Q. Did you play any part in the attack on Rotterdam?

A. As Air Force Chief 2, to which rank I had been promoted, I led on the right flank the attack on Holland, Belgium and France, and the Airborne Corps operated under my command also. The Airborne Corps was commanded by General Student, who asked for his Paratroops to be supported by a bomber attack. General Student had such a comprehensive knowledge of the ground situation that he alone must be considered responsible for preparation and execution of the attack. The Fourth Air Corps was ordered to provide air support, and one group, the smallest unit necessary for this purpose, was employed. The attack was carried out solely in accordance with the tactical requirements and technical possibilities. The orders of General Student reached my command very early. Thus all preparations could be made leisurely according to plan. At the instance of the Reich Marshal the troops were informed of possible changes within Rotterdam and of the approach of Panzer Divisions. The objective set by General Student was quite clear as to extent, central and key points, and occupation. It was not difficult for seasoned troops to grasp the objective. There was radio communication between General Student's command, my staff and other staffs, including C.-in-C. of the Air Force. Any interruption of this communication could only have been a very short one as radio orders were transmitted by me or the Reich Marshal. The technique at that time made it possible to maintain contact, through this radio communication, between the tactical ground station and the flying unit via its ground station. The ground communications usual at that time, such as flares, and signal code designations, were maintained at the front according to plan. They functioned without hitch. In accordance with its training and its orders, the formation had sent out a reconnaissance aircraft which kept them informed of the position and the objective. In addition, by order of the Reich Marshal, there followed a General Staff officer attached to my air fleet who had the same mission.

Q. Had the order been given that the situation and the objective ...

A. I myself never had any doubt that the attack had to be carried out, only I was not quite sure whether or not it should be repeated. This was the question to which the signals referred. Judging from my knowledge of General Student and - I stress this particularly - his technique in leading an attack and his clearly stated requirements, I had to expect the attack to be carried out.

The attack was carried out according to plan and time schedule. The report that the target had been accurately bombed came through very quickly together with the message that no further attacks were necessary. During the three days of fighting in Holland the C.-in-C. of the Air Force was kept well informed. Particularly on the third day, i.e., the day I am talking of, the Reich Marshal in his outspoken manner intervened more than usual in the direction of the air fleet and did, in my opinion, everything that could possibly be done from such a leading position. I do not remember any message to the effect that the bomber attack was no longer warranted by the tactical situation.

Q. Bombs are said to have been dropped when negotiations about capitulation had already started.

A. As I said, no message to this effect had been received by the Command, neither had the formation operating over Rotterdam picked up a message from the ground. It may be that some confusion occurred at the Command in Rotterdam itself. I do not know about the agreements reached between General Student and the officer commanding the Dutch troops in Rotterdam. I wanted later to talk with General Student on this question but this was not possible because of his having received a serious brain injury. If (though I am convinced such was not the case) the attack was not warranted by the situation, it was most regrettable. As a soldier of 42 years' standing, as an artillery man, as an airman, as a General Staff officer and as a leader for many years, I wish to make it clear that this was one of those unforeseeable accidents of war which, I am sorry to say, occur in the Armed Services of all countries more frequently than one might think, though the outside world does not know this to be the case.

Q. How do you explain the big fires that kept breaking out in Rotterdam?

A. When I received the report from the formation I was very pleasantly surprised to learn that the effect of the bombing was confined to the target area, but this war has shown that most of the destruction is not caused by the bombs themselves, but by the spreading of fires. Unfortunately, a bomb had hit a margarine or some other factory in Rotterdam, causing oil to run out and the fire to spread. As, after the attack, the capitulation was already effective, it should have been possible to prevent the fires from spreading by bringing in the fire services and the troops.

Q. What were the military consequences of this attack?

A. The immediate consequences of the attack was the surrender of the Rotterdam troops. General Wenninger, who was Air Chief at the time and who later on was attached to my air fleet, told me that in consequence of this attack the whole of the Dutch Army capitulated.

Q. Did you lead the attack on Coventry in November, 1940?

A. As Chief of Air Fleet 2 I took part in this attack. I cannot say now whether Air Fleet 3 took part in it as well, but I did.

Q. What was the object of this attack?

A. According to the target index kept by the archives department of the C.-in-C. of the Air Force, Coventry was an English armament centre: it was known as "Little Essen." This index was compiled with meticulous care by experts, engineers and officers, and contained charts, photographs, description of targets, key points, etc. I myself, as well as my men, were fully familiar with these details. Furthermore, I arranged for the above-mentioned General Wenninger and several engineers with the C.-in-C. of the Air Force to give lectures to the troops about targets, in order to make them acquainted with the nature of the targets, their vulnerability and the effects of an air attack. Preparations for an attack were made most conscientiously. I was very often present and the Reich Marshal himself occasionally inspected them. The case of Coventry was extremely simple as, in those November nights, favourable weather conditions prevailed, so that Coventry could be reached without radio navigation. The distribution of the objectives in Coventry was likewise very simple, so that bombs could be dropped without the help of flares, and it was hardly possible to miss the target. But bombs follow the same law as other explosives - in other words, in land and air warfare the dispersion covers a wide range. So with air attack, if strong formations are employed, not the individual target but only the target area as a whole can be aimed at, which naturally causes a deviation from the target itself. By order of the C.-in-C. of the Air Force and on the reconnaissance pilot's own initiative, the photographs showing the hits were checked the following day. The ground visibility was good but, as I already said in the case of Rotterdam, the destruction of the objective was not caused so much by the bombs themselves as by the spreading of fire. I do not know whether I should add anything further. The Hague Convention on land warfare did not provide for the requirements of air warfare. In order to avoid an arbitrary selection of targets the Supreme Command had to go into the question and issue general directives based on the preamble to The Hague Convention, the literature published in the meantime and, finally, the special conditions governing air operations. Only those targets which we considered admissible according to International Law were assigned to the air fleet or formation. This did not exclude the reconsideration and change of targets in individual cases, which were discussed with the C.-in-C. of the Air Force, and we took the responsibility...

THE PRESIDENT: You are speaking too fast.

A. By personal visits and other methods we impressed upon our formations the need to study and apply carefully the preparatory work, the aiming and the meteorological conditions, so that the highest degree of accuracy could be obtained. The case of Coventry was particularly fortunate, as it presents an important military target, so that one could not speak of an attack directed against the civilian population.