in slogger for times 13:14:O2,
13:34:03, 13:34:48, 3503, 13:33:48.
Have you reviewed this data prior to your
giving your testimony two days ago, sir?
A No, not the Sierra 14 data.
Q It appears that just about a minute before the
collision the fire control technician is working the
Sierra 14 contact, correct, sir?
A Well, from what you've just given me here he's
working on Sierra 13 at about six minutes before the
collision, on. That's what this would say.
I don't know if there is other data that fills
in the blanks that says switches back to 14.
That is possible.
Q This data here on Exhibit 7 that is the system
update for 13:37:48 correct, sir?
A The one on the left there, I would say is.
Q Yes, sir. And according to slogger, the ship
was coming to periscope depth according to the
144
right-hand column of the exhibit, correct, sir?
A Correct.
Q And at that time that would have been a time
when the control room was supposed to be quiet,
correct, sir?
A Yes. I think it's -- from the data that I've
seen here, and of course it's discrete, it's not
continuous, so these are examples, and there may be
strings that I would determine from further lines of
data on either side of these times, but from what
you've show me here it says 0H (phon.) 4,000 yards
inserted into the system while the ship was coming up
to periscope depth and that would be a time that he
wouldn't expect anybody to say anything until you
hear "emergency deep."
Now once you're at periscope depth, and you've
heard no close contacts, at that point, this key
information that we've got a new range that is
weighed in on this contact, Sierra 13, from what I've
previously thought, is real pertinent at that point
to be brought up.
Q Exactly, sir.
But what Exhibit 23 indicates is solutions
where we have a button that is hit on the console,
sir, the only time the button is hit between 13:34,
145
so you would agree with me, would you not, that you
can't really interpolate between -- you would only
have the operator's testimony regarding what he may
have done between obtaining solutions, correct, sir?
A I am not sure that is correct. Here is why.
If you look at the data here, it's not
continuous, but there are discrete changes in it.
And I would think the operator would have needed to
have created those changes. So for example, to go
from here down in range from here, I would have
thought the operator would have entered something --
maybe I am wrong and that needs to be resolved
technically, but I think there are going to be more
than just one entry in this period by the operator
between 13:14 and this range. I think you'll see
this requires an operator action. When he rings it
back up it requires an operator action. So I see
four or five or six times he should have hit the
enter button in this region here.
Q This will be -- slogger data is going to be
testified about by Captain Kyle?
A Captain Kyle, yes.
Q So he would be informed as to what this data
actually shows, correct, sir?
A He would be a better source of information on
146
that than I would.
Q You would agree with me, though, that there was
more going on here on Exhibit 7 than just contacts
Sierra 13 just prior to this accident, correct, sir?
A I certainly would. And that makes it more
complicated for the OD and the captain, the fire
control technician of the watch.
Of course, that's what we pay them to do -- is
to manage those additional inputs in the time that
they have to do so. But it is a timesharing, they
have to put time into developing one solution and
then another, and they do have displays that show the
current displays on all of them simultaneously. But
that's only as good as, they can update them. The
captain knows that, the OD knows that, the geographic
display that shows all the contacts isn't true, but
it's the best the fire control technician has been
able to create at that moment. And I think all of
that, if I may add, argues for putting more time in,
if the FT of the watch is trying to manage more than
one contact and needs more time, then he should be
given more time.
Q But there is no indication that any
information about Sierra 13 was being --
A Do you mean 14 or 13?
147
Q I believe I am sure, in fact, sonar would have
reported a new contact -- 14?
Q I am speaking of the fire control technician,
sir.
A No, I don't think the fire control technician
of the watch was very communicative in that period at
all in this period. That's one of the issues that I
have. But the captain and the OD were able to --
periodically able to look at the fire control system
if they chose to, and they could glance at this
without verbal communications and I have no way of
determining how often they looked.
And again, testimony from them would be helpful
in knowing all that, because they can know all of
this without any verbal communications by just going
over and observing.
THE WITNESS: Mr. Gittins, are you
going to refer to this further?
MR. GITTINS: I am not, sir.
Q (By Mr. Gittins) Sir, I am showing you
Exhibit 24. Exhibit 24, just for illustration
purposes, would be closer to what the fire control
technician of the watch would see on his -- rather
than Exhibit 8?
A Possibly. It depends on the scale he's
148
adjusted the screen to show, and that's one of the
skill issues here, is if your contacts are in one
sector of the circle around the ship, you don't show
the whole scale because you can't get as accurate a
bearing rate from these expanded views, so you change
the scale to focus in more closely on this, and so
what he may have been really looking at on the ship
at that moment would have been much more -- shown
much more resolution than these dots on this sheet of
paper. But had he not gone to that level of
refinement, and I would call that an issue of
experience and skill to make that change in scale.
This would be kind of the worst case scale that he
could have chosen for the context he thought he had.
Q But that would be -- it's about the size of the
cathode rate and that would display all three
contacts, correct, sir?
A Yes. But so would a much more refined scale
display all of these three contacts. And a typical
FT would quickly adjust that scale so he could get
better information to the OD.
Q And in particular, for Sierra 13, when he was
trying to stack the dots, correct, sir?
A For all three of them, sure, Sierra 13
included.
149
Q What does "stack the dots" mean?
A Actually, that is a different display than this
display. This display allows you to put a cursor,
let's assume that this was closer to -- I am looking
up now at this chart on the wall -- let's assume that
the display he chose gave more of a sense a slope to
the curve than this one on paper does, he would place
a cursor to be coincident with that slope, and then
at the end of the cursor on the screen, you would
read bearing rate 6 degrees right per minute, and he
would use that as one of the input to match to an
additional display. We don't have a picture of it,
but it would be the console just aft of this one --
that was just after this one --
Q Yes, sir.
A -- in the control room. And it's got a what
we call a mate, M-A-T-E, display, which is a display
where you do try to conduct a process called
"stacking the dots." And that's what gives you the
course, the speed, and the range of the contact in a
way that is consistent with the bearing history
generated by sonar.
Q Yes, sir. When you said "the console just aft
of this one" you were referring to Exhibit 24,
correct, sir, in the Exhibit 8 in your hand?
150
A Yes. Just aft of the one this one would be
on.
Q Exhibit 24 in the record?
A Sure. It would be on the console after the
Exhibit 24 console.
Q So this process is somewhat complex to begin
with, for one contact, correct, sir? You have to
deal with a number of different things to compute a
solution?
A It takes skill, and it takes time.
Q And it can be complicated by the -- by the
existence of another target or another contact that
appears in the middle of that process, correct?
A Each new contact adds to the burden, and the
investment in time per individual contact to develop
parameters of value to the OD and the captain. Each
new contact makes it a little bit harder and requires
a little bit more time. So each time you get a new
contact, you kind of buy into needing to spend more
time.
Q And about the time that the bearing rate
increased, as you described in your testimony on
Exhibit 8, that's when a new contact was presented to
the fire control technician of the watch in this
case, correct, sir?
151
A Correct. And that could have been one of the
reasons the ship did not note that right bearing
rate. I am sure there were reasons, and that could
well be one of them. It's -- you know, that would
have been a very important thing to know -- you had a
right 6 bearing rate contact here.
The ship, for whatever reason, didn't know that
perhaps. The reason you've just brought up is one of
the contributing reasons.
Q Yes, sir.
(End Session 5 at 2:45 p.m.)
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